Annual Financial Report 2024
BANK OF CYPRUS HOLDINGS GROUP
Annual Financial Report 2024
Annual Financial Report
for the year ended 31 December 2024
Contents
Board of Directors and Executives 1
Forward Looking Statements and Notes 2
Directors' Report of Bank of Cyprus Holdings Public Limited Company 3
Risk and Capital Management Report 41
Sustainability Statement 77
Independent Practitioners’ Limited Assurance Report on Bank of Cyprus Holdings Public Limited Company’s consolidated
Sustainability Statement 255
Annual Corporate Governance Report 259
Independent Auditor’s Report to the Members of Bank of Cyprus Holdings Public Limited Company on the Consolidated
Financial Statements and the Company Financial Statements 360
Consolidated Financial Statements of Bank of Cyprus Holdings Public Limited Company 372
Financial Statements of Bank of Cyprus Holdings Public Limited Company 562
Alternative Performance Measures Disclosures 582
Additional Information – EU Taxonomy Disclosure Tables 599
Page
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Board of Directors and Executives
as at 26 March 2025
Board of Directors of Bank of Cyprus
Holdings Public Limited Company
Efstratios-Georgios Arapoglou
CHAIRMAN
Lyn Grobler
VICE-CHAIRPERSON
Panicos Nicolaou
Eliza Livadiotou
Monique Eugenie Hemerijck
Adrian John Lewis
Christian Philipp Hansmeyer
William Stuart Birrell
Executive Committee
Panicos Nicolaou
CHIEF EXECUTIVE OFFICER
Dr. Charis Pouangare
DEPUTY CHIEF EXECUTIVE OFFICER & CHIEF OF BUSINESS
Eliza Livadiotou
EXECUTIVE DIRECTOR FINANCE
Demetris Th. Demetriou
CHIEF RISK OFFICER
Irene Gregoriou Pavlidi
EXECUTIVE DIRECTOR PEOPLE & CHANGE
George Kousis
EXECUTIVE DIRECTOR TECHNOLOGY & OPERATIONS
Company Secretary
Katia Santis
Legal Advisers as to matters of Irish
Law
Arthur Cox
Legal Advisers as to matters of
English and US Law
Sidley Austin LLP
Legal Advisers as to matters of
Cypriot Law
Chryssafinis & Polyviou LLC
Legal Advisers as to matters of Greek
Law
Potamitis Vekris
Independent Statutory Auditors
PricewaterhouseCoopers
Chartered Accountants and Statutory Audit Firm
One Spencer Dock
North Wall Quay
Dublin 1
D01 X9R7
Ireland
Registered Office
10 Earlsfort Terrace
Dublin 2
D02 T380
Ireland
1
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Forward Looking Statements and Notes
This document contains certain forward-looking statements which can usually be identified by terms used
such as 'expect', 'should be', 'will be' and similar expressions or variations thereof or their negative
variations, but their absence does not mean that a statement is not forward-looking. Examples of forward-
looking statements include, but are not limited to, statements relating to the Bank of Cyprus Holdings
Group's (the 'Group') near term and longer term future capital requirements and ratios, intentions, beliefs
or current expectations and projections about the Group’s future results of operations, financial condition,
the level of the Group’s assets, liquidity, performance, return of tangible equity, projected levels of growth,
capital distributions (including policy on dividends and share buybacks) prospects, anticipated growth,
provisions, impairments, business strategies and opportunities, any commitments and targets (including
environmental, social and governance (ESG) commitments and targets). By their nature, forward-looking
statements involve risk and uncertainty because they relate to events, and depend upon circumstances,
that will or may occur in the future. Factors that could cause actual business, strategy and/or results to
differ materially from the plans, objectives, expectations, estimates and intentions expressed in such
forward-looking statements made by the Group include, but are not limited to: general economic and
political conditions in Cyprus and other European Union (EU) Member States, interest rate and foreign
exchange rate fluctuations, legislative, fiscal and regulatory developments and information technology,
litigation and other operational risks, adverse market conditions, the impact of outbreaks, epidemics or
pandemics, and geopolitical developments as well as uncertainty over the scope of actions that may be
required by us, governments and other to achieve goals relating to climate, environmental and social
matters, as well as the evolving nature of underlying science and industry and governmental standards and
regulations. This creates significantly greater uncertainty about forward-looking statements. Should any one
or more of these or other factors materialise, or should any underlying assumptions prove to be incorrect,
the actual results or events could differ materially from those currently being anticipated as reflected in
such forward-looking statements. Further, forward-looking statements may be affected by changes in
reporting frameworks and accounting standards, including practices with regard to the interpretation and
application thereof and emerging and developing ESG reporting standards. The forward-looking statements
made in this document are only applicable as at the date of publication of this document. Except as required
by any applicable law or regulation, the Group expressly disclaims any obligation or undertaking to release
publicly any updates or revisions to any forward-looking statement contained in this document to reflect any
change in the Group’s expectations or any change in events, conditions or circumstances on which any
statement is based.
Non-IFRS performance measures
Bank of Cyprus Holdings Public Limited Company's (the Company) management believes that the non-IFRS
Accounting Standards performance measures included in this document provide valuable information to the
readers of the Annual Financial Report as they enable the readers to identify a more consistent basis for
comparing the Group’s performance between financial periods and provide more detail concerning the
elements of performance which management are directly able to influence or are relevant for an
assessment of the Group. They also reflect an important aspect of the way in which the operating targets
are defined and performance is monitored by the Group’s management. However, any non-IFRS Accounting
Standards performance measures in this document are not a substitute for IFRS Accounting Standards
measures and readers should consider the IFRS Accounting Standards measures as the key measures of the
31 December position. Refer to ‘Alternative Performance Measures Disclosures’ on pages 582 to 598 of the
Annual Financial Report for the year ended 31 December 2024 for further information and calculations of
non-IFRS Accounting Standards performance measures included throughout this document and their
reconciliation to the most directly comparable IFRS Accounting Standards measures included in the
Consolidated Financial Statements.
The Annual Financial Report for the year ended 31 December 2024 is available on the Group’s website
www.bankofcyprus.com (Group/Investor Relations) (the Group's website).
The Annual Financial Report 2024 is originally issued in English. The Greek translation of the Annual
Financial Report 2024 will be available on the Group’s website by 4 April 2025. In case of a difference or
inconsistency between the English document and the Greek document, the English document prevails.
2
DIRECTORS’ REPORT
FOR THE YEAR
2024
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
4
The Board of Directors submits to the shareholders of Bank of Cyprus Holdings Public Limited Company (the
‘Company’) their Directors’ Report together with the audited Consolidated Financial Statements (‘Consolidated
Financial Statements’) and Financial Statements of the Company for the year ended 31 December 2024.
The Annual Financial Report relates to the Company and together with its subsidiaries the Group, which was listed
on the Main Market of the Regulated Securities Market of the Athens Stock Exchange (‘ATHEX’) and the Cyprus
Stock Exchange (‘CSE’) as at 31 December 2024.
Activities
The Company is the holding company of the Group and of Bank of Cyprus Public Company Ltd (‘BOC PCL’ or the
‘Bank’). The principal activities of BOC PCL and its subsidiary companies involve the provision of banking,
financial, and insurance services and the management and disposal of property predominately acquired in
exchange of debt.
All Group companies and branches are set out in Note 50 to the Consolidated Financial Statements. The Group
has established branches in Greece. There were no acquisitions of subsidiaries and no material disposals of
subsidiaries during the year ended 31 December 2024. Information on Group companies and acquisitions and
disposals during the year are detailed in Note 50 to the Consolidated Financial Statements.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
5
Group financial results on the underlying basis
Commentary on underlying basis
The financial information presented in this section provides an overview of the Group financial results for the year
ended 31 December 2024 on the ‘underlying basis’, which management believes best fits the true measurement
of the performance and position of the Group, as this presents separately any non-recurring items and also
includes certain reclassifications of items, other than non-recurring items, which are done for presentational
purposes under the underlying basis for aligning their presentation with items of a similar nature.
Reconciliations between the statutory basis and the underlying basis to facilitate the comparability of the
underlying basis to the statutory information, are included in section ‘Reconciliation of the Consolidated Income
Statement for the year ended 31 December 2024 between the statutory basis and the underlying basis’ and
‘Alternative Performance Measures Disclosures’ of the Annual Financial Report 2024.
The main financial highlights for the year ended 31 December 2024 are set out below:
Consolidated Income Statement on the underlying basis
million 2024
1
2023
1
Net interest income 822
792
Net fee and commission income 177
181
Net foreign exchange gains and net gains/(losses) on financial instruments 36
37
Net insurance result 46
54
Net
(losses)
/
gains
from revaluation and disposal of investment properties and
on disposal of stock of property
(1)
10
Other income 14
18
Total income 1,094
1,092
Staff costs (203)
(192)
Other operating expenses (164)
(149)
Special levy on deposits and other levies/contributions (39)
(43)
Total expenses (406)
(384)
Operating profit 688
708
Loan credit losses (30)
(63)
Impairments of other financial and non-financial assets (56)
(53)
Provisions for pending litigation,
claims,
regulatory and other
matters (net
of reversals)
(12)
(28)
Total loan credit losses, impairments and provisions (98)
(144)
Profit before tax and non-recurring items 590
564
Tax (81)
(73)
Profit attributable to non-controlling interests (1)
(2)
Profit after tax and
before non
-
recurring items (attributable to the
owners of the Company)
508
489
Advisory and other transformation costs - organic -
(2)
Profit after tax (attributable to the owners of the Company) 508
487
1. The financial information is derived from and should be read in conjunction with the accompanied Consolidated Financial
Statements.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
6
Group financial results on the underlying basis (continued)
Consolidated Income Statement on the underlying basis (continued)
Key Performance Ratios 2024 2023
Net interest margin 3.53%
3.41%
Net interest margin excluding TLTRO III 3.60%
3.74%
Cost to income ratio 37%
35%
Cost to income ratio excluding
special levy on deposits and other
levies/contributions
34%
31%
Operating profit return on average assets 2.7%
2.7%
Basic earnings per share attributable to the owners of the Company ()
1
1.14
1.09
Return on tangible equity (ROTE) 21.4%
24.8%
Return on tangible equity (ROTE) on 15% CET1 ratio
2
27.6%
27.4%
Tangible book value per share
3
() 5.77
4.93
Tangible book value per share excluding the cash dividend () 5.29
4.68
1. The diluted earnings per share attributable to the owners of the Company as at 31 December 2024 amounted to 1.14.
2. Calculated as Profit/(loss) after tax (attributable to the owners of the Company), divided by the quarterly average of Shareholders’
equity minus intangible assets and after deducting the excess CET1 capital on a 15% CET1 ratio from the tangible shareholders’
equity and the amount approved/recommended for distribution in respect of earnings of the relevant year the distribution relates
to.
3. Tangible book value per share is calculated based on number of shares in issue at the end of the period, excluding treasury shares.
Consolidated Balance Sheet on the underlying basis
million 2024
1
2023
1
Cash and balances with central banks 7,601
9,615
Loans and advances to banks 821
385
Reverse repurchase agreements 1,010
403
Debt securities, treasury bills and equity investments 4,358
3,695
Net loans and advances to customers 10,114
9,822
Stock of property 649
826
Investment properties 36
62
Other assets 1,872
1,821
Non-current assets and disposal groups held for sale 23
-
Total assets 26,484
26,629
Deposits by banks 364
472
Funding from central banks -
2,044
Customer deposits 20,519
19,337
Debt securities in issue 989
672
Subordinated liabilities 307
307
Other liabilities 1,475
1,309
Total liabilities 23,654
24,141
Shareholders’ equity 2,590
2,247
Other equity instruments 220
220
Total equity excluding non-controlling interests 2,810
2,467
Non-controlling interests 20
21
Total equity 2,830
2,488
Total liabilities and equity 26,484
26,629
1. The financial information is derived from and should be read in conjunction with the accompanied Consolidated Financial
Statements.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
7
Group financial results on the underlying basis (continued)
Consolidated Balance Sheet on the underlying basis (continued)
Key Balance Sheet figures and ratios
202
4
Pro forma
1
2024 2023
Gross loans ( million) 10,320
10,374
10,070
Allowance for expected loan credit losses ( million) 223
254
267
Customer deposits ( million) 20,519
20,519
19,337
Loans to deposits ratio (net) 49%
49%
51%
NPE ratio 1.9%
2.5%
3.6%
NPE coverage ratio 111%
100%
73%
Leverage ratio 10.4%
10.4%
9.1%
Capital ratios and risk weighted assets
2024
(Regulatory)
2
2023
(Regulatory)
3
Common Equity Tier 1 (CET1) ratio (transitional) 19.2%
17.4%
Total capital ratio (transitional) 24.0%
22.4%
Risk weighted assets (RWAs) ( million) 10,834
10,341
1. References to pro forma figures as at 31 December 2024 refer to the agreement for the sale of two non-performing loan portfolios, which
is expected to be completed in the first half of 2025 subject to necessary approvals. The portfolios are classified as non-current assets
held for sale with a net book value of 23 million as at 31 December 2024. Numbers on a pro forma basis are based on 31 December
2024 underlying basis figures and assume completion of the sale.
2. Includes profits for the year ended 31 December 2024 net of distribution at 50% payout ratio (refer to section ‘Balance Sheet Analysis –
Capital Base’ below).
3. Includes profits for the year ended 31 December 2023 net of distribution at 30% payout ratio, following ECB approval in March 2024.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
8
Group financial results on the underlying basis (continued)
Reconciliation of the Consolidated Income Statement for the year ended 31 December 2024 between
the statutory basis and the underlying basis
million
Underlying
basis
Other
Statutory
basis
Net interest income 822
-
822
Net fee and commission income 177
-
177
Net foreign exchange gains and net gains on financial
instruments
36
2
38
Net gains on derecognition of financial assets measured at
amortised cost
-
-
-
Net insurance result* 46
-
46
Net
loss
from revaluation and disposal of investment properties
and on disposal of stock of properties
(1)
-
(1)
Other income 14
-
14
Total income 1,094
2
1,096
Total expenses (406)
(12)
(418)
Operating profit 688
(10)
678
Loan credit losses (30)
30
-
Impairment of other financial and non-financial assets (56)
56
-
Provisions for
pending
litigation,
claims,
regulatory and other
matters (net of reversals)
(12)
12
-
Credit losses on financial assets and impairment net of
reversals of non-financial assets
-
(88)
(88)
Profit before tax and non-recurring items 590
-
590
Tax (81)
-
(81)
Profit attributable to non-controlling interests (1)
-
(1)
Profit after tax (attributable to the owners of the
Company)
508
-
508
* Net insurance result per underlying basis comprises the aggregate of captions Net insurance finance
income/(expense) and net reinsurance finance income/(expense)’, ‘Net insurance service result’ and ‘Net
reinsurance service result’ per the statutory basis.
The reclassification differences between the statutory basis and the underlying basis are explained below:
Net gains on loans and advances to customers at FVPL of 1 million included in ‘Loan credit losses’ under
the underlying basis are included in ‘Net gains on financial instruments’ under the statutory basis. Their
classification under the underlying basis is done to align their presentation with the loan credit losses on
loans and advances to customers at amortised cost.
‘Net gains on derecognition of financial assets measured at amortised cost’ is nil under the statutory basis
and comprises the below items which are reclassified accordingly under the underlying basis as follows:
- 0.3 million net gains on derecognition of loans and advances to customers included in ‘Loan
credit losses’ under the underlying basis as to align their presentation with the loan credit losses
arising from loans and advances to customers.
- Net losses on derecognition of debt securities measured at amortised cost of approximately 0.3
million included in ‘Net foreign exchange gains and net gains on financial instruments’ under the
underlying basis in order to align their presentation with the net gains on financial instruments.
‘Provisions for pending litigation, claims, regulatory and other matters (net of reversals)’ amounting to 12
million presented within Operating profit before credit losses and impairment' under the statutory basis,
are presented under the underlying basis in conjunction with loan credit losses and impairments.
Credit losses on financial assets' and 'Impairment net of reversals on non-financial assets under the
statutory basis include: i) credit losses to cover credit risk on loans and advances to customers of 32
million, which are included in Loan credit lossesunder the underlying basis, and ii) net reversal of credit
losses of other financial assets of a 0.1 million and impairment net of reversals on non-financial assets of
56 million, which are included in Impairment of other financial and non-financial assets under the
underlying basis, as to be presented separately from loan credit losses.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
9
Group financial results on the underlying basis (continued)
Balance Sheet Analysis
Capital Base
Total equity excluding non-controlling interests totalled 2,810 million as at 31 December 2024 compared to
2,467 million as at 31 December 2023. Shareholders’ equity totalled to 2,590 million as at 31 December 2024
compared to 2,247 million as at 31 December 2023.
The regulatory Common Equity Tier 1 capital (CET1) ratio on a transitional basis stood at 19.2% as at 31
December 2024 compared to 17.4% as at 31 December 2023. Throughout the Directors’ Report, the capital ratios
as at 31 December 2024 include profits for the year ended 31 December 2024, net of a deduction for the
distribution in respect of 2024 earnings of 241 million, following relevant recommendation by the Board of
Directors to the shareholders for a final cash dividend of 211 million and approval by the Board to undertake a
share buyback of ordinary shares of the Company for an aggregate consideration of up to 30 million and in
compliance with the terms of the ECB approval – refer to section ‘Distributions’ below. During the year ended 31
December 2024, the CET1 ratio was positively affected by profit after tax and partially decreased by the
distribution accrual at 50% payout ratio, as well as the increase in operational RWAs primarily driven by the
inclusion of higher 2024 income compared to 2021. Since September 2023, a charge is deducted from own funds
in relation to the ECB prudential expectations for NPEs, which amounted to 26 basis points as at 31 December
2024, compared to 32 basis points as at 31 December 2023. A prudential charge in relation to an onsite inspection
on the value of the Group’s foreclosed assets is being deducted from own funds since June 2021, the impact of
which was 3 basis points on Group’s CET1 ratio as at 31 December 2024 (compared to 12 basis points on Group’s
CET1 ratio as at 31 December 2023). In addition, the Group is subject to increased capital requirements in
relation to its real estate repossessed portfolio which follow a SREP provision to ensure minimum capital levels
retained on long-term holdings of real estate assets, with such requirements being dynamic by reference to the
in-scope REMU assets remaining on the balance sheet of the Group and the value of such assets. As at 31
December 2024, the impact of these requirements was 51 basis points on Group’s CET1 ratio, compared to 24
basis points as at 31 December 2023. The above-mentioned requirements are within the capital plans of the
Group and incorporated within its capital projections.
The regulatory Total Capital ratio on a transitional basis stood at 24.0% as at 31 December 2024 compared to
22.4% as at 31 December 2023.
The Group’s capital ratios are above the Supervisory Review and Evaluation Process (SREP) requirements.
As at 31 December 2024, the Group’s minimum phased-in CET1 capital ratio requirement was set at 11.34%,
comprising a 4.50% Pillar I requirement, a 1.55% Pillar II requirement, the Capital Conservation Buffer of 2.50%,
the O-SII Buffer of 1.875% and CcyB of approximately 0.92%. Likewise, the Group’s minimum phased-in Total
Capital ratio requirement was set at 16.05%, comprising an 8.00% Pillar I requirement, of which up to 1.50%
can be in the form of AT1 capital and up to 2.00% in the form of T2 capital, a 2.75% Pillar II requirement, the
Capital Conservation Buffer of 2.50%, the O-SII Buffer of 1.875% and the CcyB of approximately 0.92%. For the
year ended 31 December 2024, the ECB had also provided revised lower non-public guidance for an additional
Pillar II CET1 buffer (P2G) compared to 2023.
The Central Bank of Cyprus (‘CBC’), following the revised methodology described in its macroprudential policy,
decided to set the CcyB to 1.00% of the total risk exposure in Cyprus for each licensed credit institution
incorporated in Cyprus, effective from June 2024. As a result, the CcyB for the Group as at 31 December 2024
amounted to approximately 0.92%. In January 2025, CBC, based on its macroprudential policy, decided to
increase the CCyB from 1.00% to 1.50% of the total risk exposure amount in Cyprus, for each licensed credit
institution incorporated in Cyprus, effective from January 2026.
The Bank has been designated as an Other Systemically Important Institution (O-SII) by CBC in accordance with
the provisions of the Macroprudential Oversight of Institutions Law of 2015 and the relevant buffer stood at
1.875% on 1 January 2024. In April 2024, following a revision by the CBC of its policy for the designation of
credit institutions that meet the definition of O-SII institutions and the setting of O-SII buffer to be observed, the
Group’s O-SII buffer has been reduced to 2.00% on 1 January 2026 (from the previous assessment of 2.25% on
1 January 2025) to be phased by 6.25 basis points annually, to 1.9375% on 1 January 2025 and 2.00% as of 1
January 2026.
Own funds held for the purposes of P2G cannot be used to meet any other capital requirements (Pillar I, Pillar
II requirements or the combined buffer requirement), and therefore cannot be used twice.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
10
Group financial results on the underlying basis (continued)
Balance Sheet Analysis (continued)
Capital Base (continued)
Following the annual SREP performed by the ECB in 2024 and based on the final SREP decision received in
December 2024, effective from 1 January 2025, the Group’s minimum phased-in CET1 capital ratio and Total
Capital ratio requirements remain unchanged from prior year, when disregarding the phasing in of the O-SII
buffer. On 1 January 2025 the Group’s minimum phased-in CET1 capital ratio is set at 11.40%, comprising a
4.50% Pillar I requirement, a 1.55% Pillar II requirement, the Capital Conservation Buffer of 2.50%, the O-SII
Buffer of 1.9375% and CcyB of approximately 0.92%. Likewise, on 1 January 2025 the Group’s minimum phased-
in Total Capital ratio requirement is set at 16.11%, comprising an 8.00% Pillar I requirement, of which up to
1.50% can be in the form of AT1 capital and up to 2.00% in the form of T2 capital, a 2.75% Pillar II requirement,
the Capital Conservation Buffer of 2.50%, the O-SII Buffer of 1.9375% and CcyB of approximately 0.92%. The
non-public guidance for an additional Pillar II CET1 buffer (P2G) remains unchanged compared to 2024. Based
on the final SREP decision, the requirement for prior regulatory approval for the declaration of dividends has been
lifted, effective from 1 January 2025.
Distributions
FY2024 Distribution at 50% payout ratio
Following the Group’s strong financial performance, the successful execution of its strategic targets in 2024 and
its ongoing commitment to delivering sustainable returns to shareholders, the Company in February 2025
proposed a total distribution of 241 million in respect of 2024 earnings, comprising a cash dividend of 211
million and a share buyback of up to 30 million (together, the ‘2024 Distribution’).
Additional information on the 2024 Distribution, as well as on distributions in respect of prior years’ earnings is
provided in section ‘Distributions’ further below on this Directors’ Report.
Upgraded Distribution policy from financial year 2025
The Group aims to provide a sustainable return to shareholders. The distribution policy is upgraded in order to
reflect the steady sustained progress achieved over the last years, the profitability profile and medium-term
outlook of the Group. Ordinary distributions are expected to be in the range of 50-70% payout ratio (from 30-
50%) of the Group’s adjusted recurring profitability through a combination of cash dividends and share buybacks.
Additionally the Board of Directors will also consider the introduction of interim dividends if it considers
appropriate to do so. Group adjusted recurring profitability is defined as the Group’s profit after tax before non-
recurring items (attributable to the owners of the Company) taking into account distributions under other equity
instruments such as the annual AT1 coupon.
The decision to make any future final or interim distributions, including proposed distribution quantum, as well
as envisaged allocation between dividend and buyback, will take into consideration market conditions as well as
the outcome of the Group’s ongoing capital and liquidity planning strategy at the time.
Share Capital
As at 31 December 2024, there were 440,502,243 issued ordinary shares with a nominal value of 0.10 each,
compared to 446,199,933 issued ordinary shares as at 31 December 2023. The reduction since the beginning of
the year relates to the share buyback programme that was launched in April 2024 and was completed in
November 2024.
Other equity instruments
At 31 December 2024, the Group’s other equity instruments relate to Additional Tier 1 Capital Securities (the
‘AT1 securities’) and amounted to 220 million, at the same levels as at 31 December 2023.
The Fixed Rate Reset Perpetual Additional Tier 1 Capital Securities constitute unsecured and subordinated
obligations of the Company, are perpetual and are issued at par. They carry an initial coupon of 11.875% per
annum, payable semi-annually and resettable on 21 December 2028 and every 5 years thereafter.
The Company will have the option to redeem these capital securities from, and including, 21 June 2028 to, and
including, 21 December 2028 and on each interest payment date thereafter, subject to applicable regulatory
consents and the relevant conditions to redemption.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
11
Group financial results on the underlying basis (continued)
Balance Sheet Analysis (continued)
Capital Base (continued)
Legislative amendments for the conversion of DTA to DTC
Legislative amendments allowing for the conversion of specific deferred tax assets (DTA) into deferred tax credits
(DTC) became effective in March 2019. The legislative amendments cover the utilisation of income tax losses
transferred from Laiki Bank to the Bank in March 2013. The introduction of the Capital Requirements Regulation
(CRR) and Capital Requirements Directive (CRD) IV in January 2014 and its subsequent phasing-in led to a more
capital-intensive treatment of the DTA arising from tax losses. With this legislation, institutions are allowed to
treat such DTAs as ‘not relying on future profitability’, according to CRR/CRD IV and as a result not deducted
from CET1, hence improving a credit institution’s capital position. They also provide that a guarantee fee on
annual tax credit is payable annually by the credit institution to the Government.
Following certain modifications to the relevant law in May 2022, the annual guarantee fee is to be determined by
the Cyprus Government on an annual basis, providing however that such fee to be charged is set at a minimum
fee of 1.5% of the annual instalment and can range up to a maximum amount of 10 million per year.
The Group estimates that such fees could range to approximately 5 million per year (for each tax year in scope
i.e., since 2018), although the Group understands that such fee may fluctuate annually as to be determined by
the Ministry of Finance. An amount of 5.4 million was recorded as an expense in the year ended 31 December
2024.
Regulations and Directives
The 2021 Banking Package (CRR III and CRD VI and BRRD)
In October 2021, the European Commission adopted legislative proposals for further amendments to the Capital
Requirements Regulation (CRR), CRD and the BRRD (the ‘2021 Banking Package’). Amongst other things, the
2021 Banking Package would implement certain elements of Basel III that have not yet been transposed into EU
law. In the case of the proposed amendments to CRD and the BRRD, their terms and effect will depend, in part,
on how they are transposed in each member state. In December 2023, the preparatory bodies of the Council and
European Parliament endorsed the amendments to the CRR and the CRD and the legal texts were published on
the Council and the Parliament websites. In April 2024, the European Parliament voted to adopt the amendments
to the CRR and the CRD; Regulation (EU) 2024/1623 (known as CRR III) and Directive (EU) 2024/1619 (known
as CRD VI) were published in the EU's official journal in June 2024, with entry into force 20 days from the date
of the publication. Most amended provisions of the CRR III have become effective on 1 January 2025 with certain
measures subject to transitional arrangements or to be phased-in over time. Member states shall adopt and
publish, by 10 January 2026, the laws, regulations and administrative provisions necessary to comply with CRD
VI and shall apply most of those measures by 11 January 2026. The implementation of CRR III is estimated to
have a positive impact of approximately 1% on the CET1 ratio (transitional) of the Group on initial application on
1 January 2025. However, during 2025 the publication of ECB guidelines on options and discretions and EBA
mandates could result in additional impacts on CET1 ratios across the industry.
Bank Recovery and Resolution Directive (BRRD)
Minimum Requirement for Own Funds and Eligible Liabilities (MREL)
The Bank Recovery and Resolution Directive (BRRD) requires that from January 2016, EU member states shall
apply the BRRD’s provisions requiring EU credit institutions and certain investment firms to maintain a minimum
requirement for own funds and eligible liabilities (MREL), subject to the provisions of the Commission Delegated
Regulation (EU) 2016/1450. On 27 June 2019, as part of the reform package for strengthening the resilience and
resolvability of European banks, the BRRD ΙΙ came into effect and was required to be transposed into national
law. BRRD II was transposed and implemented in Cyprus law in May 2021. In addition, certain provisions on
MREL have been introduced in CRR ΙΙ which also came into force on 27 June 2019 as part of the reform package
and were immediately effective.
In January 2024, the Bank received final notification from the SRB regarding the 2024 MREL decision, by which
the MREL requirement was set at 25.00% of risk weighted assets (or 30.30% of risk weighted assets taking into
account the prevailing CBR as at 31 December 2024 which needs to be met with own funds on top of the MREL)
and 5.91% of Leverage Ratio Exposure (‘LRE’ as defined in the CRR) and had to be met by 31 December 2024.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
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Group financial results on the underlying basis (continued)
Balance Sheet Analysis (continued)
Regulations and Directives (continued)
Bank Recovery and Resolution Directive (BRRD) (continued)
Minimum Requirement for Own Funds and Eligible Liabilities (MREL) (continued)
In January 2025, the Bank received final notification from the SRB regarding the 2025 MREL decision, by which
the MREL requirement is now set at 23.85% of risk weighted assets (or 29.21% of risk weighted assets taking
into account the prevailing CBR as at 1 January 2025 which needs to be met with own funds on top of the MREL)
and 5.91% of LRE. The revised MREL requirements became binding with immediate effect.
The Bank must comply with the MREL requirement at the consolidated level, comprising the Bank and its
subsidiaries.
The regulatory MREL ratio as at 31 December 2024, calculated according to the SRB’s eligibility criteria currently
in effect, stood at 33.7% of RWAs (including capital used to meet the CBR) and at 13.9% of LRE (based on the
regulatory Total Capital as at 31 December 2024), demonstrating that the Bank finalized its MREL build-up and
created a comfortable buffer over the MREL requirements.
The CBR stood at 5.30% as at 31 December 2024, higher compared to 4.48% as at 31 December 2023, reflecting
the increase of the CcyB and O-SII buffer by approximately 50 basis points and 37.5 basis points respectively.
The CBR is expected to increase further as a result of the phasing in of O-SII buffer from 1.875% to 1.9375% on
1 January 2025 and to 2.00% on 1 January 2026 as well as of the expected increase of CcyB from 1.00% to
1.50% in January 2026.
Throughout the Directors’ Report, the MREL ratios as at 31 December 2024 include profits for the year ended 31
December 2024, net of a deduction for the distribution in respect of 2024 earnings, following relevant
recommendation by the Board of Directors to the shareholders.
Funding and Liquidity
Funding
Funding from Central Banks
Following the repayment of 1.7 billion under the seventh TLTRO III operation in March 2024 and 0.3 billion
under the eighth TLTRO III operation in June 2024, the funding from Central Banks was nil as at 31 December
2024, compared to 2,044 million as at 31 December 2023.
Deposits
Customer deposits totalled 20,519 million at 31 December 2024, compared to 19,337 million at 31 December
2023. Customer deposits are mainly retail-funded and approximately 55% of deposits are protected under the
deposit guarantee scheme as at 31 December 2024.
The Bank’s deposit market share in Cyprus reached 37.2% as at 31 December 2024, compared to 37.7% as at
31 December 2023. Customer deposits accounted for 77% of total assets and 87% of total liabilities at 31
December 2024, compared to 73% of total assets and 80% of total liabilities as at 31 December 2023. The
increase in the share of total assets and liabilities since the beginning of the year relates mainly to the repayment
of 2.0 billion TLTRO.
The net loans to deposits (L/D) ratio stood at 49% as at 31 December 2024, compared to 51% as at 31 December
2023 on the same basis.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
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Group financial results on the underlying basis (continued)
Balance Sheet Analysis (continued)
Funding and Liquidity (continued)
Funding (continued)
Subordinated liabilities
At 31 December 2024, the carrying amount of the Group’s subordinated liabilities amounted to 307 million,
compared to 307 million at 31 December 2023, and relate to unsecured subordinated Tier 2 Capital Notes (‘T2
Notes’).
The T2 Notes were priced at par with a fixed coupon of 6.625% per annum, payable annually in arrears and
resettable on 23 October 2026. The maturity date of the T2 Notes is 23 October 2031. The Company will have
the option to redeem the T2 Notes early on any day during the six-month period from 23 April 2026 to 23 October
2026, subject to applicable regulatory approvals.
Debt securities in issue
At 31 December 2024, the carrying value of the Group’s debt securities in issue amounted to 989 million,
compared to 672 million at 31 December 2023 and relate to senior preferred notes. The increase of 47% since
the beginning of the year relates to the issuance of 300 million green senior preferred notes (‘Green Notes’) in
April 2024.
In April 2024, the Bank successfully launched and priced an issuance of 300 million green senior preferred notes.
The Green Notes were priced at par with a fixed coupon of 5% per annum, payable in arrear, until the Option
redemption date, i.e., 2 May 2028. The maturity date of the Green Notes is 2 May 2029; however, the Bank may,
at its discretion, redeem the Green Notes on the Optional Redemption Date subject to meeting certain conditions
(including applicable regulatory consents) as specified in the Terms and Conditions.
If the Green Notes are not redeemed by the Bank, the coupon payable from the Optional Redemption Date until
the Maturity Date will convert from a fixed rate to a floating rate and will be equal to 3-month Euribor plus 197.1
basis points, payable quarterly in arrear. The transaction represents the Bank's inaugural green bond issuance in
line with the Group’s Beyond Banking approach, aimed at creating a stronger, safer and future-focused Βank and
leading the transition of Cyprus to a sustainable future. An amount equivalent to the net proceeds of the Green
Notes will be allocated to Eligible Green Projects as described in the Bank's Sustainable Finance Framework, which
include Green Buildings, Energy Efficiency, Clean Transport and Renewable Energy.
In July 2023, the Bank successfully launched and priced an issuance of 350 million of senior preferred notes
(the ‘Notes’). The Notes were priced at par with a fixed coupon of 7.375% per annum, payable annually in arrear,
until the Optional Redemption Date, i.e., 25 July 2027. The maturity date of the Notes is 25 July 2028; however,
the Bank may, at its discretion, redeem the Notes on the Optional Redemption Date subject to meeting certain
conditions (including applicable regulatory consents) as specified in the Terms and Conditions. If the Notes are
not redeemed by the Bank, the coupon payable from the Optional Redemption Date until the Maturity Date will
convert from a fixed rate to a floating rate and will be equal to 3-month Euribor plus 409.5 basis points, payable
quarterly in arrear.
In June 2021, the Bank executed its inaugural MREL transaction issuing 300 million of senior preferred notes
(the ‘SP Notes‘). The SP Notes were priced at par with a fixed coupon of 2.50% per annum, payable annually in
arrears and resettable on 24 June 2026. The maturity date of the SP Notes is 24 June 2027, and the Bank may,
at its discretion, redeem the SP Notes on 24 June 2026, subject to meeting certain conditions as specified in the
Terms and Conditions, including applicable regulatory consents.
All issuances of senior preferred notes comply with the criteria for the Minimum Requirement for Own Funds and
Eligible Liabilities (‘MREL’) and contribute towards the Bank’s MREL requirements.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
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14
Group financial results on the underlying basis (continued)
Balance Sheet Analysis (continued)
Funding and Liquidity (continued)
Liquidity
At 31 December 2024, the Group Liquidity Coverage Ratio (LCR) stood at 309%, compared to 359% at 31
December 2023, well above the minimum regulatory requirement of 100%. The LCR surplus as at 31 December
2024 amounted to 8.1 billion, compared to 9.1 billion at 31 December 2023.
At 31 December 2024, the Group Net Stable Funding Ratio (NSFR) stood at 162%, compared to 158% at 31
December 2023, well above the minimum regulatory requirement of 100%.
Loans
Group gross loans totalled 10,374 million at 31 December 2024, compared to 10,070 million at 31 December
2023.
New lending in the year ended 31 December 2024 reached 2,435 million, compared to 2,025 million in the
year ended 31 December 2023, driven mainly by business demand.
At 31 December 2024, the Group net loans and advances to customers totalled 10,114 million, compared to
9,822 million at 31 December 2023.
The Bank is the largest credit provider in Cyprus with a market share of 43.0% at 31 December 2024, compared
to 42.2% at 31 December 2023.
In December 2023, the Bank entered into an agreement with Cyprus Asset Management Company (‘KEDIPES’)
to acquire a portfolio of performing and restructured loans with gross book value of approximately 58 million
with reference date 31 December 2022 (the ‘Transaction’). The Transaction was broadly neutral to the Group’s
income statement and capital position. The Transaction was completed in March 2024.
Loan portfolio quality
The Group has continued to make steady progress across all asset quality metrics. The Group’s priorities focus
mainly on maintaining high quality new lending with strict underwriting standards and preventing asset quality
deterioration.
The loan credit losses totalled 30 million for the year ended 31 December 2024. Further details regarding loan
credit losses are provided in section ‘Profit before tax and non-recurring items’.
Non-performing exposures
Non-performing exposures (NPEs) as defined by the European Banking Authority (EBA) were reduced to 255
million at 31 December 2024, compared to 365 million at 31 December 2023. As a result, the NPEs reduced to
2.5% of gross loans as at 31 December 2024, compared to 3.6% of gross loans as at 31 December 2023.
The NPE coverage ratio stands at 100% at 31 December 2024, compared to 73% at 31 December 2023.
Agreement for the sale of NPEs
In September 2024, the Bank entered into an agreement with funds associated with Cerberus Global Investments
B.V. to sell a non-performing loan portfolio of mainly corporate secured exposures. In December 2024 the Bank
entered into an additional agreement with funds associated with Cerberus Global Investments B.V. for the sale
of a non-performing loan portfolio of mainly retail and SME exposures.
Both transactions are expected to be broadly neutral to both the income statement and to capital on completion,
are subject to the necessary approvals and completion is expected during the first half of 2025. The portfolios
are classified as non-current assets held for sale and as at 31 December 2024 the gross book value and net book
value amounted to 55 million and 23 million respectively. Pro forma for the NPE sale agreements, the NPE ratio
is reduced further to 1.9%, whilst the NPE coverage increased to 111%.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
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Group financial results on the underlying basis (continued)
Balance Sheet Analysis (continued)
Loans (continued)
Loan portfolio quality (continued)
Mortgage-To-Rent Scheme (‘MTR’)
In July 2023, the Mortgage-to-Rent Scheme (‘MTR’) was approved by the Council of Ministers and aims for the
reduction of NPEs backed by primary residence and simultaneously protect the primary residence of vulnerable
borrowers. The eligible criteria include:
Borrowers that were non-performing as at 31 December 2021, remained non-performing as at 31
December 2022 and who also received government allowances during the period January 2021 to
December 2022, with facilities backed by primary residence with Open Market Value up to 250k;
Borrowers that had a fully completed application to Estia Scheme and were assessed as eligible but not
viable with a primary residence of up to 350k Open Market Value; and
all applicants that were approved under Estia Scheme but their inclusion was terminated.
Under the MTR, eligible property owners will voluntarily surrender ownership of their residence to Cyprus Asset
Management Company (‘KEDIPES’) which has been approved by the Government to provide and manage social
housing and will be exempted from their mortgage loan, as the state will be covering fully the required rent on
their behalf. KEDIPES will carry out a new valuation and a technical due diligence for the eligible applicants’
property and if satisfied will approve the application and pay to the banks an amount equal to 65% of the Open
Market Value of the primary residence in exchange for the mortgage release, the write off of the NPE loan and
the transfer of the property title deeds.
The eligible applicants will be able to acquire the primary residence after 5 years at a favourable price, below the
Open Market Value.
The scheme has been launched in December 2023; it is expected to act as another tool to address NPEs in the
Retail sector.
Fixed income portfolio
Fixed income portfolio amounts to 4,212 million as at 31 December 2024, compared to 3,548 million as at 31
December 2023, increased by 19% on prior year. As at 31 December 2024, the portfolio represents 16% of total
assets and comprises 3,806 million (90%) measured at amortised cost and 406 million (10%) at fair value
through other comprehensive income (‘FVOCI’).
The fixed income portfolio measured at amortised cost is held to maturity and therefore no fair value gains/losses
are recognised in the Group’s income statement or equity. This fixed income portfolio has high average rating at
Aa2. The amortised cost fixed income portfolio as at 31 December 2024 has an unrealised fair value gain of 32
million.
Reverse repurchase agreements
Reverse repurchase agreements amount to 1,010 million as at 31 December 2024, compared to 403 million
as at 31 December 2023. The increase since the beginning of the year related to the hedging activities the Group
is carrying out in order to reduce its net interest income sensitivity. The average yield of reverse repurchase
agreements is approximately 3.0% p.a. and the remaining average duration is estimated at approximately 2.1
years.
Real Estate Management Unit (REMU)
The Real Estate Management Unit (REMU) is focused on the disposal of on-boarded properties resulting from debt
for asset swaps.
REMU completed disposals of 175 million in the year ended 31 December 2024, resulting in a gain on disposal
of 1 million, compared to 172 million disposals in the year ended 31 December 2023 at a profit of approximately
11 million. Asset disposals are across all property classes, with 44% of sales in gross sale value in the year
ended 31 December 2024 relating to land.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
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Group financial results on the underlying basis (continued)
Balance Sheet Analysis (continued)
Real Estate Management Unit (REMU) (continued)
REMU on-boarded 30 million of assets in the year ended 31 December 2024, compared to additions of 21
million in the year ended 31 December 2023, via the execution of debt for asset swaps and repossessed
properties.
As at 31 December 2024, repossessed properties held by REMU had a carrying value of 660 million, compared
to 862 million as at 31 December 2023 and remain on track to achieve its target of reducing this portfolio to
approximately 0.5 billion by end-2025.
Income Statement Analysis
Total income
Net interest income (NII) for the year ended 31 December 2024 amounted to 822 million, compared to 792
million for the year ended 31 December 2023. The annual increase is mainly attributed to higher interest rates
on liquid assets and loans and higher liquidity compared to prior year, partially offset by a moderate increase in
the deposit and funding costs as well as the cost of hedging.
Quarterly average interest earning assets (AIEA) for the year ended 31 December 2024 amounted to 23,271
million, compared to 23,211 for the year ended 31 December 2023.
Net interest margin (NIM) for the year ended 31 December 2024 amounted to 3.53% (compared to 3.41% for
the year ended 31 December 2023), up 12 basis points year-on-year, supported by the higher interest rates
compared to prior year.
Non-interest income for the year ended 31 December 2024 amounted to 272 million, compared to 300 million
for the year ended 31 December 2023. Non-interest income for the year ended 31 December 2024 comprises net
fee and commission income of 177 million, net foreign exchange gains and net gains/(losses) on financial
instruments of 36 million, net insurance result of 46 million, net loss from revaluation and disposal of
investment properties and on disposal of stock of properties of 1 million and other income of 14 million. The
year-on-year reduction is mainly due to lower net insurance result as well as net losses from revaluation and
disposal of investment properties and on disposal of stock of properties.
Net fee and commission income for the year ended 31 December 2024 amounted to 177 million compared to
181 million in prior year, primarily due to lower transactional fees.
Net foreign exchange gains and net gains/(losses) on financial instruments amounted to 36 million for the year
ended 31 December 2024, compared to 37 million for the year ended 31 December 2023, and comprise of net
foreign exchange gains of 27 million and net gains on financial instruments of 9 million. The year-on-year
reduction is mainly due to lower net foreign exchange income through FX swaps. Net foreign exchange gains and
net gains/(losses) on financial instruments are considered volatile profit contributors.
Net insurance result amounted to 46 million for the year ended 31 December 2024, compared to 54 million for
the year ended 31 December 2023, impacted partially by negative claim experience in the non-life insurance
business, arising from the severe weather-related events that occurred in 2024, as well as models’ recalibration
in the life insurance business.
Net gains/(losses) from revaluation and disposal of investment properties and on disposal of stock of properties
amounted to a net loss of 1 million for the year ended 31 December 2024, compared to a net profit 10 million
for the year ended 31 December 2023, and comprise of 1.2 million gain on disposal of stock of properties and
investment properties, and net loss from revaluation of investment properties of approximately 2.4 million.
REMU profits remain volatile.
Total income amounted to 1,094 million for the year ended 31 December 2024, compared to 1,092 million for
the year ended 31 December 2023.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
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Group financial results on the underlying basis (continued)
Income Statement Analysis (continued)
Total expenses
Total expenses for the year ended 31 December 2024 were 406 million, compared to 384 million for the year
ended 31 December 2023, of which 50% related to staff costs (203 million), 40% to other operating expenses
(164 million) and 10% to special levy on deposits and other levies/contributions (39 million).
Total operating expenses amounted to 367 million for the year ended 31 December 2024, compared to 341
million for the year ended 31 December 2023, reflecting both higher staff costs and other operating expenses.
Staff costs for the year ended 31 December 2024 were 203 million, compared to 192 million for the year ended
31 December 2023, and include 11 million performance-related pay cost and approximately 9.5 million
termination cost (compared to 12 million performance-related pay cost and approximately 7.5 million
termination cost in the year ended 31 December 2023). Net of the performance-related pay cost and termination
cost, staff costs increased by 6% year-on-year, reflecting salary increments and higher cost of living adjustments
(COLA) as well as higher employer’s contributions. During the year ended 31 December 2024 a small-scale,
targeted Voluntary Exit Plan (‘VEP’) took place, by which 57 full-time employees were approved to leave the
Group at a total cost of approximately 9.5 million.
The performance-related pay cost relates to the Short-Term Incentive Plan (‘STIP’) and the Long-Term Incentive
Plan (‘LTIP’). The Short-Term Incentive Plan involves variable remuneration to selected employees and driven by
both, delivery of the Group’s strategy as well as individual performance. The LTIP is a share-based compensation
plan and provides for an award in the form of ordinary shares of the Company based on certain non-market
performance and service vesting conditions. Additional information on the LTIP is provided in section ‘Share based
payments – share awards’ further below.
As at 31 December 2024, the Group employed 2,880 persons compared to 2,830 persons as at 31 December
2023.
Other operating expenses for the year ended 31 December 2024 amounted to 164 million, compared to 149
million for the year ended 31 December 2023, impacted by inflationary pressures, higher marketing expenses
due to various campaigns carried out in the year ended 31 December 2024, higher technology and system costs
and higher professional fees for ATHEX listing.
Special levy on deposits and other levies/contributions for the year ended 31 December 2024 amounted to 39
million compared to 43 million for the year ended 31 December 2023. The year-on-year decrease reflects mainly
lower contribution of the Bank to paying contributions to the Deposit Guarantee Fund (‘DGF’). As from 2020 to
end-June 2024 the Bank was subject to DGF contributions on a semi-annual basis and calculated on the covered
deposits of all authorised institutions with the target level expected to reach at least 0.8% of the covered deposits
by 3 July 2024. The management committee of the Deposit Guarantee and Resolution of Credit and Other
Institutions Schemes can decide to collect additional ex-ante contributions to achieve a higher return.
The cost to income ratio excluding special levy on deposits and other levies/contributions for the year ended 31
December 2024 was 34% compared to 31% for the year ended 31 December 2023.
Profit before tax and non-recurring items
Operating profit for the year ended 31 December 2024 amounted to 688 million, compared to 708 million for
the year ended 31 December 2023, down by 3% year-on-year due to the higher total operating expenses.
Loan credit losses for the year ended 31 December 2024 were 30 million compared to 63 million for the year
ended 31 December 2023, down by 52% year-on-year, supported by the continued robust performance of the
credit portfolio and improved macroeconomic assumptions, partially offset by charges on IFRS9 model
calibrations.
Cost of risk for the year ended 31 December 2024 is equivalent to 30 basis points, compared to a cost of risk of
62 basis points for the year ended 31 December 2023, as in prior year there were higher credit losses on specific
customers with idiosyncratic characteristics assessed as ‘Unlikely to pay’ (‘UTPs’).
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Group financial results on the underlying basis (continued)
Income Statement Analysis (continued)
Profit before tax and non-recurring items (continued)
At 31 December 2024, the allowance for expected loan credit losses, including residual fair value adjustment on
initial recognition and credit losses on off-balance sheet exposures (please refer to ‘Alternative Performance
Measures Disclosures’ of the Annual Financial Report 2024 for definition) amounted to 254 million, including the
portfolio held for sale, compared to 267 million at 31 December 2023, and accounted for 2.5% of gross loans
(compared to 2.7% as at 31 December 2023, calculated on the same basis). Pro forma for the held for sale, the
allowance for expected loan credit losses, including residual fair value adjustment on initial recognition and credit
losses on off-balance sheet exposures, amounted to 223 million and accounted for 2.2%.
Impairments of other financial and non-financial assets for the year ended 31 December 2024 amounted to 56
million, compared to 53 million for the year ended 31 December 2023 and relate mainly to REMU stock of
property.
Provisions for pending litigation, claims, regulatory and other matters (net of reversals) for the year ended 31
December 2024 amounted to 12 million, compared to 28 million for the year ended 31 December 2023. The
charge for the year mainly relates to the resolution of cases on existing litigation and claims arising from legacy
matters, thereby further reducing the exposure from such legacy matters, which was partially offset by the
progress and conclusion of other items relating to other matters.
Profit before tax and non-recurring items for the year ended 31 December 2024 totalled to 590 million, compared
to 564 million for the year ended 31 December 2023 and was positively impacted by lower loan credit losses
and provisions for pending litigation, claims and other matters (net of reversals).
Profit after tax (attributable to the owners of the Company)
The tax charge for the year ended 31 December 2024 amounted to 81 million compared to 73 million for the
year ended 31 December 2023.
On 22 December 2022, the European Commission approved Directive 2022/2523 which provides for a minimum
effective tax rate of 15% for the global activities of large multinational groups (Pillar Two tax). The Directive
follows closely the OECD Inclusive Framework on Base Erosion and Profit Shifting. In December 2024, the Cyprus
Parliament voted to transpose the Directive (EU) 2022/2523 into Law 151(Ι)/2024 (the 'Cyprus Pillar Two Law'),
which introduces an Income Inclusion Rule (IIR), effective for financial years starting from 31 December 2023.
The Group is in scope of the Cyprus Pillar Two Law for the year ended 31 December 2024. The Group is eligible
for the transitional provision under Article 55 of the Cyprus Pillar Two Law which results in zeroing any top-up
tax computed in accordance with the rules laid out in the Cyprus Pillar Two Law for the year ended 31 December
2024.
Profit after tax and before non-recurring items (attributable to the owners of the Company) for the year ended
31 December 2024 is 508 million, compared to 489 million for the year ended 31 December 2023.
Advisory and other transformation costs organic for the year ended 31 December 2024 are nil, compared to 2
million for the year ended 31 December 2023.
Profit after tax attributable to the owners of the Company for the year ended 31 December 2024 amounts to
508 million corresponding to a ROTE of 21.4%, compared to 487 million for the year ended 31 December 2023
(and a ROTE of 24.8%). ROTE on 15% CET1 ratio for the year ended 31 December 2024 increases to 27.6%,
compared to 27.4% for the year ended 31 December 2023, calculated on the same basis. The adjusted recurring
profitability used for the Group’s distribution policy (i.e. defined as the Group’s profit after tax before non-
recurring items (attributable to the owners of the Company) taking into account distributions under other equity
instruments such as the annual AT1 coupon which is paid semi-annually) amounted to 482 million for the year
ended 31 December 2024, compared to 455 million for the year ended 31 December 2023.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
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Operating Environment
The Cypriot economy has demonstrated remarkable resilience and growth in recent years, navigating through
global uncertainties and regional challenges. In 2024, the economy achieved an estimated growth rate of 3.4%,
in line with the projections by the Ministry of Finance. Growth in 2024 was driven by rising exports and strong
economic activity in key sectors, primarily the information and communications sector, business and professional
services, tourism and construction. The growth of the information and communications services was driven by
computer software and consulting services, thus increasing economic diversification. In 2025 GDP is forecasted
to continue to grow by 3.3% in real terms, outpacing the Eurozone average.
The recent sovereign rating upgrades by the major rating agencies to 'A-' or equivalent, 3 notches above
investment grade are the recognition of the robust growth performance, the strong fiscal dynamics and declining
public debt, and the improved stability in the financial system.
Employment growth averaged 2.0% and labour productivity growth averaged 1.4% in 2024. Labour productivity
growth remains a strong contributor to overall growth in the economy with efficiency improving, demonstrated
by the increased ability to generate output per worker. The unemployment rate, after rising in 2020 and the first
half of 2021, has been declining in the period since, dropping to 5.8% in 2023 and to 4.9% in 2024, on average,
and to 4.6% in the fourth quarter, seasonally adjusted. The unemployment rate in Cyprus is expected to average
4.8% for 2025 as per latest projections by the Ministry of Finance.
Inflation measured by the Harmonised Index of Consumer Prices, has been declining since the peak in July-
August 2022 10.6% for headline and 7.2% for core inflation. Harmonised inflation dropped to 3.9% in 2023
and dropped further to 2.3% in 2024 and is expected to remain broadly flat at 2.0% for 2025. Core inflation,
which is headline inflation excluding energy and food, was a little stickier at 2.8% in the year. Services inflation
– all items excluding goods – was up 4.2% in the year, compared with 3.6% in 2023.
Cyprus’ fiscal performance remains robust. Following a general government budget surplus of 2% of GDP in 2023
and 4.5% of GDP in 2024, fiscal developments have continued to be favourable, with government revenues
increasing at a higher rate than public spending. Total general government revenues rose by 7.8% year-on-year
in 2024 and by 15.3% in 2023. Over the next few years, government accounts are likely to continue benefiting
from strong, albeit decelerating revenue growth due to the favourable economic outlook. This will help manage
moderate budgetary pressures.
General government debt metrics have significantly improved. The government debt-to-GDP ratio decreased to
65.4% in December 2024 from 73.6% in 2023 and 113.6% at the end of 2020. Looking ahead, continued
budgetary surpluses and favourable debt dynamics are expected to further reduce the debt ratio, potentially
dropping below 60% by 2026.
Reduction in financial system risks is reflected in the continuous improvement of the private and banking sectors’
financial position. Private sector debt in active banks' balance sheets has more than halved over the past decade
and is now among the lowest in Europe.
Total domestic loans excluding the government were 20.2 billion at the end of December 2024 or 60% of GDP.
Loans to non-financial companies were about 26% of GDP and loans to households about 32%, where housing
loans were about 25% of GDP.
The non-performing exposures ratio in the Cyprus banking sector dropped to 6.6% of gross loans or 1.6 billion,
at the end of November 2024, while the coverage ratio of provisions, accounted for 61.6% of the non-performing
loans. At the same time about 44% of non-performing loans consisted of restructured facilities. This steady
progress in the banking sector continues to strengthen the sector’s shock absorption capacity.
The Cypriot economy is largely constrained by structurally large current account deficits, reflecting high imports
and low savings relative to domestic investment. The large current account deficits are driven by primary income
imbalances, reflecting high repatriation of profits by foreign-owned enterprises.
Short-term risks are mostly external and skewed to the downside, including a downturn in key tourism markets,
an escalation of regional conflicts, and delays in the implementation of the Recovery and Resilience Plan. Medium-
term risks stem from climate change and a possible further deterioration in the global geopolitical outlook. The
digital and green transitions remain key challenges in the medium term. The implementation of the Recovery and
Resilience Plan requires structural reforms to further strengthen governance and economic resilience.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
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Operating Environment (continued)
Sovereign ratings
The sovereign risk ratings of the Cypriot government have improved significantly in recent years, reflecting
reduced banking sector risks, improved economic resilience and consistent fiscal outperformance. Cyprus has
demonstrated policy commitment to correcting fiscal imbalances through reform and restructuring of its banking
system.
In December 2024, S&P Global Ratings upgraded Cyprus’ long-term local and foreign currency sovereign credit
ratings to A- from BBB+, and revised its outlook in Cyprus to stable. This one-notch upgrade of Cyprus’ rating
reflects the third consecutive solid annual fiscal surplus as well as the capital and labour inflows from nearby
conflict zones amid rising geopolitical developments.
Additionally, in December 2024, Fitch Ratings upgraded Cyprus' long-term foreign currency issuer default rating
to A- from BBB+ and revised its outlook on Cyprus to stable. The one notch upgrade relates mainly to the rapid
decline in public debt, strong fiscal surpluses and strong growth momentum.
In November 2024, Moody's Investors Service upgraded the long-term issuer and senior unsecured ratings of the
Government of Cyprus to A3 from Baa2. The outlook was revised to stable from positive. The upgrade of Cyprus
ratings reflects the material improvement in fiscal and debt metrics, the reduced government debt ratio and the
solid medium-term economic outlook driven by the steady expansion of high-productivity services sectors
supported by headquartering of companies, significant foreign direct investments as well as reforms and
investments related to Cyprus’ National Recovery and Resilience Plan.
In October 2024, Scope Ratings GmbH upgraded the Cyprus’ long-term issuer and senior unsecured debt ratings
to A- from BBB+ in local and foreign currency and maintained the Stable Outlooks. The upgrade was driven by
the strong fiscal outlook characterised by sustained primary surpluses and declining general government debt.
DBRS Ratings GmbH (DBRS Morningstar) confirmed Cyprus’ Long-Term Foreign and Local Currency Issuer
Ratings at BBB (high) in September 2024. The trend was revised from stable to positive reflecting the view that
public debt metrics are likely to continue to improve and that economic growth is likely to continue to benefit
from robust private consumption, rising service exports and strong construction investment over the next few
years.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
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Business Overview
Credit ratings
The Group’s financial performance is highly correlated to the economic and operating conditions in Cyprus. In
March 2025, Fitch Ratings upgraded the long-term issuer default rating to the investment grade BBB- from BB+,
whilst maintaining the positive outlook. The one-notch upgrade reflects BOC PCL’s strengthened capitalisation
and reduced stock of legacy problem assets, as well as the structurally sound profitability which is expected to
remain satisfactory despite the declining interest rate environment. In February 2025, S&P Global Ratings
upgraded the long-term issuer credit rating of the Bank to the investment grade BBB- from BB+ and revised the
outlook to stable from positive. The upgrade by one notch was driven on the improved funding profile of the
banking sector in Cyprus and the supportive economic environment. Additionally, in December 2024, Moody’s
Investors Service affirmed the Bank’s long-term deposit rating at Baa1 and revised the outlook to positive from
stable. The affirmation reflects the Bank’s strong domestic franchise and solid financial fundamentals, supported
by the stable economic environment. The change in the outlook reflects the expectations of a solid medium-term
economic outlook for Cyprus, which will support further reductions in the Bank’s foreclosed assets, sustained
asset quality improvements and solid profitability. This is the highest long-term deposit rating for the Bank since
2011.
Financial performance
The Group is the leading, financial and technology hub in Cyprus, with a diversified and sustainable business
model. The Group’s financial performance for the year ended 31 December 2024 remained strong, benefitting
from the high-interest rate environment and recorded a profit after tax of 508 million, 4% higher compared to
prior year. As a result, the Group has successfully exceeded its financial targets for 2024 across all metrics,
generating a ROTE of 21.4% (compared to a ROTE of 24.8% for the year ended 31 December 2023). This strong
financial performance in 2024 facilitated further the rapid build-up of equity base, with tangible book value per
share growing by 17% on prior year.
Following the Group’s ongoing commitment to providing sustainable returns to shareholders, the Group has
proposed to make distributions out of 2024 earnings based on the targeted 50% payout ratio, at the top-end of
the Group’s 2024 distribution policy. The distribution comprises a cash dividend of 211 million and a share
buyback of 30 million; together it represents a material increase both in terms of payout ratio and total quantum,
compared to prior year, with a yield of 12%, exceeding the 2024 Eurozone banking sector average. Overall, the
Group reached shareholder remuneration of 400 million for 2022-2024, exceeding the target set at the 2023
Investor Update event a year earlier, of delivering distributions in the range of 200-350 million for 2023-2025.
For further details, please refer to section ‘Capital Base’.
Interest rate environment
The structure of the Group’s balance sheet remains highly liquid. As at 31 December 2024, cash balances with
ECB amounted to 7.6 billion and 43% of the Group’s loan portfolio is Euribor based. Net interest income for the
year ended 31 December 2024 amounted to 822 million, up 4% year-on-year due to higher interest income on
loans and liquid assets, underpinned by high interest rates and increased liquidity, all of which served to more
than offset the higher cost of deposits and funding costs and the continued hedging activity to reduce NII
sensitivity.
The Group used hedging activities in the year ended 31 December 2024 in order to reduce the sensitivity of net
interest income. The hedging tools include receive fixed interest rate swaps, further investment in fixed rate
bonds, additional reverse repos and continuing offering of fixed rate loans.
During 2024, the Group carried out additional hedging activities of 4.5 billion, totaling 9.0 billion by year end,
representing 37% of interest earning assets. The average yield of receive fixed interest rate swaps and reverse
repos is 2.9%. Additionally, about a quarter of the Group’s loan portfolio is linked with the Bank’s base rate which
provides a natural hedge against the cost of deposits of household time and notice deposit accounts. Overall,
these actions have led to a reduction in the net interest income sensitivity (to a parallel shift in interest rates by
100 basis points) by 43 million since 31 December 2022.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
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Business Overview (continued)
Growing revenues in a more capital efficient way
The Group remains focused on growing revenues in a more capital efficient way through growth of high-quality
new lending and the growth in areas, such as insurance and digital products that provide further market
penetration and diversify through non-banking operations.
The Group has continued to provide high quality new lending in the year ended 31 December 2024. Growth in
new lending in Cyprus has been focused on selected industries in line with the Bank’s target risk profile. During
the year ended 31 December 2024, the Group granted new lending of 2.4 billion, up 20% on prior year, driven
mainly by business demand. Gross performing loan book increased by 4% since the beginning of the year to
approximately 10.2 billion, in line with the 2024 target of low-single digit growth on an annual basis.
Fixed income portfolio continued to grow in the year ended 31 December 2024 to 4,212 million, and represents
16% of total assets. The portfolio is mostly measured at amortised cost and is highly rated with average rating
at Aa2. The amortised cost fixed income portfolio as at 31 December 2024 has an unrealised fair value gain of
32 million.
Separately, the Group focuses to continue improving revenues through multiple less capital-intensive initiatives,
with a focus on fees and commissions, insurance and non-banking opportunities, leveraging on the Group’s digital
capabilities.
During the year ended 31 December 2024, non-interest income stood at 272 million, down 9% on prior year,
mainly due to higher claims and recalibration of models in insurance business as well as subdued transactional
fees. Despite this, non-interest income remains an important profit contributor to the Group, covering almost
75% of the Group’s total operating expenses.
In 2024, net fee and commission income amounted to 177 million and was down by 2% compared to the
previous year, primarily due to lower transactional fees. Net fee and commission income is enhanced by
transaction fees from the Group’s subsidiary, JCC Payment Systems Ltd (JCC), a leading player in the card
acquiring and processing business and payment solutions, 75% owned by the Bank. JCC’s net fee and commission
income contributed 10% of total non-interest income and amounted to 28 million for the year ended 31
December 2024, down 4% year-on-year, primarily reflecting increased fee and commission expense due to higher
third-party commissions absorbed internally. Following a strategic review the Board of Directors concluded that
in line with the Group’s strategy and capital allocation policy, there is greater value to stakeholders through
retaining JCC as part of the Group.
The Group’s insurance companies, EuroLife and GI are respectively key market players in the life and general
insurance business in Cyprus, and have been providing recurring income, and generate the highest profitability
in the sector. The net insurance result for the year ended 31 December 2024 contributed 17% of non-interest
income and amounted to 46 million for the year ended 31 December 2024, down 14% on prior year impacted
by high claims and the recalibration of models. The insurance companies remain valuable and sustainable
contributors to the Group’s profitability.
Finally, the Group through the Digital Economy Platform (Jinius) (‘the Platform’) aims to support the national
digital economy by optimising processes in a cost-efficient way, allow the Bank to strengthen its client
relationships, create cross-selling opportunities as well as to generate new revenue sources over the medium
term, leveraging on the Bank’s market position, knowledge and digital infrastructure. Jinius is expected to
contribute to the Group by enhancing further the Group’s non-interest income through transaction and merchant
fees and enhance the Group’s digital footprint connecting e-commerce to financial services.
The first Business-to-Business services are already in use by clients and include invoice, remittance, tender,
ecosystem management and advertising. Currently, approximately 2,450 companies are registered in the
platform and approximately 1.1 billion cash were exchanged via the platform in 2024 and through invoicing and
remittance services. In February 2024, the Business-to-Consumer service was launched, a Product Marketplace
aiming to increase the touch points with customers. Currently approximately 200 retailers were onboarded in
fashion, technology, beauty, small appliances, personal care devices, home & garden, DIY, toys and bookstore
sectors and around 270 thousand products were embedded in the Marketplace.
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Business Overview (continued)
Lean operating model
Striving for a lean operating model is a key strategic pillar for the Group in order to deliver shareholder value,
without constraining investment in the business and funding in its digital transformation.
In 2024, the Group completed a small-scale, targeted VEP through which 57 full-time employees were approved
to leave at a total cost of approximately 9.5 million, recorded in staff costs in the year ended 31 December
2024. Since the beginning of the year, there was further branch footprint rationalization as the Group reduced
the number of branches by 5 to 55, a reduction of 8%.
The Group’s total operating expenses for the year ended 31 December 2024 amounted to 367 million, up 8%
on prior year, impacted by inflationary pressures mainly on staff costs, as well as higher professional fees for
ATHEX listing and higher marketing expenses on various campaigns. The cost to income ratio excluding special
levy on deposits and other levies/contributions for the year ended 31 December 2024 remained low at 34%.
Transformation plan
The Group‘s focus continues on deepening the relationship with its customers as a customer centric organisation.
The Group aims to enable the shift to modern banking by digitally transforming customer service, as well as
internal operations. The holistic transformation aims to (i) shift to a more customer-centric operating model by
defining customer segment strategies, (ii) redefine distribution model across existing and new channels, (iii)
digitally transform the way the Group serves its customers and operates internally, and (iv) improve employee
engagement through a robust set of organisational health initiatives.
Digital transformation
In the dynamic world of banking, the Group is a key player in digital banking innovation in Cyprus, reshaping the
banking experience into something more intuitive, more responsive, and more aligned with the contemporary
needs of its customers, consistently pushing the boundaries to offer unparalleled banking services. The Group
aims to continue to innovate, and simplify the banking journey, providing a unique and personalised experience
to each of its customers.
The Group’s digital channels continue to grow. As at 31 December 2024, the Group’s digital community has
increased to 480 thousand active subscribers, across Internet Banking and the BoC Mobile App, improving by 7%
year-on-year. Likewise, the BoC Mobile App, had 447 thousand active subscribers as at 31 December 2024, an
increase of 9% year-on-year.
During the year ended 31 December 2024, the Group continued to enrich and improve its digital portfolio with
new innovative services to its customers. During the first quarter of 2024, two new QuickPay features ‘Split the
Bill’ and ’Request Payments’ were launched in the BoC Mobile App, empowering users to share the cost with
others or request payments by adding just the contact number and the relevant amount. Additionally, the ability
to get a Car Loan for used cars has been added in QuickCar Loans. In the second quarter of 2024, the Bank’s
loyalty scheme ‘Pronomia’ was launched rewarding customers with several benefits, such as additional Antamivi
points, lower interest rates and no initial bank fees on new loans, and discounts on new insurance policies.
Furthermore, the ability to provide the beneficiary details for dividend payments was given to the Bank’s
shareholders. In July 2024, Bank of Cyprus was the first bank in Cyprus that enabled instant payments via digital
channels, providing the ability to the customer to make credit transfers in Euros, making the funds available in
the beneficiary customer’s account within ten seconds within Cyprus and outside Cyprus (to 36 countries in the
SEPA Zone) (limits for amounts for instant transfers apply). During the third quarter of 2024, the Bank’s Junior
App ‘Joey’ was launched, a banking app for kids and teens from 9-17 years old, providing autonomy in a secure
environment that enables them to develop money management skills and guardians to maintain control and
oversight. During the fourth quarter of 2024, the new QuickAccount Foreign currency was launched available in
Pound Sterling (GBP) and US Dollar (USD), offering customers a preferential FX pricing with live rates and without
any FX commission through BoC eFX Convert. A new innovative micro lending product ‘Fleksy’ was launched to
selected customer segments in BoC Mobile App enabling customers to apply for up to 3 thousand in credit to
use for online and in-store purchases, allowing them to repay in 3, 6 or 9 month instalments. Finally, the Digital
Housing Loan was launched to selected customer segments in Internet Banking, providing customers the ability
to apply for a Housing Loan digitally, recommending repayment options based on customers credit profile and
getting an instant decision. Both lending digital initiatives will be widely available in the first quarter of 2025.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
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Business Overview (continued)
Lean operating model (continued)
One of the Group’s digital innovations, Quickloans, accessible through both the BoC Mobile App and Internet
Banking, has transformed the traditional loan process, enabling customers to obtain a credit facility instantly,
without the need to visit a branch. Since the beginning of the year 2024, over 15.3 thousand applications were
disbursed, granting 107 million new digital loans and quick loans in the year ended 31 December 2024.
In collaboration with Genikes Insurance, the ability to purchase insurance policies is integrated into the BoC
Mobile App and was also made available via Internet Banking during the fourth quarter of 2024, enabling
customers to access car or home insurance plans through digital channels at preferential rates. Digital insurance
sales for the year ended 31 December 2024 amounted to 613 thousand, compared to 415 thousand for the
year ended 31 December 2023, reflecting 1,969 policies in the year ended 31 December 2024, compared to
1,410 policies for the year ended 31 December 2023.
Lastly, digital account openings increased by 68% in the year ended 31 December 2024 to 21,500 from 12,780
in the year ended 31 December 2023 and new debit cards more than doubled year-on-year to 23,380 in the year
ended 31 December 2024, compared to 11,530 in 2023.
Asset quality
As at 31 December 2024 the Group’s NPE ratio stood at 1.9% (pro-forma for held for sale) achieving its 2024
NPE ratio target early. This incorporates two agreements the Group entered into with a third party, in September
and December 2024, for the sale of NPEs with total net book value of approximately 23 million as at 31 December
2024. Completion is expected within the first half of 2025, subject to necessary approvals. The Group’s priorities
remain intact, maintaining high quality new lending with strict underwriting standards and preventing asset
quality deterioration.
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Strategy and Outlook
As the Group navigates through the cycle of widening of the monetary policy, it has established key priorities
going forward to maintain a strongly capitalised and highly profitable organisation delivering attractive returns to
shareholders, while simultaneously supporting the Group’s stakeholders and the broader economic environment.
These priorities are set below:
Driving new growth initiatives in both banking and non-banking areas (such as international and digital
respectively) to complement the strength of the domestic franchise whilst managing the current interest
rate headwinds
Maintaining a lean operating model via ongoing cost management discipline while continuing to re-invest
in the business
Protecting the quality of the balance sheet with continuous meticulous underwriting standards to ensure
asset quality in line with European sector
Providing attractive shareholder returns in line with European sector with focus on prudent management
of surplus capital and value creation
Leading the transition of Cyprus to a sustainable future and building a forward-looking organisation
embracing ESG in all aspects
During the year ended 31 December 2024 the Group continued to deliver compelling financial results, generating
a ROTE of over 20% for the second consecutive year, underpinned mainly by interest rate tailwinds. Embarking
into the cycle of interest rate normalisation towards 2%, the Group reiterates its target for the year ending 31
December 2025 of delivering high-teens ROTE on 15% CET1 ratio and mid-teens ROTE on reported equity,
corresponding to organic capital generation of approximately 300 basis points, which will support attractive
shareholder remunerations in the future.
This ROTE target factors in the current market expectations of the evolution of interest rates with ECB deposit
facility rate and six-month Euribor averaging to 2.3% each for the year ending 31 December 2025, compared to
3.7% and 3.5% respectively for the year ended 31 December 2024. As a result, the net interest income guidance
is updated and is expected to be below 700 million for the year ending 31 December 2025, reflecting mainly the
current forward curves. Other main assumptions incorporated to net interest income target for the year ending
31 December 2025 include:
Loan book to grow by approximately 4% in 2025 supported by domestic economic growth and expansion
of international lending
Deposit volumes to remain broadly stable at current levels (i.e. approximately 20 billion)
Cost of deposits to remain broadly flat on an annual basis, reflecting the time lag in deposit repricing
Fixed income portfolio to grow to approximately 18% of total assets by end-2025 and approximately 20%
in the medium-term, subject to market conditions
Hedging activity to continue to reduce further NII sensitivity
Higher wholesale funding costs in 2025, reflecting the full year impact of the 2024 senior preferred
issuance (coupon of 15 million p.a.)
Based on the average market forward rates for January 2025, interest rates are expected to reduce to
approximately 2% by June 2025 and remain broadly stable during 2026. Therefore, the net interest income for
2026 is expected to stabilise above 650 million.
Going forward, the Group aims to improve its net interest income through the growth of performing loan book by
approximately 4% per annum in the medium-term. The Group places emphasis on expanding its international
loan book; a portfolio comprising international, shipping and syndicated loans, by approximately 50% in the
medium-term to approximately 1.5 billion (from approximately 1.0 billion as at 31 December 2024),
capitalising on the customer base of IBU overseas and targeting selective industries in line with the Bank’s target
risk profile. Simultaneously, domestic loan portfolio is expected to grow supported by economic growth as well
as the gradual slowdown of loan repayments in a normalised interest rate environment.
Separately the Group aims to grow its non-interest income through less capital-intensive initiatives, with a focus
on fees and commission income and insurance. In the year ended 31 December 2024 the Group’s non-interest
income experienced a moderate drop of 9% on a yearly basis, mainly due to the high claims, recalibrations of
models of the insurance business and subdued transactional fees. Despite this, non-interest income remains an
important contributor to the Group profitability and covered almost 75% of its total operating expenses during
2024.
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Strategy and Outlook (continued)
For 2025 and beyond the Group targets net fees and commission income to grow by approximately 4% per
annum. The growth in net fee and commission income is expected to be supported by economic growth and
increased volume of transactions, whilst there are initiatives underway to enhance and diversify further this
revenue stream, mainly via Jinius, the customer-centric digital platform, leveraging mainly on the Group’s strong
digital capabilities and strong customer base. The Group aims to improve further the visibility of Marketplace,
enhance user experience, introduce new lifestyle products and facilitate in streamlining business operations
further. As a result of these actions, it is expected to enhance its Marketplace fees. Additionally, the Group aims
to offer high-quality, financial solutions to high-net worth customers with investible capital with the aim of growing
the assets under management of Private and Affluent Banking to 1.2 billion in the medium-term (from the
current 0.5 billion level).
Growth in the insurance income is expected to be driven by continuing strengthening the agency force, leveraging
on the bancassurance model potential, enhancing digital sales further and optimizing synergies between the life
and non-life insurance business. In this respect, total regular income for the life insurance business is expected
to rise by over 6% in the medium-term, whilst premium income for the non-life insurance business is expected
to rise by approximately 6% for the same period.
Maintaining cost discipline remains an ongoing focus for the Group. The cost to income ratio excluding special
levy on deposits or other levies/contributions is expected at approximately 40% for the year ending 31 December
2025, as the Group navigates to approximately 2% normalised interest rate environment. This will be facilitated
via ongoing staff optimisation to mitigate payroll cost inflation and staff reward schemes aiming to incentivize
individual performance. Simultaneously, the Group will continue reinvesting in the business and digital
transformation to support expansion of digital offering, improve customer experience and acceleration of sales.
Lastly, the use of AI technology aims to improve efficiency and enhance customer experience further.
In terms of asset quality, given the fact that the balance sheet de-risking is completed with the NPE ratio reduced
to below 2%, the cost of risk is expected towards the lower-end of the normalised levels of 40-50 basis points
for 2025.
Since 2019, the Real Estate Management Unit (REMU) repossessed stock has been consistently reducing, with
properties sold exceeding the book value of properties acquired, while inflows remain substantially reduced
following balance sheet derisking. Going forward, REMU sales are expected to continue, with expected inflows to
remain at limited levels. Therefore, the target of REMU portfolio to reduce to approximately 0.5 billion by end-
2025 is reiterated and the Group is well on track to achieve this target.
The Group aims to provide a sustainable return to shareholders. The distribution policy is upgraded in order to
reflect the steady sustained progress achieved over the last years, the profitability profile and medium-term
outlook of the Group. Ordinary distributions are expected to be in the range of 50-70% payout ratio of the Group’s
adjusted recurring profitability through a combination of cash dividends and share buybacks. Additionally, the
Board of Directors will also consider the introduction of interim distributions if it considers it appropriate to do so.
Overall, the Group reiterates its confidence of delivering high-teens ROTE on 15% CET1 ratio for 2026 and
beyond.
Targets and guidance are based on management’s current expectations as to the macroeconomic environment
and the business and are subject to change.
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Going concern
The Directors have made an assessment of the ability of the Group, the Company and BOC PCL to continue as a
going concern for a period of 12 months (the period of assessment) from the date of approval of the Consolidated
Financial Statements.
The Directors have concluded that there are no material uncertainties which would cast a significant doubt over
the ability of the Group, the Company and BOC PCL to continue to operate as a going concern for a period of 12
months from the date of approval of the Consolidated Financial Statements and the Financial Statements of the
Company.
In making this assessment, the Directors have considered a wide range of information relating to present and
future conditions, including projections of profitability, cash flows, capital requirements and capital resources,
liquidity and funding position, taking also into consideration the Group’s Financial Plan 2025-2028 approved by
the Board in February 2025 (the ‘Plan’) and the operating environment (as set out in section ‘Operating
Environment’ in the Directors’ Report’). The Group has sensitised its projection to cater for a downside scenario
and has used reasonable economic inputs to develop its medium-term strategy.
Capital
The Directors and Management have considered the Group’s forecasted capital position, including the potential
impact of a deterioration in economic conditions. The Group has developed capital projections under a base and
an adverse scenario and the Directors believe that the Group has sufficient capital to meet its regulatory capital
requirements throughout the period of assessment.
Funding and liquidity
The Directors and Management have considered the Group’s funding and liquidity position and are satisfied that
the Group has sufficient funding and liquidity throughout the period of assessment. The Group continues to hold
a significant liquidity buffer at 31 December 2024 that can be easily and readily monetised in a period of stress.
Viability statement
In accordance with the requirements of Provision 31 of the UK Corporate Governance Code 2018 (as amended),
as published by the Financial Reporting Council in the UK (‘UK Code’), the Directors have assessed the viability
of the Group, taking account of the Group’s current position and the potential impact of the principal risks that
the Group is facing.
Time horizon
The Directors have selected a three-year period for this assessment in arriving at the viability statement. This
period is chosen as it is within the period covered by the Group’s Financial Plan approved by the Board which
contains projections of profitability, capital and liquidity requirements and capital resources as well as within the
period covered by the Group’s stress testing programmes. This period is representative of the time horizon to
consider the impact of ongoing regulatory changes in the financial services industry. The Group’s Financial Plan
covers the period 2025–2028.
Planning process and assessment
The Directors have assessed the prospects of the Group through a number of sources, including the latest
Financial Plan of the Group, the Internal Capital Adequacy Assessment Process (‘ICAAP’) and the Internal Liquidity
Adequacy Assessment Process (‘ILAAP’) reports.
The Group’s Financial Plan takes into account the Group’s strategy, risk appetite and objectives in the context of
its operating environment including actual and reasonably expected changes in the Cyprus macroeconomic
environment, competitive landscape, margin pressures and capital requirements. The Board-approved risk
appetite framework is a key consideration of the Group's Financial Plan. Risks to the achievement of the Group’s
Financial Plan are identified and assessed through a Risk Assessment of the Financial Plan. Performance against
the risk appetite for each of the risk indicators is reported to the Board on a regular basis.
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Viability statement (continued)
Planning process and assessment (continued)
The ICAAP is a process, the main objective of which is to assess the Group’s capital adequacy in relation to the
level of underlying material risks that may arise from pursuing the Group’s strategy or from changes in its
operating environment. More specifically, the ICAAP analyses, assesses and quantifies the Group’s risks,
establishes the current and future capital needs for the material risks identified and assesses the Group’s
absorption capacity under both the baseline scenario and stress testing conditions, aiming to assess whether the
Group has sufficient capital, under both the base and stress case scenarios, to support its business and achieve
its strategic objectives as per its Board-approved Risk Appetite and Strategy.
The Group undertakes quarterly reviews of its ICAAP results as well as on an ad-hoc basis if needed, considering
the latest actual and forecasted information. During the quarterly review, any material changes/developments
since the annual ICAAP exercise are assessed in terms of capital adequacy. The 2024 quarterly ICAAP reviews
indicated that the Group has sufficient capital and available mitigants to support its risk profile and its business
and to enable it to meet its regulatory requirements, both under baseline and stressed conditions.
The ILAAP is a process, the main objective of which is to assess whether the volume and capacity of liquidity
resources available to the Group are adequate to support its business model, to achieve its strategic objectives
under both the base and severe stress scenarios, and to meet regulatory requirements.
The Group undertakes quarterly reviews of its ILAAP through quarterly liquidity stress tests, where actual and
forecasted information is considered. Any material changes since the year-end are assessed in terms of liquidity
and funding. The 2024 quarterly ILAAP reviews indicated that the Group maintains liquidity resources which are
adequate to ensure its ability to meet obligations as they fall due under ordinary and stressed conditions.
The 2024 ICAAP and ILAAP packages are due for submission to the SSM on 31 March 2025.
Risk management and assessment
The Group identifies, assesses, manages and monitors its risk profile based on the disciplines outlined within its
Risk Management Framework. The Group is exposed to a number of risks, the most significant of which are credit
risk, liquidity and funding risk, market risk (arising from adverse movements in interest rates, foreign currency
exchange rates, and in security and property prices), non-financial risks (mainly operational risk, compliance risk,
reputational risk, climate and environmental risks, information security and data quality risks) and strategic risk
(business model risks and macroeconomic risks). These risks are identified, monitored, managed and mitigated
through various control mechanisms and processes set out in the 'Principal risks and uncertainties-Risk
management and mitigation' section below. Similarly, the Group monitors the uncertain geopolitical environment
and the macroeconomic outlook and assesses and manages the potential impact on its operations.
Further, stress testing is an integral risk management principle used to assess the financial and operational
resilience of the Group. Stress tests are performed to assess the capital adequacy, liquidity and funding
availability. Internal scenarios used for the ICAAP are designed to be extreme but plausible and take account of
potential risk management actions. Reverse stress testing is also used to assess scenarios and circumstances
that could potentially make the Group’s business model unviable. These exercises begin with a definition of
business model failure e.g. a breach of capital minimum thresholds, and analyse potential events that could cause
such failure and the identification of appropriate mitigating actions. The results are reported to the Board Risk
Committee and the Board.
The Group has identified a suite of management actions which can be implemented to manage and mitigate the
impact of stress scenarios. Management actions’ impact on capital, liquidity and recovery planning under stress
conditions is assessed. This enables the Group to understand, monitor and control the risks identified.
Management believes that the stress testing process considers a range of severe but plausible scenarios.
However, stress tests should not be assumed to be an exhaustive assessment of all possible hypothetical extreme
or remote scenarios.
In making their viability assessment the Directors have considered a wide range of detailed information relating
to present and potential conditions, including projections for profitability, cash flows, capital and liquidity
requirements and capital and liquidity resources.
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Viability statement (continued)
Risk management and assessment (continued)
The Group has sensitised its baseline projections to cater for a downside scenario and has used conservative
economic inputs. The Financial Plan adverse scenario considers the capital forecast for the Group, and its ability
to withstand adverse scenarios such as the deterioration of the economic environment in Cyprus.
In addition to the information outlined above, the Directors have also considered a wide range of information and
a number of factors including but not limited to:
- The Group’s business and operating models and strategy.
- The Group’s approach to managing risk and allocating capital.
- The Group’s financial position considering performance, its ability to maintain minimum levels of
regulatory capital, liquidity and funding and the minimum requirements for own funds and eligible
liabilities over the period of the assessment.
- The Group’s strong capital position as at 31 December 2024.
- The Group’s strong liquidity position as at 31 December 2024.
The Directors confirm that based on their assessment of the principal risks and the assessment of the Group’s
current position and prospects, the Directors have a reasonable expectation that the Group will be able to continue
in operation and meet its liabilities as they fall due over the period to 31 December 2027.
Principal risks and uncertainties - Risk management and mitigation
As part of its business activities, the Group faces a variety of risks. The Group identifies, monitors, manages and
mitigates these risks through various control mechanisms. Credit risk, liquidity and funding risk, market risk
(arising from adverse movements in interest rates, foreign currency exchange rates, security prices and property
prices), insurance and re-insurance risk and operational risk, are some of the principal risks the Group faces. In
addition, principal risks facing the Group include geopolitical risk, legal risk, regulatory compliance risk,
information security and cyber risk, digital transformation and technology risks, climate related and
environmental risks, and business model and strategic risk.
Information relating to the principal risks the Group faces and risk management is set out in Notes 44 to 47 of
the Consolidated Financial Statements and in the ‘Risk and Capital Management Report’, both of which form part
of the Annual Financial Report for the year ended 31 December 2024. In addition, in relation to legal risk arising
from litigation, investigations, claims and other matters, further information is disclosed in Note 38 of the
Consolidated Financial Statements.
Additionally, the Group is exposed to the risk of changes in the value of property which is held either for own use
or as stock of property or as investment property. Stock of property is predominately acquired in exchange for
debt and is intended to be disposed of in line with the Group’s strategy. Further information is disclosed in Note
27 of the Consolidated Financial Statements.
As the war in Ukraine and the military conflict in the Middle east continue, considerable uncertainly is added to
the outlook for the global economy and the impact will largely depend on how these conflicts evolve. The Group
has limited direct exposure to both Ukraine and Russia as well as to Israel, and is continuously monitoring the
current affairs and remains vigilant to take precautionary measures as required.
The risk factors discussed above and in the reports referenced above should not be regarded as a complete and
comprehensive statement of all potential risks and uncertainties. There may be risks and uncertainties of which
the Group is not aware of, or which the Group does not consider significant, but which may become significant.
There are challenging conditions in global markets due to the high interest rate environment, inflationary
pressures, the geopolitical developments, the growing threat from cyberattacks and other unknown risks. As a
result the precise nature of all risks and uncertainties that the Group faces cannot be predicted with accuracy as
many of these risks are outside of the Group’s control.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
30
Events after the reporting date
Distribution in respect of 2024 earnings
In February 2025 the Company announced its proposal to make a total distribution of 241 million in respect of
2024 earnings, comprising an aggregate cash dividend of 211 million (calculated by reference to the number of
shares in issue as at 31 December 2024) and a share buyback in an aggregate consideration amount of up to
30 million (together, the ‘2024 Distribution’). The Board of Directors of the Company has resolved to propose
to the AGM that will be held on 16 May 2025 for approval, a final cash dividend of 0.48 per ordinary share in
respect of earnings for the year ended 31 December 2024. On 24 February 2025 the Company launched a
programme to buy back ordinary shares of the Company for an aggregate consideration of up to 30 million, for
which approval by the ECB has been received.
During the period from 24 February 2025 to 20 March 2025, 1,035 thousand ordinary shares have been bought
back at a total cost of 5,744 thousand. As at 20 March 2025, the Company holds 1,035 thousand ordinary
shares, all arising from the share repurchase programme.
No other significant non-adjusting events have taken place since 31 December 2024.
Capital base
Total equity excluding non-controlling interests totalled 2,810 million at 31 December 2024, compared to 2,467
million at 31 December 2023. The regulatory CET1 ratio on a transitional basis stood at 19.2% at 31 December
2024 and at 17.4% at 31 December 2023. The regulatory Total Capital ratio on a transitional basis at 31
December 2024 stood at 24.0%, compared to 22.4% at 31 December 2023.
Additional information on the regulatory capital is disclosed in the 'Risk and Capital Management Report' which
forms part of this Annual Financial Report and in the Pillar III Disclosures Report, which is published on the
Group’s website.
Share capital
As at 31 December 2024, there were 440,502,243 ordinary shares in issue, of a nominal value of 0.10 each.
During the year ended 31 December 2024, the number of shares in issue decreased by 5,698 thousand shares
and the value of the issued share capital decreased by 570 thousand, as shares were repurchased and cancelled
under a share repurchased programme (as detailed below). As a result, an equivalent amount of 570 thousand
has been transferred to the Company's capital redemption reserve by 31 December 2024. Additional information
about the authorised and issued share capital during 2024 and 2023 is disclosed in Note 34 of the Consolidated
Financial Statements.
Share repurchase programme (Buyback)
In April 2024, the Group launched its inaugural programme to buy back ordinary shares of the Company for an
aggregate consideration of up to 25 million (the ‘Programme’). The purpose of the Programme is to reduce the
Company’s issued share capital and therefore the shares purchased under the Programme are cancelled.
As at 29 November 2024, the Programme was successfully completed, resulting in the Company repurchasing
5,697,690 ordinary shares at a volume weighed average price of 4.39 per share for a total consideration of 25
million. All shares bought back were cancelled by 31 December 2024.
Capital redemption reserve
The capital redemption reserve is a legal reserve arising as a result of the acquisition and cancellation of the
Company’s ordinary shares under the buyback Programme announced in April 2024, and represents transfers
from share capital. The capital redemption reserve is not distributable. As at 31 December 2024, the capital
redemption reserve amounted to 570 thousand representing 5,698 thousand shares in the Company which have
been cancelled as a result of the Buyback Programme executed in 2024.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
31
Share-based payments - share awards
Long-term incentive award
During the Company’s AGM which took place on 20 May 2022, a special resolution was approved for the
establishment and implementation of the share-based Long-Term Incentive Plan of Bank of Cyprus Holdings
Public Limited Company (the ‘LTIP’), which is effective for ten years from the date of its adoption.
The LTIP is a share-based compensation plan for executive directors and senior management of the Group. The
LTIP provides for an award in the form of ordinary shares of the Company based on certain non-market
performance and service vesting conditions. Performance will be measured over a 3-year period. The performance
conditions are set by the Human Resources & Remuneration Committee (HRRC) each year and may be
differentiated to reflect the Group’s strategic targets and employee's personal performance, at its discretion.
Performance will be assessed against an evaluation scorecard consistent with the Group’s Medium Term Strategic
Targets containing both financial and non-financial objectives, and including targets in the areas of: (i)
Profitability; (ii) Asset quality; (iii) Capital adequacy; (iv) Risk control & compliance; and (v) Environmental,
Social and Governance ('ESG') targets and (iv) Customer Experience (targets in the area of Customer Experience
have been introduced for non-control functions from 2024). The awards ordinarily vest in six tranches, with 40%
vesting in the year following the year the performance period ends and the remaining 60% vesting in five equal
tranches (12%), on each annual anniversary following the first vesting date. For any award to vest the employee
must be in employment of the Group up until the date of the vesting of such an award. Awards are subject to
potential forfeiture under certain leaver scenarios. Under certain circumstances the HRRC has the discretion to
determine whether the award will lapse and/or the extent to which the award will be vested.
The maximum number of shares that may be issued pursuant to the LTIP until the tenth anniversary of the
relevant resolution shall not exceed 5% of the issued ordinary share capital of the Company, as at the date of
the resolution (being 22,309,996 ordinary shares of 0.10 each), as adjusted for any issuance or cancellation of
shares subsequently to the date of the resolution (excluding any issuances of shares pursuant to the LTIP). The
awards are not entitled to dividend equivalents in accordance with regulatory requirements.
Under the LTIP, share awards were granted by the Company in December 2022 (subject to a three-year
performance period 2022-2024), in October 2023 (subject to a three-year performance period 2023-2025) and
in April 2024 (subject to a three-year performance period 2024-2026). Each award vests in six tranches and
vesting is subject to service conditions. At 31 December 2024 the performance period for 2022 LTIP (performance
period 2022-2024) was concluded and the Board of Directors has approved in early 2025 the amounts of shares
to be awarded under the 2022 LTIP to eligible participants including the Executive Directors. The award will vest
in accordance to the vesting schedule set out above and is subject to continued service employment. The award
is also subject to malus and claw back conditions. Information on number of shares awarded is included in Note
49 of the Consolidated Financial Statements.
Short-term incentive award
Short-term incentive award refers to a Short-Term Incentive Plan established by the Company in 2023. This is
an annual incentive which involves variable remuneration in the form of cash to selected employees and is driven
by both delivery of the Company's Strategy, as well as individual performance, in the relevant year. Executive
Management are also eligible to be considered for the short-term incentive award. The short-term incentive award
is generally paid in cash and is non-deferred. However, in cases where the total variable remuneration amount
for an employee in a year (i.e., including amounts under both STIP and LTIP) exceeds a specified threshold as
per regulatory guidelines, at least 50% of the total variable remuneration for this employee is awarded in shares
and is deferred. In such cases, the award vests similarly to LTIP vesting, i.e. 40% vests in the year of the grant
i.e. following the performance year to which the incentive award relates to and the remaining 60% vests in
tranches (12%) over five years.
Shares vesting as part of the short-term incentive award are subject to one year retention period and 100% of
the award is subject to clawback provisions.
Further information on the long-term incentive and short-term incentive awards for the performance year 2024
in disclosed in Note 14 of the Consolidated Financial Statements and information for awards to Executive Directors
and Other Key Management personnel is disclosed in Note 49 of the Consolidated Financial Statements. The
Short-Term Incentive Plan award for the performance year 2024 will be in the form of cash.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
32
Treasury shares of the Company
The consideration paid, including any directly attributable incremental costs (net of income taxes), for shares of
the Company held by entities controlled by the Group is deducted from equity attributable to the owners of the
Company as treasury shares, until these shares are cancelled or reissued. No gain or loss is recognised in the
consolidated income statement on the purchase, sale, issue or cancellation of such shares.
The life insurance subsidiary of the Group, as at 31 December 2024, held a total of 142 thousand ordinary shares
of the Company of a nominal value of 0.10 each (2023: 142 thousand ordinary shares of the Company of a
nominal value of 0.10 each), as part of its financial assets which are invested for the benefit of insurance
policyholders (Note 34 of the Consolidated Financial Statements). The cost of acquisition of these shares was
21,463 thousand (2023: 21,463 thousand).
Change of control
There are no significant agreements to which the Company is a party and which take effect following a change of
control of the Company following a bid, but the Company is a party to a number of funding agreements that may
allow the counterparties to alter or terminate the agreements following a change of control. As at 31 December
2024, these agreements were not deemed to be significant in terms of their potential effect on the Group as a
whole given the liquidity position of the Group at the time, but the extent of their significance could vary
depending on the liquidity position at the time of the change of control.
The Group also has agreements which provide for termination if, upon a change of control of the Company, the
Company’s creditworthiness is materially worsened.
Other information
During 2024 and 2023 there were no restrictions on the transfer of the Company’s ordinary shares or securities
and no restrictions on voting rights other than the provisions of the Banking Law of Cyprus which requires
regulatory approval prior to acquiring shares of the Company in excess of certain thresholds, and the generally
applicable provisions including those of the Market Abuse Regulation and applicable takeover legislation. From
time to time, specific shareholders may have their rights in shares restricted in accordance with sanctions,
anti-corruption, anti-money laundering and/or anti-terrorism compliance, including sanctions relating to events
in Ukraine as applicable. The Group’s policy is to comply with all applicable laws, including sanctions and other
restrictive measures that apply at all times, and the Group may from time to time request individual shareholders
to refrain from exercising certain rights to facilitate compliance with such measures or related compliance issues.
Shares of the Company held by the life insurance subsidiary of the Group as part of its financial assets which are
invested for the benefit of insurance policyholders carry no voting rights, pursuant to the insurance law. The
Company does not have any shares in issue which carry special control rights.
There are no agreements between shareholders, known to the Company, which may result in restrictions on the
transfer of securities or voting rights.
Rights and obligations of ordinary shares
In accordance with the Company’s Constitution, the rights and restrictions attaching to the ordinary shares are
as follows:
- subject to the right of the Company to set the record dates for the purposes of determining the identity
of members entitled to notice of and/or to vote at a general meeting, the right to attend and speak at
any general meeting of the Company and to exercise one vote per ordinary share at any general meeting
of the Company;
- the right to participate pro rata in all dividends declared by the Company; and
- the right, in the event of the Company’s winding up, to participate pro rata in the distribution of the total
assets of the Company.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
33
Major holders of shares and financial instruments
As at 31 December 2024 and 10 March 2025, the Company has been advised of the following notifiable interests
in the share capital of the Company:
31 December 2024
Number of
ordinary shares
or Depositary
Interests
representing
Company
ordinary shares
% held
Financial
instruments with
similar economic
effect (Regulation
17(1)(b) of the
Transparency
(Directive
2004/109/EC)
Regulations 2007 of
Ireland as amended)
% held
Senvest Management LLC 40,100,080
9.10%
1,439,626
0.33%
Lamesa Investments Ltd 41,383,699
9.39%
-
-
CarVal Investors
26,955,322
6.12%
-
-
Caius Capital LLP
23,156,267
5.26%
-
-
European Bank for Reconstruction and Development (EBRD) 22,401,744
5.09%
-
-
Provident Fund of the Cyprus Bank Employees
21,221,863
4.82%
-
-
Wellington Management Group LLP
20,992,909
4.77%
-
-
Helikon Investments Limited 1,300,000
0.30%
15,686,876
3.56%
Osome Investments 14,809,498
3.36%
-
-
Eaton Vance Management
13,344,076
3.03%
-
-
10 March 2025
Number of
ordinary shares
or Depositary
Interests
representing
Company
ordinary shares
% held
Financial
instruments with
similar economic
effect (Regulation
17(1)(b) of the
Transparency
(Directive
2004/109/EC)
Regulations 2007 of
Ireland as amended)
% held
Senvest Management LLC 40,100,080
9.11%
1,439,626
0.33%
Lamesa Investments Ltd
41,383,699
9.41%
-
-
European Bank for Reconstruction and Development (EBRD) 22,401,744
5.09%
-
-
Provident Fund of the Cyprus Bank Employees 21,221,863
4.82%
-
-
Wellington Management Group LLP
20,992,909
4.77%
-
-
CarVal Investors
20,846,374
4.74%
-
-
Caius Capital LLP 19,868,913
4.52%
-
-
Helikon Investments Limited
1,300,000
0.30%
15,686,876
3.57%
Osome Investments
14,809,498
3.37%
-
-
Eaton Vance Management 13,344,076
3.03%
-
-
On 24 February 2025 the Company launched a programme to buy back ordinary shares of the Company for an aggregate
consideration of up to 30 million, as further explained in section ‘Distributions’ below. As a result, for the purposes of the
table above, the percentage holding as at 10 March 2025 has been calculated based on the total voting rights as of 10 March
2025, which do not include any shares that have been repurchased under the buyback programme launched on 24 February
2025, and held as treasury shares.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
34
Distributions
Based on the relevant SREP decisions in the years 2023 and 2024 any equity dividend distribution was subject
to regulatory approval, both for the Company and BOC PCL. The requirement for approval did not apply if the
distributions were made via the issuance of new ordinary shares to the shareholders which were eligible as
Common Equity Tier 1 Capital nor to the payment of coupons on any AT1 capital instruments issued by the
Company or BOC PCL. Based on the SREP decision for 2024, effective from 1 January 2025, the requirement for
prior regulatory approval for the declaration of dividends is no longer required.
Distribution in respect of 2024 earnings
In February 2025, the Company announced its proposal to make a total distribution of 241 million in respect of
2024 earnings, comprising an aggregate cash dividend of 211 million (calculated by reference to the number of
shares in issue as at 31 December 2024) and a share buyback in aggregate consideration amount of up to 30
million (together, the ‘2024 Distribution’). The 2024 Distribution corresponds to 50% payout ratio of the Group’s
FY2024 adjusted recurring profitability for the year ended 31 December 2024, at the top-end of the Group’s 2024
Distribution Policy and represents a significant increase both in terms of payout ratio and total quantum,
compared to prior year.
Cash dividend
The Board of Directors of the Company has resolved to propose to the AGM that will be held on 16 May 2025 for
approval, a final cash dividend of 0.48 per ordinary share in respect of earnings for the year ended 31 December
2024. The financial statements for the year ended 31 December 2024 do not reflect this dividend, which will be
accounted for in shareholders’ equity as an appropriation of retained earnings in the year ending 31 December
2025.
Share Buyback Programme
Following approval by the Board of Directors, on 24 February 2025 the Company launched a programme to buy
back ordinary shares of the Company for an aggregate consideration of up to 30 million, for which approval by
the ECB has been received. The shares will be repurchased on the Main Market of the Regulated Securities Market
of the ATHEX and the CSE and will be cancelled. The financial statements for the year ended 31 December 2024
do not reflect the impact of the share buyback programme, which will be accounted for as and when the shares
are repurchased by the Company.
The implementation of the share buyback programme will comply with the Company’s general authority to
repurchase the Company’s ordinary shares as approved by shareholders at the Company’s AGM on 17 May 2024,
which is subject to renewal at the AGM scheduled to take place on 16 May 2025, and with the terms of the
approval received from the ECB.
Distributions in respect of 2023 and 2022 earnings
In March 2024, the Company obtained the approval of the ECB to pay a cash dividend and to conduct a Share
Buyback Programme (together the ‘2023 Distribution’) in respect of earnings for the year ended 31 December
2023. The Distribution amounted to 137 million in total, comprising a cash dividend of 0.25 per ordinary share
(approved at the Company’s AGM held on 17 May 2024) amounting to 112 million, and a Share Buyback
Programme of up to 25 million.
In April 2023, the Company obtained the approval of the ECB to pay a dividend in respect of earnings for the
year ended 31 December 2022. The shareholders at the Company’s AGM, held on 26 May 2023 declared a final
cash dividend of 0.05 per ordinary share in respect of earnings for the year ended 31 December 2022. The
dividend amounted to 22 million in total.
Dividends and share buybacks are funded out of distributable reserves.
Books and significant records
The measures that the Directors have taken to secure compliance with the requirements of sections 281 to 285
of the Companies Act 2014 of Ireland (‘Companies Act 2014’), with regards to the keeping of accounting records,
include the allocation of appropriate resources to maintain adequate accounting records throughout the Company
and the Group, including the appointment of personnel with appropriate qualifications, experience and expertise.
The accounting records are maintained at the Company’s registered office at 10 Earlsfort Terrace, Dublin 2, D02
T380, Ireland and at 51 Stasinos Street, 2002 Strovolos, Nicosia, Cyprus.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
35
Research and development
In the ordinary course of business, the Group develops new products and services within its business lines.
Additional information is disclosed in the 'Business Overview' section of this Directors' Report.
Relevant audit information
In the case of persons who are Directors at the time this report is approved in accordance with section 330 of
the Companies Act 2014:
- the Directors hereby individually and collectively acknowledge, that so far as each Director is aware, there
is no relevant audit information of which the Company’s statutory auditors are unaware; and
- that he/she has taken all the steps that he/she ought to have taken as a Director in order to make
himself/herself aware of any relevant audit information and to establish that the Company’s statutory
auditors are aware of that information.
Preparation of periodic reporting
The Board is responsible for ensuring that management maintains an appropriate system of internal controls
which provides assurance of effective operations, internal financial controls and compliance with rules and
regulations. It has the overall responsibility for the Group and approves and oversees the implementation of the
Group’s strategic objectives, ESG and risk strategy and internal governance.
The Group has appropriate internal control mechanisms, including sound administrative and accounting
procedures, Information Technology (IT) systems and controls. The governance framework is subject to review
at least once a year.
Policies and procedures have been designed in accordance with the nature, scale and complexity of the Group’s
operations in order to provide reasonable but not absolute assurance against material misstatements, errors,
losses, fraud or breaches of laws and regulations.
The Board, through the Audit Committee and the Risk Committee, conducts reviews on a frequent basis, regarding
the effectiveness of the Group’s internal controls and information systems, as well as in relation to the procedures
used to ensure the accuracy, completeness and validity of the information provided to investors. The reviews
cover all systems of internal controls, including financial, operational and compliance controls, as well as risk
management systems. The role of the Audit Committee is inter alia to ensure the financial integrity and accuracy
of the Company’s financial reporting.
The Group’s financial reporting process is controlled using documented accounting policies and procedures
supported by instructions and guidance on reporting requirements, issued to all reporting entities within the
Group in advance of each reporting period. The submission of financial information from each reporting entity is
subject to sign off by the responsible financial officer.
Further analytical review procedures are performed at Group level. The internal control system also ensures that
the integrity of the accounting and financial reporting systems, including financial and operational controls and
compliance with legal and regulatory requirements and relevant standards, is adequate.
Where occasionally areas of improvement are identified these become the focus of management’s attention in
order to resolve them and thus strengthen the procedures that are in place. Areas of improvement may include
the formalisation of existing controls and the introduction of new information technology controls, as dependency
on information technology is ever increasing.
The Annual Financial Report in advance of its submission to the Board is reviewed and approved by the Executive
Committee. The Board, through the Audit Committee, scrutinises and approves the financial statements, results
announcements and the Annual Financial Report and ensures that appropriate disclosures have been made. This
governance process ensures that both management and the Board are given sufficient opportunity to challenge
the Group’s financial statements and other significant disclosures before their publication.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
36
Corporate Governance Statement
In April 2024, the CSE released the 6th Edition of the Corporate Governance Code (the ‘2024 CSE Code’). It is
mandatory for listed companies to incorporate a report by the Board of Directors on Corporate Governance,
known as the Corporate Governance Report, in their Annual Financial Report. In the first part of their Corporate
Governance Report companies are required to disclose their level of compliance with the 2024 CSE Code and the
extent of implementation of its principles. The second part necessitates an explicit confirmation from the
companies regarding their adherence to the provisions of the 2024 CSE Code. Additionally, in instances where
there is any deviation from the provisions of the 2024 CSE Code, companies are obligated to provide a
comprehensive explanation justifying the non-compliance.
Greek corporate governance law provisions, namely the provisions of articles 1-24 of Greek Law 4706/2020 (the
‘Greek Corporate Governance Regime’), apply only to companies whose registered seat is in Greece. As a result,
the Company, being a public limited company incorporated and registered in the Republic of Ireland, is not obliged
to follow and adhere to the Greek Corporate Governance Regime. Instead, the Company complies with the
corporate governance regime of the Republic of Ireland.
The Company has voluntarily chosen to adhere to the provisions of the UK Code. Following the delisting from the
international commercial companies secondary listing category of the Official List of the London Stock Exchange
(LSE), the Company continues to voluntarily adhere to the UK Code on a transitional basis. In accordance with
the Corporate Governance Report, it is hereby noted that the Group has applied the principles and complied with
the provisions of the UK Code, other than as set out in ‘Introduction and Compliance Statement Compliance
Statement (‘Second part’ for purposes of CSE Code categorisation)’ of the Corporate Governance Report for the
year 2024.
In relation to the 2024 CSE Code requirements for the first part of the Corporate Governance Report, the
Company, as an entity listed on the CSE, has formally adopted the 2024 CSE Code, and is actively implementing
its principles. In reference to the 2024 CSE Code requirements for the second part of the Corporate Governance
Report, it is affirmed that the Company adheres to the provisions of the 2024 CSE Code. The Corporate
Governance Report for the year 2024 includes a detailed narrative statement on how the principles of the 2024
CSE Code have been effectively applied. The narrative also covers principles of the UK Code and how these have
been applied throughout the year.
The rules governing the composition of the Board of Directors and the appointment and replacement of its
members are set out in section ‘Governance’ of the Corporate Governance Report for the year 2024. The powers
of the Board of Directors and committees of the Board with administrative, management and supervisory
functions, including any powers of the Directors in relation to the issuing or buying back by the Company of its
shares, are also set out in the Corporate Governance Report for the year 2024.
Any amendment or addition to the Articles of Association of the Company is only valid if approved by a special
resolution at a shareholders’ meeting.
A description of the operation of the shareholders' meeting, the key powers of the shareholders' meeting,
shareholders’ rights and the exercise of such rights are contained in section ‘Governance’ of the Corporate
Governance Report for the year 2024.
Details of restrictions in voting rights and special control rights in relation to the shares of the Company are set
out in the section ‘Other information’ above. Other information required to be disclosed for the purposes of the
European Communities (Takeover Bids (Directive 2004/25/EC)) Regulations 2006 is included on page 33.
In accordance with section 167 of the Companies Act 2014, the Directors confirm that a Board Audit Committee
is established. The Corporate Governance Report for 2024 details the role and responsibilities of the Board Audit
Committee and also includes a thorough account of the Board Audit Committee’s activities throughout the year
ended 31 December 2024. Furthermore, the Corporate Governance Report explicitly enumerates the members
of the Board Audit Committee and records the frequency of meetings held, as well as the attendance record of
each member for the reporting year.
Diversity information for the purposes of European Union Disclosure of Non-Financial and Diversity Information
by certain large undertakings and groups Regulations 2017, SI No. 360 of 2017 (as amended) is included in the
Corporate Governance Report for 2024 on pages 282 to 287.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
37
Corporate Governance Statement (continued)
The Corporate Governance Report for 2024 is included within this Annual Financial Report on pages 259 to 359
and contains the information required for the purposes of section 1373 of the Companies Act 2014.
The statements and information referred to in this Corporate Governance Statement are deemed to be
incorporated herein.
Directors’ Compliance Statement
As required by section 225 of the Companies Act 2014, the Directors acknowledge that they are responsible for
securing the Company’s compliance with its ‘relevant obligations’ (as defined in section 225(1) of the Companies
Act 2014). The Directors further confirm that a compliance policy statement has been drawn up setting out the
Company’s policies and that appropriate arrangements and structures have been put in place that are, in the
Directors’ opinion, designed to secure material compliance with the relevant obligations. A review of those
arrangements and structures has been conducted in the financial year to which this report relates.
Service agreements termination
The service contract of one of the Executive Directors in office as at 31 December 2024 includes a clause for
termination, by service of six months’ notice to that effect by the Executive Director but provided there is a
change of control of BOC PCL as this is defined in the service agreement. In such an event, the Executive Director
will be entitled to compensation as this is determined in the service contract. The terms of employment of the
other Executive Director are mainly based on the provisions of the collective agreement in place, which provides
for notice or compensation by BOC PCL based on years of service and for a four-month prior written notice by
the Executive Director, in the event of a voluntary resignation.
Political donations
Political donations are required to be disclosed under the Electoral Act 1997 of Ireland (as amended). Based on
the Donations, Sponsorships and Partnerships Policy of the Group, the Group does not sponsor political parties,
or any associations/organisations related directly, or indirectly, to one. The Directors, on enquiry, have satisfied
themselves that there were no political donations made during the year ended 31 December 2024.
Board of Directors
The members of the Board of Directors of the Company as at the date of this Directors' Report are listed on page
1. All Directors were members of the Board throughout the year and up to the date of this Directors’ Report
except as disclosed below.
On 26 September 2023 the Board of Directors nominated Mr William Stuart Birrell as a new member to the Board
of Directors. On 29 April 2024 ECB approved the appointment of Mr William Stuart Birrell as a member of the
Board of Directors and during the AGM on 17 May 2024, he was appointed to the Board of Directors.
On 30 August 2023 the Board of Directors nominated Mr Christian Philipp Hansmeyer as a new member to the
Board of Directors. On 29 April 2024 ECB approved the appointment of Mr Christian Philipp Hansmeyer as a
member of the Board of Directors and during the AGM on 17 May 2024, he was appointed to the Board of
Directors.
On 17 June 2024 the Board of Directors announced the death of Mr Constantine (Dinos) Iordanou, who had
served as a member of the Board of Directors since 29 November 2021 and also served as Senior Independent
Director.
In accordance with the Articles of Association at each AGM of the Company every Director who has been in office
at the completion of the most recent AGM since they were last appointed or reappointed, shall retire from office
and offer themselves for re-election if they wish.
The remuneration of the Board of Directors is disclosed in Note 49 of the Consolidated Financial Statements and
in the Remuneration Policy Report set out in the Corporate Governance Report.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Directors’ Report
38
Directors’ and Secretary’s interests
The interest in the share capital of the Company held by each member of the Board of Directors and the Company
Secretary, including interests of their close family members at 31 December 2024, is presented in the table
below:
Ordinary shares or
Depositary Interests
representing Company
ordinary shares of 0.10
each at 31 December 2024
Ordinary shares or
Depositary Interests
representing Company
ordinary shares of 0.10
each at 1 January 2024 or
at the date of appointment
Non-executive directors
Efstratios-Georgios (Takis) Arapoglou
106,500 106,500
Constantine
(Dinos)
Iordanou
(
passed
away on 16/06/2024)
n/a 1,395,449
Executive directors
Panicos Nicolaou
5,027 5,027
Eliza Livadiotou 35 35
Company Secretary
Katia Santis 5 5
111,567 1,507,016
The table above excludes awards under the Company’s long-term incentive plan and short-term incentive plan,
details of which are outlined on pages 348 to 350 and 355 to 359 of the Remuneration Policy Report.
Apart from the interests set out above, the Board of Directors and the Company Secretary had no other interests
in the shares of the Company or its subsidiaries at 31 December 2024.
Auditors
The Auditors, PricewaterhouseCoopers (‘PwC’) Chartered Accountants and Statutory Audit Firm, were
re-appointed as Auditors at the last AGM of the Company held on 17 May 2024 in accordance with section 383(2)
of the Companies Act 2014.
The Group commenced an external tender process for the Group’s statutory auditor. This process is being led by
the Audit Committee, and supported by management who will have an advisory role only. The Audit Committee
will make its recommendation to the Board for selection of the preferred firm. The successful firm will commence
the provision of services for the financial year ending 31 December 2027.
Non-financial Statement
In accordance with Part 28 of Companies Acts 2014, the Group has prepared a Sustainability Statement for the
year ended 31 December 2024. This Sustainability Statement is set out on pages 77 to 254 of the Annual Financial
Report 2024 and represents a dedicated section of the Directors' report. Information requirement in accordance
with the EU (disclosure of non-financial and diversity information by certain large undertakings and groups)
Regulations 2017 (the 'Irish NFRD Regulations') can be found in the Sustainability Statement.
The Sustainability Statement for the year ended 31 December 2024 has been prepared on a consolidated basis
for the Group. This is in line with the basis of consolidation used in the Group's financial statements.
Key intangible resources
The Group’s intangible resources, on which the Group depends and which are a source of value creation for the
Group, are set out in Note 26 Intangible assets of the Consolidated Financial Statements.
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Directors’ Report
39
Statement of Directors’ Responsibilities
The Directors are responsible for preparing the Annual Financial Report and the Financial Statements in
accordance with International Financial Reporting Standards (IFRSs) adopted by the EU and with those parts of
the Companies Act 2014 applicable to companies reporting under IFRSs, the EU (Credit Institutions: Financial
Statements) Regulations 2015 and, in respect of the consolidated financial statements, Article 4 of the
International Accounting Standards (IAS) Regulation. Company law requires the Directors to prepare Group and
Company financial statements for each financial year.
Under the Company law the Directors shall not approve the financial statements unless they are satisfied that
they give a true and fair view of the Group’s and Company’s assets, liabilities and financial position as at the end
of the financial year and of the profit or loss of the Group and the Company for the financial year and otherwise
comply with the Companies Act 2014.
In preparing these Financial Statements, the Directors are required to:
- select suitable accounting policies and apply them consistently;
- make judgements and estimates that are reasonable and prudent;
- state whether the financial statements have been prepared in accordance with IFRSs adopted by the EU
and ensure that they contain the additional information required by the Companies Act 2014; and
- prepare the financial statements on a going concern basis unless it is inappropriate to presume that the
Group and the Company will continue in business.
The Directors are responsible for keeping adequate accounting records that are sufficient to show and explain the
Company’s transactions, to disclose with reasonable accuracy at any time the assets, liabilities and financial
position of the Company and enable them to ensure that the financial statements comply with the provisions of
the Companies Act 2014 and Article 4 of IAS Regulation. The Directors, through the use of appropriate procedures
and systems, have also ensured that measures are in place to secure compliance with the Company’s and the
Group’s obligations to keep adequate accounting records. These accounting records are kept at the Company’s
registered office at 10 Earlsfort Terrace, Dublin 2, D02 T380, Ireland and at 51 Stasinos Street, 2002, Strovolos,
Nicosia, Cyprus.
In compliance with section 283 of the Companies Act 2014, the information and returns relating to the business
dealt with in the accounting records for 2024 have been sent to the registered office of the Company. The
Directors are also responsible for safeguarding the assets of the Group and the Company and hence for taking
reasonable steps for the prevention and detection of fraud and other irregularities.
The Directors are responsible for the preparation of the Sustainability Statement in accordance with Part 28 of
the Companies Act 2014 and including the Sustainability Statement in a clearly identifiable dedicated section of
the Directors’ Report.
The Directors are also responsible for designing, implementing and maintaining such internal controls that they
determine are necessary to enable the preparation of the Sustainability Statement in accordance with Part 28 of
the Companies Act 2014 that is free from material misstatement, whether due to fraud or error.
In preparing the Sustainability Statement, the Directors are required to:
- prepare the statement in accordance with the European Sustainability Reporting Standards (ESRS)
including the selection and application of appropriate sustainability reporting methods;
- disclose the double materiality assessment process performed to identify the information required to be
reported in the sustainability statement;
- prepare the disclosures within the environmental section of the sustainability statement, in compliance
with Article 8 of EU Regulation 2020/852 (the ‘Taxonomy Regulations’);
- ensure that the Group maintains adequate records for the preparation of the sustainability statement; 
- make judgements and estimates that are reasonable in the circumstances including the identification and
description of any inherent limitations in the measurement or evaluation of information in the
sustainability statement; and
- prepare forward-looking information, where applicable, on the basis of disclosed assumptions about
events that may occur in the future and possible future actions by the Group.
Risk and Capital Management Report
2024
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The Group’s approach to risk management
One of the Group’s main priorities is to continually improve its risk management framework to be able to respond
to the everchanging environment in an appropriate manner. Effective risk management is critical to the success
of the Group, and as such the Group maintains a risk management framework designed to ensure the safety
and soundness of the institution, protect the interests of depositors and shareholders and comply with regulatory
requirements. Clearly defined lines of authority and accountability are in place as well as the necessary
infrastructure and analytics to allow the Group to identify, assess, monitor and control risk.
1. Risk Management Framework (RMF)
The Board of Directors, through the Risk Committee (RC), is responsible to ensure that a coherent and
comprehensive Risk Management Framework (the ‘Framework’ or ‘RMF’) is in place, for the identification,
assessment, monitoring and controlling of all risks. The Framework ensures that there is proper governance and
process for the identification of material and emerging risks, including, but not limited to, risks that might
threaten the Group’s business model, future performance, liquidity and solvency. Such risks are taken into
consideration in defining the Group’s risk appetite, ensuring that the Group’s overall business strategy aligns
with the Group’s risk appetite and remains within the Group’s risk bearing capacity, always maintaining
appropriate capital and liquidity levels.
The RMF is supported by a strong governance structure and is comprised of several components that are
analysed in the sections below. The RMF is reviewed, updated and approved by the Board at least annually to
reflect any changes to the Group’s business or to take into consideration external regulations, corporate
governance requirements and industry best practices.
1.1 Risk Governance
The responsibility for the governance of risk at the Group lies with the Board of Directors (the ‘Board’) which is
ultimately accountable for the effective management of risks and for the system of internal controls in the Group.
The Board is assisted in its risk governance responsibilities by the Board Risk and Board Audit Committees (RC
and AC respectively) and at executive management level by the Executive Committee (EXCO), Asset and Liability
Committee (ALCO), Asset Disposal Committee (ADC), Technology Committee (TC), Sustainability Committee
(SC), Data Quality & Governance committee and the Credit Committee.
The RC supports the Board on risk oversight matters including the monitoring of the Group’s risk profile and of
all risk management activities whilst the AC supports the Board in relation to the effectiveness of the system of
internal controls. In addition, discussion and escalation processes are in place through both the Board
Committees and executive level committees that provide for a consistent approach to risk management and
decision-making.
Discussion around risk management is supported by the appropriate risk information submitted by the Risk
Management Division (RMD) and Executive Management. The Chief Risk Officer (CRO) or his representatives
participate in all such key committees to ensure that the information is appropriately presented, and that RMD’s
position is clearly articulated.
Furthermore, the roles of the CEO and the Group CRO are critical as they carry specific responsibilities with
respect to risk management. These include:
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1. Risk Management Framework (RMF) (continued)
1.1 Risk Governance (continued)
Chief Executive Officer (CEO)
The CEO is accountable for leading the development of the Group’s strategy and business plans in a manner
that is consistent with the approved risk appetite and for managing and organising executive management to
ensure these are executed. It is the CEO’s responsibility to manage the Group’s financial and operational
performance within the approved risk appetite.
Chief Risk Officer (CRO)
The CRO leads an independent RMD across the Group including its subsidiaries. The CRO is responsible for the
execution of the Risk Management Framework and the development of risk management strategies. The CRO is
expected to challenge business strategy and overall risk taking and risk governance within the Group and
independently submit his findings, as necessary, to the RC. The CRO reports to the RC and for administrative
purposes has a dotted line to the CEO, as presented in the organizational diagram below.
1.2 Organisational Model
The RMD is responsible for the risk identification and risk management of the Group on a day-to-day basis. The
risk management process is integrated into the Group’s internal control system. The RMD is organized into
several departments, each of which is specialized in one or several categories of risks. The organization of RMD
reflects the types of risks inherent in the Group.
*The Data Quality and Governance Unit of the Data Office & Risk Analytics Department directly reports through its manager
to the Data Quality & Governance committee chaired by the Executive Director People & Change.
RMD organisational model
The RMD operates independently through:
- Organisational independence from the controlled activities;
- Unrestricted and direct access to executive management and the Board, either through the RC or directly;
- Direct and unconditional access to all business lines that have the potential to generate material risk to
the Group. Front line managers are required to cooperate with the RMD managers and provide access to
all records and files of the Group, as well as any other information necessary;
- A separate and independent budgeting process whereby the RMD’s budget is submitted to the RC for
approval;
- The CRO is a member of the EXCO and holds voting as well as veto rights in key executive and operational
committees.
Furthermore, this independence is also ensured as:
- The CRO is assessed annually by the RC that is jointly responsible with the Human Resources &
Remuneration Committee;
- The CRO maintains a close working relationship with both the RC and its Chairperson which includes
regular and frequent direct communication both during official RC meetings, as well as unofficial meetings
and discussions.
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1. Risk Management Framework (RMF) (continued)
1.2 Organisational Model (continued)
The RMD organisational model is structured so as to:
- Define risk appetite and report regularly on the status of the risk profile;
- Ensure that all material and emerging risks have proper ownership, management, monitoring and clear
reporting;
- Promote proper empowerment in key risk areas that will assist in the creation of a robust risk culture;
- Provide tools and methodologies for risk management to the business units;
- Report losses from risks identified to the EXCO, the RC and the Board and, where necessary, to the
Regulatory Authorities;
- Collect and monitor Key Risk Indicators (KRIs).
1.3 Risk Identification
The risk identification process is comprised of two simultaneous but complementary approaches, namely, the
top-down and the bottom-up approaches. The top-down process is led by Senior Management and focuses on
identifying the Group’s material risks, whilst in the bottom-up approach risks are identified and captured through
several methods such as the Risk and Control Self-Assessment (RCSA) process, incident capture, fraud events
capture, regulatory audits, direct engagement with specialized units and other. The risks captured by these
processes are compiled during the annual ICAAP process and its quarterly updates and form the Groups’ material
risks.
To ensure a complete and comprehensive identification of risks the Group has integrated several key processes
into its risk identification process, including the:
- Internal Capital Adequacy Assessment Process (ICAAP);
- Internal Liquidity Adequacy Assessment Process (ILAAP);
- Stress testing;
- Group Financial Plan compilation process;
- Regulatory, internal and external reviews and audits.
1.4 Three Lines of Defence
The Group complies with the regulatory guidelines for corporate governance and has established the "Three
Lines of Defence" model as a framework for effective risk and compliance management and control. The three
lines of defence model defines the responsibilities in the risk management process ensuring adequate
segregation in the oversight and assurance of risk.
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1. Risk Management Framework (RMF) (continued)
1.4 Three Lines of Defence (continued)
First Line of Defence
The first line of defence includes functions that own and manage risks as part of their responsibility for achieving
objectives and are responsible for implementing corrective actions to address, process and control deficiencies
identified in their processes. It comprises of the management and staff of business lines and support functions
who are directly responsible for the delivery of products and/or services. Support functions include but are not
limited to the human resources, legal services, information technology, central operations, etc. The first line of
defence ensures that controls are designed into systems and processes under the guidance of the second line
of defence.
Second Line of Defence
The second line of defence includes functions that oversee the compliance of the first line management and staff
with the regulatory framework and risk management principles. It comprises of the RMD, Information Security
and Compliance functions. The second line of defence sets the corporate governance framework of the Group
and establishes policies and guidelines that the business lines and support functions, Group entities and staff
should operate within. The second line of defence also provides support, as well as independent oversight of the
risk profile and risk framework.
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1. Risk Management Framework (RMF) (continued)
1.4 Three Lines of Defence (continued)
Third Line of Defence
The third line of defence is the Internal Audit Division (IA) which provides independent assurance to the Board
and the EXCO on the design adequacy and operating effectiveness of the Group’s internal control framework,
corporate governance and risk management processes, including the manner in which the first and second lines
of defence achieve risk management and control objectives. Findings are communicated to the Board through
the committees and senior management and other key stakeholders, with remediation plans monitored for
progress against agreed completion dates.
1.5 Risk Appetite Framework (RAF)
The objective of the Risk Appetite Framework (RAF) is to set out the level of risk that the Group is willing to
take in pursuit of its strategic objectives, outlying the key principles and rules that govern the risk appetite
setting. It comprises the Risk Appetite Statement (RAS), the associated policies and limits where appropriate,
as well as the roles and responsibilities for the implementation and monitoring of the RAF.
The RAF has been developed in order to be used as a key management tool to better align business strategy
(financial and non-financial targets) with risk management, and it should be perceived as the focal point for all
relevant stakeholders within the Group, as well as the supervisory bodies, for the assessment of whether the
undertaken business activities are consistent with the set risk appetite.
The RAF is one of the main elements of the Risk Management Framework which includes, among others, a
number of frameworks, policies and circulars that address the principal risks of the Group.
Risk Appetite Statement (RAS)
The RAS is the articulation, in written form, of the aggregate level and types of risk that the Group is willing to
accept in the course of executing its business objectives and strategy. It includes qualitative statements as well
as quantitative measures expressed relative to Financial, Non-Financial and Strategic risks. As part of the overall
framework for risk governance, it forms a boundary condition to strategy and guides the Group in its risk-taking
and related business activities.
Risk appetite and Financial Plan interaction
The Group’s Financial Plan is integral to how the Group manages its business and monitors performance. It
informs the delivery of the Group’s strategy and is aligned to the Risk Appetite Statement. The RAS is subject
to an annual review process during the period in which the Group Financial Plan as well as the divisional strategic
plans are being formulated. The interplay between these processes provides for a cycle of feedback during which
certain RAS indicators (such as the ones related to minimum regulatory requirements) act as a backstop to the
Group’s Financial Plan, while for other indicators the Group Financial Plan provides input for risk tolerance
setting. Furthermore, the Group Financial Plan is tested against the RAS indicators to ensure it is within the
Group’s risk appetite.
Risk Appetite monitoring
To ensure that the risk profile of the Group is within the approved risk appetite, a consolidated risk report and
a risk appetite profile report are regularly reviewed and discussed by the Board and the RC.
Where a breach of a RAS indicator occurs, the Risk Appetite Framework provides the necessary escalation
process to analyse the materiality and nature of the breach, notify the appropriate authorities and decide the
necessary remediation actions.
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1. Risk Management Framework (RMF) (continued)
1.6 Risk Taxonomy
In order to ensure that all risks the Group may face are identified and managed, a risk taxonomy is in place
which is a key component of the Internal Capital Adequacy Assessment Process (ICAAP) and the Internal
Liquidity Adequacy Assessment Process (ILAAP). The taxonomy ensures that the coverage of risks is
comprehensive and identifies potential linkages between risks.
The risk taxonomy provides a categorisation of different risk types/factors enabling the Group to assess,
aggregate and manage risks in a consistent way through a common risk language and mapping. It comprises
of several levels of risks in increasing granularity and supports a multi-level tree categorization to enhance the
overall risk classification. This risk categorization is also used to accommodate additional regulatory compliance
requirements and internal risk analysis and reporting needs.
1.7 Risk measurement and reporting
The RMD uses several systems and models to support key business processes and operations, including stress
testing, credit approvals, fraud risk and financial reporting. The RMD has established a model governance and
validation framework to help address risks arising from model use.
Additionally, the RMD:
- Maintains a categorization and definitions of risks and terminologies used throughout the Group;
- Collates reports of Key Risk Indicators (KRIs) and other relevant risk information. When limit violations
occur, escalation and reporting procedures are in place;
- Checks that risk information provided by management is complete and accurate and management has
made all reasonable endeavour to identify and assess all key risks;
- Ensures that the risk information submitted to the RC and the Board by RMD and management is
appropriate and enables monitoring and control of all the risks faced by the Group;
- Discloses risk information externally and prepares reports on significant risks in line with internal and
external regulatory requirements.
Stress testing
Stress testing is a key risk management tool used by the Group to provide insights on the behaviour of different
elements of the Group in a crisis scenario and to assess the Group’s resilience and capital and liquidity adequacy.
To make this assessment, a range of scenarios is used, based on variations of market, economic and other
operating environment conditions. Stress tests are performed for both internal and regulatory purposes and
serve an important role in:
- Understanding the risk profile of the Group;
- Evaluating whether there is sufficient capital or adequate liquidity under stressed conditions (ICAAP and
ILAAP) so as to put in place appropriate mitigants;
- Evaluating of the Group’s strategy;
- Establishing or revising limits;
- Assisting the Group to understand the events that might push the Group outside its risk appetite.
The Group carries out the stress testing process through a combination of bottom-up and top-down approaches.
Scenario and sensitivity analysis follows a bottom-up approach, whereas reverse stress testing follows a top-
down approach.
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1. Risk Management Framework (RMF) (continued)
1.7 Risk measurement and reporting (continued)
If the stress testing scenarios reveal vulnerability to a given set of risks, management makes recommendations
to the Board, through the RC, for remedial measures or actions.
The Group’s stress testing programme embraces a range of forward-looking stress tests and takes all the Group’s
material risks into account. These key internal exercises include:
Stress testing undertaken in support of the Internal Capital Adequacy Assessment Process (ICAAP);
Stress testing applied to the funding and liquidity plan in support of the Internal Liquidity Adequacy
Assessment Process (ILAAP) to formally assess the Group’s liquidity risks;
Annual recovery stress tests which use scenarios to assess the adequacy of recovery indicators of both
capital and liquidity in identifying the recovery plan options used to exit that stress;
Ad hoc stress testing as and if required, including in response to regulatory requests.
Other business and specific risk type stress tests
The Market and Liquidity Risk Department performs additional stress tests, which include the following:
- Monthly stress testing for interest rate risk (2% shock on Economic Value (EV));
- Quarterly stress testing for interest rate risk (2% shock on Net Interest Income (NII));
- Quarterly stress testing for interest rate risk (based on the six predefined Basel interest rate scenarios
which involve flattening, steepening, short up, short down, parallel up, parallel down shocks);
- Quarterly stress testing on items that are marked to market: impact on profit/loss and reserves is
indicated from changes in interest rates and prices of bonds and equities.
ICAAP
The ICAAP is a process whose main objective is to assess the Group’s capital adequacy in relation to the level
of underlying material risks that may arise from pursuing the Group’s strategy or from changes in its operating
environment. More specifically, the ICAAP analyses, assesses and quantifies the Group’s material risks,
establishes the current and future capital needs for the material risks identified, and assesses the Group’s capital
adequacy under both the baseline scenario and stress testing conditions, aiming to assess whether the Group
has sufficient capital, under both the base and stress scenarios, to support its business and achieve its strategic
objectives as per the Board approved Risk Appetite and Strategy.
The Group undertakes quarterly reviews of its ICAAP results as well as on an ad-hoc basis if needed, which are
submitted to the ALCO and the RC, taking into consideration the latest actual and forecasted information. During
the quarterly review, the Group’s risk profile is reviewed and any material changes/developments since the
annual ICAAP exercise are assessed in terms of capital adequacy.
The 2024 annual ICAAP package will be submitted to the ECB on 31 March 2025, indicating that the Group has
sufficient capital and available mitigants to support its risk profile and its business and to enable it to meet its
regulatory requirements, both under baseline and stressed conditions.
ILAAP
The ILAAP is a process whose main objective is to assess whether the volume and capacity of liquidity resources
available to the Group are adequate to support its business model, to achieve its strategic objectives under both
the base and severe stress scenarios, and to meet regulatory requirements, including the LCR and the NSFR.
The Group undertakes quarterly reviews of its ILAAP results through quarterly liquidity stress tests which are
submitted to the ALCO and the RC, where actual and forecasted information is considered. Any material changes
since the annual ILAAP exercise are assessed in terms of liquidity and funding.
The 2024 annual ILAAP package will be submitted to the ECB on 31 March 2025, indicating that the Group
maintains liquidity resources which are adequate to ensure its ability to meet obligations as they fall due under
ordinary and stressed conditions.
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1. Risk Management Framework (RMF) (continued)
1.8 The Group participated in the Fit-for-55 exercise.
During 2024, the Group participated in the European Banking Authority (“EBA”) “Fit-for-55” climate risk scenario
analysis exercise. The exercise was part of the new mandates received by the EBA in the scope of the European
Commission's Renewed Sustainable Finance Strategy. Under the European Green Deal, all 27 EU Member States
committed to turning the EU into the first climate-neutral continent by 2050 and pledged to reduce emissions
by at least 55% by 2030, compared to 1990 levels. The one-off Fit-for-55 climate risk scenario analysis aimed
at assessing the resilience of the financial sector in line with the Fit-for-55 package and to gain insights into the
capacity of the financial system to support the transition to a lower carbon economy under conditions of stress.
1.9 The Group participated in the ECB Cyber Resilience Stress Test
The Group participated in the cyber resilience stress test exercise conducted by the ECB in the first half of 2024.
The aim was to assess the cyber-resilience posture for all SSM Significant Institutions. In more detail, the
objective of the exercise was to assess how banks respond to and recover from a cyberattack, rather than their
ability to prevent it. The findings and lessons learned were discussed as part of the 2024 Supervisory Review
and Evaluation Process.
1.10 2025 EU wide stress test
The Group is participating in the 2025 EU-wide stress test exercise. Balance sheets are assumed to remain
constant with reference date 31 December 2024, with the primary focus being the evaluation of the impact of
adverse shocks on solvency. The exercise is designed to provide valuable input for assessing the resilience of
the European banking sector in a hypothetical adverse macroeconomic scenario. The exercise was launched in
January 2025 and the results will be published in August 2025. The stress test results will be used to update
each bank’s Pillar 2 guidance in the context of the Supervisory Review and Evaluation Process
(SREP). Qualitative findings on weaknesses in banks’ stress testing practices could also affect banks’ scores
related to risk data aggregation capabilities and thus their Pillar 2 requirements.
2. Recovery and resolution planning
The Group’s recovery plan sets out the arrangements and measures that the Group could adopt in the event of
severe financial stress to restore the Group to long term viability. A suite of indicators and options are included
in the Group’s recovery plan, which together present the identification of stress events and the tangible
mitigating actions available to the Group to restore viability. The Group’s recovery plan is approved by the Board
on the recommendation of the RC and ALCO.
The Group resolution plan is prepared by the Single Resolution Board in cooperation with the National Resolution
Authority (Central Bank of Cyprus). The resolution plan describes the Preferred Resolution Strategy (PRS), in
addition to ensuring the continuity of the Group’s critical functions and the identification and addressing of any
impediments to the Group’s resolvability. The PRS for the Group is a single point of entry bail-in via BOC PCL.
The resolution authorities also determine the Minimum Requirements for own funds and Eligible Liabilities
(MREL) corresponding to the loss absorbing capacity necessary to execute the resolution.
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3. Risk Culture
A robust risk culture is a substantial determinant of whether the Group will be able to successfully execute its
strategy within its defined risk appetite. The RMD is committed to fostering a robust governance and risk culture
that aligns with the Group's strategic objectives and risk appetite. This includes ensuring that risk management
practices are integrated into all aspects of the business, promoting a culture of risk awareness, and maintaining
effective communication and accountability across the Group.
An action plan towards the implementation of a firm-wide risk culture is in place across the Group involving
various stakeholders including all the control functions, human resources, legal services, Company’s secretary
office and other. The action plan is under the auspices of the Chief Risk Officer and the Executive Director People
and Change and the Board retains close oversight through Mr Adrian John Lewis, Senior Independent Director.
The RMD has a leading role in the action plan which includes, among other actions, the measurement of risk
culture, both at Bank wide and divisional level, through a specific Risk Culture Dashboard, the communication
of a series of topics aiming at re-enforcing risk culture and the provision of specific training for areas such as
credit underwriting and other risk management related topics.
Other actions include the introduction and formalisation of the role of the ‘Business Risk and Control Officers’,
dedicated control functions liaisons for non-financial risks, within the business lines.
4. Principal Risks
As part of its business activities, the Group faces a variety of risks. The principal and other risks faced by the
Group are described below as well as the way these are identified, assessed, managed and monitored by the
Group, including the available mitigants. The risks described below, should not be regarded as a complete and
comprehensive statement of all potential risks, uncertainties or mitigants as other factors either not yet
identified or not currently material, may also adversely affect the Group.
4.1 Credit Risk
Credit risk is defined as the current or prospective risk to earnings and capital arising from an obligor’s failure
to meet the terms of any contract with the Group (actual, contingent or potential claims both on and off balance
sheet) or failure to perform as agreed. Within the general definition of credit risk, the Group identifies and
manages the following types of risk:
Counterparty credit risk (CCR): the Group’s credit exposure with other counterparties. The risk of
losses arising as a result of the counterparty not meeting their contractual obligations in full and on
time.
Settlement risk: the risk that a counterparty fails to deliver the terms of a contract with the Group.
Issuer risk: the risk of losses arising from a credit deterioration of an issuer of instruments in which
the Group has invested.
Concentration risk: the risk that arises from the uneven distribution of exposures (i.e. credit
concentration) to individual borrowers or by industry, collateral, product, currency, economic sector or
geographical region.
Country risk: the Group’s credit exposure arising from lending and/or investments or the presence of
the Group in a specific country.
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4. Principal Risks (continued)
4.1 Credit Risk (continued)
In order to manage these risks, the Group has a Credit Risk Management function within RMD that:
- Develops policies, guidelines and approval limits necessary to manage and control or mitigate the
credit and concentration risk in the Group. These documents are reviewed and updated at least
annually, or more frequent if deemed necessary, to reflect any changes in the Group’s risk appetite
and strategy and consider the market environment or any other major changes from external or
internal factors that come into effect;
- Evaluates credit applications from an independent credit risk perspective before submission for
approval to Credit Committee 3, the RC, or the Board. This ensures compliance with the Group’s risk
appetite, policies, and guidelines, supporting the role of the observer who holds veto rights;
- Participates as an observer in the Credit Committee 3 and in specific cases that fall under the approving
authority of Corporate Sanctioning as delegated by the CRO;
- Sets KRIs for monitoring the loan portfolio quality and adopts a proactive monitoring approach for such
risks;
- Measures the expected credit losses in an appropriate way in order to have a fair representation of the
loan book in the financial statements of the Group.
The Group sets and monitors risk appetite limits relating to credit risk. Furthermore, a limits framework is in
place in relation to the credit granting process and also the general rules are documented in the Group’s Lending
Policy. Relevant circulars and guidelines are in place that provide parameters for the approval of credit
applications and related credit limits. The Group has established credit approving authorities, which are
authorised to approve the granting, review and restructuring of credit facilities in the Bank, including the Credit
Sanctioning Department and the Credit Committee 3. Credit Committee 3 is comprised of members from various
Group divisions outside RMD to ensure independence of opinion. Applications falling outside the approval limits
of Credit Committee 3 are submitted to the RC or the Board, depending on the total exposure of the customer
group.
The Group has adopted methodologies and techniques for credit risk identification. These methodologies are
revised and modified whenever deemed necessary to reflect changes in the financial environment and adjusted
to be in line with the Group’s overall strategy and its short-term and long-term objectives.
The Group dedicates considerable resources to assess credit risk and to correctly reflect the value of its on-
balance and off-balance sheet exposures in accordance with regulatory and accounting guidelines. This process
can be summarised in the following stages:
Analysing performance and asset quality
Measuring exposures and concentrations
Raising allowances for impairment
Furthermore, post-approval monitoring is in place to ensure adherence to both terms and conditions set in the
approval process and credit risk policies and procedures. A key aspect of credit risk is credit risk concentration
which is defined as the risk that arises from the uneven distribution of exposures to individual borrowers, specific
industry or economic sectors, geographical regions, product types or currencies. The monitoring and control of
concentration risk is achieved by limit setting (e.g. sector and name limits) and reporting them to senior
management.
Approved policies and procedures are in place for the approval of credit and settlement limits per counterparty
based on the business needs, current exposures and investment plans. Counterparty credit and settlement limits
for Treasury transactions are monitored real-time through the Treasury front to back system.
With the aim of identifying credit risk at an early stage, a number of key reports are prepared for the EXCO
and/or the Board. Indicatively, these include a credit quality dashboard which analyses, among others, the
overall loan book performance, forborne facilities, the performance of new lending, specific products or
portfolios, new forbearances and modifications and other portfolio quality KPIs.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Risk and Capital Management Report
52
4. Principal Risks (continued)
4.1 Credit Risk (continued)
Country Risk
Country Risk refers to the possibility that borrowers of a particular country may be unable or unwilling to fulfil
their foreign obligations for reasons beyond the usual risks which arise in relation to all lenders. Country risk
affects the Group via its operation in other countries and also via investments in other countries (Money Market
(MM) placements, bonds, shares, derivatives, etc.). In addition, the Group is indirectly affected by credit facilities
provided to customers for their international operations or due to collateral in other countries. In this respect,
country risk is considered in the risk assessment of all exposures, both on-balance sheet and off-balance sheet.
Country risk exposures are the aggregation of the various on-balance sheet and off-balance sheet exposures
including investments in bonds, money market placements, loans or guarantees to residents of a
country/companies incorporated in a country, letters of credit, properties etc.
The Group monitors country risk and on a quarterly basis reports to ALCO exposures by country and compares
these against approved country limits. The Board, through the RC is also informed on a regular basis and at
least annually. Any limit breaches are included in the regular reporting to ALCO, EXCO and RC. The country
limits are allocated based on the CET1 capital of the Group, the country's credit rating and internal scoring.
Credit Risk Mitigation
The fundamental lending principle of the Group is to approve applications and provide credit facilities only when
the applicant has the ability to pay and where the terms of these facilities are consistent with the customers’
income and financial position, independent of any collateral that may be assigned as security and in full
compliance with all external laws, regulations, guidelines, internal codes of conduct and other internal policies
and procedures. The value of collateral is not a decisive factor in the Group’s assessment and approval of any
credit facility, since collaterals may only serve as a secondary source of repayment in case of default.
Collaterals are used for risk mitigation. Collaterals are considered as an alternative means of debt recovery in
case of default. Collateral by itself is not a predominant criterion for approving a loan, except when the loan
agreement envisages that the repayment of the loan is based on the sale of the property pledged as collateral
or liquid collateral provided (e.g. cash). The Group’s requirements around completion, valuation and
management of collateral are set out in appropriate Group policies.
Credit risk mitigation is also implemented through a number of policies, procedures, guidelines circulars and
limits. Policies are approved by the RC/Board and include the:
Lending Policy
Write-off policy
Concentration Risk Policy
Valuation Policy
Credit Risk Monitoring Policy
Environmental & Social Policy
Asset Acquisition and Disposal Policy for Debt Settlement
Loan Syndication Policy
Green Lending Policy
Shipping Finance Policy
Early Warning Policy
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Risk and Capital Management Report
53
4. Principal Risks (continued)
4.1 Credit Risk (continued)
Systems
The effective management of the Group’s credit risk is achieved through a combination of training and
specialisation as well as appropriate credit risk assessment (risk rating) systems. The Group continuously
upgrades the systems and models used in assessing the creditworthiness of Group customers. Additionally, the
Group continuously upgrades the systems and models for the assessment of credit risk so as to correctly reflect
the value of its on-balance and off-balance sheet exposures in accordance with regulatory and accounting
guidelines.
The analysis of loans and advances to customers in accordance with the EBA standards is presented
below.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Risk and Capital Management Report
54
4. Principal Risks (continued)
4.1 Credit Risk (continued)
The tables below present the analysis of loans and advances to customers in accordance with the EBA standards.
Gross loans and advances to customers
Accumulated impairment, accumulated negative changes in fair value due to
credit risk and provisions
31 December 2024
Group gross
customer
loans and
advances
1,2
Of which:
NPEs
Of which exposures with
forbearance measures
Accumulated
impairment,
accumulated
negative changes in
fair value due to
credit risk and
provisions
Of which:
NPEs
Of which exposures with forbearance
measures
Total exposures
with forbearance
measures
Of which:
NPEs
Total exposures
with forbearance
measures
Of which:
NPEs
000 000 000 000 000 000 000 000
Loans and advances to customers
General governments 68,892 - - - 3 - - -
Other financial corporations 296,345 545 34,871 475 3,904 377 1,297 308
Non-financial corporations 5,033,827 75,589 209,835 57,040 58,681 36,952 33,041 29,324
Of which: Small and Medium sized
Enterprises
3
(SMEs)
2,900,947 62,950 113,932 46,764 35,447 26,482 20,551 19,208
Of which: Commercial real estate
3
3,463,617 66,202 188,182 54,506 46,462 30,978 31,142 27,954
Non-financial corporations by sector
Construction 483,832 1,862 9,069
Wholesale and retail trade 891,437 16,086 8,565
Accommodation and food service activities 1,149,973 1,614 3,002
Real estate activities 892,563 21,252 12,666
Transport and storage 551,168 194 1,131
Other sectors 1,064,854 34,581 24,248
Households 4,862,349 125,955 122,133 52,747 84,431 57,501 24,152 19,055
Of which: Residential mortgage loans
3
3,761,702 94,107 107,516 44,065 53,360 36,164 19,172 14,554
Of which: Credit for consumption
3
638,798 24,218 13,526 7,304 20,278 14,643 3,967 3,404
10,261,413 202,089 366,839 110,262 147,019 94,830 58,490 48,687
Loans and advances to customers
classified as held for sale
54,921 54,921 15,221 15,221 31,778 31,778 7,562 7,562
Total on-balance sheet 10,316,334 257,010 382,060 125,483 178,797 126,608 66,052 56,249
1
Excluding loans and advances to central banks and credit institutions and reverse repurchase agreements (including an amount of 6.865 thousand cash collateral placed).
2
The residual fair value adjustment on initial recognition (which relates mainly to loans acquired from Laiki Bank and is calculated as the difference between the outstanding contractual amount and the fair value of loans acquired and
bears a negative balance) is considered as part of the gross loans, therefore decreases the gross balance of loans and advances to customers.
3
The analysis shown in lines ‘non-financial corporations’ and ‘households’ is non-additive across all categories as certain customers could be in both categories.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Risk and Capital Management Report
55
4. Principal Risks (continued)
4.1 Credit Risk (continued)
Gross loans and advances to customers
Accumulated impairment, accumulated negative changes in fair value due to
credit risk and provisions
31 December 2023
Group gross
customer
loans and
advances
1,2
Of which:
NPEs
Of which exposures with
forbearance measures
Accumulated
impairment,
accumulated
negative changes in
fair value due to
credit risk and
provisions
Of which:
NPEs
Of which exposures with forbearance
measures
Total exposures
with forbearance
measures
Of which:
NPEs
Total exposures
with forbearance
measures
Of which:
NPEs
000 000 000 000 000 000 000 000
Loans and advances to customers
General governments 35,249 - - - 6 - - -
Other financial corporations 253,077 805 1,201 448 4,247 378 308 305
Non-financial corporations 4,931,801 155,212 258,469 95,156 91,640 61,097 37,355 33,472
Of which: Small and Medium sized
Enterprises
3
(SMEs)
3,017,909 125,600 161,086 69,551 66,104 48,370 25,743 22,814
Of which: Commercial real estate
3
3,567,684 136,152 228,516 90,842 66,458 50,862 33,774 31,716
Non-financial corporations by sector
Construction 484,893 24,873 8,585
Wholesale and retail trade 869,753 37,739 22,936
Accommodation and food service activities 1,169,399 14,310 9,657
Real estate activities 1,019,544 40,296 23,461
Manufacturing 359,874 3,852 4,589
Other sectors 1,028,338 34,142 22,412
Households 4,781,114 207,883 196,070 96,019 83,560 58,962 30,330 25,227
Of which: Residential mortgage loans
3
3,726,056 169,734 173,407 83,445 52,863 39,732 25,119 20,849
Of which: Credit for consumption
3
590,945 29,347 21,312 12,704 21,108 13,357 4,897 4,157
Total on-balance sheet 10,001,241 363,900 455,740 191,623 179,453 120,437 67,993 59,004
1
Excluding loans and advances to central banks and credit institutions.
2
The residual fair value adjustment on initial recognition (which relates mainly to loans acquired from Laiki Bank and is calculated as the difference between the outstanding contractual amount and the fair value of loans acquired and
bears a negative balance) is considered as part of the gross loans, therefore decreases the gross balance of loans and advances to customers.
3
The analysis shown in lines ‘non-financial corporations’ and ‘households’ is non-additive across all categories as certain customers could be in both categories.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Risk and Capital Management Report
56
4. Principal Risks (continued)
4.2 Market Risk
Market Risk is defined as the current or prospective risk to earnings and capital arising from adverse movements
in interest rates, currency/foreign exchange rates and from any other changes in market prices. The main types
of market risk to which the Group is exposed, are listed below:
a. Interest Rate Risk in the Banking Book (IRRBB);
b. Currency/foreign exchange rates risk;
c. Securities price risk (bonds, equities);
d. Properties price risk.
Each of the risks above is defined and further analysed in the subsections below. Furthermore, additional
information relating to Market risk is set out in Note 45 of the Consolidated Financial Statements.
The management of market risk in the Group is governed by the Group’s Risk Appetite Statement and by the
Market Risk Policy, approved by the Board. These are supplemented by a range of approved limits and controls
also approved by the Board. The Group has an established governance structure for market risk. Market risk is
measured using portfolio sensitivity analysis, Value at Risk (VaR’), scenario analysis and stress testing
measures. Measurement and reporting to the committees is performed on a frequent basis.
Interest Rate Risk in the Banking Book
Interest rate risk in the banking book (‘IRRBB’) is the current or prospective risk to both the earnings and capital
of the Group as a result of adverse movements in interest rates. The four components of interest rate risk are:
repricing risk, yield curve risk, basis risk and option risk. Repricing risk is the risk of loss of net interest income
or economic value as a result of timing mismatch in the repricing of assets, liabilities and off-balance sheet
items. Yield curve risk arises from changes in the slope and the shape of the yield curve. Basis risk is the risk
of loss of net interest income or economic value as a result of imperfect correlation between different reference
rates. Option risk arises from options, including embedded options, e.g. consumers redeeming fixed rate
products when market rates change.
The Group does not operate a trading book and thus all interest rate exposure arises from the banking book.
In order to manage interest rate risk, the Group sets a one-year limit on the maximum reduction of the net
interest income. Limits are set as a percentage of Group Tier 1 capital and as a percentage of Group annual net
interest income (when positive). Whilst limit breaches must be avoided at all times, any such occurrence is
reported to the relevant authorities (ALCO and/or the RC) following relevant escalation process and mitigating
actions are put in place. Regular update is provided to the ALCO/ the EXCO/ the RC.
Treasury Division is responsible for managing the interest rate exposure of the Group. Corrective actions are
taken by Treasury Division to minimize the risk exposure and in any event to restrict exposure within limits.
Currency/foreign exchange rates risk
Currency/foreign exchange rates risk is the risk that the fair value of future cash flows of a financial instrument
will fluctuate because of changes in foreign exchange rates.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Risk and Capital Management Report
57
4. Principal Risks (continued)
4.2 Market Risk (continued)
Currency/foreign exchange rates risk (continued)
In order to limit the risk of loss from adverse fluctuations in foreign exchange rates, overall Intraday and
Overnight open currency position limits have been set. These internal limits are lower compared to the maximum
permissible by the regulator. Internal limits serve as a trigger to management for avoiding regulatory limit
breaches. Due to the fact that there is no Foreign Exchange Trading Book, VaR (Value at Risk) is calculated on
a quarterly basis on the position reported to the CBC. Intraday and overnight FX position limits are monitored
daily and the open foreign currency position or any breaches follow the escalation process and are reported to
the ALCO and to the RC through regular reporting.
Treasury Division is responsible for managing the foreign currency open position of the Group emanating from
its balance sheet. The foreign currency position emanating from customer transactions is managed by the Global
Markets & Treasury Sales Department. Treasury Division is also responsible for hedging the foreign currency
open positions of the foreign non-banking units of the Group.
Equities Price Risk
Equities Price Risk is the risk of loss from changes in the price of equity securities when there is an unfavorable
change in the prices of equity securities held by the Group as investments.
The Group holds equity and fund investments on its balance sheet. The equity portfolio mainly relates to certain
legacy positions acquired through loan restructuring activity and specifically through debt for equity swaps,
whereas the fund portfolio mainly relates to investments held by the insurance operations of the Group. The
policy is to manage the current equity portfolio with the intention to reduce it by selling positions for which there
is a market. No new purchases of equities are allowed without ALCO approval. Analysis of equity and fund
holdings are reported to ALCO on a quarterly basis. Analysis of the positions the Group maintains as at 31
December 2024 is presented in Note 20 of the Consolidated Financial Statements.
Debt Securities Price Risk
Debt securities price risk is the risk of loss as a result of adverse changes in the prices of debt securities held
by the Group. Debt security prices change as the credit risk of the issuers changes and/or as the interest rates
of fixed rate securities change.
The Group invests a significant part of its liquid assets in debt securities. Changes in the prices of debt securities
classified as investments at FVPL, affect the profit or loss of the Group, whereas changes in the value of debt
securities classified as FVOCI affect directly the equity of the Group. Debt securities classified as HTC are
measured at amortised cost.
Debt security investment limits exist at RAS level governing the level of riskiness of the overall portfolio. Credit
limits per issuer as well as concentration limits are also in place. Limit monitoring is performed on a daily basis
by the Market & Liquidity Risk Unit. Any breaches are reported following an established escalation process by
reference to the limit breach.
The debt security portfolio is managed by the Treasury Division and governed by the Bond Investment Policy.
The annual bond investment strategy is proposed by Treasury and approved by ALCO and ultimately by the
Board as part of the approval of the Group Financial Plan. Treasury proceeds with the approved bond investments
which are within the Bond Investment Policy and within limits and parameters set in the various policies and
frameworks. Analysis of the positions the Group maintains as at 31 December 2024 is presented in Note 20 of
the Consolidated Financial Statements.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Risk and Capital Management Report
58
4. Principal Risks (continued)
4.2 Market Risk (continued)
Property Price Risk
Property price risk is the risk that the value of property will decrease, either as a result of:
˗ Changes in the demand for, and prices of, real estate; or
˗ Regulatory requests which may increase the capital requirements for stock of property.
The Group is exposed to the risk of negative changes in the fair value of property which is held either for own
use, as stock of property or as investment property. Stock of property has been predominately acquired in
exchange of debt with a strategy and intention to be disposed of in line with the Group’s strategy.
The Group has in place a number of actions to manage and monitor the exposure to property price risk as
indicated below:
˗ It has an established Real Estate Management Unit (REMU), a specialised division to manage, promote
and monetise the repossessed portfolio, including other non-core assets, through appropriate real estate
disposal initiatives;
˗ It has placed great emphasis on the efficient and quick disposal of on-boarded properties and in their
close monitoring and regular reporting. RAS indicators and other KPIs are in place monitoring REMU
properties in terms of value, aging, and sales levels;
˗ It assesses and quantifies property price risk as one of the material risks for ICAAP purposes under both
the normative and economic perspective;
˗ It monitors the changes in the market value of the collateral and, where necessary, requests the pledging
of additional collateral in accordance with the relevant agreement;
˗ As part of the valuation process, assumptions are made about the future changes in property values, as
well as the timing for the realisation of collateral, taxes and expenses on the repossession and subsequent
sale of the collateral as well as any other applicable haircuts;
˗ For the valuation of properties owned by the Group, judgement is exercised which takes into account
available reference points, such as comparable market data, expert valuation reports, current market
conditions and application of appropriate illiquidity haircuts where relevant.
4.3 Liquidity and Funding Risk
Liquidity risk is the risk that the Group does not have sufficient financial resources to meet its commitments as
they fall due. This risk includes the possibility that the Group may have to raise funding at high cost or sell
assets at a discount to fully and promptly satisfy its obligations.
Funding risk is the risk that the Group does not have sufficiently stable sources of funding or access to sources
of funding may not always be available at a reasonable cost and thus the Group may fail to meet its obligations,
including regulatory requirements (e.g. MREL).
Further information relating to Group risk management in relation to liquidity and funding risk is set out in Note
46 of the Consolidated Financial Statements. Additionally, information on encumbrance and liquidity reserves is
provided below.
4.3.1 Encumbered and unencumbered assets
Asset encumbrance arises from collateral pledged against secured funding and other collateralised obligations.
An asset is classified as encumbered if it has been pledged as collateral against secured funding and other
collateralised obligations and, as a result, it is no longer available to the Group for further collateral or liquidity
requirements. The total encumbered assets of the Group amounted to 3,566,251 thousand as at 31 December
2024 (2023: 3,681,929 thousand).
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Risk and Capital Management Report
59
4. Principal Risks (continued)
4.3 Liquidity and Funding Risk (continued)
4.3.1 Encumbered and unencumbered assets (continued)
An asset is classified as unencumbered if it has not been pledged as collateral against secured funding and other
collateralised obligations. Unencumbered assets are further analysed into those that are available and can
potentially be pledged and those that are not readily available to be pledged. As at 31 December 2024, the
Group held 20,119,123 thousand (2023: 20,640,651 thousand) of unencumbered assets that can potentially
be pledged and can be used to support potential liquidity funding needs and 1,167,169 thousand (2023:
717,575 thousand) of unencumbered assets that are not readily available to be pledged for funding
requirements in their current form.
The table below presents an analysis of the Group’s encumbered and unencumbered assets and the extent to
which the unencumbered assets can be potentially pledged for funding or other purposes. The carrying amount
of such assets is disclosed below:
31 December 2024
Encumbered Unencumbered
Total
Pledged as
collateral
Which
ca
n
potentially
be pledged
Which are not
readily available
to be pledged
000 000 000 000
Cash and other liquid assets 55,434
8,373,595
1,002,441
9,431,470
Investments 39,958
4,298,155
20,230
4,358,343
Loans and advances to customers 3,470,859
6,536,252
107,283
10,114,394
Non
-
current assets and disposed
groups held for sale
-
-
23,143
23,143
Property -
911,121
14,072
925,193
Total on-balance sheet 3,566,251
20,119,123
1,167,169
24,852,543
31 December 2023
Cash and other liquid assets 72,800
9,890,350
439,353
10,402,503
Investments 260,011
3,419,445
15,953
3,695,409
Loans and advances to customers 3,349,118
6,229,383
243,287
9,821,788
Property -
1,101,473
18,982
1,120,455
Total on-balance sheet 3,681,929
20,640,651
717,575
25,040,155
Encumbered assets primarily consist of loans and advances to customers and investments in debt securities.
These are mainly pledged for any potential use of the funding facilities of the European Central Bank (ECB) and
for the covered bond (Notes 29 and 46 of the Consolidated Financial Statements for the year ended 31 December
2024 respectively). Encumbered assets include cash and other liquid assets placed with banks as collateral
under ISDA agreements which are not immediately available for use by the Group but are released once the
transactions are terminated. Cash is mainly used to cover collateral required for (i) derivatives and (ii) trade
finance transactions and guarantees issued. It may also be used as part of the supplementary assets for the
covered bond.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
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60
4. Principal Risks (continued)
4.3 Liquidity and Funding Risk (continued)
4.3.1 Encumbered and unencumbered assets (continued)
BOC PCL maintains a Covered Bond Programme set up under the Cyprus Covered Bonds legislation and the
Covered Bonds Directive of the Central Bank of Cyprus (CBC). Under the Covered Bond Programme, BOC PCL
has in issue covered bonds of 650 million secured by residential mortgages originated in Cyprus. The covered
bonds have a maturity date on 12 December 2026 and interest rate of 3-months Euribor plus 1.25% payable
on a quarterly basis. On 9 August 2022, BOC PCL proceeded with an amendment to the terms and conditions
of the covered bonds following the implementation of Directive (EU) 2019/2162 in Cyprus. The covered bonds
are listed on the Luxemburg Bourse and have a conditional Pass-Through structure. All the bonds are held by
BOC PCL. The covered bonds are eligible collateral for the Eurosystem credit operations and are placed in the
ECB pool providing access to funding from the ECB.
Unencumbered assets which can potentially be pledged include debt securities and Cyprus loans and advances
which are less than 90 days past due. Balances with central banks are reported as unencumbered and can be
pledged, to the extent that there is excess available over the minimum reserve requirement. The minimum
reserve requirement is reported as unencumbered not readily available to be pledged.
Unencumbered assets that are not readily available to be pledged primarily consist of loans and advances which
are prohibited by contract or law to be encumbered or which are more than 90 days past due or for which there
are pending litigations or other legal actions against the customer, a proportion of which would be suitable for
use in secured funding structures but are conservatively classified as not readily available to be pledged as
collateral. Properties whose legal title has not been transferred to the Company or a subsidiary are not
considered to be readily available to be pledged as collateral.
Insurance assets held by Group insurance subsidiaries are not included in the table above or below as they are
primarily due to the insurance policyholders.
The carrying and fair value of the encumbered and unencumbered investments of the Group as at 31 December
2024 and 31 December 2023 are as follows:
31 December 2024
Carrying value
of encumbered
investments
Fair value of
encumbered
investments
Carrying value of
unencumbered
investments
Fair value of
unencumbered
investments
000 000 000 000
Equity securities -
-
135,464
135,464
Debt securities 39,958
40,870
4,182,921
4,214,146
Total investments 39,958
40,870
4,318,385
4,349,610
31 December 2023
Equity securities -
-
144,016
144,016
Debt securities 260,011
250,480
3,291,383
3,303,818
Total investments 260,011
250,480
3,435,399
3,447,834
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Risk and Capital Management Report
61
4. Principal Risks (continued)
4.3 Liquidity and Funding Risk (continued)
4.3.2 Liquidity regulation
The Group is required to comply with provisions on the Liquidity Coverage Ratio (LCR) under CRD IV/CRR (as
supplemented by Delegated Regulations (EU) 2015/61), with the limit set at 100%. The Group must also comply
with the Net Stable Funding Ratio (NSFR) calculated as per the Capital Requirements Regulation II (CRR II),
with the limit set at 100%.
The LCR is designed to promote the short-term resilience of a Group’s liquidity risk profile by ensuring that it
has sufficient high-quality liquid resources to survive an acute stress scenario lasting for 30 days. The NSFR has
been developed to promote a sustainable maturity structure of assets and liabilities.
As at 31 December 2024, the Group was in compliance with all regulatory liquidity requirements. As at 31
December 2024, the Group’s LCR stood at 309% (compared to 359% at 31 December 2023) and the Group’s
NSFR stood at 162% (compared to 159% at 31 December 2023).
4.3.3 Liquidity reserves
The below table sets out the Group’s liquidity reserves:
Composition of the
liquidity reserves
31 December 2024 31 December 2023
Internal
Liquidity
Reserves
Liquidity reserves as
per LCR Delegated
Regulation (EU)
2015/61 LCR eligible
Internal
Liquidity
Reserves
Liquidity reserves as
per LCR Delegated
Regulation (EU)
2015/61 LCR eligible
Level 1
Level
2A & 2B
Level 1
Level
2A & 2B
000 000 000 000 000 000
Cash and balances with
central banks
7,341,141
7,341,141
-
9,428,052
9,428,052
-
Placements with banks 658,154
-
-
214,588
-
-
Liquid investments 4,787,396
4,206,223
377,572
3,299,967
2,801,667
354,128
Available ECB Buffer 1,999,540
-
-
92,088
-
-
Total 14,786,231
11,547,364
377,572
13,034,695
12,229,719
354,128
Internal Liquidity Reserves present the internally defined liquid buffer of the Bank. Liquidity reserves as per LCR
Delegated Regulation (EU) 2015/61 present the liquid assets as per the definition of the aforementioned
regulation i.e., High-Quality Liquid Assets (HQLA).
Balances in Nostro accounts and placements with banks are not included in Liquidity reserves as per LCR, as
they are not considered HQLA (they are part of the LCR Inflows).
Liquid investments under the Liquidity reserves as per LCR are shown at market values reduced by standard
weights as prescribed by the LCR regulation. Liquid investments under Internal Liquidity Reserves include
additional unencumbered liquid bonds which are shown at market values net of haircuts based on the ECB
methodology and haircuts for the ECB eligible bonds, while for the non-ECB eligible bonds, a more conservative
internally developed haircut methodology is used.
Currently available ECB buffer is not part of the Liquidity reserves as per LCR.
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4. Principal Risks (continued)
4.4 Operational Risk
Operational risk is defined as the risk of direct or indirect impact/loss resulting from inadequate or failed internal
processes, people, systems or from external events. The Group includes in this definition compliance, legal and
reputational risk.
The Group recognises that the control of operational risk is directly related to effective and efficient management
practices and high standards of corporate governance. To that effect, the management of operational risk is
geared towards maintaining a strong internal control governance framework and managing operational risk
exposures through a consistent set of management processes that drive risk identification, assessment, control
and monitoring.
The Group also maintains adequate insurance policies to cover for unexpected material operational losses.
Operational Risk Management (ORM) Framework
The Group has established an Operational Risk Management Framework which addresses the following
objectives:
- Raising operational risk awareness and building the appropriate risk culture;
- Providing effective risk monitoring and reporting to the Group’s management at all levels in relation to
the operational risk profile, so as to facilitate decision making for risk control activities;
- Mitigating operational risk to ensure that operational losses do not cause material damage to the Group’s
franchise and that the impact on the Group’s profitability and corporate objectives is contained; and
- Maintaining a strong system of internal controls to ensure that operational incidents do not cause material
damage to the Group’s franchise and have a minimal impact on the Group’s profitability and reputation.
Operational risks can arise from all business lines and from all activities carried out by the Group and are thus
diverse in nature.
To enable effective management of all material operational risks, the operational risk management framework
adopted by the Group is based on the three lines of defence model, through which risk ownership is dispersed
throughout the organisation.
The key components of the Operational Risk Management Framework include the following:
Operational Risk Appetite
A defined Operational RAS is in place, which forms part of the Group RAS. Thresholds are applied for conduct
and other operational risk related losses.
Risk Control Self-Assessment (RCSA)
An RCSA methodology is established across the Group. According to the RCSA methodology, business owners
are requested to identify risks that arise primarily from the risk areas under the Group’s Risk Taxonomy.
Updating/enriching the risk register in terms of existing and potential new risks identified and their mitigation
is an on-going process, sourced from RCSA, but also from other Risk and Control Assessments (RCAs)
performed.
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4. Principal Risks (continued)
4.4 Operational Risk (continued)
Operational Risk Management (ORM) Framework (continued)
Incident recording and analysis
An operational risk event is defined as any incident where through the failure or lack of a control, the Group has
incurred an actual or potential loss/gain, or could have had a negative reputational or regulatory impact.
Operational risk loss events are classified and recorded in the Group’s Risk and Compliance Management System
(RCMS), which serves as an enterprise tool integrating all risk-control data (e.g. risks, loss incidents, KRIs) to
provide a holistic view with regards to risk identification, corrective action and statistical analysis.
Key Risk Indicators (KRIs)
These are operational or financial variables, which track the likelihood and/or impact of a particular operational
risk. KRIs serve as a metric, which may be used to monitor the level of particular operational risks.
Operational Risk Capital Requirements and ICAAP
Regulatory and economic capital requirements for operational risk are calculated using the Standardised
Approach. Additional Pillar II Regulatory capital is calculated for operational risk on a scenario-based approach.
Scenarios are built after taking into consideration the Key Risk Drivers, which are identified using a combination
of methods and sources, through top-down and bottom-up approaches.
Training and awareness
The Group strives to continuously enhance its risk control culture and increase the awareness of its employees
on operational risk issues through ongoing staff training (both through physical workshops and through e-
learning).
Reporting
Important operational risks identified and assessed through the various tools/methodologies of the Operational
Risk Management Framework, are regularly reported to top management, as part of overall risk reporting.
Specifically, the CRO reports on risk to the EXCO and the RC on a monthly basis, while annual risk reports are
submitted to the Regulators. Ad-hoc reports are also submitted to management, as needed.
4.4.1 Fraud Risk Management
The Group has a dedicated unit under the ORM Function, the Fraud Risk Management (FRM) unit, which is
responsible for the oversight of internal and external fraud by:
˗ Developing and maintaining a framework and supporting policies for the management of internal and
external fraud risks;
˗ Undertaking Specialised Fraud Risk Assessments and ensuring that divisions and business departments
have a sound process for identifying new and emerging fraud risks;
˗ Promoting and adopting automated/alert-based systems and controls for the prevention and early
detection of external and internal fraud;
˗ Establishing structured fraud incident response management processes and plans;
˗ Analysing data and emerging fraud trends for the proactive management of emerged fraud;
˗ Providing direction through policy, education, tools and training;
˗ Ensuring compliance with relevant regulations and assessing new regulations or amendments to existing
ones with regards to fraud related issues, by performing regulatory gap analysis in cooperation with other
related stakeholders.
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4. Principal Risks (continued)
4.4 Operational Risk (continued)
4.4.1 Fraud Risk Management (continued)
Ongoing activities/initiatives towards further enhancements of FRM involved inter alia, the provision of fraud
risks and emerged frauds awareness seminar to Group’s staff and top-management, and the further
strengthening of external fraud prevention controls and framework, as a result of the customers’ accelerated
shift towards digital channels and digital banking.
4.4.2 Third-Party Risk Management
Third-party risk is defined as the risk brought on to the organisation by external parties in its ecosystem or
supply chain. Such parties include vendors, suppliers, partners, contractors or service providers who have access
to internal company or customer data, systems, processes or other privileged information. Third Party Risk,
remains of significant importance, and this is primarily due to the existence of outsourcing engagements and
the risks identified through the Third-Party risk assessments.
To mitigate this risk, a number of controls are in place which include regular third-party risk assessments on
outsourcing/intragroup and strategic contracts, third-party performance assessments, and established third
party risk trainings to ensure third-party risk awareness by the Group’s staff. The outsourcing contracts of the
Group should be fully aligned with the EBA Guidelines on Outsourcing Arrangements and/or the Third-Party &
Outsourcing Risk Management Policy. In cases where the arrangements in scope are not aligned with the EBA
Guidelines and/or policies of the Group, risks are identified, and mitigating controls are put in place. Examples
of potential risks include inadequate contract clauses, third-party resilience/inadequate due diligence, and over-
reliance on third parties.
4.4.3 Business Continuity Risk Management (BCRM)
The Group has a dedicated unit under the ORM Function, the Business Continuity Risk Management unit, which
provides direction and sets the overall framework to individual business units to mitigate business continuity
risks and minimize the impact of severe disruptive incidents such as natural disasters, loss of Information
Technology Center, loss of electricity, pandemics etc.
5. Other principal risks and uncertainties
In addition to the risks described in section 4 above, further principal risks are also faced by the Group. These
risks are described below as well as the way these are identified, assessed, managed and monitored by the
Group, including the available mitigants.
Emerging risks are defined as new risks or existing risks that may escalate in a different way, with the potential
to threaten the execution of the Group’s strategy or operations over a medium-term horizon. The Group is
forward-looking in its risk identification processes to ensure emerging risks are identified. The internal and
external risk environment of the Group as well as macro-themes are assessed to identify such emerging risks
that may require escalation and implementation of suitable mitigation actions. Reporting of emerging risks to
the RC and the EXCO is performed on a bi-annual basis to ensure all significant risks are escalated effectively
for discussion and action. The main emerging risks currently considered by the Group are Geopolitical, Digital
Transformation and Climate and Environment Risks all of which are also principal risks and are further described
below.
The risks described, should not be regarded as a complete and comprehensive statement of all potential risks,
uncertainties or mitigants, as other factors either not yet identified or not currently material, may also adversely
affect the Group.
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5. Other principal risks and uncertainties (continued)
5.1 Business Model and Strategic Risks
Business model and strategic risks refer to the uncertainty in implementing the Group’s strategy and achieving
its business targets. Such risks can arise from changes in the external environment, including economic trends,
competition, geopolitics, and regulatory changes, or due to operational factors, such as inadequate planning or
implementation. The Group faces competition from banks, financial institutions, insurance and financial
technology companies operating locally or abroad. Also, deterioration of the macroeconomic environment can
lead to adverse impacts in the financial performance impacting the Group’s profitability, asset quality or capital
resources.
Furthermore, the Group's business environment and operational performance are heavily dependent on the
current and future economic conditions and prospects in Cyprus, where the Group's operations are based, and
earnings are predominantly generated. The Group is also dependent on the economic conditions and prospects
in the countries of the main counterparties it conducts business with.
The Group has a clear strategy with key objectives to enable delivery and operates within defined risk appetite
limits which are calibrated considering the Group’s risk bearing capacity. The strategy is closely monitored on a
regular basis. Furthermore, the Group remains ready to explore opportunities that complement its strategy
including diversification of income.
The Group monitors and manages business model risk within its Risk Appetite Framework, by setting limits in
respect of measures such as financial performance, portfolio performance, concentration and capital levels. At
a more operational level, the risk is mitigated by monitoring deviations from the Group Financial Plan, while
during the year, periodic reforecast updates of the financial plan are prepared. The frequency of reforecast
updates during each year is determined by the prevailing business and economic conditions. Performance
against the plan is monitored on a monthly basis, both at Group and Business Line levels, and reported to the
EXCO and the Board.
The Group also closely monitors the risks and impact of changing macroeconomic conditions on its lending
portfolio, strategy and objectives, considering mitigating actions where necessary. An internal stress testing
framework as part of the Group’s ICAAP is in place to provide insights and to assess capital resilience to shocks.
5.2 Geopolitical Risk
Cyprus is a small, open, services-based economy, with a large external sector and high reliance on tourism and
international business services. As a result, external factors such as economic and geopolitical events that are
beyond the control of the Group can have a significant impact on domestic economic activity. A number of macro
and market related risks, including weaker economic activity, a volatile interest rate environment for longer,
and higher competition in the financial services industry, could negatively affect the Group’s business
environment, results, and operations.
Geopolitical tensions remain high because of the continuing war in Ukraine and the military conflict in the Middle
East. The continuation of these conflicts adds considerable uncertainty to the outlook for the global economy
with the impact dependent on how these conflicts are resolved.
A change in the US approach may drive changes in global trade. The potential for the introduction of a higher
tariff regime by the US administration may result in inflationary and monetary policy reactions with the trading
partners of the US.
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5. Other principal risks and uncertainties (continued)
5.2 Geopolitical Risk (continued)
Up until now, the Cyprus economy has proved robust and flexible to withstand external shocks and has displayed
the ability to sufficiently diversify income in order to maintain GDP growth and suppress unemployment.
These factors, as well as the current political context in the United States and Europe, increase the uncertainty
about the evolution of the global economy. The Group closely monitors these events and their impact on the
economy and the business and remains vigilant to take any precautionary measures as required.
Although, there have been distinct improvements in Cyprus’ risk profile after the banking crisis, risks do remain
given the open structure of the Cypriot economy.
The Group continuously monitors current affairs, the impact of forecasted macroeconomic conditions and
geopolitical developments on the Group’s strategy to proactively manage emerging risks. Where necessary,
bespoke solutions are offered to affected exposures and close monitoring on those is maintained. Furthermore,
the Group includes related events in its stress testing scenarios in order to gain a better understanding of the
potential impact.
5.3 Legal Risk
The Group may, from time to time, become involved in legal or arbitration proceedings which may affect its
operations and results. Litigation risk arises from pending or potential legal proceedings and regulatory
investigations against the Group. In the event that legal issues are not properly dealt with by the Group, this
may result in financial and/or reputational loss to the Group. Information on pending litigation, claims, regulatory
and other matters is disclosed in Note 38 of the Consolidated Financial Statements.
The Group has procedures in place to ensure effective and prompt management of legal risk including, among
others, the risk arising from regulatory developments, new products and internal policies.
The Legal Services Department (LSD) monitors the pending litigation against the Group and assesses the
probability of loss for each legal action against the Group based on IFRS Accounting Standards. It also estimates
the amount of potential loss where it is deemed as probable. Additionally, it reports pending litigation and latest
developments to the Board.
5.4 Technology Risk
Technology risk arises from system downtimes impacting business operations and/or customer service.
Downtimes may be caused by hardware or software failures due to malfunctions, failed processes, human error,
or cyber incidents. The use of outdated, obsolete and unsupported systems increases this risk.
The Group has in place a Technology Strategy designed to support business strategy and a customer centric
view. The strategy includes investments in skills and technology to minimize system downtimes and security
risks, modernization of legacy applications, a risk-based approach to leverage the benefits of Cloud technologies
and investments in new and innovative applications to support business requirements. The Group implements
a collaborative operating model to implement the technology initiatives that support business strategy and its
digital agenda. The Operating Model involves setting up cross-functional teams that combine technical, business
and risk skills for accelerated results. Where necessary, the Group engages with appropriate external experts
to augment capacity and meet peak demand for technical initiatives while always maintaining good levels of
internal skills and capacity.
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5. Other principal risks and uncertainties (continued)
5.4 Technology Risk (continued)
The Group’s policies, standards, governance and controls undergo ongoing review to ensure continued alignment
with the Group’s Technology Strategy, compliance with regulation and effective management of the associated
risks.
5.5 Digital Transformation Risk
Digital transformation risk continues to be a principal and emerging risk, as banking models are rapidly evolving
both locally and globally as available technologies have resulted in the customers’ accelerated shift towards
digital channels. Money transmission, data driven integrated services and Digital Product Sales are rapidly
evolving. How the Group adapts to these emerging developments could impact the realisation of its market
strategies and financial plans.
In the context of the overall business strategy, the Group assesses and develops its Digital Strategy and
maintains a clear roadmap that provides for migration of transactions to the Digital Channels, full Digital and
Digital Assisted Product Sales, embedded banking and self-service banking support services. The Group’s
emphasis on the Digital Strategy is reflected in the operating model with a designated Chief Digital Officer
supported by staff with the appropriate skills that work closely with Technology and Control functions to execute
the strategy.
The Group’s policies, standards, governance and controls undergo ongoing review to ensure continued alignment
with the Group’s strategy for digital transformation and effective management of the associated risk.
5.6 Information Security and Cyber Risk
Information security and cyber-risk is a significant inherent risk, which could cause a material disruption to the
operations of the Group. The Group’s information systems have been and will continue to be exposed to an
increasing threat of continually evolving cybercrime and data security attacks. Customers and other third parties
to which the Group is significantly exposed, including the Group's service providers (such as data processing
companies to which the Group has outsourced certain services), face similar threats.
Current geopolitical tensions have also led to increased risk of cyber-attack from foreign state actors.
The Group has an internal specialized Information Security team which constantly monitors current and future
cyber security threats (either internal or external, malicious or accidental) and invests in enhanced cyber security
measures and controls to protect, prevent, and appropriately respond against such threats to Group systems
and information. The Group maintains an approved Group Information Security Policy that provides a set of
standards, guidelines, controls, measures designed to achieve a desired level of information security.
The Group also collaborates with industry bodies, the National Computer Security Incident Response Team
(CSIRT) and intelligence-sharing working groups to be better equipped to face the growing threat from cyber
criminals. In addition, the Group maintains insurance coverage which covers certain aspects of cyber risks.
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5. Other principal risks and uncertainties (continued)
5.7 Regulatory Compliance Risk
The Group conducts its business subject to on-going regulations and the associated regulatory risks, including
the effects of changes in laws, regulations, policies, codes of conduct etc. Regulatory compliance risk is the risk
of impairment to the organization’s business model, reputation and financial condition from failure to meet laws
and regulations, internal standards and policies, and expectations of key stakeholders such as shareholders,
regulators, customers, employees and society. Failure to comply with regulatory framework requirements or
identify and plan for emerging requirements could lead to, amongst other things, increased costs for the Group,
regulatory fines, limitation on BOC PCL’s capacity to lend and could have a material adverse effect on the
business, financial condition and results, operations and prospects of the Group.
The Group's management maintains continuous and transparent communication with its Regulators (including
the ECB, the CBC, and others, such as the CySec, the CSE and the LSE/ATHEX). The Regulatory Steering Group,
led by the CEO and composed of executive management, receives regular updates on Regulatory Compliance
Risk issues via the Regulatory Affairs Department. The Group Compliance monitors the status of upcoming new
laws and amendments to existing laws, to ensure that all regulatory developments and requirements are
promptly addressed by the Group.
Regulatory compliance risks are identified and assessed using diverse methods as outlined in the Group
Compliance Policy. This policy details the compliance framework for the Group, covering their business and legal
environment, and assigning compliance responsibilities at both Group and entity levels. Additionally, it ensures
BOC PCL adheres to CBC Internal Governance Directive and EBA Guidelines on Internal Governance.
The Compliance Risk Assessment Methodology outlines how to evaluate compliance risks. The Compliance team
identifies and informs business areas about new or updated regulations, enabling them to conduct impact
assessments or regulatory gap analyses, while the Compliance function reviews and challenges as the second
line of defence.
Tools and mechanisms are in place for identifying, assessing, monitoring, escalating and reporting compliance
risks which, inter alia, include:
˗ The assessment of periodic reports submitted by the network of compliance liaisons;
˗ The use of aggregated risk measurements such as compliance risk indicators;
˗ Overseeing and challenging regulatory risks identified by compliance liaisons and subsidiary officers
through gap analysis of new or amended regulations, processes, procedures, projects,
products/services, and other assessments, to ensure effective management of compliance risks within
the Group and recommending additional controls and corrective actions as necessary;
˗ Supervising the compliance risk assessment procedures conducted by the compliance liaisons and
subsidiary compliance officers, as well as overseeing the implementation of mitigation efforts to manage
identified risks;
˗ Overseeing the complaints process and utilising customer complaints as a source of relevant information
in the context of its general monitoring responsibilities;
˗ Collaborating and sharing information with other internal control and risk management teams on
compliance issues, evaluating regulatory incidents, monitoring mitigating actions to avoid recurrence,
managing the risk, and reporting non-compliance incidents to competent authorities in accordance with
relevant regulations;
˗ Conducting periodic onsite/offsite reviews with applicable laws, rules, regulations and standards and
providing recommendations/advice to management on measures to be taken to ensure compliance;
˗ Investigating potential breaches of compliance policy and regulations, and conducting these
investigations as requested by relevant authorities, with the assistance of internal experts like those
from Internal Audit, Legal Services, Information Security, or Fraud Risk Management if needed.
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5. Other principal risks and uncertainties (continued)
5.7 Regulatory Compliance Risk (continued)
Regulatory compliance risks are reported promptly to senior management and the Board in accordance with the
guidelines of the CBC Internal Governance Directive.
5.8 Insurance risk and re-insurance risk
The Group, through its subsidiaries, EuroLife Ltd (‘EuroLife’) and General Insurance of Cyprus Ltd (‘Genikes
Insurance’), provides life insurance and non-life insurance services, respectively, and is exposed to certain risks
specific to these businesses. Insurance events are unpredictable and the actual number and amount of claims
and benefits will vary from year to year from the estimate established using actuarial and statistical techniques.
Insurance risk therefore is the risk that an insured event under an insurance contract occurs and uncertainty
over the amount and the timing of the resulting claim exists.
The above risk exposure is mitigated by the Group through the diversification across a large portfolio of
insurance contracts. The variability of risks is also reduced by careful selection and implementation of
underwriting strategy guidelines, as well as the use of reinsurance arrangements. Although the Group has
reinsurance coverage, it is not relieved of its direct obligations to policyholders and is thus exposed to credit
risk with respect to ceded insurance, to the extent that any reinsurer is unable to meet the obligations assumed
under such reinsurance arrangements.
The creditworthiness of reinsurers is evaluated by considering their solvency and credit rating and reinsurance
arrangements are monitored and reviewed to ensure their adequacy as per the reinsurance policy. In addition,
counterparty risk assessment is performed on a frequent basis.
Both EuroLife and Genikes Insurance perform their annual stress tests (ORSA) which aim to ensure, among
others, the appropriate identification and measurement of risks, an appropriate level of internal capital in relation
to each company’s risk profile, and the application and further development of suitable risk management and
internal control systems.
5.9 Climate Related & Environmental Risks
Climate and environmental matters is a growing agenda for financial institutions given the increasing effects of
climate change globally and the sharp regulatory focus on addressing the resultant risks. The Group’s
businesses, operations and assets could be affected by climate-related and environmental (C&E) risks over the
short, medium and long term. The Group is committed to integrate C&E risk considerations into all relevant
aspects of the decision-making, governance, strategy and risk management and has taken the necessary steps
to achieve this.
The Group applies the definition used in the Task Force on Climate-related Financial Disclosures (TCFD) for C&E
risks whereby climate-related risks are divided into two major categories: (1) risks related to the transition to
a lower-carbon economy (transition risks) and (2) risks related to the physical impacts of climate change
(physical risks).
˗ Physical risk refers to the financial impact of a changing climate, including more frequent extreme
weather events and gradual changes in climate, as well as of environmental degradation, such as air,
water and land pollution, water stress, biodiversity loss and deforestation. Physical risk is categorised
as “acute” when it arises from extreme events, such as droughts, floods and storms, and “chronic” when
it arises from progressive shifts, such as increasing temperatures, sea-level rises, water stress,
biodiversity loss, land use change, habitat destruction and resource scarcity. Physical risk can directly
result in, for example, damage to property or reduced productivity, or indirectly lead to subsequent
events, such as the disruption of supply chains.
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5. Other Principal Risks and uncertainties (continued)
5.9 Climate Related & Environmental Risks (continued)
˗ Transition risk refers to an institution’s financial loss that can result, directly or indirectly, from the
process of adjustment towards a lower-carbon and more environmentally sustainable economy. This
could be triggered, for example, by a relatively abrupt adoption of climate and environmental policies,
technological progress or changes in market sentiment and preferences.
Accelerating climate change could lead to sooner than anticipated physical risk impacts to the Group and the
wider economy and there is uncertainty in the scale and timing of technology, commercial and regulatory
changes associated with the transition to a low carbon economy.
The Group has put in place targets which set transparent ambitions on its climate strategy and decarbonization
of its operations and portfolio. An overall ESG strategy and working plan is thus in place to facilitate these
ambitions and address ECB expectations.
The Group also acknowledges the growing importance of environmental / nature-related risks which, as per the
Task Force for Nature-related Financial Disclosures (TNFD), are defined as those potential threats posed to an
organization arising from its own and the wider society’s dependencies and impacts on nature.
Dedicated teams both within Risk Management and Investor Relations & ESG Department, as well as other
resources, have been mobilised across the Group and are engaged in various streams of work such as the
measuring of own and financed emissions, the integration of C&E risk in the risk management framework and
the enhancement of green products offering.
Further information on C&E risks and their risk management is provided in the Sustainability Statements,
prepared in accordance with the European Sustainability Reporting Standards, that form part of the Group’s
2024 Annual Financial Report.
6. Capital management
The primary objective of the Group’s capital management is to ensure compliance with the relevant regulatory
capital requirements and to maintain healthy capital adequacy ratios to cover the risks of its business, support
its strategy and maximise shareholders’ value.
The capital adequacy framework, as in force, was incorporated through the Capital Requirements Regulation
(CRR) and Capital Requirements Directive (CRD) which came into effect on 1 January 2014 with certain specified
provisions implemented gradually. The CRR and CRD transposed the new capital, liquidity and leverage
standards of Basel III into the European Union’s legal framework. CRR establishes the prudential requirements
for capital, liquidity and leverage for credit institutions. It is directly applicable in all EU member states. CRD
governs access to deposit-taking activities and internal governance arrangements including remuneration, board
composition and transparency. Unlike the CRR, member states were required to transpose the CRD into national
law and national regulators were allowed to impose additional capital buffer requirements.
On 27 June 2019, the revised rules on capital and liquidity (Regulation (EU) 2019/876 (CRR II) and Directive
(EU) 2019/878 (CRD V)) came into force. As an amending regulation, the existing provisions of CRR apply,
unless they are amended by CRR II. Certain provisions took immediate effect (primarily relating to Minimum
Requirement for Own Funds and Eligible Liabilities (MREL)), but most changes became effective as of June 2021.
The key changes introduced consist of, among others, changes to qualifying criteria for Common Equity Tier 1
(CET1), Additional Tier 1 (AT1) and Tier 2 (T2) instruments, introduction of requirements for MREL and a binding
Leverage Ratio requirement (as defined in the CRR) and a Net Stable Funding Ratio (NSFR).
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6. Capital management (continued)
The amendments that came into effect on 28 June 2021 are in addition to those introduced in June 2020
through Regulation (EU) 2020/873, which among others, brought forward certain CRR II changes in light of the
COVID-19 pandemic. The main adjustments of Regulation (EU) 2020/873 that had an impact on the Group’s
capital ratio relate to the acceleration of the implementation of the new SME discount factor (lower RWAs),
extending the IFRS 9 transitional arrangements and introducing further relief measures to CET1 allowing to
fully add back to CET1 any increase in ECL recognised in 2020 and 2021 for non-credit impaired financial assets
and phasing-in this starting from 2022 (phasing-in at 25% in 2022, 50% in 2023 and 75% in 2024) and
advancing the application of prudential treatment of software assets as amended by CRR II (which came into
force in December 2020).
In October 2021, the European Commission adopted legislative proposals for further amendments to the CRR,
CRD and the BRRD (the ‘2021 Banking Package’). Amongst other things, the 2021 Banking Package would
implement certain elements of Basel III that had not yet been transposed into EU law. The 2021 Banking
Package included:
a proposal for a Regulation (‘CRR III’) to make amendments to CRR with regard to (amongst other
things) requirements on credit risk, credit valuation adjustment risk, operational risk, market risk
and the output floor;
a proposal for a Directive (‘CRD VI’) to make amendments to CRD with regard to (amongst other
things) requirements on supervisory powers, sanctions, third-country branches and ESG risks; and
a proposal for a Regulation to make amendments to CRR and the BRRD with regard to (amongst
other things) requirements on the prudential treatment of G-SII groups with a multiple point of
entry resolution strategy and a methodology for the indirect subscription of instruments eligible
for meeting the MREL requirements.
In December 2023 the preparatory bodies of the Council and European Parliament endorsed the amendments
to the CRR and the CRD and the legal texts were published on the Council and the Parliament websites. In
April 2024, the European Parliament voted to adopt the amendments to the CRR and the CRD; Regulation
(EU) 2024/1623 (the ‘CRR III’) and Directive (EU) 2024/1619 (the ‘CRD VI’) were published in the EU's
official journal in June 2024, with entry into force 20 days from the date of the publication. Most provisions
of the CRR III have become effective on 1 January 2025 with certain measures subject to transitional
arrangements or to be phased-in over time. Member states shall adopt and publish, by 10 January 2026, the
laws, regulations and administrative provisions necessary to comply with CRD VI and shall apply most of
those measures by 11 January 2026. The implementation of CRR III is estimated to have a positive impact
of approximately 1% on the CET1 ratio (transitional) of the Group on initial application on 1 January 2025.
However, during 2025 the publication of ECB guidelines on options and discretions and EBA mandates could
result in additional impacts on CET1 ratios across the industry.
The Regulatory CET1 ratio of the Group as at 31 December 2024 stands at 19.2% and the Total Capital ratio
at 24.0%. The ratios as at 31 December 2024 include profits for the year ended 31 December 2024 and a
deduction for the distribution in respect of 2024 earnings as described in Section ‘Distributions’ in the
Directors Report included within the Annual Financial Report.
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6. Capital management (continued)
The Groups minimum capital requirements are presented below:
Minimum CET1 Regulatory Capital Requirements 2024 2023
Pillar I – CET1 Requirement 4.50% 4.50%
Pillar II – CET1 Requirement 1.55% 1.73%
Capital Conservation Buffer (CCB)* 2.50% 2.50%
Other Systematically Important Institutions (O-SII) Buffer** 1.875% 1.50%
Countercyclical Buffer (CcyB) 0.92% 0.48%
Minimum CET1 Regulatory Capital Requirements 11.34% 10.72%
* Fully phased in as of 1 January 2019
** Increasing by 0.0625% every year thereafter, until being fully implemented on 1 January 2026 at 2.00%.
Minimum Total Capital Regulatory Requirements 2024 2023
Pillar I – Total Capital Requirement 8.00% 8.00%
Pillar II – Total Capital Requirement 2.75% 3.08%
Capital Conservation Buffer (CCB)* 2.50% 2.50%
Other Systematically Important Institutions (O-SII) Buffer** 1.875% 1.50%
Countercyclical Buffer (CcyB) 0.92% 0.48%
Minimum Total Capital Regulatory Requirements 16.05% 15.56%
* Fully phased in as of 1 January 2019
** Increasing by 0.0625% every year thereafter, until being fully implemented on 1 January 2026 at 2.00%.
The minimum Pillar I total capital requirement ratio of 8.00% may be met, in addition to the 4.50% CET1
requirement, with up to 1.50% by AT1 capital and with up to 2.00% by T2 capital.
The Group is also subject to additional capital requirements for risks which are not covered by the Pillar I capital
requirements (Pillar II add-ons). Applicable Regulation allows a part of the said Pillar II Requirements (P2R) to
be met also with AT1 and T2 capital and does not require solely the use of CET1.
The capital position of the Group and BOC PCL as at 31 December 2024 exceeds both their Pillar I and their
Pillar II add-on capital requirements. However, the Pillar II add-on capital requirements are a point-in-time
assessment and therefore are subject to change over time.
The CBC, in accordance with the Macroprudential Oversight of Institutions Law of 2015, sets, on a quarterly
basis, the CcyB rates in accordance with the methodology described in this law.
On 30 November 2022, the CBC, following the revised methodology described in its macroprudential policy,
decided to increase the CcyB rate from 0.00% to 0.50% of the total risk exposure amount in Cyprus of each
licensed credit institution incorporated in Cyprus effective from 30 November 2023. Moreover, on 2 June 2023,
the CBC, announced its decision to raise the CcyB rate to 1.00% of the total risk exposure amount in Cyprus,
effective from 2 June 2024. The CcyB for the Group as at 31 December 2024 has been calculated at
approximately 0.92% (2023: 0.48%). In January 2025, the CBC, based on its macroprudential policy, decided
to increase the CcyB rate from 1.00% to 1.50% of the total risk exposure amount in Cyprus effective from
January 2026. Based on the above, the CcyB for the Group is expected to increase further.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Risk and Capital Management Report
73
6. Capital management (continued)
In accordance with the provisions of this law, the CBC is also the responsible authority for the designation of
banks that are Other Systemically Important Institutions (O-SIIs) and for the setting of the O-SII Buffer
requirement for these systemically important banks. BOC PCL has been designated as an O-SII. The O-SII
Buffer as at 31 December 2023 stood at 1.50% and increased by 37.5 bps to 1.875% on 1 January 2024,
following a revision of the O-SII buffer by the CBC in October 2023. In April 2024, following a revision by the
CBC of its policy for the designation of credit institutions that meet the definition of O-SII institutions and the
setting of an O-SII buffer to be observed, the Group’s O-SII buffer has been set to 2.00% from 1 January 2026
(from the previous assessment carried out in October 2023 of 2.25% from 1 January 2025) to be phased-in by
6.25 bps annually to 1.9375% on 1 January 2025 and 2.00% as of 1 January 2026.
The ECB also provides non-public guidance for an additional Pillar II CET1 buffer (P2G) to be maintained.
Following the annual SREP performed by the ECB in 2024 and based on the final SREP decision received in
December 2024, effective from 1 January 2025, the Group’s minimum phased-in CET1 capital ratio and Total
Capital ratio requirements are expected to remain unchanged, when disregarding the phasing-in of the O-SII
buffer. The non-public guidance P2G is also expected to remain unchanged compared to 2024. Furthermore,
based on the final SREP decision, the requirement for prior regulatory approval for the declaration of dividends
is lifted, effective from 1 January 2025.
The Group is subject to a 3% Pillar I Leverage Ratio requirement.
The above minimum ratios apply for both BOC PCL and the Group.
The EBA final guidelines on SREP and supervisory stress testing and the Single Supervisory Mechanism’s (SSM)
2018 SREP methodology provide that the own funds held for the purposes of Pillar II Guidance (P2G) cannot
be used to meet any other capital requirements (Pillar I requirement, P2R or the Combined Buffer Requirement
(CBR)), and therefore cannot be used twice.
The regulatory capital position of the Group and BOC PCL as at the reporting date (after applying the transitional
arrangements) is presented below:
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Risk and Capital Management Report
74
6. Capital management (continued)
Regulatory capital
Group BOC PCL
31
December
2024
1
31 December
2023
3
31
December
2024
2
31 December
2023
3
000 000 000 000
Common Equity Tier 1 (CET1)
4
2,075,484
1,798,015
2,015,685
1,766,707
Additional Tier 1 capital (AT1) 220,000
220,000
220,000
220,000
Tier 2 capital (T2) 307,138
300,000
307,955
300,000
Transitional total regulatory
capital
2,602,622
2,318,015
2,543,640
2,286,707
Risk weighted assets – credit risk
5
9,172,397
9,013,267
9,228,404
9,005,552
Risk weighted assets – market risk -
-
-
-
Risk weighted assets operational risk
1,661,691
1,327,871
1,601,470
1,292,350
Total risk weighted assets 10,834,088
10,341,138
10,829,874
10,297,902
Transitional % % % %
Common Equity Tier 1 (CET1) ratio
19.2
17.4
18.6
17.2
Total capital ratio 24.0
22.4
23.5
22.2
Leverage ratio 8.8
7.6
8.5
7.5
1
.
Includes profits for the year ended 31 December 2024 net of a deduction for the distribution in respect of 2024
earnings of 241 million, following relevant recommendation by the Board of Directors to the shareholders for a final
cash dividend of 211 million and approval by the Board to undertake a share buyback of ordinary shares of the
Company for an aggregate consideration of up to 30 million and in compliance with the terms of the ECB approval.
2.
Includes profits for the year ended 31 December 2024 net of a deduction for the distribution in respect of 2024
earnings, following relevant recommendation by the Board of Directors to the shareholders for a final cash dividend
of 241 million.
3.
Includes profits for the year ended 31 December 2023 net of a deduction for the distribution in respect of 2023
earnings of 137 million, following approval received by the ECB in March 2024 and relevant recommendation by the
Board of Directors to the shareholders for a final cash dividend of 112 million and approval by the Board to undertake
a share buyback of ordinary shares of the Company for an aggregate consideration of up to 25 million and in
compliance with the terms of the ECB approval. Similarly, for BOC PCL, amounts include profits for the year ended
31 December 2023 net of a deduction for the distribution in respect of 2023 earnings following approval received by
the ECB in March 2024 and relevant recommendation by the Board of Directors to the shareholders for a final cash
dividend of 137 million.
4.
CET1 includes regulatory deductions, comprising, amongst others, intangible assets amounting to 25,231 thousand
for the Group and 16,039 thousand for BOC PCL as at 31 December 2024 (31 December 2023: 24,337 thousand
for the Group and 16,861 thousand for BOC PCL).
5.
Includes Credit Valuation Adjustments (CVA).
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Risk and Capital Management Report
75
6. Capital management (continued)
The capital ratios of the Group and BOC PCL as at the reporting date on a fully loaded basis are presented below:
Fully loaded
Group BOC PCL
31 December
2024
1,4
31 December
2023
3,4
31 December
2024
2,4
31 December
2023
3,4
% % % %
Common Equity Tier 1 ratio 19.1
17.3
18.6
17.1
Total capital ratio 24.0
22.4
23.5
22.2
Leverage ratio 8.7
7.6
8.5
7.5
1.
Includes profits for the year ended 31 December 2024 net of a deduction for the distribution in respect of 2024
earnings of 241 million, following relevant recommendation by the Board of Directors to the shareholders for a final
cash dividend of 211 million and approval by the Board to undertake a share buyback of ordinary shares of the
Company for an aggregate consideration of up to 30 million and in compliance with the terms of the ECB approval.
2.
Includes profits for the year ended 31 December 2024 net of a deduction for the distribution in respect of 2024
earnings, following relevant recommendation by the Board of Directors to the shareholders for a final cash dividend
of 241 million.
3.
Includes profits for the year ended 31 December 2023 net of a deduction for the distribution in respect of 2023
earnings of 137 million, following approval received by the ECB in March 2024 and relevant recommendation by the
Board of Directors to the shareholders for a final cash dividend of 112 million and approval by the Board to undertake
a share buyback of ordinary shares of the Company for an aggregate consideration of up to 25 million and in
compliance with the terms of the ECB approval. Similarly, for BOC PCL amounts include profits for the year ended 31
December 2023 net of a deduction for the distribution in respect of 2023 earnings following approval received by the
ECB in March 2024 and relevant recommendation by the Board of Directors to the shareholders for a final cash
dividend of 137 million.
4.
IFRS 9 fully loaded as applicable.
During the year ended 31 December 2024, the regulatory CET1 ratio was mainly affected by pre-provision
income, provisions and impairments, the payment of AT1 coupon, other movements and the movement in risk-
weighted assets. The CET1 ratio is also impacted by the deductions for distribution in respect of 2024 earnings
and charges in line with the applicable framework as set out above. As a result, the CET1 ratio (on a transitional
and on a fully loaded basis) has increased by approximately 180 bps during the year ended 31 December 2024.
A charge, which amounted to 26 bps as at 31 December 2024, is deducted from own funds in relation to ECB
expectations for NPEs. In addition, a prudential charge in relation to the onsite inspection on the value of the
Group’s foreclosed assets is being deducted from own funds since June 2021, the impact of which is 3 bps on
the Group’s CET1 ratio as at 31 December 2024. Furthermore, the Group is subject to increased capital
requirements in relation to its real estate repossessed portfolio which follow a SREP provision to ensure minimum
capital levels retained on long-term holdings of real estate assets, with such requirements being dynamic by
reference to the in-scope REMU assets remaining on the balance sheet of the Group and the value of such
assets. As at 31 December 2024 the impact of these requirements was 51 bps on the Group’s CET1 ratio
compared to 24 bps as at 31 December 2023. The above-mentioned requirements are within the capital plans
of the Group and incorporated within its capital projections.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Risk and Capital Management Report
76
6. Capital management (continued)
Capital requirements of subsidiaries
The insurance subsidiaries of the Group, the General Insurance of Cyprus Ltd and Eurolife Ltd, comply with the
requirements of the Superintendent of Insurance including the minimum solvency ratio. The regulated Cyprus
Investment Firm (CIF) of the Group, The Cyprus Investment and Securities Corporation Ltd (CISCO), complies
with the minimum capital adequacy ratio requirements. In 2021 the new prudential regime for Investment Firms
(‘IFs’) as per the Investment Firm Regulation (EU) 2019/2033 (‘IFR’) on the prudential requirements of IFs and
the Investment Firm Directive (EU) 2019/2034 (‘IFD’) on the prudential supervision of IFs came into effect.
Under the new regime CISCO has been classified as a Non-Systemic ‘Class 2’ company and is subject to the
new IFR/IFD regime in full. The payment services subsidiary of the Group, JCC Payment Systems Ltd, complies
with the regulatory capital requirements under the Provision and Use of Payment Services and Access to
Payment Systems Laws of 2018 to 2023.
Minimum Requirement for Own Funds and Eligible Liabilities (MREL)
The Bank Recovery and Resolution Directive (BRRD) requires that from January 2016 EU member states shall
apply the BRRD’s provisions requiring EU credit institutions and certain investment firms to maintain a Minimum
Requirement for Own Funds and Eligible Liabilities (MREL), subject to the provisions of the Commission
Delegated Regulation (EU) 2016/1450. On 27 June 2019, as part of the reform package for strengthening the
resilience and resolvability of European banks, the BRRD ΙΙ came into effect and was required to be transposed
into national law. BRRD II was transposed and implemented in Cyprus law in May 2021. In addition, certain
provisions on MREL have been introduced in CRR ΙΙ which also came into force on 27 June 2019 as part of the
reform package and were immediately effective.
In January 2024, BOC PCL received final notification from the SRB regarding the 2024 MREL decision, by which
the final MREL requirement was set at 25.00% of risk weighted assets (30.30% of risk-weighted assets when
taking into account the prevailing CBR as at 31 December 2024 which needs to be met with own funds on top
of the MREL) and 5.91% of Leverage Ratio Exposure (LRE) (as defined in the CRR) and must be met by 31
December 2024.
In January 2025, ΒOC PCL, received final notification from the SRB regarding the 2025 MREL decision, by which
the final MREL requirement is now set at 23.85% of risk weighted assets (or 29.21% of risk weighted assets
taking into account the prevailing CBR as at 1 January 2025 which needs to be met with own funds on top of
the MREL) and 5.91% of Leverage Ratio Exposure. The revised MREL requirements became binding with
immediate effect.
BOC PCL must comply with the MREL requirement at the consolidated level, comprising BOC PCL and its
subsidiaries.
The MREL ratio as at 31 December 2024, calculated according to the SRB’s eligibility criteria currently in effect
and based on internal estimate, stood at 33.7% of RWAs (including capital used to meet the CBR) and at 13.9%
of LRE (based on the regulatory Total Capital as at 31 December 2024) demonstrating that the Bank finalized
its MREL build-up and created a comfortable buffer over the final requirements. The CBR stood at 5.30% as at
31 December 2024, compared to 4.48% as at 31 December 2023, reflecting the increase of the CcyB and O-SII
buffer by approximately 50 bps and 37.5 bps respectively. The CBR is expected to increase further as a result
of the phasing-in of O-SII buffer from 1.875% to 1.9375% on 1 January 2025 and to 2.00% on 1 January 2026
as well as the expected increase of the CcyB rate as of January 2026 as aforementioned.
Sustainability Statement 2024
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
78
Contents
Page
Sustainability Statement - Summary 79
ESRS 2 - General Disclosures 82
Environmental Section
ESRS E1 - Climate Change 110
ESRS E2 - Pollution 156
ESRS E3 - Water and Marine resources 162
ESRS E5 - Resource Use and Circular Economy 166
Social Section
ESRS S1 - Own Workforce 171
ESRS S4 - Consumers and End Users 190
Governance Section
ESRS G1 - Business Conduct 214
Sustainability Statement - Additional Information 229
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
79
Sustainability Statement – Summary
As part of its vision to be the leading financial hub in Cyprus, the Group is determined to be a leader in Cyprus
towards sustainable future. The Group systematically moves forward to the alignment with sustainable banking
and continues to embed Environmental, Social and Governance (ESG) in its infrastructure, strategies, risk
management practises, governance arrangements and policies. Corporate Sustainability Reporting Directive
(CSRD), coming into force in 2024, acts as a turning point in the sustainability reporting landscape in the European
Union (EU). This is the first Sustainability Statement, based on CSRD, published by the Group, representing a
step change in corporate reporting reflecting disclosures on impacts, risks and opportunities that are of material
importance to our stakeholders on sustainability matters.
Environment
Climate change is one of the biggest challenges that humanity faces. The World
Meteorological Organization (WMO) declared that 2024 is the warmest year on record, with
the global average surface temperature being approximately 1.55°C above the pre-industrial
level, breaching the 1.5 °C global warming level for the first time. Global Greenhouse Gas
(GHG) emissions continue to increase, and extreme climate events are more frequent than
ever. This means GHG emissions need to decline now. Consequently, the Group continues to
be committed, through its ESG Strategy, to lead the transition of Cyprus to a sustainable
future by aligning its own operations, supply chain and portfolios with the transition to a
sustainable economy. Group’s commitment is enforced through the Group’s ESG primary
ambitions:
1. Reduction by 42% of GHG emissions from own operations by 2030;
2. Become Net Zero by 2050;
3. Steadily increase Green Asset Ratio (GAR);
4. Steadily increase Green Mortgage Ratio.
The Group leads by example by decarbonizing its own operations. BOCH has developed a
decarbonisation plan to reduce its own carbon footprint relating to Scope 1 and Scope 2 GHG
emissions, and ultimately achieve the interim target to decrease emissions from own
operations by 42% (absolute target) by 2030, compared to the baseline of 2021. The Group
managed to reduce its Scope 1 and Scope 2 GHG emissions by 25% between the start of
2022 and the end of 2024.
In line with its Net Zero ambition by 2050, the Group, in 2023, set its first decarbonisation
target on its loan portfolio, aiming to reduce the carbon intensity metric of its mortgage
portfolio by 43% by 2030 compared to the baseline of 2022, by directing its new lending
towards more energy efficient residential properties. In that respect, BOCH launched a Green
Housing product to support the green transition and ensure reaching the decarbonisation
target set. The Group managed to reduce the carbon intensity metric of Mortgage portfolio
by 12% as at 31 December 2024 compared to 31 December 2022.
Additionally, by taking into account the regulatory, policy and macroeconomic developments
in the climate and environmental area, the Group has set green new lending internal KPIs on
Business Lines so as to mobilise and incentivise the green transition of its customers and
effectively help to manage the risks to which its customers might be exposed. The Group’s
Gross environmentally friendly loans as at 31 December 2024 reached 355mn, 90% higher
compared to 31 December 2023. In line with Beyond Banking approach, the Group
proceeded, in 2024, with the issuance of its inaugural 300mn green bond, the proceeds of
which will be allocated to green eligible projects under the Sustainable Finance Framework.
During 2024, the Group made progress in integrating climate-related and environmental
(C&E) risks into risk management approach and risk culture. The Group established and
enhanced the C&E risks identification and materiality assessment process (RIMA). The Group
carried out a comprehensive identification and assessment of C&E risks as drivers of existing
financial and non-financial risks considering its business profile, loan portfolio composition
and other. In addition, the Group through a combination of sensitivity analysis and stress
testing approaches, including scenario analysis, ensures the Group has the adaptive capacity
to respond to the material C&E physical and transition risks. The Group established policies
to support its ESG strategy, manage material C&E risks and impacts and grasp material
opportunities.
Key Highlights
25% reduction
in Group’s Scope 1
and Scope 2 GHG
emissions, in 2024
compared to 2021
baseline
12% reduction
in kgCO
2
/m
2
of
Mortgage portfolio
between
December 2022 to
December 2024
2,893,635
(tCO
2
eq) GHG
emission
inventory in 2024
355mn Gross
environmentally
friendly loans as
at 31 December
2024 (90%
increase
compared to 31
December 2023)
3.9% Gross loans
exposures to coal,
oil and gas related
economic
activities
300mn inaugural
green bond
issuance in 2024
0.6% GAR as at
31 December
2024 compared to
0% as at 31
December 2023
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
80
Sustainability Statement – Summary (continued)
Social
The Group embraces a broad approach to sustainability, from how we take care of our
employees, to how we advise and work together with our customers and partners on
sustainable choices. The Group respects human rights and integrates them into
operational policies and procedures. The Group’s Code of Ethics and Code of Conduct
outline defined standards for behaviour, responsibilities, and ethical practices applicable
to all employees. These frameworks are supported by reporting mechanisms and
investigation procedures to address issues and ensure equitable treatment. BOCH
engages with its workforce and customers through channels designed to promote
accountability and inclusion, supporting a culture aligned with these principles.
The health and safety (H&S) of our own workforce and other stakeholders remains a top
priority, reflecting Group’s dedication to a culture that puts people first. The Group
implements a Health and Safety management system (HSMS) designed to identify and
address hazards across all operations. 94.65% of Group’s own workforce is covered by
the Group’s HSMS. The Group implements actions such as incident investigation,
emergency response, H&S inspections and H&S risk assessment studies to manage the
H&S risks associated with own workforce. The Group recorded 3 work related injuries, in
2024, and the rate of recordable work-related injuries remains low at 0.65. The HSMS
covers customers, suppliers and visitors.
BOCH prioritises the protection of data and personal data. The Group has implemented
measures to mitigate the negative impact on privacy as well as the identified risks
associated with cyber-attacks and data breaches, reflecting its compliance with applicable
data protection regulations and its commitment to the secure handling of employee and
customer information. The Group maintains a strict no-tolerance policy for any non-
compliance with GDPR and expects full adherence to legal and regulatory requirements
across all operations. The Group has zero tolerance towards data leakage.
The Group constantly strives to become an even more client-centric organization
supporting the accessibility to products and services. A targeted digital transformation
program is already underway, with the goal of facilitating the shift to a more modern way
of conducting business, enhancing the digitisation of services provided to our clients, as
well as the digitisation of our internal operations. The percentage of the Group’s digital
transactions in its total portfolio was 95.54% in 2024 with key digital features such as
digital deposits, QuickLoans, QuickCards, digital accounts and digital housing being
introduced. In addition, the Group through the implementation of Business Continuity
Management system manages the risk of system downtimes impacting customers
accessibility to products and services and customer service.
The Group, though its Digital Economy Platform (Jinius), is leading the efforts underway
to digitise and technologically upgrade the Cypriot economy and to facilitate
entrepreneurship. Jinius platform shapes the digital ecosystem of the Cypriot economy,
bringing together businesses, organisations, suppliers, and customers in a single digital
environment. Jinius through Business-to-Business Services offer tender management,
ecosystem management, invoice management and remittance management services.
At the centre of positive impact lies our contribution to the Bank of Cyprus Oncology
Centre which represents a partnership between the public and the private sector in Cyprus
serving cancer patients and the society at large. Around 2mn was contributed to the
Centre in 2024.
Key Highlights
58.8% of own
workforce is female
98.7% of own
workforce is
permanent
94.65% of own
workforce is
covered by the
undertaking’s HSMS
3 work-related
injuries
95.54% Digital
transaction ratio
(total portfolio)
491mn new
lending on retail
housing
2mn contribution
to the BOC Oncology
Center in 2024
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
81
Sustainability Statement – Summary (continued)
Governance
BOCH recognises that responsible business conduct is the cornerstone to sustainability and
ethical business practices. Group’s approach to business conduct is guided by its core
values of integrity, reliability, collaboration, professionalism and innovation, ensuring that
every decision reached aligns with our ethical standards and stakeholder expectations.
The Group believes that a culture of ethical behaviour and strong governance is essential
for long-term success and trust-building with our customers, partners, and communities.
Our business conduct framework encompasses comprehensive policies, procedures, and
training programs designed to promote responsible practices across all levels of our
organization. The Board of Directors (Board) provides ethical leadership and promote the
Group’s vision, values, culture, and behaviour, within a framework of prudent and effective
controls, which enables risk to be identified, assessed, measured, and managed. The Board
sets the Group's corporate values and high ethical standards of business conduct for itself
and all members of the Group and ensures that its obligations to its shareholders and
others are understood and met. The Group implements a Whistleblowing system offering
accessible, confidential channels for employees to report violations, unethical behaviour,
or improper practices.
Expanding sustainable practices towards the supply chain, the Group implements
Sourcing, Procurement & Vendor Management Policy which establishes clear expectations
for suppliers to operate responsibly and sustainably, aligning with the Group's dedication
to ethical and responsible business practices. The Group implements various actions and
procedures to ensure long-term relationship with suppliers and adherence to ethical labor,
human rights, working conditions and H&S principles. The Group is in the process to
implement vendor ESG Due Diligence process, using structured ESG questionnaires, which
will facilitate assessing vendors’ performance towards ESG as well as their exposure to
ESG risks.
The Group has no tolerance to facilitating any sort of Financial crime/ terrorism financing
therefore, implements appropriate Due Diligence procedures to ensure that the Group’s
systems and processes are not used by money launderers or anyone involved in criminal
and illegal activities. In addition, the Group is exposed to material risk of external fraud
given the nature of its business model, therefore a set of actions, procedures and internal
controls are implemented to identify, prevent, detect and respond to fraud.
Conflicts of interest and compliance with laws and regulations are fundamental to business
conduct and sustainable business practices. The Group established a compliance
framework that encompasses a set of policies, procedures, and controls designed to ensure
that all our operations and activities align with applicable laws and regulations and conflicts
of interest are identified and managed. The Group’s conflict of interest registry reports
zero conflict of interests assessed as High in 2024.
Key Highlights
Zero conflict of
interests classified
as High
1,576.5 training
hours on
Antibribery and
Whistleblowing
system
1,732.3 training
hours on prevention
of money laundering
and terrorism
financing
1,558.5 training
hours on Fraud risk
awareness
No tolerance to
financial
crime/terrorism
financing
No tolerance to acts
of bribery and
corruption
No tolerance with
regards to non-
compliance with
regulatory, legal and
compliance
requirements
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
82
ESRS 2 General Disclosures
1. General Basis for Preparation
The Sustainability Statement of Bank of Cyprus Holdings Public Limited Company (‘BOCH’ or ‘the Group’) for the
year ended 31 December 2024 has been prepared, on a consolidated basis, in accordance with Part 28 of the
Companies Act 2014 and in compliance with the European Sustainability Reporting Standards (ESRS). The
reporting period and the scope of consolidation of the Sustainability Statement is consistent with the consolidated
financial statements of BOCH.
CSRD mandates the Group to present a comprehensive perspective on ESG topics, covering both the issues that
affect the Group's business and those influenced by the Group's operations, including its entire value chain.
In 2024, BOCH conducted its first Double Materiality Assessment (DMA) to set the basis of the Sustainability
Statement. This analysis identifies the Group’s material impacts, risks and opportunities (IROs) across its
operations, upstream and downstream value chain considering all time horizons; short, medium and long-term.
The Group’s policies, actions, targets, and metrics to address the material IROs identified as part of the DMA
have been disclosed in the respective topical sections, including those associated with the broader value chain.
The methodology and reporting criteria for the DMA process are outlined in 4. Impacts, Risks and Opportunities
under ESRS 2 General Disclosures in page 103. The results of the DMA are reflected in 4. Impacts, Risks and
Opportunities under ESRS 2 General Disclosures in page 107. The DMA supports to inform the Group's potential
strategic choices and shapes its ESG data collection. The Group aims to support a deeper integration of
sustainability across its operations and this includes influencing decision making at every level.
The Group has not omitted any specific information on the basis of intellectual property, know-how, or innovation
results, or the basis of negotiation. Disclosures in the Sustainability Statement refer to the Group, except for
disclosures associated with material impacts, risks and opportunities of banking activities of the Group in which
reference to Bank of Cyprus Public Company Ltd (‘BOC PCL’ or ‘the Bank’) and may be used interchangeably with
the terms BOCH or Group.
For the Statement of Directors' Responsibilities for the Sustainability Statement refer to pages 39 to 40 of the
2024 Annual Financial Report.
Limited Assurance
In accordance with section 1613 of the Companies Act, 2014, this sustainability statement, set out on pages 77
to 254, has been subject to limited assurance by PricewaterhouseCoopers. The elements of this report outside of
the sustainability statement that are covered by their limited assurance procedures are clearly indicated by the
specific ‘(limited assurance)’ reference. Their limited assurance procedures do not extend to any comparative
information, links or references to material outside of the Annual Financial Report (AFR) nor to other sections of
the AFR unless clearly otherwise indicated to the contrary. Their limited assurance report is included on pages
255 to 258 of the AFR and should be read in conjunction with this sustainability report.
Key estimates and judgment
The Group’s presentation of sustainability information may be subject to measurement uncertainty due to
limitations in methodologies and data, including reliance on third-party data for GHG emissions estimation. The
Group uses judgments and estimates for reporting towards Scope 3 GHG emissions. The Group has used
estimates based on recognised frameworks available at this time. The Group will continue to monitor
methodologies and data availability, and update as appropriate. Refer to Reporting Principles under the
Sustainability Statement - Additional Information in page 247.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
83
ESRS 2 General Disclosures (continued)
2. Governance
The role of the administrative, management and supervisory bodies
The Board has ultimate oversight of the identification, assessment and integration of ESG impacts, risks and opportunities throughout the organisation. The Board has
delegated authority to Board Committees to support the ESG oversight. These committees play a role in identifying, managing, and reporting material ESG impacts,
risks, and opportunities as well as oversight the content, scope and reporting process of the CSRD Sustainability Statement. The Terms of Reference of each committee
dictate the responsibilities regarding ESG matters. The following sustainability governance diagram illustrates how BOCH’s governance is currently structured towards
sustainability.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
84
ESRS 2 General Disclosures (continued)
2. Governance (continued)
Sustainability Oversight at Board Level
Group Board
Committees
Role and Responsibilities
Risk
Committee
The main purpose of the Risk Committee (RC) is to review, on behalf of the Board, the
aggregate Risk Profile of the Group, including performance against Risk Appetite for all risk
types and ensure both Risk Profile and Risk Appetite remain appropriate. The RC is
responsible for the following:
i. Oversee the identification, assessment, control and monitor of financial/economic
risks and non-financial risks (including operational, technological, tax, legal,
reputational, compliance, and ESG including C&E risks) which the Group faces in
cooperation with the responsible Board Committees.
ii. Ensure that the Group's overall Risk Profile and Risk Appetite remain appropriate
given the evolving external environment, the Group’s character and the internal
control environment.
iii. Ensure effective and on-going monitoring and review of the Group's management
or mitigation of risk, including the Group's control processes, training and culture,
information and communication systems and processes for monitoring and
reviewing their continuing effectiveness.
iv. Report to the Board any current or emerging topics relating to ESG risks and
matters, including C&E risks and matters, that are expected to materially affect the
business, operations, performance, or public image of the Group or are otherwise
pertinent to it and its stakeholders and if appropriate, detail actions taken in relation
to the same.
v. Determine the principles that should govern the management of risks (including ESG
and C&E risks), through the establishment of appropriate Risk Policies.
vi. Review and monitor key enterprise wide ESG, including C&E, metrics, targets, Key
Performance Indicators (KPIs), Key Risk Indicators (KRIs) and related goals and
monitor the progress towards achieving targets and benchmarks.
vii. Receive and review periodic reports from management on ESG and climate trends,
issues, and risks, including developments in applicable regulations, as well as the
corresponding mitigation initiatives and controls.
Nominations
and Corporate
Governance
Committee
The Nominations and Corporate Governance Committee
(NCGC) has been delegated
authority by the Board to provide oversight to the Group’s sustainability strategy aimed at
achieving present and future economic prosperity, environmental integrity, climate stability
and social equity for the Group and its stakeholders. The NCGC is responsible for the
following:
i. Oversight the development of the strategy for ESG including C&E matters focusing
on Environmental, Climate, Ethical, Social, and Economic pillars and ensure it is
embedded throughout the operations of the Group.
ii. Advise, support and guide the Chief Executive Officer (CEO) and Executive
Management Team in formulating and implementing a business strategy geared to
the sustainable development of the Group taking into account ESG, including C&E
impacts.
iii. Oversee the Sustainability Committee’s (SC) implementation and progress
regarding the ESG working plan.
iv. Review the institution’s response and plan of action to the objectives set out under
international agreements.
v. Review and recommend to the Board for approval the ESG targets and KPIs,
including C&E targets and KPIs, and monitor their performance.
vi. Review and recommend to the Board for approval the non-financial disclosures
presented by the SC, including CSRD Sustainability Statement in accordance with
ESRS.
vii. Review and recommend to the Board for approval the ESG and Environmental Policy
and Sustainable Finance Framework which enables BOCH and/or BOC PCL to issue
Green/Social or Sustainable bonds.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
85
ESRS 2 General Disclosures (continued)
2. Governance (continued)
Sustainability Oversight at Board Level (continued)
Group Board
Committees
Role and Responsibilities
Human
Resources and
Remuneration
Committee
The Human Resources and Remuneration Committee (HRRC) has been delegated authority
by the Board to oversee the implementation of Strategic HR initiatives which promote and
are aligned with the Group’s ESG ambition, strategy and objectives. The HRRC reviews at
least annually the appropriate structure of the remuneration system and whether the total
amount of variable compensation has been set in accordance with the Remuneration
Framework of the Central Bank Directive on Governance. Any enhancements to the
Remuneration Policy to incorporate ESG and climate criteria are recommended to the Board
for approval by the HRRC.
Audit
Committee
The Audit Committee (AC) has been delegated authority by the Board to assess the
soundness of the methodologies and policies that the management of the Group uses to
develop ESG, including C&E metrics and other disclosures and to assess the key vendors’
plans about sustainability.
The AC is responsible for the following:
i. Ensure the ESG frameworks/standards, including C&E frameworks/standards, used
are proper and relevant climate-related financial disclosures are investor grade.
ii. Consider materiality in terms of how ESG issues, including C&E issues, impact the
Group’s financial performance and ability to create long-term value (Financial
materiality) and how the Group’s actions impact people and the planet (Impact
materiality).
iii. Review other material public disclosures with respect to ESG, including C&E matters
and discuss with management the Group’s engagement with stakeholders on key
ESG matters, including C&E matters, including in response to any proposals or other
concerns that have been submitted to BOCH and/or BOC PCL or the Board.
iv. Ensure that Internal audit incorporates ESG, including C&E risks, in its Risk and
Audit Universe.
v. Overseeing all matters relating to the relationship between the Group and the
external auditors. This also includes overseeing the external audit activities in
relation to the limited assurance over the Sustainability Statement.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
86
ESRS 2 General Disclosures (continued)
2. Governance (continued)
Sustainability Oversight at Management level
The Group has set certain roles and responsibilities for the Group’s Management Committees to provide oversight
related to ESG impacts, risks, opportunities, goals and disclosures. Refer below to the roles and responsibilities
associated with the Group Executive Committee and Group Sustainability Committee.
Role and Responsibilities
Group Sustainability Committee
The
Sustainability Committee (
SC
)
is an executive level committee chaired by the CEO and has as a primary
role the oversight of the ESG agenda of the Group aiming to lead the Group towards a cleaner, fairer, healthier,
and safer world by helping its customers manage risks in a long term sustainable and equitable way, and to
be the employer of choice. The SC is responsible for the following:
i. Monitor and review the development of the Group's ESG strategy including the management of ESG
risks, including C&E risks and recommend to EXCO for approval. Following EXCO approval then it is
recommended to the Board for consideration and approval through NCGC.
ii. Oversee the implementation of the Group's ESG & Climate strategy.
iii. Review the institution’s response and plan of action to the objectives set out under international
agreements and makes recommendations for the plan of actions to the EXCO for approval. Following
EXCO approval then is recommended to the Board for consideration and approval through NCGC.
iv. Review the ESG including C&E targets and KPIs and recommends to EXCO for approval. Following EXCO
approval then is recommended to the Board for consideration and approval through NCGC. Monitor the
performance of the targets and KPIs set.
v. Review the incorporation of ESG including C&E targets, KPIs and KRIs in the business strategy and risk
appetite.
vi. Monitor progress against the Group’s ESG working plan on a quarterly basis including the implementation
of the ECB Guide on C&E risks.
vii. Monitor progress on KPIs set to manage C&E risks and the performance against wider ESG targets, on
a quarterly basis, through the Sustainability Performance Report. The Sustainability performance report
is monitored by the EXCO and NCGC on a quarterly basis.
viii. Request from the relevant departments to submit proposals and recommendations of corrective actions
whenever a KPI to manage C&E risks is not aligned with the thresholds set.
ix. Monitor KRIs set to manage C&E risks, through the Climate Risk report, on a quarterly basis. The Climate
Risk Report is also monitored by the EXCO and RC on a quarterly basis.
x. Oversee the degree of the Group’s alignment with regulatory ESG including C&E related guidance, rules
(such as EU Taxonomy, SFDR and CSRD) and ECB expectations.
xi. Oversee the establishment of environmentally friendly products and Sustainable Finance Framework.
xii. Review policies relating to ESG matters, including C&E matters, to ensure that they are in line with the
needs of the Group and the Group’s ESG strategy and that they comply with applicable legal and
regulatory requirements. Monitors the implementation of policies relating to ESG including C&E matters
(excluding ESG and C&E risks related policies).
xiii. Review and challenge Risk Management Division (RMD) regarding ESG matters and policies, including
C&E risks related matters and policies, such as ESG and C&E risk identification, quantification, materiality
assessment (MA) and establishment of ESG and C&E criteria in the loan origination process. RMD
subsequently submits to the Board for consideration and approval through RC for approval of ESG and
C&E risks related matters and policies, also notifying EXCO.
xiv. Review non-financial disclosures and recommends to the Board for consideration and approval through
NCGC and EXCO.
xv. Monitor the external ESG and C&E trends affecting the formulation of ESG policies, strategies and
objectives
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
87
ESRS 2 General Disclosures (continued)
2. Governance (continued)
Sustainability Oversight at Management level (continued)
Role and Responsibilities
Group Executive Committee
The EXCO is responsible for the following:
i. Consider the overall financial performance and progress of the Group per line of business, including,
but not limited to, the Group’s capital and liquidity position, the Group profitability, the Non-Performing
Exposures (NPE) and the REMU portfolio.
ii. Consider the market conditions and strategic initiatives.
iii. Monitor the recovery and early warning indicators and assess the need to escalate for further action to
the RC and the Board.
iv. Consider the Risk Report.
v. Consider and approve budgets, business strategies/risk strategy to be presented to the Board for
approval.
vi. Consider and approve the Group’s Risk Appetite Statement to be presented to the RC and Board for
approval.
vii. vii. Consider and approve the Group’s Capital Plan to be presented to the RC and the Board for approval.
viii. Consider the Compliance Reports/Matters and progress.
ix. Consider the Internal Audit Reports/Matters and progress.
x. Consider the HR/People Management/Matters and progress.
xi. Consider the Corporate Affairs Report/Matters and progress.
xii. Approve all matters escalated to EXCO within its delegated authorities and/or recommend matters
requiring escalation to the Board.
xiii. Consider all other matters escalated for discussion by any member of the EXCO or any other
Committee/Forum.
xiv. Monitor the Board and Board Committees pending decision lists.
xv. Note the minutes of the Acquisition & Disposal Committee (ADC), Group Asset & Liability Committee
(ALCO), the Regulatory Steering Group (RSG) and the Business Development Committee (BDC).
Internal controls and procedures in place for Management Committees and Board to monitor the management of
impacts, risks and opportunities are described in pages 84-87, 88, 91-92 and 104.
Following the compilation of the ESG strategy in 2021, and the ESG working plan in 2022 - 2024, specific
accountabilities are assigned to the Group’s Executives and Directors. The ESG responsibilities assigned to key
Executives and Directors of the Group are summarised in the table below:
Chief
Executive
Officer
The CEO governs the sustainability performance of the Group, driving focus
on ESG and climate
stewardship and tracking progress made across the business to meet the Group’s ESG and climate
ambitions through the long-term ESG working plan. The CEO is involved in the identification of
sustainable finance growth opportunities for the Group and promoting the development of these
in tackling climate change.
Executive
Director
Finance
The Executive Director of Finance is responsible for the successful integration of ESG into the
Group’s core business operations, in cooperation with business lines Directors, and long-term
business strategy as well as the oversight of the progress of the ESG working plan for the
implementation of ESG and climate strategy and sustainability reporting including Sustainability
Statement under CSRD. In addition, the Executive Director of Finance is responsible for the
oversight of the estimation of Scope 1, Scope 2 and Scope 3 GHG emissions of the Group and the
establishment of C&E decarbonisation targets and strategy, in cooperation with Deputy CEO and
Chief Risk Officer.
Chief
Risk
Officer
The Chief Risk Officer
(CRO)
is responsible and accountable for the process of effectively managing
ESG, including the C&E, risks of the Group. This includes the responsibility of overseeing the
implementation of the ESG working plan which supports the C&E risk identification, measurement,
assessment, stress-testing and limit setting, as well as the supporting governance. The role
further encompasses the responsibility of reviewing risk appetite and C&E risk appetite metrics.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
88
ESRS 2 General Disclosures (continued)
2. Governance (continued)
Sustainability Oversight at Management level (continued)
The Group, in 2024, further enhanced the ESG working plan, compiled in 2022, which is monitored by Investor
Relations & ESG Department (IR&ESG), RMD, the SC, the EXCO and ultimately by NCGC and RC. The ESG working
plan is structured in workstreams which are designed to articulate delivery of Group’s ESG strategic objectives
and are aligned with ECB expectations and other regulatory disclosure requirements. Each workstream is
associated with specific activities designed to meet relevant reporting and regulatory requirements and achieve
the Group’s targets and objectives. For the successful delivery of the Group’s ESG strategic objectives the Group
has formed an ESG working group comprising of experts from various departments assigned with specific
activities under the ESG working plan. Each activity completed by the ESG working group, is reviewed by the
IR&ESG and RMD. The progress, status and output of activities is following the relevant governance arrangements
as described above. In addition, the Group has assigned roles and responsibilities on ESG to the Business Lines,
Compliance Division (CD) and Internal Audit Division (IAD).
Sustainability related skills and expertise
At Board level, the NCGC assesses periodically, and at least annually, the structure, size, composition, and
succession plan of the Board (including skills, knowledge, experience, independence and diversity) and
recommends to the Board the skills and experience required to provide sound governance oversight. Following
2023 review of knowledge, experience and skills in the Board, the NCGC concluded that the Board's skills profile,
both academic and professional, aligns with the diverse needs of the Group's business. However, it was identified
that the area of ESG require further strengthening to align with the Group's strategic direction. The Group, on
May 2024, appointed Mr. Christian Philipp Hansmeyer as an independent non executive director with significant
experience in sustainable finance, ESG and impact investing to enhance further the ESG expertise in the Board.
NCGC, in 2024, concluded that the Board's skills profile, both academic and professional, aligns with the diverse
needs of the Group's business. All members of the Board, as well as the Executive and Supervisory Committees,
possess an appropriate level of understanding of sustainability matters. To ensure its administrative and
supervisory bodies collectively maintain the necessary skills and expertise, the Group engages internal and
external sustainability experts and provides dedicated training programs.
In support of the Group’s sustainability strategy and to meet regulator, investor, customer and colleague
expectations, the Group develops on an annual basis a Board training plan which includes trainings associated
with sustainability. In addition, all employee training on climate concepts and processes as well as job specific
training supports the development of skills and expertise across the Group.
2024 Sustainability Trainings
Trainings No. of participants
Training
attendance (Hours)
Relevance to IROs
Board
Embedding
C
limate
Risk
in Business Strategy &
Execution
8 9
Climate Change
-
Climate
Change Mitigation & Climate
Change Adaptation & Energy
EXCO
and
SC
Embedding
C
limate
Risk
in Business Strategy &
Execution
22 30
Climate Change
-
Climate
Change Mitigation & Climate
Change Adaptation & Energy
All staff
E-learning on Green
Transition
2,561 1,280.5
Climate Change
-
Climate
Change Mitigation & Climate
Change Adaptation & Energy
The Board, during the Board offsite in 2024, received training associated with CSRD. For trainings conducted at
Board, Senior Management level and individual contributors on Business Conduct IROs refer to 5. Training on
Business Conduct under ESRS G1 – Business Conduct in page 216.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
89
ESRS 2 General Disclosures (continued)
2. Governance (continued)
Board’s Composition
As at 31 December 2024, the Board comprised of eight (8) members (2023: nine (9)), the Group’s Chairperson,
who was independent at the time of appointment and remains independent, alongside two (2) executive directors
(2023: two (2)) and five (5) non-executive directors (2023: six (6)). The Board comprises of six (6) non-executive
directors (including the Chairperson) as at 31 December 2024 (2023: seven (7)). 75%
ii.
(2023: 66.7%
ii.
) of Board
members have the status of independent as at 31 December 2024.
Board of Directors Composition
31
December 2024
Position in Board
Name
Independence Status
Chairperson
Efstratios
-
Georgios Arapoglou, (Non
-
Executive Member)
Independent
Vice
-
Chairperson
Lyn Grobler (Non
-
Executive Member)
Independent
Executive Members
Panicos Nicolaou
Non
-
independent
Eliza Livadiotou
Non
-
independent
Non-Executive
Members
Adrian John Lewis
Independent
Monique Eugenie Hemerijck
Independent
Christian Philipp Hansmeyer
Independent
William Stuart Birrell
Independent
Note:
i. The Chairperson, Mr. Arapoglou, was independent on appointment and continues to operate in a manner that is
independent in character and remains objective in his opinions having no other relationship or circumstances to affect
his judgement. He commits the appropriate time for the Group’s business, which is slightly more than the other non-
executive directors, and it approximately amounts between 60-70 days per year. He has no other remuneration from
the Group other than as Chairperson of the Board and chairperson of the NCGC, and member of the HRRC.
ii. The ratio includes the Chairperson both in the numerator and denominator.
Topical details on the role of Administrative, management and supervisory bodies are described in the following
sections.
GOV
1
Topical ESRS
ESRS
Page
G1
-
Business conduct
214
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
90
ESRS 2 General Disclosures (continued)
2. Governance (continued)
Board’s Diversity
Female representation on the Board is a key aspect of diversity, with three (3) women and five (5) men, resulting
in an average female-to-male ratio of 0.6:1 as at 31 December 2024 (2023: 0.8:1). BOCH has a strategic
objective to include diverse perspectives, and this is assessed through the at least annual assessment performed
by the NCGC on structure, size, composition and succession plan of the Board. For further information on the
Group’s approach to Board diversity, refer to the Board Nominations and Diversity Policy which is available on
the Group’s website.
In the 2024 review of knowledge, experience, and skills, the NCGC concluded that the Board's skills profile, both
academic and professional, aligns well with the diverse needs of the Group's business. This includes sectors such
as banking, insurance, audit and accounting, risk management, interactions with competent authorities, strategy
and business modelling, capital markets, information technology, ESG and human resource management.
35%
22%
26%
17%
Industry Skills/ Experience
Banking
Insurance
Digital/ Tech/ IT
Other Industry
9%
11%
6%
8%
6%
11%
7%
8%
9%
11%
11%
3%
Functional Skills/Experience/Knowledge
Accounting & Audit
Risk/ Compliance Management
Consumer Banking
Investment Banking
Corporate Banking
Capital Markets
Human Resources/ Remuneration
Digital / Tech/ Cybersecurity
ESG
Governance
Strategy/ Transformation
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
91
ESRS 2 General Disclosures (continued)
2. Governance (continued)
Sustainability matters addressed by the Board and Management Committees
All ESG matters that are submitted to the Board and Management Committees are in the form of formal documentation describing the purpose and scope of the paper,
the methodology applied, any considerations conducted during the process, any assumptions made, and the conclusions/results reached. The papers are presented to
the Board and Management Committees by the responsible Division/Department. The relevant Board and Management Committee enquires and challenges the
responsible Division/Department in order to approve the relevant paper. The Group has introduced frequent reporting to administrative, management and supervisory
bodies around sustainability matters, predominantly climate, as follows:
Reporting
Frequency
Committee
Material Impacts, Risks and
Opportunities
Progress update to the ESG
working plan
Quarterly
1. SC/EXCO
2. NCGC/RC
1.
Progress update on the ESG Working plan designed to articulate delivery of Group’s ESG
strategic objectives and is aligned with ECB expectations and other regulatory disclosure
requirements
Sustainability performance report Quarterly
1. SC/EXCO
2. NCGC
1.
Progress update on Climate change mitigation GHG emission reduction targets
(42%
reduction of Scope 1 and Scope 2 GHG emissions by 2030 compared to 2021 and 43%
reduction in carbon intensity metric of mortgage portfolio by 2030 compared to 2022)
2. Progress update on Climate change mitigation new lending internal KPIs
Climate risk report Quarterly
1. SC/EXCO
2. RC
1.
Update on e
xposure
to
C&E risks
2. Progress on Climate change mitigation KRIs
3. Progress on Climate change adaptation KRIs
4. Update on implementation of ESG Due Diligence on loan Origination process
5. Update on Energy Performance Certificates (EPC)
Risk
a
ppetite
f
ramework
(RAS)
dashboard
Quarterly
1.
EXCO
2. RC
1. Climate change mitigation and climate change adaptation update on KRIs
Business
e
nvironment
s
can
(
BES
)
preliminary impact assessment on
C&E updates and developments
Quarterly 1. SC/EXCO
1. Identification of C&E related updates and developments impacting Business Strategy and
Risk assessment of the Group (Climate Change ROs).
BES
f
inal
i
mpact
a
ssessment on
C&E updates and developments
Annually
1.
SC/EXCO
2. NCGC/RC
1.
Identification of C&E risk related updates and developments and integration to
the Business
Strategy and Risk assessment of the Group (Climate Change ROs).
Double materiality assessment Annually
1. SC/EXCO
2. NCGC/AC
1.
Approach towards DMA
2. Approach to the Group’s Business segments on DMA
3. Impacts identified and threshold applied
4. Risks and opportunities identified and threshold applied
5. Key assumptions used in the DMA and procedures performed to support the assumptions
6. Material IROs identified and comparison of IROs with best practices
7. Results of stakeholder validation and consultation procedures
Green new lending internal KPIs Monthly 1. BDC/EXCO
1.
Progress update on
energy, c
limate change mitigation
and adaptation
new lending
internal
KPIs
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
92
ESRS 2 General Disclosures (continued)
2. Governance (continued)
Sustainability matters addressed by the Board and Management Committees (continued)
The Board, through Board committees engaged in a broad range of matters associated with sustainability IROs
in 2024, including:
Updates to Group’s policies
Corruption and bribery
Financial crime and fraud
Compliance with laws and regulations including occupational safety
Information security
Privacy matters
Grievance mechanisms
Double materiality assessment in accordance with ESRS
Sustainability and C&E risks
Green new lending internal KPIs embedded in Group’s Financial Plan
Strategic GHG emissions reduction targets
Operational limits on C&E physical and transition risks
Remuneration policy
Digital transformation
Integration of sustainability in Business Strategy
The Group enhanced the Group Financial and Business Plan manual to ensure the incorporation of considerations
on ESG including C&E impacts, risks and opportunities in the Business Strategy. Specifically, during the planning
phase of new lending the RMD and IR&ESG provide the sectors associated with C&E risks, the preliminary impact
assessment derived from BES process, science-based targets (GHG emission reduction targets aligned with a
climate scenario) set and the direction of Green/Transition new lending based on BES. In addition, each Division,
taking into account the preliminary impact assessment (performed by RMD, IR & ESG and Strategy) on risk profile
and strategy arising from the BES on C&E risks as well as the MA on C&E risks, identifies which are the material
C&E risks over the Financial plan period and defines the actions, strategies and products to mitigate the C&E risks
identified. IR&ESG department is responsible for the adequacy, relevance and reasonableness of the business
lines strategies to manage material C&E risks on the main portfolios.
Integration of sustainability-related performance in incentive schemes
The Group has taken necessary steps in embedding its ESG strategic goals within its remuneration policy, to
connect the performance of its personnel to ESG and climate matters. The remuneration policy promotes sound
and effective risk management, in line with the Group’s ESG and climate strategy and does not encourage
excessive risk taking that exceeds the level of risk tolerated by the Group. Remuneration structure of the Group
typically consists of fixed plus variable pay. Fixed remuneration does not embed any ESG incentive considerations.
Variable remuneration
1
is based on a combination of the performance of the employee, the overall performance
of the business unit the individual belongs to, and the Group’s consolidated financial results.
Regarding variable remuneration, performance criteria (financial and/or not financial), set to measure the
performance of Senior Management, contain KPIs that relate to the implementation of the Group's ESG strategy,
reflecting the Group’s emphasis on achieving its sustainability related objectives, in accordance with the role and
responsibility of each Senior Manager in relation to the ESG Strategy. These KPIs are used to evaluate the
performance of Senior Management, when the distribution of a Short-Term Incentive Plan (STIP) is activated.
Specifically, the percentage of the salary to be paid as STIP for Senior Management is adjusted in accordance
with Group’s performance and individual performance. The KPIs embedded in the performance criteria of Senior
Management are primarily qualitative (Oversee the ESG Working Plan, effective implementation of
decarbonisation activities on own operations etc.) but certain quantitative KPIs are included as well, such as
annual Green new lending internal KPIs for Business Lines. The weight of ESG related KPIs on individual Senior
Management’s performance appraisal is between 3%-15%. Senior Management’s KPIs for individual performance
appraisal are approved annually by HRRC. The Board should annually approve a proposal for the implementation
of a Short-Term Incentive Plan (STIP) across the organisation. The allocation criteria are to be decided on an
annual basis by the HRRC.
1
Additional discretionary remuneration paid to an individual as an incentive for increased productivity and competitiveness.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
93
ESRS 2 General Disclosures (continued)
2. Governance (continued)
Integration of sustainability-related performance in incentive schemes (continued)
The annual bonus pool will vary in accordance with the Group’s performance/profitability for each financial year.
Performance will typically be assessed based on a one-year performance period.
The Long-Term Incentive Plan (LTIP) was approved by the 2022 AGM, which took place on 20 May 2022. The
LTIP involves the granting of share awards and is driven by scorecard achievement, with measures and targets
set to align pay outcomes with the delivery of the Group’s strategy. Currently, under the plan, the employees
eligible for LTIP awards are the members of the Extended EXCO, including the executive directors. The LTIP
stipulates that performance will be measured over a 3-year period and sets financial and non-financial objectives
to be achieved. At the end of the performance period, the performance outcome will be used to assess the
percentage of the awards that will vest. The AGM resolution, approved by the shareholders in May 2024, gave
the Group the flexibility to increase the ratio of variable to fixed remuneration to up to a maximum of 100% for
Material Risk Takers. Up to 100% of the awards will be subject to malus and clawback provisions in accordance
with applicable legislation and regulations.
The applicable scorecard under the LTIP include a KPI on external ESG rating score with a target being an AA
ESG rating for the Group, and this outcome has a 5% weight in the LTIP. Topical details on the integration of
sustainability-related performance in incentive schemes is described in the ESRS E1 - Climate Change in page
110.
Statement on due diligence
The following table provides a mapping of how BOCH applies the core elements of due diligence for people and
the environment and where they are presented in this Sustainability Statement:
Core elements of Due
Diligence
ESRS
Does the disclosure
relate to people and/or
the environment?
Page
Embedding due
diligence in governance,
strategy and business
model
ESRS 2 GOV-2 People and Environment 83
ESRS 2 GOV
-
3
People and Environment
92
ESRS 2 SBM-3 People and Environment 95
Engaging with affected
stakeholders
ESRS 2 GOV-2 People and Environment 91
ESRS 2 SBM
-
2
People and Environment
99
ESRS 2 IRO
-
1
People and
Environment
105
identifying and
assessing negative
impacts on people and
the environment
ESRS 2 IRO-1 People and Environment 103
ESRS 2 SBM-3 People and Environment 102
taking action to address
negative impacts on
people and the
environment
ESRS – E1 People and Environment 132
ESRS – E2 People and Environment 158
ESRS – E3 People and Environment 164
ESRS – E5 People and Environment 168
ESRS – S1 People and Environment 176, 179, 184
ESRS – S4 People and Environment
193, 195, 199,203, 205,
209, 210,
211, 213
ESRS – G1 People 217, 218, 219, 222,224, 226, 227
tracking the
effectiveness of these
efforts
ESRS – E1 People and Environment 132
ESRS
E2
People and Environment
161
ESRS
E3
People and Environment 165
ESRS
E5
People and
Environment
166
ESRS
S1
People and Environment
176, 180, 184, 187
ESRS – S4 People and Environment
193, 195, 197, 200, 203, 205,
207,209, 210, 211, 213
ESRS
G1
People
217, 219, 222, 223, 224, 226,
227
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
94
ESRS 2 General Disclosures (continued)
2. Governance (continued)
Risk management and internal controls over sustainability reporting
The Group identified the operational risks in respect of sustainability reporting, which are similar to existing risks
of the Group's Annual Report. This enabled the Group to leverage the existing suite of controls around the Annual
Report and have applied those controls to the Sustainability Statement where appropriate. Key risks in
sustainability reporting include inaccurate and/or incomplete reporting due to human error and failure to deliver
the Sustainability Statement on time, due to system failure or manual processes.
Internal controls in place to mitigate those risks include:
Responsible team comprises of properly qualified, well trained, experienced and competent staff.
Automations to the extent possible are made (e.g. data automatically extracted from/uploaded in
systems/files).
Files are reconciled with Group’s systems and/or other financial information.
Four eyes principle in place.
Monitoring arrangements towards Sustainability Statement:
Development and monitoring of work plan and deliverables ensures adherence to deadlines.
The Sustainability Statement is reviewed by the relevant content owners (Senior Management), the
Manager of the IR&ESG Department, Group’s Deputy Chief Financial Officer and the Executive Director
Finance.
The Sustainability Statement is prepared with the support of external advisors.
The Sustainability Statement is reviewed and recommended by the SC and EXCO to the Board for
consideration and approval through NCGC, RC and AC. Detailed papers are prepared for review and
approval by the Management and Board Committees covering all sustainability issues including
presentations and disclosures.
Monthly update performed to the AC regarding the Sustainability Statement in accordance with ESRS.
The Group has developed an Integrated Risk Identification Framework which provides for the identification,
evaluation and management of the principal risks the Group faced. Risks on sustainability reporting are currently
captured under the Key Risk Matrix, which is updated and is approved by the Board through RC, under the risk
for Statutory reporting. The group will continue to enhance the procedures and controls as the reporting matures.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
95
ESRS 2 General Disclosures (continued)
3. Strategy, Business Model, Value Chain and Stakeholder Engagement
Strategy, business model and value chain
Strategy
The Group’s strategy is guided by the mission statement “Our organisation exists to support our clients in their
most important life events as well as in their daily needs. To achieve this, we invest capital and effort to ensure
that our services are provided by top quality professionals and the usage of cutting-edge technology and uphold
sound and ethical practices. We will continue to be not only a systemic bank driving growth and shareholder value
but also a key driver of progress in our community.”
The Group, as enforced by the ESG strategy, is determined to play a leading role in the transition of Cyprus into
a sustainable future. During 2024, the Group has made significant progress in enhancing its ESG agenda in its
portfolio and operations. The Group continues its “Beyond Banking” strategic approach to sustainability and
established ESG as one of its four strategic pillars, with a special focus on the fight against climate change and
its ambition to Net Zero by 2050. BOCH’s ESG strategy, formulated in 2021, is continuously expanding ensuring
the Group maintains its leadership role in the Social and Governance pillars while accelerating efforts to address
critical environmental challenges. In 2024, BOCH continues to be committed towards its primary ESG ambition:
Own operations
42% GHG
emission
reduction by
2030
The Group aims to become carbon
-
neutral
in own operations
by 20
5
0, by gradually
eliminating its scope 1 and 2 GHG emissions. The Group has estimated the Scope 1 and
Scope 2 GHG emissions of 2021 relating to own operations in order to set the baseline for
carbon neutrality target in own operations by 2050. The Group has estimated Scope 1 and
Scope 2 GHG emissions for 2024 to monitor the progress on carbon neutrality target in
own operations. The Group has set an interim target in line with carbon-neutrality ambition
in own operations to reduce Scope 1 and Scope 2 GHG emissions by 42% (absolute target)
by 2030 compared to the baseline of 2021.
Become Net
Zero by 2050
The
Group
’s
ambition
to become Net Zero, by reducing its
Scope 1, Scope 2 and
Scope 3
emissions through its supply chain (i.e. third-party providers) and its financing activities,
which also entails the alignment and commitment of our customers towards this goal.
Steadily
increase Green
Asset Ratio
(GAR)
The Group aims to increase GAR.
The GAR indicates the degree of alignment with the EU
Taxonomy, such as showing the proportion of the share of credit institution’s assets
financing and invested in EU Taxonomy-aligned economic activities as a share of total
covered assets, such as those consistent with the European Green Deal and the Paris
agreement goals.
The Group’s GAR as at 31 December 2024 was 0.6% (Turnover based) and 0.3% (CapEx
based) as at 31 December 2023 was 0% (Turnover based) and 0.01% (CapEx based).
Steadily
increase Green
Mortgage Ratio
In accordance with the Green Asset Ratio, the numerator consists of mortgages used only
for sustainable activities related to the construction of new buildings and renovation of
buildings, while the denominator includes all mortgages. The Group has not yet developed
EU taxonomy aligned Mortgages, however, aims to launch such an offering in upcoming
years.
The aspiration to achieve a representation of at least 30% women in Group’s management bodies (Defined as
the EXCO and the Extended EXCO) by 2030, has been reached earlier with 33% representation of women, as at
31 December 2023 and 31 December 2024.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
96
ESRS 2 General Disclosures (continued)
3. Strategy, Business Model, Value Chain and Stakeholder Engagement (continued)
Strategy, business model and value chain (continued)
Business Model
Input How we operate
How we add value
Outputs and Impacts
Financial Capital
1. Total Assets
2. Cost (staff costs,
other operating
expenses, Special
levy on deposits and
other
levies/contributions):
406mn
3. Customer deposits:
20,519mn
Group products and services
1. Retail Banking
2. SME Banking
3. Corporate Banking & Large Corporate Banking
4. International Business Unit & International Banking
5. Brokerage Services
6. Asset Management
7. Finance
8. Affluent Banking
9. Custody and Depositary Services
10. Global Markets execution services
11. Factoring
12. Investment Banking
13. Life Insurance
14. General Insurance
Group’s significant products and services and
customer group applying AR13 ESRS 2 SBM 1, are
the following:
1. Retail Banking
2. SME Banking
3. Corporate Banking & Large Corporate Banking
4. International Business Unit & International Banking
Group’s significant geographical area is Cyprus.
1.
Net profit:
508mn
2. Total Operating
income: 1,096mn
3. Tax: 81mn
4. Gross loans:
10,114mn
5. Net Interest Income:
822mn
Social and
Relationship Capital
1. 1mn social
responsibility budget
to support society
2. 2mn in 2024 for
Oncology Centre
1.
Oncology
Centre
reinforced medical
education and
research through
collaborations with
the University of
Cyprus and St.
George’s University of
London
Intellectual and
industrial Capital
1. Digital
transformation
2. Internet Banking
3. BoC Mobile App
(Group’s mobile
application)
4. GIC customer portal
T
he Group stands as a pioneer of digital banking
innovation in Cyprus, reshaping the banking experience
into something more intuitive, more responsive, and more
aligned with the contemporary needs of its customers,
consistently pushing the boundaries to offer unparalleled
banking services. The Group aims to continue to innovate
and simplify the banking journey, providing a unique and
personalised experience to each of its customers. The
Internet Banking and BoC Mobile App are central part of
the ongoing ambition to refine, expand and elevate digital
services.
1.
Quick loans and
eloans: 106.7mn
2. Non-life insurance
digital sales: 613k
3. Digital cards: 23k
4. Digital Deposit ratio:
92.2%
5. Digital Transaction
ratio: 95.54%
6. Digital Accounts: 22k
Human Capital
1. Employee costs:
203mn
2. Strong team of data
scientists, engineers
and analysts
3. Health & Safety
Management System
The Group employed on
head count basis as at 31
December 2024 2,872 (2023: 2,819) employees in
Cyprus, 8 (2023: 11) employees abroad.
1.
94.65%
of Group’s
employees covered
under HSMS
2. 3 recordable work-
related injuries
3. 0.65 rate of work
related injuries
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
97
ESRS 2 General Disclosures (continued)
3. Strategy, Business Model, Value Chain and Stakeholder Engagement (continued)
Strategy, business model and value chain (continued)
Business Model
Input How we operate
How we add value
Outputs and Impacts
Natural Capital
1. ESG strategy
2. ESG working plan
designed to deliver
the ESG agenda of
the Group
3. ESG working group
4. Investment in energy
saving activities
5. Set Green/Transition
new lending internal
KPIs
6. Established a
structured and
detailed BES process
7. Set the first
decarbonisation
target on Mortgage
portfolio aligned with
climate scenario
8. Launhed Green
Housing product
9. Fil-eco Product
Scheme
The Group in its ESG Strategy is committed to increase
positive impacts on the Environment by transforming not
only its own operations, but also the operations of its
customers. A key part of the Group's commitment is to
develop financial products that support the transition
which aligns with the Group's commitments under the
United Nations Environment Programme Finance Initiative
(UNEP FI) Principles for Responsible Banking (PRB).
Group’s Environmentally friendly and green products
offerings include:
1. Energy Loans (Solar panels, energy efficiency actions,
energy upgrade and other systems)
2. Green Housing
3. Green Car
4. Renewable energy projects
5. Green lending to Corporate & SME customers under
the Green lending policy
At the end of 2024, the Group announced the following to
support Cypriot economy:
1. Reward programme for performing housing loan
borrowers
2. Provision of interest rate subsidies for young couples
and Cypriots in designated or mountain areas
3. 5-year fixed rate business loan to microbusiness (Line
1) and small SMEs (Line 2) at preferential fixed
interest rate for energy and digital upgrade
1.
2
5
%
reduction in
Group’s Scope 1 and
Scope 2 GHG
emissions, achieved
by 2024 compared to
baseline of 2021
2. 12% reduction
achieved in carbon
intensity metric on
Mortgage portfolio
between 2024 and
2022 baseline
3. 355mn gross loan
amount for
environmentally
friendly products and
Green Housing as at
31 December 2024
4. 17,412 MWh energy
consumed
5. Solar Energy
Production 408 MWh
6. Established an ESG
Due Diligence process
in the loan origination
process
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
98
ESRS 2 General Disclosures (continued)
3. Strategy, Business Model, Value Chain and Stakeholder Engagement (continued)
Strategy, business model and value chain (continued)
Value Chain
The concept of the value chain takes into account the entire spectrum of activities, resources, and relationships that are part of the Group's business model and its
interaction with the external environment. This includes the Group's internal operations and its interactions with suppliers, partners, and customers. It is a
comprehensive view of how the Group operates within its ecosystem:
1. an entity is considered downstream from the Group when it receives products or services from the Group.
2. an entity is considered upstream from the Group when it provides products or services that are used by the Group.
3. Group's own operations comprise the Group's properties, branches and its internal functions.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
99
ESRS 2 General Disclosures (continued)
3. Strategy, Business Model, Value Chain and Stakeholder Engagement (continued)
Interests and views of stakeholders
The Group’s approach to sustainability is rooted in regular, transparent, and trust-based dialogue with its stakeholders. This engagement helps identify, evaluate, and
prioritise the most significant impacts of the Group’s activities on the environment, people, and the economy.
Stakeholders are defined as individuals or groups whose interests are affected or could be affected by the Group’s activities or those who may reasonably influence the
Group’s ability to implement its strategies and achieve its objectives for building an inclusive and sustainable community. In 2024, BOCH reaffirmed the stakeholder
groups identified in its 2023 sustainability report, ensuring consistency and relevance in its engagement efforts. While no direct consultations with external stakeholders
were conducted, the Group leveraged the expertise of its internal management members who are in frequent communication with the external stakeholder groups and
have a deep understanding of their expectations.
Stakeholders
Type of stakeholder
engagement /
Engagement Channels
Purpose Outcome
Board
1. Meetings
2. AGMs
3. Ask the Board
4. Trainings
1. Drive accountability and transparency in decision-
making processes
2. Provide strategic direction for achieving long-term
value creation
1.
Update the ESG
Working Plan
2. Enhance Sustainability Statement
3. Product/service improvements
4. Improvements in the distribution channels
5. Improvements in the loan origination process
6. Establish GHG emission reduction targets
Employees
1.
Personal/Group meetings
2. Internal workshops
3. Employee opinion survey
4. Management practices
survey
5. Ask the CEO / Extended
Leadership Team
6. Ask the Board
1. Foster a strong, engaged, and informed workforce
2. Improve job satisfaction and morale through
feedback mechanisms
3. Enhance skills and knowledge
4. Build a culture of collaboration and innovation
1. Improved workplace morale reflected in
employee engagement metrics
2. Update Organisation Health initiatives
3. Update employee training programme
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
100
ESRS 2 General Disclosures (continued)
3. Strategy, Business Model, Value Chain and Stakeholder Engagement (continued)
Interests and views of stakeholders (continued)
Stakeholders
Type of stakeholder
engagement /
Engagement Channels
Purpose Outcome
Investors and
Shareholders
1. Investor meetings,
emails, conference calls
2. Annual and Extraordinary
general meetings
3. Conferences and
roadshows
1.
Ensure transparency on financial and non
-
financial
performance, including ESG disclosures
2. Demonstrate commitment to long-term value
creation and risk management
3. Attract responsible investment aligned with
sustainability goals
4. Address investor concerns and align with
shareholder expectations
1. Update the ESG Working Plan
2. Enhance Sustainability Statement
3. Adapt internal communication on
sustainability practices
4. Responses to investor queries
Customers
1. Phone access to one’s
personal banker
2. Personal meetings
3. Teams or teleconference
4. Focus groups and surveys
5. SupportCY
2
network
6. ESG Due Diligence
1.
Understand and address
customer needs and
preferences through offering transparent, ethical,
and innovative financial products and services.
2. Enhance customer loyalty through tailored
solutions and strengthening customer
relationships through clear communication and
value-added services
3. Assess customers’ performance and risk exposure
against ESG criteria
1. Product/service improvements
2. Improvements in the distribution channels
3. Improvements in the loan origination process
4. Adaptation of marketing strategies
5. Customer ESG score and high-level action
plan to improve the ESG score
6. Support customer’s decarbonisation through
environmentally friendly and green solutions
Civil Society and
Non-governmental
organizations
(NGOs)
1.
Regular direct contact
and honest cooperation
2. Partnerships with NGOs
3. Contributions to research
projects
4. Interviews, press releases
5. Advertising campaigns
6. Content creation and
support on non-banking
issues
7. SupportCY
2
network
1. Contribute to community well-being through
education, health and environmental initiatives,
and social development programs.
2. Addressing concerns of communities
3. Strengthen relationships with local communities
and NGOs to address societal needs effectively.
4. Collaborate to address environmental and social
challenges, leveraging NGOs’ expertise.
1. Specific initiatives on education, health and
environmental pillars
2. Develop new initiatives based on society’s
needs
2
The SupportCY network was created in March 2020 by BOC PCL for immediate support to frontline professionals working in the battle against COVID-19, by forming a unique chain of supporters, receivers and
enablers, and creating Social Capital. SupportCY also offers further assistance during other national and international crises and disasters, such as fires, earthquakes, etc. Furthermore, SupportCY focuses on
meeting the various needs of the Cypriot society and has become a central point of response and assistance, not only for NGOs but also for governmental services.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
101
ESRS 2 General Disclosures (continued)
3. Strategy, Business Model, Value Chain and Stakeholder Engagement (continued)
Interests and views of stakeholders (continued)
Stakeholders
Type of stakeholder
engagement / Engagement
Channels
Purpose Outcome
Government and
Regulators
1. Meetings
2. Public consultations
3. SupportCY network
4. Feedback letter
1. Ensure compliance with regulatory frameworks, such as
the CSRD, EU Taxonomy, and other financial and
environmental regulations
2. Support national and EU-level climate, economic, and
sustainability goals
3. Embedding C&E risks in Governance, Business Model
and Strategy, Risk Management and Disclosures
1. Aligning business model and strategy
2. Value creation and risk mitigation from
compliance
3. Updating ESG Working Plan to address
regulator’s feedback
Business Partners
1. Contact via telephone, email
2. Personal meetings
3. Vendor assessments
4. SupportCY network
1. Foster collaboration to promote responsible supply chain
practices and shared ESG objectives
2. Ensure mutual alignment on sustainability goals and
ethical business conduct
3. Strengthen partnerships to drive innovation and shared
growth
1. Streamlined supplier expectations
2. Vendor improvement plans
3. Informed selection of vendor
Business
Community
1.
SupportCY
n
etwork
2. Telephone
3. Email
4. Personal meetings
5. Media campaigns
6. Focus groups and surveys
1. Promote sustainable and ethical business practices
within the broader business ecosystem.
2. Foster innovation and entrepreneurship in collaboration
with peers and institutions.
1. Product/service improvements
2. Improvements in the distribution
channels
Peers/Competitors
1. Personal meetings
2. Association of Cyprus Banks
1.
Share best practices and collaborate on common
challenges, such as ESG data transparency and climate
resilience
2. Improve industry-wide sustainability performance and
standards
3. Foster healthy competition to drive innovation and
accountability within the banking sector
1. Common ESG Due Diligence solution
across Cyprus Banking industry
Nature
1. Updates and developments
obtained BES process on
C&E risks
1. Inform the Business Strategy and Risk assessment
1.
Updates and
d
evelopments from BES
are incorporated in the Group’s
Financial Plan and Materiality
Assessment on C&E risks
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
102
ESRS 2 General Disclosures (continued)
3. Strategy, Business Model, Value Chain and Stakeholder Engagement (continued)
Interests and views of stakeholders (continued)
Key Stakeholders
How A
dministrative, management and supervisory bodies
are informed about sustainability impacts
Board
1.
Refer to
2.
Governance
under ESRS 2
General Disclosures
in
page 83.
Employees
1. Through the Complaints Resolution Process. Refer to page 176.
2. Through Whistleblowing system. Refer to page 217.
For more details on the employee engagement refer to ESRS S1in
page 174.
Investors and Shareholders
1.
Through the monthly Market Update & Share Trading Activity
report of IR&ESG to EXCO and Board.
Customers
1.
Through the Complaints Management process. Refer to
p
age
193.
2. Through Customer survey submitted to EXCO and BDC.
Civil Society and Non-governmental
organizations (NGOs)
1.
Through the
Complaints Management
process. Refer to
p
age
193. For positive impacts through the six-monthly Corporate
Social Responsibility Update Report to EXCO.
Government and Regulators
1.
Regulatory Steering Group (RSG
3
) update on bi
-
weekly basis
.
2. Updates on major correspondence to Board Chairman and CEO
on bi-weekly basis.
3. Regulatory engagement update to Board through RC on a
quarterly basis.
Business Partners
1.
Through the
Complaints Management
process. Refer to
p
age
193.
Business Community
1.
Through the Complaints Management process. Refer to
p
age
193.
Peers/Competitors
1.
The Group
CEO
is the chairman of the Association of Cyprus
Banks informing EXCO and Board accordingly on any significant
matters.
Nature
1.
Preliminary impacts assessment report from BES is presented
to SC, EXCO on a quarterly basis and annually to the Board
through NCGC and RC.
Topical details on the interest and views of stakeholders are described in the following sections.
SBM
2
Topical ESRS
ESRS
Page
S1
Own workforce
171
S4
Consumers and end
-
users
190
3
A forum of Senior Executives of the Group chaired by the Group CEO which was established to ensure proper procedures are
in place for managing regulatory risk and to oversee Groups regulatory obligations.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
103
ESRS 2 General Disclosures (continued)
4. Impacts, Risks and Opportunities
Identification and assessment of material impacts, risks and opportunities
BOCH employs a Double Materiality Assessment (DMA) to determine the basis of the disclosures included in the
Group’s Sustainability Statement. The Group, through the DMA process, is identifying and assessing the material
impacts, risks and opportunities (IROs) which are considered significant in achieving its long-term objectives and
strategic plans. The scope of this assessment extends beyond the operational activities of BOCH, covering its
entire value chain, from upstream to downstream, as well as any external parties affected by the Group’s
operations. The DMA was carried out in three distinct phases: value chain analysis, IRO identification, assessment
and mapping, and stakeholder validation.
1. Value chain analysis
As part of the value chain analysis, the Group has identified the related activities, business relationships and
geographies that are considered more relevant to the identification and assessment of IROs. The assessment
incorporated information from all the business segments of the Group (i.e. Corporate, SME, Retail, International
Corporate, Restructuring & Recoveries, Wealth Management, REMU, Treasury, Insurance and Payments services).
In terms of geographical scope, the Group’s activities are mainly concentrated in Cyprus; therefore, the
assessment has been focused on activities in Cyprus. The Group have not identified any material IROs from the
Group’s overseas activities, namely Greece, Romania and Russia, given the size of these operations which are in
a run-down mode and relate to legacy operations of the Group. The assessment considered the value chain of
BOCH vendors through impacts identified and assessed at the loan portfolio, given the close alignment of sector
exposures. Risks and opportunities associated with BOCH vendors were identified and assessed accordingly based
on the approach described in the 4. Financial Materiality section below. Following detailed analysis of the
underlying portfolio and consideration of the nature of these investments, the Group made the judgement that
Impacts associated with direct or indirect exposures to mutual funds do not give rise to material IROs given the
fact that the exposures to mutual funds include numerous underlying assets of small individual size within several
jurisdictions and are associated with various industries. This results in multiple impacts fragmented across several
sectors, jurisdictions and asset types which are not considered material.
2. IRO identification, assessment and mapping
The IROs identified and assessed through the DMA, embed considerations resulting from a range of Group’s
products and services, as well as from its operations. The scope of the assessment also considered the internal
mechanisms of the Group, including legal reviews, anti-corruption compliance systems, occupational health and
safety inspections, as well as shareholder filings. The dependencies between the Group’s impacts with risks and
opportunities were taken into account throughout the identification and assessment process of IROs, especially
when assessing loan and investment portfolios. The most significant impacts of the Group are indirect impacts
arising by financing industries that are impacting people and the environment. When assessing risks and
opportunities the dependencies of our customers’ impacts were assessed, through the transmission channels.
The Group ensured that the identified and assessed IROs are clearly distinguished and pragmatically mapped to
the relevant ESRS Topics/Sub-topics/Sub-sub-topics before proceeding to the validation phase. For additional
details on the process used to identify, assess, prioritise and monitor impacts, risks and opportunities refer to
section 3. Impact Materiality and 4. Financial Materiality below.
3. Impact materiality
In order to assess the Group’s Impact Materiality, internal stakeholders from various departments were requested
to identify actual and potential operational impacts, including both positive and negative effects mapped to the
impact areas and topics outlined in the UNEP FI Impact Radar. With regards to the impacts arising from loan and
owned investment portfolios, the Group identified the actual and potential positive and negative impacts using
UNEP FI PRB Impact Analysis (Institutional Banking, Consumer Banking and Investment Portfolio Impact Analysis
Tools). The identified impacts were incorporated into an e-survey, requesting from the Group’s Management and
Senior Management to prioritise and score them based on scale and scope (+ irremediability for the negative
Impacts) (+ likelihood for the potential Impacts). Group’s Management and Senior Management was informed
during prioritization sessions that in the case of a potential negative human rights impact, the severity of the
impact takes precedence over its likelihood. The results from the stakeholder prioritisation exercise were
aggregated leading to a score between 1-5 for actual and potential, positive and negative impacts for each UNEP
FI Impact Radar topic. Refer to the table below for the scoring approach:
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
104
ESRS 2 General Disclosures (continued)
4. Impacts, Risks and Opportunities (continued)
Identification and assessment of material impacts, risks and opportunities (continued)
3. Impact materiality (continued)
Grading scales
1
2
3
4
5
Scale
Minimal
Low
Medium
High
Absolute
Scope
Limited
Concentrated
Medium
Widespread
National
-
wide
Irremediability
Relatively
easy to
remedy
short-term
Remediable with
effort (time and
cost to society)
Difficult to
remedy or
mid-term
Very difficult to
remedy or
long-term
Non-
remediable or
irreversible
Likelihood Unlikely Possible Likely Very Likely
Almost
guaranteed
The UNEP FI ESRS AR 16 Topics Mapping tool was utilized to associate the identified impacts and their scores
to the relevant ESRS sub-sub-topics. For those ESRS topics, sub-topics and sub-sub-topics not addressed by the
UNEP FI - ESRS AR 16 Topics Mapping tool, an independent impact identification and assessment exercise was
conducted by the Group. This process led to the identification of specific impacts from Group’s operations and
loan and investment portfolios, at the sub-sub-topic level of ESRS 1 AR 16, including the scores derived from the
e-survey, the impacted time horizons, and their association with relevant value chain activities.
The results of the Impact materiality assessment were aggregated at ESRS topic level, using the maximum score
assigned at each sub-sub-topic level, to identify the material topics to be discussed and reported in the
Sustainability Statement of the Group. The impact materiality threshold set is greater or equal to 3.9, which
corresponds to the average score of each aggregated score at ESRS topic level. The Group performed
corroborative procedures to support the impact materiality threshold set. Specifically, the Group utilised the
average scoring approach rather that the maximum approach to aggregate the scores at ESRS topic level, using
again the average score as threshold, leading to the same material topics with the threshold set. In addition, the
Group considered the outcome of a range of sensitivities to support threshold set.
4. Financial Materiality
To assess Financial materiality, BOCH utilized its existing risk assessment processes and frameworks. The Group
continuously monitors external developments, issues and events affecting its business model, integrating ESG
considerations into these existing steering and risk management processes at different maturity levels. The
Financial Materiality assessment involved the evaluation of the Group's business profile and the composition of
its loan portfolio, further examining associated risk drivers, including credit risk, liquidity risk, market risk,
operational risk, strategic risk, reputational risk and legal risk.
The Group has leveraged internal risk exercises, such as the Risk Identification Materiality Assessment (RIMA)
and the Key Risk Matrix (KRM), which are designed to identify relevant financial and non-financial risks. RIMA
has been used for the identification and assessment of the C&E risks related to the ESRS topics, as it combines
qualitative and quantitative approaches, using both the Group’s specific internal data and external sources to
assess exposures related to C&E risks. KRM was the source of data regarding Social and Governance risks
identification, which follows a similar assessment methodology as RIMA. Any additional risks, associated with
ESRS sub-sub-topics identified were assessed independently by the Group.
Financial opportunities have been identified using BOCH’s Financial Plan which highlights the strategic orientation
of the Group, and is complemented by forecasts and industry research, as well as the BES process on C&E risks
which informs the Group’s risk and strategic profile. Financial opportunities were individually assessed taking into
account qualitative and quantitative aspects of their Magnitude and Likelihood.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
105
ESRS 2 General Disclosures (continued)
4. Impacts, Risks and Opportunities (continued)
Identification and assessment of material impacts, risks and opportunities (continued)
4. Financial Materiality (continued)
The financial risks and opportunities were assessed for likelihood and magnitude based on the approach already
applied under existing KRM and RIMA processes:
Impact
(1-5)
Critical (5) H H H C C
High (4) M M H H C
Moderate
(3)
L M M H H
Low (2) L L M M M
Minimal (1) L L L L L
Remote (1) Unlikely (2) Likely (3)
Highly likely
(4)
Expected (5)
Likelihood (1
5)
The threshold applied to identify material financial risks and opportunities as per scoring approach mentioned
above, is greater or equal to 4 which correlates with the abovementioned risk management processes. Risk
assessment tools are regularly enhanced to capture aspects of risks, including the latest CSRD requirements.
5. Stakeholder validation
The final DMA phase involves the validation of the results by internal stakeholders through workshops, round
tables and interviews with the outcome of these validations being considered as part of the final DMA decisions.
Engaging with key stakeholders who have expertise in their relevant topic is essential for achieving the
appropriate prioritization of IROs. Stakeholder engagement was conducted in several stages of the assessment
to ensure appropriate identification and validation of sustainability matters. While no direct consultations with
external stakeholders were conducted, the Group leveraged the expertise of its internal management members
who are in frequent communication with the external stakeholder groups and have a deep understanding of their
expectations. By utilizing these internal proxies, the Group has ensured that the insights, perspectives and
expectations of external stakeholders are incorporated in the DMA results and reflected in the Group’s
Sustainability Statement.
6. DMA Governance
The IR&ESG Department of the Group documented the DMA outcome and a summary of the process performed
was submitted to the SC, EXCO, NCGC, AC and ultimately the Board, for consideration and approval. The paper
included the following to provide adequate detail to the Management and Board Committees to review, challenge
and approve the DMA:
1. Approach followed to identify and assess IROs under DMA.
2. External and internal tools utilised on the identification and assessment process.
3. The approach and rational behind setting materiality thresholds to determine which IROs are material.
4. The corroborative assessments performed to support the Impact materiality threshold set.
5. Detailed DMA results embedding scores of positive and negative impacts as well as risks and opportunities,
at a sub-sub-topic level.
6. Peer benchmarking on material topics identified.
7. Detailed explanation on how affected stakeholders were engaged in the process.
8. Mapping exercise between the material topics identified in previous Sustainability Statement (GRI) compared
to material topics identified under the DMA.
9. Key assumptions and judgments along with relevant procedures performed to corroborate those assumptions
and judgments.
10. Detailed definitions of sustainability topics under ESRS.
11. Detailed substantiations of positive and negative impacts as well risks and opportunities
12. Detailed Impact scores as derived from Management and Senior Management e-survey
13. Subsidiary scoping exercise
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
106
ESRS 2 General Disclosures (continued)
4. Impacts, Risks and Opportunities (continued)
Identification and assessment of material impacts, risks and opportunities (continued)
6. DMA Governance
14. Detailed mapping between UNEP-FI and ESRS Topics
15. DMA Handbook which provides a detailed guidance on how the DMA was conducted.
This paper was discussed, challenged and reviewed by the Board through the SC, EXCO, AC and NCGC, reaching
an approval on the DMA and the material IROs disclosed in the Sustainability Statement and highlight the Group’s
strategic priorities.
7. Conclusion
To achieve its ambitions, the Group established, an ESG working plan, in 2021 which was further enhanced in
2024. This plan is designed to articulate the delivery of the Group’s ESG strategic objectives and considered ECB
expectations, and other regulatory disclosure requirements.
The working plan will be further enhanced to reinforce the Group's commitment to comprehensive and dynamic
ESG practices based on DMA results. The Group understands that the incorporation of material IROs in the overall
risk profile and risk management processes is an evolving process. Certain impacts and risks are reflected in the
Risk Appetite Statement (RAF) through key risk indicators, and various risk policies. Opportunities identified
across the Group’s various business segments are assessed and embedded into the Group’s Financial Plan
following consultation, validation and authorisation from relevant Management and Board Committees, as
required by the Group’s Governance arrangements.
Topical details on the identification and assessment of material IROs are described in the following sections.
IRO
1
Topical ESRS
ESRS
Page
E1
Climate Change
122
E2
Pollution
156
E3
-
Water and marine resources
162
E5
-
Resource use and circular economy
166
G1
-
Business conduct
215
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
107
ESRS 2 General Disclosures (continued)
4. Impacts, Risks and Opportunities (continued)
Identification and assessment of material impacts, risks and opportunities (continued)
8. DMA results – ESRS Sub-Topic
The table shall be read in conjunction with the detailed IROs in the topical sections.
ESRS Material Topic Material Sub-topics I R O
Non
-
Material
E
E1 Climate change
Climate change
adaptation
n/a
Climate change mitigation
Energy
E2 Pollution
Pollution of air
Pollution of
water,
Substances of
concern,
Substance of
very high
concern,
Microplastics
Pollution of soil
Pollution of living organisms and
food resources
E3
Water and marine
resources
Water
Marine
resources
E5 Circular economy
Resources inflows, including
resource use
Waste
Resource outflows related to
products and services
S
S1 Own workforce
Working conditions
Equal
treatment and
opportunities
for all
Other work-related rights
S4
Consumers and
end-users
Information
-
related impacts for
consumers and/or end users
n/a
Personal safety of consumers
and/or end-users
Social inclusion of consumers
and/or end-users
G G1 Business conduct
Corporate culture
Protection of
whistle-
blowers
Animal
welfare³
Political
engagement
Corruption
and bribery
Management of relationships with
suppliers including payment
practices
Entity specific
Information
Security
n/a - Entity specific
Financial Crime
and Fraud
Conflict of Interest
Compliance with
laws are
Regulations
Reputational risk
Digitalisation
BOC Oncology
Centre
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
108
ESRS 2 General Disclosures (continued)
4. Impacts, Risks and Opportunities (continued)
Identification and assessment of material impacts, risks and opportunities (continued)
9. Time Horizons
The time horizons used by the Group on the identification and management of sustainability IROs deviate from
those prescribed by ESRS, except for short-term time horizon, in order to be aligned with the time-horizons
applied by the Group when developing and formulating the strategy and risk management processes.
Time
horizon
label
Start
Year
End
Year
Rationalisation
Short-
term (1
years)
2024 2025
The Group is committed to become carbon neutral
in own operations
by 20
5
0
with interim target to reduce Scope 1 and Scope 2 GHG emissions from own
operations by 42% by 2030 compared to 2021 baseline. The Group has focused
its main decarbonisation actions in the short-term up to 2026 in order to lead
the decarbonisation efforts, lead by example and also to benefit from any
government subsidies that will be announced as part of the Recovery and
Resilience Facility (RRF) of the EU. Taking also into account the CSRD which is
a milestone for sustainability activation effective for FY2024 for EU listed
companies, and every year thereafter up until 2028 to include certain SMEs and
large companies, the Group decided to set short-term time horizon at 1 year as
of the end of the reporting date.
Medium
-term
(2-6
years)
2026 2030
The Group is committed to become carbon neutral
in own operations
by 20
5
0
with interim target to reduce Scope 1 and Scope 2 GHG emissions from own
operations by 42% by 2030 compared to 2021 baseline, therefore sustainability
IROs should be identified and managed in a horizon of 2-6 years. As 2030 is
the year set by the EU for the goal of “Fit for 55” (i.e., a 55% reduction of GHG
emissions below 1990 levels), the Group has also set 2030 as the medium-term
risk horizon for the identification and management of sustainability IROs.
Therefore, the time horizon for medium term is between 2-6 years.
Long-
term
(>6
years)
2031 n/a
The Group considers a time horizon of
more than
6 years
. T
he Group has set
its ambition to become net zero by 2050, which indicates that Scope 1, Scope
2 and Scope 3 GHG emissions should be reduced by 2050 to net zero. The
climate related risks associated with Financed Scope 3 GHG emissions depend
also on the useful life of the assets, which for the majority of the current loan
portfolio of the Group this translates to a maturity beyond 7 years. As such a
long-term time horizon has been set of over > 6 years to cover both the risks
as well as the strategic aspects of climate-related risks within the organisation.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
109
ESRS 2 General Disclosures (continued)
4. Impacts, Risks and Opportunities (continued)
Identification and assessment of material impacts, risks and opportunities (continued)
10. Key assumptions in the DMA
DMA area Assumption/Judgement
Corroborative
procedures
UNEP FI PRB
tools
PRB’s impact analysis tools are input and output models
associating NACE codes (statistical classification of
economic activities) or products (i.e. Housing, credit cards
etc.) with actual and potential positive and negative
impacts on Impact radar’s topics (i.e. climate stability,
education, finance etc.). Positive and negative impacts
(loans and investment portfolios) are assumed based on
the association between NACE/Product codes and impacts.
UNEP-FI PRB tools are
used by more than 345
Financial Institutions
globally for the
identification of impacts
and is considered a best
practice approach.
Mapping between
UNEP-FI topics
and ESRS topics
In certain instances, the mapping of impact’s
substantiations, at the Impact radar’s topic level, was not
fully aligned with the ESRS topics/sub-topics/sub-sub-
topics. Therefore, during the scoring exercise we utilised
the most appropriate Impact radar topic to score the
relevant ESRS sub-sub topic substantiation.
Mapping is aligned with
UNEP-FI guidance.
Impact materiality
threshold
Impact materiality threshold was set as the average of
scores associated with each Topical ESRS. The aggregated
scoring at Topical ESRS level was based on the maximum
impact score of the underlying sub-sub-topic.
Corroborative procedures
(Sensitivity, average
scoring approach) were
performed to ensure the
threshold selected was
appropriate.
Financial
materiality
threshold
Financial materiality threshold was set at level
to be
aligned with existing Group’s risk processes like Key Risk
Matrix and RIMA at >=4.
The approach is consistent
with current Group’s
processes.
Mapping of RIMA
and KRM to ESRS
sub-sub topics
Risks identified through the RIMA and KRM process were
mapped with ESRS sub-sub topic level and used the
existing score based on existing methodology.
The mappings were
confirmed with the
relevant internal risk
owners.
Mapping of
Financial Plan and
BES to ESRS sub-
sub topics
Opportunities identified through Financial Plan and BES
process were mapped with ESRS sub-sub-topic level and
scored based on impact and likelihood using judgment.
The mappings and scoring
was reviewed and agreed
by external sustainability
experts.
Use on internal
proxies on
consultation &
validation
The Group performed consultation and validation
procedures on DMA using internal proxy stakeholders
BOCH considered that
given the maturity in the
market, limited value
would have been added to
the DMA if external
stakeholders were
engaged.
11. Non-Material topics
The environmental topics ESRS E4 (Biodiversity and Ecosystems), ESRS S2 (Workers in the value chain) and
ESRS S3 (Affected communities) were assessed as 'Non-Material', through both the financial and impact
materiality lens. This is closely aligned with the Group's internal expectations, strategic objectives, industry trends
and in particular, with the specifics of the Group's portfolio. However, the Group acknowledges that the integration
of these considerations into business practices is evolving and the Group plans to revisit these topics as well as
the associated IROs, as part of the annual DMA refresh. For more details on the Biodiversity IROs refer to ESRS
E1 – Climate Change in page 118.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
110
ESRS E1 - Climate Change
This section outlines the Group’s policies, actions, metrics and targets in addressing material climate change
negative impacts and risks as well as policies, actions, metrics and targets designed to further enhance material
positive impacts and exploring material opportunities.
1. Integration of Sustainability-Related Performance in Incentive Schemes
In terms of climate-related considerations, the Group integrates sustainability factors into its remuneration
process. Senior Management (EXCO and Extended EXCO) KPIs are linked to actions for the reduction of GHG
emissions from own operations and the green lending associated with the decarbonisation of the mortgage
portfolio. Specifically, the Director of Operations & Chief Cost Officer includes actions to reduce Scope 1 and
Scope 2 emissions, while the Deputy CEO and Director of Consumer Banking have KPIs tied to Green Housing
metrics aligned with the mortgage decarbonisation strategy.
For Senior Management, C&E KPIs, aligned with the Group’s ESG strategy, are factored into Directors’ variable
remuneration as part of the performance appraisal cycle. These climate KPIs account for less than 15% of total
Director KPIs and percentage weight vary for each Director. Specific details on Directors’ C&E KPIs have not yet
been disclosed.
The Group’s Long-Term Incentive Plan (LTIP 2022), approved by shareholders, incorporates ESG objectives within
its evaluation scorecard, which measures performance against the Group’s Medium-Term Strategic Targets. The
scorecard includes KPIs on external ESG ratings, based on independent external assessments of the Group’s ESG
performance. For more details on the integration of sustainability-related performance in incentive schemes refer
to ESRS 2 - General Disclosures in page 92.
2. Transition plan for climate change mitigation
2.1 Introduction
As a signatory to the UN PRB, the Group aims to align its own operations, supply chain and portfolios with the
transition to a sustainable economy. This commitment was enforced through the Group’s ESG primary ambitions,
as determined in the ESG strategy, which was formulated in 2021. The Group’s primary ESG ambitions are:
Group’s ESG Primary
ambitions
Ambition
Description
Own operations
42% GHG
emission
reduction by
2030
The Group aims to become carbon-neutral in own operations by 2050, by gradually
eliminating its scope 1 and 2 GHG emissions. The Group has set an interim target in line
with carbon-neutrality ambition in own operations to reduce Scope 1 and Scope 2 GHG
emissions by 42% (absolute target) by 2030 compared to the baseline of 2021.
Become Net
Zero by 2050
The Group
’s ambition
to become Net Zero, by reducing its Scope 3 emissions through its
supply chain (i.e. third party providers) and its financing activities, which also entails the
alignment and commitment of its clients towards this goal.
Steadily
increase GAR
The GAR indicates the
degree of alignment with the EU Taxonomy, such as showing the
proportion of the share of credit institution’s assets financing and invested in EU
Taxonomy-aligned economic activities as a share of total covered assets, such as those
consistent with the European Green Deal and the Paris agreement goals.
Steadily
increase Green
Mortgage Ratio
In
line
with the Green Asset Ratio, the numerator consists of mortgages used only for
sustainable activities related to the construction of new buildings and renovation of
buildings, while the denominator includes all mortgages.
While the Group has established GHG emissions reduction targets in certain emission categories and asset classes,
based on data and methodologies available (Refer to 7. Climate Change Metrics & Targets in page 139), and
implements climate change mitigation actions to be aligned with those targets (Refer to 6. Policies and Actions
related to Energy, Climate Change Mitigation and Adaptation in page 132), it has not yet established a
comprehensive transition plan for climate change mitigation. The establishment of GHG emission reduction
targets and climate change mitigation actions to meet those targets were reviewed, discussed and approved by
the Board through the SC, EXCO and NCGC. The Group will perform reasonable efforts to establish a
comprehensive climate change mitigation transition plan in order to be aligned with limiting the global warming
to 1.5 °C by 31 December 2026. The Group’s climate change mitigation transition plan will be reviewed and
approved by the SC, EXCO and the Board through the NCGC.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
111
ESRS E1 - Climate Change (continued)
2. Transition plan for climate change mitigation (continued)
2.2 Strategy integration of climate transition plan
The Group updated its Group Financial and Business Plan manual to incorporate considerations on C&E risks in
the Business Strategy. Specifically, during the planning phase for new lending the RMD and IR&ESG provide the
sectors associated with C&E risks, the preliminary impact assessment derived from the BES, the science-based
targets set (GHG emission reduction targets aligned with a climate scenario) and the direction of Green/Transition
new lending based on BES. In addition, each Division, considers the preliminary impact assessment (performed
by RMD, IR & ESG and Strategy) on the risk profile and strategy arising from the BES and the RIMA on C&E risks.
Based on this, the Division identifies which are the material C&E risks over the Financial plan period and defines
the actions, strategies and products to mitigate them. The IR&ESG reviews the adequacy, relevance and
reasonableness of the business lines strategies to manage material C&E risks in key portfolios.
The Group’s approach to climate action is evolving over time and has progressively been embedded into the
Group’s activities, actions and strategies. Consequently, the Group focuses on creating lifelong partnerships with
customers, as well as guiding and supporting them in a changing world by financing projects which bear a positive
climate impact. Underpinning the Group’s Climate Strategy (a pillar within its ESG strategy), there are three
strategic areas where, moving forward, the Group will focus its climate action:
i. Reinforcing the impact of climate financing;
ii. Building resilience to climate change; and
iii. Further integrating climate change considerations across all of Group’s standards, methods and
processes.
2.3 Emission reduction targets
The Group aims to work with its customers, colleagues and communities to support their transition to a resilient,
low carbon 1.5°C aligned economy by 2050, in line with Cyprus governments' ambitions and actions.
The Group, taking into account the maturity of the market in Cyprus regarding climate change, the available
methodologies for setting GHG emission reduction targets and the limited climate data, decided to set its GHG
emission reduction targets by applying the International Energy Agency’s Below 2 °C climate scenario (IEA B2DS),
aiming to limit global warming to 1.75 °C. However, as methodologies evolve and more reliable climate data
becomes available, the Group is committed to adjusting its targets to align with the 1.5°C goal. The Group utilized
the Science Based Targets Initiative (SBTi) tools to set the GHG emission targets however, these targets are not
externally validated by any global climate body. The Group has committed to reducing its scope 1, 2 and 3 GHG
emissions to meet its stated targets below:
1. 42% reduction in GHG emissions (Scope 1 and 2) by 2030 compared to a 2021 base year;
2. 43% reduction in residential mortgage portfolio GHG emissions per square metre by 2030 from a 2022
base year.
For more details on GHG emission reduction targets refer to 7. Climate Change Metrics & Targets in page 139.
2.4 Sustainable finance metrics
The Group is providing customers with sustainable products, such as green housing, green car, energy loans,
renewable energy financing and green lending for Corporate & SME under the Green lending policy, supported by
green bond issuance under the Sustainable Finance Framework, and is continuing to develop its suite of green
finance products offered to customers. The Group is taking these actions because it understands the significant
role it can play in facilitating the transition to a low-carbon economy. The Group as at 31 December 2024,
following the launch of Green housing product, reached 355mn gross environmentally friendly loans. For more
details on Sustainable finance metrics refer to 7. Climate Change Metrics & Targets in page 144.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
112
ESRS E1 - Climate Change (continued)
2. Transition plan for climate change mitigation (continued)
2.5 Locked-in GHG emissions
The Group under the current risk assessment framework, considers that changes in climate change mitigation
and adaptation policies and regulations could lead in asset stranding or assets becoming locked-in to GHG
emissions especially for organisations that operate in carbon intensive industries (i.e. oil and gas industry). The
Group currently assesses the risk of stranded and locked-in assets qualitatively, however it will perform a detailed
identification and quantification exercise during 2025 on stranded assets associated with the assets financed or
assigned as collaterals. The Group’s own assets are not considered to be locked-in to GHG emissions or stranded
by nature as the vast majority relates to office buildings and branches. The Group’s exposure to carbon intensive
sectors, which are considered high risk of stranding or locked-in, is immaterial. Therefore, the risk of stranding
and locked-in is low. Refer to the table below indicating Group’s gross loan and corporate bond exposures to
carbon intensive sectors as per ESRS E1-1 Paragraph 16(f).
Gross loans exposure to coal, oil and gas related economic activities
Gross Loans
(mn) - 2023
Gross Loans
(mn) – 2024
B.05 Mining of coal and lignite
- -
B.06 Extraction of crude petroleum and natural gas (limited to
crude petroleum)
- -
B.09.1 Support activities for petroleum and natural gas
extraction (limited to crude petroleum)
0.2 -
C.19 Manufacture of coke and refined petroleum products
2.0
1.4
D.35.1
-
Electric power generation, transmission and
distribution
40.1 52.9
D.35.3
-
Steam and air conditioning supply (limited to coal
-
fired and oil-fired power and/or heat generation)
0.4 0.4
G.46.71
-
Wholesale of solid, liquid and gaseous fuels and
related products (limited to solid and liquid fuels)
139.1 142.5
Total
181.8 197.2
% to total Non – Financial Corporation Gross Loans
3.7% 3.9%
Corporate Bonds exposure to coal, oil and gas related economic activities (
e
xcluding Green
Bonds)
Corporate Bonds
(mn) - 2023
Corporate Bonds
(mn) – 2024
B.05 Mining of coal and lignite
- -
B.06 Extraction of crude petroleum and natural gas
(limited to
crude petroleum)
- -
B.09.1 Support activities for petroleum and natural gas
extraction (limited to crude petroleum)
4.9 15.2
C.19 Manufacture of coke and refined petroleum products
-
-
D.35.1
-
Electric power generation,
transmission and
distribution
- -
D.35.3
-
Steam and air conditioning supply (limited to coal
-
fired and oil-fired power and/or heat generation)
- -
G.46.71
-
Wholesale of solid, liquid and gaseous fuels and
related products (limited to solid and liquid fuels)
- -
Total
4.9 15.2
% to total Non – Financial Corporation Corporate Bonds
4.5% 10.2%
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
113
ESRS E1 - Climate Change (continued)
2. Transition plan for climate change mitigation (continued)
2.5 Locked-in GHG emissions (continued)
The Group is not excluded from the EU Paris-aligned Benchmarks but maintains exposures to certain sectors
within its portfolio that are classified as excluded under the EU Paris-aligned Benchmarks framework (Articles
12.1(d) and (g) and 12.2 of (EU) 2020/1818).
These exposures relate to economic activities that currently do not meet Paris-aligned benchmarks but are
important to the market and transition efforts. Refer to the table below for details on financing exposure to
excluded sectors:
Financing exposure to sectors excluded from EU Paris
-
aligned Benchmarks (Articles 12.1 (d) and
(g) and 12.2 of (EU) 2020/1818
2023 2024
Gross carrying
amount (mn)
Of which exposures
towards companies
excluded from EU
Paris aligned
Benchmarks
Gross
carrying
amount
(mn)
Of which exposures
towards companies
excluded from EU
Paris aligned
Benchmarks
D - Electricity, gas,
steam and air
conditioning supply
57 27 121 46
G - Wholesale and
retail trade; repair
of motor vehicles
and motorcycles
881 54 908 67
H.52 -
Warehousing and
support activities
for transportation
47 19 162 49
Total
985 100 1,191 162
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
114
ESRS E1 - Climate Change (continued)
3. Material impacts, risks and opportunities and their interaction with strategy and business model
Material IROs
-
Climate Change (E1)
ESRS Topic/Sub-Topic IRO Type Description
Climate Change - Climate
Adaptation, Climate
Mitigation and Energy
Impact
Actual and potential
positive
The Group's decarbonisation plan on own operations to reduce Scope 1 and Scope 2 GHG emissions
create actual positive impact to climate change adaptation, through increase in renewable energy
utilisation, climate change mitigation, through reduction of GHG emissions, and energy consumption,
through energy efficiency measures implemented
Time Horizons Value Chain
Originate or connected to
strategy
Business
relationship
Short-Term
Medium
-
Term
Long-Term Own Operations Upstream Downstream
Originate from strategy
Own Operations
ESRS Topic/Sub-Topic IRO Type Description
Climate Change - Climate
Adaptation, Climate
Mitigation and Energy
Impact
Actual and potential
positive
Financing activities to certain NACE sectors (i.e. Electric power generation, transmission and
distribution) with total portfolio exposure of 1.44% out of 5bn exposures assessed under PRB
institutional banking impact analysis of 2024, create key/direct actual positive impacts to climate
stability. In addition, the Group implemented various actions in the downstream value chain which
create positive impacts on climate change mitigation (sector limits, GHG emission reduction targets,
ESG Due Diligence, Green lending internal KPIs). The Group is in the process to design the strategy to
manage material physical risks through adaptation measures in the underwriting process associated
with loan exposures, REMU portfolio and insurance contracts. Currently, the Group has positive impact
to climate change adaptation through insurance contracts covering weather perils.
Time Horizons Value Chain
Originate or connected to
strategy
Business
relationship
Short-Term
Medium
-
Term
Long-Term Own Operations Upstream Downstream
Connected to strategy through
provision of finance
Customers
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
115
ESRS E1 - Climate Change (continued)
3. Material impacts, risks and opportunities and their interaction with strategy and business model (continued)
Material IROs - Climate Change (E1) (continued)
ESRS Topic/Sub-Topic IRO Type Description
Climate Change
-
Climate
Mitigation and Energy
Impact
Actual and potential
negative
The Group produce Scope 1, 2 and 3 GHG emissions through operations and across the value chain.
Time Horizons Value Chain
Originate or connected to
strategy
Business
relationship
Short-Term
Medium
-
Term
Long-Term Own Operations Upstream Downstream
Connected to strategy
Own operations,
vendors and
customers
ESRS Topic/Sub-Topic IRO Type Description
Climate Change - Climate
Adaptation, Climate
Mitigation and Energy
Impact
Actual and potential
negative
Financing activities to certain NACE sectors (i.e. Rental and operating of own or leased real estate,
development of building projects, buying and selling of own real estate) with total portfolio exposure
of 36.55% out of 5bn exposures assessed under PRB institutional banking impact analysis of 2024,
create key/direct actual negative impacts to climate stability. The fact that the Group has not yet
implemented sufficient risk management practises on climate change adaptation indicates that the
Group negatively impacts climate change adaptation. The Group has not yet launched innovative
solutions on climate change adaptation leading to a negative impact on climate change adaptation.
Time Horizons Value Chain
Originate or connected to
strategy
Business
relationship
Short-Term
Medium
-
Term
Long-Term Own Operations Upstream Downstream
Connected to strategy through
provision of finance
Customers
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
116
ESRS E1 - Climate Change (continued)
3. Material impacts, risks and opportunities and their interaction with strategy and business model (continued)
Material IROs - Climate Change (E1) (continued)
ESRS Topic/Sub-Topic IRO Type Description
Climate Change - Climate
Adaptation
Risk
Climate -
Physical - Acute
Wildfire risk as a driver of credit risk, liquidity risk, market risk, operating risk and strategic risk has been
identified as material. All acute hazards combined have been assessed as material as drivers to strategic
risk (Extreme heat, Drought, High intensity / duration precipitation events, Landslide, River flood, Storms)
Time Horizons Value Chain
Financial Effects
Short-Term
Medium
-
Term
Long-Term Own Operations Upstream Downstream
No
material
current financial effects. Anticipated
financial effects include the increase in probability of
default (PD) and loss-given-default (LGD) of clients
and counterparties, depositors might simultaneously
withdraw deposits to address increased operational
costs, devaluation of REMU portfolio, disruption and
increased cost on owned buildings and branches and
reduction in profitability for strategic sectors of the
Group.
ESRS Topic/Sub-Topic IRO Type Description
Climate Change - Climate
Adaptation
Risk
Environmental -
Physical - Acute
Earthquake risk as a driver of credit risk, liquidity risk, market risk and operating risk has been identified
as material
Time Horizons Value Chain
Financial Effects
Short-Term
Medium
-
Term
Long-Term Own Operations Upstream Downstream
No
material
current financial effects. Anticipated
financial effects include the increase in PD and LGD
of clients and counterparties, depositors might
simultaneously withdraw deposits to address
increased operational costs, devaluation of REMU
portfolio, disruption and increased cost for owned
buildings and branches.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
117
ESRS E1 - Climate Change (continued)
3. Material impacts, risks and opportunities and their interaction with strategy and business model (continued)
Material IROs - Climate Change (E1) (continued)
ESRS Topic/Sub-Topic IRO Type Description
Climate Change - Climate
mitigation and energy
Risk Climate - Transition
Transition risk as a driver of credit and liquidity risks arising from low emission alternative products
and business models as well as increased costs of energy and raw materials.
Time Horizons Value Chain
Financial Effects
Short-Term
Medium
-
Term
Long-Term Own Operations Upstream Downstream
No
material
current financial effects. Anticipated
financial effects include lagging behind competitors
in terms of required technological change (shifts to
low-carbon technologies) may affect clients and
counterparties, retail customers might be vulnerable
to increasing energy costs / dependence on single
energy provider. Corporate clients might be affected
by increasing energy costs as well as by carbon
pricing on carbon intensive materials, which may
result in increased cost of raw components such as
steel, concrete, plastic, agricultural products, fuels
etc., leading to increased PD and LDG.
ESRS Topic/Sub-Topic IRO Type Description
Climate
Change
-
Climate
mitigation and energy
Opportunities Green finance
Opportunity to provide Green lending so to finance the transition to low carbon economy and manage
climate risks.
Time Horizons Value Chain
Financial Effects
Short-Term
Medium
-
Term
Long-Term Own Operations Upstream Downstream
Increase profitability and mitigate the possibility of
increased credit risk.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
118
ESRS E1 - Climate Change (continued)
4. Resilience to Climate Change
The concept of climate resilience requires that organisations develop the adaptive capacity to respond to climate
change, leveraging opportunities and managing the associated transition and physical risks. The Group
established and evolves climate risk stress testing and sensitivity practices to ensure climate resilience.
a. Climate Risk Sensitivity and Stress Testing
BOC PLC has a risk-based approach for the management of climate-related transition and physical risks in
lending.
i. Stress Testing for ICAAP Quantification
Transition Risk Quantification
BOC PCL developed a Framework to quantify transition risk for the purposes of stress-testing within the context
of ICAAP, under the normative perspective. The framework addresses all sectors of the BOC PCL’s portfolio, but
dedicated models were created for those sectors that are more susceptible to transition risks, based on their
inherent activities and their exposures. Such sectors include Construction, Hotels, Real Estate and Mortgages
whilst the remainder of BOC PCL’s portfolio is catered through a generic model.
The approach builds on the risk quantification methodology that BOC PCL has put in place. The main elements of
the approach are described below.
The overall approach regarding Climate Stress Testing (CST) design is structured into three layers:
i. Scenario Layer: This layer encompasses scenario variables, which are divided into macroeconomic
variables and climate risk parameters. It is essential that the macroeconomic variables remain
internally consistent with the climate risk parameters.
ii. Climate Risk Layer: The climate risk parameters are utilized to adjust the customer’s rating
components through transition risk models.
iii. Quantification Layer: The macroeconomic variables are used to estimate IFRS 9 PD and LGD based
on a forward-looking approach.
For the preliminary Stress Test run the following Network for Greening the Financial System (NGFS) scenarios
have been selected:
i. NDCs (Nationally Determined Contributions), which for the case of Cyprus, almost coincides with the
“Below 2°C” scenario given the EU Members’ aspiration for climate Policies. “Below C” scenario
gradually increases the stringency of climate policies, giving a 67% chance of limiting global warming to
below 2°C.
ii. Current Current Policies scenario assumes that only currently implemented policies are preserved,
leading to high physical risks.
iii. Delayed Transition Delayed Transition scenario is under the Disorderly scenario category. It assumes
annual emissions do not decrease until 2030. In addition, it requires strong policies to limit warming to
below 2°C and negative emissions are limited.
The results of the above-mentioned approach are expected to be disclosed in the 2025 Sustainability Statement.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
119
ESRS E1 - Climate Change (continued)
4. Strategy resilience to Climate Change (continued)
a. Climate Risk Sensitivity and Stress Testing (continued)
i. Stress Testing for ICAAP Quantification (continued)
Physical Risks on Collateral Portfolio
In terms of physical risks, efforts were focussed on estimating the impact on property value from the potential
materialisation of climate-related physical risks. This is considered relevant to BOC PCL, given the concentration
to clients in activities relating to immovable properties such as Construction, Accommodation & Food Service,
Real Estate, Mortgages as well as the fact that a significant portion of BOC PCL’s collaterals are real estate assets.
To that end, granular data were obtained from an external vendor, providing granular, location level information.
Based on existing literature, only five physical hazards are considered as having impact on immovable properties
and these were analysed further. These include wildfire, landslide, wind gust, flood and sea level rise. For the
purposes of the analysis which was also used as part of its RIMA process, the NGFS scenarios were employed and
used as a reference. In particular, the following scenarios were used and projected up to 2050:
i. Orderly transition: assume that climate policies are introduced early and gradually become more stringent.
Physical and transition risks are relatively small.
ii. Disorderly transition: explore higher transition risk due to delayed or divergent policies across countries
and sectors.
iii. Hot House World: assume that some climate policies are being implemented in some jurisdictions, but
that global efforts are insufficient to halt significant global warming. These scenarios pose serious physical
risks.
The analysis of the data allowed BOC PCL to gain an understanding of the assets vulnerable to the various physical
risks, their level of riskiness as well as potential concentrations across the island. Furthermore, following the
identification of physical risks, the monetary impact (damage function) for each combination of property, hazard,
scenario, and year was estimated. This monetary impact considered not only the geo-localisation features, but
also the asset-specific characteristics, i.e., commercial, industrial, residential and other use.
Focusing on the most conservative climate scenario (Hot House World) the data indicated that only three physical
hazards, namely wildfire, landslide and flood could potentially impact collaterals’ market value. The impact of
these physical hazards on the collateral portfolio was quantified in the 2024 year-end ICAAP as well as in the
subsequent quarterly updates both from an economic and a normative perspective. The wildfire hazard was
chosen, as the analysis indicated that it can potentially affect the largest amount of collaterals.
For the purposes of the quantification and taking a worst-case scenario perspective, BOC PCL considered the
effectiveness of insurance contracts as mitigants of wildfire as well as the below factors:
i. Macro-economic conditions: Economic downturns could increase insurance lapses.
ii. Severe economic depression: This could challenge insurers' financial stability and ability to pay claims.
iii. Climate change: Increasingly severe wildfires may lead insurers to limit coverage.
iv. Limited coverage: Standard policies might not cover all wildfire damages.
Economic Perspective:
Conclusively, based on the revised reduced market value of collaterals, the economic capital requirement add-on
for the impact on Physical Risk for the four-year period of the financial plan (2025 2028) was calculated to c.
3mn. The presence of insurance contracts as mitigant was considered in the calculation.
Normative Perspective:
For the normative perspective, three different potential scenarios were considered for each of the ICAAP horizon
based on once-off event impact for wildfires in 2025, floods in 2026 and landslides in 2027.
Based on the revised reduced market value of the selected collaterals and the presence of insurance contracts as
mitigant for both wildfire and flood, the impact was calculated at c.0.4mn.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
120
ESRS E1 - Climate Change (continued)
4. Strategy resilience to Climate Change (continued)
a. Climate Risk Sensitivity and Stress Testing (continued)
i. Stress Testing for ICAAP Quantification (continued)
Physical Risks on Non-Financial Corporations (NFCs)
BOC PCL is in the process of estimating the impact of physical risks on Non-Financial Corporations (NFCs) credit
risk profiles. This project involves geolocating companies and their units to map and measure physical risks such
as floods, heatwaves, and other hazards. The mapping process assigns risk levels to different locations based on
the likelihood and severity of these hazards, and the potential financial impacts on companies are assessed by
focusing on key financial metrics like revenue and operating costs.
The final output of this process will show the potential financial losses for each company due to various hazards,
helping to understand the vulnerability of NFCs to these risks. This information will enable the Bank to adjust risk
drivers in the rating model and calculate climate-adjusted ratings under different climate scenarios and time
horizons.
ii. Sensitivity Analysis
Scenario analysis and climate risk stress testing are methods which assist in evaluating and managing the possible
effects of C&E risks, to the Group’s business strategy and financial planning decisions. By nature, this analysis is
of an informative nature and focuses on the planning horizon of the Group’s Financial plan. The sensitivity analysis
carried out on physical and transition risks are described below.
Transition risks
To assess the potential impact of transition risks on the Business Model, a sensitivity analysis was carried out on
portions of the corporate and mortgage portfolios that were identified as being exposed to transition risks. The
analysis related to the Financial Plan for the period between 2025 – 2028 and reflected the potential impact of a
short-term disorderly scenario according to which a set of climate related policies are implemented at the
beginning of 2024.
Estimation of impact was done on a top-down basis considering the outcome of regulatory climate stress tests,
and specifically the outcome of the Bank of England Climate Biennial Exploratory Scenario. Considering the
specific composition of BOC PCL’s portfolio, such climate related policies would most likely affect customers in
the sectors identified as vulnerable to transition risks as well as customers with mortgage loans granted prior to
2009, implying thus a less-energy efficient property. These sectors account for c.49% of the BOC PCL’s total loan
portfolio as at September 2024. The outcome of the analysis thus provided a magnitude of losses BOC PCL might
face if both BOC PCL and its customers do not respond effectively to climate risks.
The analysis indicated that over the period of the next financial plan (2025 – 2028), an average decrease of the
Group’s profitability of 19mn per year was estimated, aggregated to 75mn for the period. This is an adverse
sensitivity scenario and given the energy strategy of Cyprus, this is not considered a likely outcome.
Physical risks
This sensitivity analysis is designed to evaluate the financial implications of climate-related physical risks on the
real estate assets held as collateral within the four-year timeframe of the Financial Plan. It focuses on three risks,
namely wildfire, landslide and flood. The analysis utilised the concept of damage functions. The analysis assumes
that climate-related risks will gradually materialize through market pricing mechanisms, even before physical
damage occurs. This assumption reflects growing market awareness of climate risks and their incorporation into
property valuations. The transmission channels through which these risks affect property values could include:
i. Insurance premium adjustments reflecting increased risk exposure
ii. Market participants' risk perception and preference shifts
iii. Regulatory changes affecting building requirements and land use
iv. Adaptation costs necessary to protect properties
v. Changes in local economic conditions due to climate vulnerabilities
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
121
ESRS E1 - Climate Change (continued)
4. Strategy resilience to Climate Change (continued)
a. Climate Risk Sensitivity and Stress Testing (continued)
Physical risks (continued)
While actual climate impacts may materialize over longer timeframes, it is possible that market pricing
mechanisms will begin to incorporate these risks more rapidly as climate risk awareness increases.
Scenarios
The NGFS scenarios considered for this assessment were the Hot House World and the Orderly Transition. The
former scenario is more appropriate for wildfires and floods as it implies that physical risks increase the further
you move into the future. On the other hand, the Orderly Transition scenario is more appropriate for landslide as
the particular risk requires the additional element of heavy rain to act as a trigger. Heavy rain is not assumed in
the Hot House World scenario. The damage functions resulting from each scenario up to the year of 2034 were
thus compared. No significant differences were observed between the two scenarios given the rather short time
frame examined and therefore the Hot House World scenario was used to run the sensitivity analysis which aligns
with the scenario used for physical risks in the RIMA process.
Results
The sensitivity analysis results indicate a collective charge of 3.5mn and 6.8mn, assuming that prices are
reduced equally to the calculated damage functions for the years 2028 and 2034 respectively. Both charges are
not deemed material.
Employing the damage functions over a longer term would yield additional provisions as per the logic embedded
in the climate scenarios which provide for increasing impacts as you move further into the future. However, that
would ignore both the dynamic nature of the balance sheet and the mitigating actions that the BOC PCL can put
in place in the interim. Furthermore, the precise timing and magnitude of any climate impact on property prices
remain uncertain.
b. Resilience of Strategy and Business Model
BOCH has embedded climate resilience into its strategic planning. ESG is a core pillar of the Group’s long-term
strategy, with the ambition to achieve Net Zero by 2050. In line with this commitment, a decarbonisation target
has been established for the mortgage portfolio, aligned with the IEA’s B2DS. The lending strategy has been
adjusted to support this target, with integration into the Financial Plan for 2025-2028. Multiple scenario-based
sensitivity tests have been conducted to ensure alignment with climate targets and resilience under varying
transition risk scenarios.
The overall resilience of BOCH’s business model is reinforced by a relatively low exposure to carbon-intensive
sectors, such as coal, oil, and gas. Further mitigating measures include the introduction of new lending sector
limits to carbon-intensive industries. These restrictions do not apply to green or transition financing or to entities
operating in carbon-intensive sectors with an externally validated transition plan, thereby incentivising customers
to transition toward a low-carbon economy.
The current assessment indicates that BOCH’s business model remains resilient under a 2°C or lower climate
scenario, supported by a risk assessment framework, portfolio management, and the integration of climate risk
considerations into financial planning. Additional details on sectoral loan and investment exposures are provided
in 7. Climate Change Metrics & Targets in pages 149 and 151.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
122
ESRS E1 - Climate Change (continued)
5. Description of the processes to identify and assess material climate-related impacts, risks and
opportunities
C&E Risks Identification & Materiality Assessment (RIMA) process
The Group while conducting the DMA, utilised the results derived from the RIMA process in regards to C&E risks.
In 2023, BOCH has refined its MA of C&E risks as drivers of existing financial and non-financial risks, namely
Credit risk, Liquidity risk, Market risk, Operational risk, Strategic risk as well as Reputational and Legal risk, taking
into consideration its business profile and loan portfolio composition.
As part of the RIMA process, BOCH has enhanced the following steps to ensure a comprehensive and structured
MA process, having due consideration on the specificities of its business model, operating environment and risk
profile:
i. Identification and documentation of C&E risk drivers
ii. Definition of transmission channels for C&E risks
iii. Assessment of materiality of C&E risk drivers
Specifically, BOCH has conducted an assessment of the following C&E risks, as drivers of existing risks:
i. Climate-related physical risk drivers
ii. Climate-related transition risk drivers
iii. Environmental transition risk drivers (other than climate risks)
iv. Environmental physical risk drivers (other than climate risks)
The assessment has been conducted using both quantitative and qualitative methods. For data driven methods,
a combination of internally collected BOCH specific data and external data have been used.
In summary, as a first step, a more granular list of potential C&E risk drivers has been identified through the
enhancement of the inventory of C&E risks already developed by BOCH in the course of the previous C&E risk
assessment exercises. In particular, BOCH has proceeded with an additional classification and categorisation of
the C&E risks across four levels of granularity as per the following example:
i. Climate-related risk (Level-1)
ii. Physical risk (Level-2)
iii. Acute risk (Level-3)
iv. Wildfire (Level-4).
As a second step, the C&E risks have been mapped, by RMD, to the existing financial and non-financial risks
through respective transmission channels. For transmission channels refer to page 125.
As a third step, a combination of qualitative and quantitative methods has been utilised for the purpose of the
performance of the MA of C&E risks using various materiality parameters and thresholds, depending on the
method and data used for the assessment. In addition, the evolution of C&E risks has been considered over the
short, medium and long-term time horizons. For the time horizons considered refer to 9. Time Horizons in page
108.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
123
ESRS E1 - Climate Change (continued)
5. Description of the processes to identify and assess material climate-related impacts, risks and
opportunities (continued)
C&E Risks Identification & Materiality Assessment (RIMA) process (continued)
An overview of the steps followed for the performance of the MA is presented in the following figure:
Figure 1: Overview of BoC’s C&E MA 2023 stages
The following table (Table 2), provides an overview of BOCH’s C&E risks inventory, which includes all C&E risks
considered as part of the MA performed. A further break down of C&E risks has been considered accordingly by
defining thirty (30) underlying risk types.
ID C&E risk
C&E risk
sub-type
C&E risk
sub-type
C&E risk sub-type
[Level 1] [Level 2] [Level 3] [Level 4]
1
Climate-
related
Physical
Acute
(Extreme) Heat
2 Drought (increased frequency, intensity, duration)
3
High intensity / duration precipitation events (increase; causing
flooding)
4 Landslide
5 River flood
6 Storms (increased activity and/or intensity)
7 Wildfire
8
Chronic
Desertification
9
Ocean acidity
10 Precipitation (decreased average precipitation)
11
Sea level rise (increasing risk from coastal flood)
12 Temperature (increase of average temperature)
13
Transition
Policy and
Regulation
Failure to comply with climate (ESG) disclosures and GHG
reporting obligations
14 Risks from litigation
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
124
ESRS E1 - Climate Change (continued)
5. Description of the processes to identify and assess material climate-related impacts, risks and
opportunities (continued)
C&E Risks Identification & Materiality Assessment (RIMA) process (continued)
ID C&E risk
C&E risk
sub-type
C&E risk
sub-type
C&E risk sub-type
[Level 1] [Level 2] [Level 3] [Level 4]
15
Climate-
related
Transition
Technology
Transition to low-emission alternative products and
services/business models
16
Market
Increased energy costs and costs of raw materials
17
Increased stakeholder concern or negative stakeholder feedback
/ markets sentiment and preferences
18
Environmental
Physical
Acute
Earthquake
19
Tsunami
20
Chronic
Air pollution
21
Soil pollution
22 Water pollution
23 Biodiversity loss (incl. species extinction)
24 Deforestation (incl. habitat destruction) and land use change
25 Water scarcity
26 Pests (increased prevalence)
27
Transition
Policy and
Regulation
Circular economy & waste management
28
Environmental protection requirement
29 Technology Environmentally friendly technologies
30 Market Environmentally driven consumer behaviour
Each C&E risk has been individually assessed as a driver of Credit risk, Liquidity risk, Market risk and Operational
risk, and individual risk scores have been assigned. For these categories of existing risks, the results of the
assessment have been aggregated at the level of physical and transition risks sub-types. The assessment of C&E
risks as drivers of Strategic risk, Reputational risk and Legal risk has been performed at the abovementioned
granularity level.
C&E Transmission Channels
C&E risks are recognized as drivers of the existing risks and may impact BOCH directly or indirectly through
counterparties, assets (microeconomic channels) or the broader economy in which the relevant clients and BOCH
operates (macroeconomic channels). BOCH has defined the transmission channels through which the C&E risks
can influence each of its existing risk categories, the Table below provides a non-exhaustive list of transmission
channels and is not limited to the C&E risks identified as material. A more detailed description of each of the C&E
risk transmission channels regarding the principal risks and the arising impact on BOCH is provided in Table 3
below.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
125
ESRS E1 - Climate Change (continued)
5. Description of the processes to identify and assess material climate-related impacts, risks and opportunities (continued)
C&E Transmission Channels (continued)
C&E Risk
Drivers
Transmission Channels
(Non-exhaustive List)
Potential Impact on the Group
Affected
Financial and
Non-Financial
Risk Types
Climate
related and
Environmental
Transition
Risks
i.
Impact on repayment ability of clients through:
i. Increased operating costs for compliance
and/or lower revenues
ii. Increased capital expenditures to comply
with regulatory standards
iii. Closure of business lines or facilities due to
transition to greener economies and public
sentiment
Increased Probability of Default (‘PD’) and Loss Given Default
(‘LGD’)
Credit Risk
4
i. Impact on the price of marketable instruments
(bonds/equity) and to Real Estate assets
ii. Impact on BOC PCL’s valuation if it does not reduce
its emissions and/ or increase its GAR
i.
Decrease in value of the REMU portfolio due to increase in
operational costs and decrease in the value of the assets
ii. Large/ small sell-off (of High Quality Liquid Assets
(‘HQLA’)) against reduced prices and/ or potential
difficulty to liquidate
iii. Interest rate and FX shocks, credit spreads changes
Market Risk
5
i. Inability to raise funding due to lack of climate
change action by the organisation
ii. Depletion of deposits to address increase operational
costs or mitigate transition risks
i.
Rapid withdrawal of customer deposits
ii. Unexpected significant expenses or charges that may
influence liquidity position and net outflows
iii. Lack of funding sources / negative changes in funding
structure
iv. Lower demand for BOC PCL’s capital issuance
v. Difficulties in selling assets / selling of assets with a
discount
Liquidity Risk
6
Table 3: Overview of the key transmission channels and potential impact on the Group through C&E risks
4
Including Counterparty risk, Settlement risk, Issuer risk, Concentration risk and Country risk.
5
Including Interest rate risk, FX risk, Real Estate risk, Credit Spread risk and Equity risk.
6
Including Liquidity risk and Funding risk.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
126
ESRS E1 - Climate Change (continued)
5. Description of the processes to identify and assess material climate-related impacts, risks and opportunities (continued)
C&E Transmission Channels (continued)
C&E Risk
Drivers
Transmission Channels (Non-exhaustive List) Potential Impact on the Group
Affected
Financial and
Non-Financial
Risk Types
Climate
related and
Environmental
Transition
Risks
Socio-economic changes (e.g. changing consumption
patterns / customer preferences)
i.
Losses due to physical damages or shutdowns
ii. Increased operational costs for the buildings of BOC PCL
iii. Losses from lower productivity
iv. Losses from wrong decisions/ process issues
v. Additional significant operating or capital expenses
Operational
Risk
7
i. Inability to meet stakeholders' demands as a result
of changing market sentiment
ii. Reputational damage due to the financing of
environmentally harmful projects
i. Limited business opportunities/ lessened expansion potential
ii. Workforce fluctuations
iii. Client withdrawal
iv. Additional investments to improve internal processes and
comply with expectations
Reputational
Risk
Litigation risks due to financing of environmentally harmful
projects
i.
Litigation costs may reduce the value of the REMU
portfolio
ii. Non-compliance with regulation and policy measures
iii. Investments in carbon intensive and unsustainable projects,
buildings or similar
iv. Misalignment of communicated targets and reality
Legal/Litigation
Risk
i.
Additional costs and
regulatory repercussions
relating to, for example, exposure to real estate
portfolio without adequate EPC labels, or exposure
to high emitting/ polluting sectors
ii. Regulatory and / or market developments in
relation to financial institutions offering 'green'
products impacting BOC PCL's competitiveness
i.
Loss of revenues due to strategic reorientation (e.g. loss of
profitable business line)
ii. Inadequate definition and execution of the strategy (e.g.
incorrect or faulty assumptions, poor implementation)
iii. Expenses for the implementation of upcoming C&E regulatory
requirements / changes
iv. Limited business opportunities/ lessened expansion potential
Strategic Risk
Table 3: Overview of the key transmission channels and potential impact on the Group through C&E risks (continued)
7
Including Regulatory Compliance/Conduct risk, FEC risk, Internal/ External Fraud risk, People risk, BC risk, IT/ Cyber Risk, Technology risk, Data Accuracy and Integrity risk, Physical Security
and Safety risk, Statutory Reporting and Tax risk, Transaction Processing and Execution risk, Project risk, Model risk and Third Party risk.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
127
ESRS E1 - Climate Change (continued)
5. Description of the processes to identify and assess material climate-related impacts, risks and opportunities (continued)
C&E Transmission Channels (continued)
C&E Risk
Drivers
Transmission Channels (Non-exhaustive List) Potential Impact on the Group
Affected
Financial and
Non-Financial
Risk Types
Climate
related and
Environmental
Physical Risks
i.
Increased operating costs due to retrofitting and/or
damage / substitution of assets
ii. Increase in insurance costs
iii. Lower revenues due to reduced productivity or
damage in value chain operations
iv. Decrease in value of property collateral
Increased PD and LGD Credit Risk
i. Impact on the price of marketable instruments
(bonds/equity) and to Real Estate assets
ii. Impact on BOC PCL’s valuation if it does not reduce
its emissions and/ or increase its GAR
i.
Decrease in value of the REMU portfolio due to increase in
operational costs and decrease in the value of the assets
ii. Large / small sell-off (of HQLA) against reduced prices and/
or potential difficulty to liquidate
iii. Interest rate and FX shocks, credit spreads changes
Market Risk
Depletion of deposits to address increase operational costs or
address or mitigate physical risks (e.g. to finance damage
repairs)
i.
Rapid withdrawal of customer deposits
ii. Unexpected significant expenses or charges that may
influence liquidity position and net outflows
iii. Lack of funding sources / negative changes in funding
structure
iv. Lower demand for Bank's capital issuance
v. Increase in funding costs
vi. Difficulties in selling assets/ selling of assets with a discount
Liquidity Risk
Table 3: Overview of the key transmission channels and potential impact on the Group through C&E risks (continued)
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
128
ESRS E1 - Climate Change (continued)
5. Description of the processes to identify and assess material climate-related impacts, risks and opportunities (continued)
C&E Transmission Channels (continued)
C&E Risk
Drivers
Transmission Channels (Non-exhaustive List) Potential Impact on the Group
Affected
Financial and
Non-Financial
Risk Types
Climate
related and
Environmental
Physical Risks
Increased operating costs due to damage on premises,
operating locations and other facilities
i.
Losses due to physical damages or shutdowns
ii. Increased operational costs for the buildings of BOC PCL
(e.g. to comply with energy efficiency standards)
iii. Losses from lower productivity
iv. Losses from wrong decisions/ process issues
v. Unplanned or additional significant operating or capital
expenses
Operational
Risk
Increased operating costs arising from the management
of C&E risks
i.
Limited business
opportunities/ lessened expansion potential
(including respective operating losses)
ii. Workforce fluctuations (including respective operating
losses)
iii. Client withdrawal (including respective operating losses)
iv. Additional investments to improve internal processes and
comply with expectations
Reputational
Risk
Litigation risks arising from BOC PCL's exposure to
physical climate-related and/ or environmental damages
i.
Litigation costs may reduce the value of the REMU portfolio
ii. Non-compliance with regulation and policy measures
iii. Investments in carbon intensive and unsustainable projects,
buildings or similar (knock on effects from reputational loss)
iv. Misalignment of communicated targets and reality
Legal/Litigation
Risk
Inadequacies in BOC PCL’s product offerings without
factoring in the potential damages resulting from physical
risks associated with climate change; this could result in
increased defaults on loans and negatively impact BOC
PCL's asset quality.
i.
Loss of revenues due to strategic reorientation (e.g. loss of
profitable business line)
ii. Inadequate definition and execution of the strategy (e.g.
incorrect or faulty assumptions, poor implementation)
iii. Expenses for the implementation of upcoming C&E
regulatory requirements / changes
iv. Limited business opportunities
Strategic Risk
Table 3: Overview of the key transmission channels and potential impact on the Group through C&E risks (continued)
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
129
ESRS E1 - Climate Change (continued)
5. Description of the processes to identify and assess material climate-related impacts, risks and
opportunities (continued)
Assessment of C&E risks as drivers of financial and non-financial risks
Following the mapping of C&E risks as potentially relevant or not-relevant drivers of the principal risks through
the transmission channels, follows the assessment of the C&E risks and their relevant impact based on the
principal risks. BOCH has applied a combination of both qualitative and quantitative methods. The following
methodologies have been applied:
a. Quantitative Geographic Assessment
This assessment is applicable to C&E physical risks as drivers of Credit, Market, Liquidity and Operational risks.
Specific physical climate-related hazards, namely Wildfire, Landslide, River Flood, Wind Gusts (Storms), and Sea
Level Rise have been considered using geolocation data (i.e. coordinates, postal codes, municipalities) with
respect to the following:
i. Credit risk: borrowers’ collateralized (secured) portfolio (geolocation coordinates of collateral properties)
and unsecured portfolio (postal codes or municipalities of borrowers’ location);
ii. Market risk: properties of BOCH’s REMU portfolio (geolocation coordinates of collateral properties);
iii. Liquidity risk: deposits held by Cyprus residents (postal codes or municipalities of deposit holders’
locations);
iv. Operational risk: BOCH’s physical locations (postal codes or municipalities of Bank’s facilities).
Furthermore, specific environmental hazards, namely Air Pollution, Soil Pollution and Earthquake have been
considered with respect to the following:
i. Property collateral for Credit risk secured portfolio (geolocation coordinates of collateral properties) - with
respect to Air pollution, Soil pollution and Earthquake;
ii. Borrowers for Credit risk unsecured portfolio (postal codes or municipalities of borrowers’ location) - with
respect to Air pollution, Soil pollution and Earthquake;
iii. Property collateral for the REMU portfolio for Market risk (geolocation coordinates of collateral properties)
- with respect to Earthquake;
iv. Deposits held by Cyprus residents for Liquidity risk (postal codes or municipalities of deposit holders’
locations) - with respect to Earthquake;
v. BOC PCL’s physical locations for Operational risk (postal codes or municipalities of BOC PCL’s facilities) -
with respect to Earthquake.
To further analyze the materiality of risk exposures to both physical and environmental hazards, a distribution
analysis of underlying credit exposures (for both secured and unsecured portfolios), deposit amounts and
employees count across risk scores (1-Low, 2-Medium, 3-High, 4-Critical) is performed. To conclude on the
materiality of a specific hazard based on the distribution analysis across risk scores, a decision tree logic has been
applied leading to one resulting risk score per hazard.
b. Quantitative Country Heatmaps
To inform the MA process, BOCH has performed a heatmapping exercise to determine how physical and transition
risks affect certain industries that BOCH is exposed to, and subsequently to determine the impact on the overall
BOCH’s risk profile and operations. The following heatmaps were constructed to assess specific risks and
segments as described below.
Country climate transition risk heat map
The heatmap was used to assess:
i. Liquidity risk: deposits held by non-Cyprus residents (foreign deposit amounts)
ii. Market risk: HQLA Bond portfolio (corresponding Conditional Value at Risk (CvaR))
A corresponding risk score from the heat map has been assigned to foreign deposit holders based on the
underlying country of residence, and to bonds based on the underlying country of the issuer. As a next step, a
distribution analysis of deposit amounts and CVaR across risk scores has been performed.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
130
ESRS E1 - Climate Change (continued)
5. Description of the processes to identify and assess material climate-related impacts, risks and
opportunities (continued)
Assessment of C&E risks as drivers of financial and non-financial risks (continued)
b. Quantitative Country Heatmaps (continued)
Country climate physical risk heat map
The heatmap was used to assess:
i. Market risk and Liquidity risk: HQLA Bonds portfolio
ii. Operational risk: Foreign locations of BOC PCL’s third party outsourcing/ providers
A corresponding risk score from the heat map has been assigned to bonds based on the country of issuer and to
third party providers based on country of location. As a next step, a distribution analysis of HQLA balances (CVaR
for Market risk and market value for Liquidity risk) and number of employees (per country of third-party provider
location) across risk scores has been performed.
In order to conclude on the materiality of climate transition and physical risks based on the distribution analysis
described above, the same logic as described in the quantitative geolocation methodology (decision tree) has
been applied, leading to a single resulting risk score (consistently, the same 4-level unique risk scale has been
applied).
c. Qualitative analysis based on Expert Judgement
Expert judgement has been also employed to assess certain risk drivers including those for Strategic, Reputational
and Legal risks. Expert judgement includes additional external sources and publicly available statistical data such
as consultation reports, scientific publications and other sources featuring Cyprus-specific data from Eurostat,
World Resource Institute, Climate Analytics, Climate Vulnerability Monitor etc.
d. Sectoral Analysis
For transition risks, the BOCH has used an industry heatmap with GHG emissions intensity as the indicator of the
sectors’ sensitivity to transition risks (the higher the GHG intensity, the higher exposure to transition risks). As a
next step, a distribution of the credit exposures to these emissions categories has been allocated and an overall
score for transition related risks was determined.
e. Determination of materiality
Different types of scores have been considered during the MA depending on the type of risks analysed and
methods considered. Determination of materiality was concluded at C&E Risks Level 3, i.e., at the level of chronic,
acute etc. risks sub-types, utilizing BOCH’s existing Risk and Control Self-Assessment methodology and thus
assessing Magnitude and Likelihood on a scale from one (1) to five (5), to ensure consistency.
The definitions of each Magnitude and Likelihood scores have been formulated, taking into account the nature of
C&E risks and encompassing different characteristics of the physical and transition risks, as well as the acute and
chronic drivers in a harmonised way. Thus, for the purposes of this MA, the definitions of Impact and Likelihood
have been tailored to describe the occurrence of severe C&E events or circumstances, since these are typically
responsible for the great majority of the potential risk. Following the assessment, score levels “High” and “Critical”
have been considered as “material for the purposes of the MA, whilst “Low’ and “Medium” scores as non-
material”.
Reperformance of MA for 2024
In November 2024, the Bank reperformed the MA using identical methodologies to establish whether new risks
must be considered as material. More specifically, Credit, Liquidity, Market and Operational risk analysis was
reperformed with revised data and for the rest of prudential risks that were critically assessed based on expert
judgement, the assessment has been revisited to ensure its validity. The outcome of this analysis did not yield
any changes in the material risks. The RIMA process will be performed at least on an annual basis, or ad-hoc, if
necessary.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
131
ESRS E1 - Climate Change (continued)
5. Description of the processes to identify and assess material climate-related impacts, risks and
opportunities (continued)
The process to identify and assess climate-related impacts, using UN PRB impact analysis tools, is described in
the 4. Impacts, Risks and Opportunities in page 103. The Group identifies climate-related opportunities through
the BES process and Group’s Financial Plan.
BOCH, established and implements a structured and detailed process, with clear roles and responsibilities, to
gather a broad range of updates and developments, both internal and external, and link them with
sectors/industries and products/services so to assess their impact, across different time horizons, and identify
C&E risks emerging from these updates and developments and inform Group’s risk and strategic profile.
The BES process facilitates the ongoing monitoring of potential impacts of C&E risks on its business environment
across short-, medium- and long-term time horizons. This process involves the systematic monitoring of various
news, updates, and developments, including regulatory developments, macroeconomic trends, competitive
landscape, technological trends, as well as societal demographic developments and geopolitical updates. As part
of the process, BOCH collects external information, on a monthly basis, from various sources, such as news
articles, publications, policy and regulatory updates, as well as internal information such as strategy updates,
process changes and other relevant internal documentation.
The identified developments are then mapped to the relevant business lines, sectors/industries and portfolios
that might be impacted, as well as to specific products/services, where applicable. Developments are further
assessed in terms of their relevance across the various time horizons, and preliminary impact scores are assigned
based on the expected effect on the BOCH’s risk and strategic profile. Scores range from 0 (No impact) to 5
(Critical impact).
BOCH has established a dynamic interaction between the BES and the RIMA to ensure that the insights from both
exercises continually inform each other. The results of the BES, for 2024, have been considered and informed
the RIMA and Business Strategy, particularly developments which have been classified as having a “High” or
“Critical”. The results of BES have been utilized to identify climate related opportunities as part of the DMA
process.
The preliminary impact assessment of key updates and developments on risk profile and strategy is conducted
and reported to the SC and EXCO on a quarterly basis. The final impact assessment of key updates and
developments on risk profile and strategy is conducted and presented to the SC, EXCO, NCGC and RC on an
annual basis.
BOCH established also a BES working group with specific responsibilities assigned to Compliance Division, RMD
and Strategy Department so to collectively perform the impact assessment arising from key updates and
developments on risk profile and strategy.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
132
ESRS E1 - Climate Change (continued)
6. Policies and Actions Related to Energy, Climate Change Mitigation and Adaptation
BOCH has developed a set of policies, embedding recurring actions, to effectively manage its material impacts,
risks, and opportunities related to climate change mitigation, energy and adaptation.
Environmental and Social (E&S) Policy
BOCH’s E&S Policy aims to address E&S responsibilities by establishing an E&S management framework, fostering
a culture of E&S responsibility, managing E&S risks in lending activities, training staff for policy implementation,
and supporting customers address E&S matters. The policy guides departments involved in credit granting
process and applies to granting new facilities to physical persons or legal entities secured by mortgage on
immovable property and granting of new funded facilities to legal entities (excluding credit cards). The Policy
does not apply to activities outside of Cyprus nor to restructuring cases unless new facilities are also requested
with the restructuring.
Lending applications associated with activities included in the policy’s Exclusion Sectors / Prohibited Activities
(i.e. Thermal coal mining, upstream oil exploration etc.) are rejected and reported to RMD. For activities that are
classified as low risk by EBRD’s E&S Risk Categorization assessment a written customer confirmation for proper
business conduct, relevant licenses and work permits must be obtained. For activities that are classified as
Medium / High risk by EBRD’s E&S Risk Categorization assessment a written customer confirmation for proper
business conduct, relevant licenses and work permits must be obtained and an E&S study by external expert
should be performed. In addition, other E&S checks should be performed, such as investigations into penalties,
public complaints, adverse media reports, accidents / incidents, regulatory investigations and legal actions as
well as site visits. The findings of the above actions must be stated in the credit application together with any
corrective measures for the mitigation of the E&S risk.
The approving authority decides whether the E&S risk is acceptable and set specific terms and covenants to
control any E&S risks as well as decides the frequency of future E&S studies (at least every 3 years for High-Risk
E&S ratings).
E&S risks associated with a facility are monitored throughout its lifetime:
1. As part of the normal monitoring of the facility (i.e. customer’s credit review)
2. When certain events qualify for re-evaluation of the E&S risks, such as change in business activity, expiry
of operating permits, regulatory investigations, company investments / improvements, public complaints
or adverse media reports, changes to environmental legislation, accidents / incidents and legal actions.
The Board bears the ultimate responsibility for the effective implementation of the Policy and for setting the right
tone from the top. Credit Risk Control & Monitoring (CRC&M) reviews the Policy for proper governance and is
responsible to examine adherence to policy and report divergence to guidelines, as part of on-going monitoring,
through the review of credit applications on a sample basis, at regular intervals, as described in the Credit
Monitoring Policy and CRC&M operations manual. Monitoring compliance with this Policy, on a regular basis, is a
key factor in minimizing E&S risks. This is achieved through quality checks from CRC&M, which indicate the level
of adherence to the Policy in order to take corrective action. Findings are communicated to Chief Risk Officer
(CRO), and recommendations are made for enhancing compliance. RMD performs periodic (at least on an annual
basis) monitoring on the E&S management procedures, to inform management and other stakeholders if policies
and procedures have been implemented and are functioning as expected or if improvements or revisions are
required. An annual report is submitted by CRM to the EBRD, covering the previous financial year and confirming
that BOCH is in full compliance with EBRD’s E&S requirements. The Board approves the Policy, RC reviews and
recommends the Policy prior to the submission to the Board for approval, making sure, that sufficient,
dependable, and secure internal procedures are in place to ensure that the Group complies with the Policy and
monitoring the effective implementation of the Policy via the Control Functions. The policy is available for all
employees through internal portal.
Details on the E&S Policy are provided directly to customers through Business lines as part of the loan origination
process.
The above-mentioned actions are not associated with any capital or operating expenditure as are allocated on
existing resources of the Group including Consumer Banking Division, Corporate & SME Division, International
Banking Division, Credit Risk Control & Monitoring, Corporate & SME Credit Risk and Credit Sanctioning.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
133
ESRS E1 - Climate Change (continued)
6. Policies and Actions Related to Energy, Climate Change Mitigation and Adaptation (continued)
Lending Policy
BOCH’s Lending Policy underpins its efforts to manage environmental and social risks associated with financing
activities, focusing also on minimising climate change mitigation, energy and adaptation impacts and risks. The
Policy sets the standards and effective guidelines to be used during the credit granting process which is aligned
with the BOCH’s risk tolerance and approved limits and guides individuals involved in the credit granting process
on effective credit granting standards and sound evaluation of credit risk, including ESG Due Diligence in the loan
origination process for legal entities and its interaction with credit risk.
BOCH, considering the ESG Framework and the C&E risks, which might impact credit risk and repayment ability,
has established an ESG Due Diligence process applied during credit granting and review process. The ESG Due
Diligence process is applicable to customers that meet specific thresholds / criteria. Specifically, the ESG Due
Diligence is applied on legal entities under Corporate & SME Division, within Cyprus, with new lending amount
over 250,000 (direct facilities) and Group’s exposure over 3,000,000 or new lending amount over 1,000,000
(direct facilities).
ESG Due
D
iligence
p
rocess
Roll
o
ut
p
lan
2025
2026
2027
1.
Amend eligibility criteria (Group exposure
thresholds) to increase the number of
entities from the SME Business Line
2. Initiate data collection for the Shipping
portfolio
3. Include large customer groups from the
International Corporate Banking (exact
criteria to be determined)
4. Initiate data collection from existing
international syndicated loans. The
majority of these loans have external ESG
reports which will be used by BOCH for the
data collection.
1.
Further amend
eligibility criteria
(Group exposure
thresholds) to increase
the number of entities
from Corporate and the
SME Business Line
1.
Include selected legal
entities of the Retail
Division
ESG Due Diligence is not applied for dormant companies, start-ups, holding companies, management companies,
companies with total exposure less than 250,000 and Group’s exposure over 3,000,000, special purpose
vehicles and Governmental authorities. During the credit application assessment process, that falls under specific
thresholds / criteria, for granting new and/or reviewing existing credit facilities, Business Units must identify,
evaluate and assess ESG matters that are relevant to the borrower. ESG Due Diligence includes the following:
1. ESG questionnaires (applicable for new lending and review): The questionnaires must be completed by
the customer, in order to collect relevant quantitative and qualitative information, identify and assess
ESG matters that are relevant to the borrower and derive an ESG score which reflects the performance
of the customer towards ESG factors and exposure of customers towards ESG risks.
2. Scenario Analysis (applicable for new lending): The repayment ability of the borrower is evaluated under
certain negative Environmental (E) scenarios, to assess the extent to which environmental risks affect
the borrower’s financial position and repayment ability.
3. Assessments under (1) and (2) above are evaluated and, where necessary, recommendations to
borrowers in aligning with regulations and existing best practices are made, (depending on the ESG
questionnaires results) and/or specific covenants will be set for monitoring (depending on the joint
assessment of (1) and (2) above).
RMD is authorized to set thresholds and criteria through detailed guidelines, for the application of the above
process to the Business Lines and to issue guidelines as to how the findings of the assessment under (1) and (2)
may impact the cost of the borrower (refer to Lending Pricing Policy below) and/or whether any issues identified
should be resolved before disbursement.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
134
ESRS E1 - Climate Change (continued)
6. Policies and Actions Related to Energy, Climate Change Mitigation and Adaptation (continued)
Lending Policy (continued)
The relevant ESG questionnaire incorporates specific questions relating climate change mitigation, adaptation
and energy. Depending on the customer’s response and the associated weight of the Environmental (E) score,
the customer’s aggregated score derives. The above-mentioned process develops also a high-level roadmap for
the customer under assessment in order to improve the ESG score and mitigate potential ESG risks. The ESG
questionnaire, Synesgy solution, takes into account Global Reporting Initiative (GRI) and ESRS metrics in order
to assess customer’s performance on ESG spectrum.
Investment cost for the implementation of ESG Due Diligence process (Synesgy Questionnaire & Data Lake)
solution for the FY2024 was 62k. The budgeted cost included in the Financial Plan period 2025-2028, for the
ESG Due Diligence, is 420k. Therefore, the above-mentioned actions are not associated with any significant
capital or operating expenditure.
In addition, through this policy the Group mandates the collection of Energy Performance Certificates, in loan
origination process, for properties financed or assigned as collaterals (building or planning permit after
01/01/2010) which indicate the exposure to climate transition risk. Currently, mandatory collection of EPCs has
been instructed for better quality of data in assessing Group’s exposure to climate transition risks, and classify
Housing loans, with EPC Category A and meeting certain criteria, as Green, in accordance with the decarbonization
strategy of Residential mortgage portfolio. Further details on EPC gathering in loan origination process are
included in relevant procedure manuals and circulars.
The Board approves this Policy and bears the ultimate responsibility for the effective implementation of the Policy
and for setting the right tone from the top.
High-level information on the Lending policy is available on the Group’s website and further details at product or
service level are provided to customers either through direct communication with the Business Lines or through
Group’s website.
The Group follows the three lines of defence model, each performing certain duties in relation to credit risk
exposure, namely front line, RMD and IAD.
CRC&M reports are used to monitor and assess Asset quality, examine Lending Policy compliance and identify
any Policy deviations. This is achieved through:
1. identification of areas of risk and establishing if the risk / return relationship is within the appetite of the
Group;
2. discussing and analysing possible risk scenarios and risk gaps;
3. assessing and reviewing the credit application and granting process;
4. identification of early warning signs in aggregated portfolio and separate sub portfolios and provision of
information so that remedial actions are made.
Green Lending Policy
The Group’s Green Lending Policy, which is based on Green Loan Principles (GLP) of Loan Market Association
(LMA), actively promotes financing towards projects with tangible environmental benefits, including projects
aiming to mitigate climate change mitigation, adaptation and energy impacts and risks. In addition, the policy
enables the Group to grasp green lending opportunities in the market. The policy establishes the criteria to classify
a loan as ‘green’, focusing, among others, on projects such as renewable energy, energy efficiency, clean
transportation, green technologies, climate change adaptation and Green buildings. By providing Green lending
BOCH effectively manages the material negative impacts and risks associated with energy, climate change
mitigation and climate change adaptation. BOCH is in the process of preparing the relevant guidelines, which will
provide further guidance on the specific procedures to be followed for the complete operationalisation of the
Green Lending Policy.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
135
ESRS E1 - Climate Change (continued)
6. Policies and Actions Related to Energy, Climate Change Mitigation and Adaptation (continued)
Green Lending Policy (continued)
Following the BES process on C&E risks, BOCH incorporates Green new lending internal KPIs to Business Lines in
order to promote Green lending practices and effectively manage climate change adaptation, climate change
mitigation and energy impacts and risks as well as grasp available opportunities in the market. For more details
on the Green new lending internal KPIs refer to page 144.
The Board bears the ultimate responsibility for the effective implementation of the Policy and for setting the right
tone from the top. Monitoring of green loans is performed by CRC&M and control functions. More details on Green
lending policy at product or service level can be provided to customers through direct communication with the
Business Lines during the loan origination process.
The above-mentioned actions are not associated with any significant capital or operating expenditure. The
resources allocated relate to existing resources including Consumer Banking Division, Corporate & SME Division,
International Banking Division, CRC&M, Corporate & SME Credit Risk and Credit Sanctioning.
Sustainable Finance Framework
The Group established a Sustainable Finance Framework (SFF) aiming to improve disclosure and transparency
on sustainability and to bring to international investors more opportunities to invest in sustainable developments
in Cyprus. The SFF is designed to support the management of climate change mitigation, adaptation and energy
impacts and risks and grasp opportunities through sustainable financing. The Group has set up a SFF which
facilitate the issuance of:
i. Green Bonds/Loans – for which the funds raised are exclusively allocated to Eligible Green Projects;
ii. Social Bonds/Loans – for which the funds raised are exclusively allocated to Eligible Social Projects;
iii. Sustainability Bonds whereby the funds raised are exclusively allocated to Eligible Green Projects
and to Eligible Social Projects.
The SFF is aligned with the Green Bond Principles and defines the following core elements:
i. Use of Proceeds;
ii. Process for Project Evaluation and Selection;
iii. Management of Proceeds;
iv. Reporting.
For Use of Proceeds an amount at least equivalent to the net proceeds of any Sustainable Financing Instrument
issued by the Group will be allocated to finance new or re-finance, in whole or in part sustainable projects which
meet the eligibility criteria of the following Eligible Green and/or Social Project categories.
The Project Evaluation and Selection Process ensures that the proceeds of any of the Group’s Sustainable
Financing Instruments are allocated to new lending or existing projects that meets the criteria set out under the
SFF. The Group has established a Sustainable Financing Working Group (SFWG) to carry out the evaluation and
selection process.
In addition, it is Group’s intention to maintain an aggregate amount of Eligible Sustainable Projects that are at
least equal to the aggregate net proceeds of all the Group’s Sustainable Financing Instrument issuances that are
concurrently outstanding under this Framework. In the event that the aggregate value of Eligible Sustainable
Projects in the Group’s Eligible Asset Portfolio is less than the total outstanding amount of the Group’s Sustainable
Financing Instrument(s), the unallocated surplus funds will be held in line with the Group’s general liquidity
management guidelines until allocated to Eligible Sustainable Projects. Eligible projects are:
a) Renewable Energy (Environmental)
b) Energy Efficiency (Environmental)
c) Clean transportation (Environmental)
d) Green Buildings (Environmental)
e) Access to Essential Services – Healthcare
f) Employment Generation and SME financing
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
136
ESRS E1 - Climate Change (continued)
6. Policies and Actions Related to Energy, Climate Change Mitigation and Adaptation (continued)
Sustainable Finance Framework (continued)
For all Sustainable Financing Instrument issuances under this Framework, the Group is committed to providing
investors with transparent reporting on the allocation of proceeds towards Eligible Sustainable Projects (Allocation
Reporting), as well as to report on the positive environmental and social impacts of those projects (Impact
Reporting). The Sustainable Financing Instrument Report will be updated annually, until full allocation of the
proceeds of the issued Sustainable Financing Instrument(s).
Following the setup of the SFF in 2023, BOC PCL, in 2024, issued a 300mn green senior preferred notes under
the EMTN programme in line with the Group’s Beyond Banking approach, aimed at creating a stronger, safer and
future-focused bank and leading the transition of Cyprus to a sustainable future. An amount equivalent to the
net proceeds of the Notes will be allocated to eligible green projects as described in the SFF.
Concentration Risk Policy
The Concentration Policy applies at Group level and defines limits and the methodology for setting limits towards
exposures in specific assets, liabilities and off-balance sheet items to ensure that concentration risk is within the
Risk Appetite. The Concentration Risk Policy complements the efforts of managing negative impacts and risks
associated with energy, climate change adaptation and climate change mitigation by restricting lending to carbon-
intensive sectors, including oil, gas, manufacturing of cement, manufacturing of Iron & Steel & Aluminium and
non-renewable power generation. Financing in these sectors is only permitted for carbon-intensive NACE sectors
subject to a total (cumulative) exposure of 100m as per the provisions of this policy and for transition or green
projects that align with the Group’s sustainability objectives, subject to approval by its highest credit committees.
The Board approves the Policy and bears the ultimate responsibility for the effective implementation of the Policy
and for setting the right tone from the top. Monitoring of Concentration Risk Policy is performed by:
1. CRC&M through monitoring of:
1. Large exposures on a monthly basis.
2. Credit risk concentration limits through semi-annual quality assurance reviewed.
2. Market & Liquidity Risk Department is responsible for monitoring country, counterparty risks, funding sources,
derivatives and brokers.
3. Credit Risk Management Department is responsible for monitoring sector, collateral and name concentration.
In general, monitoring is performed at least on a monthly basis and more frequently as required by the type
of limit and Business Lines are informed accordingly, in order to ensure real time monitoring. As part of this
process, data is sourced from the Data Warehouse system. Such data is governed by data quality rules put
in place by the Data Quality & Governance department. RC is informed about the outcome of this monitoring.
The above-mentioned actions are not associated with any significant capital or operating expenditure. The
resources allocated relate to existing resources including Consumer Banking Division, Corporate & SME Division,
International Banking Division, Credit Risk Control & Monitoring, Corporate & SME Credit Risk and Credit
Sanctioning.
Lending Pricing Policy (LPP)
The purpose of LPP is to define the principles of pricing new loans and overdrafts. The Group is recognising the
important of promoting sustainability in its lending practises so it has developed a comprehensive plan aiming to
integrate ESG and climate factors into its loan pricing framework to ensure a long-term sustainable growth.
The Group performed market research to identify the best practices to incorporate ESG and climate considerations
in the loan pricing. Following the market research, BOCH introduced margin discounts by taking into account the
customer’s ESG score and the transaction eligibility under Green Lending Policy. A margin discount, based on the
client’s ESG and climate impact, has been implemented for both new and existing clients on new lending requests,
for all clients (all sectors) under Corporate Division, differentiating however between carbon-intensive vs. non-
carbon intensive sectors. The Group linked the margin discount at the client level to the borrower's “E” scoring
(extracted from borrower’s ESG score). In addition, the margin discount is linked at the transaction level (i.e.
whether lending is green or not) utilizing the provisions of the Green Lending Policy. This approach aims to
incentivize customers to have a better ESG score and obtain Green lending in order to be exposed to lower level
of energy, climate change transition and adaptation impacts and risks.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
137
ESRS E1 - Climate Change (continued)
6. Policies and Actions Related to Energy, Climate Change Mitigation and Adaptation (continued)
Lending Pricing Policy (LPP) (continued)
CRC&M currently monitors the implementation of the LPP through a sample review of new lending cases approved
for a reduction in pricing on a semi-annual basis.
Treasury monitors pricing deviations (related to customer-based lending or to pre-priced products or to any other
lending of which pricing has already been approved by ALCO) below Directors’ discretionary limits (as per relevant
ALCO approval) on a quarterly basis through a centralised ex-post reporting procedure. All pricing deviations per
business line are reported to ALCO quarterly. In case pricing deviations exceed 10% of new lending in the
respective reporting period (in terms of amount per business line), ALCO is informed accordingly. All pricing
deviations below Director’s discretionary limits should be agreed with the relevant line Director and approved by
Deputy Chief Executive Officer.
LPP is reviewed and revised at least on an annual basis (or more frequently if deemed necessary), by Treasury,
after considering the input provided by each stakeholder. The policy is subject to approval by the Board, following
Asset & Liability Committee (ALCO) and RC recommendation and is subject to review at least on an annual basis
or more frequently if deemed necessary.
The policy is made available through detailed circulars and procedures and is readily available in the Employee
Internal Portal. More details on LPP at product or service level can be provided to customers through direct
communication with the Business Lines during the loan origination process or through Group’s website.
The above-mentioned actions are not associated with any significant capital or operating expenditure. The
resources allocated relate to existing resources including Consumer Banking Division, Corporate & SME Division,
International Banking Division, Credit Risk Control & Monitoring, Treasury, Corporate & SME Credit Risk and
Credit Sanctioning.
Collateral Valuation Policy
The purpose of the policy is to set the guidelines on how collaterals obtained by BOCH are valued at origination
and how such value is monitored and reviewed at regular intervals, to ensure:
a) that they provide adequate coverage for the credit facilities granted by BOC PCL and an accurate picture
of the value of collateral in case of enforceability, provisioning, or capital calculations.
b) valuation risk is prevented and deterred and, where it does occur, it is addressed in a timely and
expeditious manner.
The Policy guides relevant departments involved in the credit process, regarding collateral valuation and
monitoring. All departments involved in the credit process must be aware and comply with this policy and related
policies and circulars which are adopted in conjunction with the policy.
Furthermore, BOC PLC’s collateral, REMU and own property valuation process involves several significant
valuation parameters and considerations. The existing valuation templates include among other a section on
environmental risks, which valuers must assess to determine the market value.
BOC PCL through a specific circular, during 2023, emphasised to the valuers the importance of considering certain
physical risks during the valuation process. The following risks must be considered in the valuation process are
listed below although the list is not considered as exhaustive.
a) Ground Geological Suitability (identifying and reporting the zone and its characteristics)
b) Area seismicity around the property (identifying and reporting the zone and intensity)
c) Risk of flooding (identifying and reporting the zone and intensity)
It is also mandatory, during the valuation of collaterals, to request EPC of the collateral and to be adequately
captured in the valuation report. It is also mandatory for valuers to include adequate commentary on the presence
of contamination and hazardous substances deriving from current or past activities on the property or its location.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
138
ESRS E1 - Climate Change (continued)
6. Policies and Actions Related to Energy, Climate Change Mitigation and Adaptation (continued)
Collateral Valuation Policy (continued)
The Property Valuation System has been enhanced to record the above information about physical risks and EPC.
The above-mentioned process mitigates the exposure of the Group towards energy, climate change mitigation
and adaptation impact and risks. On a quarterly basis, a Quality Assurance Report, is submitted to the SC, by
Premises & Valuations Department, indicating the percentage of valuation reports obtained that are full compliant
with the new requirements, partial compliance or major deviations observed, on a sample basis. The SC
determines the actions to be followed by the Valuations Department.
External valuations are reviewed on a regular and sample basis as appropriate, by Premises & Valuations
Department, to confirm that the external valuer has complied with BOC PCL’s valuation requirements. For all
cases above, Premises & Valuations Department submits an annual report to the CRO with relevant information
and suggestions. In addition, as part of on-going monitoring, CRC&M reviews credit applications on a sample
basis, to ensure adherence to policy.
The Board approves the Policy and bears the ultimate responsibility for the effective implementation of the Policy
and for setting the right tone from the top. RC reviews and recommends, the Policy, for approval to the Board,
making sure, that sufficient, dependable, and secure internal procedures are in place to ensure that the Group
complies with the Policy and monitoring the effective implementation of the Policy via the Control Functions. The
above-mentioned action is not associated with any capital or operating expenditure. The resources allocated
relate to existing resources including Consumer Banking Division, Corporate & SME Division, International
Banking Division, Credit Risk Control & Monitoring, Treasury, Corporate & SME Credit Risk and Credit Sanctioning.
Group’s Own Operations and Decarbonisation Levers
The Group, even with no established policy yet associated with energy, climate change mitigation and adaptation
on own operations, has implemented and plans to implement several actions, on owned buildings and branches,
aiming to mitigate material negative impacts on climate change mitigation, climate change adaptation, energy
efficiency and renewable energy deployment.
The Group plans to establish an Environmental Management Policy on own operations within 2025 in order to
provide guidance to the Group on how to actively promote environmental sustainability in own operations through
ongoing identification, management and improved efficiency of environmental impacts associated with the
Group's business activities, namely: energy management, adaptation measures, use of resources, renewable
energy, recycling and waste management and procurement decisions. The decarbonisation activities conducted
the last two years are depicted in the following table. Group’s own funds are supporting the implementation of
decarbonisation actions. The Group’s Financial Plan embeds actions associated with the decarbonization plan for
2025-2028.
Group’s Decarbonisation Actions – Own Operations
202
3
2024
(
000)
Installation of electric chargers for cars
3
88
Air
-
conditioning systems replacements
42
107
Roof insulation
88
Solar Panels
132
38
Plug in hybrid vehicles
139
Electric vehicles
139
Lighting replacement
2
7
55
Total
204
654
In addition, Branch rationalisation associated with the Digital Transformation programme is considered a
decarbonization lever as well. The Group is considering the implementation of a large project which is expected
to reduce Scope 1 and Scope 2 GHG emissions between 10%-20% compared to 2024 emissions inventory.
Resources allocated towards implementation of the above-mentioned actions are the existing employees under
the Administrative operations Department of the Group. The above-mentioned investment costs are reflected as
additions in the Note 25 Property and equipment of the Consolidated Financial Statements.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
139
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
GHG Emission Reduction Targets – Own Operations – Scope 1 and Scope 2
The Group has estimated the Scope 1 (Mobile Combustion, Stationary Combustion and Fugitive Emissions) and
Scope 2 GHG emissions of 2021 relating to own operations in order to set the baseline for carbon neutrality target
in own operations, given this was the year the Group’s decarbonisation efforts were initiated. For the Group to
meet the carbon neutrality target by 2050, the Group has set an interim target to reduce Scope 1 and Scope 2
GHG emissions by 42% (absolute target) by 2030. The absolute reduction target has been set following the IEA’s
B2DS and sectoral decarbonisation approach using Science Based target initiative’s (SBTi) tool. The
decarbonisation target has not been externally assured by relevant climate global bodies, such as SBTi. The target
is directly linked with the Group’s ESG strategy until the Group’s Environmental policy becomes effective by the
end of 2025.
BOCH’s decarbonisation efforts, including actions described in section Group’s Own Operations and
Decarbonisation Levers, lead to the reduction in Scope 1 and Scope 2 GHG emissions by 3,431 tCO
2
e in 2024
compared to 2021 which represents c.25% reduction. BOCH should perform additional decarbonisation actions
to reduce Scope 1 and Scope 2 GHG emissions by c.17% to achieve the interim target of 2030.
The Group’s own carbon footprint will continue to be calculated on an annual basis which will enable comparisons
to be made and progress against decarbonisation target to be monitored.
The energy efficiency actions conducted in 2024 were netted off with the increased electricity consumption due
to cooling needs associated with summer heatwaves, leading to stable Scope 2 GHG emissions between 2023
and 2024.
Metric
2021
Base
line
Target
year
Target
Target
reduction
Performance
as at 31
December 2024
Figure as at
31 December
2024
Methodology
Benchmark
1.5 °C
Scenario
tCO
2
eq 13,693 2030 7,942 (42%) (25%) 10,262 SBTi (66%)
Notes:
1) Scope 2 GHG emissions used to set the GHG emission reduction target are based on the location-based approach.
2) The gases included in the calculations are CΟ2, CH4, and N2O.
3) The GHG emission reduction target is reported on a gross basis and does not include GHG removals, carbon credits or avoided emissions.
4) The carbon footprint for Scope 1 and Scope 2 were estimated based on the methodologies described in the Greenhouse Gas Protocol and ISO14064-1:2019
standard.
5) Benchmark 1.5°C indicates the % reduction compared to the baseline if the 1.5 °C scenario was used.
The Group monitors the performance against the GHG emission target on own operation through SC, EXCO and
NCGC on a quarterly basis through the Sustainability Performance Report.
GHG Emission Reduction Targets – Loan Portfolio - Scope 3
The Group, by taking into account the GHG emissions estimated for loan portfolio, the most significant loan
exposures and the RIMA on C&E risks, decided to set a decarbonisation target on Mortgage portfolio, since their
exposure corresponds to 34% of Households, Non-Financial and Other-Financial Corporations exposures and
corresponds to c.6% of Group’s GHG emissions of loan portfolio. The target is aligned with the Group’s ESG
ambition to reach Net Zero by 2050 and is linked with the objectives of the policies mentioned above. The Group
has estimated the GHG emissions per square metre, as at 31 December 2022, for the properties financed under
its Mortgage portfolio using the PCAF methodology and proxies, to identify the baseline. By applying SBTi target
setting methodology, the baseline should be no more than a year from the target’s effective date. Therefore,
given the target was effective from December 2023, the baseline was set at December 2022. Then Group utilised
the SBTi’s tools, sectoral decarbonisation approach, in order to estimate the decarbonisation pathway that the
Mortgage portfolio should follow to be aligned with the IEA B2DS. The Group decided to align the Mortgage
portfolio with IEA B2DS due to the following reasons:
i. The scenario is consistent with Global warming projections (IEA and Intergovernmental Panel on Climate
Change (‘IPCC’)) and is considered a widely acceptable scenario.
ii. The scenario is considered more plausible compared to the IEA’s Net Zero Scenario given the fact that
Cyprus market is pre-mature in the climate field. Therefore, BOCH considers reasonable to initiate its
efforts based on a less intense scenario and then intensify its efforts when the overall Cyprus market is
more mature in the field.
iii. Lack of data, enhances the risk of not having a solid baseline, so BOCH considers that is more prudent to
initiate its efforts based on a less optimistic scenario until data availability and quality is enhanced.
iv. The scenario is more straightforward to obtain and use as it is aligned with SBTi’s available tools.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
140
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
GHG Emission Reduction Targets – Loan Portfolio - Scope 3 (continued)
In order to ensure the feasibility of the interim decarbonisation target and derive the decarbonisation strategy of
Mortgage portfolio, the Group has projected the GHG emissions per square metre for the properties financed
under its Mortgage portfolio as at 31 December 2030. In order to project the Mortgage portfolio as at 31 December
2030, BOCH used various assumptions such as:
i. Projected new lending on Mortgage portfolio between 2025-2030;
ii. Projected square metres of each property financed under projected Mortgage new lending;
iii. Allocation of new lending on Mortgages to EPC classifications;
iv. PCAF proxies on GHG emissions per financed residential property;
v. Cyprus Government targets on the reduction of GHG emissions as well as the utilisation of renewable
energy on residential buildings by 2030;
vi. Maturity of Mortgage exposures between 2025-2030.
When setting the target, the Group performed several sensitivities on the assumptions used to project Mortgage
portfolio as at 31 December 2030 in order to ensure the feasibility of the target. Under all scenarios (sensitivities)
the decarbonisation target on Mortgage on 2030 is achieved. In addition, sensitivities were performed to the
baseline of 2022, given the lack of sufficient data, in order to ensure that when data quality of the estimation is
improved in the upcoming years the adjusted decarbonisation target will be met. The decarbonisation target on
Mortgage is also achieved after the increase / decrease of baseline by 10%, under all scenarios. The
decarbonisation target has not been externally assured by relevant climate global bodies such as SBTi.
Metric
2022
Base
line
Target
year
Target
Target
reduction
Performance
as at 31
December 2024
Figure as at
31
December
2024
Methodology
Benchmark
1.5 °C
Scenario
kgCO
2
/m
2
53.50 2030 30.65 (43%) (12%) 47.19 PCAF/SBTi 25.32
kgCO
2
/m
2
53.50 2035 18.60 (65%) (12%) 47.19 PCAF/SBTi 13.77
kgCO
2
/m
2
53.50 2040 11.27 (79%) (12%) 47.19 PCAF/SBTi 4.78
kgCO
2
/m
2
53.50 2045 5.29 (90%) (12%) 47.19 PCAF/SBTi 2.47
kgCO
2
/m
2
53.50 2050 2.34 (96%) (12%) 47.19 PCAF/SBTi 1.22
The Group aims to reduce by 43% the kilograms of GHG emissions financed per square metre (kgCO
2
e/m
2
) under
the Mortgage portfolio, by 2030 compared to 2022 baseline. The Mortgage portfolio as at 31 December 2024
produced 47.19 kgCO
2
e/m
2
which is 12% lower compared to the baseline due to increase in energy efficient
residential properties financed in 2024 following introduction of Green Housing product.
54
51
48
46
43
40
37
34
31
28
26
23
21
19
17
16
14
13
11
10
9
8
6
5
5
4
4
3
2
-
10
20
30
40
50
60
2020 2025 2030 2035 2040 2045 2050
Carbon Intensity (kgCO
2
/m
2
)
Year
Carbon Intensity Target – Mortgage Portfolio
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
141
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
GHG Emission Reduction Targets – Loan Portfolio - Scope 3 (continued)
At the end of 2023, the Group introduced the Green Housing product with a variable interest rate. In 2024, the
Group introduced the Green Housing product with a fixed interest rate. Both products are aligned with the GLP
of the LMA, supporting the decarbonization strategy of the mortgage portfolio. The Group’s new lending strategy,
embedded in the 2025-2028 Financial Plan, include a new lending internal KPI associated with the Green Housing
product which represents the decarbonization lever to reach the carbon intensity reduction as presented in the
above graph.
The feasibility of this GHG emission reduction target is strengthened by Cyprus legislation, which mandates that
residential properties must have an EPC Category A to obtain a planning permit for construction after July 1,
2020. The Group’s Mortgage portfolio should be aligned with the abovementioned graph in order to be aligned
with the climate scenario of IEA B2DS and being exposed to lower transition risks. BOCH following the
abovementioned analysis determined its new Mortgage lending strategy to meet the decarbonisation target on
Mortgage.
The Group monitors the performance against the new lending metric associated with decarbonisation target on
Mortgage in order to take remedial action on time:
i. By the SC, EXCO and NCGC through the Sustainability Performance Report (Quarterly)
ii. By the SC, EXCO and RC through the Climate Risk Report (Quarterly)
iii. By EXCO through the monthly performance pack (Quarterly)
iv. By BDC on a monthly basis.
The GHG emission reduction target on Mortgage portfolio is reported based on the intensity value, adopting the
transitional provision to limit the information on value chain targets, for the first three years, to the information
available in-house, on absolute values for target year and interim years.
Operational Limits to manage material climate transition and physical risks
In addition to the decarbonisation target set on Mortgage portfolio, the Group has set Key Risk Indicators (KRIs)
for both climate-related transition and physical risks. The KRI related to transition risks of Non-Financial
Corporations (NFCs) measures the Scope 1 intensity per loan as compared with the average Scope 1 emission
intensity of Cyprus Republic. The KRI and relevant thresholds are updated on an annual basis through revision
of Risk Appetite process. The indicator is monitored by the SC, EXCO, RC and Board as part of the Risk Appetite
quarterly reporting. The KRI is effective for the FY2025 therefore no progress against the indicator has been
reported. The limit is linked with the Group’s Lending Policy.
Description
The
indicator measures the potential exposure at risk in relation to transition risk.
The indicator is applicable to Non – Financial Corporations only.
Thresholds
Business as usual: Early warning: In-breach:
<=30% 30 – 40% >40%
Note:
1) The KRI measures the Potential Exposure at Risk [PEAR = (Exposures with GHG emissions >= the Cyprus average
Scope 1 emissions)/(Total Exposure)].
2) The GHG emissions for BOC PCL’s exposures are estimated using the PCAF proxies and standard.
3) The average Scope 1 emissions (kg per euro) for Cyprus, as reported by the Republic to EuroStat, covering the period
between 2013 to 2019. The data from 2020 to 2021 were excluded due to the impact of COVID-19, which resulted in
lower and non-representative emissions figures. When setting the indicator those were the latest available GHG
emission data for Cyprus.
4) To calculate the PEAR ratio, the Scope 1 emissions per loan exceeding the Cyprus average were summed (numerator)
and then divided by the total GHG emissions of the Non-Financial Corporation Bank (denominator).
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
142
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
Operational Limits to manage material climate transition and physical risks (continued)
The Group is also exposed to climate-related physical acute risks driven by the wildfire risk through its impact on
credit risk on the loan portfolio. Therefore, the Group has set a KRI that measures the exposure collateralised by
immovable property with a “Very High” rating for any physical risk that can impact collaterals (wildfire and
landslides) over the total exposure collateralised with immovable property. This allows the monitoring and
mitigation of such risks. The KRI is effective for the FY2025 therefore no progress against the indicator has been
reported. The limit is linked with the Group’s Lending Policy.
Description
The indicator measures the exposure collateralised by immovable property with a
“Very Highrating for any physical risk over the total exposure collateralised with
immovable property.
Thresholds Business as usual: Early warning: In-breach:
<=30%
30
45%
>45%
Note:
1) The KRI measures the Potential Exposure at Risk [PEAR = (Exposures with physical risk graded “Very High”)/(Total
Exposure)] both at country and district level.
2) Potential exposure at Risk is calculated by considering exposure collateralised by immovable property with a “Very
High” rating for wildfire and / or landslide over the total exposure collateralised with immovable property.
3) Each collateral location receives a rating for each risk, ranging from “Low” to “Very High”. This is referred to as the
SPRI (Synthetic Physical Risk Index), representing the asset's vulnerability to physical risk based on its geographic
location, different climate scenarios and time periods. It is noted that SPRIs do not indicate losses on asset values but
aid in measuring the materiality of exposure to physical risks in the bank’s collateral portfolio.
The above indicator also monitored across material portfolios and geographies (concentration) and their
thresholds are the same as indicated above. The Group has set the following operational limits, applicable for
FY2025, to track the effectiveness of the policies mentioned in Section Policies and Actions Related to Climate
Change Mitigation and Adaptation:
limits Level
Policies to address material
impacts and risks
% of
customers with ESG
Due Diligence
100% of all eligible
(as per Lending
Policy) customers
Lending Policy
Overdue insurance policies
0% overdue insurance polices
Lending Policy
Outstanding valuations
0% overdue outstanding valuations
Valuation Policy
EPCs collections for new
lending
100% of eligible
(as per Lending
Policy) collateral population
Lending Policy
50% of new EPCs to be >
C
50% of eligible
(as per Lending Policy)
new collateral to be greater than EPC C
Lending Policy
Operational Limits – Details
Limit
% of customers with ESG Due Diligence
Description
Requires the completion of the ESG Due Diligence process through the Synesgy
platform (ESG questionnaires). The assessment takes place annually.
Risks addressed
The questionnaires cover
a wide spectrum of
ESG risks
as it is structured based on
GRIs, ESRS and SDGs.
Lines / Portfolios
All eligible customers under SME Banking (Line 2) and Corporate Banking (Line 3).
The KPI will become applicable to any line to
which the ESG Due Diligence process
is introduced.
Thresholds 100% of eligible customers within a single calendar year
limit
Overdue insurance policies
Description
Requires that all real estate obtained as collateral maintains insurance against the
main physical risks
Risks addressed Physical risks: wildfire, flood, earthquake
Lines / Portfolios All lines that obtain real estate as collateral
Thresholds
0% overdue insurance polices
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
143
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
Operational Limits to manage material climate transition and physical risks (continued)
Operational Limits – Details (continued)
Limit
Outstanding valuations
Description
Requires that all real estate obtained as
collateral maintains current valuations as
defined in the Valuation Policy. Since 2024, all valuers are requested to comment
on C&E risks that affect each property. Furthermore, they are required to record
in the Valuations System any flood, earthquake, an
d ground geological suitability
findings as determined by the various authorities of the Republic.
Risks addressed Physical risks: flood, earthquake, geological findings
Lines / Portfolios All lines that obtain real estate as collateral.
Thresholds 0% overdue outstanding valuations
Limit
EPCs collections for new lending
Description
Requires that EPCs are collected for all new real estate obtained as collateral as
part of new lending and are required by Law to have an EPC issued.
Risks addressed Transition risks
Lines / Portfolios All lines that obtain real estate as collateral.
Thresholds 100% of eligible collateral population
Limit
EPCs classification for new lending
Description
Requires that 50% of EPCs collected for all
new real estate obtained as collateral
as part of new lending to have a classification greater than C. The KPI relates to
collaterals that are required by Law to have an EPC.
Risks addressed Transition risks
Lines / Portfolios All lines that obtain real estate as collateral.
Thresholds 50% of eligible collateral population to be greater than C
The KRIs and operational indicators are effective for the FY2025 therefore no progress against the indicators is
reported. The limits are not based on scientific evidence and only internal stakeholders were engaged in setting
those limits.
KPIs Escalation process
If any of the KRIs listed above is breached (whether at the early warning level or the in-breach level) then the
breach is escalated to the CRO. If the breach relates to either a RAS or a Recovery Plan indicator, then the
respective escalation process is followed. KPIs will be monitored as per the existing monitoring process in place
which provides for:
1. KPIs are reported to the Credit Monitoring Forum on a monthly basis and monitored versus thresholds on
a quarterly basis
2. In case of material deviations, these will be reported to the RC as necessary.
Given that the KPIs related to C&E risks, deviations will be reported to the CRO who may decide to escalate to
the SC before any further escalation to the RC.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
144
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
Green lending to manage climate transition and physical risks
The Group, by taking into account the results of BES and the RIMA on C&E risks, has set Green /Transition new
lending internal KPIs for 2024 in order to support the transition of its customer and Cyprus to a low carbon
economy and limit its exposure to transition and physical risks in certain sectors. Specifically, BOCH by taking
into account the results of the RIMA on C&E risks, the expected introduction of Green taxation in Cyprus, the
amendments adopted on the Energy Performance Directive on buildings as well as the Cyprus Government
subsidies identified climate related opportunities and has set Green/Transition new lending internal KPIs on
specific sectors (i.e., Manufacturing, Trade, Construction and Accommodation) to enable the Green transition.
The Green/Transition new lending internal KPIs have been included in the Group’s Financial Plan for 2024 – 2027
and monitored on a monthly basis by the BDC of the Group. Green / Transition new lending internal KPIs are set
on an annual basis during the development of the Group’s Financial Plan.
In addition, BOCH offers a range of environmentally friendly products to manage transition risk and help its
customers become more sustainable. For example, a number of loan products are offered under the Fil-eco
Product Scheme. BOCH offers environmentally friendly Car Hire Purchase addressed to anyone who wants to buy
a new hybrid or electric car, providing its customers the opportunity to buy a new electric or hybrid vehicle and
to move away from transport options reliant on fossil fuels. Moreover, an environmentally friendly loan for home
renovation is offered to customers who want to renovate and upgrade the energy efficiency of their privately
owned primary residence or holiday home and achieve a higher energy efficiency rating. Further, the customers
may benefit from an Energy Loan for the installation of energy saving systems for home use. This product is
addressed to customers who seek financing for the installation of photovoltaic systems for home use and other
home energy-saving systems. At the end of 2023, the Group launched the Green Housing product, with variable
interest rate and in 2024 launched Green Housing product with fixed interest rate, aligned with GLP of LMA, which
drives the decarbonisation strategy of Mortgage portfolio. Green housing products provide a discount to
customers providing the EPC Category A. The new lending strategy of the Group, embedded in the Financial Plan
for 2025-2028, includes the ambition on the new Green Housing product in order be aligned with the GHG
emissions reduction target set and manage transition risk. The fact that the Cyprus legislation imposes residential
properties to have an EPC A so to issue a planning permit after 1 July 2020 facilitates the process. The
Environmentally friendly Gross Loans are not verified by independent body.
Notes:
1) Renewable energy projects relate to Solar and wind parks financed.
2) Energy loans relate to energy efficient equipment, solar panels and energy upgrade financed.
3) Car loans relate to financing the acquisition of Environmentally friendly vehicles under Fil-eco and Green cars under
hire purchase agreement.
4) Green Housing relates to financing the acquisition or construction of a residential property with EPC A. The EPC is
available at collateral level in the Group’s database therefore the one to one (one account number one collateral
property with EPC A) assumption has been applied to identify the Green Housing loans as at 31 December 2024 and
then used the same pool to identify the Green Housing as at 31 December 2023.
154
6
2
25
187
321
11
2
20
355
Green Housing (EPC
A)
Car Loans Energy Loans Renewable Energy
Projects
Total
Environmentally Friendly Loans - Gross Loans as at 31 December (mn)
2023 2024
109%
91%
90%
20%
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
145
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
Energy Consumption and mix
Energy Consumption and mix
Energy consumption and mix
For the period ending 31
December 2023
For the period ending 31
December 2024
(1) Fuel consumption from coal and coal
products (MWh)
- -
(2) Fuel consumption from crude oil and
petroleum products (MWh)
1,749 1,716
(3) Fuel consumption from natural gas
(MWh)
- -
(4) Fuel consumption from other fossil
sources (MWh)
- -
(5) Consumption of purchased or
acquired electricity, heat, steam, and
cooling from fossil sources (MWh)
12,816 12,792
(6) Total fossil energy consumption
(MWh) (calculated as the sum of
lines 1 to 5)
14,565 14,508
Share of fossil sources in total
energy consumption (%)
84% 83%
(7) Consumption from nuclear
sources (MWh)
- -
Share of consumption from nuclear
sources in total energy consumption
(%)
- -
(8) Fuel
consumption for renewable
sources, including biomass (also
comprising industrial and municipal
waste of biologic origin, biogas,
renewable hydrogen, etc.) (MWh)
- -
(9) Consumption of purchased or
acquired electricity, heat, steam, and
cooling from renewable sources (MWh)
2,501 2,497
(10) The consumption of self
-
generated
non-fuel renewable energy (MWh)
285 408
(11) Total renewable energy
consumption (MWh) (calculated as
the sum of lines 8 to 10)
2,786 2,905
Share of
renewable sources in total
energy consumption (%)
16% 17%
Total energy consumption (MWh)
(calculated as the sum of lines 6, 7
and 11)
17,351 17,412
Notes: Energy mix as published by Electricity Authority of Cyprus has been used to break-down energy consumption between
fossil fuels sources and renewable energy sources.
The Group is a Financial Institution and does not belong to High climate impact sectors.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
146
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
Gross Scope 1, 2, 3 and Total GHG emissions
Group’s Gross Scopes 1, 2, 3 and Total GHG emissions
Reporting Year
Gross Scope 1
Emissions
(tCO2eq)
Gross Scope 2
Emissions
(tCO2eq)
Gross Scope 3
Emissions
(tCO2eq)
Total GHG
Emissions
(tCO2eq)
2023
969 9,422 2,512,729 2,523,120
2024
934 9,327 2,883,374 2,893,635
Note: Refer to GHG emissions reporting principles in Additional Information – Sustainability Statement in page 247.
Group’s Gross Scopes 1, 2, 3 and Total GHG
emissions
Reporting Year
Gross Scope 1
Emissions
(tCO2eq)
Gross Scope 2
Emissions
(tCO2eq)
Gross Scope 3
Emissions
(tCO2eq)
Total GHG
Emissions
(tCO2eq)
2023
BOC PCL (including
Jinius)
844 8,565 2,495,033 2,504,442
Eurolife
74 697 4,496 5,267
GIC
31 123 12,793 12,947
CISCO
20 37 407 464
Total
969 9,422 2,512,729 2,523,120
2024
BOC PCL (including
Jinius)
845 8,424 2,857,758 2,867,027
Eurolife
44 726 6,048 6,818
GIC
25 142 19,150 19,317
CISCO
20 35 418 473
Total
934 9,327 2,883,374 2,893,635
Note: Refer to GHG emissions reporting principles in Additional Information – Sustainability Statement in page 247.
Scope 3 GHG emissions
BOC PCL
(including Jinius)
Scope 3 GHG Emissions
(tonnes CO₂e) 2023 2024
% of inputs used from
upstream and
downstream value
chain
Purchased Goods and
Services (Cat. 1)
47,171 43,891
0%
Upstream transportation
and distribution (Cat. 4)
1,376 1,735
0%
Waste generated in
operations (Cat. 5)
2,929 2,970
0%
Business Travel (Cat. 6)
317
327
100%
Employee commuting (Cat.
7)
1,732 1,957 47%
Mortgages
Loans
(Cat. 15)
152,251
139,419
12%
Motor Vehicles
Loans
(Cat.
15)
61,879 51,900
0%
Business Loans (Cat. 15)
1,763,963
2,024,808
0%
Commercial Real Estate
Loans (Cat. 15)
59,685 64,634
0%
Sovereign Bonds (Cat. 15)
343,103
381,871
60
%
Corporate Bonds (Cat. 15)
60,627
144,246
0%
Total Scope 3 emissions
2
,
495,033
2
,
8
57
,
758
Note: Refer to GHG emissions reporting principles in Additional Information – Sustainability Statement in page 247.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
147
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
Gross Scope 1, 2, 3 and Total GHG emissions (continued)
Scope 3 GHG emissions (continued)
Aligned with the Group’s 2050 Net Zero ambition, BOCH joined the Partnership for Carbon Accounting Financials
(PCAF) in October 2022 and adopted its recommended methodology for estimating Financed Scope 3 GHG
emissions from the Group’s investment and lending activities, as well as its insurance contracts. Group’s Financed
Scope 3 GHG emissions constitute 97% of the Group’s total emissions, estimated using the PCAF Standard and
proxies. The PCAF Standard, reviewed by the GHG Protocol, aligns with the Corporate Value Chain (Scope 3)
Accounting and Reporting Standard for category 15 investment activities. It includes a data quality ranking scale
from 1 (highest quality) to 5 (lowest quality), applied to the estimation of emissions for each asset class.
To improve data quality and reduce data gaps, BOCH launched ESG Due Diligence process to gather relevant
data and enhanced its loan origination process to gather Energy Performance Certificates (EPCs) for financed and
certain collateral properties. Additional data collection actions will be undertaken in 2025 based on the ESG and
Climate Data Gap & Strategy. The loan portfolio has been classified into PCAF asset classes to facilitate future
decarbonisation target-setting.
PCAF Asset
class
Definition
Business
loans
8
Business loans include all loans and lines of credit for general corporate purposes (i.e., with
unknown use of proceeds as defined by the GHG Protocol) to businesses, non-profits, and any
other structure of organisation that are not traded on a market and are on the balance sheet
of the financial institution. Revolving credit facilities, overdraft facilities, and business loans
secured by real estate such as CRE-secured lines of credit are also included. Any off-balance
sheet loans and lines of credit are excluded.
Commercial
real estate
This asset class includes on
-
balance sheet loans for specific corporate purposes, namely the
purchase and refinance of CRE, and on-balance sheet investments in CRE. This definition implies
that the property is used for commercial purposes, such as retail, hotels, office space, industrial,
or large multifamily rentals. In all cases, the building owner or investor leases the property to
tenants to conduct income-generating activities
Mortgages
This asset class includes on
-
balance sheet loans for specific consumer purposes namely the
purchase and refinance of residential property, including individual homes and multifamily
housing with a small number of units. This definition implies that the property is used only for
residential purposes and not to conduct income-generating activities
Motor
vehicles
This asset class refers to on
-
balance sheet loans and lines of credit for specific (corporate or
consumer) purposes to businesses and consumers that are used to finance one or several motor
vehicles. Corporate loans for acquisition of vehicles for trade purposes were classified as
‘Business Loans
8
The Group classified Project Finance under Business Loans asset class due to limited available data on use of proceeds to
classify them under Project Finance asset class. GHG emission estimation is not impacted by this classification, as the two asset
classes utilise the same PCAF proxies.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
148
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
Gross Scope 1, 2, 3 and Total GHG emissions (continued)
Scope 3 GHG emissions (continued)
The Group estimated the Financed Scope 3 GHG emissions for the above-mentioned asset classes. GHG emissions
associated with loan portfolio are metrics of transition risks that the portfolio is exposed. The Group, by taking
into account the GHG emissions estimated for loan portfolio, the most significant loan exposures and the
Materiality Assessment on C&E risks, it has decided to set a decarbonisation target on Mortgage portfolio in order
to be aligned with its Net Zero ambition and manage transition risk by directing its lending to more energy
efficient residential buildings.
Note: Refer to GHG emissions reporting principles in Additional Information – Sustainability Statement in page 247.
61,879
59,685
152,251
1,763,963
2,037,778
51,900
64,634
139,419
2,024,808
2,280,762
Motor Vehicles CRE Mortgages Business loans Total
Financed Scope 3 GHG emissions (tCO2e per year) - Loan Portfolio
2023 2024
DQS: 5
DQS:4.4
DQS:4.9
DQS:5
DQS: PCAF Data Quality Score
16%
8%
8%
15%
12%
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
149
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
Gross Scope 1, 2, 3 and Total GHG emissions (continued)
Scope 3 GHG emissions (continued)
Given that the majority of Financed Scope 3 GHG emissions of loan portfolio derive from Business Loan asset
class, the carbon concentrated sectors under Business Loan asset class have been identified and are considered
primary sectors for setting decarbonisation targets. The primary sectors identified under Business Loan asset
class are:
1. Transportation and storage (51%),
2. Wholesale and retail trade (19%),
3. Manufacturing (11%) and
4. Construction (6%).
BOC PCL – Financed Scope 3 GHG emissions – Business loan asset class
2023 2024
NACE Sector
OS Loan
Amount
(mn)
Emissions
(tCO
2
e per
year)
OS Loan
Amount
(mn)
Emissions
(tCO
2
e per
year)
H
TRANSPORTATION AND STORAGE
299
736,988
504
1,029,608
G
WHOLESALE AND RETAIL TRADE;
REPAIR OF MOTOR VEHICLES AND
MOTORCYCLES
745 377,354 764 385,555
C MANUFACTURING 331 256,115 279 225,123
F CONSTRUCTION 306 112,440 317 116,190
D
ELECTRICITY, GAS, STEAM AND
AIR CONDITIONING SUPPLY
86 85,758 97 84,408
A
AGRICULTURE, FORESTRY AND
FISHING
34 65,941 31 58,568
M
PROFESSIONAL, SCIENTIFIC AND
TECHNICAL ACTIVITIES
235 42,638 231 41,850
I
ACCOMMODATION AND FOOD
SERVICE ACTIVITIES
712 28,090 651 25,664
L REAL ESTATE ACTIVITIES 595 26,198 453 19,973
J
INFORMATION AND
COMMUNICATION
43 9,922 43 9,014
Q
HUMAN HEALTH AND SOCIAL
WORK ACTIVITIES
53 5,479 49 5,045
B MINING AND QUARRYING 8 4,144 8 4,003
N
ADMINISTRATIVE AND SUPPORT
SERVICE ACTIVITIES
22 3,794 38 8,331
K
FINANCIAL AND INSURANCE
ACTIVITIES
211 2,263 282 2,916
S OTHER SERVICE ACTIVITIES 16 2,038 19 2,476
R
ARTS, ENTERTAINMENT AND
RECREATION
15 1,816 13 1,642
P EDUCATION 40 1,501 36 1,364
E
WATER SUPPLY; SEWERAGE,
WASTE MANAGEMENT AND
REMEDIATION ACTIVITIES
4 1,484 18 3,078
Total
3,
755
1,763,963
3,833
2,024,808
Note: Refer to GHG emissions reporting principles in Additional Information – Sustainability Statement in page 247.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
150
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
Gross Scope 1, 2, 3 and Total GHG emissions (continued)
Scope 3 GHG emissions (continued)
The Group has estimated the Financed Scope 3 GHG emissions of Corporate and Sovereign bond investment
portfolio for 2023 and 2024 using the PCAF standard and proxies.
Note 1: BOCH has not estimated Financed Scope 3 GHG emissions of c.18% of Corporate and Sovereign bond portfolio due to lack of available
data mainly on Supranational Organisations which is allowed by PCAF methodology.
BOCH – Financed Scope 3 GHG emissions – Bond portfolio – 31 December 2024
Investment
Class
Total investment
amount (mn)
Total GHG
Emissions (tCO
2
e)
Emission intensity
(tCO
2
e/mn)
Weighted data
quality score
Corporate
Bonds
1,378 146,310 106 5
Sovereign
Bonds
1,982 368,452 186 2
Total 3,360 514,762
Note: As at 31 December 2024 BOCH has bond exposures to Supranational Organisations amount to 848mn of which 738mn are out of scope
for GHG emission estimation due to lack of publicly available information and relevant proxies. The Financed Scope 3 GHG emissions of bond
exposures to Supranational Organisations, with publicly available information, are estimated at 17,176 tCO2e. Refer to GHG emission estimation
principles in Additional Information – Sustainability Statement in page 247.
BOCH – Financed Scope 3 GHG emissions – Bond portfolio – 31 December 2023
Investment
Class
Total investment
amount (mn)
Total GHG
Emissions
(tCO
2
e)
Emission intensity
(tCO
2
e/mn)
Weighted data
quality score
Corporate
Bonds
1,276 62,678 49 5
Sovereign
Bonds
1,575 327,820 208 2
Total
2
,
851
390
,
498
Note: As at 31 December 2023 BOCH has bond exposures to Supranational Organisations amount to 696mn of which 600mn are out of scope
for emission estimation due to lack of publicly available information and relevant proxies. The Financed Scope 3 GHG emissions of bond exposures
to Supranational Organisations, with publicly available information, are estimated at 15,698 tCO2e. Refer to GHG emission estimation principles
in Additional Information – Sustainability Statement in page 247.
The increase in Financed Scope 3 GHG emissions for the Corporate and Sovereign bond portfolios reflects the rise
in investment exposure at each reporting date. To address this, BOCH has established sector limits on corporate
bond investments in carbon-intensive sectors to reduce the corporate portfolio's GHG emissions.
62,678
343,518
146,310
385,628
Corporate Bonds Sovereign Bonds
Financed Scope 3 GHG emissions (tCO2e/yr) - Bond portfolio
2023 2024
133%
12%
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
151
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
Gross Scope 1, 2, 3 and Total GHG emissions (continued)
Scope 3 GHG emissions (continued)
For the Sovereign bond portfolio, 56% of Financed Scope 3 GHG emissions are linked to exposure to Cyprus
Government bonds. As Cyprus accelerates its transition to a low-carbon economy, the associated emissions are
expected to decrease. Under the Effort Sharing Regulation, each EU Member State has targets to reduce GHG
emissions by 2030 in key sectors, covering nearly 60% of total domestic EU emissions. Cyprus aims to cut GHG
emissions in these sectors by 32% by 2030, contributing to the EU’s commitment to Net Zero by 2050.
BOCH's decarbonisation strategy for Sovereign exposure considers progress against EU targets and evaluates
GHG emissions per million euros invested and ESG scores for Government bonds. As of 31 December 2024,
countries like Saudi Arabia, USA and Canada and Bulgaria exhibit the highest emission intensity per million euros
invested. Notably, Bulgaria is Paris Agreement signatory, while Saudi Arabia and USA and Canada are not.
Sovereign Bond Portfolio
2024
Analysis by country
Country
Investment amount
(mn)
Financed Scope 3 GHG
emission (tCO
2
e)
Emission intensity
(tCO
2
e/mn)
Cyprus
1,023
205,000
200
France
125
14,899
119
Finland
108
16,924
15
7
Belgium
83
13,375
161
Luxembourg
80
8,786
110
Croatia
58
10,310
17
8
Spain
58
8,333
144
Poland
40
10,820
2
71
Austria
39
5,585
14
3
Ireland
38
4,160
109
Slovakia
37
7,645
20
7
Iceland
35
7,235
2
07
Chile
34
6,800
200
Israel
31
6,368
205
USA and
Canada
27
8,709
32
8
Italy
26
3,744
14
4
Hungary
21
3,822
1
82
Saudi Arabia
21
9,279
442
Sweden
21
1,560
7
4
Slovenia
18
3,169
17
6
Bulgaria
18
5,065
2
81
Germany
18
2,713
151
Peru
10
2,057
206
Lithuania
10
1,668
16
7
Netherlands
3
426
14
2
Total
1,98
2
368,45
2
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
152
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
Gross Scope 1, 2, 3 and Total GHG emissions (continued)
GHG Emission Inventory
Retrospective Milestones and target years
Emission Categories
Base
year
2023 2024
%
Change
(yoy)
2030 2050
Annual
%
target /
Base
year
Gross Scope 1 GHG
emissions (tCO2eq)
1,166 969 934 -3% -42% -20%
Percentage of Scope 1
GHG emissions from
regulated emission
trading schemes (%)
0% 0% 0%
Gross location-based
Scope 2 GHG emissions
(tCO2eq)
12,528 9,422 9,327 -1% -42% -26%
Gross market-based
Scope 2 GHG emissions
(tCO2eq)
Total Gross indirect
(Scope 3) GHG
emissions (tCO2eq)
2,512,729 2,883,374
Purchased goods and
services
50,298 47,608 -5%
Capital goods
Fuel and energy-related
Upstream transportation
and distribution
1,508 1,852 23%
Waste generated in
operations
3,202 3,263 2%
Business traveling 363 405 11%
Employee commuting 1,929 2,170 12%
Upstream leased assets
Downstream
transportation
Processing of sold
products
Use of sold products
End-of-life treatment of
sold products
Downstream leased
assets
Franchises
Investments 2,443,974 2,812,698 15%
of which lending portfolio 2,037,778 2,280,762 12%
of which investment
portfolio
406,196 531,937 31%
Insurance associated
GHG emissions
11,454 15,377 34%
Total GHG emissions
(location-based)
(tCO2eq)
2,523,120 2,893,635
Total GHG emissions
(market-based)
(tCO2eq)
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
153
ESRS E1 - Climate Change (continued)
7. Climate Change Metrics & Targets (continued)
Gross Scope 1, 2, 3 and Total GHG emissions (continued)
Scope 3 GHG emissions (continued)
GHG intensity per net revenue
2023
2024
% Change
Total GHG emissions (location
-
based) per net
revenue
(tCO2eq/Mn of Total operating Income)
2,288 2,641 15%
Total GHG emissions (market
-
based) per net revenue
(tCO2eq/Mn of Total operating Income)
Revenue reconciliation with Note 6 of the
Consolidated
Annual Financial Statements (
mn)
2023 2024
Net revenue used to calculate GHG intensity
Total
operating income
1,103 1,096
Total net revenue
Note 6
1,103
1,09
6
8. Increasing the Green Asset and Green Mortgage Ratios
EU Taxonomy Disclosures in accordance with Article 8 of the Taxonomy Regulation
The preparation of the EU Taxonomy reporting is based on prudential consolidation of the Group. The
consolidation is in accordance with the supervisory reporting of financial institutions as defined in Regulation (EU)
No 575/2013 of the European Parliament and of the Council, and the Commission Implementing Regulation (EU)
2021/451 (FINREP). The EU Taxonomy is a classification system of economic activities that make a substantial
contribution to environmental sustainability under Taxonomy Regulation (EU) 2020/852. In addition, the
preparation of reporting is based on the Delegated Act supplementing Article 8 of the Taxonomy Regulation
(Disclosures Delegated Act 2021/2178). Article 3 of the EU Taxonomy Regulation sets out the criteria that an
economic activity must meet to qualify as environmentally sustainable. This includes economic activity that is
carried out in compliance with the minimum safeguards and contributes substantially to one or more of the
environmental objectives.
The EU Taxonomy has six environmental objectives namely:
1. climate change mitigation (CCM);
2. climate change adaptation (CCA);
3. sustainable use and protection of water and marine resources (WTR);
4. transition to a circular economy (CE);
5. pollution prevention and control (PPC); and
6. protection and restoration of biodiversity and ecosystems (BIO).
Minimum Safeguards
As part of the assessment of environmentally sustainable economic activities, it is required that economic activity
is carried out in compliance with minimum safeguards as part of Article 18 of the EU Taxonomy Regulation. The
purpose of the minimum safeguards is to ensure compliance with minimum human and labour rights standards,
preventing activities that breach key social principles by aligning with the OECD Guidelines for Multinational
Enterprises and the UN Guiding Principles on Business and Human Rights, including the principles and rights set
out in the eight fundamental conventions identified in the Declaration of the International Labour Organisation
on Fundamental Principles and Rights at Work and the International Bill of Human Rights. As part of Taxonomy
reporting, compliance with minimum safeguards is a mandatory requirement for non-financial undertakings. In
alignment with this requirement, the Group integrates minimum safeguards assessments into the Taxonomy Key
Performance Indicators (KPIs) applied to its exposures.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
154
ESRS E1 - Climate Change (continued)
8. Increasing the Green Asset and Green Mortgage Ratios (continued)
Substantial contribution to the EU environmental objectives
Through its financing of large undertakings subject to the Non-Financial Reporting Directive (NFRD) and
investments in bonds and equities, the Group supports a variety of economic activities that contribute to the EU
environmental objectives. In addition, the Group’s sustainable finance products including green housing and
green motor loans contributes to the EU environmental objective of climate change mitigation. To classify such
sustainable products as Taxonomy-Aligned there are further criteria that must be adhered in addition to the
contribution to EU environmental objectives. The above-mentioned products are designed based on the GLPs of
LMA and are not structured as EU taxonomy aligned products. The Group intends to perform necessary action so
to be able to classify such products as EU taxonomy aligned.
Taxonomy KPIs
The Group is reporting on Taxonomy KPIs and GAR. The total GAR covers all six EU environmental objectives.
GAR is calculated as Taxonomy Aligned Assets as a % of Total Covered Assets. Total Covered Assets comprise of
total assets as defined under the prudential consolidation of the Group per FINREP, minus trading book assets
and minus exposures to central banks, central governments and supranational issuers (Total covered assets are
also referred to as total GAR assets). The GAR is calculated on two bases. One, referred to as the “Turnover
basis”, uses the % of each counterparty’s turnover that they report as taxonomy-eligible and taxonomy-aligned
to quantify how much of our loan exposure to that counterparty is taxonomy-aligned. The other, referred to as
the “CapEx basis”, uses the % of each counterparty’s CapEx that they report as taxonomy-eligible and taxonomy-
aligned to quantify how much of our loan exposure to that counterparty is taxonomy-aligned. The Group’s total
GAR based on turnover amounted to 0.6% of total covered assets, with the total GAR based on CapEx equivalent
to 0.3% of total covered assets as at year end 2024. The Taxonomy-aligned activities amounted to 91mn at
year end 2024. Gross carrying amount of total covered assets amounted to 15,774mn as at year end 2024.
Climate Delegated Act the Complementary Climate Delegated Act 2022/1214 including specific nuclear and gas
energy activities published in July 2022, requires the Group to assess and disclose taxonomy eligibility and non-
eligibility of nuclear and fossil gas-related activities at 31 December 2024. The Group has no direct exposure
through lending to customers that have economic activities related to the production of electricity or heating
using nuclear installations or electricity generation facilities that produce electricity from nuclear processes. The
Group also has exposure to customers involved in the operation of electricity generation facilities that produce
electricity using fossil gaseous fuels. See supplementary information in the section ‘Additional Information – EU
Taxonomy Disclosure Tables’ of Annual Financial Report under Annex XII of the Delegated Act in page 599.
EU taxonomy reporting principles
As companies' transparency in line with the EU Taxonomy increases, it will enable expanded reporting against
the Taxonomy. The adoption of CSRD and ESRS will support the further implementation of the EU Taxonomy
Regulation into our business strategy, systems, and investment and lending processes. Due to limitations in data
when assessing Taxonomy-eligible and Taxonomy-aligned activities for financial and non-financial undertakings,
actual published information provided by counterparties is utilised. However, a complete data collection has been
limited as published reporting on Taxonomy-alignment KPIs from financial and non-financial undertakings is not
yet available at the reporting date.
The EU Taxonomy disclosures have been prepared on a ‘best efforts’ basis using corporate disclosures and
published financial reports and information from our counterparty exposures (which primarily cover activity in
FY23 and not FY24). Our approach is to analyse and calculate taxonomy-eligibility and taxonomy- aligned based
on the published Taxonomy KPIs of our counterparties. The EU Taxonomy related disclosures presented in this
section have been made on the basis of our understanding of the terms and concepts used under the EU
Taxonomy Regulation and its implementing acts. As the EU Taxonomy reporting requirements and guidance
evolve over the coming years, and as we continue to develop our industry data sourcing methodologies, we will
continue to review our disclosure in future periods.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
155
ESRS E1 - Climate Change (continued)
8. Increasing the Green Asset and Green Mortgage Ratios (continued)
Summary of KPIs
The following table is a summary of KPIs to be disclosed by credit institutions under Article 8 of the EU Taxonomy Regulation. See supplementary information in section
‘Additional Information – EU Taxonomy Disclosure Tables’ in page 599 of the 2024 Annual Financial Report for additional EU Taxonomy tables reported under Annex VI
of the Disclosures Delegated Act and taxonomy aligned activities.
Limitations in data Reporting on Taxonomy-aligned activities for FY 2024 has been constrained due to current limitations on the availability of relevant information
across key categories:
i. When assessing Taxonomy-eligible and Taxonomy-aligned activities for financial and non-financial counterparties, actual information published by counterparties is required:
i. published reporting on Taxonomy-alignment KPIs from financial undertakings is not available at the reporting date for WTR, CE, PPC environmental objectives given financial
undertakings are required to report towards eligibility on these objectives for the first time in FY2024;
ii. non-financial undertakings have not yet published data for FY2024; consequently, the Taxonomy reporting of eligibility and alignment for non-financial undertakings is based
on published data from FY2023;
iii. furthermore, reporting on Taxonomy-eligibility for the four additional environmental objectives is implemented in 2024, limited to information of non-financial undertakings
that were required to report towards these objectives from FY2023; and
iv. exposure to non-financial counterparties in the Group’s corporate lending portfolio currently considered taxonomy eligible is limited due to the eligibility criteria requiring
counterparties to be large companies publicly listed in the EU.
ii. When assessing Taxonomy-eligible and Taxonomy-aligned activities for lending to households, other data limitations impact reporting:
i. Hybrid and Electric Vehicles lending exposures originated since the beginning of FY2024 are considered eligible per taxonomy criteria. However, they are not classified as
aligned due to the lack of available information in the industry to assess the vehicles against the Taxonomy DNSH (Do No Significant Harm) criteria.
9
Based on the Turnover KPI of the counterparty.
10
Based on the CapEx KPI of the counterparty.
11
Percentage of assets covered by the KPI over the total assets.
12
Trading book and Fees and Commissions KPIs only apply starting 2026.
Total
environmentally
sustainable
assets (mn)
KPI
turnover
9
%
KPI
CapEx
10
%
%
coverage
(over total
assets)
11
% of assets
excluded from the
numerator of the
GAR
% of assets excluded
from denominator of
the GAR
Main KPI
Green asset ratio (GAR)
stock
91 0.6% 0.3% 0.4% 27% 38%
Additional
KPIs
GAR (flow) 27 1.18% 0.8% 1% 33% 12%
Trading book
12
n/a
n/a n/a
Financial guarantees
-
0% 0%
Assets under management
-
0% 0%
Fee and commission income
11
n/a
n/a n/a
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
156
ESRS E2 – Pollution
This section outlines the Group’s approach in addressing pollution-related impacts. It highlights the policies and
actions in place to mitigate pollution associated with lending activities and support sustainable development.
1. Description of the processes to identify and assess material pollution-related impacts, risks and
opportunities
As outlined in detail in ESRS E1 – Climate Change in pages 122 - 130, BOCH has established a RIMA process for the
identification and assessment of C&E risks and utilises PRB Impact analysis tools to systematically identify, measure,
and assess C&E IROs, including pollution-related impacts, risks, and opportunities across its operations and value
chain.
Through a structured screening of site locations and business activities, the Group evaluates actual and potential
pollution IROs using both quantitative and qualitative methodologies. For the assessment of soil and air pollution as
credit risk drivers the Group utilized geolocation database for collaterals, using coordinates, and unsecured lending,
using postal codes. For Group’s site locations, given the quantitative assessment performed on collaterals and
unsecured lending, using expert judgement, the Group concluded that that pollution impacts and risks are low for
Group’s site locations. BOCH assesses the materiality of pollution across multiple financial risk categories, including
credit risk, market risk, liquidity risk and operational risk.
The Group applies geolocation-based risk scoring methodologies to assess physical pollution hazards, such as air
pollution, soil contamination, and seismic activity, across its secured lending portfolio, deposit base, and business
locations.
BOC PCL, as part of stakeholder engagement, incorporates insights from expert judgment and external datasets such
as Eurostat, the World Resource Institute, and Climate Analytics which also capture the views of affected
communities. Additionally, internal consultations were performed through the DMA conclusion process, where key
affected stakeholders' views on the Group’s material impacts on pollution were gathered. The Group has not consulted
directly with affected communities. Following the deployment of ESG due diligence process in loan origination process
in 2024, BOC PCL will be in a better position to engage with customers on the ESG spectrum, including pollution
related matters. For more details on the identification and assessment of pollution related impacts and opportunities
refer to 4. Impacts, Risks and Opportunities in page 103.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
157
ESRS E2 – Pollution (continued)
2. Material impacts, risks and opportunities and their interaction with strategy and business model
The Group has not identified material risks and opportunities for pollution, therefore no material current financial effects on financial position, financial
performance and cash flows are disclosed.
Material IROs - Pollution (E2)
ESRS Topic/Sub-Topic IRO Type Description
Pollution - Pollution of soil,
living organisms and food
resources
Impact Actual Negative
Financing activities to certain NACE sectors (i.e. Development of building projects,
other specialized wholesale, construction of residential and non-residential buildings)
with total portfolio exposure of 15.94% out of 5b exposures assessed under PRB
institutional banking impact analysis of 2024, create key/direct actual negative
impacts to composition of soil and its ability to deliver ecosystem services.
Time Horizons Value Chain
Originate or
connected to
strategy
Business
relationship
Short-Term Medium-Term Long-Term Own Operations Upstream Downstream
Connected to
strategy through
provision of finance
Customers
ESRS Topic/Sub-Topic IRO Type Description
Pollution - Pollution of air,
living organisms and food
resources
Impact Actual Negative
Financing activities in certain NACE sectors (i.e. sea and coastal freight transport,
electric power generation, and pharmaceutical manufacturing), with total portfolio
exposure of 11.11% out of 5b exposures, create key/direct actual negative impacts
to air quality.
Time Horizons Value Chain
Originate or
connected to
strategy
Business
relationship
Short-Term Medium-Term Long-Term Own Operations Upstream Downstream
Connected to
strategy through
provision of finance
Customers
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
158
ESRS E2 – Pollution (continued)
3. Policies, actions and resources related to pollution
BOCH’s material negative impacts on pollution stem from downstream value chain, through its loan portfolio.
Material pollution related impacts include air pollution, pollution of living organisms and food resources, and soil
pollution as shown in the table above.
As per the PRB impact analysis of 2024, BOC PCL provides financing to certain sectors that create negative impact
among others, to the air quality. As per the 2024 PRB institutional banking impact analysis, financing to key
sectors that amount to 11.11% of the portfolio under assessment (i.e. 49% of the Bank’s overall business activity
represented per business segment) and account for 560bn loans, create negative impacts to Air pollution.
Additionally, BOC PCL provides financing to certain sectors that as per PRB impact analysis of 2024, create
negative impacts among others, on the composition of soil and its ability to deliver ecosystem services. As per
the 2024 PRB institutional banking impact analysis, financing to key sectors that amount to 15.94% of the
portfolio under assessment (i.e. 49% of the Bank’s overall business activity represented per business segment)
and account for 804bn of loans, create negative impacts to the pollution of soil, by exposing it to pollutants and
factors that may interfere with soil stability for future land use.
Financing to key NACE sectors that create negative impacts on air (as per the 2024 PRB Impact
Analysis)
2023 2024
Sectors
Total %
to total
portfolio
OS Loan
Amount
(mn)
Total %
to total
portfolio
OS Loan
Amount
(mn)
E&S Policy
Score – Risk
Categorization
01.4 Animal production 0.50% 24 0.43% 22 Medium
10.8 Manufacture of other food
products
0.41% 20 0.52% 26 Medium
21.2 Manufacture of pharmaceutical
preparations
0.77% 38 0.83% 42 High
28.9 Manufacture of other special-
purpose machinery
0.21% 11 0.40% 20 Medium
35.1 Electric power generation,
transmission and distribution
1.15% 57 1.44% 72 High
49.3 Other passenger land transport 0.83% 41 0.74% 37 Medium
50.2 Sea and coastal freight water
transport
4.98% 245 6.76% 341 High
Total 8.86% 436 11.11% 560
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
159
ESRS E2 – Pollution (continued)
3. Policies, actions and resources related to pollution (continued)
BOCH’s policies, integrated into broader environmental and/or sustainability policies, are designed to address
considerations towards pollution. Aligned with the guidelines of the European Bank for Reconstruction and
Development (EBRD), Green Loan Principles, these policies establish a structured approach to identifying and
mitigating ESG impacts and risks. The Group recognises the interconnected nature of pollution, biodiversity, and
sustainability and integrates this perspective into its financing activities. Hence, it addresses pollution in key
areas, including air pollution, soil pollution, and pollution affecting living organisms and food resources, through
a combination of due diligence processes, and sustainable financing practices.
Environmental and Social (E&S) Policy
BOCH’s E&S Policy underpins its efforts to manage environmental and social risks associated with financing
activities, including minimisation of potential pollution impacts. For the abovementioned activities, financed by
the Group and lead to material negative impacts, that are classified as low risk by EBRD’s E&S Risk Categorization
assessment a written customer confirmation for proper business conduct, relevant licenses and work permits is
obtained. For activities that are classified as Medium / High risk by EBRD’s E&S Risk Categorization assessment
a written customer confirmation for proper business conduct, relevant licenses and work permits is obtained and
an E&S study by an external expert is performed. In addition, other E&S checks are performed, such as
investigations into penalties, public complaints, adverse media reports, accidents / incidents, legal actions, and
regulatory investigations as well as site visits. The findings of the above actions must be stated in the credit
application together with any corrective measures for the mitigation of the E&S risk. The approving authority
decides whether the E&S risk is acceptable and set specific terms and covenants to control any E&S risks as well
as decides the frequency of future E&S studies (at least every 3 years for High-Risk E&S ratings).
Financing to key NACE sectors that create negative impacts on soil (as per the 2024 PRB Impact
Analysis)
2023 2024
Sectors
Total % to
total portfolio
OS Loan
Amount
(mn)
Total % to
total
portfolio
OS Loan
Amount
(mn)
E&S Policy
Score – Risk
Categorization
01.4 Animal production 0.50% 24 0.43% 22 Medium
21.2 Manufacture of
pharmaceutical
preparations
0.77% 38 0.83% 42 High
35.1 Electric power
generation, transmission
and distribution
1.15% 57 1.44% 72 High
41.1 Development of
building projects
7.18% 354 6.18% 312 Low
41.2 Construction of
residential and non-
residential buildings
1.22% 60 1.35% 68 High
42.9 Construction of other
civil engineering projects
0.17% 8 0.68% 34
43.9 Other specialised
construction activities
0.51% 25 0.74% 38 Medium
46.6 Wholesale of other
machinery, equipment and
supplies
0.74% 36 0.72% 37 Low
46.7 Other specialised
wholesale
2.82% 139 2.82% 142 Medium - High
49.3 Other passenger land
transport
0.83% 41 0.74% 37 Medium
Total 15.89% 782 15.94% 804
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
160
ESRS E2 – Pollution (continued)
3. Policies, actions and resources related to pollution (continued)
Environmental and Social (E&S) Policy (continued)
For more details on the key content, general objectives, scope, monitoring arrangements, most senior level
accountable for the policy, any third-party standards, allocated resources other relevant information to
Environmental and Social (E&S) Policy refer to page 132.
Lending Policy
BOCH’s Lending Policy underpins its efforts to manage environmental and social risks associated with financing
activities, including minimization of potential pollution impacts. The Policy sets the standards and guidelines to
be used during the credit granting process. This guides individuals involved in the credit granting process on
credit granting standards and evaluation of credit risk, including ESG Due Diligence in the loan origination process
for legal entities and its interaction with credit risk.
During the credit application assessment process, that falls under specific thresholds / criteria, for granting new
and/or reviewing existing credit facilities, Business Units must identify, evaluate and assess ESG matters that are
relevant to the borrower by applying the ESG Due Diligence process. The first step of ESG Due Diligence embeds
an ESG questionnaire designed to assess customer’s performance and risk exposure against ESG factors
(applicable for new lending and customer’s annual review). The questionnaires must be completed by the
customer, in order to collect relevant quantitative and qualitative data, identify and assess ESG matters that are
relevant to the borrower and derive an ESG score which reflects the performance of the customer towards ESG
factors and exposure of customers towards ESG risks. The relevant ESG questionnaire includes queries designed
to assess the performance and risk exposure of the counterparty towards pollution, taking into account the
industry the counterparty operates. The question relates to whether the counterparty, in the context of production
process, releases polluting chemicals into the environment. The customers have the option to not provide
information under the ESG questionnaire, hence in such case their overall ESG performance is penalised and
reflected in the overall ESG score obtained.
Following completion of ESG questionnaire an ESG score is derived which in combination with scenario analysis
to assess customer’s repayment ability under certain negative transition risk scenarios derives to the aggregated
score for environmental aspect of ESG. The aggregated score is then used to derive the loan pricing. In line with
the Lending Pricing Policy, a margin discount, based on the client’s E aggregate score, is implemented for both
new and existing clients on new lending requests, for all clients (all sectors) under Corporate Division,
differentiating however between carbon-intensive vs. non-carbon intensive sectors. The Group linked the margin
discount at the client level to the borrower's “E” scoring (extracted from borrower’s ESG score). In addition, the
Group linked the margin discount at the transaction level (i.e. whether lending is Green or not) utilizing the
provisions of the Group's Green Lending Policy.
All customers operating in the abovementioned industries are eligible for ESG Due Diligence process subject to
meeting relevant thresholds. For more details on the key content, general objectives, scope, monitoring
arrangements, most senior level accountable for the policy, any third-party standards, allocated resources and
other relevant information to Lending Policy refer to page 133.
Green Lending Policy
The Group’s Green Lending Policy, which is based on GLP of LMA, promotes financing towards projects with
tangible environmental benefits, including those aimed at pollution mitigation. The policy establishes the criteria
to classify a loan as green, focusing on projects such as renewable energy, sustainable construction, and pollution
prevention and control including reduction of air emissions, soil remediation, waste prevention, waste reduction,
waste recycling and other. By providing green lending BOC PCL manages the material negative impacts associated
with pollution of air and soil.
Following the BES process on C&E risks, BOC PCL incorporates green new lending internal KPIs, in the Group’s
Financial Plan, to Business Lines in order to promote green lending practices and manage C&E risks. For
environmentally friendly gross loans refer to page 144.
For more details on the key content, general objectives, scope, monitoring arrangements, most senior level
accountable for the policy, any third-party standards, allocated resources and other relevant information to Green
Lending Policy refer to page 134.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
161
ESRS E2 – Pollution (continued)
3. Policies, actions and resources related to pollution (continued)
Concentration Risk Policy
The Concentration Policy applies at Group level and defines limits and the methodology for limit setting towards
exposures in specific assets, liabilities and off-balance sheet items to ensure that concentration risk is within the
Risk Appetite. The Concentration Risk Policy complements the efforts of managing negative impacts towards air
and soil pollution by restricting lending to carbon-intensive sectors, including oil, gas, manufacturing of cement,
manufacturing of Iron & Steel & Aluminium and non-renewable power generation. Financing in these sectors is
only permitted for transition or green projects that align with the Group’s sustainability objectives, subject to
approval by its highest credit committees.
For more details on the key content, general objectives, scope, monitoring arrangements, most senior level
accountable for the policy, any third-party standards, allocated resources and other relevant information to
Concentration Policy refer to section ESRS E1 in page 136.
Together, these policies and actions demonstrate the Group’s commitment to addressing pollution impacts and
risks through responsible financing practices. The above-mentioned policies do not include specific information
on pollutants or substances covered given that impacts derive from the value chain on the Group.
4. Metrics & Targets related to Pollution
While the policies and actions described above address air and soil pollutants downstream value chain negative
impact of the Group, no specific, measurable, time-bounded and outcome-oriented targets have been established
to directly prevent or control these impacts. This is due to the current lack of industry-wide data readiness, which
limits the ability to establish informed and measurable objectives.
Nevertheless, the Group intends to:
1. Examine, following the data gathered from ESG Due Diligence process, to establish and monitor pollution
related targets associated with loan portfolio by applying Science Based Target initiative’s guidance for
nature.
2. Set Green new lending KPIs, that will be embedded in the Group’s Financial Plan, associated with pollution
and sectors of the economy which we are currently associated with negative impacts to pollution of air,
soil and living organisms and food resources.
Given the fact that the Group has not yet set measurable outcome-oriented targets, it tracks the effectiveness of
actions to meet the objectives of the above-mentioned policies through the monitoring arrangements established
on each policy which are explained in detail in 6. Policies and Actions Related to Energy, Climate Change Mitigation
and Adaptation in page 132.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
162
ESRS E3 - Water and Marine Resources
This section outlines the Group’s approach in addressing water-related risks. It highlights the policies and actions
in place to manage water scarcity risks as drivers of credit risk associated with lending activities.
1. Description of the processes to identify and assess material pollution-related impacts, risks and
opportunities
BOCH acknowledges the essential role of water and marine resources in maintaining sustainable ecosystems,
supporting societal wellbeing, and driving economic development. The Group has assessed material water related
IROs using primarily qualitative methodologies and expert judgment. The Group determined that the material
water-related topics are primarily associated with its loan portfolio rather than its operating activities given the
nature of operations. Water scarcity, in particular, has been identified as a material risk.
Water scarcity was evaluated based on the Cyprus Government’s annual water balance reports and external tools
such as the Aqueduct Water Risk Atlas and Climate ADAPT initiative. The assessment recognised water scarcity
as a material risk due to Cyprus’ reliance on rainfall and desalination, with water stress exceeding 80% in current
and projected scenarios. Sectoral exposure was analysed, identifying potential financial implications, particularly
in energy, manufacturing, and agriculture.
In case of years with insufficient rainfall, there might be profitability issues in water-intensive sectors such as "D:
Energy", "C: Manufacturing" and Agriculture, where water is needed for instance for cooling, cleaning or
production purposes leading to increased credit risk. While the Bank's exposure to these sectors is limited,
important secondary effects might spread to other economic sectors. In a long-term time horizon, the water
scarcity issue might be exacerbated by an increase of anomalies in precipitation patterns, as also discussed in
the context of Drought risk as well as long-term desertification risk and rainfall trends. The tool Climate ADAPT
also labels Water Scarcity as a "significantly increasing" hazard in Cyprus with high impact and vulnerability, and
provides a dedicated section to Water Management as a key affected sector: "Cyprus is already facing intense
problems of water shortage and drought, which are expected to intensify as a result of climate change". Cyprus'
Government has been already implementing actions to reinforce Cyprus’ adaptive capacity to the decreasing
availability of freshwater resources. For the next decades, Climate ADAPT indicates that the estimated water
resources are expected to satisfy the future water demand from all sectors. However, the occurrence of severe
droughts and water scarcity events might induce overexploitation of water resources.
Overall, the assessment incorporated expert judgement, consultation reports, and statistical data from sources
such as Eurostat, the World Resource Institute, and Climate Analytics to enhance the accuracy of its evaluations
and capture the views of affected communities. Additionally, internal consultations were performed through the
DMA conclusion process, where key affected stakeholders' views on the Group’s material IROs on water and
marine resources were gathered. The Group has not consulted directly with affected communities. Following the
deployment of ESG due diligence process in loan origination process in 2024, BOC PCL will be in a better position
to engage with customers on the ESG spectrum, including water related matters. For more details on the
identification and assessment of water related impacts and opportunities refer to 4. Impacts, Risks and
Opportunities in page 103.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
163
ESRS E3 - Water and Marine Resources (continued)
2. Material impacts, risks and opportunities and their interaction with strategy and business model
Material IROs - Water and Marine Resources (E3)
ESRS Topic/Sub-Topic IRO Type Description
Water and marine resources - Water
Consumption, Water Use and Water
Withdrawals
Risk
Environmental -
Physical -
Chronic
Chronic Water Scarcity could gradually impact the evaluation and operations of
buildings, assets, internal operations of customers and counterparties (e.g. data centres
or buildings, pledged as collaterals with the Bank). As a result, the PD and LGD of
customers and counterparties might be increased, and hence, the corresponding
normative and economic capital of BOCH.
Time Horizons Value Chain
Financial Effects
Short-Term Medium-Term Long-Term Own Operations Upstream Downstream
No material current financial
effects were identified.
Anticipated financial effects
include increase in PD and LGD
of customers.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
164
ESRS E3 - Water and Marine Resources (continued)
3. Policies, actions and resources related to water and marine resources
Environmental and Social (E&S) Policy
BOCH’s E&S Policy provides the foundational framework for managing environmental and social risks, including
indirect considerations for water and marine resources. While the policy does not explicitly address water and
marine resources as standalone topics, it incorporates these considerations within its broader environmental
management system requirements.
Lending applications in Exclusion Sectors (e.g., thermal coal mining) are rejected and reported to RMD. For
activities classified as low-risk by EBRD’s E&S Risk Categorization assessment, a written confirmation of
compliance and permits are required. For medium/high-risk activities, a written customer confirmation for proper
business conduct, relevant licenses and work permits are obtained and an E&S study by external expert is
performed. In addition, other E&S checks are performed, such as investigations into penalties, public complaints,
adverse media reports, accidents / incidents, legal actions, and regulatory investigations as well as site visits.
The findings of the above actions must be stated in the credit application together with any corrective measures
for the mitigation of the E&S risk.
The approving authority decides whether the E&S risk is acceptable and set specific terms and covenants to
control any E&S risks as well as decides the frequency of future E&S studies (at least every 3 years for High-Risk
E&S ratings).
For more details on the key content, general objectives, scope, monitoring arrangements, most senior level
accountable for the policy, any third-party standards, allocated resources and other relevant information to
Environmental and Social (E&S) Policy refer to page 132.
Lending Policy
BOCH’s Lending Policy underpins its efforts to manage environmental and social risks associated with financing
activities, including minimization of water and marine resources risks. The Policy sets the standards and guidelines
to be used during the credit granting process. This guides individuals involved in the credit granting process on
credit granting standards and evaluation of credit risk, including ESG Due Diligence in the loan origination process
for legal entities and its interaction with credit risk.
During the credit application assessment process, that falls under specific thresholds / criteria, for granting new
and/or reviewing existing credit facilities, Business Units must identify, evaluate and assess ESG matters that are
relevant to the borrower by applying the ESG Due Diligence process. The first step of ESG Due Diligence embeds
an ESG questionnaire designed to assess customer’s performance and risk exposure against ESG factors
(applicable for new lending and customer’s annual review). The questionnaires must be completed by the
customer, in order to collect relevant quantitative and qualitative data, identify and assess ESG matters that are
relevant to the borrower and derive an ESG score which reflects the performance of the customer towards ESG
factors and exposure of customers towards ESG risks. The relevant ESG questionnaire includes queries designed
to assess the performance and risk exposure of the counterparty towards water and marine resources, taking
into account the industry the counterparty operates. The customers have the option to not provide information
during the ESG questionnaire, hence in such cases their overall ESG performance is penalised and reflected in
the overall ESG score obtained. The ESG questionnaire’s questions include the following:
1. Water consumption in cubic meters (m³);
2. Whether the customer's operations are located in areas classified as water-stressed;
3. Whether the customer adopted technologies for water reuse and recovery.
4. Whether the customer integrated advanced systems for processing and reusing water or sewage within
the production processes
Following completion of ESG questionnaire an ESG score is derived which in combination with scenario analysis
to assess customer’s repayment ability under certain negative transition risk scenarios, derives to the aggregated
score for environmental aspect of ESG. The aggregated score is then used to derive the loan pricing. In line with
the Lending Pricing Policy, a margin discount, based on the client’s E aggregate score, is implemented for both
new and existing clients on new lending requests, for all clients (all sectors) under Corporate Division,
differentiating however between carbon-intensive vs. non-carbon intensive sectors. The Group linked the margin
discount at the client level to the borrower's “E” scoring (extracted from borrower’s “ESG” score). In addition, the
Group linked the margin discount at the transaction level (i.e. whether lending is Green or not) utilizing the
provisions of the Group's Green Lending Policy.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
165
ESRS E3 - Water and Marine Resources (continued)
3. Policies, actions and resources related to water and marine resources (continued)
Lending Policy (continued)
For more details on the key content, general objectives, scope, monitoring arrangements, most senior level
accountable for the policy, any third-party standards, allocated resources and other relevant information to
Lending Policy refer to section ESRS E1 in page 133.
Green Lending Policy
The Group’s Green Lending Policy, which is based on GLP of LMA, promotes financing towards projects with
tangible environmental benefits, including those aimed at sustainable water-related initiatives. The policy
establishes the criteria to classify a loan as ‘green’, including projects associated with sustainable water and
wastewater management (including sustainable infrastructure for clean and/or drinking water, wastewater
treatment, sustainable urban drainage systems and river training and other forms of flooding mitigation). By
providing green lending BOC PCL manages the material risks associated with water and marine resources.
Following the BES process on C&E risks, BOC PCL incorporates green new lending internal KPIs, in the Group’s
Annual Financial Plan, to Business Lines in order to promote green lending practices and manage C&E risks. For
environmentally friendly gross loans refer to page 144.
For more details on the key content, general objectives, scope, monitoring arrangements, most senior level
accountable for the policy, any third-party standards, allocated resources and other relevant information to Green
Lending Policy refer to page 134.
Concentration Risk Policy
The Concentration Policy applies at Group level and defines limits and the methodology for limit setting towards
exposures in specific assets, liabilities and off-balance sheet items to ensure that concentration risk is within the
Risk Appetite. The Concentration Risk Policy complements the efforts of managing material risks identified on
water scarcity by restricting lending to carbon-intensive and water-intensive sectors, including oil, gas,
manufacturing of cement, manufacturing of Iron & Steel & Aluminium and non-renewable power generation.
Financing in these sectors is only permitted for transition or green projects that align with the Group’s
sustainability objectives, subject to approval by its highest credit committees.
For more details on the key content, general objectives, scope, monitoring arrangements, most senior level
accountable for the policy, any third-party standards, allocated resources and other relevant information to
Concentration Policy refer to page 136.
4. Metrics & Targets related to water and marine resources
The Group has not yet established specific targets for water management. European Central Bank’s (ECB)
expectations (Expectation 2.1, 2.2, 4.1 and 4.2) on C&E risks, as described in the ECB Guide, require the Bank
to set specific KPIs and KRIs for material C&E risks identified. Given the fact that water scarcity risk has been
identified as material in the long-term, the Bank is obligated by June 2025 to set measurable water scarcity
related KPI and KRI. The Group acknowledges this regulatory requirement and is in the process of aligning its
strategies and frameworks to address this in future reporting, with a target to be set by 30 June 2025.
Given the fact that the Group has not yet set measurable outcome-oriented targets, it tracks the effectiveness of
actions to meet the objectives of the above-mentioned policies through the monitoring arrangements established
on each policy which are explained in detail in page 132.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
166
ESRS E5 – Resource Use and Circular Economy
This section outlines the Group’s approach to addressing resource use and circular economy related impacts. It
highlights the policies, actions and targets in place to increase circularity associated with lending activities and
support sustainable development.
1. Description of the processes to identify and assess material resource use and circular economy-
related impacts, risks and opportunities
BOCH has conducted a screening of its assets and activities to identify actual and potential impacts, risks, and
opportunities across its operations and value chain for resource use and the circular economy. The assessment
was performed using UNEP FI tools (loan & investment portfolio impact assessment) to evaluate material negative
impacts on resource intensity topics and the RIMA framework for risk identification as described in page 122.
Key areas examined include:
1. Circular Economy & Waste Management and Environmental Protection Requirements: Cyprus' low circular
material usage rate (Eurostat) and national waste management and environmental protection initiatives
were analyzed. Potential additional costs for businesses in key sectors (Accommodation & Food Services,
Wholesale & Retail Trade, Construction, Manufacturing) were considered, but no material risk was
identified.
2. Environmentally Friendly Technologies: The impact of regulatory and market-driven technological
upgrades (e.g., water-efficiency, circular economy solutions) was assessed, particularly for Real Estate,
Transport & Storage, and Manufacturing. While potential short-term financial distress was noted, no
material risk was identified.
3. Environmentally Driven Consumer Behaviour: The market sentiment in Cyprus towards sustainable
products remains at an early stage (PwC Cyprus CEO Survey 2023), leading to an overall low risk impact.
The Bank will monitor future developments through its Business Environment Scan process on C&E risks.
BOCH conducted qualitative consultations based on expert judgment, utilising external sources such as
consultation reports, scientific publications, and Cyprus-specific data from Eurostat, World Resource Institute,
Climate Analytics, and Climate Vulnerability Monitor. Additionally, internal consultations were performed through
the DMA conclusion process, where key affected stakeholders' views on the Group’s material impact on resource
use and the circular economy were gathered. The Group has not consulted directly with affected communities.
Following the deployment of ESG due diligence process in loan origination process in 2024, BOC PCL will be in a
better position to engage with customers on the ESG spectrum, including resource use and circularity matters.
For more details on the identification and assessment of resource use and identification of impacts and
opportunities refer to 4. Impacts, Risks and Opportunities in page 103.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
167
ESRS E5 – Resource Use and Circular Economy (continued)
2. Material impacts, risks and opportunities and their interaction with strategy and business model
Material IROs - Resource Use and Circular Economy (E5)
ESRS Topic/Sub-Topic IRO Type Description
Resource Use and Circular
economy - Resources inflows,
including resource use and
resource outflows related to
products and services
Impact Actual Negative
Financing activities to certain NACE sectors (i.e. Rental and operating of own or leased
real estate, development of building projects, buying and selling of own real estate) with
total portfolio exposure of 40.58% out of 5b exposures assessed under PRB institutional
banking impact analysis of 2024, create key/direct actual negative impacts to the efficient
use of limited, non-renewable and renewable natural resources.
Time Horizons Value Chain
Originate or
connected to
strategy
Business
relationship
Short-Term Medium-Term Long-Term Own Operations Upstream Downstream
Connected to
strategy through
provision of finance
Customers
The Group has not identified material risks and opportunities for resource use and circular economy, therefore no material current financial effects on financial
position, financial performance and cash flows are disclosed.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
168
ESRS E5 – Resource Use and Circular Economy (continued)
3. Policies, actions and resources related to resource use and circular economy
BOCH’s negative impacts to circular economy derive from the downstream value chain as those associated with
loan portfolio. As part of its business activity, the Group provides financing to key certain sectors that as per PRB
impact analysis of 2024, create negative impacts among others, on the efficient use of limited, non-renewable
and renewable natural sources. In detail, as per the 2024 PRB institutional banking analysis, financing to sectors
that amount to 40.58% of the portfolio under assessment (i.e. 49% of the Bank’s overall business activity
represented per business segment) and account for 2,046mn of loans, create negative impacts to resource use
and circular economy. Refer to the table below for the Group’s exposure to certain sectors (Exposure >1%)
associated with negative impacts on resource use and circular economy.
The policies adopted to manage the material negative impacts on resource use and circular economy are:
Environmental and Social (E&S) Policy
BOCH’s Environmental and Social (E&S) Policy underpins the efforts to manage environmental and social risks
associated with financing activities, including minimisation of potential resource use and circular economy
impacts.
For the abovementioned activities, financed by the Group and lead to material negative impacts, that are classified
as low risk by EBRD’s E&S Risk Categorization assessment a written customer confirmation for proper business
conduct, relevant licenses and work permits is obtained. For activities that are classified as Medium / High risk
by EBRD’s E&S Risk Categorization assessment a written customer confirmation for proper business conduct,
relevant licenses and work permits must be obtained and an E&S study by external expert should be performed.
In addition, other E&S checks should be performed, such as investigations into penalties, public complaints,
adverse media reports, accidents / incidents and regulatory investigations as well as site visits. The findings of
the above actions are stated in the credit application together with any corrective measures for the mitigation of
the E&S risk.
The approving authority decides whether the E&S risk is acceptable and set specific terms and covenants to
control any E&S risks as well as decides the frequency of future E&S studies (at least every 3 years for High-Risk
E&S ratings).
For more details on the key content, general objectives, scope, monitoring arrangements, most senior level
accountable for the policy, any third-party standards, allocated resources and other relevant information to
Environmental and Social (E&S) Policy refer to page 132.
Financing to key NACE sectors with an exposure of >1% that create negative impacts on resource
use and circular economy (as per the 2024 PRB Impact Analysis)
2023 2024
Sectors
Total %
to total
portfolio
OS Loan
Amount
(mn)
Total %
to total
portfolio
OS Loan
Amount
(mn)
E&S Policy
Score – Risk
Categorization
35.1 Electric power generation,
transmission and distribution
1.15% 57 1.44% 72 High
41.1 Development of
building
projects
7.18% 354 6.18% 312 Low
41.2 Construction of residential
and non-residential buildings
1.22% 60 1.35% 68 High
50.2 Sea and coastal freight water
transport
4.98% 245 6.76% 341 High
68.1 Buying and selling of own
real estate
4.05% 200 4.14% 209 Low
68.2 Rental and operating of own
or leased real estate
15.48% 763 13.04 658 Medium
68.3 Real estate activities on a fee
or contract basis
1.14% 56 0.52% 26 Medium
Total
35.20%
1,735
33.44%
1,686
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
169
ESRS E5 – Resource Use and Circular Economy (continued)
3. Policies, actions and resources related to resource use and circular economy (continued)
Lending Policy
BOCH’s Lending Policy underpins its efforts to manage environmental and social risks associated with financing
activities, including minimization of potential resource use and circularity impacts. The Policy sets the standards
and guidelines to be used during the credit granting process. This guides individuals involved in the credit granting
process on credit granting standards and evaluation of credit risk, including ESG Due Diligence in the loan
origination process for legal entities and its interaction with credit risk.
During the credit application assessment process, that falls under specific thresholds / criteria, for granting new
and/or reviewing existing credit facilities, Business Units must identify, evaluate and assess ESG matters that are
relevant to the borrower by applying the ESG Due Diligence process. The first step of ESG Due Diligence embeds
an ESG questionnaire designed to assess customer’s performance and risk exposure against ESG factors
(applicable for new lending and customer’s annual review). The questionnaires must be completed by the
customer, in order to collect relevant quantitative and qualitative data, identify and assess ESG matters that are
relevant to the borrower and derive an ESG score which reflects the performance of the customer towards ESG
factors and exposure of customers towards ESG risks. The relevant ESG questionnaire includes queries designed
to assess the performance and risk exposure of the counterparty towards resource use and circularity, taking into
account the industry the counterparty operates. The questions are the following:
1. Whether the counterparty promotes separation of waste in its facilities.
2. Description of nature and weight (kg/tonnes) of the main raw materials used in production.
3. Indication of the percentage of recycled and reused raw material that are used in production over total
raw materials used.
4. Description of main materials/products and relevant weight (kg/tonnes), associated with counterparty’s
production process.
5. Indication of percentage of company’s products that can be considered recycled / reused.
6. Indicate the total amount of waste produced in the latest financial year.
Following completion of ESG questionnaire an ESG score is derived which in combination with scenario analysis
to assess customer’s repayment ability under certain negative Environmental scenarios derives to the aggregated
score for environmental aspect of ESG. The aggregated score is then used to derive the loan pricing. In line with
the Lending Pricing Policy, a margin discount, based on the client’s E aggregate score, is implemented for both
new and existing clients on new lending requests, for all clients (all sectors) under Corporate Division,
differentiating however between carbon-intensive vs. non-carbon intensive sectors. The Group linked the margin
discount at the client level to the borrower's “E” scoring (extracted from borrower’s “ESG” score). In addition, the
Group linked the margin discount at the transaction level (i.e. whether lending is Green or not) utilizing the
provisions of the Group's Green Lending Policy.
All customers operating in the abovementioned industries are eligible for ESG Due Diligence process subject to
meeting relevant thresholds. For more details on the key content, general objectives, scope, monitoring
arrangements, most senior level accountable for the policy, any third-party standards, allocated resources and
other relevant information to Lending Policy refer to page 133.
Green Lending Policy
The Group’s Green Lending Policy, which is based on Green Loan Principles (‘GLP’) of Loan Market Association
(‘LMA’), actively promotes financing towards projects with tangible environmental benefits, including those aimed
at improving resource use and circular economy. The policy establishes the criteria to classify a loan as ‘green’,
focusing, among others, on projects such circular economy adapted products, production technologies and
processes (such as the design and introduction of reusable, recyclable and refurbished materials, components
and products; circular tools and services; and/or certified eco-efficient products) as well as renewable energy. By
providing Green lending the Group effectively manages the material negative impacts associated with resource
use and circular economy.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
170
ESRS E5 – Resource Use and Circular Economy (continued)
3. Policies, actions and resources related to resource use and circular economy (continued)
Green Lending Policy (continued)
Following the Business Environment Scan process on C&E risks, BOC PCL incorporates Green new lending internal
KPIs to Business Lines in the Group’s Financial Plan in order to promote Green lending practices and manage C&E
risks. For the environmentally friendly gross loans associated with the above-mentioned KPIs refer to page 144.
For more details on the key content, general objectives, scope, monitoring arrangements, most senior level
accountable for the policy, any third-party standards, allocated resources and other relevant information to Green
Lending Policy refer to page 134.
The Cyprus market’s demand for financing Green projects is focused on energy efficiency and renewable energy
projects at the moment. The Bank’s exposure to renewable energy projects (solar and wind parks) is disclosed
in the following graph. Reduction of c.20% has been observed in Gross loans to renewable energy projects due
to increased repayments in 2024 compared to new renewable energy projects financed in 2024.
Concentration Risk Policy
The Concentration Policy applies at Group level and defines limits and the methodology for limit setting towards
exposures in specific assets, liabilities and off-balance sheet items to ensure that concentration risk is within the
Risk Appetite. The Concentration Risk Policy aims to manage negative impacts towards resource use and circular
economy by restricting lending to resource intensive sectors, including oil, gas, manufacturing of cement,
manufacturing of Iron & Steel & Aluminium and non-renewable power generation. Financing in these sectors is
only permitted for transition or green projects that align with the Group’s sustainability objectives, subject to
approval by its highest credit committees.
For more details on the key content, general objectives, scope, monitoring arrangements, most senior level
accountable for the policy, any third-party standards, allocated resources and other relevant information to
Concentration Policy refer to section ESRS E1 in page 136.
4. Metrics & Targets related to resource use and circular economy
While the policies and actions described above address resource use and circular economy downstream value
chain negative impact of the Group, no specific, outcome-oriented targets have been established to directly
prevent or control these impacts. This is due to the current lack of industry-wide data readiness, which limits the
ability to establish informed and measurable objectives.
Nevertheless, the Group intends to:
1. Examine, following the data gathered from ESG Due Diligence process, to establish and monitor resource
use and circular economy targets associated with loan portfolio by applying Science Based Target
initiative’s guidance for nature.
2. Set Green new lending KPIs, that will be embedded in the Group’s Financial Plan, associated with resource
use and circular economy and sectors of the economy which we are currently associated with negative
impacts to resource use and circular economy.
Given the fact that the Group has not yet set measurable outcome-oriented targets, it tracks the effectiveness of
actions to meet the objectives of the above-mentioned policies through the monitoring arrangements established
on each policy which are explained in detail in page 132.
25,1
20
Renewable energy projects
Renewable energy - Gross Loans (mn)
Dec 23 Dec 24
20%
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
171
ESRS S1 - Own Workforce
BOCH’s employees are crucial to the Group’s operations, culture and success. Group’s employees are all part of
the business, which is governed by the Group’s strategy and business model and may be exposed to identified
impacts, risks and opportunities. This applies to employees of BOCH, as well as those who perform assignments
on behalf of the Group as self-employed or employees of third-party service providers or seconded staff. As an
employer, BOCH has a great responsibility to use policies, procedures and processes to manage impacts, risks
and opportunities and to continue to take these into account in the overall strategy. To continue to be a successful
Group and promote long-term sustainable growth, it is important that BOCH has committed and motivated
employees. The Group’s employees are paid an adequate wage compared to Cyprus average wage.
1. Interests and views of stakeholders
The Group integrates own workforce interests, views, and rights into its strategy and business model through
engagement and governance mechanisms. Employee feedback from surveys, performance appraisals, complaints
and whistleblowing channels directly inform decisions on workforce policies, training programs, wellbeing
initiatives and system of internal controls. The Executive Director of People & Change and Trade Union’s
representatives ensure workforce concerns are embedded in leadership’s decision-making process. Workforce-
related matters are factored into strategic planning, embedding areas such as talent retention, diversity,
remuneration, learning & development and workplace safety.
2. Material impacts, risks and opportunities and their interaction with strategy and business model
The following categories of employees and non-employees within the organisation have been identified as subject
to material impacts from the Group’s operations:
1. Normal salaried employees Individuals directly employed by the Group under permanent full-time
contracts (employees).
2. Part-time employees Individuals directly employed by the Group under part-time contracts
(employees).
3. Fixed-term employees – Individuals directly employed by the Group on a temporary basis under a fixed-
term contract (employees).
4. Interns Individuals engaged for internships, either directly employed or provided through educational
or third-party programs (employees or third-party personnel).
5. External associates Professionals engaged under contractual agreements, classified as self-employed
or provided through third-party service providers (self-employed or third-party personnel).
The Group as described in ESRS E1 - Climate Change, has not yet established a comprehensive transition plan.
However, based on the existing decarbonisation actions to reach GHG emission reduction target on own
operations and achieve Net Zero ambition by 2050, no material impacts on the company’s own workforce were
identified. The decarbonization strategy on own operations does not involve branch closures. Branch
rationalisation conducted during 2023 and 2024 was part of the digitalization agenda of the Group and any
affected staff resulting from branch rationalisation were redeployed within the Group.
The risk of forced labour, compulsory labour, or child labour is not relevant for the Group. The Group's vision,
mission and values as well as strategy and business model do not ignite significant risks associated with forced
or child labour. The Group does not operate in countries or geographic areas considered high-risk for forced or
child labour, given the fact that the majority of the operations are in Cyprus.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
172
ESRS S1 - Own Workforce (continued)
3. Commitment to Human Rights
Respect for human rights is integrated into the Group’s operational policies and procedures. The Group’s Code of
Ethics and Code of Conduct outline defined standards for behaviour, responsibilities, and ethical practices
applicable to all employees. These frameworks are supported by reporting mechanisms and investigation
procedures to address issues and ensure equitable treatment. BOCH engages its workforce through channels
designed to promote accountability and inclusion, as detailed below, supporting a culture aligned with these
principles.
The Group’s approach to Human rights is based on internationally recognised frameworks, including the
International Bill of Human Rights and international directives, principles and initiatives to protect human rights,
such as the Core Labour Conventions of the International Labour Organisation (ILO). The Group adheres to the
ILO Declaration on Fundamental Principles and Rights at Work, integrating its principles into various aspects of
operations. For instance, the Group’s collective agreement and relationship with the trade union address the first
principle of the Declaration. Fair and inclusive hiring practices ensure compliance with the second and third
principles, while health and safety measures, supported by the “Well at Work” wellbeing programme and Health
& Safety Management system, reflect the fifth principle. Group’s policies and practices are aligned with ILO
Declaration on Fundamental Principles and Rights at Work so by monitoring adherence to such policies and
practises also align with ILO. Additionally, the OECD Guidelines for Multinational Enterprises are encompassed
within the Group’s Code of Conduct, Code of Ethics, and Employee Handbook. These frameworks establish clear
expectations for ethical behaviour and corporate responsibility. Violations are addressed through the Group’s
formal disciplinary process.
BOCH’s existing policies and processes, including the Recruitment Policy, Code of Ethics, and Code of Conduct,
already address concerns related to human trafficking, forced labour, and child labour, ensuring responsible
management. However, to enhance clarity and explicitly reinforce these commitments, the Group will update its
policies and processes by the end of 2025.
BOCH maintains a zero-tolerance policy toward discrimination of any kind. This includes, but is not limited to,
discrimination based on race, ethnicity, colour, sex, sexual orientation, gender identity, disability, age, religion,
political opinion, national origin, social background, or any other grounds. Similarly, harassment in any form—
whether verbal, physical, visual, sexual, or bullying—is strictly prohibited. In addition, decisions related to
recruitment, promotion, and remuneration are based solely on objective criteria such as ability, ethics, and
experience. The Group through the Code of Conduct and Anti-Sexual Harassment Code of Practice set clear
standards for employee behaviour and responsibilities against any form of discrimination. No human rights
violations, such as forced labour or discrimination, were reported during the period.
The Group promotes integrity, as a core organisational value, through the implementation of the Disciplinary
code. This framework ensures timely detection and mitigation of any violations related to the Code of Conduct,
Code of Ethics, Anti-Sexual Harassment Code, internal policies, employment terms, circulars and any other
decisions of the Group associated with own workforce. To address significant breaches, the Group has established
the Disciplinary Committee. Misconduct, breaches or violations can be reported through various channels:
1. Whistleblowing channel (Refer to page 217);
2. Planned or unplanned internal audits;
3. Complaints;
4. Other means (Direct communication to Branch Manager, Manager, Director or through Internet
Banking).
The internal Audit Division investigates the violation and submits a report to the Executive Director People &
Change who oversees the process. If the investigation confirms a violation, the report is escalated to the
Disciplinary Committee. For breaches relating to the Code of Conduct or Code of Ethics (or any other matter
associated with HR) the matter is investigated by the relevant HR department and the relevant report is submitted
as described above. A Senior Management committee decides whether the matter requires escalation to the
Disciplinary Committee, which is responsible for determining appropriate disciplinary actions.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
173
ESRS S1 - Own Workforce (continued)
3. Commitment to Human Rights (continued)
Incidents, complaints and severe human rights impacts
In FY2024, zero incidents of discrimination, including harassment, were reported.
Separately, a total of 12 matters were reported through the Group's channels for its workforce to raise concerns.
Matters reported / complaints filed relate to employee grievances or allegations made under the either complaints
or Whistleblowing process. These can relate to various issues including working conditions and other work-related
matters. Numbers quoted reflect all such incidents and complaints reported whether upheld or not. In FY24, the
Group faced no fines, penalties or compensation for damages as a result of these incidents and complaints.
In FY2024, the Group has not had any severe human rights incidents connected to the Group, in relation to cases
of non- respect of the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental
Principles and Rights at Work or OECD Guidelines for Multinational Enterprises. The Group faced no fines, penalties
or compensation as a result of severe human rights incidents. Severe human rights incidents are defined as cases
of modern slavery, human trafficking or child labour.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
174
ESRS S1 - Own Workforce (continued)
4. Processes for engaging with own workforce and workers’ representatives about impacts
Own workforce engagement occurs at planning, decision-making, implementation, and evaluation stages to ensure a comprehensive approach that integrates employee
input throughout the process. Engagement occurs directly with employees, as well as through structured interactions with workers' representatives, where relevant.
The following table summarises the general processes for engaging with people in its own workforce and worker’s representatives about actual and potential positive
and/or negative impacts.
Engagement
Description
Direct
Engagement/Worke
r representative
Stages of the
engagement
Type of
engagement
Frequency
Operational
responsibility of
the engagement
Effectiveness of the
Engagement
Divisional/Regional
Meetings with all
staff
Direct
1. Identification
2. Determine
the approach
for mitigation
1. Participation
2. Consultation
1. Annually for
strategy
2. 6-monthly for
other
communications
1. Divisional
Directors
1.
Determination of key
priorities and establishment
of strategic initiatives
aligned with the set
priorities
2. Divisional Strategy
approved by Divisional
Director
3. Divisional Strategy is
reflected in Group’s
Financial Plan submitted for
approval to the EXCO and
the Board.
4. Financial Plan is monitored
by EXCO and the Board.
Employee Opinion
Surveys
1.
Identification
3. Evaluating
effectiveness
of mitigation
1. Consultation
1. Annual
2. Human
Resources –
Executive
Director of People
& Change
1.
Determination of key
priorities
2. Establishment of an action
plan with initiatives
designed to meet these
priorities
3. Quarterly monitor the
action plan by EXCO and
HRRC
Focus Groups
4. Determine
the approach
for mitigation
1. Participation
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
175
ESRS S1 - Own Workforce (continued)
4. Processes for engaging with own workforce and workers’ representatives about impacts (continued)
Engagement
Description
Direct
Engagement/Worker
representative
Stages of the
engagement
Type of
engagement
Frequency
Operational
responsibility of
the engagement
Effectiveness of the
Engagement
Kill-Bureaucracy
program (email/
Yammer)
13
Direct
1. Identification
2. Determine
the approach
for mitigation
5. Evaluating
effectiveness
of mitigation
1. Participation
2. Consultation
1. Ongoing
1. Human
Resources –
Executive
Director of
People & Change
1.
Determination of key
priorities
2. Establishment of an action
plan with initiatives
designed to meet these
priorities
3. Quarterly monitor the
action plan by EXCO and
HRRC
The steps BOCH takes to gain insight into its workforce perspectives are inclusive of all employees, including those who may be particularly vulnerable or marginalised.
While current engagement processes do not explicitly differentiate between employee groups, those ensure that diverse voices are considered in shaping workplace
policies and decisions. BOCH is a member of the European Banking Federation (EBF). This membership provides a platform for the Group to engage in industry-wide
discussions, share best practices, and gain deeper insights into the perspectives of its own workforce, particularly regarding human rights and labour standards. EBF
facilitates regular dialogue with workers’ representatives and contributes to shaping policies that respect and promote the rights of employees across the banking
sector.
13
Kill-Bureaucracy program: Internal program that employees can provide their recommendations through email / yammer / internal portal and those are evaluated for implementation.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
176
ESRS S1 - Own Workforce (continued)
5. Processes to remediate negative impacts and channels for own workforce to raise concerns
The Group provides employees with a formal mechanism to raise concerns or complaints as outlined in the Code
of Conduct, which is accessible through the Internal Employee Portal. Employees may submit formal complaints
in writing, which are addressed through the Group’s Complaints Resolution Process. This process is designed to
manage and resolve employee grievances effectively, aiming to eliminate any form of discrimination or unequal
treatment. Complaints are addressed hierarchically, with escalation to the Personal Complaints Committee, if
necessary. The Committee consists of at least three members, one of whom is selected by Trade Union among
Group staff to represent the employees, and one member is appointed by Group’s Management. Following
consultation with the two members, the Group appoints a suitable individual to act as Committee Chair.
Employees can submit complaints in writing to their direct superior. Where the complaint is such that it pertains
to, or affects, the direct superior or supervisors, the complaint is submitted to the immediately higher superior in
the hierarchy. In exceptional circumstances, and provided this can be justified, the employee may submit their
complaint directly to the Personal Complaints Committee. Upon receiving a complaint, the recipient must provide
a written response to the employee within 15 days. If no response is provided, within the designated timeframe,
or if the employee concerned is not satisfied with the response, the complaint is submitted to the Personal
Complaints Committee. Complaints submitted to the Committee must be in writing and accompanied by all
relevant data and documentation. These submissions are routed through the Committee member appointed by
Trade Union or their alternate representative.
The Human Resources Division is responsible for the preparation of the case file, which is delivered to all
Committee members. Committee sessions are convened by the Chair whenever there are matters to be discussed.
The list of matters to be discussed during the session is submitted to the Committee Chair at least four days prior
to the day of the session. Committee members are entitled to request that the Committee examines both the
employee concerned as well as any other staff member they believe may assist in reviewing the complaint. The
request is submitted to the Committee Chair, who is responsible for issuing the necessary summons. Additionally,
Committee members are entitled to request the submission of any evidence which might assist in reviewing the
case. The minutes of sessions are kept by the Committee secretary, who shall be appointed by the Committee
and is a Group staff member. Copies of the minutes are distributed to all Committee members after the session
and are formally ratified during the subsequent session. The complaints review procedure must be concluded at
the latest within one month of the date of submission of the complaint to the Committee.
The Committee’s findings, which are solely advisory in nature, are forwarded by the Committee Chair to the
relevant Divisional Director and to the complainant.
The effectiveness of Complaints Resolution Process is measured on a case-by-case basis. Follow-up discussions
are conducted between the employee and the HR Business Partner (HRBP) to assess whether the grievance has
been resolved. In addition, the HRBPs through ad-hoc communication with employees (one to one meetings
performed throughout the year) explore the overall working conditions and employee relations. In order to gain
employee’s trust on these channels the Group provides information through Internal portal on how it deals with
complaints and information on the governance and monitoring arrangements of handling any complaint.
The departments responsible for managing workforce complaints and related processes are subject to a risk
assessment and audits relevant to these areas are included in the Internal Audit’s Internal Audit Plan.
In addition to the above, BOCH has established a Whistleblowing Policy, offering accessible, confidential channels
for employees and external stakeholders to report violations, unethical behaviour, or improper practices. For
more details on the Whistleblowing system refer to page 217.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
177
ESRS S1 - Own Workforce (continued)
6. Data Protection & Privacy
Material IROs
-
Own Workforce (S1)
ESRS Topic/Sub
-
Topic
IRO Type Description
Own Workforce - Other
work-related rights -
Privacy
Impact
Potential -
Negative
Given the number of Group's employees there is a potential negative impact to own workforce arising
from personal data leakage.
Time Horizons Value Chain
Originate from /
Connected to
Group’s strategy
and business
models
Widespread
or Systemic
/ Individual
Incidents
Inform and
contribute to
adapting the
undertaking’s
strategy and
business model
Short-Term Medium-Term Long-Term
Own
Operations
Upstream Downstream
Connected to
business Model
Individual
Incidents
Refer to
6
.
Data
Protection & Privacy
Section
ESRS Topic/Sub
-
Topic
IRO Type Description
Own Workforce
-
Other
work-related rights -
Privacy
Risk
Regulatory
Compliance /
Conduct Risk
Non-compliance with Data Protection Law (GDPR) leading to data leakage to employee personal data.
Time Horizons
Value Chain
Financial Effects
Short-Term Medium-Term Long-Term
Own
Operations
Upstream Downstream
Anticipated financial effects include i
ncreased costs due to
penalties arising from Commissioner for Personal Data
Protection (CPDP) and possible litigation costs. No litigation or
penalties arising due to personal data leakage in 2024.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
178
ESRS S1 - Own Workforce (continued)
6. Data Protection & Privacy (continued)
Material IROs
-
Own Workforce (S1)
ESRS Topic/Sub-Topic IRO Type Description
Own Workforce - Other work-
related rights - Privacy
Risk
Information
Security
(Including
Cyber) Risk
Cyber-attacks targeting the Group through Internet using a variety of techniques may
lead to loss or theft of data (including employee data), execution of fraudulent payments
and IT disruption.
Time Horizons Value Chain
Financial Effects
Short-Term Medium-Term Long-Term Own Operations Upstream Downstream
No material current financial effects
associated with cyber-attacks.
Anticipated financial effects include
reputational issues, identity theft,
fraud and regulatory penalties, fines,
increased cost to due inefficiencies and
loss of business.
The Group’s material risks on Data Protection and Privacy have not arisen from any negative impacts or dependencies on own workforce. Group’s own workforce is
exposed to similar types of privacy impacts and risks. It is important to note that employees who operate in departments which have access to personal data and
sensitive data are inherently exposed to greater Data Protection & Data Privacy risks. Information security and data privacy trainings are conducted annually to all staff.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
179
ESRS S1 - Own Workforce (continued)
6. Data Protection & Privacy (continued)
6.1 Policies on Data Protection & Privacy
BOCH prioritises the protection of data and personal data in its operations. The Group has implemented measures
to mitigate the negative impact on privacy as well as the identified risks associated with cyber-attacks and data
breaches, reflecting its compliance with applicable data protection regulations and its commitment to the secure
handling of employee information.
The Group maintains a Personal Data Protection Compliance Policy, to align with relevant regulations, including
the EU General Data Protection Regulation (GDPR) and national laws such as the Protection of Natural Persons
regarding the Processing of Personal Data Law 125(1)/2018 and section 106 of the ‘Regulation of Electronic
Communications and Postal Services Law 112(I)/2014’, as well as the relevant guidelines issued by the CPDP
from time to time. This policy outlines the Group’s commitment in protecting the personal data of customers,
employees, suppliers, and business partners, ensuring that data collection, use, and retention are lawful,
transparent, and aligned with GDPR principles. Protecting the security and privacy of personal data is important
to the Group, in order to conduct its business activities in the context of the envisaged privacy culture. The Board
and Senior Management are responsible to oversee the Group`s compliance with this policy. Additionally, they
have the ultimate responsibility for the implementation and adherence to this policy throughout the Group, and
the imposition of any remedial action. BOCH and its subsidiaries must, as a minimum meet the requirements of
this policy. The policy is applicable for all subsidiaries of the Group as they are considered separate data
controllers. The management of each subsidiary is ultimately responsible for the implementation of this policy
and to ensure, at entity level, that there are adequate and effective procedures in place for its implementation
and ongoing monitoring to its adherence. The policy is readily available to all employees through internal portal
and to any affected stakeholder through Group’s website.
The Group also complies with the ISO 27001 Information Security Standard. The Group’s Information Security
Policy further outlines a structured incident management approach, ensuring that all information and cyber-
security risks associated with the Group’s systems and assets are handled in a timely and consistent manner.
More information on the policy is described in ESRS S4 – Consumers and end-users in page 195.
6.2 Actions on material impacts approach to managing material risks on Data Protection and
Privacy
The Group complies with GDPR requirements, ensuring transparency and accountability in employee data
processing activities. The Employee Privacy Notice, which was last updated in March 2024, outlines how employee
data is collected, processed, and protected. This notice is readily accessible on the Group’s internal portal,
ensuring employees are informed of their data privacy rights at all times.
The Group collects and processes personal data strictly as necessary for its business activities, in accordance with
legal obligations, contractual requirements, legitimate interests, or with employee consent. Data collection is
limited to relevant and essential information, with retention periods aligned to guidelines provided by the Local
CPDP. To ensure lawful processing, employees are informed of their right to withdraw consent at any time, and
specific consent is appropriately secured and documented when required.
Employees can raise concerns about how employee data are collected, processed or protected by emailing a
dedicated Human Resources address for GDPR matters or contacting the CPDP, as described in the Employee
privacy notice.
In the event of suspected or actual data breaches, employees are required to report such incidents to the Data
Protection Officer (DPO), within a maximum timeframe of 24 hours. The reporting can be done through designated
communication channels, including email or phone and after completing a form (form for reporting a possible
personal data breach). In case where the data breach incident affects a large volume (combination between data
subjects affected and systems affected or could be affected) of customers/employees, the Information Security
Department is notified, and the Security Incident Response Plan procedures are initiated. The Group has
established an incident response plan that includes containment, investigation and notification procedures in the
event of data breach. The plan is annually tested and updated to ensure effectiveness and compliance with
applicable laws and regulations. To facilitate effective reporting of data breaches, the Group has established a
guidance that serves as a reference for all employees and is embedded in the Employee Portal. This guidance
outlines the criteria and procedures for identifying and reporting reportable data breaches, empowering
employees to promptly and accurately report any incidents.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
180
ESRS S1 - Own Workforce (continued)
6. Data Protection & Privacy
6.2 Actions on material impacts approach to managing material risks on Data Protection and Privacy
(continued)
BOCH has faced privacy-related challenges, including a data breach in 2023 due to human error, where inaccurate
addresses were used to mail loan sale notification letters. The breach was identified through internal reporting
mechanisms and assessed by the DPO within 72 hours, as required by GDPR. Remedial actions were immediately
implemented, including strengthening internal controls, while the breach was reported to the CPDP, resulting in
a fine of 8,000. The Group did not have any fine relating to breach of the Regulation 2016/679 in 2024.
In addition, the Group employs Data Protection Impact Assessments (DPIAs) at all stages of data processing and
follows a data minimisation strategy. DPIAs support the identification of potential data privacy risks and comply
with data protection obligations and meet individuals’ expectations on privacy. The DPIA is initiated whenever a
new process/ product or system that involves personal data is implemented and it shall be revisited/updated
when there is a change in the risk profile of the process (e.g. new vendor, change of the procedure etc.). All
procedures relating to DPIA are analysed in the relevant circular which is readily available in the Internal Employee
Portal.
Internal circulars and manuals are annually reviewed and updated to ensure adherence from own workforce. The
Group’s DPO oversees GDPR compliance, provides guidance on data protection policies, and ensures effective
handling of data breaches and privacy complaints as part of the complaints handling procedure. The DPO advises
the Group on GDPR obligations, monitors compliance, oversees DPIAs, consults on high-risk processing, and
liaises with supervisory authorities. The DPO also ensures the resolution of data breaches and privacy complaints,
coordinating with other Group DPOs to address compliance issues. The Chief Information Officer (CIO) works
closely with the DPO to address and mitigate data security incidents. This collaborative approach reflects the
Group’s commitment to maintaining a high standard of data privacy and security, protecting employees’ personal
data, and adhering to all regulatory requirements.
The Group tracks the effectiveness of its privacy actions through quarterly monitoring report submitted by the
DPO to the Board through AC. Metrics such as the number of reported incidents, participation rates in training
programs, and vendor compliance evaluations enhance processes. The incident response plan undergoes annual
testing to ensure readiness, while privacy statements and data-handling procedures are reviewed annually to
maintain compliance with the regulations.
Internal Audit includes Personal Data Protection Compliance Policy as part of its Risk & Audit Universe and
assesses the need for audit engagements during the annual audit planning process.
BOCH invests in privacy management through cybersecurity tools, dedicated DPOs for each legal entity handling
personal data, and cross-departmental collaboration across Legal, IT, HR, Internal Audit, Compliance,
Procurement, Vendor Management and Risk Management. This approach aims to mitigate risks, enhance privacy
practices, and maintain stakeholder trust.
6.3 Metrics and Targets to manage negative impacts and material risks
There is no set measurable, time-bound and outcome-oriented target associated with data protection and privacy
however, the Group nevertheless tracks the effectiveness of these actions through quarterly reporting to EXCO
and AC. Metrics reported include the number of data incidents, employee participation in privacy and information
security training programs. Board, Management and all staff participate, in 2024, in Information security training
(9,889 training hours), GDPR training (107 hours) and use of personal data training (1,207.5 hours).
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
181
ESRS S1 - Own Workforce (continued)
6. Data Protection & Privacy (continued)
6.3 Metrics and Targets to manage negative impacts and material risks (continued)
Metrics associated with information security and GDPR training hours as well as personal data leakage reported
to the CPDP, are not validated by an external body.
In line with its Risk Appetite Statement (RAS), the Group has adopted the following qualitative stances associated
with data privacy and information security:
1. Zero Tolerance for Privacy Risks: BOCH maintains a strict no-tolerance policy for any non-compliance with
GDPR and expects full adherence to legal and regulatory requirements across all operations.
2. No Data Leakage: The Group has zero tolerance to data leakage, whether due to system vulnerabilities or
employee mishandling. Rigorous protocols are in place to prevent and respond to potential breaches.
3. Vendor Compliance: BOCH does not engage with vendors who lack robust GDPR-aligned procedures and
practices. All third-party relationships are subject to assessments to ensure compliance with data protection
standards.
4. Immediate Response to Data Subject Rights: The Bank has a zero-tolerance approach to delays or avoidance
in responding to data subject rights under GDPR. Processes are streamlined to ensure timely action on data
access, correction, or deletion requests.
The process for setting the above-mentioned qualitative metrics is described in the Risk Appetite Framework of
the Group. The objective of the Risk Appetite Framework (RAF) is to set out the level of risk that the Group is
willing to accept in pursuit of its strategic objectives, outlying the key principles and rules that govern the risk
appetite setting. It comprises the Risk Appetite Statement (RAS), the associated policies and limits where
appropriate, as well as the roles and responsibilities for the implementation and monitoring of the RAF.
6
13
FY2023 FY2024
Personal data leakage reported to the Commissioner for Personal Data
Protection
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
182
ESRS S1 - Own Workforce (continued)
7. Health and Safety
Material IROs - Own Workforce (S1)
ESRS Topic/Sub-Topic IRO Type Description
Own Workforce - Working
Conditions - Health & Safety
Risk
Health & Safety
risks
Poor health and safety practices can result in workplace accidents, incurring costs for
increased insurance premiums, legal defences, compensation payouts, and potential
regulatory fines for non-compliance. Operational disruptions stemming from such incidents
can diminish productivity and revenue, further straining financial performance.
Time Horizons Value Chain
Financial Effects
Short-Term Medium-Term Long-Term Own Operations Upstream Downstream
No material current financial effects
associated with work related injuries and
accidents. Anticipated financial effects
include reputational issues, increased
costs due to litigations and compensation.
The Group’s material risks on Health & Safety have not arisen from any negative impacts or dependencies on own workforce. Group’s entire own workforce is exposed
to similar types of Health & Safety risks given the office nature of operations, this is also evident from Health & Safety trainings conducted to all staff.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
183
ESRS S1 - Own Workforce (continued)
7. Health and Safety (continued)
7.1 Health and Safety Policies (H&S)
The Group implements systems and policies to mitigate H&S risks associated with its own workforce. These
measures support operational efficiency and align with the Group’s commitment to maintaining a safe and
accountable workplace.
Health & Safety Policy
The Group’s H&S policy supports a safe and healthy environment for its employees, customers, visitors, suppliers,
external associates and other third parties. The policy emphasises risk prevention, legal compliance, and
continuous improvement. It includes regular risk assessments, workplace inspections, corrective actions, and
oversight by Safety Committees.
The policy was updated in 2023 and is readily available through Internal Employee Portal. The policy was reviewed
in 2024 and no changes were deemed necessary. The Organisational Procedure on H&S and the H&S internal
manual, outlines the responsibilities of line management, employees, and departments. These resources foster
collaboration and accountability in maintaining safety standards.
Executive Management has the ultimate responsibility to ensure compliance with the H&S regulatory framework,
its relevant provisions and adherence to H&S policy.
Health and Safety Management System (HSMS)
The HSMS, complies with the Safety and Health at Work Laws of 1996 to 2020 in Cyprus. This system defines
roles and responsibilities for management, employees, and technical teams to identify and address hazards across
all operations. It incorporates tailored measures for each facility, including emergency response plans, risk
assessments, training protocols, and detailed record-keeping.
In 2023, the HSMS underwent an external audit by a H&S consultant (approved by the Department of Labour
Inspection – member in EXYPP registry). The findings identified, were assessed and an action plan was prepared
to address them. External audit confirmed the system’s compliance and effectiveness. Senior Management
ensures consistent application of HSMS protocols, promoting accountability and standardisation across all offices.
The system applies to all employees and extends to outsourced workers and associates whose work is under the
Group’s control.
Employees under HSMS
Unit
202
3
202
4
Percentage of people in its own workforce who are
covered by the undertaking’s health and safety
management system based on legal requirements and/or
recognised standards or guidelines
# 2,673 2,726
% 94.45% 94.65%
Notes:
i. The percentage of own workforce who is covered by the BOCH’s HSMS is calculated on a head count basis at the end
of the reporting date.
ii. Employees of JCC Payment Systems Ltd, Unoplan and representative offices abroad are not covered by BOCH’s HSMS.
iii. The above-mentioned metric has not been validated by an external body.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
184
ESRS S1 - Own Workforce (continued)
7. Health and Safety (continued)
7.2 Actions to manage material risks on Health and Safety
H&S Committees
The Group promotes H&S at work and takes measures to prevent any occupation hazards and inform and share
knowledge to its workforce on H&S issues. The Group has approximately 51 H&S Committees that meet every
six months and, on an ad-hoc basis when requested by a member or in response to an incident. The Group’s
employees are represented in committees by staff from all the units of the buildings. As per the regulatory
framework, a committee must exist at all premises with more than 10 employees and its composition depends
on the number of employees stationed at the premises. The presidents of H&S Committees are the manager of
the branch or the Technical Project Coordinator of the building. Buildings with less employees have a responsible
person for the H&S issues which is the manager. The Committees are responsible to identify workplace hazards,
prevent / assess risks of accidents and resolve issues at the premises in cooperation with other departments (e.g.
Technical Services).
Incident Investigation
Employees play an active role in the HSMS by identifying hazards in their work environment. They are trained to
report these hazards via the Group’s dedicated application, or directly to the Safety Committee of their respective
building or H&S Officer. This ensures timely response and resolution of any identified issues.
The investigation of H&S incidents and work-related accidents are managed by the H&S Officer in collaboration
with the Manager of the respective branch or unit. The procedure includes:
1. A detailed analysis of the cause,
2. A description of the incident provided by the affected employee and witnesses,
3. A site inspection, and
4. The implementation of corrective actions to minimise future risks.
Any investigation of an incident/accident is documented in the relevant form, by the H&S officer and delivered to
the Manager of the Branch or Unit, Head of Claims of General Insurance and Human resources. The H&S officer,
within 15 working days from the accident, reports through dedicated forms the Department of Labour Inspection
of Cyprus Government.
Following the incident investigation, a form detailing corrective measures and actions is delivered by the H&S
officer to the Manager of Branch or Unit associated with the incident. The measures and actions are implemented
by Technical Services Department of the Group. The Implementation of corrective measures is monitored by the
Manager of the Branch or Unit associated with the incident and the Chairman of H&S Committee. Written
confirmation of the completion of these actions is provided to all involved parties.
Emergency Response and Preparedness
The Group premises have emergency evacuation plans. Annual evacuation drills are conducted across branches
and buildings, under the supervision of the Corporate Security Manager for all employees. These drills involve
fire prevention and evacuation training for assigned employees, with outcomes reviewed to implement any
necessary improvements.
The H&S Officer, as mandated by law, oversees the coordination and effectiveness of these procedures within the
broader HSMS. This ensures that emergency response measures are both comprehensive and compliant with
legal and operational standards, supporting the Group’s commitment to a safe and secure working environment.
H&S Inspections
Inspections are conducted across the Group’s branches and buildings to identify and mitigate H&S risks to
maintain a healthy environment for own workforce and any other party.
Inspections are conducted by:
1. An H&S officer on an annual basis (random inspection and ad-hoc following incidents or complaints)
2. An H&S representative of the property every three months
3. The Chairman of H&S Committee on a six-month basis
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
185
ESRS S1 - Own Workforce (continued)
7. Health and Safety (continued)
7.2 Actions to manage material risks on Health and Safety (continued)
Inspections are conducted to:
1. Identify issues and weaknesses that should be remediated;
2. Assess issues and weaknesses identified;
3. Document an action plan to remediate the issues and weaknesses identified.
The Technical Services department or any other relevant department should be informed about the action plan
and the relevant timelines for implementation. The measures to remediate the issues and weaknesses identified
are monitored by the H&S Officers and Chairman of the H&S Committee. When the measures are implemented
the H&S Officer and Chairman of the H&S Committee are properly informed, and subsequently re-assess whether
the remedial actions implemented have resolved the issues and weaknesses identified.
H&S risk assessment studies
Additionally, the Group conducts H&S risk assessments in partnership with external H&S consultants (EXYPP).
These assessments, performed every two years, prioritise high and medium risks through detailed action plans.
Hazards such as slips and falls are addressed proactively by measures like floor inspections, placement of anti-
slip tapes, and safety signage.
Work-related injuries
The work-related injuries reported by the Group relate to slip and fall type injuries, none of which resulted in
high-consequence injuries. A procedure has been implemented by the Group in order to provide an analysis of
the cause, description of the incident by the affected employee and the people involved, along with the site
inspection and decisions taken to minimise the identified incident. Such incidents are addressed on a case-by-
case basis, and the actions taken by the Group include floor inspection, placement of anti-slip tapes and safety
signs wherever considered necessary. The chart below illustrates Group’s employees only, as no work-related
injuries occurred for workers who are not employees but whose work is controlled by the Group.
Notes:
i. The rate of recordable work-related injuries has been calculated as follows:
(Total number of recordable work-related injuries) / (Total number of hours worked) x 1,000,000.
ii. The number of hours worked was compiled using estimation. The total number of hours (2024: 4,646,016 2023:
4,670,066) is estimated based on total number of employees at each year end multiplied by 52 weeks/year multiplied
by 5 working days/week and excludes average leave days per employee and public holidays.
iii. Recordable work-related injuries exclude JCC Payment Systems Ltd, Unoplan and representative offices abroad as
those establishments are not covered by BOCH’s Health and Safety Management System.
iv. The above-mentioned metrics have not been validated by an external body.
2
3
0.43
0.65
1
2 0 2 3 2 0 2 4
R e c o r d a b l e w o r k - r e l at e d i n j u r i e s - E m p l o y ee s
Number of recordable work-related injuries Rate of recordable work-related injuries
Days lost to work-related injuries
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
186
ESRS S1 - Own Workforce (continued)
7. Health and Safety (continued)
7.2 Actions to manage material risks on Health and Safety (continued)
No fatalities existed as a result of work-related injuries or high consequence work-related injuries to either
employees and non-employees, nor any work-related ill health occurred in any of the years reported either to
employees and non-employees. The Group’s responsibility for H&S extends beyond its employees to outsourced
workers, visitors, customers, and suppliers. Vendors are required to comply with BOCH’s H&S standards, including
risk assessments and certifications for equipment like lifting machinery. These assessments are reviewed
biannually, with corrective actions implemented as necessary to minimise risks.
Key action taken in 2024 in adherence to Group’s H&S policy and in management H&S risks:
1. Monitor implementation of remedial actions identified from H&S risk assessments
2. H&S training
3. Buildings evacuation drills
4. Air quality measurements for Head Office and IT buildings
5. Electromagnetic and Magnetic Field Measurements at IT building
6. Microbiological analysis of water quality from drinking dispensers
7. Disinfection of water tanks at owned buildings and installation of filtration system.
Key action
s
planned
2025
2026
2027
1.
H&S
r
isk
a
ssessment on:
1. Job positions
2. Installation of special
equipment
3. Safe evacuation of
vulnerable people
4. Branches and buildings (re-
assessment)
2. Estimation harmful factors (air
quality) 3 buildings and 3
branches
3. Monitor implementation of
remedial actions identified from
H&S risk assessments
4. Support in drafting new
procedure manuals and update of
existing procedure manual
associated with H&S
5. Trainings to Protection &
Prevention Internal Service and
H&S representatives
6. Diagnostic assessment towards
fire safety, analysis of the results
and drafting of a report of
deviations and remedial actions -
(Head office)
1.
Confirmation of Group’s
adherence to regulatory
requirement through external
audit and preparation of
relevant report.
2. Diagnostic assessment towards
fire safety, analysis of the
results and drafting of a report
of deviations and remedial
actions – 1 Building per district
for 2026.
3. Support and guide an internal
process to inform own
workforce on H&S
4. H&S risk assessment on
management of new working
conditions like hybrid working
environment. Policies and
procedures drafted, approved
and adhered at Group level.
5. Trainings to Protection &
Prevention Internal Service and
H&S representatives
6. Coordination and monitoring of
action plan on the outcome of
H&S Risk Assessment for
period 2025-2026.
1.
H&S
r
isk
a
ssessment on
Branches and buildings (re-
assessment and assessment on
new buildings)
2. Coordination and monitoring of
action plan on the outcome of
H&S risk assessment for period
2025-2026.
3. Trainings to Protection &
Prevention Internal Service and
H&S representatives.
4. Support and guidance in an
internal staff awareness
campaign.
5. Diagnostic assessment towards
fire safety, analysis of the
results and drafting of a report
of deviations and remedial
actions – 1 Building per district
for 2027.
6. Diagnostic assessment of H&S
culture using e-survey.
The actions taken and planned for the future are all associated, derived and aligned with the Group H&S Policy
aiming on a safe and healthy environment for employees, customers, visitors, suppliers, external associates and
other third parties. In addition, the above-mentioned actions did not and will not require significant operating
expenditure and capital expenditure. The Group’s resources associated with H&S extend beyond H&S department,
certain roles and responsibilities (First aids, Security, Fire prevention) are assigned to employees of each Branch
and Building as well as members of the H&S committees.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
187
ESRS S1 - Own Workforce (continued)
7. Health and Safety (continued)
7.3 Metrics & Targets related to managing material risks on Health and Safety
There are no measurable, time-bound, outcome-oriented targets associated with H&S risks, however the Group
nevertheless tracks the effectiveness of these actions through qualitative Key Risk Indicators and monitoring
mechanisms designed to mitigate potential hazards and ensure a safe working environment. Current qualitative
statements include:
1. Managing H&S risks:
1. Reducing the number of occupational accidents, illnesses, and injuries through preventive measures and
improved systems.
2. Monitoring and reducing the number of untrained first aiders across premises to ensure preparedness in
emergencies.
3. Addressing high- and medium-risk findings from risk assessments through corrective actions within
defined timelines.
4. Conducting regular audits and inspections of the HSMS to ensure compliance with regulatory
requirements and industry standards.
2. Compliance statements:
1. Maintaining full compliance with the H&S regulatory framework, ensuring all policies and practices align
with legal obligations.
2. Incorporating new regulations into the H&S Management System as they are issued, with annual reviews
to ensure alignment.
The process of setting the above-mentioned qualitative indicators is described in the Risk Appetite Framework of
the Group. The objective of the Risk Appetite Framework (RAF) is to set out the level of risk that the Group is
willing to accept in pursuit of its strategic objectives, outlying the key principles and rules that govern the risk
appetite setting. It comprises the Risk Appetite Statement (RAS), the associated policies and limits where
appropriate, as well as the roles and responsibilities for the implementation and monitoring of the RAF.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
188
ESRS S1 - Own Workforce (continued)
8. Own workforce characteristics
Characteristics of Groups own workforce
Gender
Number of employees (head count)
14
2024
2023
Male
1
,
187
1
,
177
Female
1
,
69
3
1
,
653
Other
-
-
Not reported
-
-
Total Employees
2
,
880
2
,
830
Number of employees (head count)
Female
Male
Other
Not Disclosed
Total
2024
2023
2024
2023
2024
2023
2024
2023
2024
2023
Total e
mployees
1
,
693
1
,
653
1
,
187
1
,
177
-
-
-
-
2
,
880
2
,
830
Permanent employees
1
,
667
1
,
637
1
,
176
1
,
168
-
-
-
-
2
,
843
2
,
805
Temporary employees
19
9
10
8
-
-
-
-
29
17
Non
-
guaranteed hours
7
7
1
1
-
-
-
-
8
8
New employee hires and turnover
Total
2024
2023
Number of new employee hires
105
124
Number of employees turnover
81
211
Number of intragroup employee transfers
26
28
Rate of employee turnover
0
.
03
0
.
07
Notes:
i. The number of employees (headcount) refers to the total number of people employed by the Group at the end of each reporting period.
ii. The data has been collected based on the detailed payroll registers as of 31/12 for every fiscal year, in headcount. If data about a specific legal subsidiary of the Group was not
available in the systems, the legal entity representative was requested to provide the data.
iii. 99.7% of the employees relate to BOCH’s own workforce in Cyprus (2023: 99.6%).
iv. Staff turnover has been calculated as the aggregated number of employees who left voluntary or due to dismissal, retirement or death / Total head count of employees at each
year end.
Temporary staff consist of staff employed to undertake specific projects within the Group or are employed on a temporary basis at Real Estate Management Unit (REMU).
14
As disclosed in Note 14 of the 2024 Annual Financial Statements on page 443.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
189
ESRS S1 - Own Workforce (continued)
9. Own workforce related metrics
Collective Bargaining
The freedoms to associate and to bargain collectively are fundamental rights and require a conducive and enabling environment. At BOCH we recognise the right to
collective bargaining as the key to the representation of collective interests.
2024
#
%
Employees covered by collective bargaining agreements
2,76
6
96%
Notes:
i. The % of employees covered by collective bargaining agreements is calculated using the number of employees covered by collective bargaining agreements on a head count basis as at 31 December 2024 / Total head count of
employees as at 31 December 2024*100.
ii. Employees not covered by collective bargaining agreement primarily relates to fixed term contract employees. Temporary employees are entitled to Provident Fund benefit under the collective agreement with Trade Union. They are
eligible to all other benefits included on the collective agreements with full -time employees (including Medical Fund and Life Insurance, in case of death or permanent total disability - once permanency is confirmed).
2024
Collective Bargaining Coverage
Social Dialogue
Employees – EEA Employees – Non-EEA
Workplace representation (EEA only)
0-19% - -
-
20-39% - -
-
40-59% - -
-
60-79% - -
-
80-100% Cyprus -
Cyprus
The Group has collective bargaining agreements in place within the European Economic Area (EEA). The Group does not have representation agreements with any
European Works Council (EWC), Societas Europaea (SE) Works Council, or Societas Cooperativa Europaea (SCE) Works Council in place.
Gender Pay Gap
The Gender Pay Gap (GPG) is the difference in the hourly pay of men and women across the organisation. The Group’s gender pay gap (excluding LTIP 2024) is
calculated at 12.6%. The Group’s gender pay gap (including LTIP 2024) is calculated at 15.1%. The primary reason for the GPG is the larger number of females in
lower level roles, and higher numbers of males in more senior roles. The highest paid individual in our organisation is our CEO. The median annual total compensation
for all employees (excluding the CEO) for 2024 was 54,603 and, the ratio of the annual total compensation of our CEO to the median annual total compensation of all
employees (excluding the CEO) was 15:1 (excluding LTIP 2024) and 31:1 (including LTIP 2024). The Group prepared for the first time a gender pay gap analysis in line
with the EBA guidelines which will be monitored through an annual internal benchmarking study, aiming to identify the reasons for any such gap and find ways to
address it via our remuneration practices and policies.
Notes:
i. For the calculation of GPG the Group utilizes all cash emoluments paid, in 2024, to all employees including base salary, bonus and benefits in kind. STIP bonus included in the calculation relates to the
amount paid in 2024 for FY2023, given the STIP 2023 and STIP 2024 are comparable amounts.
ii. The GPG and the ratio of the annual total compensation of our CEO to the median annual total compensation of all employees has been calculated based on 98% of employee
headcount as at 31 December 2024.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
190
ESRS S4 - Consumers and End Users
Consumers and end-users include individuals and legal entities who purchase or use our financial products and services. BOCH offers customers a wide range of financial
products and services, which might affect our customers in several ways. Additionally, how the Group interacts with its customers might also affect and pose risks to
us as a financial institution.
1. Interests and views of stakeholders
Consumers and end-users are central to the Group’s decision-making, as outlined in BOCH’s Code of Conduct and the Ethics Code. Stakeholder engagement mechanisms,
including complaint channels, surveys, focus groups and direct customer interactions, enable the Group to integrate customer feedback into strategic decision making.
Customer complaint statistics are analysed and reported quarterly to the AC and the Central Bank of Cyprus (CBC), and their satisfactory resolution is monitored on an
ongoing basis. The Group also evaluates its broader impact on consumers and end-users as part of its sustainability and risk management strategy. It provides several
engagement channels where customers can communicate concerns and suggestions, which are an input into strategic decision making. To ensure business resilience
and adaptability, the Group remains responsive to operational disruptions, by accelerating digital banking solutions to meet evolving consumer needs.
2. Material impacts, risks and opportunities and their interaction with strategy and business model
As a result of the DMA, the Group identified three material actual and potential positive impacts and one negative impact. The types of consumers and end-users subject
to a material impact include retail customers, business customers, digital and online customers, marginalised customers and customers in vulnerable circumstances.
These can be divided into the below categories:
Category of consumer and / or end
-
user
Group applicability
Consumers and / or end
-
users of services that potentially negatively impact their rights to privacy,
to have their
personal data protected, to freedom of expression and to non-discrimination.
All types of Group consumers and end
-
users.
Consumers and / or end
-
users who are dependent on accurate and accessible product
-
or service
-
related information,
to avoid potentially damaging use of a product or service.
All types of Group consumers and end
-
users.
Consumers and / or end
-
users who are particularly vulnerable to health or privacy impacts or
impacts from marketing
and sales strategies, such as children or financially vulnerable individuals.
Excluded populations and customers in
vulnerable circumstances
The Group positively impacts Health & Safety within Cypriot Society through the Bank of Cyprus Oncology Centre, which represents a partnership between the public
and the private sector. Since its inauguration in 1998, it has served cancer patients and the society at large. In addition, the Group creates positive impacts through
its Digital Transformation, which facilitates accessibility to financial services for all customers. In addition, the Group identified material positive impacts associated with
financing certain NACE (statistical classification of economic activities) sectors such as Rental and operating of own or leased real estate, development of building
projects, buying and selling of own real estate which support the access to safe and affordable housing. Regarding retail customers, the Group through provision of
housing loans, consumer loans and overdrafts create positive impacts on the accessibility to the use of financial services and being confident for the financial future
through the enhanced capacity to reach future goals.
A material negative impact arises, in relation to privacy, due to one privacy incident identified at the end of 2023. There was an internal data leak which resulted in the
improper use of addresses for loan notification letters leading to fine from the Commissioner for Personal Data Protection. Risks and opportunities described below arise
through impacts and dependencies with all Group’s consumers and end-users categories.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
191
ESRS S4 - Consumers and End Users (continued)
2. Material impacts, risks and opportunities and their interaction with strategy and business model (continued)
The Group’s strategy and business model are actively shaped by both negative and positive impacts identified. The negative impact on privacy drives the enhancement
of policies and governance, while by continuously adapting its products, services, and operational model in line with economic and technological changes, the Group
ensures that its business strategy drives positive consumer impact. Similarly, the Group’s strategy and business model are informed by material risks and opportunities
arising from its dependencies on consumers and end-users. These are explained in the sections below.
The Group offers financial products and services to businesses and individuals, both nationally and internationally. All types of customers, can be materially impacted,
positively or negatively, by the Group's operations, products, services, value chain, and business relationships, and are therefore included in the scope of disclosures.
The Group has considered all types of consumers in its materiality assessment, incorporating historical incidents (privacy, health, safety) and scientific assessment
tools (PRB Tool) to evaluate actual and potential negative impacts. The material IROs relate to, all consumers and / or end-users, rather than to any specific groups.
3. Commitment to Human rights
At BOCH, respecting human rights of consumers and end-users is embedded in the Group’s Code of Ethics, Code of Conduct, and organisational values. These
commitments are integrated into the Group’s strategy and business model to ensure that the interests, views, and rights of consumers and end-users are considered
in the decision-making processes. BOCH’s policies follow internationally recognised frameworks, including the UN Guiding Principles on Business and Human Rights, the
ILO Core Labour Conventions, the Universal Declaration of Human Rights (UDHR), and the OECD Guidelines for Multinational Enterprises. BOCH has established formal
policies to ensure ethical practices, consumer protection, and operational transparency. The Customer Complaints Management Policy provides a structured framework
for addressing and resolving complaints. The Group Information Security Policy sets out safeguards for customer data, breaches, and GDPR compliance. These policies
are supported by the Code of Ethics and Code of Conduct, embedding fairness, accountability, and respect for consumer and end-user rights into all operations. For
more details on Human rights impacts refer to ESRS S1 Own Workforce in page 172. The Group has no reported cases of non-compliance with the UN Guiding
Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises
involving consumers or end-users have been reported in its downstream value chain. Additionally, there were no reported severe human rights issues or reported
incidents connected to consumers or end-users.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
192
ESRS S4 - Consumers and End Users (continued)
4. Processes for engaging with consumers and end-users about impacts
The Group actively engages with consumers and end-users, their representatives or with credible proxies about actual and potential impacts, including human right
impacts, in alignment with Group’s vision to create partnerships with customers, guiding and supporting them in a changing world. BOCH is actively engaging with
customers at various stages and through different channels to ensure a comprehensive approach is in place to integrate customer’s input throughout the decision-
making process. The following table summarises the general processes for engaging with customers about actual and potential impacts.
Engagement
Description
Direct
Engagement
Stages of the
engagement
Type of
engagement
Frequency
Operational
responsibility
Effectiveness of the Engagement
Call Centre
Direct
1. Identification
2. Determine the
approach for
mitigation
3. Evaluating
effectiveness of
mitigation
1. Participation
2. Consultation
3. Information
1. Ongoing
1. Corporate Affairs
Department
2. Business
Banking Division
3. Complaints
Management
Unit (CMU)
1. The customer is requested monthly to
complete a satisfaction survey on the
customer service received by the Group
which is communicated to line Directors
and may lead to improvements in
processes, products and activities.
2. For the effectiveness of handling
complaints for consumers and end users
refer to 5. Customer complaint
management in page 193.
Personal
Meeting
Branches
Complaints
through various
means
Website
Customer
Survey
1. Identification 1. Participation 1. Monthly
1.
Corporate Affairs
Department
The steps BOCH takes to gain insight into its customers’ perspectives aim to be inclusive of all customers, including those who may be vulnerable. While current
engagement processes do not explicitly differentiate between customer groups, they engage across diverse voices in shaping policies and decisions. In addition to the
above, the Group engages with credible proxies, such as regulatory authorities, the Association of Banks, the Central Bank of Cyprus, and Financial Ombudsman, who
have knowledge of the interests, experiences or perspectives of consumer and end-users.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
193
ESRS S4 - Consumers and End Users (continued)
5. Customer Complaints Management
BOCH addresses negative impacts on consumers through a formal Customer Complaints Management Policy,
aiming to ensure a consistent, efficient, and impartial resolution process. The policy is publicly available for
transparency and includes follow-up feedback mechanisms to assess remedies and drive continuous
improvement. The Board holds ultimate responsibility for its implementation. The Policy and the underlying
Circular for Handling Complaints set the tone for managing feedback and complaints, ensuring that customers
and other stakeholders can express their dissatisfaction and allowing the Group to take appropriate action.
Customers can raise concerns through multiple channels, including in-person interactions with customer-facing
employees, call centre, formal letter and digital channels such as website, internet banking and portal, BOC
mobile application and emails. Information on how to raise concerns or complaints are readily available in the
Group’s website. Customers can raise concerns through institutional bodies, such as Central Bank of Cyprus,
Cyprus Securities and Exchange Commission, Cyprus Government Ministries, Commissioner of Data Protection
and Financial Ombudsman.
While the Customer Complaints Management Policy applies to BOCH’s operations, vendors are expected to adhere
to similar standards on Complaints Management. The Group expects that all the principles regarding Labor /
Human Rights / Ethics, Working Conditions and Health & Safety matters will be adhered by the vendors. Refer to
page 219.
Complaints are registered with sufficient detail to enable tracking and analysis. The analysis support the
identification of systemic issues and the effectiveness of remediation measures, aiming to ensure that that the
complaints handling process is continually improved and the issues are identified and addressed. Statistics on
customer complaints are prepared and reported by Internal Governance & Operations Department to the AC on
a quarterly basis. The Regulatory Compliance Division (RCD) also submits to the Central Bank of Cyprus (CBC) a
numerical complaint report on a quarterly basis. In addition, following the resolution of a complaint, the customer
is requested to provide feedback on how satisfied the customer is with the handling of the complaint. On a
monthly basis, the Complaint Management Unit provides a number of complaints to 1bank so to be provided with
customer’s feedback. Furthermore, on an annual basis the customer’s complaints are reviewed by RCD.
The Internal Audit Division evaluates the Customer Complaint Management Policy and reports any findings to the
AC with recommendations for improvement. Complaint investigations identify root causes and corrective
measures to prevent recurrence and enhance processes. Findings and recommendations are included in the
Annual Audit Report to the Board. Departments handling grievances undergo risk assessments and audits as part
of the Internal Audit’s Annual Plan, aiming to ensure oversight and compliance.
In order to gain customer’s trust on these channels the Group provides public information on how it deals with
complaints and information on the governance and monitoring arrangement of handling any complaint. BOCH’s
Customer Complaints Management policy describes procedures and mechanisms to ensure confidentiality in
dealing with customer complaints which are implemented by the Group.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
194
ESRS S4 - Consumers and End Users (continued)
6. Data Privacy, Information technology and security risks for consumers and end-users
The operational activities of the Group may negatively impact individuals' right to privacy, particularly through the unauthorised use or mishandling of personal data.
With expanding digital financial transactions, safeguarding personal information is a priority. Risks include GDPR compliance challenges, cybersecurity threats, financial
losses, and reputational damage. Cyberattacks and data breaches necessitate regular enhancement of secure networks. To mitigate these risks, the Group implements
safeguards to strengthen security and prevent threats.
Material IROs
-
Consumers and End
-
Users (S4)
ESRS Topic/Sub
-
Topic
IRO
Type
Description
Consumers and end
-
users
-
Information-related impacts for
consumers and/or end users -
Privacy
Impact Potential Negative
Negative impacts linked to incidents regarding customer privacy breaches during the
last three years (one incident during 2023, which was due to human error).
Time Horizons
Value Chain
Originate or
connected to
strategy/Business
Model
Business
relationship
Short-Term Medium-Term Long-Term
Own
Operations
Upstream Downstream
Connected to busi
ness
model through
processing of personal
data
Customers
ESRS Topic/Sub
-
Topic
IRO
Type
Description
Consumers and end-users -
Information-related impacts for
consumers and/or end users -
Privacy
Risk
Regulatory
compliance and
Information
Security (Including
Cyber risk)
The risk of:
a) non-compliance with Data Protection Law;
b) cyber-attacks leading to loss of theft or data;
c) lack or inadequate control provisions on information assets, leading to data misuse,
unrestricted or unauthorised access to information assets;
d) Unauthorised disclosure of sensitive data by staff and agents/services providers,
either accidentally or maliciously, may lead to significant reputational issues, identity
theft, fraud and regulatory penalties.
Time Horizons
Value Chain
Financial Effects
Short-Term Medium-Term Long-Term
Own
Operations
Upstream Downstream
No
material
current financial effects.
Anticipated financial effects include fines,
penalties and loss of business.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
195
ESRS S4 - Consumers and End Users (continued)
6. Data Privacy, Information technology and security risks for consumers and end-users (continued)
6.1 Policies to manage material impacts and risks on Data Privacy, Information technology and
security for consumers and end-users
Data Privacy
The Group maintains Personal Data Protection Compliance Policy, to comply to relevant regulations, including the
EU General Data Protection Regulation (GDPR) and national laws such as the Protection of Natural Persons
regarding the Processing of Personal Data Law 125(1)/2018 and section 106 of the ‘Regulation of Electronic
Communications and Postal Services Law 112(I)/2014’, as well as the relevant guidelines issued by the
Commissioner of Personal Data protection from time to time. This policy outlines the Group’s commitment to
protect the personal data of customers, employees, suppliers, and business partners, to ensure that data
collection, use, and retention are lawful, transparent, and aligned with GDPR principles. Protecting the security
and privacy of personal data is important to the Group, in order to conduct its business activities in the context
of the envisaged privacy culture. The Group complies with the ISO 27001 Information Security Standard,
reinforcing its commitment to secure data handling. The Board and Senior Management are responsible to oversee
the Group`s compliance with this policy. Additionally, they have the ultimate responsibility for the implementation
and adherence to this policy throughout the Group, and the imposition of any remedial action. BOC PCL and its
subsidiaries must, as a minimum meet the requirements of this policy. The policy is applicable for all subsidiaries
of the Group as they are considered separate data Controllers. The management of each subsidiary is ultimately
responsible for the implementation of this policy and to ensure, at entity level, that there are adequate and
effective procedures in place for its implementation and ongoing monitoring to its adherence. The privacy
statement of the Group is published in Group’s website to be made available to potentially affected stakeholder.
For more detail on Personal Data Protection Compliance Policy refer to ESRS S1 – Own Workforce in page 179.
Information Technology and security risks
The Group’s Information Security Policy further outlines a structured management approach, to address
information and cybersecurity risks and events associated with the Group’s technology systems and information
assets.
The purpose of the Policy is to provide an unambiguous set of standards, guidelines, controls, measures and
requirements designed to achieve a desired level of information security across all business and technical layers
of the Group. In essence, it governs the direction of all activities in the areas of information security and acts as
an umbrella document to all other Group Security Policies and associated standards, aiming to contribute to a
safe and responsible Information Security Management System (ISMS) within the Group, while supporting the
overall business objectives and goals. The scope of this policy includes all subsidiaries of the Group and all
individuals working at all levels and grades.
The functional scope of the policy includes all assets (in the broadest sense, e.g. systems, platforms, networks,
applications, documents, devices, etc.) that are used to store, process and transport Group’s information and the
information belonging to the customers, as well as facilities, equipment, resources, people and property.
This Policy is approved by the Group Board Risk Committee (RC) and reviewed on an annual basis, adhering to
internal guidelines for continued pertinence of the business documentation, to reflect in the policies and
procedures the latest regulatory requirements and any changed business processes and circumstances.
6.2 Actions to manage material impacts and risks on Data Privacy, Information technology and
security for consumers and end-users
Data Privacy
The Group safeguards customer data in compliance with GDPR and with transparency and accountability in all
processing activities. Data is collected through direct interactions, digital platforms (1bank, website), and
representatives, covering employees, clients, suppliers, and business partners when required for contractual,
legal, or legitimate interests. Data is limited to necessity, retained as per GDPR principles, and aligned with Local
Commissioner guidelines. Privacy Statements, available on the website, branches, and customer documents,
provide clear, accessible information, especially for children.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
196
ESRS S4 - Consumers and End Users (continued)
6. Data Privacy, Information technology and security risks for consumers and end-users (continued)
6.2 Actions to manage material impacts and risks on Data Privacy, Information technology and
security for consumers and end-users (continued)
Data Privacy (continued)
The Privacy Statement, last updated in July 2024, outlines the right to withdraw consent anytime. Consent is
specific, documented, and managed. The Legal Department reviews and updates policies annually to ensure
compliance.
Customers can raise concerns on how their personal data are collected, processed or protected through channels
described in 5. Customer Complaints Management in page 193 respectively.
For details on actions on suspected or actual data breaches, actual negative impacts remediation, Data Protection
Impact Assessment, resources involved in Data privacy and effectiveness of actions performed refer to ESRS S1
– Own Workforce in page 179.
Information Technology and security risks
The Group has adopted an Information Security Management System (ISMS), in line with acknowledged
international standards (ISO/IEC 27001, NIST, CSA), as a basis for the structuring and maintaining of a system
of measures to safeguard confidentiality, integrity and availability of its information assets and information
systems. The ISMS provides a set of policies, frameworks, standards, guidelines, controls, measures and
requirements designed to achieve a desired level of information security across all business and technical layers
of the Group.
The Group is committed in protecting the security of its business information. For the purposes of meeting that
business objective the Group established the Information Security Division with the IT related personnel and
implemented, maintained an ISMS based on internationally acknowledged standards. Information Security team
is constantly monitoring cyber security threats (either internal or external, malicious or accidental) and invests
in cyber security measures and controls to protect, prevent, and respond against such threats to Group systems
and information. The ISMS ensures the protection of information assets through key security controls:
1) Risk Management: Identifies, assesses, and mitigates security risks.
2) Information Protection: Implements measures to classify, handle, and secure data.
3) Supplier Security: Ensures third-party security compliance.
4) Human Resources Security: Trains employees and contractors on security responsibilities.
5) Physical Security: Protects assets from unauthorized access and disruptions.
6) Operations Security: Secures IT infrastructure, networks, and communication channels.
7) Cloud Security: Maintains data integrity and security in cloud environments.
8) Mobile Security: Controls for secure mobile device management.
9) Access Management: Restricts system and data access to authorized users.
10) System Security: Integrates security in system development and maintenance.
11) Backup Management: Ensures data recovery through secure backups.
12) Data Retention: Defines retention and archival policies.
13) Data Leakage Prevention: Detects and prevents unauthorized data distribution.
14) Patch Management: Regularly updates systems to address vulnerabilities.
15) Incident Response: Implements processes for managing security incidents.
16) Business Continuity: Ensures resilience against data loss and disruptions.
The Group implements processes to conduct periodic reviews to evaluate the effectiveness of implemented
information security controls in accordance with current risk appetite and prioritise corrective actions. The reviews
combine several different approaches, to improve situational awareness on the status of security controls across
the Group’s environment and increase insights into the processes used to manage organisational security. Those
reviews include Information security assessments, Information security controls maturity assessment,
Vulnerability and Security Configuration assessments/scanning, Enterprise penetration testing and Penetration
testing of specific applications/systems.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
197
ESRS S4 - Consumers and End Users (continued)
6. Data Privacy, Information technology and security risks for consumers and end-users (continued)
6.2 Actions to manage material impacts and risks on Data Privacy, Information technology and
security for consumers and end-users (continued)
Information Technology and security risks (continued)
Where a control is found to operate outside the Group’s defined risk appetite:
1. A risk assessment should be performed and risks should be managed using the procedure defined in the
Information Security Risk Management Methodology.
2. Each control owner should aim to reduce the identified exposure within the defined risk appetite, in line
with the defined risk remediation targets.
The Board Technology Committee (TC) supports the Board in fulfilling the oversight responsibilities with respect
to the overall role of technology, including information security. The RC has the responsibility for the oversight of
Operational and Information Security risks. The TC is informed on the application of Information Security policies.
No significant operational expenditures and/or capital expenditures are associated with the above-mentioned
actions.
6.3 Metrics & Targets on Data Privacy, Information technology and security
There is no set measurable, time-bound, outcome-oriented target however, the Group nevertheless tracks the
effectiveness of these actions through established processes, procedures and KRIs. The Group maintains a
leakage registry to document and monitor data incidents, reviewed quarterly and reported to senior management
and the AC. Data subject requests and complaints are tracked to ensure resolution. Cyber-attacks and resolutions
are recorded, with updates provided to the DPO and regulatory authorities. The Group also maintains a Record
of Processing Activities (RoPA), conducts Data Protection Impact Assessments (DPIAs), updates GDPR-related
actions, including Privacy Statement revisions and provides internal training. Moreover, the Group’s Risk Appetite
Statement (RAS) reflects a zero-tolerance approach to privacy and data protection risks. Board, Management and
all staff participate, in 2024, in Information security training (9,889 training hours), GDPR training (107 hours)
and use of personal data training (1,207.5 hours).
For personal data leakage reported to the Commissioner for Personal Data Protection refer to the quantitative
metrics in ESRS S1 – Own Workforce in page 180.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
198
ESRS S4 - Consumers and End Users (continued)
7. Access to Products and services
7.1 Digital Transformation
The Group positively impacts accessibility to products and services through the strategic orientation to continuously scale up digital transformation.
Material IROs
-
Consumers and End
-
Users (S4)
ESRS Topic/Sub-Topic IRO Type Description
Consumers and end
-
users
-
Social
inclusion of consumers and/or end-users -
Access to products and services
Impact
Actual &
Potential
Positive
The Group's Branch network, expansion in digital means and digital product offerings (1Bank,
Internet Banking, Subsidiary portals) contribute positively to accessibility on products and
services.
Time Horizons Value Chain
Originate or
connected
to strategy
Business
relationship
Short-Term
Medium
-
Term
Long-Term Own Operations Upstream Downstream
Originate from
Digital
Transformation value
proposition
Customers
7.1.1 Policies related to consumers and end-users associated with access to product and services through Digital transformation
The Group through digital networks supports customer accessibility to financial products and services. Digital solutions like Internet Banking (1bank) and BOC Mobile
Application with offerings like QuickLoans, Digital Deposits, QuickPay, QuickCards, Digital Accounts, Antamivi Scheme, Digital card ‘wallets’ which provide secure,
efficient, and accessible way to financial services, reducing the need for branch visits and allowing customers to manage their finances remotely. The Group’s Treating
Customers Fairly Policy, on the Consumer Protection Law of 2021 (Law 112(I)/2021), emphasises the customer’s best interests and understanding of their needs,
ensuring products are designed with customer’s interest in mind and are easy to explain. This policy is available publicly in Group’s website through Code of Ethics and
Code of Conduct. The Board is responsible to oversee the Group`s compliance with this Policy. Additionally, the Board has the ultimate responsibility for the
implementation and adherence to this policy throughout the Group, and the imposition of any remedial action. The Board approves this Policy through AC and oversee
that sufficient, dependable, and secure internal procedures are in place to facilitate compliance with the policy. Internal audit includes the policy as an auditable area
in its Risk & Audit Universe and assesses the need for audit engagements during the annual audit planning process.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
199
ESRS S4 - Consumers and End Users (continued)
7. Access to Products and services (continued)
7.1 Digital Transformation (continued)
7.1.2 Actions enhancing positive impacts through Digital transformation
The Group in 2024, undertaken several actions to evolve its positive impact arising from digitalisation:
S
ch
emes/Feature
/Product
Scope Expected Outcome Effectiveness Tracking
Pronomia
The new 'pronomia' loyalty scheme
primarily aims to acknowledge and
reward loyal Group’s customers
through privileges and benefits
Increase customer satisfaction, facilitate access to products
and services through reward schemes and increase
customer’s trust.
Internal KPIs are set towards these
features, products and schemes which
are monitored through BDC and EXCO
on a monthly basis. In addition,
customers are providing feedback
through monthly customer survey
towards satisfaction on Group’s digital
means.
JOEY
Next
-
generation banking app
lication
designed specifically for kids aged 9 to
17
Joey supports kids and teens learn to manage money in a
safe, structured way, with the guidance of their guardian.
GIC Portal
Customer portal to apply or renew
general insurance contracts
embedding also reward schemes
Increase customer satisfaction, facilitate access to products
and services through reward schemes and increase
customer’s trust.
Quick Loans
Digital lending solution for rapid credit
access with minimal processing time
and lower fees.
Increase customer satisfaction, facilitate access to products
and services and increase customer’s trust.
Digital Deposits
Online platform for deposit
management, reducing physical
interactions.
Increase customer satisfaction, facilitate access to products
and services and increase customer’s trust.
Digital Accounts and
Cards
Fully digital banking accounts and card
solutions for enhanced accessibility.
Increase customer satisfaction, facilitate access to products
and services and increase customer’s trust.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
200
ESRS S4 - Consumers and End Users (continued)
7. Access to Products and services (continued)
7.1 Digital Transformation (continued)
7.1.3 Metrics & Targets on positive impacts through Digital transformation
There is no set measurable, time-bounded and outcome-oriented
target however, the Group tracks effectiveness of these actions
through the internal KPIs. The Group sets annual internal KPIs
towards its digital offerings, features and schemes. Those KPIs are
monitored on a monthly basis through BDC and EXCO. Those KPIs
are set taking into account market conditions, operating environment
and historic information. Refer to the following metrics on the above-
mentioned internal KPIs. The below metrics are extracted either
through internally established dashboards or through export from
Group data warehouse. No significant assumptions made towards
extraction of metrics. Metrics are not validated by any external body.
12,781
21,531
Digital Accounts (#)
FY2023 FY2024
104.2
106.7
Quick Loans and ELoans (mn)
FY2023 FY2024
415,045
613,486
Digital Sales Non-life insurance
(000)
FY2023 FY2024
11,536
23,386
Debit Cards (#)
FY2023 FY2024
89.80%
92.20%
Digital Deposit Ratio (%)
FY2023 FY2024
95.56%
95.54%
Digital Transactions Ratio
(Total Portfolio)
FY2023 FY2024
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
201
ESRS S4 - Consumers and End Users (continued)
7. Access to Products and services (continued)
7.1 Digital Transformation (continued)
7.1.4 Material Opportunities on Digital Transformation
Material IROs - Consumers and End-Users (S4)
ESRS Topic/Sub
-
Topic
IRO
Type
Description
Consumers and end-users - Social
inclusion of consumers and/or end-
users - Access to products and
services
Opportunity
Digital
Transformation
Expand the QuickLoans offering through digital channels by allowing individuals to an
end-to-end Housing Loan capability.
Time Horizons
Value Chain
Financial Effects
Short-Term Medium-Term Long-Term Own Operations Upstream Downstream
Enhance customer's
accessibility
to financial products and increase
market share and revenue
ESRS Topic/Sub
-
Topic
IRO
Type
Description
Consumers and end-users - Social
inclusion of consumers and/or end-
users - Access to products and
services
Opportunity
Digital
Transformation
A POS (Point-of-Sale) credit facility is a lending product that offers the opportunity to
the customers to instantly obtain a product or a service both digitally and physically (at
the Point of Sale) with flexible payment options over a period of time.
Time Horizons Value Chain
Financial Effects
Short-Term Medium-Term Long-Term Own Operations Upstream Downstream
Enhance customer's
accessibility
to financial products and increase
market share and revenue
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
202
ESRS S4 - Consumers and End Users (continued)
7. Access to Products and services (continued)
7.1 Digital Transformation (continued)
7.1.4 Material Opportunities on Digital Transformation (continued)
Material IROs
-
Consumers and End
-
Users (S4)
ESRS Topic/Sub
-
Topic
IRO
Type
Description
Consumers and end-users - Social
inclusion of consumers and/or end-
users - Access to products and
services
Opportunity
Digital
Transformation
Evolution of Jinius platform.
Time Horizons Value Chain
Financial Effects
Short-Term Medium-Term Long-Term Own Operations Upstream Downstream
Digitalise Cyprus economy and
enhance customer's accessibility
to financial products leading to
increased revenue and market
share
7.1.4.1 Policies associated with material opportunities on Digital Transformation
The Group implements a Group New product/Services Management policy to pursue a new product opportunity. This policy sets out and addresses key principles for
the development of new Products/Services and modification/amendment of existing ones. Failure to promptly identify, assess and mitigate product risk can have
adverse financial, regulatory, technology and/or reputational impact. This policy applies to all Group entities and in any country. The Board bears the ultimate
responsibility for the effective implementation of the Policy and for setting the right tone from the top. The RC maintains oversight and ensures that the framework for
assessing new Products/Services is in place and is effective, making sure that sufficient, dependable, and secure internal procedures are in place to ensure that the
Group complies with the policy. RC also monitors the effective implementation of the Policy through the Control Functions. The Group dedicates resources to ensure
appropriate launch of new products. The departments involved in the process are Operational Risk Management, Risk Operations, Data Office & Risk Analytics,
Information Security, Compliance Division, Data Protection Officer, Corporate Affairs, Legal, Information Technology, Organisation Department, Treasury Division,
Finance, HR, Internal Audit, Product Owner and Chief Digital Division. Certain Committees are involved in the process, Executive Committee, Product Governance, Asset
and Liability Committee and New Products Forum.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
203
ESRS S4 - Consumers and End Users (continued)
7. Access to Products and services (continued)
7.1 Digital Transformation (continued)
7.1.4 Material Opportunities on Digital Transformation (continued)
7.1.4.2 Actions associated with material opportunities on Digital Transformation
1. Digital Housing
The Bank aims to offer Housing loans through Internet Banking and BOC Mobile Application. This initiative streamlines the loan assessment process by enabling
automatic approvals or rejections based on predefined criteria, improving both customer experience and the in-branch application processing. The Digital Housing is
expected to increase in-branch efficiency and sales. The Group followed the New Products/Services procedure, engaged with all relevant stakeholders to pursue the
relevant opportunity. The Phase 1 of the product was launched in January 2025 and relates to Digital Housing Product through Internet Banking. The Phase 2 of the
product is expected to be launched in 2025 allowing Digital Housing to be offered through BOC Mobile Application. A detailed road map has been established for effective
implementation and rollout.
2. POS Credit Facility (Flexy)
The POS Credit Facility is a lending solution that allows customers to access products or services, both digitally and physically at the point of sale, with flexible payment
options. Delivered through the Group’s Internet banking, it enhances customer convenience while expanding the Group’s financial services portfolio. The POS Credit
Facility is expected to streamline operations with automated assessments and support environmental sustainability by cutting paper consumption and carbon emissions,
drive revenue growth through expanded loan offerings, empower customers with tools for better financial decision-making and enhance customer engagement and
gather valuable feedback.
After conducting market analysis, cost-benefit evaluation, benchmarking, and other assessments to explore the opportunity, the product is now progressing through
the appropriate governance framework under the New Products Circular, with a planned launch in 2025. The opportunity does not include any significant operating and
capital expenditure to pursue the above-mentioned opportunities.
3. Digital Economy Platform (Jinius)
The Jinius platform offers services and tools that digitalise, simplify, and speed up the daily transactions and activities of businesses. Jinius through Business-to-Business
Services offer tender management, ecosystem management, invoice management and remittance management services. Jinius through Business to Consumers
services, launched in February 2024, offer product marketplace were retailers and consumers can interact. Jinius represents a significant opportunity for growth and
thus the strategic evolution of Jinius is part of the 5-year Group’s Financial Plan, evaluated each year, and any internal KPIs are monitored through BDC on a monthly
basis.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
204
ESRS S4 - Consumers and End Users (continued)
7. Access to Products and services (continued)
7.2 Financed Positive Impacts
Material IROs
-
Consumers and End
-
Users (S4)
ESRS Topic/Sub-Topic IRO Type Description
Consumers and end-users - Social
inclusion of consumers and/or end-
users - Access to products and
services
Impact
Actual & Potential
Positive
a) Financing activities to certain NACE sectors (i.e. Rental and operating of own or leased
real
estate, development of building projects, buying and selling of own real estate) with
total portfolio exposure of 25.98% out of 5
b exposures assessed under PRB institutional
banking impact analysis of 2024
, create key/direct actual positive impacts to stakeholders’
accessibility to affordable housing. Financing activities to consumer banking portfolio (i.e.
Home loans /mortgages) with total portfolio exposure of 80.8% out of 4.9
b exposures
addressed under consumer banking impact analysis of 2024, create k
ey/direct actual
positive impacts to stakeholders’ accessibility affordable housing.
b) Financing activities to consumer banking portfolio (i.e. Home loans /mortgages,
consumer loans & overdraft) with total portfolio exposure of 100% out of 4.9
b exposures
assessed under consumer banking impact analysis of 2024
, create key/direct actual
positive impacts to accessibility to the use of financial services.
Time Horizons Value Chain
Originate or
connected to
strategy
Business
relationship
Short-Term Medium-Term Long-Term Own Operations Upstream Downstream
Connected to
strategy through
provision of
Finance
Customer
The Group provides a wide range of high-quality financial products and services, including retail and commercial banking, factoring, private banking, life and general
insurance, aiming to cover fully and effectively the constantly changing needs of its customers, whether businesses or individuals. Products such as Housing loans,
Consumer loans, Credit Cards and Overdrafts as well as loans granted to the Real estate sector, positively contribute to the accessibility to adequate, safe and affordable
housing and to the use of financial services by individuals and firms.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
205
ESRS S4 - Consumers and End Users (continued)
7. Access to Products and services (continued)
7.2 Financed Positive Impacts
7.2.1 Policies on Financed positive impacts associated with access to product and services
The Group’s Lending Policy sets the principles for credit risk management and supports the risk culture in the
Group in order to be aligned with regulatory requirements and the strategic ambitions. The acceptance of credit
risk is an integral part of our core business, and fulfilling our financial goals requires commercial decisions that
balance risk and reward. The Policy sets principles for the customer’s credit risk profile (Risk rating systems),
repayment ability, loan to value and loan to cost limits, collateral, concentration risks, ESG Due Diligence and
how the exposures are monitored and reported on. Detailed guidelines for the implementation of the Policy are
incorporated in the Credit Risk Circulars which are approved by the CRO.
The Board bears the ultimate responsibility for the effective implementation of the Policy and for setting the right
tone from the top. The Board approves this policy through RC, making sure, that sufficient, dependable, and
secure internal procedures are in place to ensure that the Group complies with the Policy and monitoring the
effective implementation of the Policy via the Control Functions. Internal Audit Division reviews the policy for
proper governance and periodically assesses the Policy and the Group’s system of internal controls, corporate
governance and risk management processes related to the Policy and informs Audit Committee of its findings and
relevant recommendations. Credit Risk Control & Monitoring reviews the Policy for proper governance and is
responsible to examine adherence to policy, as part of on-going monitoring through reporting in regular intervals
or the review of credit applications on a sample basis, as described in the Group’s Credit Monitoring Policy and
CRC&M operations manual. For more details on MDR-P refer to ESRS E1 – Climate Change in page 133.
7.2.2 Actions on Financed positive impacts associated with access to product and services
1. Housing
Housing is a key strategic priority, representing 35% of its performing loan portfolio as at 31 December 2024.
Taking into account the high construction costs and increased property prices in Cyprus market, the Group
understands that through the provision of finance it supports the increase of the housing supply in Cyprus. In
addition, the Group recognizes that increasing housing supply has a material positive social impact and
acknowledges any potential negative environmental impacts from the construction (Refer to ESRS E1 Climate
Change in page 110, ESRS E2 Pollution page 156 and ESRS E5 Resource Use and Circular Economy page
166).
At the end of 2023 and during 2024, the Bank launched the “Green Housing” product, aligned with GLP of LMA,
in order to support the decarbonisation of residential properties in Cyprus and achieve the decarbonisation target
set. The Green Housing product enhances the accessibility and affordability on Housing, as it finances the
construction or acquisition of an energy efficient residential property (Energy Performance Certificate (EPC)
Category A) which has lower environmental impact and lower energy costs. In addition, the Green Housing
product is offered at lower interest rates as it provides discounts to those who provide the design and post
construction (EPC) Category A.
The retail housing is considered a critical financial product to support our customers to acquire their own home.
BOC PCL supports customers who are buying their first home, their holiday home, carrying renovation to their
existing home or acquiring a home for investment. In the Group’s website, new and existing customers can find
useful information to support them on their way. The Bank offers also an online calculation tool to provide an
indicative instalment to its customers. In addition, the Bank launched the Digital Housing product through internet
Banking and aims to launch it through BOC Mobile Application during 2025 to support further customer’s access
to affordable housing.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
206
ESRS S4 - Consumers and End Users (continued)
7. Access to Products and services (continued)
7.2 Financed Positive Impacts
7.2.2 Actions on Financed positive impacts associated with access to product and services (continued)
1. Housing (continued)
The Group to further support the access to Housing, given the increases in interest rates the recent years,
introduced a series of support measures to the Cypriot society. The following measures were announced at the
end of 2024 and will be implemented in 2025:
1) Support to performing borrowers: Rewarding performing Housing loan borrowers who have a Housing
loan with ECB or Euribor base rates if certain criteria are met. The rewards can be either through Antamivi
points or cash. The reward represents 0.5% of interest rate for the period 30/06/24-31/12/24.
2) Personal Loans to Performing Borrowers with Housing loans: Introduction of new five-year fixed rate
personal loan product with limit 5,000 at preferential interest rate for energy upgrade.
3) Interest Rate Subsidies:
a. In alignment with Government Subsidy Scheme Housing Subsidy Scheme for Young Couples
and/or Individuals up to 41 Years Old” a 1% interest rate subsidy for the approved Cypriot
residents under the scheme. The subsidy to be offered with the Bank’s 3 Years Fixed interest rate
Housing Loan product during the fixed rate period of the loan only.
b. In alignment with Government Subsidy Scheme “Housing Scheme for the Revitalization of
Mountainous, Near the Buffer Zone and Disadvantaged Areas” a 1% interest rate subsidy for the
approved Cypriot residents under the scheme. The subsidy to be offered with the Bank’s 3 Years
Fixed interest rate Housing Loan product during the fixed rate period of the loan only.
4) Offering of Housing Loans at lower Fixed interest rate by the Bank: Offering 3 year fixed interest housing
loan at a discount of 0.75% during the three-year Fixed rate period of the loan only. The product will be
with a rate of 2.85% or 2.90% depending on customer contribution (higher or below 30%). The discount
to be available only for primary residence Housing Loans for the acquisition of properties up to 350K for
a total amount of 100m.
The are no significant operating expenditure or capital expenditure on the above-mentioned actions.
In addition to the above, the Group through financing to certain sector of the economy continues to support the
access to adequate housing:
Financing to key NACE sectors that create positive impacts on Housing (as per the 2024 PRB
Impact Analysis)
2023 2024
Sectors
Total % to
total
portfolio
OS Loan
Amount
(mn)
Total % to
total
portfolio
OS Loan
Amount (mn)
41.1 Development of building
projects
7.18% 354 6.18% 312
41.2 Construction of residential and
non-residential buildings
1.22% 60 1.35% 68
43.9 Other specialised construction
activities
0.51% 25 0.74% 38
68.1 Buying and selling of own real
estate
4.05% 200 4.14% 209
68.2 Rental and operating of own or
leased real estate
15.48% 763 13.04% 658
68.3 Real estate activities on a fee
or contract basis
1.14% 56 0.52% 26
Total
29.58%
1,458
25.98%
1,311
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
207
ESRS S4 - Consumers and End Users (continued)
7. Access to Products and services (continued)
7.2 Financed Positive Impacts
7.2.2 Actions on Financed positive impacts associated with access to product and services (continued)
2. Consumer Banking
The Group also provides a of day-to-day banking products and services, such as current accounts, deposits and
savings, cards, loans and insurance. The Bank acknowledges that its retail product offerings relating to Credit
cards, Consumer loans and Overdrafts positively impact the customers’ access to finance. At the same time, the
Bank also understands that those offerings may impact the customers’ disposable income due to higher interest
rates and fees. The above-mentioned product offerings correspond to 13% (660mn) and 13% (642mn) in 2024
and 2023 respectively of the Group’s consumer banking portfolio, as per the 2024 and 2023 PRB consumer
banking impact analysis. Even though not significant in terms of value those products provide individuals with
access to finance for any unexpected expenses and cover their needs. In addition, the Group associates Credit
Card products with ‘Privileges’ to boost the access to finance and mitigate the inherent negative impacts:
Participation in Antamivi Scheme;
Worldwide free ATM withdrawals;
Lounge key;
Free travel insurance and purchase protection insurance.
Through its digitalisation journey as already mentioned in Digital Transformation section, the Group offers
QuickLoans which provide easy access to Consumer loans with less impact to the customers’ disposable income.
The customers have quick access to finance as the applications for such products are submitted and assessed
electronically based on the creditworthiness, repayment ability and the Group’s credit policy. The decision for the
approval or rejection of the online credit application will be reached by processing the personal data using solely
automated means (including profiling), without human involvement, and only after the explicit consent to do so.
Therefore, the Quick Loan products are offered without any initial bank charges (arrangement or documentation
fees, except stamp duties which are required by law).
The above-mentioned metrics are extracted either through internally established dashboards or through export
from Group data warehouse. No significant assumptions made towards extraction of metrics. Metrics are not
validated by any external body.
7.2.3 Metrics & Targets related to financed positive impacts associated with access to product and
services
There are no set measurable, time-bound, outcome-oriented targets associated with financed positive impacts
nevertheless, the Group tracks the effectiveness of these actions through the Financial Plan process. The Group
sets specific internal annual KPIs associated with new lending of housing and other consumer banking offerings.
The Group has set its new lending internal KPIs for 2025-2028 in the Group’s Financial Plan. Those metrics are
monitored on a monthly basis at the BDC and EXCO and on quarterly basis from the Board. The Bank joined UN
PRB last year, therefore, a public outcome-oriented target on financial inclusion should be set in the upcoming
years.
During the year, the Group offered 491mn new lending on retail housing (2023: 454mn) which comprises 20%
of Group’s new lending and indicates the Group’s commitment to this area. The total performing gross loans
under performing retail housing amounts to 3,56bn as at 31 December 2024 (2023: 3.35bn). The Group aims
to steadily increase its retail housing portfolio and continue its positive impact to affordable housing. The above-
mentioned metrics are extracted either through internally established dashboards or through export from Group’s
data warehouse. No significant assumptions made towards extraction of metrics. Metrics are not validated by any
external body. In addition, there were 355mn gross environmentally friendly loans as at 31 December 2024
which correspond to a 90% increase compared to 31 December 2023. For details on environmentally friendly
loans refer to ESRS E1 – Climate Change in page 144. For the measures launched to support the Cypriot society,
describes above, metrics will be reported in FY2025, given those were launched in December 2024.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
208
ESRS S4 - Consumers and End Users (continued)
7. Access to Products and services (continued)
7.3 System Downtime and Disaster risks
Material IROs
-
Consumers and End
-
Users (S4)
ESRS Topic/Sub-Topic IRO Type Description
Consumers and end
-
users
-
Social
inclusion of consumers and/or end-
users - Access to products and services
Risk Technology risk
Group's system downtimes impacting accessibility to products and services and
customer service.
Time Horizons
Value Chain
Financial Effects
Short-Term
Medium
-
Term
Long-Term Own Operations Upstream Downstream
No current
material
financial
effect. Anticipated financial effect
include loss of business
ESRS Topic/Sub
-
Topic
IRO
Type
Description
Consumers and end
-
users
-
Social
inclusion of consumers and/or end-
users - Access to products and services
Risk
Business
Continuity risk
One of the IT Data centres to be rendered unavailable due to natural disaster
Time Horizons
Value Chain
Financial Effects
Short-Term
Medium
-
Term
Long-Term Own Operations Upstream Downstream
No current
material
financial
effect. Anticipated financial effect
include loss of business
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
209
ESRS S4 - Consumers and End Users (continued)
7. Access to Products and services (continued)
7.3 System Downtime and Disaster risks (continued)
7.3.1 Policies related to system downtime and disaster risks associated with access to product and
services
The Group’s wide range of financial products and services change from time to time and in order to adapt to the
needs of its customers, whether businesses or individuals, and aim to be in line with the changes in the broader
economy and environment. However, access to products and services can be significantly affected by system
downtimes, posing a material risk to the Group’s operations. Such downtimes disrupt customer services and
hinder transaction capabilities, leading to potential revenue losses, customer dissatisfaction, and reputational
damage. To address these risks, the Group has adopted a Business Continuity Management Policy that
demonstrates its commitment to maintaining a Business Continuity Management System (BCMS). This policy
applies to all employees within the Group that support the delivery of financial products and services to consumers
and businesses. It ensures that essential banking functions remain available, even in the event of disruptions,
safeguarding customer access and operational stability.
This internal policy approved by the Board through RC, supports with the Group’s business continuity objectives
as well as statutory, regulatory, and contractual obligations. The BCMS framework is designed according to the
standards set by ISO 22301:2019 “Societal security - Business continuity management systems Requirements.”
BCMS aims to safeguard the interests of key stakeholders, reputation, brand and value creating-activities. It also
adheres to directives from the Central Bank of Cyprus, in order to ensure a structured and reliable approach to
mitigating the risks associated with service disruptions. The overall responsibility for approving and monitoring
the Group`s strategy and policy for managing Business Continuity risk lies with the Board which exercises this
responsibility through the RC. The Policy, circulars and procedures are readily available on the Employee Internal
Portal. In addition, the Head Business Continuity Risk Management conducts BCMS workshops and training
programs to ensure that the business continuity liaisons who are assigned business continuity responsibilities are
competent to perform the required tasks.
7.3.2 Actions related to system downtime and disaster risks associated with access to product and
services
To manage interruptions of critical IT systems and to avoid loss of data and services, as an after effect of natural
or man-made disasters, the Group implements a Disaster Recovery Plan (DRP). The DRP applies both to major
events that deny access to datacentres for an extended period, and to events that may deny access to parts of
the datacentres or certain systems. In that respect, the DRP is IT focused and designed to restore operability of
IT systems and applications at an alternative site, with the aim to mitigate any effects a disaster might have upon
the on-going operations of the Group. The Executive Director Technology & Operations is responsible for
reviewing, amending and updating the Group’s DRP for the recovery of key IT systems, telecommunications and
data to support the implementation of recovery locations in the context of Business Continuity Plan (BCP).
The DRP covers all relevant risk and incident types (i.e., flood, fire, tornado, electrical storms, act of sabotage,
electrical power failure, loss of communications network services), including recovery options and strategies for
cyber-security scenarios. The plan incorporates and define the priorities in recovering IT systems, considering
their interdependencies. Procedures for recovery priority identification and management are defined and
periodically reviewed. Ownership of the DRP is assigned to the Disaster Recovery Committee (DRC), which
nominates a Disaster Recovery Coordinator (DR Coordinator) to undertake responsibility for the efficient
maintenance of the DRP. The DRP is tested annually for the identification and implementation of necessary
remedial actions on any issues recognised during the test. The Group must maintain Crisis Management processes
towards the effective and efficient management of any crisis events in order to mitigate, as much as possible,
the impact on the organization, its stakeholders and its customers.
7.1 Metrics & Targets related to system downtime and disaster risks
There are no measurable, time-bound and outcome-oriented targets on system downtime and disaster risks
however, the Group tracks effectiveness of these actions through established escalation arrangements to CEO,
CRO and Deputy CEO in case of a critical impact incidents. The Group, in 2024, conducted Business Continuity
Management training (1,299.5 hours in 2024) and Disaster Recovery training (161 hours in 2024). 5 system
downtime incidents were reported, in 2024, to CBC. No disaster incidents occurred in 2024.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
210
ESRS S4 - Consumers and End Users (continued)
8. Health & Safety
The Group faces material physical security risks and health & safety risks for its stakeholders.
9. Policies and actions related to physical security risks and H&S
To mitigate the above-mentioned risks, the Group is implementing the following policies:
1. Health & Safety Policy: For the description, actions and metrics and targets associated with this policy refer to page 183 of ESRS S1 – Own Workforce.
2. Physical and Environmental Security Policy: This policy applies to all premises and facilities and establishes minimum standards for safeguarding company
assets and creating a secure working environment. By protecting against unauthorised physical access, theft, and damage to operational equipment, this
framework minimises service disruptions and ensures the safety of individuals at Group premises.
This policy applies to all property, facilities, assets, and equipment, whether owned or leased by the Group, including but not limited to all premises and buildings of
the Group. In addition, this policy applies to all individuals working at all levels and grades. The Group regularly reviews and updates its strategic plans and compliance
with health and safety and physical security policies taking into account any H&S incident. The Operations and Cost Management Division oversees the policy, addresses
interpretation queries, ensures appropriate access controls based on the criticality of each location, and monitors adherence to established physical security KRIs. KRIs
and compliance audits ensure risks are effectively mitigated. The policy ensures implementation of security controls, access controls, physical monitoring controls,
equipment security and measures against physical and environmental threats. The material risks primarily affect customers who visit the Group’s branches or premises.
By mitigating these risks, the Group ensures a safe and secure environment for these interactions, by reducing potential harm to consumers and end-users.
10. Metrics & Targets related to physical security risks and H&S
There are no set measurable, time-bound and outcome-oriented targets nevertheless, the Group tracks the effectiveness of these actions through the following
monitoring mechanisms. BOCH is committed to managing material risks on consumers and end-users, particularly in the area of physical security and health and safety,
through KRIs and monitoring mechanisms designed to mitigate potential hazards and ensure a safe working environment. For more details on the refer to page 187 of
ESRS S1 – Own Workforce.
Material
IROs Consumers and End
-
Users (S4)
ESRS Topic/Sub
-
Topic
IRO
Type
Description
Consumers and end
-
users
-
Social inclusion
of consumers and/or end-users - Health &
Safety and Security of a person
Risk
Physical
Security and
Safety Risk
Increased physical security risks (theft, vandalism, property damage, trespassers,
squatters etc.) health and safety risks (injuries, public health and safety hazards)
and/or legal and regulatory violations and penalties.
Time Horizons
Value Chain
Financial Effects
Short-Term
Medium
-
Term
Long-Term
Own
Operations
Upstream Downstream
No current
material
financial
effects. Anticipated financial effects include
potential litigation claims
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
211
ESRS S4 - Consumers and End Users (continued)
9. Bank of Cyprus Oncology Centre
The Group positively impacts Health & Safety of customers, end-users and Cypriot Society through the Bank of Cyprus Oncology Centre, which represents a partnership
between the public and the private sector. Since its inauguration in 1998, it has served cancer patients and the society. It is also the first hospital in Cyprus and Greece
to receive quality accreditation from Caspe Healthcare Knowledge Systems (CHKS), one of Europe’s hospital accreditation organisation.
Material IRO
ESRS Topic/Sub
-
Topic
IRO Type Description
Entity Specific -
BOC Oncology entre
Impact
Actual
Positive
The Group positively impacts Health & Safety of customers
,
end
-
users and Cypriot Society through the Bank of Cyprus
Oncology Centre, which represents the biggest and most successful partnership between the public and the private
sector.
Time Horizons
Value Chain
Originate or
connected to strategy
Business relationship
Short-Term
Medium
-
Term
Long-Term Own Operations Upstream Downstream
Connected to strategy Operational/Customers/Suppliers
9.1 Policies and actions related to BOC Oncology Centre
Through their efforts, the Centre continues its positive impacts through innovation, research, and patient care. The Centre reinforced medical education and research
through collaborations with the University of Cyprus and St. George’s University of London, offering training to medical students. Additionally, an amount was invested
for research from the A.G. Leventis Foundation which was allocated towards establishing a clinical trials unit, supporting cancer research. The Centre also participated
in multiple European research programs, including EU4Health initiatives, and expanded its digital molecular profiling system, benefiting patients with breast, lung, and
colorectal cancer.
9.2 Metrics and Targets related to BOC Oncology Centre
There is no set measurable, time-bound and outcome-oriented target, however the Group nevertheless track the effectiveness of the above actions through Group’s
Executive and Senior Management being members of the BOC Oncology Centre’s Board. The Group, through annual contribution, 2mn in 2024 and 2mn in 2023,
supports the Centre’s vision and mission. Through the years with the Group's financial support the Oncology Center was able to support cancer patients in Cyprus.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
212
ESRS S4 - Consumers and End Users (continued)
10. Responsible marketing practices and Access to quality information
Material
IROs Consumers and End
-
Users (S4)
ESRS Topic/Sub
-
Topic
IRO
Type
Description
Consumers and end
-
users
-
Social
inclusion of consumers and/or end-
users - Responsible marketing
practices
Risk
Regulatory
Compliance
Non
-
compliance of new products with law and customer related regulations. The Group
introduces a large number of products with different legal or compliance requirements
that need to be assessed by different departments. There is a risk associated with
misselling and non-compliance with the relevant regulations.
Time Horizons
Value Chain
Financial Effects
Short-Term Medium-Term Long-Term Own Operations Upstream Downstream
No
material
current financial effects.
Anticipated financial effects include
fines, penalties, litigations and loss of
business.
ESRS Topic/Sub
-
Topic
IRO
Type
Description
Consumers and end
-
users
-
Social
inclusion of consumers and/or end-
users - Access to (quality)
information
Risk
Data Accuracy
and Integrity
Risk
Data quality remains an inherent risk for the Group resulting from lack of data
validation controls, which might lead to wrong, inaccurate and incomplete data,
system errors in batch processing and absence of data reconciliation controls.
Time Horizons
Value Chain
Financial Effects
Short
-
Term
Medium
-
Term
Long
-
Term
Own
Operations
Upstream
Downstream
No
material
current financial effects.
Anticipated financial effects include
fines, penalties, litigations and loss of
business.
10.1 Policies related to responsible marketing practices
The Group recognises the material risks associated with non-compliance with legal and customer-related regulations during the introduction and management of new
products and services. Given the large number of offerings introduced, each with varying compliance requirements, the potential for misselling or regulatory non-
compliance could lead to significant financial, regulatory, technological, or reputational impacts. To mitigate these risks, the New Products/Services Management Policy
has been established. This policy sets out and addresses key principles for the development of new Products/Services and modification/amendment of existing ones.
Failure to promptly identify, assess and mitigate product risk can have adverse financial, regulatory, technology and/or reputational impact. This policy applies to all
Group entities. In any country or entity where the requirements of applicable legislation, directives or practices establish a higher standard, the corresponding Group
entities must meet those standards. The Board of Directors bears the ultimate responsibility for the effective implementation of the Policy and for setting the right tone
from the top.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
213
ESRS S4 - Consumers and End Users (continued)
10. Responsible marketing practices and Access to quality information (continued)
10.2 Actions related to responsible marketing practices
The New Products/Services procedure provides a framework addressing critical aspects of marketing and product development. This includes a process involving SWOT
analysis, target market identification, testing minimum viable products, conducting product and beta testing, analysing business data, and running marketability tests.
Additional steps include market research, procedures to consider alignment with the Group’s marketing and brand strategy, breakeven analysis, lead capture systems,
lead nurturing, and enhancement of customer experience. Specific controls are set with roles and responsibilities throughout the product lifecycle, particularly during
development and marketing.
Once new products or services receive the necessary approvals, the Corporate Affairs Division (CAD) collaborates with the Product Owner to implement marketing
campaigns that adhere to the Group’s branding and strategic objectives. The objective is that consumers and end-users are provided with reliable, accurate, and high-
quality information.
10.3 Policies and Actions related to access to quality information
To mitigate risks related to data quality, such as incomplete, inaccurate, or poorly validated information, the Group has a Data Quality & Governance Policy. This internal
policy establishes the Group’s standards, controls and guidelines for managing data Governance, Data Organisation, Data Architecture, Data Quality, Data Culture and
Data Security and Compliance integrity across relevant business and technical layers. The policy applies to all applicable data held by the Group. The Board bears the
ultimate responsibility for the effective implementation of the Policy and for setting the right tone from the top. RC reviews and recommends the Policy prior to
submission to the Board and considers that sufficient, dependable, and secure internal procedures are in place to ensure that the Group complies with the policy.
Updates on Data & Report Quality progress / status, as well as level of compliance to BCBS 239 Principles, are submitted to Data Quality & Governance Committee,
Executive Committee and Board through Joint AC & RC once a quarter, or as required. These measures aim to ensure that consumers and end-users are provided with
reliable, accurate, and high-quality information.
10.4 Metrics & Targets related to responsible marketing practices and Access to quality information
The Group has not set a measurable, time-bound and outcome-oriented target on responsible marketing practices and access to quality information, nevertheless the
above risks are monitored through the Risk Appetite Framework procedures. KRIs are embedded in RAS which are monitored through EXCO and RC on a quarterly
basis. The Group conducted, in 2024, training associated with responsible marketing practices (94 hours). Regarding data quality risks, those are monitored on a
quarterly basis through the Data Quality & Governance Committee (DQGC), EXCO and Board.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
214
ESRS G1 - Business Conduct
1. Role of the Board on Business Conduct
The Board’s role, as stated in the Group’s Group Corporate Governance Policy & Framework, is to provide ethical
leadership and promote the Group’s vision, values, culture, and behaviour, within a framework of prudent and
effective controls, which enables risk to be identified, assessed, measured, and managed. The Board sets the
Group's corporate values and high ethical standards of business conduct for itself and all members of the Group
and ensures that its obligations to its shareholders and others are understood and met. Through oversight,
monitoring and review functions, the Board ensures the Group is being run in a sound and prudent manner on a
going concern basis to fulfil its obligations to all majority and minority shareholders while upholding and protecting
the interests of different constituencies.
The Board is responsible to set, approve and oversee the implementation of adequate and effective internal
governance and internal controls framework that includes a clear organisational structure and well-functioning
independent internal risk management, information security, compliance and audit functions that have sufficient
authority, stature and resources to perform their functions and ensures compliance with regulatory requirements
related to the prevention of money laundering. Arrangements adopted to ensure the integrity of the accounting
and financial reporting systems, including financial and operational controls and compliance with the law and
relevant standards.
The Board sets the Group’s strategic objectives and risk appetite to support the strategy; integrates sustainability
into the way business is conducted and should ensure that it is embedded in the Corporate Governance
Framework; ensures that the necessary financial and human resources are in place for the Group to meet its
objectives; ensures that the Group’s purpose, values, strategy and culture are all aligned and reviews
management performance in that regard. In addition, the Board ensures that policies to identify conflicts of
interest are developed and implemented and if these conflicts cannot be prevented, are appropriately managed.
The Board receives reports on, and reviews annually, the effectiveness of the Group’s internal control processes
to support its strategy and objectives in the context of its Risk Appetite.
2. Expertise of the Board on Business Conduct
The Chairperson of the Board is responsible for ensuring the assessment of performance of individual Board
Directors, the Board as a whole and its Committees at least once a year and for preparing and submitting the
evaluation report to the Board. The Chairperson shall have due regard to the Group’s Suitability Policy. Pursuant
to the provisions of the CBC Governance Directive at least every three years an independent external consultant
performs an external review of the (i) composition and (ii) efficiency as well as (iii) effectiveness of the Board
and its Committees having regard to the requirements of the CBC Governance Directive and the EBA Governance
Guidelines, to bring an objective perspective and share leading industry practices. Such external advisors must
be rotated after two consecutive appraisals. The NCGC assesses annually the structure, size, composition,
performance, effectiveness, and diversity of the Board and submits recommendations and initiate the renewal
and replacement processes of the Directors. The Committee also assess the skills, knowledge, and expertise of
the Directors of the Board annually in accordance with the requirements of the EBA Governance Guidelines and
Joint Suitability Guidelines. Details of nature and depth of skills and experience of the Board are submitted to
NCGC for approval each year.
Board members have access to seminars and presentations on aspects of the Group's business activities and
opportunities to familiarise themselves with the Group's strategic plans, enterprise risks, group structure,
compliance programs, Code of Conduct, and corporate governance arrangements. The Company Secretary
prepares an annual training program for the Board, which is submitted to the NCGC for approval. The Board and
Key Function Holders require ongoing training sessions and a continued education program that keeps the Board
and Key Function Holders fluent and up to date regarding rapidly developing topics, which supports the Board
and Key Function Holders maintain the skills, knowledge and competence needed to effectively execute their
responsibilities on an on-going basis.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
215
ESRS G1 - Business Conduct (continued)
3. Description of the processes to identify and assess material impacts, risks and opportunities
The overall process to identify and assess material impacts, risks and opportunities is described in 4. Impacts,
Risks and Opportunities in page 103. Regarding Business Conduct the Group analyses its business structure,
organisational structure, control environment, historic incidents as well as loan portfolio exposures to sectors that
ethics and compliance are considered key issues for the identification of impacts, risks and opportunities. In
identifying and assessing financial materiality, internal stakeholders and internal experts within relevant units
(Fraud Risk Management, Third Party Risk Management, Legal, Regulatory Compliance, Financial Crime &
Sanctions, Compliance and other) provided their opinions and assessments. In identifying and assessing material
impacts the PRB tool was engaged for loans and investment portfolio and assessment was conducted from various
internal stakeholders within the Group.
4. Business conduct policies and corporate culture
The Group’s Corporate Governance Policy and Framework, which is aligned with internationally recognised
standards, including the UK Governance Code, CSE Code, EBA Guidelines on internal governance and CBC Internal
Governance Directive, provides the standards for Business Conduct and Ethical Behaviour across the Group.
BOCH’s approach to business conduct is driven by leadership at the highest levels and firmly rooted in three key
pillars that define how the Group operates:
1. Code of Ethics
The foundation of BOCH’s values, the Code of Ethics guides decision-making by distinguishing right from
wrong. It provides ethical standards and general guidelines to help employees exercise sound judgement
and demonstrate appropriate behaviour in all situations.
2. Code of Conduct
Establishing clear rules, the do’s and don’ts, the Code of Conduct outlines the required and prohibited
practices and behaviours for all employees. Adherence is mandatory, with accountability for any violations
ensuring consistent ethical practices.
3. Policies
Designed to align operations with the expectations of the Board, the Group and stakeholders, the policies
detail the principles, processes and procedures essential for sound Business Conduct.
The Group’s Vision, Mission and Values indicating Group’s commitment to Business Conduct and Ethical
Behaviour.
These pillars, which apply to all employees and Group’s subsidiaries, work together to guide ethical practices into
BOCH’s operations. BOCH offers clear guidance on expected behaviour across all levels of the organisation. The
Code of Ethics and Code of Conduct are readily available to all employees through internal portal and to any
affected stakeholder through Group’s website.
Our Vision
To create lifelong partnerships with our customers, guiding and supporting them in a changing world.
Our Mission
Our organisation exists to support our clients in their most important life events as well as in their daily needs. To achieve
this, we invest capital and effort to ensure that our services are provided by top quality professionals and the usage of
cutting edge technology and uphold sound and ethical practices. We will continue to be not only a systemic bank driving
growth and shareholder value but also a key driver of progress in our community.
Our Values
The following key values comprise the core values of the Bank and the Group.
• Integrity: We are honest, ethical and fair.
• Reliability: We keep our promises and adhere to our word.
• Collaboration: We build lifelong partnerships and work together for a better common future.
Professionalism: We constantly enrich our skills and knowledge, keeping up to date with the developments in our
industry.
• Innovation: We continuously move forward, innovating and improving.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
216
ESRS G1 - Business Conduct (continued)
4. Business conduct policies and corporate culture (continued)
The Board obtains reasonable assurance that there is an ongoing appropriate and effective process in place for
ensuring adherence to the Code of Conduct. Compliance reports are submitted to the AC on such compliance,
noting any instances or material deviation from the standards together with any corrective action taken. The
Group promotes a strong compliance culture by strictly enforcing the Code of Conduct and by taking decisive
disciplinary action where warranted.
The Group’s established and implements policies, which provide additional guidance to support these principles,
the policies associated with material IROs are describes later in the section.
5. Training on Business Conduct
To reinforce employee awareness on Business Conduct policies, the Board and the CEO actively promote a culture
of openness and accountability. Ad-hoc messages from the CEO encourage staff to raise concerns, while training
programs, tailored for all employees and the Board, provide an understanding and awareness of these critical
policies and mechanisms to raise concerns.
During 2024, Business Conduct and compliance related e-learnings, face-to face seminars and trainings were
organised and attended by the Board, Management and employees of the Group as presented in the table below.
All participants had to pass a short assessment course related to the training.
Business Conduct
-
Board of Directors
Training
No of
participants
Training
Hours
Women
Men
Total
AML ESSENTIALS & SANCTIONS
Board
5
0.5
2
2.5
Sanctions
Board
8
2.3
3.8
6.1
Prevention of ML
&
TF
Board
6
0.5
2.5
3
Market Abuse
Board
2
-
1
1
Business Conduct
All Staff
Training
No of
participants
Training
Hours
Women
Men
Total
Antibribery, Whistleblowing, Gifts
Management
564
146.5
149
295
Individual contributors
2,428
790
491.5
1,281.5
AML
Management
518
197.3
165.5
362.8
Individual contributors
2,155
914
455
1,369.5
Business Ethics
Board
10
10
6.5
16.5
Individual contributors
45
35.5
31.5
67
Conflict of interest
Management
6
21
-
21
Individual contributors
39
87.5
49
136.5
Complaints Management
Management
456
104.5
122.5
226.5
Individual contributors
1,925
607
355.5
962.5
Compliance Management
Management
44
57
57.5
114.5
Individual contributors
146
203.5
157.5
361
Fraud Risk Awareness
Management
572
145.5
151.5
297
Individual contributors
2,386
792
469.5
1,261.5
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
217
ESRS G1 - Business Conduct (continued)
5. Training on Business Conduct (continued)
The Group adopted an Induction and Training policy applicable to the Board and Key Function Holders. The policy
aims on continues professional development and ongoing training to ensure the ongoing enhancement of skills,
knowledge and familiarity with the Group’s activities to ensure that they fulfil their roles effectively, and in
accordance with their duties. Regarding rest of the employees there is no specific Training Policy, however during
the annual performance appraisal, a mandatory development plan should be agreed between the appraiser and
the appraisee which includes training towards areas of development which are customised to each employee’s
needs. In addition, each Business Conduct policy specifically states training requirements to employees of the
Group. Refer to the table below.
Business Conduct Policies
-
Training
Business
Conduct Policy
Frequency Target audience Depth of coverage
Group Anti
-
Bribery &
Corruption
This will be reflected in
the relevant policy by
the end of FY2025.
All
employees,
High risk positions,
Recently appointed staff
Anti-Bribery and Corruption
issues, policies, and procedures
Group
Whistleblowing
policy
This will be reflected in
the relevant policy by
the end of FY2025.
Management and
employees
Principles of whistleblowing and
relevant procedures
Group policy
Relating to the
Prevention of
Money Laundering
and Terrorism
Financing
Annually
Management and
employees
Changes in policies / procedures,
new regulatory developments,
identification and reporting of
suspicious transactions
Conflicts of
Interest Group
Policy
Annually
Management and
employees
Matters of conflict of interest, to
build awareness around the topic
and develop the knowledge
around processes and procedures
Group Sanctions
Policy
This will be reflected in
the relevant policy by
the end of FY2025.
All employees,
High risk positions,
Recently appointed staff
Outlines the provisions of this
policy, importance of compliance
with the policy and the
implications of failure
Fraud Risk
Management
Policy
Annually
Compliance
, DPO, HR,
Business Lines, FRM
Department
Fraud related policies, standards
and procedures
6. Whistleblowing system
BOCH established and implements a Whistleblowing Policy, in compliance with the Protection of Persons who
Report Breaches of Union and National Law, Law N. 6(I)/2022, and harmonised with the EU Directive 2019/1937
of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report
breaches of Union law, offering accessible, confidential channels for employees to report violations, unethical
behaviour, or improper practices.
The policy offers multiple reporting channels, including an anomymous telephone line, written submissions via
letters or email to Internal Audit Director or Whistleblowing Champion, and in-person meetings with the Internal
Audit Division upon request. All staff members have a duty to report such concerns and incidents in accordance
with the relevant provisions of the Code of Conduct and Code of Ethics of the Group and this Policy. Reports can
be submitted anonymously or eponymously, ensuring flexibility and comfort for whistleblowers. The Board bears
the ultimate responsibility for the effective implementation of this Policy and setting the right tone from the top.
The Chairperson of the Audit Committee acts as the Whistleblowing Champion and oversees the integrity,
independence and effectiveness of the Group’s policy and procedure on whistleblowing.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
218
ESRS G1 - Business Conduct (continued)
6. Whistleblowing system (continued)
Upon receiving a report, the Internal Audit Division evaluates and prioritises each case based on a preliminary
assessment. Investigations are conducted by the Internal Audit Division, with findings and recommended actions
submitted to the AC and other relevant reporting lines on a need-to-know basis. Investigation outcomes are
shared with the Board through the Annual Audit Report. Records of reports are securely maintained and stored
for as long as necessary, in accordance with the provisions of the Law N.6(I)/2022. If procedural risks are
identified during investigations, recommendations are made to the relevant divisions for improvement. When
breaches involve staff, the Human Resources Division (HRD) initiates disciplinary actions following the Code of
Conduct and Code of Ethics. For sensitive matters, the Corporate Affairs Division manages any potential media
exposure to safeguard the organisation's reputation.
BOCH whistleblowing policy and procedures ensure confidentiality for whistleblowers as permitted by law. If
disclosure of a whistleblower’s identity is legally required, they are informed beforehand. The policy includes anti-
retaliation measures to protect whistleblowers from any form of reprisal, with strict disciplinary action for
violations. Additionally, the Group also protects persons that have been reported, from any negative effect, in
case the investigation results do not justify taking measures against that person.
7. Zero tolerance on Bribery and Corruption
The Group implements an Anti-bribery and Corruption policy which is aligned with international frameworks, such
as the United Nations Convention Against Corruption. The Board bears the ultimate responsibility for the effective
implementation of the Policy and setting the right tone from the top. The Board approves the Policy through AC,
and makes sure that sufficient, dependable, and secure internal procedures are in place to ensure that the Group
complies with the policy and monitors the effective implementation of the Policy through the Control Functions.
Executive Management and Board Members file an annual declaration confirming their compliance with the Anti-
Bribery and Corruption Group Policy. This policy sets out comprehensive system of internal controls, including a
gift registry, conflict-of-interest declarations, approval thresholds, fraud prevention and detection tools, to
mitigate risks in high-exposure functions of the organisation. These functions encompass the Management, Senior
Management, Local Management, and Regional Management. In addition, the Group conducts Due Diligence
procedures in respect of persons who perform or will perform services on its behalf including appointment of
employees or agents, procurement procedures, acceptance of gifts or hospitality, avoid dealing with suppliers
and contractors known or reasonably suspected to pay bribes or involved in corrupt activities. The Group has
procedures in place which enable it to take disciplinary action against personnel who violate the Policy. It could
also result in the relevant person being convicted of a criminal offence and being liable to a fine and/or
imprisonment (depending on the relevant jurisdiction). It is important to note that in the general principles of
this policy, funds, property or facilities of the Group must not be used to provide support for, or contribute to,
any political organization or political candidate and Government and/or public/local authority official interactions
require heightened care, diligence and transparency and a need for appropriate disclosures and prior approvals.
There were no incidents of corruption and bribery in 2024.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
219
ESRS G1 - Business Conduct (continued)
8. Management of relationships suppliers
Material IROs
-
Business Conduct (G1)
ESRS
Topic/Sub-
Topic
IRO Type Description
Business
Conduct -
Management
of
relationships
with
suppliers
Risk
Data Loss &
Outsourcing
& Third-
party Risk
Partial compliance with EBA Guidelines on Outsourcing Arrangements
and/or the Third-Party & Outsourcing Risk Management Policy may
result in weak contracts, over-dependence on a few providers, poor
vendor monitoring, and potentially lower service quality and
continuity. In addition, risks identified associated unauthorised
disclosure of sensitive data by agents/services providers, either
accidentally or maliciously.
Time Horizons Value Chain
Financial Effects
Short-Term
Medium
-
Term
Long-Term
Own
Operations
Upstream Downstream
R
eputational issues,
identity theft, fraud and
regulatory penalties, fines,
increased cost due to
inefficiencies and loss of
business.
BOCH’s Sourcing & Procurement and Vendor Management Policy establishes clear expectations for vendors to
operate responsibly and sustainably, aligning with the Group's dedication to ethical and responsible business
practices. The purpose of this policy is to set the rules governing procurement, upstream value chain. These rules
principally ensure the prevalence of transparency, integrity, fair competition, and accountability throughout the
execution of the process. To this extent, the policy aims to maximize the benefit in terms of expenditure on
products and services, always within a fair, lawful, and ethical framework. Each Divisional or Business Unit
Director is responsible for ensuring that the principles of this policy are implemented by the operations under
control. Tenders Committee maintains the overall responsibility for monitoring the implementation and
effectiveness of this policy. The manager of Sourcing & Procurement is responsible for the maintenance,
institutionalization, and implementation of this policy throughout the Group. Assigns a responsible Sourcing &
Procurement Analyst for each case. Follows up and monitors the execution. The policy is readily available for all
employees in the Group’s internal portal and Group’s website for all stakeholders. As part of Kill Bureaucracy
program stakeholders views are taken into account for setting and enhancing the policy.
All required purchases must follow the provisions of the Group’s Sourcing & Procurement and Vendor Management
process. Received proposals from potential vendors in response to the Group’s corresponding requests, should
not be judged solely based on economic competitiveness, but should be taking into consideration factors such as
the quality of the goods / services (fit to serve the purpose) and the Vendors/Service Providers ability to perform.
Standing by its longstanding commitment to responsible procurements / sourcing, in 2022 the Group has
implemented ZYCUS, the eProcurement system to manage vendor, contracts, and invoices.
Pre-selection process must use defined criteria regarding capacity, capability, consistency, effectiveness,
experience, current or previous cooperation and reciprocity. A structured assessment and, where appropriate,
vendor due diligence must be executed prior to selecting a Vendor/Service Provider. This is done before accepting
any proposal or signing any contract, as a key part of a vendor’s assessment or the tenders’ evaluation where
Privacy Matters are also taken into consideration.
The Procurement Process is aligned with the Group’s ESG strategy as this evolves and provides general principles
that should be adhered to. Additionally, vendors are expected to carry forward these principles to their vendors
and subcontractors. However, the Group is currently considering incorporating the ESG criteria through the
vendor qualification/onboarding process. The Group reserves the right to request from the vendor for any policies,
procedures, or documents that warrants the compliance with these principles. The Group encourages its vendors
to adopt, utilise and provide environmentally friendly technologies, products and services looking to contribute
to the sustainable development of Cyprus and the world and expects from its vendors to adhere to
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
220
ESRS G1 - Business Conduct (continued)
8. Management of relationships suppliers (continued)
all the principles regarding Labor / Human Rights / Ethics, Working Conditions and Health & Safety matters.
Vendors are expected to uphold the highest ethical standards and comply with the principles and values of
transparency, integrity, fair competition, and accountability, in all their exchanges with the Group. They must
abstain from any action that might be linked to conflict of interest, bribery, any form of corruption or financial
crime. The Group expects its vendors to comply with local laws, anti-corruption measures and initiatives that
ensure commercial integrity (refrain from all forms of financial crime, improper or unwarranted payments,
conflicts of interest, fraud, presents, copyright, among others). No confirmed incidents where contracts with
vendors were eliminated or not renewed due to violations related to corruption during 2024. The evaluation of
tenders must be transparent and be using standardised methods based on accepted industry practices. The
integrity of the evaluation weighting structure and criteria must be assured through the employment of necessary
controls before the invitation to tender is issued and maintained as such throughout the process. At the highest
level the proportional rule of 40% to 60% as regards the weight of financial criteria to technical criteria
respectively should apply. The award should always be made by the competent Approving Authority, upon
submission of a detailed proposal (evaluation report) through Group’s Sourcing Procurement & Vendor
Management Policy.
A vendor / service provider is engaged for the supply of goods or services through a legal contract and its
performance is regularly appraised on the basis of meeting their contractual objectives. The Group pays particular
attention to the relationships it forges with its vendors and business partners. In 2024, the Bank continued to
apply its centralised procurement process, while it carried out tenders to purchase products or services or to
outsource services or activities. In order to maintain long term relationships with vendors, the Group:
1) Follows a Qualification (Due Diligence) procedure for vendors
2) Performs Vendor Performance Monitoring through specific templates in accordance with official
procedures and circulars, and reviews results
3) Maintains a Complaints Procedure
4) Offers e-learning sessions to employees and publishes Portal announcements on important provisions of
procedures and circulars
5) Prepares manuals to be used by vendors for new tools and procedures or software
6) Includes certain ESG criteria, where applicable, in RFPs/RFQs, which are evaluated during the evaluation
process by the Business Owners
The Group undertakes necessary actions to incorporate ESG due diligence procedures in the Group's procurement
and vendor management processes. The initiative involves the implementation of an approved platform to extract
ESG scores for vendors. This platform will feature a comprehensive ESG questionnaire, with vendor responses
analysed to derive and validate ESG scores that will be integrated into the Group’s vendor assessment and
selection framework. Scheduled for rollout in 2025, this project underscores Group’s commitment to embedding
formal social and environmental criteria into its operations, ensuring alignment with its long-term sustainability
goals and principles.
By refining its procurement framework and embedding further sustainability into vendor management practices,
the Group is laying the groundwork for ethical, responsible, and sustainable operations.
The Group through the Risk Appetite Statement establishes, annually, certain indicators to monitor risks
associated with Outsourcing arrangements. Specifically, zero number of third-party critical outsourced
arrangements not risk assessed prior to initial signing or renewal.
For details on how privacy and information security risks are mitigated on sourcing arrangement refer to ESRS
S1 – Own Workforce in page 179.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
221
ESRS G1 - Business Conduct (continued)
9. Financial Crime and Fraud
This section concerns the Group’s reporting related to the work conducted to combat financial crime. This section
describes financial crime, defined as money laundering, financing of terrorism, bribery and corruption and fraud.
Bribery and corruption are reported above under Section Zero tolerance on Bribery and Corruption. Group’s work
with cyber security is described in S4. Refer to the following table for the material IROs towards Financial Crime.
Material IROs – Entity Specific
ESRS
Topic/Sub-
Topic
IRO Type Description
Entity
Specific -
Financial
Crime
Risk
Financial
Crime
The risk identified covers situations
which the Group's infrastructure
and services are misused for criminal purposes. In addition, risk was
identified that Group's customers may violate sanctions. External fraud
attempts that may take various forms from phishing and vishing attacks
towards customers, bogus unauthorised payment instructions and card
transactions. These risks lead to increased cost, legal and regulatory
penalties and reputational damage to the Group.
Time Horizons Value Chain
Financial Effects
Short-Term
Medium
-
Term
Long
-
Term
Own
Operations
Upstream Downstream
Increased costs due to fines
and penalties
11. Policies associated with Financial Crime and Fraud
The Group adopted a Policy relating to the Prevention of Money Laundering and Terrorism Financing. The purpose
of this policy is to set the minimum standards and provide general guidance and clarity on Group’s effort to
prevent and suppress money laundering, terrorist financing and other illegal activities and to ensure compliance
with all applicable legal and regulatory requirements. The Group is committed in the fight against money
laundering and terrorism financing and institutes appropriate procedures to comply with relevant legislation,
regulations, guidelines and best practices, and exercises due diligence to deter the use of its services and products
by money launderers and those involved in illegal activities including the financing of terrorism. The policy is
readily available for all employees in the Group’s internal portal and Group’s website for any affected stakeholders.
The policy covers both upstream and downstream value chain.
The main objectives of the principles incorporated in this Policy are to:
1. Take all reasonable steps and exercise Due Diligence to deter the use of Group’s systems and processes by
money launderers and those involved in criminal and illegal activities including the Financing of Terrorism.
2. Avoid violations, since they may result in criminal, civil and regulatory sanctions and/or penalties/fines
imposed.
3. Protect Group’s reputation by protecting the Group and its employees from unfounded allegations of
facilitating Money Laundering and Terrorist Financing.
4. Create a high standard of compliance culture among all the staff across the Group.
The Group through this policy ensures that the legal and regulatory requirements stemming from the provisions
set out in the Law 188(I) 2007, the 5th edition of the Central Bank of Cyprus Directive for the prevention of
Money Laundering and Terrorist financing and the 1st edition of the Central Bank of Cyprus Directive for
Compliance with the Provisions of UN Security Council of the European Union, are addressed.
In addition, the Group adopted a Sanction Policy to manage the risk of customer’s sanction violation. The purpose
of the Policy is to ensure Group’s full compliance with sanctions or restrictive measures imposed on countries,
territories, entities, or specific persons and bodies. The policy is readily available for all employees in the Group’s
internal portal and Group’s website for all stakeholders. The Sanctions Policy outlines the legal and regulatory
requirements/principles emanated from the provisions set out in (a) the Law for the Implementation of the
Provisions of the United Nations (UN) Security Council Resolutions (Sanctions) and the Decisions and Regulations
of the Council of the European Union (EU) Law 58(I) of 2016, and (b) the Central Bank of Cyprus Directive for
Compliance
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
222
ESRS G1 - Business Conduct (continued)
9. Financial Crime and Fraud (continued)
9.1 Policies associated with Financial Crime and Fraud (continued)
with the Provisions of United Nations Security Council Resolutions and the Decisions/Regulations of the Council
of the European Union. In addition to UN, EU sanctions, the Group fully adheres to sanctions imposed by the US
and the UK. The policy covers both upstream and downstream value chain.
The Board bears the ultimate responsibility for the effective implementation of the above-mentioned Policies and
for setting the right tone from the top. The AC makes sure that sufficient, dependable, and secure internal
procedures are in place to ensure that the Group complies with the above-mentioned policies and monitors the
effective implementation of those Policies through the Control Functions. The Internal Audit Division is responsible
for providing independent and objective assurance to the Board, through the AC, and to management, by
assessing the effectiveness of governance, risk management, and control processes related to those policies and
informs the AC of any findings and relevant recommendations.
The Group also adopted a Fraud Risk Management Policy (applicable to activities in both upstream and
downstream) which sets out the appropriate steps to be followed for managing Internal and External Fraud risks
within the Group. The purpose of this Policy is to set out the minimum requirements and basic principles
underlying the governance and management of Fraud Risks in the Group, providing guidelines on the prevention,
detection, investigation, and response of actual (perpetrated) and suspected Fraud. The policy is readily available
for all employees in the Group’s internal portal. The Policy aims to safeguard the Group and internal or external
stakeholders’ interests.
The overall responsibility for approving and monitoring the Group`s strategy and policy for managing Fraud risk
lies with the Board, which exercises this responsibility through the RC. The RC annually reviews the adequacy
and effectiveness of the internal controls system, including areas related to Fraud Risk Management (FRM), based
on data and information produced by the Internal Audit (IA) division, the observations and comments of the
Group’s external auditors and the competent supervisory authorities as well as the assurance provided by the
CEO and make appropriate recommendations to the Board.
9.2 Actions and preventive work associated with Financial Crime and Fraud
The key element of Group’s preventing Financial crime is the Customer Due Diligence. Customer Due Diligence
includes the following:
1) ascertaining the identity of the customer before establishing a business relationship or making a one-off
transaction;
2) establishing the Ultimate Beneficial Owner of legal entities taking particular care on the identification of
the true owners of trusts, foundations, client accounts and other similar entities;
3) building a detailed Economic Profile of the Customer;
4) undertaking Enhanced Due Diligence for High and Significant Risk Customers and transactions;
5) updating the identification data of customers on a regular basis;
6) Detecting suspicious activities/transactions and where appropriate, reporting such activities/transactions
to the local FIU.
The Group also implements specialised software packages for the continuous monitoring of the customers’
accounts, to enable suspicious transactions to be recognised and to maintain procedures for the reporting of such
transactions to the appropriate authorities. The Group through specific procedures and circulars established a
specific process to identify and manage specific, general, sectoral sanctions imposed by the UN, EU, US and the
UK and focused prohibitions on the export / import of commercial and dual-use goods, software and technology
issued by the Council of the European Union, or subject to U.S. jurisdiction under the Export Administration
Regulations sanctions.
The Group established a Fraud Risk Management program with the following main components to identify,
prevent, detect and respond to Fraud Risk:
1. Fraud risk identification and assessment: The risk of Fraud is identified, assessed and monitored in all
activities through established methodologies and processes. Fraud risks are scored and suitably prioritised
for action. The Group identifies inherent Fraud risk through an assessment of incentives, pressures and
opportunities to commit fraud. The Group assess likelihood and potential impact of residual Fraud risk. The
Group responds to reasonably likely, significant fraud risks through identification and implementation of
effective controls or detection procedures for the risks identified.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
223
ESRS G1 - Business Conduct (continued)
9. Financial Crime and Fraud (continued)
9.2 Actions and preventive work associated with Financial Crime (continued)
2. Fraud prevention:
a. Process-level controls: Business lines supported by Fraud Risk Management (FRM) department,
Organisation (OD) and Digital Transformation departments developed and implement appropriate anti-
Fraud control procedures and mechanisms for all relevant business processes that either prevent or
minimise the likelihood and/or the potential impact of Fraudulent Conduct.
b. Transaction level controls: Reviews of third-party and related-party transactions are established
throughout business processes. These controls are driven by appropriate know-your-customer/client
(KYC), know-your-intermediary (KYI) and know-your-staff (KYS) procedures, as well as background
checks on suppliers and business partners, to indicate potential entities that bear higher risk of Fraud.
c. Awareness: Ensure that all employees receive training on Code of Conduct, Fraud trainings as well as
training on any updates or changes on related processes and procedures.
3. Fraud detection:
a. Business process-level mechanisms: Business processes and procedures are designed so that they
accommodate and integrate the systematic identification of the types of Fraud schemes that can be
perpetrated in relation to the specific business process.
b. Key Fraud Indicators: Key Fraud Indicators (KFIs) are established and updated to monitor variables,
which may indicate the possibility of Fraud. Breach of relevant KFIs or adverse trend indications provide
early warning for high-risk Fraud areas and must trigger further assessment of the necessary controls in
that area and the residual risk.
c. Other detection mechanisms: Includes IA reports, periodic reviews by external auditors or regulators
or findings and reports from other expert external business partners.
d. Proactive Fraud detection procedures: Automated data analysis, continuous Monitoring techniques,
and appropriate technology tools to effectively detect Fraudulent Activity
e. Internal Fraud reporting channels: Report fraud incidents to Internal Audit, Compliance or Fraud Risk
Management Department or through whistleblowing channels.
f. Other external reporting channels: Complaint Management system. Refer to page 193.
4. Fraud investigation and response: The Internal Audit Director is responsible for receiving reports of
alleged or suspected internal Fraudulent Conduct involving the Group’s activities or the members of governing
bodies and employees, carry out an investigation of actual or suspected Internal Fraud and report findings to
the AC, as well as the CEO or any other reporting line, on a need-to-know basis.
The above-mentioned actions are ongoing and associated with both upstream and downstream activities. For
Information security and cyber risk management refer in page 179 of ESRS S1 – Own Workforce.
9.3 Metrics and Targets associated with Financial Crime and Fraud
There are no measurable, time-bounded and outcome oriented targets nevertheless there are indicators which
monitors the effectiveness of these actions. The Group through the Risk Appetite Statement establishes certain
qualitative indicators to monitor risks associated with Financial Crime, Sanctions and Fraud risks:
1) No tolerance for violating sanctions or other measures imposed by American Authorities, such as the US
Department of Treasury’s Office of Foreign Assets Control (OFAC), and by the UN, the EU and by the
government of countries that the Group operates in, with respect to violations of AML legislation 39 or
Sanction programs. In case of such deviations, immediate rectification and investigation actions shall be
enacted.
2) No tolerance for deviations with regards to the opening of accounts in US Dollars for persons connected
with countries subject to strict sanctions imposed by the US Department of Treasury’s Office of Foreign
Assets Control (OFAC).
3) No tolerance to facilitating any sort of financial crime/terrorism financing.
The Group, as previously mentioned, ensures relevant trainings are conducted to support mitigation of Financial
Crime risks. Refer to 5. Training on Business Conduct in page 216.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
224
ESRS G1 - Business Conduct (continued)
10. Conflict of Interest
Material IROs
Entity Specific
ESRS
Topic/Sub
-Topic
IRO Type Description
Entity
Specific –
Conflict of
Interest
Risk
Improper
Business
or Market
Practices
Risk of inadequate management of conflict of interest.
Time Horizons Value Chain
Financial Effects
Short-Term
Medium
-Term
Long
-
Term
Own
Operations
Upstream Downstream
Fines, penalties and loss of
business
10.1 Policies on conflict of interest
The Group adopts a Conflict of Interest (COI) policy which sets out the framework for the prevention,
identification, assessment, documentation, escalation, and effective management of COI in compliance with the
legal and regulatory framework to which the Group is subject. This Policy applies to the Members of the Board,
Senior Management, and all employees of the Group in every country the Group operates and to the Group’s
contractors, agents, and other Relevant Persons. The policy is readily available for all employees in the Group’s
internal portal and Group’s website for all stakeholders.
The Board bears the ultimate responsibility for the effective implementation of this Policy and setting the right
tone from the top. The AC makes sure that sufficient, dependable, and secure internal procedures are in place to
ensure that the Group complies with the above-mentioned policies and monitors the effective implementation of
those Policies through the Control Functions. The Internal Audit Division is responsible for providing independent
and objective assurance to the Board, through the AC, and to management, by assessing the effectiveness of
governance, risk management, and control processes related to those policies and informs the AC of any findings
and relevant recommendations.
10.2 Actions and preventive work on conflict of interest
The Group implements procedures to identify the relationships, services, activities, or transactions in which COI
may arise. These procedures cover relationships between the Group and customers, shareholders, Members of
management body and their family members, employees, significant business parties and other related parties.
In addition, these procedures cover COI between different customers of the Group. Board members and Senior
Management self-assess potential conflict of interests annually. All COI identified by Compliance Division across
the Group are documented in a dedicated software and relevant information is presented to the AC and EXCO
quarterly. COI identified at Management Level and Board level are reported to the NCGC for decision-taking. The
above-mentioned actions are ongoing and associated with Group’s own operations.
10.3 Metrics and Targets on conflict of interest
The Group conflicts registry recorded 80 perceived conflicts of interest in 2024 (2023: 135, 2022: 212). Zero
incidents of conflict of interest (2023: 0, 2022: 3) were considered as high, 9 (2023: 9, 2022: 6) were considered
as medium and the remaining 71 (2023: 126, 2022: 203) were considered as low.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
225
ESRS G1 - Business Conduct (continued)
11. Conflict of Interest (continued)
10.3 Metrics and Targets on conflict of interest (continued)
The Group through the Risk Appetite Statement establishes, annually, qualitative statements associated with
the mitigation of Conflict of Interest risks:
1) The Bank has no tolerance for participation in the decision making or voting on matters by persons that
have a conflict of interest.
2) No transactions in BOC securities are tolerated for persons classified as ‘Relevant persons in possession
of inside information for BOC Group’, except in cases where permission is granted under the provisions
of the BOC Dealing code.
3) The Bank has no tolerance for selecting outsourcing service providers, connected to any member of the
Group’s senior management or management body, the Group’s external auditors or legal advisors and
where this information has not been duly disclosed to the Bank.
4) The Bank has no tolerance to acts of bribery and corruption by any of its employees or any business
partner.
The Group, as previously mentioned, ensures relevant trainings are conducted to support mitigation of Conflict-
of-Interest risks. Refer to 5. Training on Business Conduct in page 216.
12. Compliance with Laws and Regulations
Material IROs
Entity Specific
ESRS
Topic/Sub-
Topic
IRO Type Description
Entity
Specific -
Compliance
with Laws
and
Regulations
Risk
Compliance
Risk
As a listed Group which operates in an evolving and complex regulatory
and legal environment there is an increased risk of not compliance with
laws and regulations (such as Arrears Directive, ESG regulations,
MIFID, EMIR, Competition Law, FACTA, Market Abuse, Benchmark
regulations, GDPR) which may lead to fines and penalties.
Time Horizons Value Chain
Financial Effects
Short-Term
Medium
-Term
Long-Term
Own
Operations
Upstream Downstream
Fines, penalties and loss of
business
71
126
203
9
9
6
0
0
3
2024
2023
2022
Perceived conflicts of interests
Low Medium High
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
226
ESRS G1 - Business Conduct (continued)
12. Compliance with Laws and Regulations (continued)
12.1 Policies associated with Compliance with Laws and Regulations
The Group adopted a Compliance policy which sets out the business and legal environment applicable to the
Group, the principles and responsibilities for compliance and how these responsibilities are allocated and carried
out at group and entity level. The policy is readily available for all employees in the Group’s internal portal and
Group’s website for all stakeholders. The policy covers operations at Group level.
The Board bears the ultimate responsibility for the effective implementation of the above-mentioned Policies and
for setting the right tone from the top. The AC makes sure that sufficient, dependable, and secure internal
procedures are in place to ensure that the Group complies with the above-mentioned policies and monitors the
effective implementation of those Policies through the Control Functions. The Internal Audit Division is responsible
for providing independent and objective assurance to the Board, through the AC, and to management, by
assessing the effectiveness of governance, risk management, and control processes related to those policies and
informs the AC of any findings and relevant recommendations.
12.2 Actions and preventive work on Compliance with Laws and Regulations
The Regulatory Compliance Department ensures that the Group adopts all regulatory, legal, and compliance
requirements and is committed to the establishment of relevant controls and procedures to protect its clients and
all other stakeholders. Regulatory compliance implemented, through the network of Compliance Liaisons at the
various Departments, the compliance management system which automated most of the compliance processes.
The system is an integrated compliance management system which provides a comprehensive set of tools for
managing regulatory risks, including modules on regulatory change management with live regulatory feeds on
new or amended regulations, the recording and management of identified risks through various assessment
processes, the recording and management of regulatory incidents, conflicts of interest and gifts, KRIs and the
monitoring and follow up of issues and actions. Additionally, Regulatory Compliance Department regularly
performs compliance assurance reviews based on clear and aligned Compliance Review Methodologies aiming to
cover high risk areas. The Compliance Division presents its Key Risk and Key Performance Indicators to the EXCO
and the AC. Cases of significant non-compliance are identified through the three lines of defence model, whereby
responsibility for compliance reviews lies primarily with management, secondly with the control functions, by
assessing the severity of the instances of non-compliance. The above-mentioned actions are ongoing and
associated with Group’s own operations.
12.3 Metrics and Targets on Compliance with Laws and Regulations
There are no measurable, time-bounded and outcome oriented targets nevertheless there are indicators which
monitors the effectiveness of these actions. We are pleased to note that in the current year, the Group did not
receive any regulatory fines in relation to breaches of compliance with laws and regulations. The Group through
the Risk Appetite Statement establishes, qualitative statements associated with the Compliance Risks and has no
tolerance with regards to non-compliance with regulatory, legal and compliance requirements.
The Group, as previously mentioned, ensures relevant trainings are conducted to support mitigation of
Compliance risks. Refer to 5. Training on Business Conduct in page 216.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
227
ESRS G1 - Business Conduct (continued)
13. Reputational Risk
Material IROs
Entity Specific
ESRS Topic/Sub
-
Topic
IRO Type Description
Entity Specific –
Reputational Risk
Risk
Reputational
Risk
Ineffective handling of reputational risk (at national and
institution level)
Time Horizons Value Chain
Financial
Effects
Short-Term
Medium
-
Term
Long-Term
Own
Operations
Upstream Downstream
L
oss of
business
13.1 Policies associated with Reputational risk
The Group adopted a Reputational Risk Management Policy to provide guidelines on the identification,
quantification and management of reputational risks that might arise from the business activities of the Group.
The overall responsibility for approving, monitoring and managing reputational risk lies with the BOD, which
exercises this responsibility through the Board Risk Committee (BRC). The policy is available for all employees
through internal portal. The engagement of customers on the effectiveness of the policy is measured through
customer’s surveys performed on monthly basis from Corporate Affairs Department. The policy is applicable for
Group’s operations. Internal Audit (IA) provides objective assurance to the AC and to EXCO that the controls in
place are appropriate in relation to this area, by including reputational risk as a primary risk in its Risk and Audit
Universe (RAU) and as such it is assessed as part of the annual update of the Internal Audit Plan.
13.2 Actions and preventive work on Reputational risk
The preventive actions associated with the management of reputational risk are primarily related to the effective
implementation of Code of Ethics, Code of Conduct as well as Business Conduct policies described in sections
above. Identification of reputational risk is primarily conducted through monitoring of media reports for possible
negative press coverage, social media, possible Information/data leaks, Customer complaints, major operational
losses (including legal cases) and key risk indicator breaches, system downtimes causing disruption of customer
service, Negative reports by statutory auditors and investigations, or penalties by regulators, Whistleblowing
reports and other. The Group prevents and reduce the impact of reputational risks through system of internal
process-level and transaction-level controls as described in detail in previous sections.
In case a reputational event has been identified the Corporate Affairs Department in conjunction with Operational
Risk Management Function, assess the impact of the event. Events with low impact are managed and resolved
at this level. For reputational events assessed as High/Critical the Incident Management & Response Team (IMRT)
undertakes to handle the incident. The IMRT convenes to further analyze the severity/impact of the reputational
event and suggest actions to effectively respond to this event. Continuous assessment of the potential impact of
the incident is being carried out throughout the lifecycle of the incident. In cases, whereby the reputational event
is believed to have the potential to escalate to a crisis, the Group Reputational Risk Committee (GRRC) and Crisis
Management and Response Plan are activated. The above-mentioned actions are ongoing and associated with
Group’s own operations.
13.3 Metrics and Targets on Reputational risk
There are no measurable, time-bounded and outcome oriented targets nevertheless there are indicators which
monitors the effectiveness of these actions. The Group has zero tolerance in respect to internal practices by
Management and employees that could lead to material reputational impact, i.e., it will not tolerate headline risk
associated with unacceptable business practices, privacy and other regulatory breaches and internal fraud.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement
228
ESRS G1 - Business Conduct (continued)
14. Process on setting Metrics and Targets on Business Conduct, Financial Crime & Fraud and
Conflict of Interest
The process of setting the above-mentioned qualitative indicators is described in the Risk Appetite Framework of
the Group. The objective of the Risk Appetite Framework (RAF) is to set out the level of risk that the Group is
willing to accept in pursuit of its strategic objectives, outlying the key principles and rules that govern the risk
appetite setting. It comprises the Risk Appetite Statement (RAS), the associated policies and limits where
appropriate, as well as the roles and responsibilities for the implementation and monitoring of the RAF.
The Group has established in RAF qualitative statements to set the overarching risk appetite direction of the
Group across material and critical risk types, articulating also the reasoning behind assuming or avoiding certain
types of risk, and to cover areas that are not fully quantifiable.
The RAS indicators are reported on a quarterly basis via the Risk Profile Report to the EXCO, RC and the Board.
Any interim breaches are assessed with respect to their Tier and breach severity and are reported/escalated to
the appropriate committee/authority. The dashboard is accompanied with a relevant commentary which
indicates:
1. All violations present at the time.
2. The nature of each violation.
3. Whether management has taken or will take remedial steps.
Sustainability Statement - Additional Information 2024
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
230
Contents Page
Disclosure requirements in ESRS covered by the undertaking’s Sustainability
Statement
231
List of disclosure requirements and related data points in cross-cutting and
topical standards that derive from other EU legislation
236
Phase-in provisions and transitional provisions 244
Reporting principles 247
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
231
Disclosure requirements in ESRS covered by the undertaking’s Sustainability Statement
ESRS
Standard
Disclosure
Requirement
Description Page number
General Information
ESRS 2 BP-1
General basis for preparation of sustainability
statement
82
ESRS 2
BP
-
2
Disclosures in relation to specific circumstances
82, 108, 244, 247
ESRS 2 GOV-1
The role of the administrative, management
and supervisory bodies
83
ESRS 2 GOV-2
Information provided to and sustainability
matters addressed by the undertaking’s
administrative, management and supervisory
bodies
84
ESRS 2 GOV-3
Integration of sustainability
-
related
performance in incentive schemes
92
ESRS 2
GOV
-
4
Statement on due
diligence
93
ESRS 2 GOV-5
Risk management and internal controls over
sustainability reporting
94
ESRS 2
SBM
-
1
Strategy, business model and value chain
95
ESRS 2
SBM
-
2
Interests and views of stakeholders
99
ESRS 2 SBM-3
Material impacts, risks and opportunities and
their interaction with strategy and business
model
114
-
117, 157, 163, 177
-
178,
182, 194, 198, 202, 204, 208,
210, 211, 212, 219, 221, 224,
225, 227
ESRS 2 IRO-1
Description of the process to identify and assess
material impacts, risks and opportunities
103
ESRS 2 IRO-2
Disclosure requirements in ESRS covered by the
undertaking’s sustainability statement
231
E1
-
Climate Change
ESRS 2 GOV-3
Integration of sustainability
-
related
performance in incentive schemes
110
ESRS E1
E1
-
1
Transition plan for climate change mitigation
110
ESRS 2 SBM-3
Material impacts, risks and opportunities and
their interaction with strategy and business
model
114
ESRS 2 IRO-1
Description of the processes to identify and
assess material climate-related impacts, risks
and opportunities
122
ESRS E1 E1-2
Policies related to climate change mitigation
and adaptation
132
ESRS 2 MDR-P Policies
Minimum disclosure requirements
Policies
adopted to manage material sustainability
matters
132
ESRS E1 E1-3
Actions and resources in relation to climate
change policies
132
ESRS 2 MDR-A Actions
Minimum disclosure requirements
Actions and
resources in relation to material sustainability
matters
132
ESRS E1 E1-4
Targets related to climate
change mitigation
and adaptation
139
ESRS 2 MDR-M Metrics
Minimum disclosure requirements
Metrics in
relation to material sustainability matters
139
ESRS 2 MDR-T Targets
Minimum disclosure requirements
Tracking
effectiveness of policies and actions through
targets
139
ESRS E1
E1
-
5
Energy consumption and mix
145
ESRS E1
E1
-
6
Gross Scopes 1, 2, 3 and Total GHG emissions
146
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
232
Disclosure requirements in ESRS covered by the undertaking’s Sustainability Statement (continued)
ESRS
Standard
Disclosure
Requirement
Description
Page
number
E2
-
Pollution
ESRS 2 IRO-1
Description of the processes to identify and assess material
climate-related impacts, risks and opportunities
156
ESRS 2 SBM-3
Material impacts, risks and
opportunities and their interaction
with strategy and business model
157
ESRS E2
E2
-
1
Policies related to pollution
158
ESRS 2 MDR-P Policies
Minimum disclosure requirements
Policies adopted to manage
material sustainability matters
158
ESRS E2
E2
-
2
Actions and resources related to pollution
158
ESRS 2 MDR-A Actions
Minimum disclosure requirements
Actions and resources in
relation to material sustainability matters
158
ESRS E2
E2
-
3
Targets related to pollution
161
ESRS 2 MDR-M Metrics
Minimum disclosure requirements
Metrics in relation to
material sustainability matters
161
ESRS 2 MDR-T Targets
Minimum disclosure requirements
Tracking effectiveness of
policies and actions through targets
161
E3
Water and Marine Resources
ESRS 2 IRO-1
Description of the processes to identify and assess material
climate-related impacts, risks and opportunities
162
ESRS 2 SBM-3
Material impacts, risks and opportunities and their interaction
with strategy and business model
163
ESRS E3
E3
-
1
Policies related to water and marine resources
164
ESRS 2 MDR-P Policies
Minimum disclosure requirements
Policies adopted to manage
material sustainability matters
164
ESRS E3
E3
-
2
Actions and resources related to water and marine
resources
164
ESRS 2 MDR-A Actions
Minimum disclosure requirements
Actions and resources in
relation to material sustainability matters
164
ESRS E3
E3
-
3
Targets related to water and marine resources
165
ESRS 2 MDR-M Metrics
Minimum
disclosure requirements
Metrics in relation to
material sustainability matters
165
ESRS 2 MDR-T Targets
Minimum disclosure requirements
Tracking effectiveness of
policies and actions through targets
165
E5
-
Resource Use and Circular Economy
ESRS 2 IRO-1
Description of the processes to identify and assess material
climate-related impacts, risks and opportunities
166
ESRS 2 SBM-3
Material impacts, risks and opportunities and their interaction
with strategy and business model
167
ESRS E5
E5
-
1
Policies related to resource use and circular economy
168
ESRS 2 MDR-P Policies
Minimum disclosure requirements
Policies adopted to manage
material sustainability matters
168
ESRS E5 E5-2
Actions and resources related to resource use and
circular
economy
168
ESRS 2 MDR-A Actions
Minimum disclosure requirements
Actions and resources in
relation to material sustainability matters
168
ESRS E5
E5
-
3
Targets related to resource use and circular economy
170
ESRS 2 MDR-M Metrics
Minimum disclosure requirements
Metrics in relation to
material sustainability matters
170
ESRS 2 MDR-T Targets
Minimum disclosure requirements
Tracking effectiveness of
policies and actions through targets
170
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
233
Disclosure requirements in ESRS covered by the undertaking’s Sustainability Statement (continued)
ESRS
Standard
Disclosure
Requirement
Description
Page
number
S1
-
Own workforce
ESRS 2
SBM
-
2
Interests and views of stakeholders
171
ESRS 2 SBM-3
Material impacts, risks and
opportunities and their interaction with
strategy and business model
171, 177,
182
ESRS S1
S1
-
1
Policies related to own workforce
179, 183
ESRS 2 MDR-P Policies
Minimum disclosure requirements
Policies adopted to manage
material sustainability matters
179, 183
ESRS S1 S1-2
Processes for engaging with own workforce and workers’
representatives about impacts
174
ESRS S1 S1-3
Processes to remediate negative impacts and channels for own
workforce to raise concerns
176
ESRS S1 S1-4
Taking action on material impacts on own workforce, and approaches
to managing material risks and pursuing material opportunities
related to own workforce, and effectiveness of those actions
179, 184
ESRS 2 MDR-A Actions
Minimum disclosure
requirements
Actions and resources in relation
to material sustainability matters
179, 184
ESRS S1 S1-5
Targets related to managing material negative impacts, advancing
positive impacts, and managing material risks and opportunities
180, 187
ESRS 2 MDR-T Targets
Minimum disclosure requirements
Tracking effectiveness of policies
and actions through targets
180, 187
ESRS S1
S1
-
6
Characteristics of the undertaking’s employees
188
ESRS S1
S1
-
8
Collective bargaining coverage and social
dialogue
189
ESRS S1
S1
-
14
Health and safety metrics
183, 185
ESRS S1
S1
-
16
Remuneration metrics (pay gap and total remuneration)
189
ESRS S1
S1
-
17
Incidents, complaints and severe human rights impacts
173
ESRS 2 MDR-M Metrics
Minimum
disclosure requirements
Metrics in relation to material
sustainability matters
180, 183,
185, 187
S4
Consumers and end
-
users
ESRS 2
SBM
-
2
Interests and views of stakeholders
190
ESRS 2 SBM-3
Material impacts, risks and opportunities and their interaction with
strategy and business model
190, 194,
204, 208,
210, 212
ESRS S4 S4-1 Policies related to consumers and end-users
195, 205,
209, 210,
212
ESRS 2 MDR-P Policies
Minimum disclosure requirements – Policies adopted to manage
material sustainability matters
195, 205,
209, 210,
212
ESRS S4
S4
-
2
Processes for engaging with consumers and end
-
users about impacts
192
ESRS S4 S4-3
Processes to remediate negative impacts and channels for
consumers and end-users to raise concerns
193
ESRS S4 S4-4
Taking action on material impacts on consumers and end
-
users, and
approaches to managing material risks and pursuing material
opportunities related to consumers and end-
users, and effectiveness
of those actions
195, 205,
209, 210,
213
ESRS 2 MDR-A Actions
Minimum disclosure requirements –
Actions and resources in relation
to material sustainability matters
195, 205,
209, 210,
213
ESRS S4 S4-5
Targets related to managing material negative impacts, advancing
positive impacts, and managing material risks and opportunities
197, 207,
209, 210,
213
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
234
Disclosure requirements in ESRS covered by the undertaking’s Sustainability Statement (continued)
ESRS Standard
Disclosure
Requirement
Description Page number
S4
Consumers and
end
-
users
(Continued)
ESRS 2 MDR-T Targets
Minimum disclosure requirements
Tracking
effectiveness of policies and actions through targets
197, 207, 209,
210, 213
ESRS 2 MDR-M Metrics
Minimum disclosure requirements
Metrics in relation
to material sustainability matters
197, 207, 209,
210, 213
G1
-
Business Conduct
ESRS 2 GOV-1
The role of the administrative, supervisory and
management bodies
214
ESRS 2 IRO-1
Description of the processes to identify and assess
material impacts, risks and opportunities
215
ESRS 2 SBM-3
Material impacts, risks and opportunities and their
interaction with strategy and business model
219
ESRS G1
G1
-
1
Business conduct policies and corporate culture
215
ESRS 2 MDR-P Policies
Minimum disclosure
requirements
Policies adopted to
manage material sustainability matters
215
ESRS G1
G1
-
2
Management of relationships with suppliers
219
ESRS G1
G1
-
4
Incidents of corruption or bribery
218
ESRS 2 MDR-A Actions
Minimum disclosure
requirements
Actions and
resources in relation to material sustainability matters
219
ESRS 2 MDR-T Targets
Minimum disclosure requirements
Tracking
effectiveness of policies and actions through targets
219
ESRS 2 MDR-M Metrics
Minimum
disclosure requirements
Metrics in relation
to material sustainability matters
219
Entity
-
specific information
BOC Oncology
Centre
MDR-P Policies
Minimum disclosure requirements
Policies adopted to
manage material sustainability matters
211
BOC
Oncology
Centre
MDR-A Actions
Minimum disclosure requirements
Actions and
resources in relation to material sustainability matters
211
BOC Oncology
Centre
MDR-T Targets
Minimum disclosure requirements
Tracking
effectiveness of policies and actions through targets
211
BOC Oncology
Centre
MDR-M Metrics
Minimum disclosure requirements
Metrics in relation
to material sustainability matters
211
Financial Crime
and fraud
MDR-P Policies
Minimum disclosure requirements
Policies adopted to
manage material sustainability matters
221
Financial Crime
and fraud
MDR-A Actions
Minimum disclosure requirements
Actions and
resources in relation to material sustainability matters
222
Financial Crime
and fraud
MDR-T Targets
Minimum disclosure
requirements
Tracking
effectiveness of policies and actions through targets
223, 228
Financial Crime
and fraud
MDR-M Metrics
Minimum disclosure requirements
Metrics in relation
to material sustainability matters
223, 228
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
235
Disclosure requirements in ESRS covered by the undertaking’s Sustainability Statement (continued)
ESRS Standard
Disclosure
Requirement
Description
Page
number
Entity
-
specific information
Conflict of Interest MDR-P Policies
Minimum disclosure
requirements
Policies adopted to
manage material sustainability matters
224
Conflict of Interest MDR-A Actions
Minimum disclosure requirements
Actions and
resources in relation to material sustainability matters
224
Conflict of Interest MDR-T Targets
Minimum disclosure requirements
Tracking
effectiveness of policies and actions through targets
224, 228
Conflict of Interest MDR-M Metrics
Minimum disclosure requirements
Metrics in relation
to material sustainability matters
224, 228
Compliance with laws
and Regulations
MDR-P Policies
Minimum disclosure requirements
Policies adopted to
manage material sustainability matters
225
Compliance with laws
and Regulations
MDR-A Actions
Minimum disclosure requirements
Actions and
resources in relation to material sustainability matters
226
Compliance with laws
and Regulations
MDR-T Targets
Minimum disclosure requirements
Tracking
effectiveness of policies and actions through targets
226, 228
Compliance with laws
and Regulations
MDR-M Metrics
Minimum disclosure requirements
Metrics in relation
to material sustainability matters
226, 228
Reputational Risk MDR-P Policies
Minimum disclosure requirements
Policies adopted to
manage material sustainability matters
227
Reputational Risk MDR-A Actions
Minimum disclosure requirements
Actions and
resources in relation to material sustainability matters
227
Reputational Risk MDR-T Targets
Minimum disclosure requirements
Tracking
effectiveness of policies and actions through targets
227, 228
Reputational Risk MDR-M Metrics
Minimum disclosure requirements
Metrics in relation
to material sustainability matters
227, 228
Digitilisation MDR-P Policies
Minimum disclosure requirements
Policies adopted to
manage material sustainability matters
198, 202
Digitilisation MDR-A Actions
Minimum disclosure requirements
Actions and
resources in relation to material sustainability matters
199, 203
Digitilisation MDR-T Targets
Minimum disclosure requirements
Tracking
effectiveness of policies and actions through targets
200
Digitilisation MDR-M Metrics
Minimum disclosure requirements
Metrics in relation
to material sustainability matters
200
Information Security MDR-P Policies
Minimum disclosure
requirements
Policies adopted to
manage material sustainability matters
195
Information Security MDR-A Actions
Minimum disclosure requirements
Actions and
resources in relation to material sustainability matters
195
Information Security MDR-T Targets
Minimum disclosure requirements
Tracking
effectiveness of policies and actions through targets
197
Information Security MDR-M Metrics
Minimum disclosure requirements
Metrics in relation
to material sustainability matters
197
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
236
List of disclosure requirements and related data points in cross-cutting and topical standards that derive from other EU legislation
Disclosure Requirement and related
datapoint
SFDR reference Pillar 3 reference
Benchmark
Regulation reference
EU
Climate Law
reference
Applicable for the
Group
Page
ESRS 2 GOV-1
Board's gender diversity paragraph 21 (d)
Indicator number
13 of Table #1 of
Annex 1
Commission Delegated Regulation
(EU) 2020/1816 (5) , Annex II
Yes 90
ESRS 2 GOV-1
Percentage of board members who are
independent paragraph 21 (e)
Delegated Regulation
(EU) 2020/1816, Annex II
Yes 89
ESRS 2 GOV-4
Statement on due diligence paragraph 30
Indicator number
10 Table #3 of
Annex 1
Yes 93
ESRS 2 SBM-1
Involvement in activities related to fossil fuel
activities paragraph 40 (d) i
Indicators number 4
Table #1 of Annex 1
Article 449a Regulation (EU)
No 575/2013;
Commission Implementing
Regulation
(EU) 2022/2453 (6) Table 1:
Qualitative information on
Environmental risk and Table
2: Qualitative information on
Social risk
Delegated Regulation
(EU) 2020/1816, Annex II
Not Applicable n/a
ESRS 2 SBM-1
Involvement in activities related to chemical
production paragraph 40 (d) ii
Indicator number 9
Table #2 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Not Applicable n/a
ESRS 2 SBM-1
Involvement in activities related to
controversial weapons paragraph 40 (d) iii
Indicator number
14 Table #1 of
Annex 1
Delegated Regulation
(EU) 2020/1818 (7), Article 12(1)
Delegated Regulation
(EU) 2020/1816, Annex II
Not Applicable n/a
ESRS 2 SBM-1
Involvement in activities related to cultivation
and production of tobacco paragraph 40 (d)
iv
Delegated Regulation
(EU) 2020/1818, Article 12(1)
Delegated Regulation
(EU) 2020/1816, Annex II
Not Applicable n/a
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
237
List of disclosure requirements and related data points in cross-cutting and topical standards that derive from other EU legislation (continued)
Disclosure Requirement and related
datapoint
SFDR reference Pillar 3 reference
Benchmark
Regulation reference
EU
Climate Law
reference
Applicable for the Group Page
ESRS E1-1
Transition plan to reach climate neutrality by
2050 paragraph 14
Regulation
(EU) 2021/1119,
Article 2(1)
Yes 110
ESRS E1-1
Undertakings excluded from Paris-aligned
Benchmarks paragraph 16 (g)
Article 449a
Regulation (EU)
No 575/2013; Commission
Implementing Regulation
(EU) 2022/2453 Template 1:
Banking book-Climate
Change transition risk: Credit
quality of exposures by
sector, emissions and residual
maturity
Delegated Regulation
(EU) 2020/1818,
Article12.1 (d) to (g), and
Article 12.2
Not Applicable n/a
ESRS E1-4
GHG emission reduction targets paragraph
34
Indicator number 4
Table #2 of Annex
1
Article 449a
Regulation (EU)
No 575/2013; Commission
Implementing Regulation
(EU) 2022/2453 Template 3:
Banking book – Climate
change transition risk:
alignment metrics
Delegated Regulation
(EU) 2020/1818, Article 6
Yes 139
ESRS E1-5
Energy consumption from fossil sources
disaggregated by sources (only high climate
impact sectors) paragraph 38
Indicator number 5
Table #1 and
Indicator n. 5 Table
#2 of Annex 1
Not Applicable n/a
ESRS E1-5 Energy consumption and mix
paragraph 37
Indicator number 5
Table #1 of Annex
1
Yes 145
ESRS E1-5
Energy intensity associated with activities in
high climate impact sectors paragraphs 40 to
43
Indicator number 6
Table #1 of Annex
1
n/a n/a n/a
Not Applicable n/a
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
238
List of disclosure requirements and related data points in cross-cutting and topical standards that derive from other EU legislation (continued)
Disclosure Requirement and related
datapoint
SFDR reference Pillar 3 reference
Benchmark
Regulation reference
EU
Climate
Law reference
Applicable for
the Group
Page
ESRS E1-6
Gross Scope 1, 2, 3 and Total GHG emissions
paragraph 44
Indicators number 1
and 2 Table #1 of
Annex 1
Article 449a; Regulation (EU)
No 575/2013; Commission
Implementing Regulation
(EU) 2022/2453 Template 1:
Banking book – Climate
change transition risk: Credit
quality of exposures by
sector, emissions and residual
maturity
Delegated Regulation
(EU) 2020/1818,
Article 5(1), 6 and 8(1)
Yes 152
ESRS E1-6
Gross GHG emissions intensity paragraphs 53
to 55
Indicators number 3
Table #1 of Annex 1
Article 449a Regulation (EU)
No 575/2013; Commission
Implementing Regulation
(EU) 2022/2453 Template 3:
Banking book – Climate
change transition risk:
alignment metrics
Delegated Regulation
(EU) 2020/1818,
Article 8(1)
Yes 153
ESRS E1-7
GHG removals and carbon credits paragraph
56
Regulation
(EU) 2021/1119,
Article 2(1)
Not material n/a
ESRS E1-9
Exposure of the benchmark portfolio to
climate-related physical risks paragraph 66
Delegated Regulation
(EU) 2020/1818,
Annex II Delegated
Regulation
(EU) 2020/1816,
Annex II
Not Applicable –
Phase-in
n/a
ESRS E1-9
Disaggregation of monetary amounts by
acute and chronic physical risk paragraph 66
(a)
ESRS E1-9
Location of significant assets at material
physical risk paragraph 66 (c).
Article 449a Regulation (EU)
No 575/2013; Commission
Implementing Regulation
(EU) 2022/2453 paragraphs
46 and 47; Template 5:
Banking book - Climate
change physical risk:
Exposures subject to physical
risk.
Not Applicable –
Phase-in
n/a
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
239
List of disclosure requirements and related data points in cross-cutting and topical standards that derive from other EU legislation (continued)
Disclosure Requirement and related
datapoint
SFDR reference Pillar 3 reference
Benchmark
Regulation reference
EU
Climate
Law reference
Applicable for
the Group
Page
ESRS E1-9 Breakdown of the carrying value
of its real estate assets by energy-efficiency
classes paragraph 67 (c).
Article 449a Regulation (EU)
No 575/2013; Commission
Implementing Regulation
(EU) 2022/2453 paragraph
34;Template 2:Banking book
-Climate change transition
risk: Loans collateralised by
immovable property - Energy
efficiency of the collateral
Not Applicable –
Phase-in
n/a
ESRS E1-9
Degree of exposure of the portfolio to
climate- related opportunities paragraph 69
Delegated Regulation
(EU) 2020/1818,
Annex II
Not Applicable –
Phase-in
n/a
ESRS E2-4
Amount of each pollutant listed in Annex II of
the E-PRTR Regulation (European Pollutant
Release and Transfer Register) emitted to air,
water and soil, paragraph 28
Indicator number 8
Table #1 of Annex 1
Indicator number 2
Table #2 of Annex 1
Indicator number 1
Table #2 of Annex 1
Indicator number 3
Table #2 of Annex 1
Not material n/a
ESRS E3-1
Water and marine resources paragraph 9
Indicator number 7
Table #2 of Annex 1
Yes 164
ESRS E3-1
Dedicated policy paragraph 13
Indicator number 8
Table 2 of Annex 1
Not material n/a
ESRS E3-1
Sustainable oceans and seas paragraph 14
Indicator number 12
Table #2 of Annex 1
Not material n/a
ESRS E3-4
Total water recycled and reused paragraph 28
(c)
Indicator number
6.2 Table #2 of
Annex 1
Not material n/a
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
240
List of disclosure requirements and related data points in cross-cutting and topical standards that derive from other EU legislation (continued)
Disclosure Requirement and related
datapoint
SFDR reference Pillar 3 reference
Benchmark
Regulation reference
EU
Climate
Law reference
Applicable for
the Group
Page
ESRS E3-4
Total water consumption in m
3
per net
revenue on own operations paragraph 29
Indicator number
6.1 Table #2 of
Annex 1
Not material n/a
ESRS 2- SBM 3 - E4 paragraph 16 (a) i
Indicator number 7
Table #1 of Annex
1
Not material n/a
ESRS 2- SBM 3 - E4 paragraph 16 (b)
Indicator number
10 Table #2 of
Annex 1
Not material n/a
ESRS 2- SBM 3 - E4 paragraph 16 (c)
Indicator number
14 Table #2 of
Annex 1
Not material n/a
ESRS E4-2
Sustainable land / agriculture practices or
policies paragraph 24 (b)
Indicator number
11 Table #2 of
Annex 1
Not material n/a
ESRS E4-2
Sustainable oceans / seas practices or
policies paragraph 24 (c)
Indicator number
12 Table #2 of
Annex 1
Not material n/a
ESRS E4-2
Policies to address deforestation paragraph
24 (d)
Indicator number
15 Table #2 of
Annex 1
Not material n/a
ESRS E5-5
Non-recycled waste paragraph 37 (d)
Indicator number
13 Table #2 of
Annex 1
Not material n/a
ESRS E5-5
Hazardous waste and radioactive waste
paragraph 39
Indicator number 9
Table #1 of Annex
1
Not material n/a
ESRS 2- SBM3 - S1
Risk of incidents of forced labour paragraph
14 (f)
Indicator number
13 Table #3 of
Annex I
Yes 171
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
241
List of disclosure requirements and related data points in cross-cutting and topical standards that derive from other EU legislation (continued)
Disclosure Requirement and related
datapoint
SFDR reference Pillar 3 reference
Benchmark
Regulation reference
EU
Climate
Law reference
Applicable for
the Group
Page
ESRS 2- SBM3 - S1
Risk of incidents of child labour paragraph 14
(g)
Indicator number
12 Table #3 of
Annex I
Yes 171
ESRS S1-1
Human rights policy commitments paragraph
20
Indicator number 9
Table #3 and
Indicator number
11 Table #1 of
Annex I
Yes 172
ESRS S1-1
Due diligence policies on issues addressed by
the fundamental International Labor
Organisation Conventions 1 to 8, paragraph
21
Delegated Regulation
(EU) 2020/1816, Annex II
Yes 172
ESRS S1-1
processes and measures for preventing
trafficking in human beings paragraph 22
Indicator number
11 Table #3 of
Annex I
Yes 172
ESRS S1-1
workplace accident prevention policy or
management system paragraph 23
Indicator number 1
Table #3 of Annex I
Yes 183
ESRS S1-3
grievance/complaints handling mechanisms
paragraph 32 (c)
Indicator number 5
Table #3 of Annex I
Yes 172, 176
ESRS S1-14
Number of fatalities and number and rate of
work-related accidents paragraph 88 (b) and
(c)
Indicator number 2
Table #3 of Annex I
Delegated Regulation
(EU) 2020/1816, Annex II
Yes 185
ESRS S1-14
Number of days lost to injuries, accidents,
fatalities or illness paragraph 88 (e)
Indicator number 3
Table #3 of Annex I
Yes 185
ESRS S1-16
Unadjusted gender pay gap paragraph 97 (a)
Indicator number
12 Table #1 of
Annex I
Delegated Regulation
(EU) 2020/1816, Annex II
Yes 189
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
242
List of disclosure requirements and related data points in cross-cutting and topical standards that derive from other EU legislation (continued)
Disclosure Requirement and related
datapoint
SFDR reference Pillar 3 reference
Benchmark
Regulation reference
EU
Climate
Law reference
Applicable for
the Group
Page
ESRS S1-16
Excessive CEO pay ratio paragraph 97 (b)
Indicator number 8
Table #3 of Annex I
Yes 189
ESRS S1-17
Incidents of discrimination paragraph 103 (a)
Indicator number 7
Table #3 of Annex I
Yes 173
ESRS S1-17 Non-respect of UNGPs on
Business and Human Rights and OECD
Guidelines paragraph 104 (a)
Indicator number 10
Table #1 and
Indicator n. 14 Table
#3 of Annex I
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818 Art 12 (1)
Yes 173
ESRS 2- SBM3 – S2
Significant risk of child labour or forced
labour in the value chain paragraph 11 (b)
Indicators number 12
and n. 13 Table #3 of
Annex I
Not material n/a
ESRS S2-1
Human rights policy commitments paragraph
17
Indicator number 9
Table #3 and
Indicator n. 11 Table
#1 of Annex 1
Not material n/a
ESRS S2-1 Policies related to value chain
workers paragraph 18
Indicator number 11
and n. 4 Table #3 of
Annex 1
Not material n/a
ESRS S2-1Non-respect of UNGPs on Business
and Human Rights principles and OECD
guidelines paragraph 19
Indicator number 10
Table #1 of Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818, Art 12 (1)
Not material n/a
ESRS S2-1
Due diligence policies on issues addressed by
the fundamental International Labor
Organisation Conventions 1 to 8, paragraph
19
Delegated Regulation
(EU) 2020/1816, Annex II
Not material n/a
ESRS S2-4
Human rights issues and incidents connected
to its upstream and downstream value chain
paragraph 36
Indicator number 14
Table #3 of Annex 1
Not material n/a
ESRS S3-1
Human rights policy commitments paragraph
16
Indicator number 9
Table #3 of Annex 1
and Indicator number
11 Table #1 of Annex
1
Not material n/a
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
243
List of disclosure requirements and related data points in cross-cutting and topical standards that derive from other EU legislation (continued)
Disclosure Requirement and related
datapoint
SFDR reference Pillar 3 reference
Benchmark
Regulation reference
EU
Climate
Law reference
Applicable for
the Group
Page
ESRS S3-1
non-respect of UNGPs on Business and
Human Rights, ILO principles or OECD
guidelines paragraph 17
Indicator number
10 Table #1 Annex
1
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818, Art 12
(1)
Not material n/a
ESRS S3-4
Human rights issues and incidents paragraph
36
Indicator number
14 Table #3 of
Annex 1
Not material n/a
ESRS S4-1 Policies related to consumers and
end-users paragraph 16
Indicator number 9
Table #3 and
Indicator number
11 Table #1 of
Annex 1
Yes 191
ESRS S4-1
Non-respect of UNGPs on Business and
Human Rights and OECD guidelines
paragraph 17
Indicator number
10 Table #1 of
Annex 1
Delegated Regulation
(EU) 2020/1816, Annex II
Delegated Regulation
(EU) 2020/1818, Art 12
(1)
Yes 191
ESRS S4-4
Human rights issues and incidents paragraph
35
Indicator number
14 Table #3 of
Annex 1
Yes 191
ESRS G1-1
United Nations Convention against
Corruption paragraph 10 (b)
Indicator number
15 Table #3 of
Annex 1
Not Applicable –
The Group has a
policy
n/a
ESRS G1-1
Protection of whistle- blowers paragraph 10
(d)
Indicator number 6
Table #3 of Annex
1
Not Applicable –
The Group has a
policy
n/a
ESRS G1-4
Fines for violation of anti-corruption and anti-
bribery laws paragraph 24 (a)
Indicator number
17 Table #3 of
Annex 1
Delegated Regulation
(EU) 2020/1816,
Annex II)
Not material n/a
ESRS G1-4
Standards of anti- corruption and anti-
bribery paragraph 24 (b)
Indicator number
16 Table #3 of
Annex 1
Yes 218
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
244
Phase-in provisions and transitional provisions
ESRS
Disclosure
Requirement
Full name of the
Disclosure
Requirement
Phase-in or effective date (including the first year)
BOCH approach in
Phase-in provisions
ESRS 2 SBM-1
Strategy, business
model and value
chain
The undertaking shall report the information prescribed by ESRS 2 SBM
-
1 paragraph
40(b) (breakdown of total revenue by significant ESRS sector) and 40(c) (list of
additional significant ESRS sectors) starting from the application date specified in a
Commission Delegated Act to be adopted pursuant to article 29b(1) third
subparagraph, point (ii), of Directive 2013/34/EU.
Adopted
ESRS 2 SBM-3
Material impacts,
risks and
opportunities and
their interaction with
strategy and business
model
The undertaking may omit the information prescribed by ESRS 2 SBM-3 paragraph
48(e) (anticipated financial effects) for the first year of preparation of its
sustainability statement. The undertaking may comply with ESRS 2 SBM-3 paragraph
48(e) by reporting only qualitative disclosures for the first 3 years of preparation of
its sustainability statement, if it is impracticable to prepare quantitative disclosures.
Adopted
ESRS E1 E1-6
Gross Scopes 1, 2, 3
and Total GHG
emissions
Undertakings or groups not exceeding on their balance sheet dates the average
number of 750 employees during the financial year (on a consolidated basis where
applicable) may omit the datapoints on scope 3 emissions and total GHG emissions
for the first year of preparation of their sustainability statement.
Not eligible
ESRS E1 E1-9
Anticipated financial
effects from material
physical and
transition risks and
potential climate-
related opportunities
The undertaking may omit the information prescribed by ESRS E1- 9 for the first
year of preparation of its sustainability statement. The undertaking may comply
with ESRS E1-9 by reporting only qualitative disclosures for the first 3 years of
preparation of its sustainability statement, if it is impracticable to prepare
quantitative disclosures.
Adopted
ESRS E2 E2-6
Anticipated financial
effects from pollution-
related impacts, risks
and opportunities
The undertaking may omit the information prescribed by ESRS E2- 6 for the first
year of preparation of its sustainability statement. Except for the information
prescribed by paragraph 40 (b) on the operating and capital expenditures occurred
in the reporting period in conjunction with major incidents and deposits, the
undertaking may comply with ESRS E2-6 by reporting only qualitative disclosures,
for the first 3 years of preparation of its sustainability statement
Adopted
ESRS E3 E3-5
Anticipated financial
effects from water
and marine
resources-related
impacts, risks and
opportunities
The undertaking may omit the information prescribed by ESRS E3-5 for the first year
of preparation ofits sustainability statement. The undertaking may comply with
ESRSE3-5 by reporting only qualitative disclosures, for the first 3 years of
preparation of its sustainability statement.
Adopted
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
245
Phase-in provisions and transitional provisions (continued)
ESRS
Disclosure
Requirement
Full name of the
Disclosure
Requirement
Phase-in or effective date (including the first year)
BOCH approach in
Phase-in provisions
ESRS E4
All disclosure
requirements
All disclosure
requirements
Undertakings or groups not exceeding on their balance sheet dates the average
number of 750 employees during the financial year (on a consolidated basis where
applicable) may omit the information specified in the disclosure requirements of ESRS
E4for the first 2 years of preparation of their sustainability statement.
Not material
ESRS E4 E4-6
Anticipated
financial
effects from
biodiversity and
ecosystem-related
impacts, risks and
opportunities
The undertaking may omit the information prescribed by ESRS E4-6 for the first year
of preparation of its sustainability statement. The undertaking may comply with ESRS
E4- 6 by reporting only qualitative disclosures, for the first 3 years of preparation of
its sustainability statement
Not material
ESRS E5 E5-6
Anticipated financial
effects from resource
use and circular
economy-related
impacts, risks and
opportunities
The undertaking may omit the information prescribed by ESRS E5-6 for the first year
of preparation of its sustainability statement. The undertaking may comply with ESRS
E5- 6 by reporting only qualitative disclosures, for the first 3 years of preparation of
its sustainability statement
Adopted
ESRS S1
All disclosure
requirements
All disclosure
requirements
Undertakings or groups not exceeding on their balance sheet dates, the average
number of 750 employees during the financial year (on a consolidated basis where
applicable) may omit the information specified in the disclosure requirements of ESRS
S1for the first year of preparation of their sustainability statement.
Not eligible
ESRS S1 S1-7
Characteristics of
non-employee
workers in the
undertaking’s own
workforce
The undertaking may omit reporting for all data points in this Disclosure Requirement
for the first year of preparation of its sustainability statement.
Adopted
ESRS S1 S1-8
Collective bargaining
coverage and social
dialogue
The undertaking may omit this Disclosure Requirement with regard
to its own
employees in non-EEA countries for the first year of preparation of its sustainability
statement.
Not material
ESRS S1 S1-11 Social protection
The undertaking may omit the information prescribed by ESRS S1-11 for the first
year of preparation of its sustainability statement.
Not material
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
246
Phase-in provisions and transitional provisions (continued)
ESRS
Disclosure
Requirement
Full name of the
Disclosure
Requirement
Phase-in or effective date (including the first year)
BOCH approach in
Phase-in provisions
ESRS
S1
S1-12
Percentage of
employees with
disabilities
The undertaking may omit the information prescribed by ESRS S1-12 for the first
year of preparation of its sustainability statement.
Not material
ESRS
S1
S1-13
Training and skills
development
The undertaking may omit the information prescribed by ESRS S1-13 for the first
year of preparation of its sustainability statement.
Not material
ESRS
S1
S1-14 Health and Safety
The undertaking may omit the datapoints on cases of work-related ill-health and on
number of days lost to injuries, accidents, fatalities and work-related ill health for
the first year of preparation of its sustainability statement.
Not adopted
ESRS
S1
S1-14 Health and Safety
The undertaking may omit reporting on non-employees for the first year of
preparation of its sustainability statement
Adopted
ESRS
S1
S1-15 Work-life balance
The undertaking may omit the information prescribed by ESRS S1-15 for the first
year of preparation of its sustainability statement.
Not material
ESRS
S2
All disclosure
requirements
All disclosure
requirements
Undertakings or groups not exceeding on their balance sheet dates the average
number of 750 employees during the financial year (on a consolidated basis where
applicable) may omit the information specified in the disclosure requirements of ESRS
S2for the first 2 years of preparation of their sustainability statement.
Not eligible
ESRS
S4
All disclosure
requirements
All disclosure
requirements
Undertakings or groups not exceeding on
their balance
sheet dates the average
number of 750 employees during the financial year (on a consolidated basis where
applicable) may omit the information specified in the disclosure requirements of ESRS
S4 for the first 2 years of preparation of their sustainability statement.
Not eligible
Other transitional provisions
BOCH
approach in other transitional provisions
First
-
time application on c
omparative
information
Adopted
Entity specific information
Adopted
First three
-
year v
alue chain
information
Adopted
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
247
Reporting principles
GHG Emission
The carbon footprint for Scope 1, Scope 2 and material Scope 3 categories were estimated based on the
methodologies described in the Greenhouse Gas Protocol and ISO14064-1:2019 standard.
i. For the purpose of the calculation of its 2023 and 2024 carbon footprint, the Group uses the operational
GHG accounting approach.
ii. The Group considers the GHG protocol guidance, a Corporate Accounting and Reporting Standard, Revised
Edition (the GHG Protocol) for its Scope 1, 2 and 3 emissions calculations and guidance from PCAF, when
calculating its financed emissions.
iii. The gases estimated and presented as in tones of CO
2
e where the calculations consist of are
2
, CH
4
,
and N
2
O gases.
iv. The Group utilises the PCAF database and standard for the estimation of Financed Scope 3 GHG emissions
associated with Business Loans, Motor Vehicles, CREs, Mortgages, Corporate Bonds and Sovereign Bonds
as well as Insurance associated GHG emissions. For other asset classes the Group adopted the transitional
provision in relation to the entity specific information and therefore, has not included other asset classes
within the disclosures.
v. The Group uses the most updated available emission factors for the estimations of 2024 and 2023,
utilizing the UK Department for Environment, Food and Rural Affairs (DEFRA) and US Environmental
Protection Agency (EPA) emission factor databases.
vi. The Group has not entered in any power purchase agreement therefore, market-based Scope 2 GHG are
not estimated. The Group reports only location-based Scope 2 GHG emissions.
vii. Gross Scope 1, 2, 3 GHG emissions do not include any removals, or any purchased, sold or transferred
carbon credits or GHG allowances in the calculation.
viii. The Group has not been involved in any Emission Traded Scheme (ETS) until reporting date.
ix. The most recent Global Warming Potential (GWP) values published by the IPCC based on a 100 year time
horizon have been used to estimate CO2
e
emission of non-CO
2
gases.
x. The Group’s GHG emissions comprise of GHG emissions of BOC PLC, Eurolife, Genikes Insurance, CISCO
and Jinius.
The estimation of GHG emissions involves assumptions and proxy data. The methodology applied, assumptions
used and sources to estimate GHG emissions are summarized below:
Scope 1
i. The Group’s direct (Scope 1) GHG emissions come from sources owned or controlled by the Group and
include stationary combustion, mobile combustion and fugitive emissions.
i. In line with the GHG Protocol, the Group's emissions are presented in tonnes of carbon dioxide equivalent
units (tCO
2
e) and include carbon dioxide (CO
2
), methane (CH4) and nitrous oxide (N
2
O).
ii. The factors used for estimation of Scope 1 emissions are:
a. Mobile Combustion: EPA 2024 and 2023 conversion factors (kg CO
2
e/ L) for diesel and gasoline
passenger cars, gasoline motorcycles, diesel and gasoline light duty trucks and hybrid (gasoline)
passenger cars. Emissions are estimated by multiplying the total consumption in litres per fuel
category with the EPA 2024 conversion factors.
b. Stationary Combustion: DEFRA 2024 and 2023 conversion factors (kg CO
2
e/ kWh) for diesel
(average biofuel blend) and gas oil, in line with applicable GWP (AR5). Emissions are estimated
by multiplying the total kWh per fuel type with the DEFRA conversion factors.
c. Refrigerants: DEFRA 2024 and 2023 conversion factors were used to estimate the emissions
from refrigerants leakage.
Scope 2
i. The Group’s Scope 2 GHG emissions represent consumption of purchased electricity. The Group does not
consume purchased or acquired steam, heating and cooling.
ii. In line with the GHG Protocol, the Group's emissions are presented in tonnes of carbon dioxide equivalent
units (tCO
2
e) and include carbon dioxide (CO
2
), methane (CH4) and nitrous oxide (N
2
O).
iii. Bio-based CO₂ emissions are not considered significant for the Group's Scope 2 emissions.
iv. Electricity Authority of Cyprus (EAC) emission factor, based on Cyprus energy mix, was used for the
calculation of Scope 2 GHG emissions (location-based). Currently, Scope 2 GHG emissions are based on
EAC emission factor for 2023 as the EAC emission factor for 2024 has been published.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
248
Reporting principles (continued)
GHG Emission (continued)
Scope 3
i. A materiality assessment was conducted to identify the material emission categories relative to the
Group’s business model, activities and processes so to estimate the most significant categories of indirect
Scope 3 GHG emissions. By performing desktop benchmark analysis and analyzing data from peers,
international reports and industry sector standards, the Group identified which of the 15 categories, as
identified by GHG protocol, are significant for the Group.
ii. In line with the GHG Protocol, the Group's emissions are presented in tonnes of carbon dioxide equivalent
units (tCO
2
e) and include carbon dioxide (CO
2
), methane (CH4) and nitrous oxide (N
2
O).
Category 1 - Purchased Good and Services
The Group utilises PCAF’s proxies tCO
2
per million of revenue (), per sector, for Cyprus to estimate GHG emission
under Category 1. The Group’s expense amount as per Trial Balance account was classified to relevant sector
and the associated emission factor was multiplied to derive GHG emissions.
Category 4 - Upstream transportation and distribution
The Group utilises PCAF’s proxies tCO
2
per million of revenue (), per sector, for Cyprus to estimate GHG emission
under Category 4. The Group’s expense amount as per Trial Balance account was classified to relevant sector
and the associated emission factor was multiplied to derive GHG emissions.
Category 5 - Waste generated in operations
The Group utilises online available sources to estimate the waste, per material, based on Group’s employee
headcount at the end of the reporting period. DEFRA emission factors (kgCO
2
e/ ton of waste activity) for 2024
and 2023 were multiplied with the waste volume to estimate GHG emissions under Category 5.
Category 6 - Business Travel
The Group collects data of business travelling (inland and abroad including air travel and accommodation) using
internal process and the Group’s systems. Air travel GHG emissions are estimated by multiplying distance
travelled (in kilometers) with EPA emissions factors for short, medium and long hauls. Inland travelling emissions
are estimated by multiplying distance travelled (in kilometers) by DEFRA emission factors (diesel and petrol
average vehicles). Hotel accommodation emissions are estimated by multiplying nights of hotel accommodation
by DEFRA emissions factors for hotel stay (kgCO
2
e/ Room per night).
Category 7 - Employee commuting
The Group conducts annually internal questionnaire to collect data regarding employee commuting (vehicle type,
fuel type, distance travelled). The GHG emissions of Category 7 were estimated by multiplying the distance
commuted (in kilometers) by DEFRA emission factors (kgCO
2
e/ km).
Category 15 - Financed Emissions
Category 15: Investments’ covers emissions associated with operation of investments (including equity and debt
investments and project finance) in the reporting year. This is considered the most material category for the
Group and relates to its lending activities. The estimation of financed emissions covers lending customers assets
and companies’ Scope 1, Scope 2 and Scope 3 emissions. The PCAF Standard defines these as follows:
i. Scope 1 of the lending customer: Direct GHG emissions that occur from sources owned or controlled
by the customer, i.e. emissions from combustion in owned or controlled boilers, furnaces, vehicles, etc.
ii. Scope 2 of the lending customer: Indirect GHG emissions from the generation of purchased or
acquired electricity, steam, heating or cooling consumed by the customer. Scope 2 emissions physically
occur at the facility where the electricity, steam, heating or cooling is generated.
iii. Scope 3 of the lending customer: All other indirect GHG emissions (not included in Scope 2) that occur
in the value chain of the customer. Scope 3 can be broken down into upstream emissions and downstream
emissions. Upstream emissions include all emissions that occur in the lifecycle of a material / product /
service up to the point of sale by the producer, such as from the production or extraction of purchased
materials. Downstream emissions include all emissions that occur because of the distribution, storage,
use and end-of-life treatment of the organisation’s products or services.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
249
Reporting principles (continued)
GHG Emission (continued)
Category 15 - Financed Emissions (continued)
The PCAF Standard applies the same general attribution principles across all lending asset classes:
i. financed emissions are always calculated by multiplying an attribution factor (specific to that asset class)
by the emissions of the borrower or asset;
ii. the attribution factor is defined as the share of total annual GHG emissions of the borrower or asset that
is allocated to the loan(s) or asset(s);
iii. the attribution factor is calculated by determining the share of the outstanding amount of loans of a
financial institution over:
a. the company value (total equity and debt of the company, project, etc.) to which the financial
institution has lent money to; or
b. the asset value in the case of asset finance (such as for properties, motor vehicles etc).
The PCAF standard provides detailed methodological guidance to measure and disclose GHG emissions associated
with six asset classes: listed equity and corporate bonds, business loans and unlisted equity, project finance,
commercial real estate, mortgages, and motor vehicle loans. The Group measures the financed emissions
associated with the following asset classes adopting the entity specific disclosure transitional provision.
1. Asset Class - Business Loans
Financed GHG emissions (tCO
2
e) for non-financial and other financial loan portfolio are estimated using the
following formula:
𝐹𝑖𝑛𝑎𝑛𝑐𝑒𝑑 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 =
𝑂𝑢𝑡𝑠𝑡𝑎𝑛𝑑𝑖𝑛𝑔 𝑎𝑚𝑜𝑢𝑛𝑡
𝐸𝑞𝑢𝑖𝑡𝑦 + 𝐷𝑒𝑏𝑖𝑡 𝑜𝑟 𝑇𝑜𝑡𝑎𝑙 𝑎𝑠𝑠𝑒𝑡𝑠
𝑥 𝐶𝑜𝑚𝑝𝑎𝑛𝑦𝑠 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠
Exposures classified as CRE or Motor vehicles under the non-financial and other financial portfolio were excluded
from the estimation under the Business loan asset class as those are estimated separately.
Data Inputs:
i. Outstanding amount: Relates to the gross carrying amount as of 31 December 2024 and 31 December
2023 from Group’s FINREP reporting system.
ii. Customer’s equity and debt are not readily available in the Group’s database, therefore the total assets
were used to estimate financed emissions. The Group, given the lack of customer’s emission data, utilized
the PCAF emission factors per sector, per million of total assets, for Cyprus. The emission factors were
multiplied with outstanding amount to estimate GHG emissions. The Group introduced the ESG Due
Diligence process aiming to enhance the emission data in the future.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
250
Reporting principles (continued)
GHG Emission (continued)
Category 15 - Financed Emissions (continued)
2. Asset Class - Residential Portfolio (Mortgages)
The estimation covers the absolute scope 1 and 2 emissions related to the energy use of the property financed
through the mortgage (energy use includes the energy consumed by the building occupant).
Residential (Mortgage) portfolio financed emissions (tCO
2
e) are estimated using the formula from the PCAF
standard (Chapter 5.5 Mortgages):
𝐹𝑖𝑛𝑎𝑛𝑐𝑒𝑑 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 =
𝑂𝑢𝑡𝑠𝑡𝑎𝑛𝑑𝑖𝑛𝑔 𝑎𝑚𝑜𝑢𝑛𝑡
𝑃𝑟𝑜𝑝𝑒𝑟𝑡𝑦 𝑣𝑎𝑙𝑢𝑒 𝑎𝑡 𝑜𝑟𝑖𝑔𝑖𝑛𝑎𝑡𝑖𝑜𝑛
𝑥 𝐵𝑢𝑖𝑙𝑑𝑖𝑛𝑔𝑠 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠
Data inputs:
i. The outstanding amount relates to the Gross Carrying Amount as of 31 December 2024 and 31
December 2023 as obtained from the Group FINREP reporting system.
ii. Due to the fact that details of the financed property (market value, floor size, year of built) are not
currently available in the Group’s database, the collateral property details associated with each loan were
utilized assuming that collateral property with priority 1 collateral is the financed property which aligned
with the principles of the Lending Policy.
iii. PCAF allows, in case the property value at origination is not available, the latest property value to be
used. The Group used the latest value of collateral property to estimate the attribution factor. In case the
latest property value was not available as well, the loan original amount was used to estimate the
attribution factor following communication with PCAF.
iv. Building’s Emissions:
a. Square metres: Obtained from Cyprus Department of Land and Surveys (DLS), by connecting
the collateral property to the DLS register.
b. Year built: Obtained from Cyprus Department of Land and Surveys (DLS), by connecting the
collateral property to the DLS register.
c. Energy Performance Certificate (EPC): EPC was obtained from the Cyprus Government’s EPC
database or directly through loan origination process documentation and stored in Group’s
database.
d. For properties with no year built and loan account open date at least two years from the reporting
date, no emissions were estimated as those properties were assumed to be under construction,
which are not within PCAF standard’s scope.
e. PCAF proxies utilised, in case actual EPC data was not available, for residential properties:
i. Average Cyprus residential property proxies per EPC Category, per property;
ii. Average Cyprus residential property proxies per EPC Category, per square metres;
iii. Average Cyprus residential property proxy.
f. Based on data available, per loan account, the financed property emissions were estimated and
multiplied with attribution factor.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
251
Reporting principles (continued)
GHG Emission (continued)
Category 15 - Financed Emissions (continued)
3. Commercial Real Estate (CRE) portfolio
For property already built, financial institutions shall cover the absolute scope 1 and 2 emissions related to the
energy use of financed buildings during their operation. Energy use includes the energy consumed by the
building’s occupant and shared facilities.
CRE portfolio financed emissions (tCO
2
e) are estimated using the formula from the PCAF standard (Chapter 5.4
Commercial Real Estate):
𝐹𝑖𝑛𝑎𝑛𝑐𝑒𝑑 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 =
𝑂𝑢𝑡𝑠𝑡𝑎𝑛𝑑𝑖𝑛𝑔 𝑎𝑚𝑜𝑢𝑛𝑡
𝑃𝑟𝑜𝑝𝑒𝑟𝑡𝑦 𝑣𝑎𝑙𝑢𝑒 𝑎𝑡 𝑜𝑟𝑖𝑔𝑖𝑛𝑎𝑡𝑖𝑜𝑛
𝑥 𝑃𝑟𝑜𝑝𝑒𝑟𝑡𝑦𝑠 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠
Data inputs:
i. The outstanding amount relates to the Gross Carrying Amount as of 31 December 2024 and 31
December 2023 as obtained from the Group FINREP reporting system.
ii. Due to the fact that details of the financed property (market value, floor size, year of built) are not
currently available in the Group’s database, the collateral property details associated with each loan were
utilized assuming that collateral property with priority 1 collateral is the financed property which aligned
with the principles of the Lending Policy.
iii. PCAF allows, in case the property value at origination is not available, the latest property value to be
used. The Group used the latest value of collateral property to estimate the attribution factor. In case the
latest property value was not available as well, the loan original amount was used to estimate the
attribution factor following communication with PCAF.
iv. Building’s Emissions
a. Square metres: Obtained from Cyprus Department of Land and Surveys (DLS), by connecting
the collateral property to the DLS register.
b. Year built: Obtained from Cyprus Department of Land and Surveys (DLS), by connecting the
collateral property to the DLS register.
c. Energy Performance Certificate (EPC): EPC was obtained from the Cyprus Government’s EPC
database or directly through loan origination process documentation and stored in Group’s
database. Trivial number of EPC were gathered for CREs.
d. PCAF proxies utilized for CREs:
i. Average Cyprus proxies per EPC Category, per property type;
ii. Average Cyprus proxies per EPC Category, per square metres, per property type;
iii. Average Cyprus non-residential property proxy.
e. Based on data available, per loan account, the financed property emissions were estimated and
multiplied with attribution factor.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
252
Reporting principles (continued)
GHG Emission (continued)
Category 15 - Financed Emissions (continued)
4. Motor Vehicles Portfolio
The Group estimated the scope 1 and scope 2 emissions of the vehicles being financed:
i. Scope 1: Direct emissions from fuel combustion in vehicles
ii. Scope 2: Indirect emissions from electricity generation consumed in electric vehicles (EVs) (hybrid and
fully EVs)
Motor Vehicles portfolio financed emissions (tCO
2
e) are estimated using the formula from the PCAF standard
(Chapter 5.6 Motor Vehicle Loans):
𝐹𝑖𝑛𝑎𝑛𝑐𝑒𝑑 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 = Σ
𝑂𝑢𝑡𝑠𝑡𝑎𝑛𝑑𝑖𝑛𝑔 𝑎𝑚𝑜𝑢𝑛𝑡
𝑇𝑜𝑡𝑎𝑙 𝑣𝑎𝑙𝑢𝑒 𝑎𝑡 𝑜𝑟𝑖𝑔𝑖𝑛𝑎𝑡𝑖𝑜𝑛
𝑥 𝑉𝑒𝑖𝑐𝑙𝑒𝑠 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠
Data Inputs:
i. The outstanding amount relates to the Gross Carrying Amount as of 31 December 2024 and 31
December 2023 as obtained from the Group FINREP reporting system.
ii. PCAF allows, in case the property value at origination is not available, the latest vehicle value to be
used. The Group used the latest value of collateral to estimate the attribution factor given that the
collateral vehicle is in the majority of cases the financed vehicle. In case the latest property value was
not available as well, the loan original amount was used to estimate the attribution factor following
communication with PCAF.
iii. Vehicle emissions:
a. Vehicles type (passenger, heavy truck etc.) was obtained from the collateral database.
b. PCAF proxies utilized for CREs:
i. Average Cyprus proxies per year ((kgCO
2
e/ year)
c. For exposures with no collaterals the Group used an internal proxy using the emissions estimated
for the Motor vehicle portfolio with vehicle type data at collateral level.
5. Corporate Bonds
This asset class includes all on-balance sheet listed corporate bonds that are traded on a market and are for
general corporate purposes (i.e., unknown use of proceeds as defined by the GHG Protocol).
The Group does not estimate the emissions from corporate bonds issued by Supranational companies due to lack
of data availability except in cases were public data is available.
The Group reports Scope 1, Scope 2 and Scope 3 GHG emissions of corporate bonds using PCAF standard and
proxies.
Corporate bond portfolio financed emissions (tCO
2
e) are estimated using the formula from the PCAF standard
(Chapter 5.1 Listed equity and corporate bonds):
For listed companies:
𝐹𝑖𝑛𝑎𝑛𝑐𝑒𝑑 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 = Σ
𝑂𝑢𝑡𝑠𝑡𝑎𝑛𝑑𝑖𝑛𝑔 𝑎𝑚𝑜𝑢𝑛𝑡
𝐸𝑛𝑡𝑒𝑟𝑝𝑟𝑖𝑠𝑒 𝑉𝑎𝑙𝑢𝑒 𝐼𝑛𝑐𝑙𝑢𝑑𝑖𝑛𝑔 𝐶𝑎𝑠ℎ (𝐸𝑉𝐼𝐶)
𝑥 𝐶𝑜𝑚𝑝𝑎𝑛𝑦𝑠 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠
For bonds to private companies:
𝐹𝑖𝑛𝑎𝑛𝑐𝑒𝑑 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 = Σ
𝑂𝑢𝑡𝑠𝑡𝑎𝑛𝑑𝑖𝑛𝑔 𝑎𝑚𝑜𝑢𝑛𝑡
𝑇𝑜𝑡𝑎𝑙 𝑒𝑞𝑢𝑖𝑡𝑦 + 𝑑𝑒𝑏𝑡 𝑜𝑟 𝑇𝑜𝑡𝑎𝑙 𝑎𝑠𝑠𝑒𝑡𝑠
𝑥 𝐶𝑜𝑚𝑝𝑎𝑛𝑦𝑠 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠
Data Inputs:
i. The outstanding amount as of 31 December 2024 and 31 December 2023 obtained from the Group
FINREP reporting system.
ii. The EVIC, Total equity + debt and the emissions of corporates are not currently available in the Group’s
database. Therefore, the Group applies total assets for the estimation of financed emissions.
iii. Company’s emissions: The Group utilizes PCAF proxies, CO
2
per million of euro of total assets, per
industry and per County to estimate the financed emissions associated with Corporate Bond portfolio.
The outstanding amount was multiplied with the PCAF proxies to estimate financed emissions.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
253
Reporting principles (continued)
GHG Emission (continued)
Category 15 - Financed Emissions (continued)
6. Sovereign Bonds
This asset class includes sovereign bonds and sovereign loans of all maturities issued in domestic or foreign
currencies. Sovereign debt is typically issued by the central government or treasury.
The Group reports gross Scope 1, domestic emissions from sources located within the country territory.
Sovereign bond portfolio financed emissions (tCO
2
e) are estimated using the formula from the PCAF standard
(Chapter 5.7 Sovereign Debt):
𝐹𝑖𝑛𝑎𝑛𝑐𝑒𝑑 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 =
𝐸𝑥𝑝𝑜𝑠𝑢𝑟𝑒 𝑡𝑜 𝑆𝑜𝑣𝑒𝑟𝑒𝑖𝑔𝑛 𝐵𝑜𝑛𝑑 (𝑈𝑆𝐷)
𝑃𝑃𝑃 𝑎𝑑𝑗𝑢𝑠𝑡𝑒𝑑 𝐺𝐷𝑃 (𝐼𝑛𝑡𝑒𝑟𝑛𝑎𝑡𝑖𝑜𝑛 𝑈𝑆𝐷)
𝑥 𝑆𝑜𝑣𝑒𝑟𝑒𝑖𝑔𝑛 𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 (𝑡𝐶𝑂2𝑒)
Data inputs:
i. Exposure to Sovereign Bond as of 31 December 2024 and 31 December 2023 obtained from the Group
FINREP reporting system.
ii. Purchasing power parity adjusted GDP is obtained from World Bank (latest available data relate to
2023).
iii. Sovereign emissions obtained from the GHG Profiles per Country United Nations Climate Change
Convention (UNFCCC) (latest available data relate to 2021).
An emission factor was created using the PPP- adjusted GDP (International USD) of 2021 and Country emission
inventory which was applied to the exposure as at 31 December 2024.
7. Insurance-Associate GHG emissions
The Group applies the PCAF methodology and proxies to estimate the insurance associated GHG emissions
resulting from the general insurance contracts issued by the Group. PCAF provides guidance on the estimation of
emission on certain lines of business. Specifically, Commercial lines and Personal motor lines portfolios.
Insurance contracts - Commercial line portfolios
Commercial line portfolio emissions (tCO
2
e) are estimated using the formula from the PCAF standard (Insurance-
Associated emissions Chapter 5.2 Emissions associated with commercial lines portfolios):
𝐼𝑛𝑠𝑢𝑟𝑎𝑛𝑐𝑒 𝑎𝑠𝑠𝑜𝑐𝑖𝑎𝑡𝑒𝑑 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 =
𝐼𝑛𝑠𝑢𝑟𝑎𝑛𝑐𝑒 𝑝𝑟𝑒𝑚𝑖𝑢𝑚
𝐶𝑢𝑠𝑡𝑜𝑚𝑒𝑟 𝑟𝑒𝑣𝑒𝑛𝑢𝑒
𝑥 𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠
Data Inputs:
i. The Insurance premium for the year ended 31 December 2024 obtained from the Group’s reporting
system.
ii. The customer’s revenue and emissions are not available in the Group’s database. Therefore, the PCAF
proxy per customer’s revenue, per sector was utilized to estimate customer’s emissions (PCAF proxy
multiplied by customer’s revenue), leading to the following equation to estimate insurance associated
GHG emissions.
𝐼𝑛𝑠𝑢𝑟𝑎𝑛𝑐𝑒 𝑎𝑠𝑠𝑜𝑐𝑖𝑎𝑡𝑒𝑑 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 = 𝐼𝑛𝑠𝑢𝑟𝑎𝑛𝑐𝑒 𝑝𝑟𝑒𝑚𝑖𝑢𝑚 𝑥 𝑃𝐶𝐴𝐹 𝑝𝑟𝑜𝑥𝑦
The following table summarizes the lines that, at the moment, are out of scope of PCAF standard.
Segment
Line of Business (LoBs)
Commercial insurance
Structured trade credit
Surety
Engineering lines: Construction all
-
risk, erection all
-
risk only
Corporate life and pensions, personal accident
Personal lines
Liability
Property
Travel assistance
Life and Health
Treaty reinsurance
All LoBs
F
acultative reinsurance
All LoBs
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Sustainability Statement - Additional Information
254
Reporting principles (continued)
GHG Emission (continued)
Category 15 - Financed Emissions (continued)
7. Insurance-Associate GHG emissions (continued)
Insurance contracts – Motor line portfolios
The Group estimated and reports the insurance-associated GHG emissions of the annual emissions of the vehicles
being insured as:
i. Scope 1: Direct emissions from fuel combustion in vehicles;
ii. Scope 2: Indirect emissions from electricity generation consumed in plug-in hybrid vehicles and electric
vehicles.
Personal motor line portfolio emissions (tCO
2
e) are estimated using the formula from the PCAF standard
(Insurance-Associated emissions Chapter 5.3 Emissions associated with personal motor portfolios):
𝐼𝑛𝑠𝑢𝑟𝑎𝑛𝑐𝑒 𝑎𝑠𝑠𝑜𝑐𝑖𝑎𝑡𝑒𝑑 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠
=
𝐼𝑛𝑠𝑢𝑟𝑎𝑛𝑐𝑒 𝑖𝑛𝑑𝑢𝑠𝑡𝑟𝑦
𝑠 𝑡𝑜𝑡𝑎𝑙 𝑝𝑟𝑒𝑚𝑖𝑢𝑚 𝑓𝑟𝑜𝑚 𝑡𝑒 𝑚𝑜𝑡𝑜𝑟 𝑙𝑖𝑛𝑒 𝑜𝑓 𝑏𝑢𝑠𝑖𝑛𝑒𝑠𝑠
𝑇𝑜𝑡𝑎𝑙 𝑐𝑜𝑠𝑡𝑠 𝑎𝑠𝑠𝑜𝑐𝑖𝑎𝑡𝑒𝑑 𝑤𝑖𝑡 𝑣𝑒𝑖𝑐𝑙𝑒 𝑜𝑤𝑛𝑒𝑟𝑠𝑖𝑝 𝑜𝑓 𝑎𝑙𝑙 𝑣𝑒𝑖𝑐𝑙𝑒𝑠
𝑥 𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 𝑜𝑓 𝑖𝑛𝑠𝑢𝑟𝑒𝑑 𝑣𝑒𝑖𝑐𝑙𝑒𝑠 𝑤
Data Inputs:
i. The Insurance industry’s total premium and total costs associated with vehicles for the year
ended 31 December 2024 are not currently available. The Group utilised the global weighted average
(Industry) attribution factor (6.99%) used to determine the percentage of cost of insurance. This factor
is calculated using consumer price index (CPI) data, which reflects the relative importance of insurance
cost based on their share in total household consumption
ii. Emissions of insured vehicles are estimated using average PCAF emission factors for Scope 1 and
Scope 2 emission (kgCO2/ year) for Cyprus, per vehicle type and fuel type.
257
Practitioners’ responsibilities
Our responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the
consolidated Sustainability Statement is free from material misstatement, whether due to fraud or error, and to issue a
limited assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered
material if, individually or in the aggregate, they could reasonably be expected to influence decisions of users taken on
the basis of the consolidated Sustainability Statement as a whole.
As part of a limited assurance engagement in accordance with ISAE (Ireland) 3000 we exercise professional
judgement and maintain professional scepticism throughout the engagement. Our responsibilities in respect of the
consolidated Sustainability Statement, in relation to the Process, include:
Obtaining an understanding of the Process, but not for the purpose of providing a conclusion on the effectiveness
of the Process, including the outcome of the Process;
Considering whether the information identified addresses the applicable disclosure requirements of the ESRS;
and
Designing and performing procedures to evaluate whether the Process is consistent with the Company’s
description of its Process set out in note ‘Identification and assessment of material impacts, risks and
opportunities’.
Our other responsibilities in respect of the consolidated Sustainability Statement include:
Identifying where material misstatements are likely to arise, whether due to fraud or error; and
Designing and performing procedures responsive to where material misstatements are likely to arise in the
consolidated Sustainability Statement. The risk of not detecting a material misstatement resulting from fraud is
higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions,
misrepresentations, or the override of internal control.
Summary of the work performed
A limited assurance engagement involves performing procedures to obtain evidence about the consolidated
Sustainability Statement. The procedures in a limited assurance engagement vary in nature and timing from, and are
less in extent than for, a reasonable assurance engagement. Consequently, the level of assurance obtained in a limited
assurance engagement is substantially lower than the assurance that would have been obtained had a reasonable
assurance engagement been performed.
The nature, timing and extent of procedures selected depend on professional judgement, including the identification
of disclosures where material misstatements are likely to arise in the consolidated Sustainability Statement, whether
due to fraud or error.
In conducting our limited assurance engagement, with respect to the Process, we:
Obtained an understanding of the Process by: performing inquiries to understand the sources of the
information used by management (e.g., stakeholder engagement, business plans and strategy documents), and
reviewing the Company’s internal documentation of its Process.
Evaluated whether the evidence obtained from our procedures with respect to the Process implemented by the
Company was consistent with the description of the Process set out in note ‘Identification and assessment of
material impacts, risks and opportunities’.
In conducting our limited assurance engagement, with respect to the consolidated Sustainability Statement, we:
Obtained an understanding of the Company’s reporting processes relevant to the preparation of its consolidated
Sustainability Statement by obtaining an understanding of the Company’s control environment, processes and
information systems relevant to the preparation of the consolidated Sustainability Statement, but not for the
purpose of providing a conclusion on the effectiveness of the Company’s internal control.
Evaluated whether the information identified by the Process is included in the consolidated Sustainability
Statement.
Evaluated whether the structure and the presentation of the consolidated Sustainability Statement is in
accordance with the ESRS.
Annual Corporate Governance Report
2024
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1. Introduction and Compliance Statement
I. The Group at a glance
II. Purpose of this Report
III. Applicable Governance Requirements (’First part’ for purposes of CSE Code
categorisation)
IV. Compliance Statement (’Second part’ for purposes of CSE Code categorisation)
2. Governance
I. Chair’s Foreword
II. The Board
III. The Executive Committee
IV. Board Governance Framework
V. The Role of the Board
VI. The Operation of the Board
VII. Board's oversight of risk management and internal control systems
VIII. Group Code of Conduct and Whistleblowing Policy
IX. Stakeholder Engagement
X. Key Board Activities in 2024
XI. Nominations and Corporate Governance Committee
XII. Human Resources and Remuneration Committee
XIII. Risk Committee
XIV. Audit Committee
XV. Technology Committee
3. Remuneration Policy Report
I. Human Resources and Remuneration Committee Chair’s Foreword
II. Remuneration Policy Report for the year 2024
Contents
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1. INTRODUCTION AND COMPLIANCE STATEMENT
The 2024 Corporate Governance Report (the ‘Report’) sets out the governance framework within which
Bank of Cyprus Holdings Public Limited Company (the ‘Company’) and Bank of Cyprus Public Company
Limited (‘BOC PCLor the ‘Bank’) operate and sets out how the Board of Directors (the ‘Board’) oversees,
evaluates and complies with such governance framework. The Report also outlines the key areas of focus
of the Board and Board Committees in 2024. In addition, the Report includes the Remuneration Policy
Report, which details the remuneration policy and practices. The Group’s commitment to the highest
standards of corporate governance ensures transparency, accountability, and sustainable growth.
I. The Group at a glance
The Company is the holding company of BOC PCL. The Bank of Cyprus Holdings Group (the 'Group')
comprises the Company, its subsidiary, BOC PCL, and the subsidiaries of BOC PCL. All Group companies
and branches are set out in Note 50 to the Consolidated Financial Statements included within the 2024
Annual Financial Report. A common board and committee structure applies for the Company and BOC
PCL, while the subsidiary companies have their own separate boards and, where applicable, their own
board committee structures. The Board exercises oversight of the Group’s risk profile and internal control
framework.
II. Purpose of this Report
The Report provides a comprehensive overview of how the Group integrated and adhered to applicable
corporate governance requirements in 2024 and includes reports from the four statutory Board
Committees and one non-statutory Board Committee, illustrating their main areas of focus, challenges
and future goals. The Report also includes the 2024 Remuneration Policy Report, which sets out the
Group’s policy on remuneration. The Report also illustrates how the Group, and more specifically the
Board, manages to maintain an open and transparent engagement and communication with
stakeholders, to continuously improve governance practices.
The Board, and the Executive Committee, are committed to upholding the highest standards of
governance, ensuring that the decision-making processes are consistently aligned with the Group’s
goals, values, and ethical principles. Through its corporate governance framework, the Group leads as
a pioneer in an era characterized by rapid changes, disruption, and digitalization. The primary objective
of its governance is to create long-term sustainable value for its shareholders, while also considering
and respecting the interests of all stakeholders: investors, customers, employees, the regulators and
the wider society (the ‘Stakeholders’). Additionally, the Board seeks to provide constructive challenges,
advice, and support to the management team by establishing the necessary checks and balances that
drive informed, collaborative, and accountable decision-making.
III. Applicable Governance Requirements (‘First part’ for purposes of CSE Code
categorisation)
The Group’s governance framework manages to achieve its objectives by adopting and embracing all
applicable corporate governance requirements. For the year ended 31 December 2024, the Group has
adopted, adhered to the following:
a) The CBC Directive on Internal Governance of Credit Institutions of 2021 (the CBC Internal
Governance Directive’), as amended (available at www.centralbank.cy);
b) The EBA Guidelines on Internal Governance under Directive 2013/36/EU, as amended;
c) The CSE Code (6th edition April 2024) (the 2024 CSE Code’), as amended (available at
www.cse.com.cy);
The UK Corporate Governance Code 2018 published by the Financial Reporting Council in the UK
(the ‘2018 UK Code’) (available at www.frc.org.uk)
1
;
The ESMA and EBA Guidelines on assessment of the suitability of the Board (the Joint
Guidelines on Suitability’), as amended;
d) The CBC Directive on the assessment of the suitability of members of the Board and Key Function
Holders (the ‘CBC Suitability Directive’) (available at www.centralbank.cy);
e) The Companies Act 2014 of Ireland (the ‘Irish Companies Act’), as amended.
1
The Group has decided to voluntarily apply the 2018 UK Code. It is noted that the 2024 UK Corporate Governance Code will be applicable from
1
st
January 2025 and aerwards, hence, for the purposes of this Report the 2018 UK Corporate Governance Code applies.
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1. INTRODUCTION AND COMPLIANCE STATEMENT (continued)
IV. Compliance Statement (’Second part’ for purposes of CSE Code categorisation)
The shares of the Company are admitted and traded on the Cyprus Stock Exchange (the ‘CSE’), and
hence, the Group adopts and adheres to the 2024 CSE Code. All principles and provisions of the 2024
CSE Code have been incorporated in the Group’s Corporate Governance Policy and Framework, a copy
of which can be found at https://www.bankofcyprus.com/en-gb/group/who-we-are/our-
governance/corporate-governance-other-group-policies/. For the year ended 31 December 2024, and
as at the date of this Report, the Group has maintained full compliance with the requirements of the
CSE Code except for:
1. Provision C3.1 with respect to the Audit Committee (the ‘AC’) stating ‘the President or any other
members of the said committee should have experience in accounting or audit’. Currently none
of the members of the AC have direct experience in accounting or audit. The Board resolved that
its functioning could benefit from further breadth of perspectives and experiences and an
enhancement of its collective experience in audit and banking whilst at the same time
considering its gender and regional diversity targets. Actions have been taken to further enhance
the composition of the Board and new members are expected to join the Board within 2025.
The shares of the Company were admitted and, starting from 23 September 2024, are also being traded
on the Main Market of the Regulated Securities Market of the Athens Stock Exchange (the ATHEX’).
Greek corporate governance law provisions, namely the provisions of articles 1-24 of Greek Law
4706/2020 (the ‘Greek Corporate Governance Regime’), apply only to companies whose registered seat
is in Greece. As a result, the Company, being a public limited company incorporated and registered in
Ireland, is not obliged to follow and adhere to the Greek Corporate Governance Regime. Instead, the
Company complies with the corporate governance regime of Ireland.
The shares of the Company were admitted and traded, up until 19 September 2024, on the international
commercial companies secondary listing category of the Official List of the London Stock Exchange (the
‘LSE’). Although not legally required to do so, the Group while complying with the LSE Listing Rules also
voluntarily opted to ‘comply or explain’ with the 2018 UK Code to demonstrate its commitment to
upholding the highest standards of corporate governance and ethical conduct. Even after the delisting
of the Company from the LSE, the Board decided, on a transitional basis, to continue to voluntarily
“comply or explain” with the principles and provisions of the 2018 UK Code. This reflects the Board’s
proactive and ongoing approach in embracing a comprehensive corporate governance framework that
promotes transparency, integrity, and accountability in its operational and strategic endeavors. For the
year ended 31 December 2024, the Group has applied the principles and complied with the provisions
of the 2018 UK Code, other than with the requirements set out below:
1. As per provision 5 of the 2018 UK Code, the Board is not using any of the methods described
therein, for engagement with the Group’s workforce. The Board has instead opted to use an
alternative arrangement as provided for in the said provision, through the work of the Human
Resources and Remuneration Committee (the ‘HRRC’) by continuing to receive regular updates
and continuously monitoring the progress of the HR function initiatives and work anchored on
key strategic goals. The work of the HRRC is further explained in Section 2, subsection XII.
2. With regards to provision 12 of the 2018 UK Code, it is noted that Mr. Constantine Iordanou held
the position of Senior Independent Director (the ‘SID’) up until 16 June 2024, the date on which
he sadly passed away. On 21 June 2024 Mr. Adrian Lewis assumed the position of SID. The three
working days in between were necessary for the Board to resume and appoint the new SID.
3. With regards to provision 23 of the 2018 UK Code, for 2024, the Board Nominations and Diversity
Policy included a target of ensuring a 40% female representation on the Board. As of 31
December 2024, 37.5% of the individuals on the Board were women following the departure of
two female members at the end of 2023. Gender diversity continues to be considered in Board
enhancement considerations.
4. With regards to provision 24 of the 2018, UK Code (DTR 7.1.1A), ‘…at least one member of the
Audit Committee must have competence in accounting or auditing…. Currently none of the
members of the AC have direct experience in accounting or audit. The Board resolved that its
functioning could benefit from further breadth of perspectives and experiences and an
enhancement of its collective experience in audit and banking whilst at the same time
considering its gender and regional diversity targets. Actions have been taken to further enhance
the composition of the Board and new members are expected to join the Board within 2025.
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263
1. INTRODUCTION AND COMPLIANCE STATEMENT (continued)
IV. Compliance Statement (’Second part’ for purposes of CSE Code categorisation)
(continued)
5. With regards to provision 32 of the 2018 UK Code, currently the Chair of the HRRC has not had
previous experience in remuneration committees for at least 12 months. The matter has been
identified, and it is expected that this will be resolved within 2025 since with the lapse of time
(i.e. of 12 months) the current Chair will be in office and will gain the relevant experience.
In accordance with section 225 of the Irish Companies Act 2014, the Directors acknowledge that they
are responsible for securing the Company’s compliance with its relevant obligations (as defined in section
225(1)). The Board confirms that a compliance statement has been drawn up, setting out the Company’s
policies, and that appropriate arrangements and structures have been put in place that are, in the
Board’s opinion, designed to secure material compliance with the relevant obligations. The Board
continuously monitors and reviews internally, at least once a year, its governance framework and that
of the Group’s subsidiary companies (where applicable) through effective oversight.
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2. GOVERNANCE
I. Chair’s Foreword
Dear Stakeholders,
It is with great pride that I present this comprehensive overview of the Board of Directors' focus and
activities in 2024, encapsulated in this Corporate Governance Report of 2024. This document provides
a detailed account of the governance framework, within which the Board and its Committees operate,
presents the role of the Board and its Committees, and provides an account of key activities and focus
areas of the Board and its Committees during 2024.
During the last year the Board experienced a notable change in its composition as it was marked by the
sudden passing of our Senior Independent Director, late Dinos Iordanou, in June 2024. Mr. Iordanou’s
contribution and unwavering commitment to the Group will always be remembered with great respect
and appreciation. Considering the loss, the Board capitalised on the skills and experiences of existing
members, many of whom have taken on new responsibilities during the year, ensuring that the quality
of the Board’s work and its standards remained uncompromised during this period. At the same time
the Board has taken several initiatives to enhance its composition, during the year, which are expected
to take effect within 2025.
The year 2024 has been marked by significant strides in our strategic initiatives, underpinned by rigorous
planning and execution. The Board has been steadfast with the listing of the Company’s shares on the
ATHEX, a move anticipated to enhance stock liquidity and capital access. The year 2024 marked the
second consecutive year that dividends were paid to our shareholders since the resumption of dividend
payments in 2023. Effective corporate governance, together with an effective risk management
framework, are fundamental to the Group’s realisation of the strategy and in our ongoing commitment
to providing sustainable shareholder returns. Our commitment to Environmental, Social, and Governance
(ESG) standards was reinforced with regular updates on sustainability initiatives, compliance, and impact
assessments. Furthermore, our digitalisation strategy has seen consistent advancements, with quarterly
updates and dedicated discussions shaping its course. These efforts collectively underscore our
dedication to long-term value creation and resilient governance, positioning us for sustained success in
a dynamic financial landscape.
Our Board has overseen and addressed regulatory matters, ensuring compliance and upholding the
highest standards of governance. In 2024, the Board enhanced its own governance practices and
functioning, and among other governance initiatives considered, discussed and approved the
comprehensive succession plan for senior management and key function holders. The plan was
meticulously crafted to align with the Company's long-term goals, fostering a resilient leadership pipeline
capable of steering the organization towards sustained success.
As it will be evident from the analysis that follows in the Report, throughout the year, the Board has
considered and approved key reports such as the Annual Risk Report, the Annual Audit Report, the
Annual Report of Compliance 2024, the Information Security yearly report 2024, the ICAAP and ILAAP
reports. These activities underscore our commitment to regulatory adherence and operational integrity.
In addition, the Board has overseen the risk management framework, which includes regular reports on
the Group’s Key Risk Indicators and Values and the Group’s Risk Profile and to identify and mitigate
potential risks proactively.
Recognizing the importance of fostering transparency and building a strong framework for future
collaboration, the Board has maintained continuous communication and liaison with its regulators
throughout 2024. Our ongoing dialogue and activities have been pivotal in addressing various emerging
matters, ensuring compliance, and reinforcing our governance framework.
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265
2. GOVERNANCE (continued)
I. Chair’s Foreword (continued)
Looking ahead to 2025, the Board remains committed to sustaining this momentum. We will continue
to prioritize strategic leadership, regulatory compliance, and operational integrity. Our focus will be on
further strengthening our governance practices, enhancing stakeholder engagement, and navigating the
evolving regulatory landscape with agility and foresight. We are confident that these efforts will drive
the organization toward new heights of success and resilience.
Thank you for your continued support and trust in our Board's leadership.
Yours Sincerely
Takis Arapoglou
Chair of the Board
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266
Risk
Committee
Human
Resources
Remuneration
Committee
Technology
Committee
Audit
Committee
Nominations
Corporate
Governance
Commiee
Where the member is chairing the Commiee, the Commiee, under the members name, appears in large bold font.
2. GOVERNANCE (continued)
II. The Board
Driving value for the shareholders, setting strategic direction and risk appetite and safeguarding robust
decision-making regarding matters of financial, regulatory, and reputational significance.
Board Committee Membership Key Commiee
Current Board Composition
Group Chairman
Independent
Non-Executive member
Appointed: June 2019
NCGC, HRRC
Skills, experience, contribution:
Experienced professional with proven track record in
International Capital Markets, Corporate, Commercial &
Investment Banking, based in Southeast Europe, the UK
and the Middle East.
Managing, restructuring and advising public listed financial
institutions and corporations, primarily in Southeast Europe
and the Middle East.
Profoundly focused on proactive culture and corporate
governance.
His other senior-level experience includes prior appointment as
Managing Director and Global Head of Banks and Securities
Industry for Citigroup, Chair of the Board of Directors and CEO
of the National Bank of Greece, and CEO of Commercial Banking
at EFG-Hermes Holding SAE.
Academic and Professional Qualifications:
BA in Mathematics and Physics, University of Athens
BSc in Naval Architecture and Ocean Engineering, University of
Glasgow
MSc in Finance and Management, University of Brunel, London
External Appointments:
Chair of the Board, Tsakos Energy Navigation (TEN) Ltd
Non-Executive Director, EFG Hermes Holding SAE
Non-Executive Director, Bank al Falah, Pakistan
Non-Executive Director, Benaki Endowment Fund Ltd (non-
profit organization)
Efstratios
Georgios
(Takis)
Arapoglou
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267
2. GOVERNANCE (continued)
II. The Board (continued)
Group Vice-Chair
Independent
Non-Executive Director
Appointed: February 2017
TC, NCGC, AC
Skills, experience, contribution:
Proven track record in technology and IT roles.
Extensive experience in digital transformation.
Managed large-scale global technology projects and
strategies within banking and trading sectors, in both
London and South Africa.
Since 2016 and throughout 2024, Ms. Grobler held the position
of Group Chief Information Officer at Howden Group Holdings
(formerly Hyperion Insurance Group). Her previous senior level
experience includes over 16 years with BP p.l.c. in senior
leadership roles, including the appointment as Vice-President
and Chief Information Officer Corporate Functions, where she
led the transformation of both the organization and the digital
landscape.
Academic and Professional Qualifications:
National Diploma in Electronic Data Processing, Cape Peninsula
University, South Africa
Higher National Diploma in Computer Systems, Durban
University, South Africa
External Appointments:
Chair of the Board, Howden Group Services
Non-Executive Director, Titan Cement International SA
Lyn Grobler
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268
2. GOVERNANCE (continued)
II. The Board (continued)
Senior Independent Director
Independent
Non-Executive Director
Appointed: November 2023
AC, HRRC, TC
Skills, experience,
contribution:
Extensive background in equity capital markets and
investment banking.
Understanding and experience in advising innovative
fintechs and other early-
stage companies, based in London.
Mr. Lewis is currently a managing director of the boutique
advisory firm, Namier Capital, supporting and advising
innovative startups and early-stage companies. He has
previously worked for over 20 years mainly within equity capital
markets at UBS Investment Bank, and from 2013 to 2020, he
was the EMEA Head of ECM at HSBC.
Academic and Professional Qualifications
M.A. Hons in Mathematics and Philosophy, University of
Oxford, UK
External Appointments:
Non-Executive Director, Bumblebee Power Limited
Adrian Lewis
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270
2. GOVERNANCE (continued)
II. The Board (continued)
Independent
Non-Executive Director
Appointed: May 2024
NCGC, RC
Skills, experience, contribution:
Highly experienced in sustainable financing/investing,
ESG impact investment.
Development and implementation of sustainable investing
strategies, including integrating ESG and impact into
investing processes and impact tracking, measurement
and reporting.
Multi-sector investment origination and execution of
growth, capital and control opportunities, with a focus on
technology and healthcare opportunities.
Mr. Hansmeyer has been the Managing Director, Head of Risk,
Legal and Strategy of Greater Pacific Capital LLP, based in
London, since 2018. Currently, he is also the Head of Research
at F4G Foundation, a non-profit institution. He has previously
held the positions of Principal for Greater Pacific Capital Co.
Ltd in Shanghai and of Vice President and Associate for
Greater Pacific Capital LLP. He has also previously served as
an analyst in investment banking with Goldman Sachs
International.
Academic and Professional Qualifications
MBA, Harvard Business School, USA
First State Examination in Law, University of Augsburg,
Germany.
External Appointments:
Non-Executive Director, Revogenex Ltd
Christian Philipp Hansmeyer
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271
2.
GOVERNANCE
(continued)
II. The Board (continued)
Independent
Non-Executive Director
Appointed: May 2024
HRRC, RC
Skills, experience, contribution:
Experienced professional with a demonstrated history in
the sector of technology, aviation, FMCG, automotive, and
sports.
History of successfully merging, separating and
transforming leading UK and international businesses.
Strategy and innovation are at the core, having challenged
and led established businesses to create new digital b2b
and b2c channels and to embed innovation as a
structured, disciplined mindset focused on realizing
strategic benefits and new revenues.
Mr. Birrell has been the Chief Data & Information Officer and
is a Member of the Executive Board of EasyJet Airline Ltd since
2020 up to 31 December 2024. He has previously served as
the Chief Information Officer and as an Executive Director for
Heathrow Airport Ltd, as well as the Chief Information Officer
of Gatwick Airport Ltd and McLaren Technology Group Ltd. Mr.
Birrell has also honorably acted as an advisor to the Board for
the Parliament Restoration and Renewal Delivery Authority of
the UK Government.
Academic and Professional Qualifications
MBA, Warwick University (2005)
BSc (Hons), Electrical and Electronic Engineering, Heriot Watt
University (1986)
Member of Institution of Engineering and Technology (MIET)
Chartered Engineer (CEng)
External Appointments:
Member of the Executive Board, EasyJet Airline Ltd
William Stuart Birrell
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272
2.
GOVERNANCE
(continued)
II. The Board (continued)
Executive Director
Appointed: September 2019
Skills, experience, contribution:
Experienced professional with significant experience in
Corporate Banking and Credit Risk.
Deep understanding of the business and the areas in
which the Group operates.
Committed to fostering a culture of integrity,
accountability, and excellence within the Group.
Mr. Nicolaou acts as the Group’s CEO and Executive Member
of the Board. Previously he held the position of Director of
the Corporate Banking Division at the Bank from June 2016 to
August 2019 and Manager in the Restructuring and Recoveries
Division from April 2014 to June 2016. Joining the Bank in
2001, he has occupied various roles, primarily within the
Corporate Banking and Credit Risk Departments.
Academic and Professional Qualifications
Degree in Mechanical Engineering, National Technical
University of Athens (Metsovio Polytechnic), Greece
BSc in Financial Services/ACIB, School of Management,
UMIST, UK
MSc in Mechanical & Industrial Engineering, University of
Illinois at Urbana-Champaign, USA
External Appointments:
Member, Association of Cyprus Banks*
Member, Employers’ Association of Cyprus Banks*
Member of the Executive Committee, Cyprus Employers &
Industrials Federation (OEB)*
*Entities which do not pursue commercial objectives. Mr. Nicolaou’s
membership stems from his capacity as the Bank’s CEO.
Panicos Nicolaou
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273
2.
GOVERNANCE
(continued)
II. The Board (continued)
Executive Director
Appointed: October 2021
Skills, experience, contribution:
Extensive experience in audit, finance and banking.
Deep understanding of Finance, Treasury, Strategy and
Corporate Finance, Investor Relations, ESG, Real Estate
Management, Restructuring & Recoveries, Regulatory
Affairs, Procurement and Economic Research.
Significant financial leadership.
Ms. Livadiotou is the Group’s Executive Director Finance and
an Executive Member of the Board. Before embarking on her
career in the banking sector, Ms. Livadiotou was employed
with the audit firm Arthur Andersen in Cambridge, UK. She
joined the Bank in 1999 and has held multiple roles, including
Assistant to the Group Chief General Manager, Chief Financial
Officer, and has overseen both the Finance and Treasury
Divisions.
Academic and Professional Qualifications
MA in Economics, University of Cambridge, UK
Qualified Chartered Accountant
External Appointments:
Board Member, Board of Trustees of Bank of Cyprus
Oncology Centre
Chair of the Board, The Girl Guides Association of Cyprus
(non-profit institution) *
Board Member, Institute of Certified Public Accountants of
Cyprus*
*Entity which does not pursue commercial objectives
Eliza Livadiotou
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274
2. GOVERNANCE (continued)
III. The Executive Committee
The Group’s Executive Committee (the ‘EXCO’) is the most senior executive committee of the Group,
responsible for executing the Group’s strategy.
Current Composition
Read more about each member of the EXCO on: https://www.bankofcyprus.com/group/who-
we-are/our-leadership/senior-management/
Changes in the EXCO during 2024:
There were no changes in the EXCO in 2024.
Observers
The Chief Compliance Officer, Mr. Marios Skandalis, and Director Internal Audit, Mr. Giorgos Zornas,
participate in the EXCO meetings as observers in attendance.
*Rights of the CRO in the EXCO
The CRO, maintaining his/her independence to challenge such decisions and ensuring that risk
considerations are considered appropriately, has the right to veto any EXCO decision that may
affect the institution’s exposure to risks following the relevant escalation procedure. The right to
veto such decisions is justified given that the decisions are made at EXCO level i.e. below the level
of the Board, which bears the ultimate and overall responsibility for the institution.
Panicos
Nicolaou
CEO
Charis
Pouangare
Deputy
CEO &
Chief of
Business
Eliza
Livadiotou
Executive
Director
Finance
(EDF)
Irene
Georgiou
Executive
Director
People &
Change
Demetris
Th.
Demetriou
Chief Risk
Officer
(CRO)*
George
Kousis
Executive
Director
Technology
&
Operations
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275
2. GOVERNANCE (continued)
IV. Board Governance Framework:
The Board derives its authority to act from the Articles of Association of the Company and the prevailing
companies’ laws, stock exchange and banking laws, the directives of the CBC, as well as the CSE and
UK Codes.
Board Composition in Compliance with CBC Directive/CSE Code
As at 31 December 2024, the Board comprised of eight members: the Group Chair, (Mr. Efstratios
Georgios (Takis) Arapoglou) who was independent on appointment and remains independent, two
executive directors (Mr. Panicos Nicolaou and Ms. Eliza Livadiotou) and five non-executive directors who
are independent (Ms. Lyn Grobler, Mr. Adrian Lewis, Ms. Monique Hemerijck, Mr. Christian Hansmeyer
and Mr. Stuart Birrell). The above composition is in adherence with the provisions of the CSE Code, with
all six non-executive directors being independent. There is clear separation of duties between the CEO
and the Chair of the Board.
Way forward
Although fully functional, following the resignation of four Board Members in 2023 and the sudden
passing of Mr. Dinos Iordanou who held the position of SID (up until 16 June 2024), the Board resolved
that its functioning could benefit from further breadth of perspectives and experiences and an
enhancement of its collective experience in audit and banking whilst at the same time considering its
gender diversity targets. Actions have been taken to further enhance the composition of the Board and
new members are expected to join the Board within 2025.
Monitoring Board Independence
The NCGC and the Board assess the independence status of each candidate for the position of director
during the recruitment process, against the criteria set out in the 2018 UK Code, the 2024 CSE Code,
the CBC Suitability Directive and the Joint Guidelines on Suitability. In addition, the NCGC and the Board
assess the independence status of each individual director on an annual basis.
A relevant ‘Confirmation of Independence’ based on the independence criteria of provision A.2.3 of the
2024 CSE Code is signed annually by each of the independent non-executive directors and submitted to
the Cyprus Stock Exchange together with the Annual Corporate Governance Report.
The Chairperson, Mr. Efstratios Georgios (Takis) Arapoglou, was independent on appointment and
continues to operate in a manner that is independent in character and remains objective in his opinions
having no other relationship or circumstances to affect his judgement. He commits the appropriate time
for the Group’s business, which is slightly more than the other non-executive directors, and it
approximately amounts between 60-70 days per year. He has no other remuneration from the Group
other than as Chairperson of the Board and chairperson of the NCGC, and member of the HRRC.
2024 Update
The NCGC has assessed and concluded that all Non-Executive Directors are independent as per provision
of the said Codes and Directives during 2024. This conclusion was reached after consideration of all
relevant circumstances that are likely to impair, or could appear to impair, independence.
Terms of Appointment, Retirement and Re-election of Directors
Non-executive directors are appointed for an initial three-year term and are typically expected to serve
further terms of three years, assuming satisfactory performance and subject to the needs of the
business, shareholder re-election and continuing suitability. A non-executive’s term of office will not
extend beyond twelve (12) years in total. Any re-appointment beyond nine (9) cumulative years is
considered on an annual basis, considering factors such as performance, independence, the need for
progressive refreshing of the Board over the medium to long-term and the best interests of the
shareholders.
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2. GOVERNANCE (continued)
IV. Board Governance Framework: (continued)
The Board may at any time appoint any person who is interested to take up the position of a non-
executive director, provided that he/she fulfils the criteria as these are determined in the Board
Nominations and Diversity Policy (latest version of the said policy available at
https://www.bankofcyprus.com/globalassets/who-we-are/our-governance/corporate-governance-
policies-2024/board-nominations-and-diversity-policy.pdf, either to fill a vacancy or to join as an
addition to the existing Board, but the total number of directors should not exceed 13. Any director so
appointed is subject to election at the AGM following his/her appointment and the approval of the
regulatory authorities. According to the Articles of Association of the Company, all directors retire each
year and if eligible, offer themselves for re-election.
The following directors, being eligible, offered themselves for re-election and were re-elected at the
2024 AGM: Efstratios-Georgios Arapoglou, Lyn Grobler, Panicos Nicolaou, Constantine Iordanou (now
deceased), Eliza Livadiotou, Monique Hemerijck and Adrian Lewis. The above AGM also elected as
Directors, Mr. Christian Hansmeyer and Mr. Stuart Birrell. In doing so, all candidacies of directors were
accompanied by sufficient biographical details upon their first election and/or re-election, these
appearing in the AGM notices published for each relevant AGM.
It is noted that Mr. Constantine Iordanou held the position of Senior Independent Director (the ‘SID’)
and Chair of the Audit Committee between 1 January 2024 and 16 June 2024, the date on which he
sadly passed away. Mr. Adrian Lewis was appointed SID on the 21 June 2024.
Board and Committee governance structure
The Board is supported by the Board Committees to exercise its role of oversight of risk and control.
Typically, matters are delegated to one of the Board Committees for consideration in greater depth than
would be practicable at Board meetings, and subsequent recommendation to the Board for approval.
Each Committee operates under terms of reference approved by the Board and reviewed annually by
the Committees. Terms of reference of Committees are available on https://www.bankofcyprus.com/en-
gb/group/who-we-are/our-governance/group-committees/.
Appropriate cross-membership of key Board committees, including between the AC and the RC and the
HRRC, is ensured. The NCGC reviews the composition and purpose of the Board committees annually
and on an ad hoc basis if circumstances warrant it and makes relevant recommendations to the Board.
Further details on the work of these committees in 2024 are set out in Section 2, subsections XI-XV of
this Report.
Nominations
and Corporate
Governance
Committee
(NCGC)
Human
Resources and
Remuneration
Committee
(HRRC)
Audit
Committee
(AC)
Risk Commitee
(RC)
Technology
Committee
(TC)
Board of Directors
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2. GOVERNANCE (continued)
IV. Board Governance Framework: (continued)
Interaction with material subsidiaries
There are close interactions between the Group’s subsidiaries’ boards of directors and their respective
committees and the Board. The chairs of each subsidiary’s audit and risk committees submit an annual
report to the respective Group Board Committees detailing the activities of the subsidiary board during
the year. Additionally, in 2024, requirements have been introduced with respect to the composition of
the board of a subsidiary and over the independence of the heads of Control Functions. The NCGC
annually reviews and recommends to the Board for approval the Corporate Governance Guidelines for
Group Subsidiaries.
2024 Update
The Corporate Governance Guidelines for subsidiaries have been significantly revised in 2024 with the
aim to further enhance the effective oversight of subsidiaries and to ensure that effective corporate
governance practices are implemented by material subsidiaries. The definitions of ‘material subsidiary
and PIES’ have also been included in the Guidelines. Basic guidelines were also provided in the
framework in relation to non-material subsidiaries and special purpose vehicles (SPVs). Additionally, the
framework has been enhanced to explicitly state that the Chief Compliance Officer, in his capacity as the
Corporate Governance Compliance Officer, may attend meetings of the boards of material subsidiaries,
as an observer by invitation, as part of his overall review and assessment of the functioning of the board
and of the subsidiary’s corporate governance function. Additionally, requirements have been introduced
when considering the composition of the subsidiary’s board and the independence of the heads of Control
Functions.
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2. GOVERNANCE (continued)
V. The Role of the Board
Role of the Board
The Board is collectively responsible for the long-term success of the Group, and is committed to effective
leadership, considering the key role of the Group in the wider society. The Board’s role is to promote the
Group’s vision, values, culture, and behaviour, within a framework of adequate controls, which enables
risk to be identified, assessed, measured, and managed. The Board sets the Group’s strategic objectives
and risk appetite to support the strategy; integrates sustainability into the way business is conducted;
ensures that the necessary financial and human resources are in place for the Group to meet its
objectives; and oversees management performance to the above ends.
The Board is also responsible for ensuring that management maintains an adequate and effective internal
governance framework and internal control system, which includes a clear organisational structure and
the smooth operation of independent risk management, regulatory compliance, internal control and ICT
and security risk management functions with adequate powers and resources for the performance of
their duties. Furthermore, the Board is accountable for presenting a fair, balanced and understandable
assessment of the Company’s, the Bank’s and the Group’s position and prospects, including in relation
to the annual and interim financial statements and other price-sensitive public reports, as well as reports
required by regulators and by law.
Moreover, the Board is responsible for endorsing the appointment of individuals who may have a material
impact on the risk profile of the Group. Their appropriateness for the role is monitored on an ongoing
basis. The removal from office of the head of a ‘control function’ as defined in the CBC Directive on
Internal Governance, is also subject to Board approval.
The roles of the Board and its Committees are described and analysed in the Group Corporate
Governance Policy and Framework, which is reviewed on an annual basis. The Group Corporate
Governance Policy and Framework can be found at hps://www.bankofcyprus.com/en-
gb/group/who-we-are/our-governance/corporate-governance-other-group-policies/.
Matters reserved for the Board
The Board maintains the ultimate responsibility for the consideration and approval of all matters which
are elevated at Board level. Typically, all such matters are discussed in depth at the relevant Board
Committees before submission to the Board with a recommendation. The Board Chair reserves the
right/discretion to instruct a matter to be brought to the Board directly for consideration, such as material
decisions relating to strategic initiatives, approval of the Distribution Policy, any decision for distributions
- dividends and share buybacks, etc.
The responsibility to make and implement operational decisions for the Group’s business on a day-to-
day basis, has been delegated by the Board to the CEO, supported by the EXCO.
Roles within the Board and attendance at the Board and Board Committees in 2024
The tables below set out the Board members’ respective roles, responsibilities and the attendance of the
Board members at Board meetings and Board Committees. The Board collectively convened 27 times
during the year (including an offsite session which took place in early October 2024 to discuss strategy
and vision for the future), 11 of which were scheduled. Joint meetings of Committees also appear in the
below tables.
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2. GOVERNANCE (continued)
V. The Role of the Board (continued)
Role/
Name
Board
Meetings
attended
Responsibilities
Chair
Efstratios
Georgios (Takis)
Arapoglou
26/27
Setting the Board’s agenda, primarily focused on strategy, performance, value
creation, culture, stakeholders’ engagement, and accountability.
Ensuring that the Board members receive timely and high-quality information to
enable them to make informed decisions.
Oversees Board operations and effectiveness.
Ensures effective communication with shareholders and the regulator.
Promotes culture of active participation in Board deliberations.
Sets expectations regarding culture, values and behaviours.
Vice Chair
Lyn Grobler
26/27
Providing support and guidance to the Chairperson.
Acting as a substitute for the Chair during Board Meetings, or other official
meetings and serves as representative of the Board and the Group in interactions
with regulators, employees and customers.
Senior
Independent
Director
Adrian Lewis
27/27
Accessible to the shareholders and to the Board for addressing unresolved
shareholder/stakeholder concerns.
Serving as a sounding board for the Chair and assists the Chair in meeting goals.
Overseeing the evaluation of the Chair's performance and ensuring a seamless
transition of leadership.
Maintaining contact with major shareholders and acts as a liaison between them
and the Board.
Other Non-
Executive
Directors
Monique
Hemerijck
Christian
Hansmeyer
Stuart Birrell
Constantine
(Dinos) Iordanou
(SID)
25/27
18/18
18/18
11/11
Providing effective monitoring, strategic guidance and constructive challenges to
Executive Directors and management.
Contributing to strategic development of the Group and empowering its
implementation.
Overseeing the adequacy of financial controls, compliance and risk management
systems, and internal control framework.
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2. GOVERNANCE (continued)
V. The Role of the Board (continued)
Role/
Name
Board
Meetings
attended
Responsibilities
Executive
Director
CEO
Panicos Nicolaou
27/27
Leading the Group’s strategic objectives and promoting the implementation of
the strategy decisions of the Board.
Ultimate responsibility for the execution of the Group’s operations, performance
and regulatory compliance.
Setting the tone of appropriate culture, values and behaviour of the Group.
Responsible for the day-to-day management of the Group.
Executive
Director
EDF
Eliza Livadiotou
27/27
Promoting success and the achievement of the financial targets of the Group and
Supports the CEO in developing and implementing the Group strategy.
Leading and overseeing the Finance Function and is responsible for effective
financial and regulatory reporting.
Leads Treasury, Real Estate Management, and Restructuring & Recoveries.
Interacting with and managing feedback from investors, financial institutions,
regulators and auditors on the performance of the Group.
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2. GOVERNANCE (continued)
V. The Role of the Board (continued)
Meetings attended
NCGC
HRRC
RC
AC
TC
Efstratios Georgios (Takis) Arapoglou
15/15 5/5 N/A N/A N/A
Lyn Grobler
15/15 3/3 7/7 8/8 6/6
Adrian Lewis
3/3 5/5 7/7 19/19 9/9
Monique Hemerijck
N/A 4/4 17/17 19/19 9/9
Christian Philipp Hansmeyer (Note 1)
12/12 N/A 10/10 N/A N/A
Stuart Birrell (Note 2)
N/A 6/6 10/10 N/A N/A
Constantine (Dinos) Iordanou (Note 3)
N/A 4/4 N/A 11/11 3/3
Panicos Nicolaou
N/A N/A N/A N/A N/A
Eliza Livadiotou
N/A N/A N/A N/A N/A
Joint Meetings attended
NCGC/
HRRC
RC/AC
RC/TC
Efstratios Georgios (Takis) Arapoglou 5/5 N/A N/A
Lyn Grobler 5/5 7/7 2/2
Adrian Lewis 5/5 7/7 2/2
Monique Hemerijck 4/4 7/7 2/2
Christian Hansmeyer (Note 1) 1/1 3/4 1/1
Stuart Birrell (Note 2) 1/1 4/4 1/1
Constantine (Dinos) Iordanou (Note 3) 4/4 3/3 1/1
Panicos Nicolaou N/A N/A N/A
Eliza Livadiotou N/A N/A N/A
Notes:
1. Christian Philipp Hansmeyer was approved by the ECB on 29 April 2024 and officially appointed at the AGM on
17 May 2024.
2. Stuart Birrell was approved by the ECB on 29 April 2024 and officially appointed at the AGM on 17 May 2024.
3. Constantine (Dinos) Iordanou passed away on 16 June 2024.
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2. GOVERNANCE (continued)
V. The Role of the Board (continued)
Diversity
The Board recognises the benefits of having a diverse Board and workforce, creating a work environment
where everyone has an opportunity to fully participate in creating business success, and where each
person is valued for their distinctive skills, experiences, and perspectives. In reviewing Board
composition and identifying suitable candidates, the NCGC and the Board consider the benefits of all
aspects of diversity including the skills identified as relevant to the business of the Group, industry
experience, nationality, gender, age and other relevant qualities, to maintain an appropriate range and
balance of skills, experience and background on the Board and its Committees.
The Group’s approach to Board diversity is set out in full in the Board Nominations and Diversity Policy,
which can be found online at https://www.bankofcyprus.com/globalassets/who-we-are/our-
governance/group-board-nominations-policy.pdf
Diverse background in the Board
The Board benefits from a wide range of backgrounds, knowledge and experiences. Non-executive
members of the Board possess a wide range of skills, knowledge and extensive experience acquired
from executive and/or non-executive appointments as directors of other companies, that combine to
provide independent perspective, insights and challenge needed to support good decision-making and
effective board dynamics. The participation of executives on the Board enhances the banking expertise
of the Board and ensures that the Board is provided with direct, precise, and up-to-date information
about significant matters concerning the Group. Areas of expertise in current Board Composition include
Banking, Insurance Business, Risk Management, IT, Information Security, ESG, and Investment Banking.
35%
22%
26%
17%
Industry Skills/ Experience
Banking Insurance Digital/ Tech/ IT Other Industry
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2. GOVERNANCE (continued)
V. The Role of the Board (continued)
Gender Diversity in the Board
During 2024, the NCGC reviewed the Board Nominations and Diversity Policy, which aims to maintain
diversity with appointments based on merit in the context of the skills and experience required. The
quantitative gender diversity of the Company remained set at 40% female representation. It is clarified
that the set ambition level is set at a Board level as opposed to also being set at Committee level.
The following were applicable in relation to the Company and the Bank as 31 December 2024:
37.5% of the members of the Board are women following the departure of two female members
at the end of 2024. Gender diversity continues to be considered in Board enhancement
considerations.
The EDF, Eliza Livadiotou, is female.
The Group’s Board gender diversity well exceeds that of listed companies in Cyprus and is aligned with
the Gender Balance Corporate Boards Directive (EU) 2022/2381 mandating a minimum of 40%
representation of the underrepresented sex among non-executive directors, or 33% among all directors
by 30 June 2026.
9%
11%
6%
8%
6%
11%
7%
8%
9%
11%
11%
3%
Functional Skills/Experience/Knowledge
Accounting & Audit Risk/ Compliance Management Consumer Banking
Investment Banking Corporate Banking Capital Markets
Human Resources/ Remuneration Digital / Tech/ Cybersecurity ESG
Governance Strategy/ Transformation Other Skills
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2. GOVERNANCE (continued)
V. The Role of the Board (continued)
*For CFO position the EDF title is used as the position encompasses further responsibilities.
Ethnic background diversity in the Board
The Board recognises the challenges in setting diversity targets. Cyprus is the geographical provenance
of the Group’s customer and employee base and having also regards to the ethnic background of the
Cyprus population, currently, the Board has not set a target for having at least one member of the Board
from a non-white ethnic minority background.
Board
members
Percentage of
the Board
Number of
senior positions
on the board
(CEO, CFO*, SID
and Chair)
Percentage of
executive
management
Number in
executive
management
White British
or other White
(including
minority-white
groups)
100%
4
100%
6
*For CFO position the EDF title is used as the position encompasses further responsibilities.
Age Diversity in the Board
The following chart illustrates the distribution of age groups within the Board, showcasing the diverse
range of ages represented.
Board
members
Percentage on
the Board
Number of senior
positions on the
Board (CEO, CFO*,
SID and Chair)
Percentage in
executive
management
Number in
executive
management
Men 63%
3
67%
4
Women 37%
1
33%
2
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2. GOVERNANCE (continued)
V. The Role of the Board (continued)
Gender Diversity at Senior Management level
The Board also places high emphasis on ensuring diversity in the senior management roles within the
Group. Several Group policies ensure unbiased career progression opportunities. The Code of Conduct
similarly ensures equal opportunities for all members of staff and treats diversity with fairness and
respect aiming to provide fair treatment for everyone at work. A primary ESG target approved by the
Board under the ESG strategy is ≥30% women in Group’s management bodies by 2030.
As of 31 December 2024, there is a 33% representation of women on the EXCO.
33%
44%
22%
45-54 55-65 66-74
33%
67%
Executive Committee Gender Diversity
Female representation Male representation
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2. GOVERNANCE (continued)
V. The Role of the Board (continued)
Gender Diversity at the wider Group Management
The Bank has a 47% representation of women at positions with subordinates (defined as ‘Managers’).
Succession
To ensure business continuity and performance at Board level and at the same time provide the basis
for the identification and development of the skills, knowledge and qualifications required for the
members of the Board, the Group has compiled a designated Succession Planning Process for the
replacement of Non-Executive Directors, and a separate succession planning process for the Chair of the
Board of Directors. It is noted that a separate succession planning processes are in place for the CEO of
the Group, the Heads of Control and the Senior Management. All processes address both circumstances
of planned vacancies (e.g. completion of tenures) as well as the eventuality of emergency succession.
In accordance with the above policies and in alignment with the needs identified above, a 2-year Board
Succession Plan and Emergency Succession Plan are also in place which are reviewed at least on an
annual basis by the NCGC and the Board.
Succession Planning is an area that is reviewed by the NCGC Committee and the Board. Further
information on the work performed by the said committee and the Board on this area can be found under
Section2, subsections XI and X respectively.
Board Collective Suitability
The latest collective suitability assessment performed revealed that the Board possesses strong
collective knowledge, skills and experience, enabling it to understand and oversee the Group's activities,
risks and strategy. The Board's composition reflects a diversity of experiences, skills, professional
backgrounds and leadership experience at senior levels, which are fully aligned to the Group's strategic
priorities, enabling the Board to effectively exercise its oversight role. More specifically all members of
the Board have experience in strategy and transformation, management experience at senior levels,
with selected members having in depth experience in the critical domains of the Group's business model,
covering expertise in the Risk Area (including Cyber/IT risk, Money laundering/terrorist financing risks),
Strategy, Insurance, Investment Banking, Recoveries and Restructuring, and ESG expertise. Expertise
in Cyber security and ESG was enhanced further with the addition of two new members of the Board
(Mr. Stuart Birrell, Mr. Christian Hansmeyer).
47 %
53%
Gender Diversity in the wider Group Management
Female representation Male representation
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2. GOVERNANCE (continued)
V. The Role of the Board (continued)
Following the completion of the internal recruitment procedures, ECB approvals for Mr. Stuart Birrell and
Mr. Christian Hansmeyer were obtained on the 29 April 2024 and their candidacies were approved by
the AGM on 17 May 2024. There is international diversity, educational diversity and age diversity in the
Board to enable effective discussions and challenges to be made and decisions to be taken. All members
of the Board are highly reputable professionals, with no conflicts of interest, independence of mind and
time commitment to perform their role.
Taking into account the departure of four Board Members in 2023, including the AC Chair, as well as the
sudden passing of Mr. Dinos Iordanou, and further to the two recently approved Directors, it was also
concluded that the functioning of the Board could benefit further from an increased number of members
including members with Audit and Banking experience as well as further gender diversity and local
expertise.
The Board has initiated a recruitment process to enhance its composition. The Board’s enhancement
initiatives are continuing into 2025 to reach optimum composition and functioning in due course.
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2. GOVERNANCE (continued)
VI. The Operations of the Board
The Operation of the Board
1. Information and Support
The Board meets on a regular basis and has a formal schedule of matters for consideration, which
evolves based on business needs and which the Board formally reviews annually.
Performance against delivery of the agreed key financial priorities is reviewed at every meeting with
reference to the Group management accounts. The CEO and the EDF comment on strategy, current
business performance, the market, regulatory and other external developments at each meeting and
present comparative data. The Board receives regular reports and presentations from other senior
management on developments in the operations of the Group. The Board considers reports from each
of the Board committees, while regular reports are also provided on the Group’s risk appetite, top and
emerging risks, risk management, the ESG agenda, credit exposures and the Group’s loan portfolio,
asset and liability management, liquidity, litigation, compliance, and reputational issues.
Under the supervision of the Chair of the Board, the Company Secretary’s responsibilities include
facilitating the flow of information within the Board and its Committees, between senior management
and non-executive directors and between heads of internal control functions and non-executive directors,
as well as facilitating the induction, development, and evaluation of members of the Board.
All members of the Board have access to the advice and services of the Company Secretary and the
Chief Compliance Officer who can provide relevant information related to Board procedures and the CSE,
and ATHEX Codes as well as the UK Code. The Company Secretary is responsible for ensuring that the
Directors are provided with relevant information on a timely basis to enable them to consider issues for
decision, and to discharge their oversight responsibilities. Both the appointment and removal of the
Company Secretary is a matter for the Board as a whole.
The Board also has access to the advice of the Group’s external legal advisors, and independent
professional advice at the Group’s expense if, and when required. Committees of the Board have similar
access and are provided with sufficient resources to undertake their duties. The Company Secretary
provides dedicated support for members of the Board on any matter relevant to the business on which
they require advice separately from or additional to that available in the normal Board process. All
members of the Board benefit from directors’ and officers’ liability insurance in respect of legal actions
against them.
2. Conflict of Interest (‘COI’)
The Group Policy on Conflict of Interest focuses on principles, procedures and arrangements for the
prevention, identification, documentation, escalation, and management of actual, potential, or perceived
conflict of interest. The policy is reviewed and approved by the Board annually and is communicated
throughout the Group.
The Group Corporate Governance Policy and Framework documents procedures specifically relating to
directors’ conflict of interest, and sets out how these are to be identified, reported, and managed to
always ensure that the Directors act in the best interests of the Company and the Group. The Group
Corporate Governance Policy and Framework is reviewed and approved by the Board, at least annually
and within 2024 this update took place in July.
Directors are required to report actual or potential conflicts of interest. Such conflicts or potential
conflicts are reviewed by the Board, and relevant actions are taken, where necessary.
All conflicts of interest are recorded in the Compliance Management System and are assessed and
managed on an ongoing basis and reported as needed.
Conflicts of interest declarations are obtained by obliged persons bi-annually, or earlier, if a potential
conflict occurs, and are assessed by the Compliance Division on an ongoing basis.
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2. GOVERNANCE (continued)
VI. The Operations of the Board (continued)
2024 Update
Conflicts of interest have been declared during 2024, have been duly recorded in the Compliance
Management System and managed according to the procedures outlined in the Group Conflicts of
Interest Policy.
Moreover, none of the Directors had, during the year or at year end, a material interest, directly or
indirectly in any contract of significance with the Group (information on transactions between the
Directors and the Group are disclosed in Note 49 of the Consolidated Financial Statements included in
the 2024 Annual Financial Report).
3. Time commitment
Before their appointment, prospective Board members disclose details of their other significant
commitments along with a broad indication of the time committed to such appointments. Such
participation is taken into consideration when deciding on their appointment to ensure it does not prevent
them from devoting the necessary time and attention to their duties as members of the Board of the
Company. A proper suitability assessment as per the prescriptions of the Suitability Directive is carried
out to ascertain, inter alia, whether the provisions/criteria set by the CBC Suitability Directive are
satisfied. Before accepting any new external appointments, which may affect existing time commitment
for the Board’s business, approval must be obtained from the Board.
Upon appointment, all newly appointed members of the Board are provided with a comprehensive letter
of appointment detailing their responsibilities as directors, the terms of their appointment and the
expected time commitment for the role. A copy of the standard terms and conditions of appointment of
non-executive directors can be inspected during normal business hours by contacting the Company
Secretary. Members of the Board are required to devote adequate time to the business of the Group,
which includes attendance at regular meetings and briefings, preparation time for meetings and visits
to business units.
In addition, non-executive directors are normally required to sit on at least one Board Committee, which
involves the commitment of additional time. Certain non-executive directors such as the Vice-Chair, the
SID and Committee Chairpersons are required to allocate additional time in fulfilling those roles.
The Board has determined the time commitment expected of non-executive directors to be 35- 42 days
per annum. When serving on Board committees more time may be necessary.
The requirements for how many directorships can a director hold is provided within the CBC Suitability
Directive. The Regulator may in exceptional cases and taking into consideration the nature and
complexity of the business of the Group, authorise members of the Board to hold one additional
directorship.
2024 Update
The required time commitment criteria have been considered by the NCGC and the Board during
appointment procedures, to ensure that candidates have sufficient time to dedicate to their duties and
having regard to applicable regulatory limits on the number of directorships which may be held by any
individual director. This requirement has also been reassessed during the year in cases where Directors
considered new directorship opportunities.
It was estimated that in 2024, each non-executive director spent at least 40 days on Board-related
duties. The Board considered the time commitment of all directors and concluded that each director
devotes the required time for the effective performance of his/her duties as described in the Joint
Guidelines on Suitability. The Chairman has devoted approximately 60-70 days on Board-related duties
and provides ongoing support.
During 2024, there were no directors whose time commitment was considered a matter of concern. All
Board Directors were within the directorship limits set out for ‘significant institutions’. Further information
on external appointments of Directors can be found in Section 2, sub-section II.
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2. GOVERNANCE (continued)
VI. The Operations of the Board (continued)
Directors’ induction and ongoing development
Formal Induction Programs are compiled for newly appointed Directors, which are tailored to their
individual needs, skills and experience and aim to facilitate their understanding of how the Group
operates, the legislative and regulatory framework that they need to adhere to and key strategic and
business areas and functions.
Further to a relevant information pack, the Induction Program typically consists of training on General
Banking, Information Security, Regulatory Training and Governance and structured meetings and
presentations of the newly appointed Directors with the senior management and key executives of the
Group who provide deep dives on: business lines, the Group’s risk appetite and Group Risk Framework,
corporate governance, internal control systems, regulatory environment, people strategies, technology,
and payments, ESG and other. Board members are entitled to request specific training if deemed
necessary.
Dedicated training and development opportunities are also provided to all Board members, training
topics deriving mainly from the effectiveness reviews of the Board and individual directors, and
developments in the external environment, such as regulatory, technological, economic and other
business developments. Moreover, meetings are arranged with senior management on a regular basis
on matters of strategic importance.
2024 Update
During 2024 all newly appointed Directors received induction training.
The Training and Development provided to the Board during 2024 (in addition to the induction training
for newly recruited members) is presented in the table below:
Training Area Training Topics
Data Management Data and Report Quality in Bank of Cyprus
Information Security
Information Security
Cyber security practices
AI
Impact of AI in Financial Services
-
Cyber
Security and Fraud Considerations
AML AML - Prevention of ML & TF
Sanctions
Compliance/Financial crime and sanctions
compliance
ESG
Embedding climate into business strategy and
execution: enablers and key success factors
Regulatory Affairs Training
Overview of Regulatory oversight practices &
cycles
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2. GOVERNANCE (continued)
VI. The Operations of the Board (continued)
4. Loans to Directors and Other Transactions
Details of credit facilities to Company Directors (and related parties) and other transactions with the
Group are set out in Note 49 of the Consolidated Financial Statements for the year ended 31 December
2024 included within the 2024 Annual Financial Report.
It is hereby confirmed that the credit facilities to Company directors (and related parties) or to its
subsidiary or associated company directors are granted in the normal course of the Company’s business,
under normal commercial and employment terms and with transparency. Furthermore, it is confirmed
that all relevant cases of bank facilities to Company directors and its subsidiary company directors are
forwarded for approval to the Board after the relevant proposal of the RC. The interested member of the
Board is neither present nor participates in the procedure.
2024 Update
All members of the Board complied with the relevant provisions of the 2024 CSE Code and the CBC
Suitability Directive as of 31 December 2024.
5. Board Performance Evaluation
The Board seeks to continuously enhance its effectiveness and operations and conducts formal
effectiveness evaluations to this end. The Board conducts both a triennial board evaluation carried out
by external evaluators, the ‘External Triennial Board Evaluation,’ and an annual board evaluation, the
‘Annual Internal Board Evaluation’ carried out by the Compliance Function being the second line of
defense. The latter comprises of the ‘Board Evaluation’ which includes reviewing the Board’s operations,
composition and overall effectiveness, whereby the evaluation reviews past performance with the aim
of identifying possible opportunities for improvement, the ‘Committee Evaluation’ which determines
whether the Board and its Committees are collectively effective in discharging their responsibilities and
and the ‘Individual Director Evaluation’ which determines whether each individual Director contributes
effectively to the collective suitability of the Board.
5.1. External Triennial Board Evaluation
An external triennial board evaluation review in accordance with Article 16 of the CBC Governance
Directive was conducted during the year 2023, by an independent company, Morrow Sodali, and a
relevant report was submitted to the Board in March 2024. The recommendations from the 2023
evaluation were published in the 2023 Corporate Governance Report and the actions taken during 2024
are included below.
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2. GOVERNANCE (continued)
VI. The Operations of the Board (continued)
Areas Recommendation from 2023 evaluation Actions taken during 2024
Commitment to
Gender Diversity.
The report underscored the importance of
maintaining a strong commitment to gender
diversity within the Board. It advised that the
Board should persistently prioritize gender
diversity as a critical agenda item, reflecting
the Group’s and Board’s dedication to fostering
an inclusive and diverse leadership
environment.
During 2024 the NCGC and the Board
have interviewed several professionals
to enhance the Board’s composition.
Considerations for appointment have
taken into account both gender and
regional diversity. The Board remains
fully committed to diversity.
Role of Senior
Independent
Director
The evaluation highlighted the crucial role of
the SID in facilitating transparent and effective
communication between the Board and the
shareholders and other key stakeholders
recommending that the SID continues to report
to the Board on his engagements with
shareholders and stakeholders.
The Board in May 2024 formally
adopted the recommendation.
During 2024, the SID has maintained
numerous interactions and
communications via calls, road shows
etc with shareholders and regularly
reported these engagements to the
Board.
Training and
development on
ESG and other key
topics.
The report highlights the fact that the Board
should continue to identify opportunities for
updates and training on developments on key
areas – on banking, regulatory compliance,
ESG and other key topics
The Board has seized opportunities to
receive updates and training and
development on key areas on
banking, regulatory compliance, ESG
and other key topics (Refer to Section 2
subsection VI (3) – ‘Directors’ Induction
and ongoing development’).
Importance of
sustainability,
technology and
digitalisation
Lastly the report highlights the critical
importance of sustainability, technology, and
digitalization in shaping the Group's future.
While time constraints have limited in-depth
discussions, the Board sees great value in
further fostering informal discussions among all
members to delve into these essential topics.
During 2024 the Board established the
roles of the ‘ESG Champion’ and
‘Cybersecurity/IT Champion’. The roles
were assigned to Mr. Christian Philipp
Hansmeyer and Mr. Stuart Birrell,
respectively.
5.2. Annual Internal Board Evaluation
5.2.1. 2023 Annual Internal Board Evaluation
During 2024, the Board considered the report of the Annual Internal Board Evaluation for the year 2023
carried out by the Compliance Function. This report evaluates the performance of the Board of Directors
according to the provisions of the CBC Internal Governance Directive of CIs of 2021 (the ‘Internal
Governance Directive’), and the UK Corporate Governance Code (the ‘UK Code’) and proposes
recommendations for the Board’s better functioning.
The outcome of the 2023 internal board review identified certain key recommendations for which actions
were taken during 2024 to address them. This related to the composition of the Board with continued
consideration given to maintaining an appropriate composition taking into account relevant factors such
as the skills and experience in the area of ESG and technology/cybersecurity. During 2024, as noted
above, Mr. Christian Hansmeyer with significant expertise in ESG matters was appointed to the Board
and has also taken the role of the Board’s ESG Champion. In addition, training on ESG matters was
provided to Board members. Similarly, Mr. Stuart Birrell was appointed to the Board and has also taken
the role of the Board’s Cybersecurity/IT Champion. Relevant training was also provided to the Board
members.
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2. GOVERNANCE (continued)
VI. The Operations of the Board (continued)
5.2.2. Annual Internal Board Evaluation for 2024
The evaluation process for 2024, was initiated in January 2025 and utilized a multifaceted approach,
including:
Self-assessments by Board members through questionnaires,
Performance assessments by the Chairman,
Summaries of relevant items discussed at committee meetings, and
Interviews between the Chief Compliance Officer (the ‘CCO’) and each Board member.
This rigorous methodology aimed at reconfirming Board members’ independence, assessing their
external engagements, and identifying areas for enhanced expertise or knowledge, especially concerning
the dynamic developments anticipated in 2025 that could influence the Board's suitability as well as the
governance related strategy set by the Board.
The 2024 Annual Internal Board Performance Evaluation Report is a comprehensive report that adheres
strictly to the provisions set forth by the Central Bank of Cyprus (the ‘CBC’) Governance Directive and
assesses the performance of the Board, its committees, and individual Board members.
The results of the Annual Internal Board Evaluation for the year 2024 will be presented to the NCGC and
the Board in 2025. Reporting on the 2024 review will be shared in the 2025 Annual Report.
VII. Board's oversight of risk management and internal control systems
1. Accountability and audit
The Directors’ Report, including a Going Concern and a Viability Statement, is set out on pages 3 to 40.
This Corporate Governance Statement forms part of the Directors’ Report.
2. Internal Controls
The Board is responsible for the adequacy and effectiveness of the system of internal controls, corporate
governance and risk management framework of the Group, which ensure amongst others that:
1. The governance framework is effective, monitored and periodically assessed.
2. The compliance framework is appropriate.
3. The integrity and internal controls of the accounting and financial reporting systems, as well
as the compliance with relevant legal / supervisory requirements and reporting standards, are
adequate.
4. The information security framework for the protection of confidential information is appropriate.
5. The process of taking appropriate steps to timely address any deficiencies is effective.
The system of internal controls, corporate governance and risk management framework have been
designed in accordance with the nature, scale, and complexity of the Group’s operations, to provide
reasonable but not absolute assurance against material misstatements, errors, losses, fraud or breaches
of laws and regulations.
The overall system of internal controls, corporate governance and risk management framework of the
Group include amongst others:
A transparent organisational structure with clear reporting lines to Senior Management and the
Board.
Board and executive committees with clear responsibilities.
Three lines of defence model for the effective risk management and compliance across the
Group.
Formal policies and procedures.
Monthly reporting by business lines to enable progress to be monitored, trends to be evaluated
and variances to be acted upon.
Regular meetings of committees to review performance.
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2. GOVERNANCE (continued)
VII. Board's oversight of risk management and internal control systems (continued)
2. Internal Controls (continued)
Code of Ethics setting out the principles and expectations governing the behaviour of all officers
and employees.
Code of Conduct setting out the standards expected of all officers and employees.
Whistleblowing policy, including processes and procedures, to be followed for independent
investigation of concerns raised by staff.
Anti-Bribery policy in line with the UK regulatory guidance as well as with ISO37001.
Conflict of Interest policy.
Quarterly representations by all Divisions of the Bank to the CEO on the effectiveness of the
system of internal controls (policies, procedures and monitoring activities).
Annual representations by all control functions (Compliance, Risk, Information Security) to the
CEO on the effectiveness of the system of internal controls (policies, procedures, monitoring
activities).
The Board confirms that, through the AC and the RC, it has conducted reviews for the year ended 31
December 2024, regarding the effectiveness of the Group’s internal control and information systems, as
well as in relation to the procedures used to ensure the accuracy, completeness and validity of the
information provided to investors. The reviews covered all systems of internal controls, including
financial, operational, compliance, as well as risk management. In carrying out their reviews, the AC
and the RC receive regular business and operational risk assessments, regular reports from the Internal
Audit Director, the Chief Compliance Officer, the Chief Information Security Officer and the Chief Risk
Officer, other internal memos and external audit reports, as well as regulatory reports.
In case significant findings are identified in the compliance, risk management and information security
system of internal controls, the action plans for their remediation are discussed at the Executive
Committee, escalated to the AC, the RC and subsequently the Board, if deemed necessary, and
monitored until their resolution.
The Board receives a confirmation on an annual basis by the CEO for the effectiveness of compliance,
risk management and information security system of internal controls. Additionally, the Board, through
the AC and RC, has received confirmation that executive management has taken or is taking the
necessary actions to remedy all significant findings identified through the operation of the framework of
internal controls, corporate governance, and risk management processes, and to continuously modify or
enhance the system of internal controls, corporate governance and risk management framework as
required by the Bank’s current transformation.
Based on the internal audit work carried out in 2024, reasonable assurance is provided, with emphasis
on specific matters, on the design adequacy and operating effectiveness of the Group’s internal control
framework, corporate governance and risk management processes, for managing significant risks,
according to the risk appetite set by the Board. Emphasis is placed on the areas of Corporate Governance
and Regulatory Compliance, the Loan Origination process followed for QuickLoans and the area of
Information Systems, which require management’s attention to further manage current, as well as any
future risk exposures.
Overall, the Board of Directors, through its committees, has reviewed the effectiveness of the system of
internal controls, corporate governance and risk management processes of the Group for the year ended
31 December 2024 and confirms their overall effectiveness through the effective design and operation
of controls and mitigating factors in place.
The Group’s financial reporting process is controlled using documented accounting policies and
procedures supported by instructions and guidance on reporting requirements, issued to all reporting
entities within the Group in advance of each reporting period. The submission of financial information
from each reporting entity is subject to sign off by the responsible financial officer.
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2. GOVERNANCE (continued)
VII. Board's oversight of risk management and internal control systems (continued)
2. Internal Controls (continued)
The internal control system also ensures that the integrity of the accounting and financial reporting
systems, including financial and operational controls and the compliance with legal and supervisory
requirements and relevant standards, are adequate. The Group has in place an adequate financial
statement closing process through which transactions and events are reflected in the Group’s accounting
records and are processed to produce the financial statements, related disclosures and other financial
reports. This process relies either on the effective design and operation of controls or compensating
controls and other mitigating factors where these were inefficient. Where occasionally areas of
improvement are identified, these become the focus of management’s attention to resolve them and
thus strengthen the procedures that are in place. Such areas may include improvement of operating
deficiencies identified, the formalisation of existing controls, clear ownership of processes, the
creation/update of procedures’ manuals and the introduction of new information technology controls, as
part of the Group’ s ongoing digital journey. The Annual Financial Report and Interim Financial Report
and quarterly financial results are reviewed and approved by the EXCO, prior to their submission to the
Board. The Board, through the AC, scrutinises and approves the financial statements, results,
announcements, and the Annual and Interim Financial Reports and ensures that appropriate disclosures
have been made. Detailed papers are prepared for review and approval by the AC covering all significant
judgemental and technical accounting matters, together with any significant presentation and disclosure
matters.
This governance process enables both management and the Board to challenge the Group’s financial
statements and other significant disclosures before their publication.
The Group has developed an Integrated Risk Identification Framework which provides for the
identification, evaluation and management of the principal risks faced by the Group. The Group is forward
looking to ensure emerging risks are identified. A separate section on emerging risks is included in the
periodic risk reports to the RC. The Key Risk Matrix is thus updated and is approved by the RC and the
Board through the ICAAP process. The Board is responsible for determining the nature and extent of the
principal risks the Group is willing to take in achieving its strategic objectives and ensuring the
maintenance of an effective risk management and oversight process across the Group.
The Board approves the Group Risk Appetite Statement on an annual basis and receives regular updates
on the Group’s risk environment and exposure to the Group’s material risk types through the Risk Report
which is reviewed monthly. A consolidated risk report and risk appetite dashboard is regularly reviewed
by the RC to ensure the risk profile remains within the Group’s risk appetite and satisfactory mitigating
actions are in place.
The Board confirms that it carries out an assessment of both principal and emerging risks, including
risks that might threaten the Group’s business model, future performance, liquidity etc.
Business continuity risks are mitigated to ensure that the Group has business resilience and continuity
plans. They also ensure that the Group operates on a continuous basis and limits potential losses in the
event of a severe business disruption.
Information relating to the principal risks the Group faces and mitigation actions and risk management
is set out in Notes 44 to 47 of the Consolidated Financial Statements and in the ‘Risk and Capital
Management Report’, both of which form part of the 2024 Annual Financial Report and in the ‘Pillar III
Disclosures 2024’.
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2. GOVERNANCE (continued)
VIII. Group Code of Conduct and Whistleblowing Policy
The Group has set out the standards that are expected from all employees and Directors of the Company
in a Code of Conduct along with guidance on how these standards should be applicable. The statement
on Conduct and a dedicated Code of Ethics are publicly available on the Group’s website.
The Group has a Whistleblowing Policy and a relevant written procedure in place for all employees and
Directors of the Company, which are in accordance with international practice. The policy is reviewed
annually. Its general principles are:
1. Concerns in good faith, about wrongdoing or malpractice can be raised in confidence without
fear of victimisation, discrimination, disadvantage, or dismissal;
2. Procedures for the reporting of any matters of concern are clearly provided. The persons
concerned must be able to bypass the main channels for confidential reporting of matters of
concern if these are considered inappropriate and instead use the whistleblowing line;
3. Disclosures are managed in a timely, consistent, and professional manner; and
4. The appointment of the chairperson of the AC, an independent non-executive director, as the
Whistleblowing Champion with specific responsibilities.
The Board and the CEO are committed to this policy, which encourages staff to raise concerns. Regular
messages from the CEO to staff to speak up and e-learning sessions, are addressed to all staff and the
Board of Directors to further increase awareness.
The Board, reviews and approves annually, through the AC, the Whistleblowing Policy. Internal Audit
Division (IA) reports bi-annually to the AC, the number of disclosures made through the whistleblowing
channels and the number of cases completed. Furthermore, IA reports to the AC the findings of the
investigation of incidents reported through the whistleblowing channels and any subsequent actions
undertaken, where deemed appropriate. The Compliance Division also provides an annual analysis in
its compliance report, detailing whistleblowing incidents reported throughout the year and their status.
The Board sets the tone from the top, by appointing the AC Chairperson as the Group’s Whistleblowing
Champion. The AC Chairperson communicates with all staff, at least annually, to remind them of the
existence of the whistleblowing channels and to encourage them to use these when appropriate, without
fear of retaliation or other consequences.
IX. Stakeholder Engagement
1. Investors’ engagement
It is incumbent upon the Chair of the Board to ascertain efficacious communication pathways with
shareholders, while fostering a comprehensive understanding among the Directors regarding the
perspectives of major shareholders. Investor Relations has primary responsibility for managing and
developing the Group’s external relationships with existing and potential institutional equity/debt
investors and analysts.
The Group’s website features a specialised Investor Relations section, offering unhindered access to
relevant information, including presentations, publications, and public announcements. The Manager
Investor Relations & ESG is responsible for the communication between shareholders and the Group.
Information concerning the Group is provided to shareholders, prospective investors, brokers, and
analysts in a prompt and unbiased manner free of charge.
Institutional equity investors and analysts
The Group maintains a dynamic and meticulously structured Investor Relations agenda, facilitating
regular meetings with the CEO, Executive Directors, selected members of the Senior Management, the
Manager of Investor Relations & ESG, and other officials with the Group’s major institutional
shareholders, potential new investors, financial analysts, and market participants. In the year 2024, 281
meetings were held. Every meeting is scrupulously conducted to prevent the disclosure of price-sensitive
information.
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2. GOVERNANCE (continued)
IX. Stakeholder Engagement (continued)
1. Investors’ engagement (continued)
Engagement with major shareholders
To facilitate the Board’s understanding of the views of major shareholders, the Directors receive an
investor relations update from management at all scheduled meetings of the Board. The content of this
update includes market updates, details of recent equity and debt investor interactions, share price and
valuation analysis, analyst updates, and share register analysis. The Group facilitates the direct dialogue
with investors since it is striving for the greatest possible transparency. The Group also works towards
integrating feedback in its corporate strategy. This is achieved through participation in conferences,
private meetings, road shows, frequent conference calls and at least quarterly updates following the
publication of financial results and corporate transactions. The CEO, the EDF and the Manager Investor
Relations & ESG engaged extensively in 2024 with existing shareholders, and potential new investors
during individual or group meetings and on roadshows and investor conferences.
Engagement with shareholders
It is a priority for the Group to communicate with shareholders.
The Group uses its website (www.bankofcyprus.com/en-gb/group/investor-relations/) to provide
shareholders and potential investors with recent and relevant financial information, including the annual
and the interim financial reports and quarterly results announcements and presentations. The Investor
Relations section of the Group’s website is updated with all announcements published on the LSE (up
until the delisting from the LSE on 19 September 2024), on the ATHEX (since the listing of the Company’s
ordinary shares on the ATHEX on 17 September 2024) and on the CSE. It also contains the contact
details of the Investor Relations Department.
One of the responsibilities of the Chair of the Board is to ensure that the views, issues, and concerns of
shareholders are effectively communicated to the Board and to ensure that Directors develop an
understanding of the views of major investors. The Board considered the views of major shareholders
on Company strategy and performance and assessed investor sentiment more broadly in conjunction
with the Group’s corporate brokers.
The Chair and the SID maintain direct contact with investors and are available to all shareholders if they
have concerns that cannot be resolved through the normal channels.
All shareholders of the Company are treated on an equal basis. There are no shareholders with special
control rights. Shareholders are promptly and accurately informed of any material changes regarding
the Group, including its financial position, financial results, ownership, and governance.
Under the Irish Companies Act 2014, one or more members holding at least 3% of the issued share
capital of the Company, representing at least 3% of the total voting rights of all the members who have
a right to vote at the meeting to which the request for inclusion of the item relates, has the right to: (a)
put an item on the agenda of the AGM, provided that the item has been accompanied by stated grounds
justifying its inclusion, or a draft resolution to be adopted; and (b) to table a draft resolution for an item
on the agenda of a general meeting.
Such a request must have been received by the Company at least 42 days prior to the relevant meeting.
Any change or addition to the Articles of Association of the Company is only valid if approved by a special
resolution at a meeting of the shareholders. Major shareholders do not have different voting rights from
those of other shareholders.
Information on notifiable interest in the share capital of the Company as of 31 December 2024 is included
in the Directors’ Report of the 2024 Annual Financial Report under section Major holders of shares and
financial instruments in page 33.
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2. GOVERNANCE (continued)
IX. Stakeholder Engagement (continued)
1. Investors’ engagement (continued)
AGM
The Annual General Meeting (‘AGM’) is an opportunity for shareholders to hear directly from the Board
on the Group’s performance and strategic direction and ask questions.
The AGM of the Company was held at the Headquarters of the Bank on Friday, 17 May 2024. The AGM
was attended by 48 Shareholders & Depository Interest Holders, either in person or by proxy, who
represented 212,918,972 shares, representing 47.75% of the total issued share capital of the Company.
Separate resolutions are proposed on each separate issue and voting is conducted by way of a poll. The
votes for, against and withheld on each resolution are subsequently published on the Group’s website.
The full set of the resolutions passed can be found on the Group’s website on
https://www.bankofcyprus.com/globalassets/group/investor-relations/agm/agm-
2024/information/eng/20240517-resolutions-of-the-shareholders-agm_en.pdf
The above Special Business resolutions are valid until the next AGM or 15 August 2025, whichever is the
earlier.
At the 2024 AGM all resolutions passed, with all resolutions receiving between 98.31% and 100%
approval. In line with the Group’s policy to issue notice of the AGM 21 clear days before the meeting,
notice of the 2024 AGM was circulated to shareholders on 12 April 2024. All members of the Board
attended the 2024 AGM. The 2025 AGM is scheduled to be held on 16 May 2025. Further details will be
issued in the AGM Notice which will be issued at least 21 clear days before the meeting.
EGM
An Extra-ordinary General Meeting (‘EGM’) of the Company was held at the Headquarters of the Bank
on Friday, 13 September 2024. The EGM was attended by 36 Shareholders & Depository Interest Holders,
either in person or by proxy, who represented 213.271.945 shares, representing 48.08%% of the total
issued share capital of the Company.
At the EGM, the Company’s shareholders voted to approve the admission to listing for trading of the
Ordinary Shares in issue from time to time, on the Main Market of the Regulated Securities Market of
the Athens Stock Exchange (‘ATHEX’), in accordance with Greek law no. 3371/2005 (the ‘Listing’).
Following the approval of the ATHEX Listing Committee for the Listing, the Company applied and
performed the delisting of the Ordinary Shares from the international commercial companies secondary
listing category of the Official List of the London Stock Exchange Group plc, with effect from 8:00 a.m.
(London time) on 19 September 2024, with the last day of trading of Ordinary Shares on the LSE being
18 September 2024, and trading was suspended at 4:30 p.m. (London time).
At the EGM, the shareholders also approved the adoption of amended Articles of Association of the
Company with effect from the conclusion of the EGM.
Both resolutions passed, with both resolutions receiving between 99.98% approval.
The full set of the resolutions passed can be found on the Group’s website on
https://www.bankofcyprus.com/globalassets/group/investor-relations/egm-2024/gr/notice-
circular/20240913-egm-resolutions_gr_final.pdf
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2. GOVERNANCE (continued)
IX. Stakeholder Engagement (continued)
2. Customers
The Group’s strategy encompasses a multichannel communication approach, personalised banking
services, and comprehensive customer support to foster enhanced customer engagement and service
delivery. It integrates physical branches with digital platforms, social media, and traditional
communication methods for effective outreach. Personalisation is achieved through tailored banking
solutions informed by customer data, including personalised offers and dedicated bankers for specific
customer segments, ensuring services are relevant and valuable. Customer support is broad, featuring
extensive online and mobile services, a responsive call centre, and specialized in-branch roles to educate
and assist customers, along with initiatives aimed at promoting financial literacy. A new loyalty scheme
called ‘Pronomia’ has been introduced to reward the overall customer relationship, elevate satisfaction
and show the Bank’s appreciation to its valued clients. This approach highlights the dedication of the
Group to customer-centricity, leveraging technology and personalized services to meet the evolving
needs of its customer base. This comprehensive approach to customer engagement and service not only
meets the evolving needs of the Group's customer base but also reinforces the principles of good
corporate governance, ensuring that the Group remains accountable, transparent, and responsive to all
stakeholders.
The Board remains committed to enhancing customer engagement by regularly tracking progress against
customer metrics (such as the trust index and the net promoter score (NPS) resulting from the Rolling
Surveys taking place monthly). The integration of customer feedback into strategic decisions and
operational improvements is a key priority. The Board, through updates from various teams of the Group,
as well as the CEO briefings, examines various aspects of the customer journey, highlighting areas of
excellence and pinpointing those in need of enhancement. Reviewing strategy, receiving implementation
updates, and assessing progress are integral components of the governance process. Furthermore, the
Board Committees are kept informed on promoting ESG knowledge initiatives aimed at customers.
3. Engagement with Colleagues
The Board, through the HRRC, continues to receive regular updates, and monitors the progress of Human
Resources initiatives that are anchored on key strategic goals. These goals are strategically designed to
enable the Organisation of Tomorrow, enhance Career Development and Advancement Opportunities,
empower a High-Performance Culture, enhance the employee experience, develop talent, and achieve
Organisational Health Excellence
2
in specific priority areas.
In an ongoing commitment to employee engagement and continuous improvement, the HRRC
meticulously reviews feedback from the Group’s staff surveys. Significant strides have been made in
implementing actions responsive to staff feedback, ensuring that the organisation evolves in alignment
with employee insights and aspirations. The Board has remained particularly attentive to promoting and
adhering to the Code of Conduct
3
and reinforcing the integrity of the speak up channels, thereby
fostering an environment where ethical conduct is prioritized.
Further information on the work overseen by the HRRC can be found in Section 2, subsection XII of this
Report.
Moreover, the Board strongly believes in fostering direct engagement with colleagues, recognising that
people at all levels are critical to our organisation’s success.
2
Organisational Health Excellence outlines the practices and behaviours that are required or prohibited by employees.
It sets out the actual rules, so it lays down the dos and don’ts. Employees are responsible to adhere to it and are
held accountable for any violation.
3
The Code of Conduct is part of the Code of Ethics, which is published on the website of the Group
(https://www.bankofcyprus.com/globalassets/who-we-are/our-culture/ethicscode_eng.pdf)
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2. GOVERNANCE (continued)
IX. Stakeholder Engagement (continued)
3. Engagement with Colleagues (continued)
During 2024, Board engagement with colleagues (i.e. the Group’s workforce) included:
Invitation of subject matter experts (in addition to their managers) to present their work
before members of the Board;
A session of the HRRC Committee with the Heads of HR Units reporting to Manager People
and CEO Office;
Participation of the Chair in a Town Hall meeting with managers and team leaders to
reinforce communication on the importance of an ethical culture within the organisation;
Sponsoring at the Board level of the Group-wide project on Risk Culture Awareness by the
Chair of the AC;
Direct communication of the AC Chair with staff members emphasizing the significance of
whistleblowing in safeguarding organisational integrity. His communications stressed the
importance of speaking up and reporting incidents, reaffirming the organisation’s staunch
commitment to ensuring anonymity, confidentiality, and the thorough investigation of all
reported incidents;
Furthermore, the Board has sustained open and responsive communication channels, notably the Ask
the Board’ initiative. This platform allows staff members direct access to the Board of Directors, enabling
them to file questions or queries, thereby fostering a culture of transparency, inclusivity, and mutual
respect.
These structured initiatives and strategic goals collectively aim to bolster the organisation’s human
resources framework, cultivating a thriving and ethically sound operational environment, and steering
the organisation towards a future marked by innovation, excellence, and continuous improvement.
4. Regulators and Government
The Chair and the Board recognize the importance of strong interpersonal relationships and dynamics in
building mutual trust, which is essential for effective on-site governance and managing business risks.
To support this, they regularly meet with key representatives from various regulatory and government
entities, including the European Central Bank (the ‘ECB’) Senior Management, the Joint Supervisory
Team (the ‘JST’), the Central Bank of Cyprus (the ‘CBC’), the Single Resolution Board (the ‘SRB’), and
the Ministry of Finance (the ‘MoF’), among others.
The main areas of discussions during these meetings, include important topics such as regulation and
supervision, risk governance and oversight, current challenges in the banking industry, strategic matters,
and efforts to build trust and risk culture within the organization. The Chair, along with the Group CEO,
ensures that the Board is kept up-to-date on the outcomes and key insights from these engagements.
The Regulatory Affairs Framework in place, facilitates the arrangement of regular meetings throughout
the year, which are coordinated by the Regulatory Affairs Department and enable productive discussions
between the Chair, the Board of Directors, the Executive Management, the Internal Control functions,
and other senior management personnel. To help the Chair and the Board understand the regulators'
views and expectations, the Regulatory Affairs Department provides regular updates on engagement
and communications with the regulators, details of on-site and off-site reviews, as well as progress
updates on the ongoing implementation of regulatory requirements and recommendations.
The Board and the Group's management is committed to maintaining a continuous, transparent, and
constructive dialogue with regulatory and supervisory bodies. This engagement aims to build their
confidence and trust, earn their respect, maintain the Bank’s good image among its stakeholders and
minimize the Group's regulatory risks. Through these efforts, the Group demonstrates its strong
commitment to upholding and enhancing the essential regulatory relationships and operational
standards.
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2. GOVERNANCE (continued)
IX. Stakeholder Engagement (continued)
5. Engagement with Society
The Group’s Corporate Social Responsibility Programme (the ‘CSR Programme’) and all relevant
initiatives are compatible with its core business and enhance the Group’s overall strategy and vision.
The CSR Programme infolds within three Pillars: Health, Education and Environment. All initiatives
operate in collaboration with expert Non-Governmental, Non-Profitable Organisations, other entities and
public services. The Corporate Social Responsibility Strategy and CSR Programme contribute to the
Social Pillar of the ESG Strategy and support the Group’s selected United Nations Sustainability
Development Goals (the ‘SDGs’).
During 2024, the Group continued its work on the Financial Education sub-pillar within the Education
Pillar. More specifically, the Group continued working on targeting elderly citizens, providing them with
information on basic financial terms and the use of the Bank's digital channels for banking transactions.
Within the same pillar, the Bank continued awarding and promoting Youth Excellence focusing on STEAM
(Science-Technology-Engineering-Art-Mathematics) subjects and sport youth talents.
Within the Health Pillar, the Group continued to undertake sustainable support to the local community
with health-related initiatives, focusing on cancer patients and having the Bank of Cyprus Oncology
Centre as its flagship with an overall investment of 70 million since 1998, whilst 55% of diagnosed
cancer cases in Cyprus are being treated at the Centre.
Additionally, the Group continued to develop initiatives that aimed to preserve local culture and history,
through the Bank of Cyprus Cultural Foundation (BOCCF) and to enhance innovation and start-ups
through the IDEA Innovation Centre.
Furthermore, the IDEA Innovation Centre, has supported the establishment of 95 startups to date, and
provided support to 230+ entrepreneurs through its Startup program since incorporation.
Staff have continued to engage in voluntary initiatives to support charities, foundations, people in need
and initiatives to protect the environment.
Finally, the Bank successfully continued and expanded the operation of the award winning SupportCY
network of companies and NGOs. SupportCY was created by the Bank in March 2020, in order to support
public services performing frontline duties during the COVID-19 pandemic. Its actions, led by the Bank
expanded in supporting various societal needs. In 2024, SupportCY continued offering important
assistance and support during natural or manmade disasters, crises and emergencies, with specialized
programmes, equipment and trained personnel, in Cyprus and abroad.
6. ESG
This year, the Group has prepared its Sustainability Statement in line with the European Sustainability
Reporting Standards (the ‘ESRS’) to comply with the Corporate Sustainability Reporting Directive (the
‘CSRD’). Progressing on the sustainability agenda is a strategic priority for the Group. The ESG strategy
formulated in 2021 is continuously expanding. The Group is maintaining its leading role in the Social
and Governance pillars and focus on increasing the Group’s positive impact on the Environment by
transforming not only its own operations, but also the operations of its customers. The Sustainability
Statement is included in the 2024 Annual Financial Report on pages 77 to 254.
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2. GOVERNANCE (continued)
X. Key Board Activities in 2024:
During 2024, the Board remained focused on the Group’s strategic direction and delivery, and overseeing
Group performance. It considered performance against financial and other strategic objectives, key
business challenges, emerging risks, sustainability and governance, business development, investor
relations and the Group’s relationships with its stakeholders. While not intended to be exhaustive, below
is a high-level overview of a number of matters considered by the Board during 2024.
Stakeholder key:
I investors S society Cu customers Co colleagues R regulator
2024
Key focus area Key Matters Actions taken
Stakeholders
affected
Strategy
Athens listing
After thorough deliberation over the year, the
Board resolved in August 2024 to proceed with
the delisting of the shares of the Company from
the LSE and the listing of the shares on ATHEX.
This strategic move came after a comprehensive
analysis of market conditions, potential growth
opportunities, and shareholder interests. The
Board believes that listing on ATHEX will enhance
the Company's visibility, improve liquidity, and
provide greater access to capital, ultimately
fostering long-term value creation for all
stakeholders.
The Board approved the
delisting of the Company's
shares from the LSE and
the listing of the shares on
ATHEX.
I, S, Cu, Co, R
Strategic and
business
performance
Overarching Strategic Plan Framework: The
Board of Directors reviewed the strategic plan
framework, ensuring the organization's long-
term success. This blueprint outlines key
objectives, priorities, and initiatives for growth.
Financial Plan 2024-2027: Reviewed and
discussed the four-year financial plan of the
Group, including external and internal
assumptions. The Board discussed in detail the
assumptions of the Financial Plan in alignment
with the macro environment and the strategy of
the Group. The impact of market interest rates
on results was extensively analysed and
discussed.
Business Updates: Received business reviews
throughout the year to understand key risks and
opportunities and monitor progress against the
targets set. The Group remains focused on
creating sustainable returns for investors,
enhancing customer service, and creating
capacity for future investment.
The Board approved the
revised Overarching
Strategic Plan Framework
for 2024.
The Board approved the
Financial Plan 2024-2027.
Throughout 2024, the
Board discussed the
Group’s strategic
performance and
opportunities to track
strategic execution and
delivery.
I, S, Cu, Co, R
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2. GOVERNANCE (continued)
X. Key Board Activities in 2024: (continued)
2024
Key focus area Key Matters Actions taken
Stakeholders
affected
ESG Strategy
Throughout 2024, the Board received regular
updates on the progress regarding the
Environmental, Social, and Governance (ESG)
strategy and regulatory reporting. These
updates were meticulously detailed, ensuring
the Board was well-informed about key
milestones, challenges, and achievements.
Regular briefings included comprehensive
reports on sustainability initiatives, compliance
with regulatory standards, and the overall
impact of the ESG strategy on the Group's
operations and reputation.
The Board considered
progress on CSRD
implementation and
monitored regularly
progress on Sustainability
KPIs.
I, S, Cu, Co, R
Digitalisation
strategy
Throughout 2024, the Board received regular
updates on the progress of executing and
forming the digitalisation strategy. These
updates were provided through quarterly
reports, which detailed milestones achieved,
challenges encountered, and solutions
implemented. Furthermore, dedicated sessions
during Board meetings allowed for in-depth
discussions on the strategy's advancements and
adjustments.
The Board was regularly
updated on the progress.
I, S, Cu, Co, R
Strategic
transactions
The Board regularly engaged in comprehensive
reviews of the Group's strategic processes,
ensuring alignment with its long-term
objectives. Through meticulous evaluation and
discussion, the Board examined market trends,
risk management protocols, and growth
opportunities. This rigorous oversight facilitated
informed decision-making and strong
governance, ultimately driving the Group's
success and stability in an ever-evolving
financial landscape.
The Board has resolved to
proceed with the
exploration of various
opportunities including the
strategic review
undertaken for the
subsidiary JCC Payment
Systems Ltd, and the
approval to proceed with
disposal of two small NPE
portfolios with funds
associated with Cerberus
Global Investments B.V.
I, S, Cu, Co, R
Culture
Organisational
Health Index
In mid-2024 the Board received an update on
the findings of the Organisational Health Index
(OHI) survey which was conducted with focus
groups composed of employees of the Group and
has been presented with the survey results.
These results were carefully considered and
affirmed.
Activities and dialogue are
on ongoing basis.
Co
Workforce
Engagement
Throughout 2024, the Board has been actively
engaged in discussions regarding workforce
engagement mechanisms. These discussions
have focused on developing strategies to
enhance employee participation, improve
communication channels, and foster a more
inclusive work environment.
Activities and dialogue are
on ongoing basis.
Co
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2. GOVERNANCE (continued)
X. Key Board Activities in 2024: (continued)
2024
Key focus area Key Matters Actions taken
Stakeholders
affected
Risk Culture
During 2024, the Board has continued placing
emphasis on enhancing the metrics with respect
to the risk culture of the Group.
The Board regularly and continuously engages in
discussions concerning the risk cultural approach
for various stakeholders.
Activities and dialogue are
on ongoing basis.
I, S, Cu, Co, R
Financial
Financial
Performance
and Reporting
Regular updates from the EDF were provided to
assess the Group's financial performance and the
performance of the business divisions. In
addition, investor feedback was received on a
regular basis including following the publication
of the Group's financial results.
The Group’s 2023 Annual
Financial Report was
approved, along with the
Interim Financial Report
and the quarterly financial
results and
announcements.
I, Cu, R
Distributions
and capital
status
Monitored capital and liquidity position and
considered distribution proposals in the context
of its four-year financial plan.
Considered the Shareholders Distribution Policy
and the distribution proposals to shareholders
for the year 2023 including the payment of a
cash dividend and the establishment of a share
buyback programme.
Approved 2023 dividend
payment of 0.25 cents per
ordinary share and a share
buyback for of up to 25
million.
I, Cu, R
Risk, Resilience, Recovery
Risk
The Risk Profile of the Group and principal risks
faced, as well as setting the Risk Appetite
Framework, were core areas of focus for 2024.
The comprehensive review, consideration and
strategic alignment of these elements were
deemed essential to guide the Group's risk
management approach.
Throughout 2024, the Board continuously
monitored the risk behaviour and performance of
the Group with respect to the set risk
performance indicators. Regular updates of loan
asset quality and analysis of the main credit risk
areas of the Group were also provided. The
Board also monitored the Group's risk behaviour
in relation to geopolitical developments in the
region as these progressed throughout the year.
The Board monitored on a
regular basis the risk
profile of the Group and
considered and approved
the revised the Risk
Appetite Framework as well
as the update of
performance over relevant
risk indicators.
I, S, Cu, Co, R
Counterparty & Country Credit Limit Framework:
The Board considered and approved the annual
revision of the framework set for the effective
assessment, monitoring and control of the
Counterparty & Country Credit Risk and
Counterparty Settlement Risk, as well as for
setting the limits’ approval levels and the
reporting levels in the cases of breaches.
The Board approved the
Annual revision of the
Counterparty & Country
Credit Limit Framework.
I, S, Cu, Co, R
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2. GOVERNANCE (continued)
X. Key Board Activities in 2024: (continued)
2024
Key focus area Key Matters Actions taken
Stakeholders
affected
Annual Review of Market Risk Limits: As an
integral part of risk management, the Board
considered the findings of the yearly review
assessment on the appropriateness of
established market risk limits (revising these
where appropriate) ensuring that the
institution's risk appetite aligns with market
conditions and approach to risk taking.
The Board approved the set
market risk limits for 2024.
I, S, Cu, Co, R
Annual ICAAP /ILAAP: The Board considered and
approved the 2023 ICAAP and ILAAP following
the assessment that the Group is in a position to
withstand severe stress situations and maintain
its capital and liquidity adequacy both from a
normative and economic perspective.
The Board approved the
Annual 2023 ICAAP and
ILAAP.
I, S, Cu, Co, R
Annual Reputational Risk Report: The Board
considered the findings of the evaluation of the
potential risks to the institution's reputation,
arising from various sources.
The Board approved the
Annual Reputational Risk
Report.
I, S, Cu, Co, R
IRRBB Strategy Framework and Significant
Outlier Test Compliance Plan: The Board
assessed and approved the Interest Rate Risk in
the Banking Book (IRRBB) strategy framework
and the revised Supervisory Outliers Test
compliance plan.
The Board approved the
IRRBB Strategy Framework
and the revisions on the
Significant Outlier Test
Compliance Plan. During
the year the Board
monitored progress on
hedging actions
undertaken.
I, S, Cu, Co, R
Updated Bond Strategy and risk assessment of
the updated bond strategy: The Board
considered updates on the progress of the bond
strategy and considered relevant risk
assessment of the updated bond strategy
concluding in favour of the proposed portfolio
expansion by the year end which largely ensured
a gradual and controlled increase allowing to
properly assess, monitor and mitigate the
various risk factors.
The Board considered and
approved the updated bond
strategy.
Recovery &
Resolution
The Board reviewed and approved the 2024
Recovery Plan, addressing the challenges and
strategies for successful implementation.
Received updates on activities to enhance the
Group’s resolvability arrangements, including
management's testing and assurance plans.
The Board considered the 2024 MREL
Compliance Plan.
Approved the Recovery
Plan 2024, 2024 MREL
Compliance plan and
resolution related material.
I, S, Cu, Co, R
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2. GOVERNANCE (continued)
X. Key Board Activities in 2024: (continued)
2024
Key focus area Key Matters Actions taken
Stakeholders
affected
Operational
Resilience
The Board's role in information security and data
quality is vital for organizational resilience. The
Board oversees and establishes policies to
protect critical data, ensuring integrity and
security protocols are in place to guard against
threats and disruptions.
The Board regularly
received Information
Security updates
monitoring the progress of
the relevant indicators.
The Board was regularly
updated on data quality
risks.
I, S, Cu, Co, R
Governance and regulatory matters
Board
Governance
Succession planning: In 2024, the Board
thoroughly reviewed and approved its own
succession planning process and the processes
for the Chair and CEO succession. Additionally,
the Board considered and endorsed a 2-year
Board succession plan to ensure the
organization's stability and effectiveness.
Approved the revised
succession planning
processes for the Board
Chair and the CEO.
Approved the revised 2-
year Board succession
plan.
Cu,I,R
Board Composition: In 2024, the Board
considered the assessment of collective
suitability of the Board, ensuring the presence of
the right skillset, experience, and diversity. The
Board also focused on the optimum size and
composition of the Board, particularly addressing
the need for gender targets, reinforcing the
Board’s commitment to inclusivity and effective
governance.
Approved the results of the
revised collective suitability
assessments of the Board
and proceeded with actions
to close the identified gaps.
Cu,I,R
Board Operation: In 2024, the Board thoroughly
reviewed and considered the enhancement of
the Company Secretary’s Office, updates to
governance and compliance policies, and
revisions to the Matters reserved for the Board
and the Terms of Reference of Board
Committees. The Board further considered the
conclusions of the Internal Annual Board
Evaluation and the Triennial Board Evaluation for
the year 2023 conducted by external
stakeholders and proceeded with the
implementation of recommendations arising
from these evaluations.
Approved the changes in
policies relating to
assigning the approval of
all matters to the Board of
Directors following the
relevant Board
Committee’s review and
recommendation.
Approved the appointment
of ESG and Cyber Security
and IT Champions.
Approved the amendment
that the SID should report
bi-annually to the Board on
the engagement with
shareholders and
stakeholders.
Cu,I,R
Succession
planning of
Senior
Management
and Key
Function
Holders
In 2024, the Board considered, discussed and
approved the comprehensive succession plans
for Senior Management and Key Function
Holders. The plans were meticulously crafted to
align with the Company's long-term goals,
fostering a resilient leadership pipeline capable
of steering the organization towards sustained
success.
The Board approved the
succession plans of the
senior management and
key function holders.
I, S, Cu, Co, R
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2. GOVERNANCE (continued)
X. Key Board Activities in 2024: (continued)
2024
Key focus area Key Matters Actions taken
Stakeholders
affected
Regulatory
matters
The Board regularly received updates on
regulatory developments impacting the Group.
The Board has, throughout 2024, maintained
continuous communication and liaison with the
Regulator.
The Board considered
updates on regulatory
developments impacting
the Group.
Cu,I,R
Deep Dives
Occasionally, the Board holds deep dive sessions
with key business lines to provide members with
a deeper insight into key areas of strategic focus,
enable better quality of debate and enhance
knowledge. The deep dives usually include
presentations and opportunity for discussion.
Deep Dives for 2024 were
performed on matters of
Credit Approval
Procedures, UTP
Framework and on the Real
Estate Portfolio and
Strategy.
I, S, Cu, Co, R
Meetings with
Heads of
Control
Functions
Monitor effectiveness of Control Functions Sessions are held for Heads
of Control Functions to
provide feedback on
general ability to perform
their duties and to bring to
the attention of the Board
any issues that could
potentially jeopardise their
independence
R
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2. GOVERNANCE (continued)
BOARD COMMITTEES:
XI. Nominations and Corporate Governance Committee
Strengthening Board Composition and Committee effectiveness, enhancing governance practices,
ensuring effective succession planning and overseeing progress in shaping and delivering the Group’s
ESG agenda.
Dear Stakeholders,
In 2024, the NCGC continued to perform a pivotal role in securing an effective Board composition and
functioning, prioritizing Board membership selection and appointment processes and overseeing Board
evaluation processes. Board succession planning procedures have been revisited and streamlined with
other internal procedures, and the NCGC reconsidered and enhanced further its own functioning. The
adherence to strong governance practices as well as the implementation of the Group’s ESG agenda and
strategic goals have also taken center stage in the past year.
With regards to the composition of the Board, following the departure of 4 Board members towards the
end of 2023 and the sudden loss of the Senior Independent Director/Chair of the HRRC, AC and TC on
16 June 2024, one of the NCGC’s priority tasks has been to initiate and implement processes for selection
and appointment of new Board members. The NCGC devoted significant time to evaluating potential
Board members and implementing all relevant recruitment procedures, keeping in mind the results of
the collective suitability assessment conducted during 2024, the Group’s gender diversity targets. During
the beginning of the second quarter of 2024, the Board composition was enhanced with two new
members with expertise in ESG and Cyber/Information Security and Technology respectively and during
2024 a number of interviews have been held with eligible candidates with a view to further enhance the
Board composition within 2025. Board Succession Planning Processes have been streamlined with
selection processes and collective suitability findings accordingly. In addition, the NCGC continued to
oversee Senior Executive Appointments and Succession Planning for Key Function Holders. The
Committee continued to uphold the view that effective corporate governance is a fundamental part of
business success and reviewed both its own functioning as well as that of the Board to introduce practices
that would make their functioning as effective as possible. The Committee continued to oversee updates
in the Terms of Reference of all Board Committees and to the ‘Matters Reserved for the Board’ and
proposed that all matters/topics/frameworks/policies are assigned to Board Committees first, prior to
being reviewed and decided at Board level, to ensure in depth deliberation and discussion at Committee
level of all matters before their submission to the Board for consideration and approval. ESG is key
priority for the Group and oversight of the Group’s ambitious ESG strategy, agenda (including climate)
and disclosures, remained a key priority for the NCGC.
Looking ahead, the NCGC will continue its work on reaching optimum Board composition, considering
governance and regulatory requirements and diversity targets and always in line with the Group’s
strategic priorities and governance practices. The NCGC will continue to oversee the evolution on the
Group’s and Board‘s governance practices to ensure adherence to any new legal and regulatory
requirements and optimize the Group’s modus operandi. 2025 will be another year of progress on the
Group’s climate and ESG agenda and we look forward to overseeing the Company reaching new highs
in making its first CSRD disclosures and in shaping and delivering ESG strategic objectives.
Finally, I would like to take this opportunity to thank all the members of the NCGC, whose expertise,
diligence and commitment has ensured the success of our journey thus far and for building a strong
foundation for achieving the Group’s goals in the coming year.
Sincerely,
Takis Arapoglou
NCGC Chair 2024
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2. GOVERNANCE (continued)
XI. Nominations and Corporate Governance Committee (continued)
Role & Composition of Committee
Role of Committee
The Committee is primarily responsible for reviewing:
Board and Committee Composition/new Board member selection;
Senior Executives and Board Succession planning;
Board effectiveness; and
Effective governance including overseeing the assessment of the fitness & probity of members
of the Group Executive Committee, other Senior Managers and Heads of the Internal Control
Functions.
The Committee’s TORs are available on:
https://www.bankofcyprus.com/en-gb/group/who-we-are/our-governance/group-
committees/nominations-corporate-governance-committee/
Composition of Committee
Composition from 01.01.2024 to 16.05.2024:
o Takis Arapoglou (Chair)
o Lyn Grobler
o Adrian Lewis
Composition from 17.05.2024 to 31.12.2024:
o Takis Arapoglou (Chair)
o Lyn Grobler
o Christian Hansmeyer
On 17 May 2024, the Committee’s composition changed following the election of the two new non-
executive directors, Mr. Stuart Birrell and Mr. Christian Hansmeyer at the 2024 Annual General Meeting.
This decision considered Mr. Hansmeyer’s expertise in ESG matters, in alignment with the NCGC’s
responsibility to provide oversight into the Group’s ESG and climate strategy.
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2. GOVERNANCE (continued)
XI. Nominations and Corporate Governance Committee (continued)
Primary activities of the Committee in 2024:
Key focus area Key Matters Actions taken
Board
Composition
Collective Suitability
Assessment
Assessment of Collective
Suitability of the Management
Body, to safeguard existence of
the right skillset, experience
and diversity for members of
the Board to be individually and
collectively suitable to perform
their role effectively.
The NCGC oversaw the conduct of a Collective
Suitability Assessment for the members of the Board,
following its enhancement with two new members. In
this context the Committee analysed existing gaps
and identified the required experiences and skillset to
ensure optimum Board functioning. The recruitment
process considered required skills, experience, gender
diversity targets, regional diversity, and criteria in the
CBC Suitability Directive for the Board.
Nomination for new NEDs
Ensuring optimum size and
composition of the Board.
The NCGC ensures a formal,
rigorous, and transparent
procedure when considering
candidates for appointment to
the Board.
Taking action to meet Gender
Targets
Following the resignation of 4 Board members in
2024, and the unexpected passing of former SID and
AC/TC/HRRC Chair Mr. Dinos Iordanou, the Committee
considered the enhancement of the Board size and
composition a key priority for 2024.
To this end the Committee initiated the Group’s
selection processes for the recruitment of new
members of the Board in accordance with its
Nominations and Diversity Policy and the Group
Suitability Policy which are in turn fully aligned with
the CBC Suitability Directive (and the Joint Guidelines
on Suitability). As a result of this work, the
composition of the Board is expected to be enhanced
within 2025.
The Board has approved relevant budget should
external support be required for the identification and
selection of suitable NEDs.
An action plan for planned actions to be taken to meet
the gender target in relation to the composition of the
Board was put in place.
Key focus area Key Matters Actions taken
Succession
Planning
Review of Board Succession
Planning Process and
introduction of Board Chair
Succession Planning Process
Ensuring continuation and
succession of a strong and
diverse Board and a smooth
succession for Key Function
Holders
Overseeing Succession Planning at both the Board
level and at the level of Key Function Holders was an
area of focus during 2024.
The Committee reviewed a revised Succession
Planning Process for the Board which fully correlated
the Collective Suitability Process with the Succession
Planning Process, and streamlined external
recruitment processes with succession planning
practices. The updated process also addresses
emergency succession and is fully aligned with
revisions of the CBC Internal Governance Directive.
A New Succession Planning Process for the Chair of
the Board of Directors was also introduced.
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2. GOVERNANCE (continued)
XI. Nominations and Corporate Governance Committee (continued)
Primary activities of the Committee in 2024: (continued)
Key focus area Key Matters Actions taken
Review of 2-Year Succession
Plan
Planning in anticipation of any
departures (e.g. end of tenure/ loss
of independence status) and
planning in a timely manner
New Succession Planning
Process for the CEO
Introducing a specific process for
this need, to ensure leadership
continuity.
Succession Planning of Key
Function Holders
The 2 Year Succession Plan in 2024, revealed the loss
of independence status for one Board member in
2026. Deliberations on suitable successor have been
initiated to ensure a smooth and timely succession.
The committee has reviewed and approved a new
succession planning process for the CEO.
Overseeing Succession Planning at the level of Key
Function Holders was an area of focus during 2024.
Succession of Key Function Holders constitutes a
separate succession planning process whose
implementation falls under both the NCGC and the
responsibilities of the HRRC.
Key focus area Key Matters Actions taken
BOD Internal
Governance
Review and updates of
Compliance Policies to align
with changes and changing role
of the Company Secretary’s
office
Revision of Matters reserved for
the Board, and Terms of
Reference of Board Committees
The following policies were reviewed and updated
regarding the functioning of the Chairman’s and
Company Secretary’s Office and Corporate
Governance Compliance Unit:
Group Corporate Governance Policy & Framework
Group Policy on the suitability of Members of the
Management Body and Key Function Holders
Board Nominations and Diversity Policy
The ‘Matters Reserved for the Board’ have been
revised as all matters requiring approval are assigned
to a Board Committee for in depth discussion and
consideration, with the relevant Committee ultimately
making a recommendation to the Board for
consideration and approval of such matter. The Board
maintains the ultimate and overall responsibility to
approve and oversee the topics included in the Matters
Reserved for the Board. Accordingly, the Terms of
Reference (TORs) of the Board Committees have been
updated to reflect this change.
Revisions of the TORs of the Board Committees were
updated with regards to the functioning of the
Committees in further embedding best practice
governance standards.
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2. GOVERNANCE (continued)
XI. Nominations and Corporate Governance Committee (continued)
Primary activities of the Committee in 2024: (continued)
Key Matters Actions taken
Governance
Update of the Corporate
Governance Policy and
Framework to reflect latest
regulatory provisions and
better address Data
Governance and ICT risk
management framework
matters
The Committee revised the Corporate Governance
Policy and Framework. The latter has been updated
twice to align with changes in the CBC Internal
Governance Directive regarding the tenure of the
Chair of the Board and the Chairs of Board
Committees. In relation to the tenure of the Chairs
this has been extended to a maximum of nine
cumulative years whether consecutive or not, this
change being reflected in the updated Corporate
Governance Policy and Framework. Further, the said
Framework was amended to reflect the latest
revisions of the Internal Governance of Credit
Institutions Directive of 2021, introducing
amendments primarily, aiming to better address Data
Governance and ICT risk management framework
matters.
Key Matters Actions taken
Conflict of
Interest and
other
professional
activities
Directors' potential conflicts of
interest and other professional
activities
Guidance notes for Board
members on managing COIs
The Committee evaluated requests of Board members
for other non-executive directorships based on the
assessments performed by the Group Compliance
Division. Requests were evaluated in relation to the
relevant CBC Suitability Directive provisions, to
ensure that none of these requests would in any way
compromise any of the suitability criteria.
A practical guide has been prepared for the Board
members, to support members in effectively
identifying, reporting and managing conflicts of
interest and conflicts of duty.
Key focus area Key Matters Actions taken
Corporate
Governance
Report
2023 Annual Corporate
Governance Report
The Committee has reviewed the 2023 Corporate
Governance Report and approved its publication.
Key focus area Key Matters Actions taken
Committee
Effectiveness
Enhancing the Committees’ own
functioning
Self-Assessment/Own Functioning
The committee undertook its annual
self-assessment internally which was
facilitated by use of questionnaires
assessing different areas such as
composition, challenge and oversight of
the areas within its remit, agendas and
material, contributions from members
in meetings.
To continuously improve its overall functioning, the
NCGC held a dedicated session in 2024 whereby it
agreed and proceeded with implementing during
the year an action plan that further enhanced its
documentation practices and its decision-making
processes.
Striving for continuous improvement is a key
aspect of the NCGC's effectiveness. At the start of
2024, the Committee evaluated its own
performance by reviewing the results from self-
assessment questionnaires completed by its
members. In a separate session, the Committee
reflected on its operations, identifying and
introducing best practices to enhance its
effectiveness and efficiency.
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2. GOVERNANCE (continued)
XI. Nominations and Corporate Governance Committee (continued)
Primary activities of the Committee in 2024: (continued)
Key focus area Key Matters Actions taken
Board
Evaluation
2023 Internal Board Performance
Evaluation BOD
The NCGC reviews, at least annually,
the structure, size, and composition of
the Board (including skills, knowledge,
experience, independence, and
diversity), and recommends to the
Board the skills and experience required
to provide sound governance oversight
Triennial Board Evaluation Report -
2024 progress on
recommendations from 2023 report
carried out by Morrow Sodali
The Committee reviewed and proposed for
approval the 2023 Annual Board Evaluation
Report. Further details on recommendations and
actions undertaken in 2024 are included in Section
2, subsection VI titled ‘The Operations of the
Board - Board Performance Evaluation.
The methodology to be used for the year 2024
report was enhanced, and consists of the
questionnaires completed by Board members, the
assessment of the Chairman in relation to the
performance of NEDs, the matters covered in the
meetings as well as the interviews performed by
members of the Board.
In August 2023, the Group retained Morrow Sodali
to perform an externally facilitated independent
evaluation of the effectiveness of the Board, which
has been presented to the NCGC and to the Board
along with recommendations.
Key tasks emanating from the Internal Board
Performance Evaluation of 2023 and the Triennial
External Board Performance Evaluation Report by
Morrow Sodali have been identified and
implemented during 2024 to further enhance
governance and Board efficiency.
Key focus area Key Matters Actions taken
Corporate
Governance for
Group
Subsidiaries
Revision of the Corporate
Governance Guidelines for Group
subsidiaries
The Corporate Governance Guidelines for
subsidiaries have been revised with the aim to
further enhance the effective oversight of the
material subsidiaries – as these are defined in the
Guidelines to ensure that effective corporate
governance practices are implemented by material
subsidiaries.
Appointment for Senior Executives
for subsidiaries
Oversight and approval of the
appointment of new executive members
for subsidiaries of the Group
Further to Board appointments, with respect to
senior executive appointments, the Committee
has supported the appointment of the following:
Ms. Christiana Agrotis for her nomination on
the Board of Directors of Genikes Insurance.
Ms. Elena Meli for the position of General
Manager of Jinius Ltd Board and the position
of executive Board Member of the same
company.
Mr. Andreas Andreou for his nomination on
the Board of CISCO as an executive non-
independent member.
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2. GOVERNANCE (continued)
XI. Nominations and Corporate Governance Committee (continued)
Primary activities of the Committee in 2024: (continued)
Key focus area
Key Matters Actions taken
ESG
Exercising strategic oversight role
on ESG matters
In exercising its role of strategic oversight on ESG
matters, the Committee has reviewed the
following external disclosures on ESG:
ESG Disclosures Annual Financial Report of
the Board
ESG Disclosures in Pillar 3 Report
Sustainability Report 2023
Moreover, the Committee received regular updates
on the progress of the ESG Working Plan, the
CSRD Disclosure preparation and oversaw updates
on ESG Governance matters.
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2. GOVERNANCE (continued)
XII. Human Resources & Remuneration Committee
Effective oversight of Human Resources strategy and practices, to align and support the Bank’s
transformation journey and strategic priorities.
Dear Stakeholders,
In 2024, the Human Resources & Remuneration Committee has worked on several key areas to oversee
Human Resource initiatives and practices of strategic importance to the Bank. The Committee’s work
has focused on overseeing progress against set strategic pillars for 2024 and reviewed HR strategy for
2025. The Committee oversaw progress in Talent Management initiatives, reviewed progress in the
design of Performance Management systems and oversaw the actual Performance Appraisals of Heads
of Control Functions and the Senior Management. Succession Planning for Key Function Holders and the
Senior Management has been another area that was examined by the Committee. Keeping in mind that
equipping the staff with the right skills and competencies will enable them to succeed not only at present
but also in the future, work on Learning and Development initiatives as well as the inaugural work of the
BOC Academy, which was taken forward during the year, have also been reviewed. Moreover, the
Remuneration practices, including variable pay, have been updated during the year to ensure alignment
with regulatory requirements and continuous improvement. The Committee has also overseen the
Workforce Planning practices and ensured these are fully aligned with the Group’s strategic priorities.
In Succession Planning, the Committee reviewed the plans in place designed to ensure smooth
transitions and continuity both in case of planned vacancies but also for the case of emergency situations.
During 2024, a Career Path Framework project has been initiated, aiming to foster a culture of career
progression within the organization. Our focus on Organizational Health has involved monitoring
progress on health initiatives which were well received by staff during the year. In an aim to ensure
continuous improvement of its own functioning, the Committee also reviewed the update of its own
Terms of Reference, the results of its self-assessment and also took time to deliberate on optimising its
own governance and documentation practices. Lastly, the Committee has followed progress of the Staff
Separation Scheme which in tandem with workforce planning initiatives will contribute to better
management of payroll costs and renewal of the staff’s skillsets.
Looking ahead, the Committee will continue to oversee completion of the Career Path Framework, will
continue to address the challenge of optimising payroll expenditure, continue to encourage innovative
talent development practices and generally contribute to the culture change needed to support the
Group’s transformation program. I look forward to strengthening the Committee’s engagement with staff
members and continuing the journey of working together with all stakeholders to deliver the Group’s HR
agenda.
Finally, I would like to thank my colleagues for all their commitment and contribution to the work of this
Committee. Their willingness to share knowledge and experience has been invaluable.
Yours Sincerely,
Adrian Lewis
HRRC Chair 2024
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2. GOVERNANCE (continued)
XII. Human Resources & Remuneration Committee (continued)
Role and Composition of Committee
Role of Committee
The Committee plays a key role in assisting the Board to fulfil its responsibilities in relation to the
remuneration of Executive Directors, Senior Management, other key personnel and the employee
Remuneration policy.
The Committee's main duties and responsibilities are:
To oversee that the Group is equipped with the Human Capital at the right size and with the right
skill mix necessary for the achievement of its strategic goals, whose rewards will be based on
personal performance and Group results.
To oversee that the Group is equipped with the Organisational Capital (Values, Engagement,
Alignment, Leadership) to be able to effect continuous improvement and elicit the right behaviour
which would lead to the desired outcome.
To oversee that the Group is equipped with the Information Capital and the technology necessary
to facilitate process improvements that will create a comparative advantage in the market and
sustainability for the future.
To regularly review, agree and recommend to the Board the over-arching principles and parameters
of Compensation & Benefits policies across the Group and to exercise oversight for such issues.
Within the over-arching principles and parameters recommended by the Committee and approved
by the Board as referred to above, to review and set the remuneration arrangements of the
Executive Directors of the Group, Senior Management and the Group Remuneration Policy, in
alignment with the EBA Guidelines on sound remuneration policies under Directive 2013/36/EU
2021, the CBC Directive on Internal Governance, the UK Corporate Governance Code 2018 and any
other applicable statutory or regulatory requirements.
To oversee the implementation of Strategic HR initiatives which promote and are aligned with the
Group’s ESG ambition, strategy and objectives.
The Committee’s TORs are available on:
https://www.bankofcyprus.com/en-gb/group/who-we-are/our-governance/group-committees/human-
resources-remuneration-committee/
Composition of Committee
Composition from 01.01.2024-16.05.2024
o Lyn Grobler (Chair)
o Monique Hemerijck
o Dinos Iordanou
Composition from 17.05.2024 to 20.06.2024
o Dinos Iordanou (Chair)
o Monique Hemerijck
o Stuart Birrell
Composition from 21.06.2024 to 31.12.2024
o Adrian Lewis (Chair)
o Takis Arapoglou
o Stuart Birrell
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2. GOVERNANCE (continued)
XII. Human Resources & Remuneration Committee (continued)
Primary activities of Committee in 2024:
Key focus area
Considerations
and Key Issues
Actions taken
HR Strategy
Ensuring
alignment of HR
strategy with
Group’s ambition
and strategy and
monitoring
progress on the
implementation of
HR initiatives
The Committee ensured alignment of HR strategy with the Group’s
Strategic goals for 2024 and monitored progress on the
implementation of actions under each HR strategic Pillar at regular
intervals throughout 2024. Implementation was in accordance to
plan and to the satisfaction of the Committee. In the second half of
the year the Committee also provided feedback and direction
regarding the 2025 HR strategy stage ensuring alignment with the
Group’s goals and ambitions for 2025.
Talent
Management
Oversight of the
progress of Talent
Management
Initiatives
undertaken and
actions planned.
Talent
Management has
been a Key
Strategic Pillar
throughout the
year.
The Committee provided direction and monitored progress on Talent
Management Initiatives completed during the year and oversaw
enhancements to the Talent Management process. The Committee
provided insights on leadership development and encouraged
further deliberations on the development of Talent with the breadth
of experiences needed to reach leadership positions.
Learning and
Development
Oversight of
learning and
development
initiatives and
knowledge centres
aligned with the
strategic goal of a
leading
organisation with a
growth mindset
The Committee reviewed key facts on training offered to staff during
2023 and reviewed the Learning and Development Plan and
approach for 2024.
The Committee reviewed progress on the BOC Academy Update
which was launched in 2023 and provided feedback with regards to
the next steps in the evolution of the Academy.
Performance
Management
Review of
Performance
Appraisals of
Heads of Control
reporting to the
relevant
Committees and
Senior
Management
before their
submission to the
Board for approval
The Committee, in conjunction with the NCGC, reviewed the
Performance Appraisals as well as the Objectives and Key Results
set for the CEO and the EDF as well as the Senior Management
team. Additionally, the Committee reviewed the Performance
Appraisals as well as the Objectives and Key Results set for Heads
of Control Functions and the Senior Management, before their
submission to the Board for approval.
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2. GOVERNANCE (continued)
XII. Human Resources & Remuneration Committee (continued)
Primary activities of Committee in 2024: (continued)
Key focus area
Considerations
and Key Issues
Actions taken
Remuneration
Oversight of the
remuneration of
the Senior
Management team
(including variable
remuneration) and
monitoring of the
advancement of
remuneration
practices and
policies
The Committee performed the annual review of salary and variable
pay for members of the Senior Management Team including Heads
of Control Functions.
More specifically the Committee engaged in the following review and
oversight actions:
Provided recommendation for approval by the Board of the
granting of awards for the 3-year performance period FY2024-
2026, as per the terms of the approved LTIP and the relevant
authority provided from the Shareholders at the 2022 AGM.
Provided recommendation to the Board with regards to the
implementation of a new Short-Term Incentive Plan for the
performance period FY2024.
Oversaw and recommended for approval by the Board of the
annual revision of the Group Remuneration Policy.
Recommended to the Board the granting of the 2023 STIP and
monitored allocation of the 2023 STIP and received
confirmations by project owners that the process was
transparent, fair and consistent across all Divisions that the
STIP guidelines approved by the Board in February 2024 were
satisfied and that regulatory obligations have been adhered to.
Reviewed Remuneration Tools in the Bank and their evolution,
considered current operating environment and deliberated on
strategic options for the way forward.
Monitored progress on Merit Pay increases granted to selected
staff in November 2024 and received assurances that the Merit
Pay was granted in accordance with the criteria agreed with the
Union, such as performance, potential and pay
competitiveness.
Monitored progress on the granting of Merit Pay and other
increases during 2024 for Material Risk Takers and received
assurances that the 2024 merit pay increases were in line with
the relevant process set out in the Remuneration Policy.
Workforce
Planning
Review of
workforce
planning practices
on a biannual basis
The Committee oversees workforce planning practices on a biannual
basis, reviewing prioritisation of needs, needs for external
recruitments and alignment of the workforce planning activities with
strategic priorities.
In particular, the Committee approved the 2024 Workforce planning
report which contains planned recruitments and timeframes for the
period 2024/2025. Workforce planning for the said period evolves
around the following areas of focus:
Business Development
Customer Experience
Digital Savviness
Operational Efficiency
Controls / Governance
The Committee has been satisfied that the submitted workforce
planning is in line with the strategic priorities of the Group and that
it ensures flexibility and responsiveness to changing business
requirements as well as other external and internal factors.
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2. GOVERNANCE (continued)
XII. Human Resources & Remuneration Committee (continued)
Primary activities of Committee in 2024: (continued)
Key focus area
Considerations
and Key Issues
Actions taken
Succession
Planning
Oversight of the
2024 Succession
Plan for the Heads
of Control
Functions & Senior
Management
The Committee oversaw the Succession Plan prepared based on the
Group’s Succession Planning Policy for Heads of Control Functions
and Senior Management. The plan ensures that:
Expiry date of each individual’s term is considered and prevents
too many senior managers having to be replaced
simultaneously.
Any transitions will occur smoothly with minimum disruption to
the operations of the institution.
Emergency succession plans are in place, so as to facilitate the
transition to both interim and longer-term leadership in the
event of an untimely vacancy.
Career Path
Framework
Oversight of
progress on the
Career Path
Framework project
The Committee oversaw progress of the Career Path Framework
project due to be completed early in 2025 and aims to foster a
culture of career progression within the Group, in alignment with
the Group’s strategic objectives and priorities.
Organizational
Health
Oversight of
achievements and
deliverables within
the Organisational
Health
Workstream
The Committee oversaw achievements and upcoming deliverables
within the Organisational Health Workstream with the aim of
monitoring progress on Organisational Health initiatives and
ensuring their alignment to strategic priorities.
The Committee oversaw and expressed its satisfaction over progress
achieved on the Organisational Health Project for 2024.
The new priorities selected under this project for the 2024-2026
period are:
▪ Customer Focus
▪ Shared Vision
▪ Talent Management
▪ Inspirational Leaders
Governance
Oversight of
updates regarding
the Terms of
Reference of the
HRRC Committee
The Committee oversaw the revision of its own TORs, to optimise
attendance to its meetings and to align with the decision on
amendments of Matters Reserved for the Board and for the Board
to have the ultimate responsibility to provide approval on policy
matters.
Separation
Scheme
Update on 2024
Staff Separation
Scheme
The Committee reviewed the 2024 Staff Separation Scheme
(Voluntary Exit Plan), and its objectives which included embedment
of a high-performance culture, and renewal of staff with new
skillsets.
Engagement with
Heads of HR
Departments
Engagement with
Heads of HR
Departments
The Committee met Heads of Human Resources Departments and
exchanged views about the projects which are currently in progress.
Self-Assessment
/Own
Functioning
Ensuring
continuous
improvement
through self-
assessment and
brainstorming on
improvements on
own functioning
Continuous improvement is one of the driving forces behind the
effectiveness of the HRRC.
The Committee reviewed the results of its own self-assessment at
the beginning of the year after HRRC members completed self-
assessment questionnaires.
In a separate session the Committee took time to deliberate on its
own functioning and identified best practices that were introduced
to optimise the effectiveness and efficiency of the Committee’s
functioning.
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2. GOVERNANCE (continued)
XIII. Risk Committee
Ensuring the Group's stability and financial health, through proactive and sound risk management
oversight.
Dear Stakeholders,
As the Chair of the Risk Committee, I am pleased to present the activities of the Risk Committee in the
Corporate Governance Report for 2024, which outlines the extensive activities and assessments
undertaken by the Risk Committee to ensure robust risk management across our institution. During
2024, the Committee focused on the identification and management of risks arising from the
macroeconomic environment and geopolitical tensions that emerged throughout the year. The Committee
undertook its annual review of Risk Appetite Framework and Risk Appetite Statement.
Risk culture and its importance has also featured extensively throughout Committee discussions,
including the development and implementation of the Risk Culture Framework.
Throughout the year 2024, the Risk Committee closely monitored the Group's risk behaviour and
performance via the Risk Report, focusing on key indicators. Regular updates on loan asset quality,
concentration risks and main credit risk areas were provided, ensuring high standards of credit quality
management.
The Committee assessed and recommended to the Board for approval Market Risk (including IRRBB)
and, Liquidity and Funding Risk Frameworks. The Committee also monitored market risk and liquidity
and funding risk through regular reporting through the year. In the first half of 2024, the Committee
focused on the risk assessment of the updated bond strategy, concluding on a controlled portfolio
expansion by year-end. Furthermore, the Committee paid attention to the monitoring of non-financial
risks such as Fraud, Business Continuity and Third-Party Risks as required under DORA regulations
including mitigating actions. The Committee oversaw the effectiveness and maturity of the Bank’s
information security framework, paying particular attention to the monitoring and management of Cyber
security risks. The Committee, in conjunction with the AC, closely monitored the actions performed for
adherence to the requirements of BCBS 239 Principles on Risk Data Aggregation and Risk Reporting and
it also closely monitored the actions conducted around Environmental and Climate risks to ensure that
these risks are adequately identified and their impact on operations, strategy and financial stability of
the Group is well understood and properly managed.
These activities highlight our commitment to a robust risk management framework supporting the
institution's long-term stability and growth.
Looking ahead to 2025, the Risk Committee remains dedicated to further strengthening our risk
management practices. We will continue to prioritise the rigorous assessment of emerging risks and
adapt our strategies to evolving regulatory landscapes. Our focus will include strengthening our IT
security risk management capabilities, addressing climate and environmental related risks, and ensuring
the resilience of our institution in an increasingly volatile economic environment. Additionally, we will
foster a strong risk culture across the organization, promoting awareness and accountability at all levels.
By maintaining our proactive approach and commitment to excellence, we aim to safeguard the
institution’s stability and drive sustainable growth in the coming year.
Thank you for your continued support.
Sincerely,
Monique Hemerijck
RC Chair 2024
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2. GOVERNANCE (continued)
XIII. Risk Committee (continued)
Role & Composition of Committee
Role of the Committee
The Risk Committee plays a key role in setting the risk appetite and strategy of the Group and ensuring
compliance with risk management strategy, policies and regulations.
The Committee's main duties and responsibilities are:
To evaluate the Group's governance, risk and control framework and its integration with the
Bank's decision-making process, covering the whole spectrum of the Bank's activities and
units as well as subsidiaries.
To monitor and ensure compliance of the Group with the adopted risk strategy by reviewing
reports prepared by the Group Risk Management Division and make recommendations to the
Board on the significant risks to which the Bank is exposed.
To review, evaluate and make relevant recommendations to the Board on the ICAAP and
ILAAP reports which aim to assess all important risks undertaken by the Group and determine
capital requirements of the Group and liquidity adequacy.
To examine whether the incentives set by the remuneration policy take into consideration
the Bank's risk, capital and liquidity structure.
To recommend to the Board for approval/approve loans which exceed a certain level as per
the Lending Policy of the Group.
To receive management reports on credit, market, liquidity, operational, litigation and
reputational risks.
The committee’s TORs are available on:
https://www.bankofcyprus.com/en-gb/group/who-we-are/our-governance/group-committees/risk-
committee/
Composition of Committee
Composition from 01.01.2024 to 16.05.2024:
o Monique Hemerijck
o Lyn Grobler
o Adrian Lewis
Composition from 17.05.2024 to 20.06.2024:
o Monique Hemerijck (Chair)
o Adrian Lewis
o Stuart Birrell
o Christian Hansmeyer
Current Composition from 21.06.2024 to 31.12. 2024
o Monique Hemerijck
o Stuart Birrell
o Christian Hansmeyer
Notes
1. The RC composition changed following the election of two new non-executive directors, Messrs
Stuart Birrell and Christian Hansmeyer on 17.05.2024 at the Annual General Meeting (AGM) and
then again on 21.06.2024 following the unexpected passing of Mr. Dinos Iordanou, Senior
Independent Director, HRRC, AC, TC Chair & Board member.
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2. GOVERNANCE (continued)
XIII. Risk Committee (continued)
Primary activities of Committee in 2024:
Key focus area Key Matters Actions taken
Risk Profile &
Strategy
To evaluate and report
to the Board on the
Group’s risk profile and
monitoring of the
Emerging Risks.
To consider proposed
material changes to the
Group’s Risk Appetite
Statement.
Risk assessment of the
Financial Plan.
To consider the ICAAP
and ILAAP processes.
The Committee reviewed and recommended the
Group Risk Appetite Framework including
revisions to key risk indicators to the Board for
approval.
The Committee received regular updates of the
Group’s Risk Profile.
The Committee, jointly with the AC, considered
the Four-year Financial Plan of the Group and
discussed the risk assessment of the Plan and
recommended for approval the risk assessment of
the Four-year Financial Plan.
The Committee reviewed and recommended
ICAAP and ILAAP exercises including assumptions,
stress scenarios and reverse stress scenarios to
demonstrate that the Group’s capital and liquidity
resources remain sufficient to withstand severe
but plausible stress conditions.
The Committee reviewed the results of the Risk
Culture Dashboard and provided
recommendations for its further improvement
aiming to the creation of an enhanced risk culture.
Risk framework
and governance
To evaluate the Group's
governance, risk, and
control framework.
To review and discuss
Risk Management
Division policies.
The Committee reviewed and recommended to
the Board the Risk Management Framework as
documented in the Division’s Charter and Annual
Risk Management report.
The annual revisions of the Risk Management
Division’s policies were reviewed and discussed by
the Committee to ensure they are aligned to the
risk profile of the Group. The Committee
recommended to the Board for approval the Risk
Management Divisions policies.
Regulatory
communication
To maintain close
monitor on regulatory
matters.
To emphasize on quality
and timeliness of
responding to
regulatory authorities
The Committee monitored and assessed reports
from management regarding guidance,
correspondence, and reviews from regulators
including updates on significant remediation
programs taking place across risks.
The Committee received regulatory updates
including key communication from regulators.
The Committee closely monitored the progress of
regulatory inspections across risk types.
The Chair of the Committee had regular
communication with the Regulator to discuss
matters of common interest.
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2. GOVERNANCE (continued)
XIII. Risk Committee (continued)
Primary activities of Committee in 2024: (continued)
Key focus area Key Matters Actions taken
Credit Risk /
Credit Risk
Control &
Monitoring
To regularly review the
quality, concentration and
performance of the loan
portfolio.
To ensure adherence to
regulatory standards, such
as those by ECB, EBA or
local regulators.
To evaluate the
effectiveness of internal
controls and monitoring of
systems to identify and
mitigate emerging credit
risks.
The Committee received comprehensive and regular
reports on loan portfolio providing a detailed
assessment of asset quality, with particular attention
to specific segments such as large exposures, trends
in non-performing exposures (the ‘NPEs’) including
inflows and outflows, quick loans, forbearances and
re-pricings.
Through a structured review of key risk indicators
the Committee gained valuable insights into
emerging vulnerabilities, the effectiveness of risk
mitigation strategies, and the resilience of the loan
portfolio under different economic scenarios
ensuring alignment with the Group’s risk appetite.
The Committee oversaw reporting which highlighted
proactive measures taken by the Group to further
enhance regulatory compliance, and control
processes, with particular emphasis on the quality of
the loan book and strict adherence to the Group’s
guidelines.
The Committee, in conjunction with the AC
reviewed, challenged and recommended to the
Board the credit related provisions.
Market /
Liquidity and
Funding Risk
To review and seek for
Board approvals for
policies, limits and
procedures to manage
market risk.
To monitor adherence to
liquidity risk appetite and
regulatory requirements.
To monitor market
developments on bonds
exposure especially on
Cyprus government
bonds.
To facilitate clear
communication between
management and the
Board regarding market
and liquidity risks.
The Committee reviewed, challenged and
recommended to the Board for approval the Bond
Investment Strategy.
In light of the changing interest rate environment,
the Interest Rate Hedging Strategy was reviewed as
formulated to protect the Bank’s NII from reductions
in market interest rates. Various available hedging
options were discussed and analysed in the
meetings. The Committee maintained an enhanced
oversight over the management of interest rate
exposure and implementation of hedging strategy.
The Committee reviewed and approved market,
country and counterparty limits.
In relation to the MREL Compliance Plan 2024 the
RC recommended submission to the Board for
approval.
Operational
Risk
Monitoring of key
operational risk indicators.
To review the Group’s
operational risk profile and
consider specific areas of
operational risks, including
fraud, business continuity,
thirty party risk
management including the
controls that are in place
for managing and
mitigating such risks.
The Committee received regular reporting on key
operational risk indicators and was briefed by
management on a number of operational risk topics,
including those relating to fraud, third party risk
management, business continuity, cyber and
information security and the controls that are in
place for managing and mitigating such risks.
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2. GOVERNANCE (continued)
XIII. Risk Committee (continued)
Primary activities of Committee in 2024: (continued)
Key focus area Key Matters Actions taken
ESG – Climate
Risk
To ensure the Group
identifies and assesses
climate-related risks that
could impact its
operations, strategy and
financial stability.
To monitor the
implementation of policies
and frameworks for
managing climate-related
risks, ensuring alignment
with regulatory
expectations.
The Committee considered and recommended to the
Board for approval the Materiality Assessment for
Climate Risk.
The Committee received reports on climate risk
management, while maintaining oversight of
delivery plans to ensure that the Group develops
strong climate and environmental risk management
capabilities.
Information
Security
To oversee and ensure the
effectiveness of the Bank’s
Information Security
framework.
To ensure Information
Security is integrated into
the Bank’s overall risk
management and strategic
objectives.
The Committee received regular Information
Security Management reports including information
on open ICT/InfoSec risks, InfoSec controls maturity
and effectiveness and related ICT/InfoSec incidents.
The Committee was provided with regular updates
on the Cyber Stress Test and the related results.
The Committee received progress updates on the
implementation status related to the DORA
regulation.
People and
Culture
To promote a healthy and
robust culture within the
Risk Management Division
and the organization in
general.
To ensure that the
remuneration of roles
within the organization
that have been identified
as Material Risk Takers
(MRTs) is aligned with the
stringent requirements
per Commission Delegated
Regulation (EU)
2021/923.
The Committee was updated on the Organisational
Health Index of Risk Management Division and plans
of action for continuous improvement.
The Committee reviewed and recommended for
approval the positions relating to Material Risk
Takers (MRTs).
The Committee performed Appraisal of the Chief
Risk Officer (CRO) and the Chief Information
Security Officer (CISO) and set their KPIs for the
following year.
Recovery
And
Resolvability
matters
To ensure work around
resolvability and recovery
plan is aligned with the
Group’s and regulatory
expectations.
The Committee considered the Group Resolvability
Self-Assessment as well as the Group Recovery Plan.
The Committee received a briefing from
management on the Resolvability work program for
2024.
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2. GOVERNANCE (continued)
XIII. Risk Committee (continued)
Primary activities of Committee in 2024: (continued)
Key focus area Key Matters Actions taken
BCBS 239
Setting and monitoring
Group’s own definition of
compliance with BCBS 239
‘Principles on Risk Data
Aggregation and Risk
Reporting’.
The Committee, in conjunction with the AC, sets,
and proposes to the Board for approval the BCBS
239 Compliance Dashboard. The dashboard is
reviewed annually and regular monitoring of the
progress, compliance status and next key actions
takes place via the quarterly “Data & Report Quality”
Report.
Other
To ensure work around
safeguarding data and
report quality meets the
Group’s and regulatory
expectations.
Risk oversight of
Insurance subsidiaries.
The Committee reviewed on a regular basis report
on the Group’s Data and Report Quality, and
timelines requirements/thresholds for Key Risk
Metrics, both in normal and stress conditions.
The Committee received ad hoc risk reporting
emanating from developments of a non-regular
nature.
The Committee reviewed the Annual Risk Committee
reports of the insurance subsidiary companies of the
Group (Eurolife and GI).
Self-assessment
Annual self-assessment to
ensure it meets the
expectations of relevant
stakeholders.
The Committee undertook its annual self-
assessment internally which was facilitated by use
of questionnaires assessing different areas such as
composition, challenge and oversight of the areas
within its remit, agendas and material, contributions
from members in meetings, etc.
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2. GOVERNANCE (continued)
XIV. Audit Committee
Supervises the integrity of financial reporting and the effectiveness of the internal control environment,
as well as the effectiveness of the Internal Audit and Compliance functions. Oversees the relationship
with the external auditor.
Dear Stakeholders,
I was appointed as Chair of the Committee on 21 June 2024. This is therefore my first report as the
Audit Committee Chair, following the passing away of my predecessor Mr. Dinos Iordanou whose
unwavering commitment left a lasting impact on the work of the Committee and who is greatly missed
by us all.
The Committee assists the Board in fulfilling supervisory oversight responsibilities mainly in relation to
the internal controls, and the integrity of accounting and financial reporting.
In 2024, the AC continued its work to ensure the integrity of financial and narrative reporting and
adequacy and effectiveness of internal controls. Jointly with the RC it discussed and challenged major
accounting estimates, such as provisions for credit losses and litigation as well as impairment for Group
properties. The Committee reviewed and recommended for approval to the Board the Internal Audit Plan
and monitored its progress as well as various policies of Internal Audit, Compliance and Finance
functions, thereby continuously reinforcing their internal control environment.
The Committee monitored progress on internal and external reviews. The Committee continues to receive
regular updates on the more material remediation actions across the Group. Moreover, it requested
additional information on transaction monitoring for Financial Crime and AML as well as segregation of
High-Risk Customers, into those of ‘Significant High Risk’ and those of ‘Perceived High Risk’. The
Committee also requested a review of the tools and hallmarks for Finance/Tax Exchange information by
an independent advisory firm.
The Committee monitored the independence and effectiveness of the Internal Audit function. The
Committee recommended to the Board the approval of the appointment of an independent firm for the
execution of a triennial external assessment of the adequacy of the Group’s Internal Control Framework,
(which will take place in 2025) as well as its scope. Moreover, the Committee evaluated the independence
and performance of the external auditors.
Looking ahead, the AC will continue its work to safeguard the integrity of the financial reporting and
internal control environment. A significant focus area in 2024 was the first CSRD reporting. The
Committee dedicated time to understanding the requirements and receiving regular updates on progress.
The Committee will continue to follow closely the work done to ensure compliance with the provisions of
the Directive. Moreover in 2025, the AC, jointly with the RC, will continue to monitor progress in the
work undertaken towards compliance with the BCBS 239 Principles for effective risk data aggregation
and reporting. The two Committees will also be monitoring compliance with the new CRR requirements
and the work done to ensure compliance with the ECB requirements on governance and risk culture.
Lastly, in early 2025 the Group commenced an external tender process for the Group’s statutory auditor
for the financial year ending 2027. This process is being led by the Committee, and supported by
management who will have an advisory role only. The tender process is expected to be concluded by
July 2025, when the Committee will make its recommendation to the Board for selection of the preferred
firm.
Finally, I would like to extend my thanks to all Committee members for their support and contribution to
the work of the Committee during 2024. I remain certain that the expertise, diligence and commitment
of all Committee members will ensure the achievement of the Committee’s goals in the year ahead.
Sincerely,
Adrian Lewis
AC Chair 2024
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2. GOVERNANCE (continued)
XIV. Audit Committee (continued)
Role & Composition of Committee
Role of Committee
The Committee is primarily responsible for:
The appropriateness, completeness and effectiveness of the Group's system of internal
controls and information systems.
Monitoring the integrity of the Group's financial statements and related announcements and
the financial reporting process.
Advising the Board on the accuracy and fairness of the annual reports and accounts.
Monitoring the effectiveness and operations of the Internal Audit function and the compliance
function.
Overseeing all matters relating to the relationship between the Group and the external
auditor.
Monitoring the effectiveness of the Group's whistleblowing procedures.
Assessing the soundness of the methodologies and policies the management of the Group
uses to develop ESG including climate related and environmental metrics and other
disclosures and to assess the key vendors’ plans about sustainability.
Providing guidance/recommendations to the Board in relation to managing risk related issues
effectively that emerge in the context of enhancing and maintaining the Group’s ethical
culture at a high level.
The Committee’s TORs are available on: https://www.bankofcyprus.com/en-gb/group/who-we-are/our-
governance/group-committees/audit-committee/
Composition of Committee
Composition from 01.01.2024 to 16.05.2024
o Dinos Iordanou (Chair)
o Monique Hemerijck
o Adrian Lewis
Composition from 17.05.2024 to 20.06.2024
o Dinos Iordanou (Chair)
o Adrian Lewis
o Lyn Grobler
Current Composition from 21.06.2024 to 31.12. 2024
o Adrian Lewis (Chair)
o Lyn Grobler
o Monique Hemerijck
Mr. Adrian Lewis was appointed as Chair to the Committee on 21 June 2024. Mr. Lewis has more than 25
years’ experience in equity capital markets and investment banking and thus has valuable knowledge in
the financial and banking sectors. He was appointed as Chair of the Committee, following the passing
of Mr. Iordanou for an interim period, until the Company recruits another Director with more targeted
experience in accounting and auditing.
Each member of the Committee has signed a declaration of independence confirming their independence.
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2. GOVERNANCE (continued)
XIV. Audit Committee (continued)
Primary activities of Committee in 2024:
Key focus area Key Matters Actions taken
External Reporting
Significant accounting estimates
judgements
The Committee, in conjunction with the RC,
performed a detailed review and discussion
of the adequacy of provisions held for
expected credit losses, litigation and
impairment relating to Group properties
during quarterly joint AC/RC meetings. The
Committee, in conjunction with the RC,
considered the key inputs driving the
outcome and level of provisions and
impairments.
The Committee reviewed and
challenged significant judgments
applied in determining expected credit
losses, including changes in modelling
assumptions and overlays and ensured
that the level of provisions was
adequate. In judging the adequacy of
provisions, the Committee considered
macro-economic conditions, market
conditions and bank specific factors.
The Committee received regular
updates on the status of current legal
and regulatory matters and considered
the impact of those matters on the
Group’s provision for pending litigation
and regulatory matters level.
Similarly, the Committee received
updates on and scrutinised
management’s approach to the
valuation and measurement of the stock
of property portfolio during the year.
The Committee considered and made
recommendations to the Board regarding the
approach to and measurement of the
proposed expected credit losses and
litigation and regulatory and other matters
provisions, and impairment of stock of
properties applied to the Group’s annual and
interim financial statements and 2024
quarterly financial results. Further
information on these significant judgement
items is set out in Note 5 of the Consolidated
Financial Statements.
In the separate financial statements of the
Company, the Company’s investment in it’s
subsidiary, BOC PCL, is reviewed for
impairment. This involves exercising
significant judgement to assess the
recoverable amounts of the investment, by
reference to projected future cash flows,
discount rates and regulatory capital
assumptions. The Committee reviewed the
judgements in relation to the impairment
review.
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2. GOVERNANCE (continued)
XIV. Audit Committee (continued)
Primary activities of Committee in 2024: (continued)
Key focus area Key Matters Actions taken
Integrity of the Group’s Financial
statements and financial
reporting.
Going Concern conclusion and
Viability Statement
IFRS 17 in the Financial Year
2023
Sustainability Reporting
Pillar III Disclosures
The Committee considered the significant
matters relating to the annual and interim
financial report as well as quarterly results,
with key accounting judgements and
disclosures subject to discussion with
management. The Committee considered
the Group's financial disclosures and
provided feedback. The Committee also
received feedback from PwC, including areas
in which they challenged management and
how those discussions impacted the
disclosures for the annual and interim
financial report.
Having evaluated all of the available information,
the assurances by management and underlying
processes used to prepare the published financial
information, the Committee concluded and
recommended to the Board for approval the
annual and interim financial statements as well
as the quarterly financial results.
The Committee assisted the Board in
determining the appropriateness of adopting
the going concern basis of accounting and in
performing the assessment of the viability of
the Company and the Group. Matters
considered in making this assessment
included the performance of the Group,
profitability projections, funding and capital
projections under base and stress scenarios
and a recommendation was submitted to the
Board for approval.
The Committee was updated on the impact
of the Group’s adoption of IFRS 17 and
related disclosures in the 2023 Annual
Financial Report.
The Committee discussed the Group’s
progress with sustainability related
reporting. The Committee has reviewed
management’s Environmental, Social, and
Governance (ESG) process and the
assessment of ESG topics that impact the
Group's business, as well as those influenced
by the Group's operations, in alignment with
the Corporate Sustainability Reporting
Directive (CSRD). The Committee discussed
the progress for the implementation of the
requirements of the CSRD and
recommended to the Board the approval of
the Double Materiality Assessment for the
year 2024.
Pillar 3 reporting is also subject to proper
governance and review processes, and the
Committee jointly with the Risk Committee
reviewed and approved the annual, interim
and quarterly Pillar III disclosures.
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2. GOVERNANCE (continued)
XIV. Audit Committee (continued)
Primary activities of Committee in 2024: (continued)
Key focus area Key Matters Actions taken
Internal Controls
Effectiveness of internal controls The Committee obtained confirmation from
the CEO on the effectiveness of the internal
controls for 2024.
The Committee performed an annual review of
the effectiveness of internal controls through
review of the Directors’ representation
process.
The Committee monitored progress on
addressing Internal Audit findings from both
internal and external reviews and obtained IA
confirmation as to the progress on addressing
findings.
Emphasis was placed in the areas of
Digitization, Information Systems and Data
Governance, regarding current, as well as any
future, risk exposures. The progress of
addressing IT audit findings was discussed with
regards to availability and continuity of IT
services. The Committee considered and
discussed assessment of IT risks and the
ongoing risk management actions to identify,
mitigate and report on IT risks, including IA and
PwC’s findings of the internal control
environment and actions arising therefrom. The
Committee welcomed management's progress
in improving the control environment during
2024, however, there remains further work
which is being undertaken.
For further information relating on how the
Committee has ensured the effectiveness of
internal controls throughout 2024, see Section
2, subsection VII, titled ‘Board's oversight of
risk management and internal control systems
– Internal Controls’.
Internal Audit
Independence of Internal Audit
Effectiveness of Internal Audit
(IA)
Reviewed the Internal Audit Division
declaration of independence.
Reviewed the Annual Conflict of Interest
declaration.
Annual appraisal and goal setting for the
Internal Audit Director.
Agreement as to the proposed remuneration of
the heads and senior staff of the Internal Audit
Division.
Discussed and recommended to the Board for
approval the Annual Audit Plan to ensure
alignment with the key risks of the business.
The Committee enquired and obtained
confirmation about the adequacy of staff levels
and skills in the Internal Audit Division.
Reviewed quarterly internal audit activity
reports and progress against the Annual Audit
Plan and discussed the audit approach,
management engagement and areas requiring
improvement and strengthening of the internal
control framework.
Reviewed the quarterly follow up on the
recommendations from internal and external
audit reviews.
Reviewed the Annual Audit Report of the
Internal Audit Division.
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2. GOVERNANCE (continued)
XIV. Audit Committee (continued)
Primary activities of Committee in 2024: (continued)
Key focus area Key Matters Actions taken
Reviewed the periodic self-assessment results
for conforming to Global Internal Audit
Standards.
Having reviewed and discussed the above
matters the Committee was satisfied with the
independence and effectiveness of the Internal
Audit function.
Recommended to the Board the approval of the
Internal Audit expenditure budget.
Recommended to the Board the approval of
Internal Audit Policies.
The Committee received regular reports from the
Internal Audit Division on internal audit activities
across the Group which outlined details of the
audit approach, management engagement and
areas identified during audits requiring further
strengthening across the Group’s risk
management and internal control framework.
Reports are rated based on the strength of the
control environment in operation, management’s
awareness of the risks facing their business areas
and the controls in place to mitigate those risks.
External Auditor
The Committee oversees
the relationship with the
Group’s external
auditors (currently
PricewaterhouseCoopers
(‘PwC’))
Independence
Approval of permissible non audit
services
External Auditors’ performance
Reviewed PwC’s Independence Confirmation
and the report of Compliance on the same
matter. Based on the reporting received,
PwC are deemed to be independent.
The Group operates a policy to regulate the
use of PwC for non-audit services. The AC
reviewed and recommended for approval the
annual revision of the policy for the approval
of permissible non-audit services. The policy
includes provisions to ensure the objectivity
and independence of the external auditor.
The policy sets out the type of services that
the auditor is permitted to carry out and pre-
approves certain of these services provided
the fee is below a certain threshold, except
for specific categories of permitted services
that require explicit Committee approval. All
other permitted services must be approved
by the Committee.
Information on fees to the independent
auditor of the Group for audit and other
professional services provided during the
year are set out in Note 15 of the
Consolidated Financial Statements included
within the 2024 Annual Financial Report.
The Committee discussed the assessment of
effectiveness of PwC as the external auditor
per the report of Internal Audit, which is
prepared utilising a questionnaire that
focused on the overall audit process, its
effectiveness and the quality of output and
concluded that it was overall satisfactory.
The Committee Chair undertook to discuss
with the PwC responsible partner findings
from the assessment and provide feedback
on the interaction and coordination with the
PwC audit team.
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2. GOVERNANCE (continued)
XIV. Audit Committee (continued)
Primary activities of Committee in 2024: (continued)
Key focus area Key Matters Actions taken
Monitoring the work of PwC as
the Group’s statutory auditor.
The Committee met with key members of
the PwC team and reviewed the Audit Plan.
This included a review of the external
auditor’s approach and strategy for the
annual audit. The Committee received
regular updates on the audit, including
observations on the control environment.
Key audit matters discussed included
management’s approach on impairment of
loans and advances to customers (expected
credit losses), valuation of stock of
properties, provisioning for pending
litigation and other matters and privileged
user access over financial reporting systems
as well as the approach to disclosures in the
Group's annual and interim financial
statements. The Committee discussed
recommendations including observations on
the control environment.
The Committee received updates from PwC
in relation to the limited assurance
conducted on Sustainability Statement
(CSRD Disclosures).
Compliance
Effectiveness of Compliance
function
Independence
Important Regulatory
Developments
Reviewed the quarterly and annual
Compliance reports which summarise the
main actions of all Compliance Division
departments.
Reviewed the Compliance Division Action
Plan to ensure alignment with the key risks
of the business.
Reviewed the annual AMLCO Report.
Reviewed the annual AMLCO/Risk
Assessment Report.
Reviewed the Annual AMLCO Sanctions Risk
Assessment Report.
Reviewed the Data Privacy Department
Annual Report.
Reviewed the MiFID Annual report on the
overall control environment of investment
services and activities of the Group and
highlighted action for enhancements in
automation of processes.
Recommended to the Board the approval of
the Compliance Division expenditure budget.
New KRIs reviewed quarterly.
Reviewed the Compliance Division
Declaration of Independence.
Annual appraisal and goal setting for the
Director of Group Compliance.
Agreement as to the proposed remuneration
of the heads and senior staff of the
Compliance Division.
The Committee was informed about
important regulatory developments
impacting the Group and the actions taken
to ensure compliance.
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333
2. GOVERNANCE (continued)
XIV. Audit Committee (continued)
Primary activities of Committee in 2024: (continued)
Key focus area Key Matters Actions taken
Culture and awareness
Customer Acceptance Policy The Committee reviewed the relevant indicators
in relation to ‘culture and awareness’ of staff for
the customer acceptance policy.
Data Privacy
Data Privacy The Committee considered further
enhancements of data access management for
vendors and aligned on the matter with the TC.
The Committee also noted the importance of
training on the development of DP matters.
Governance
Compliance with Regulatory
requirements
Reviewed, challenged and recommended the
Annual Corporate Governance Report, prepared
in accordance with regulatory requirements.
Self-Assessment
Annual self-assessment The Committee conducted its yearly internal self-
assessment evaluation, utilizing questionnaires
to examine various aspects such as composition,
the challenge and oversight of its responsibilities,
agendas and materials, and member
contributions during meetings.
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2. GOVERNANCE (continued)
XIV. Audit Committee (continued)
Arrangements relating to the external auditors
The AC oversees the relationship with the external auditor. The AC is responsible for overseeing all
matters relating to the relationship between the Group and its statutory auditors, including the external
audit plan, terms of engagement, audit and non-audit fee arrangements, interim findings and audit
finding reports.
During the year, the Committee considered PwC’s terms of engagement, including remuneration, its
independence, audit quality / performance, objectivity and considered the plans for the interim review
and year-end audit. Appropriate safeguards are in place to protect the independence and objectivity of
PwC.
The AC operates a Group Policy on the Provision of Non-Audit Services by the Group’s statutory auditors
in line with the applicable EU Directive and the Auditors’ Law to regulate the use of the statutory auditors
for non-audit services. To ensure the objectivity and independence of PwC, the policy formalises certain
restrictions in the provision of non-audit services by PwC and requires that any engagement of the
external auditors for services must be approved in advance by the AC. The AC reviews annually a
detailed analysis of the audit and non-audit fees relating to work done by the external auditors, to
confirm their independence and refers this analysis to the Board. Information on fees to the independent
auditors of the Group for audit and non-audit services provided during the year ended 31 December
2024 are set out in Note 15 of the Consolidated Financial Statements.
The Group is committed to ensuring the independence and objectivity of the statutory auditors; on a
semi-annual basis the AC formally reviews the effectiveness, independence and performance of the
external auditors. An annual assessment for the independence of external auditors takes place by the
Compliance Division in accordance with the relevant framework, regulations and ethical standards.
Compliance Division did not identify any area that could potentially compromise PwC independence.
The AC also reviews the external auditors’ approach and strategy for the annual audit and audit findings.
The process for assessing the effectiveness of the audit process using AQIs, is supported by tailored
questionnaires completed by the AC members and relevant senior management personnel. The
responses received are collated and presented to the AC for discussion.
The external auditors do not provide internal audit services to the Group.
In accordance with the provisions of the European Directive on statutory audits and following a
transparent and competitive tender process in 2017, the AC recommended to the Board the appointment
of PwC for accounting periods commencing 1 January 2019. The AGM held on 17 May 2024 considered
the continuation in office of PwC as Auditors of the Company and authorised the Board to fix their
remuneration. The AC assessed the independence of the statutory auditors prior to the commencement
of the audit period and continues to assess their independence on a six-monthly basis. The lead partner
for the audit engagement is Ms. Fidelma Boyce. The external auditor is required to rotate audit partner
every five years. PwC’s term as statutory auditor ends in 2027.
In early 2025, the Group proceeded with a formal audit tender process for the Group statutory auditor
with effect from the 2027 financial year onwards. The audit tender process is being led by the AC, having
regard to best practice for audit tenders. Management will support the Committee in the audit tender
process on an advisory only basis.
As part of the Request for Proposal (RFP) phase of the tender, firms will be invited to submit proposals
to provide statutory audit services to the Group for up to a period of 9 years commencing from the
financial year ending 31 December 2027.
The primary objective for the audit tender process is ensuring a fair and transparent tender process and
appointing the audit firm which will provide the highest quality audit in an effective and efficient manner.
Firms will be assessed against criteria determined by the AC.
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2. GOVERNANCE (continued)
XV. Technology Committee
The purpose of the Technology Committee is to assist the Board in fulfilling its oversight responsibilities
with respect to the overall role of technology, in executing the business strategy of the Group including,
but not limited to, major technology investment, technology strategy, operational performance,
information security and technology trends that may affect the Group’s customer portfolio and/or affairs
in general. The TC is not a statutory board committee, however the Company has established the
Committee since 2017 as the Group places significant focus on technology and the Group’s IT strategy
and digitalisation path.
Dear Stakeholders,
In 2024, the Technology Committee (TC) continued to oversee the overall role of technology, in executing
the business strategy of the Group. The TC reviewed and approved the Group’s technology planning and
digitization strategy within the overall strategy framework approved by the Board and significant
technology investments and expenditures as per the Committee and limit structures approved by the
Board. In its evaluative capacity, the TC monitored and evaluated existing and future trends in
technology that may affect the Group’s strategic plans, including monitoring of the overall industry.
Furthermore, the TC supervised the performance of the Group’s technology operations including, among
other things, project delivery, operations, technology architecture and the effectiveness of significant
technology investments with the use of Digital Product KPIs.
During 2024, in addition to the standard topics, the TC also oversaw deep dive and ad-hoc topics. Starting
with the deep dive topics, the TC reviewed:
the Insurance Business Digital Transformation Strategy with focus on the self-service and
embedded insurance capabilities offering;
the Technology Operations Analysis, which provide insights on trend analysis of major incidents,
update on any external (regulatory) and/or internal findings and their remediation progress and
key performance indicators (KPIs);
the Cloud Adoption update.
Finally, from the deep dive topics, the Committee as part of its oversight responsibility considered:
the Value Stream Operating Model update, which showcased the progress in operationalising
new value streams and improving the maturity of the existing ones as per the Scaled Agile
Framework;
the IT Services Talent with the strategic pillars of hiring, upskilling and augmenting the teams
with external resources through the Sourcing Framework and University collaborations;
the developments from ECB and the internal working group in relation to the Digital Euro,
evaluating how the Group’s strategy is shaped in relation to Consumer and Business customers
and the Card schemes;
updates on Data & Analytics, which showcased the strategic direction for the Group in relation
to Data and AI.
Looking ahead, the TC will continue its work to assist the Board in fulfilling its oversight responsibilities
with respect to the overall role of technology, in executing the business strategy of the Group. Next year
will be an even more challenging year on the Group’s Technology and Digital agenda and we look forward
to overseeing the Group reaching new heights while managing rising technological opportunities e.g.
amongst others, AI, threats such as Cyberattacks and regulatory obligations such as DORA, BCBS239.
Sincerely,
Lyn Grobler
TC Chair 2024
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2. GOVERNANCE (continued)
XV. Technology Committee (continued)
Role & Composition of Committee
Role of Committee
The Committee is primarily responsible to assist the Board of Directors in fulfilling its oversight
responsibilities with respect to the overall role of technology in executing:
The business strategy of the Group on major technology investment;
Technology strategy;
Operational performance;
Technology trends that may affect the Group’s affairs including its customer portfolio;
Technology affairs in general.
The committee’s TORs are available on:
https://www.bankofcyprus.com/en-gb/group/who-we-are/our-governance/group-
committees/technology-committee/
Composition of Committee
Composition from 01.01.2024 to 16.05.2024
o Dinos Iordanou, (Chair)
o Monique Hemerijck
o Adrian Lewis
Composition from 17.05.2024 to 20.06.2024
o Lyn Grobler (Chair)
o Dinos Iordanou
o Adrian Lewis
o Monique Hemerijck
Composition from 21.06.2024 to 31.12. 2024
o Lyn Grobler (Chair)
o Monique Hemerijck
o Adrian Lewis
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2. GOVERNANCE (continued)
XV. Technology Committee (continued)
Primary activities of Committee in 2024:
Key focus area Key Matters Actions taken
Group’s technology
planning and strategy
Providing oversight to the
Technology Strategy
The Committee reviewed and recommended for
Board approval the Technology Strategy 2025-
2028 which includes the oversight of major
technology investments.
The Committee also reviewed and recommended
for Board approval the following policies:
Disaster Recovery policy
AI Policy
IT Risks & Audit Metrics
Overseeing and monitoring
IT Risks and Audit Metrics
The Committee regularly reviewed progress on
the management of IT risks and Audit Metrics
and oversaw the implementation of DORA
Regulation.
The Committee regularly assessed and provided
direction in relation to the operational
performance, as this was presented in the form
of:
Major or Significant incidents;
Key Performance Indicators with
respect to IT Risks (KPIs);
Mitigation or Completion of Risk, Audit
and Regulatory findings.
With regards to DORA implementation, the
Committee monitored progress of:
Important Strategies / Frameworks;
Changes to Key Processes;
Changes to ICT Vendor / Third Party
Risk Management Process;
Vendor Register of Information;
Operationalisation of Register of
Information.
The Committee monitored the progress ensuring
timely compliance with the requirements of
DORA.
Group’s technology
strategic Action Plan
Monitoring the implementation of
the Group’s technology strategic
Action Plan
The Committee regularly reviewed the progress
of projects and roadmap initiatives, part of the
Technology’s strategic action plan for 2024 and
the programmes in place to deliver.
The main projects/initiatives reviewed by the
Committee during 2024 related to the business
objectives of customer centricity, revenue
growth, and lean operating model.
The projects/initiatives delivered include among
others the Loyalty scheme ‘Pronomia’, Junior App
‘Joey’, POS Credit ‘Fleksy’, Instant Payments
(TIPS) and Digital Housing Loan.
During the year the Committee stayed informed
and monitored progress with respect to the
implementation of the new modules on the
recently implemented accounting system of the
Bank as well as the relevant upgrade of the
system.
In addition, the Committee monitored the
Business and Technical Capability maturity
progress and provided direction to ensure
technical foundation initiatives such as Cloud and
Cyber Security initiatives continue to be the focus
in addition to the business initiatives.
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2. GOVERNANCE (continued)
XV. Technology Committee (continued)
Primary activities of Committee in 2024: (continued)
Key focus area Key Matters Actions taken
Operational
performance
Overseeing operational
performance
The Committee assessed the progress in
operational performance based on trend analysis
from the Technology Operations on a bi-annual
basis.
The Committee furthermore jointly oversaw
aspects with the RC which cover Technology,
Operational Risk and Information Security areas
of responsibility e.g. DORA to ensure proper
oversight from both Committees in complying
with the regulation.
Deep-dives and ad-hoc items were also
presented in relation to the agile operating model
adoption, future proofing, strategy realisation,
cloud adoption and operations analysis.
Technology Trends
Overseeing technology trends To ensure proper oversight of technology trends
or relevant developments, the Committee
oversaw and gave direction for the following on
a bi-annual basis:
Cloud Adoption
Data & Analytics including AI
Digital Euro
Further the Committee reviewed and discussed
the following frameworks and models for the
evolution of the Group in relation to technology:
Agile Adoption practices and Value
Stream Operating Model update.
Short-term and long-term Strategy for
Technology Talent across the Bank.
Actions to address resources / capacity
needs to deliver on projects and
initiatives which form the Technology
strategy and enable the strategy
realisation.
Operational Trend Analysis for internal
efficiencies and incident management
including Cyber Security to proactively
address any root causes and align
actions with latest best practices in the
industry. 
Digital KPIs and
roadmap overview
Monitoring progress on Digital
KPIs and roadmap.
The Committee oversaw and provided direction
in relation to the Digital KPIs and the relevant
sales’ actions to meet the KPI targets. The KPI
targets in 2024 were met.
The main actions during 2024 from the Digital
sales team related to loans, insurance and youth
products.
The Committee also oversaw and provided
direction to the most important roadmap
initiatives or features.
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2. GOVERNANCE (continued)
XV. Technology Committee (continued)
Primary activities of Committee in 2024: (continued)
Key focus area Key Matters Actions taken
Jinius Update
Monitoring Jinius Progress
The Committee oversaw and provided direction
regarding the Jinius KPIs in relation to the
Business to Business (B2B) and Business to
Customer (B2C) offerings.
The Committee acknowledged progress made
with respect to the increase in transaction
volumes during the year for both B2B and B2C
(following the public launch in April of the B2C
Marketplace).
The Committee monitored the continued
improvement over the risk management and
governance process of the subsidiary.
Insurance Business
IT/Digital Strategy
Update
Monitoring progress of the
IT/Digital Strategies of the
Insurance Business Strategy.
The Committee oversaw and provided direction
regarding the IT / Digital Strategies of the
Insurance Business Strategy for the period 2024-
2028, and reviewed and provided feedback on
the compiled action plan of projects that will
support the strategy.
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HRRC members
Meetings
attended/
Meetings held
while member of
Committee
Constantine (Dinos) Iordanou *
4/4
Adrian Lewis
5/5
Lyn Grobler *
3/3
Monique Hemerijck *
4/4
Stuart Birrell
6/6
Efstratios
-
Georgios
(Takis)
Arapoglou
5/5
*these members also aended 5/5 joint meengs of HRRC with NCGC
Mr. Adrian Lewis
Chair of HRRC
Dear Shareholders
On behalf of the Board, I present you with the Remuneration Policy Report for the Financial Year 2024.
Key Actions in 2024
During 2024, we continued to make progress in the implementation of our Human Resources strategy
whilst focusing on several key priorities including, but not limited to, the implementation of our variable
pay plans (both short-term and long-term), the review of the Remuneration Policy and Material Risk
Takers, the review of the Performance Appraisal Framework & Target Setting (OKRs), the 2024 Learning
& Development Plan and the monitoring of transformational and people-related initiatives.
We also prepared for the first time our gender pay gap analysis in line with the EBA guidelines which we
monitor through an annual internal benchmarking study, aiming to identify the reasons for any such gap
and find ways to address it via our remuneration practices and policies.
Staff remuneration
In line with our collective agreement with the employees’ union, we have awarded fixed pay increases
to our staff, comprising of an annual increment plus a Cost of Living Allowance (‘COLA’).
Numbers at a glance
Payroll Cost for increases awarded in 2024
(includes salary increments, merit pay and COLA)
10,4m
Average annual salary increase per employee
c.3.100
(6%)
3
.
REMUNERATION
POLICY
REPORT
I
.
Human Resources and Remuneration Committee Chair’s Foreword
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I. Chair’s Foreword (continued)
As per the terms of our agreement, we have paid 75% of the annual increment corresponding to each
staff member’s pay grade, and distributed the remaining 25% under our Merit Pay plan to a smaller
group of employees (c.51%), as per predetermined criteria agreed with the employees’ union (years of
service, performance, value of position/pay competitiveness).
Payroll cost for salary increments 2024 4,7m
Payroll cost for Merit Pay 2024 1,4m
Cost of Living Allowance increase 2024 4,3m
Statistics for Merit Pay increases 2024
Staff awarded merit pay (% of total staff) c. 51%
- 100% of annual increment c. 4%
- 75% of annual increment c. 7%
- 50% of annual increment c. 13%
- 25% of annual increment c. 27%
Variable Pay
The Group delivered a very strong performance for the financial year 2023. This enabled us to make
bonus payments under our Short-Term Incentive Plan (the‘STIP’) in 2024. This was the result of our
designing and approving the parameters of such a plan in the previous years, in line with the applicable
regulatory environment. The performance of the Group continued to be strong during the financial year
2024, as evidenced by the Group’s profitability and capital position, further allowing us to continue and
expand our efforts in employee rewards.
This development is a significant step in the modernization of the Group’s remuneration structure,
enabling us to align the interests of our staff members with the Group’s business strategy, objectives,
values and long-term interests. It is important to highlight that the recipients of awards under the STIP
included members of our staff across all departments and business lines, grades and managerial levels,
based on fair and transparent performance criteria.
Numbers at a glance
Cost for STIP 2024 c. 10.4m*
Recipients
c. 1
.
100
(c.35% of all staff)
Note: Numbers shown above are based on provisional approvals for participation and level of the award.
*Cost for STIP excludes employer’s contributions.
The year 2024 marked the completion of the 2022 LTIP cycle for the performance period FY 2022-2024
and includes amounts expected to vest in 2025 and amounts to be deferred in following years. In
addition, we have issued award notifications to the members of our senior management team under the
Group’s Long-Term Incentive Plan (the‘LTIP’) for the 3-year performance period FY2024-2026, in line
with the Group’s business objectives and related targets. In 2024, we further increased the customer
focus in remuneration by introducing customer experience targets in our Long-Term Incentive Plan.
The design of our incentive plans and the respective objectives, targets and associated conditions, aim
to ensure that these plans are consistent with, and promote, sound and effective management of risk
and long-term sustainable success and do not encourage excessive risk-taking.
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I. Chair’s Foreword (continued)
Full details of our incentive plans, including those applying to our Executive Directors (together with all
relevant components of executive compensation), can be found in the respective sections of this report.
Employee Engagement
During the year, we continued to engage with our employees and their representatives in an open and
transparent manner.
We have set up a committee with employee union representation to discuss remuneration matters and,
specifically, the distribution of merit pay increases. This is a forum for receiving input from our employees’
representatives on the criteria used for the distribution of merit pay increases as well as receiving
feedback after implementation and dealing with employee grievances or complaints.
We continued to provide employee benefits as per the terms of our collective agreement as negotiated
with the employees’ union and, where required, we have engaged with our employees and their
representatives to resolve any relevant issues.
In an ongoing commitment to employee engagement and continuous improvement, we continued to
review feedback from the Group’s staff surveys and have made significant strides in implementing actions
responsive to such feedback.
Additionally, we continued to foster direct engagement with colleagues through various communication
channels, recognising that people at all levels are critical to our organisation’s success.
Looking Ahead
Moving into 2025, the Human Resources & Remuneration Committee will continue its work in pay
modernization in line with clear and transparent policies for each component of remuneration.
Our work is guided by the principles of fair pay for all our staff members leading to sustainable business
outcomes for the Group in line with its overall objectives and strategy. We will continue to support our
staff across all areas of remuneration and benefits demonstrating care and socially responsible practices.
On behalf of the members of the Human Resources & Remuneration Committee of the Board, I would
like once again to thank our stakeholders for their continued support and extend my gratitude to our
staff members for delivering a very strong performance in 2024.
Sincerely,
Adrian Lewis
Chair of HRRC
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II. Remuneration Policy Report for the year 2024
1. Introduction
In accordance with the provisions of the CSE Code published by the CSE (6
th
Edition (Revised) April
2024), and in particular Annex 1 of the CSE Code, and the Irish Companies Act, the HRRC prepares the
Annual Board of Directors’ Remuneration Policy Report, which is ratified by the Board and submitted to
a non-binding advisory vote at the shareholders’ AGM. The Board of Directors Remuneration Policy
Report for the year 2024 was ratified by the Board on 26 March 2025. The Group’s objective to attract,
develop, motivate and retain high value professionals is considered fundamental in achieving the goals
and objectives of the Group, and ensuring that the right people are in the right roles whilst managing
the Group’s remuneration strategy and policies in a manner aligned with the interests of the Group’s
shareholders.
2. Human Resources and Remuneration Committee
The HRRC’s primary role is to ensure that staff members contribute to sustainable growth by staying
ahead of challenges and opportunities. The Group aims to review its remuneration policies and practices
on an ongoing basis and amend them where necessary, in order to ensure that they are consistent with,
and promote sound and effective risk management. Every year, the HRRC proposes to the Board the
Remuneration Policy Report as part of the Annual Report of the Group, which is submitted to the
shareholders’ AGM.
3. Terms of Reference of the Human Resources and Remuneration Committee
The role of the HRRC is described in detail in Section 2, subsection XII of the Annual Corporate
Governance Report. In respect of remuneration the HRRC undertakes the following:
To propose adequate remuneration considered necessary to attract and retain high value-adding
professionals.
To consider the remuneration arrangements of the Executive Directors of the Group, senior
management and the Group Remuneration Policy bearing in mind the European Banking
Authority (the‘EBA’) Guidelines on sound remuneration policies, the CBC Internal Governance
Directive, the CSE Code; the UK Code and any other applicable or regulatory requirements.
To oversee the implementation of Strategic HR initiatives which promote and are aligned with
the Group’s ESG ambition, strategy and objectives.
To review the implementation and effectiveness of the Remuneration Policy and ensure this
follows the Remuneration Framework of the CBC Internal Governance Directive.
The HRRC ensures that internal control functions are involved in the design, review and implementation
of the Remuneration Policy and that staff members who are involved in the design, review and
implementation of the Remuneration Policy and practices have relevant expertise and can form
independent judgement on the suitability of the Remuneration Policy and practices, including their
suitability for risk management.
The Group’s aim is to align its Remuneration Policy and human resources practices, with its business
strategy, objectives, values and long-term interests of the Group and ensure that they are consistent
with and promote sound and effective management of risk and long-term sustainable success and do
not encourage excessive risk-taking.
The Remuneration Policy aims to ensure the application of a fair and transparent management process
that applies equally to all staff, aligns their remuneration with job value, individual performance and
potential and considers market conditions. At the same time, the principles set out in the Remuneration
Policy aim to encourage responsible business conduct, fair treatment of customers and to avoid conflicts
of interest.
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II. Remuneration Policy Report for the year 2024 (continued)
3. Terms of Reference of the Human Resources and Remuneration Committee
(continued)
In developing its Remuneration Policy, the Group takes into account the provisions that are included in
the CSE Code, the UK Code, the CBC Internal Governance Directive which came into effect in October
2021, the Irish Companies Act, and incorporates the requirements for Remuneration Policies included in
the European Capital Requirements Directive (the‘CRD V’), the EBA Guidelines on sound remuneration
policies issued in July 2021, MiFID II and other Guidance of the EU as well as regulatory restrictions
currently pertinent to the banking sector and the Group in particular.
The HRRC reviews and approves the content of any resolutions submitted for approval at the AGM of the
shareholders, which are prepared by the Company Secretary in cooperation with the Group’s legal
advisers in accordance with Annex 3 of the Code which may concern possible plans for the compensation
of members of the Board in the form of shares, share warrants or share options.
The HRRC (jointly with NCGC) reviews and recommends for approval to the Board the remuneration
packages of executive members of the Board.
Also, the HRRC reviews and recommends for approval to the Board the remuneration packages of other
Senior Management (recommended by the CEO or by the respective Board Committees, for heads of
control functions and other staff reporting to Board committees).
The Committee reviews and approves appointments, transfers and dismissals of Group divisional
directors, senior managers and subsidiaries’ general managers (except heads of internal control
functions), recommended by the CEO, and ensures that all contractual obligations are adhered to.
The chairperson of the HRRC is available to shareholders at the AGM to answer any questions regarding
the Remuneration Policy of the Group. Colleagues’ engagement is described in Section 2, sub-section IX
of the Annual Corporate Governance Report.
4. Governance of Group Remuneration Policy
4.1. Principles of the CSE Code of Corporate Governance
Companies should implement official and transparent procedures for developing policies concerning the
remuneration of executive directors and fixing the remuneration of each Board member separately. The
level of remuneration should be sufficient to attract and retain talent required for the efficient operation
of the Company. Part of the remuneration of executive directors should be determined in such a way as
to link rewards to corporate and individual performance. Resolution, or any other authority allowing,
variable pay should be linked to performance.
The Company’s Corporate Governance Report includes a statement of the Remuneration Policy Report
and relevant criteria, as well as the total remuneration of the executive and non-executive members of
the Board.
4.2. EBA Guidelines
The EBA Guidelines aim to ensure that an institution’s remuneration policies and practices are consistent
with and promote sound and effective risk management. The Group seeks to ensure it implements
remuneration policies which are in compliance with regulatory guidelines, while at the same time
operating under legal, industrial and regulatory constraints.
In accordance with EBA guidelines for identification of those employees whose professional activities are
deemed to have a material impact on the Group’s risk profile, the Group maintains a list of these
employees known as Material Risk Takers which is reviewed and approved jointly by the NCGC and HRRC
(subject to any comments from RC) annually.
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II. Remuneration Policy Report for the year 2024 (continued)
5. Remuneration
Remuneration at all levels of the Group and all employees is governed by the Group Remuneration Policy.
The policy does not apply to Non-Executive Directors remuneration.
The Group Remuneration Policy is aligned with the European Banking Authority (EBA) guidelines on
Sound Remuneration Policies and Practices (as amended) and captures provisions from relevant
Directives and Guidance of the EU, the ECB and the Central Bank of Cyprus including, but not limited to,
the CBC Directive on Internal Governance of Credit Institutions 2021, the CSE Corporate Governance
Code, MiFID II, ECB Guide on climate related and environmental risks, Guidelines on the Remuneration
Practices, the Gender Pay Gap and Approved higher Ratios, as well as the UK Corporate Governance
Code.
The Remuneration Policy is in line with the business strategy, objectives, values and long-term interests
of the Group, is consistent with and promotes sound and effective risk management and long-term
sustainable success and does not encourage excessive risk-taking.
The Remuneration Policy aims to ensure the application of a fair, transparent pay management process
that applies equally to all staff, aligns their remuneration with job value, individual performance and
potential, and considers market conditions. At the same time, the principles set out in the Remuneration
Policy aim to encourage responsible business conduct, fair treatment of customers and to avoid conflicts
of interest.
Remuneration schemes are subject to stakeholder consultation and are largely determined by the
collective agreement with the Trade Union. They are also in line with the prevailing regulations and
guidance.
Remuneration typically consists of fixed plus variable pay.
5.1. Remuneration Tools & Components for all staff
Our remuneration package below summarises the different remuneration components for our staff.
Fixed
Variable
Basic Salary
Basic salary is determined by the collective
agreement with the trade union.
Changes in basic salary are effected through:
Annual Increment: fixed amount, granted
to all employees based on tenure, in January
of each year.
COLA Increase: granted to all staff in line
with collective agreement.
Merit Pay Increase: granted to c.50% of
staff, based on criteria agreed with the Trade
Union.
Short-Term Incentive Plan (STIP)
Aims to incentivise and reward the achievement of
the Group’s annual financial and strategic
objectives.
Discretionary cash-based bonus plan or a
combination of cash and shares in case amount for
an individual exceeds a certain threshold (not part
of the collective agreement), granted to part of the
workforce (2024: c.35% of all staff), based on
performance.
Awards are conditional on the achievement of
predefined Group financial targets and are subject
to Board approval on an annual basis.
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II. Remuneration Policy Report for the year 2024 (continued)
5. Remuneration (continued)
5.1. Remuneration Tools & Components for all staff (continued)
Pension
Supporting our staff in building long term
retirement savings.
Determined by the collective agreement with the
trade union.
Defined contribution scheme:
- 9% employer contribution
- 3%-10% employee contribution
Long-Term Incentive Plan (LTIP)
Aims to achieve incentive alignment between
shareholder interests and members of the eligible
group.
Discretionary share-based plan (not part of the
collective agreement), granted to senior
management members (2024: 21 employees).
Granting is conditional upon the Group meeting its
financial target(s), over a 3-year performance
period. Subject to Board and shareholder
approval.
Benefits
Flexible benefits as part of a competitive
remuneration package (medical cover, life
insurance, maternity leave, paternity leave,
parental leave, preferential banking rates etc.)
Total Variable Remuneration
The AGM resolution that was approved by the
shareholders in May 2024, gave the Company the
flexibility to increase the ratio of variable to fixed
remuneration to up to a maximum of 100% for
Material Risk Takers.
Our remuneration components at a glance
5.2. Remuneration of Non-Executive Directors
The remuneration of non-executive directors is not linked to the profitability of the Group. It is related
to the responsibilities and time devoted for Board meetings and decision-making for the governance of
the Group, and for their participation in the committees of the Board and any participation in the boards
of Group subsidiary companies. The shareholders’ AGM held on 20 May 2022 approved an increase in
the annual remuneration of the Chairperson of the Board and the remuneration of the non-executive
members. The annual remuneration of the Board has remained at the same levels for both years 2023
and 2024.
The remuneration of non-executive directors is determined and approved by the Board. Neither the
Chairperson nor any director participates in decisions relating to their own personal remuneration. The
HRRC proposes fees payable to the Chairperson and the Vice-Chair, while the Chairperson makes
recommendations for the remuneration of the non-executive directors to the Board for approval by the
AGM, considering the following factors:
Senior Management
c
.
35
% of
staff
Pension
Basic
Salary
Benefits STIP
LTIP
Total
Reward
+
+ + + =
Variable
Fixed
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II. Remuneration Policy Report for the year 2024 (continued)
5. Remuneration (continued)
5.2. Remuneration of Non-executive Directors (continued)
1. The time allocated and effort exerted by non-executive directors to meetings and decision-
making in the management of the Group;
2. The undertaken level of risk;
3. The increased compliance and reporting requirements;
4. The requirement not to link remuneration of non-executive directors to the profitability of
the Group;
5. The requirement that non-executive directors do not participate in the pension schemes of
the Group;
6. The requirement not to include variable remuneration or share options as remuneration of
non-executive directors.
Neither the Chairperson nor any non-executive directors received any performance related
remuneration. The remuneration of the non-executive directors is set out below:
Position Annual Remuneration (000)
Chairperson 220
Vice-Chair 90
Senior Independent Director 80
Non-Executive Members 55
Chairpersons
Audit Committee 45
Risk Committee 45
Human Resources and Remuneration Committee 30
Nominations and Corporate Governance Committee 30
Technology Committee 30
Membership
Audit Committee 25
Risk Committee 25
Human Resources and Remuneration Committee 20
Technology Committee 20
Nominations and Corporate Governance Committee 20
Additionally, the Group reimburses all directors for expenses incurred in the course of their duties.
The non-executive directors have letters of appointment which can be inspected during normal business
hours by contacting the Company Secretary.
5.3. Remuneration and Other Benefits of Executive Directors
The HRRC, jointly with the NCGC, reviews and recommends for approval to the Board the remuneration
packages of Executive Directors vis-a-vis their performance. In line with the UK Code the following
factors are also considered: clarity, simplicity, risk, predictability and proportionality and finally
alignment to culture. Both, the CEO and the Executive Director Finance (EDF) are employees of BOC
PCL.
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II. Remuneration Policy Report for the year 2024 (continued)
5. Remuneration (continued)
5.3. Remuneration and Other Benefits of Executive Directors (continued)
For 2024, the Board approved a 10% increase in the fixed remuneration of the CEO and Executive
Director Finance. The decision is reflective of Group and personal performance in the last years and also
based on considerations of benchmarking with Greek and local banks.
The AGM resolution that was approved by the shareholders in May 2024, gave the Company the flexibility
to increase the ratio of variable to fixed remuneration to up to a maximum of 100% for the CEO and the
EDF. This is applicable for performance year 2024 and onwards.
Contracts of Employment
The remuneration (salary and bonus) of executive directors is set out in their employment contracts
which have a maximum duration of five years, unless any of the executive directors is an appointed
member of the senior management team, in which case the terms of employment are based on the
provisions of the collective agreement in place, except for the CEO.
The employment contract of the CEO was for an initial period of five years commencing on 1 September
2019. The CEO’s service contract is reviewed at least every five years. In December 2022, the CEO’s
contract was renewed for a further four years to 31 December 2026 and in November 2024 it was further
extended to 31 December 2028. The employment of the Executive Director Finance, the other executive
director, is mainly based on the provisions of the collective agreement in place.
The Group at present does not grant guaranteed variable remuneration or discretionary pension
payments.
Service Termination Agreements
The employment contract of Mr. Panicos Nicolaou, CEO, includes a clause for termination, by service of
six months’ notice to that effect by the executive director on grounds of change of control.
The terms of employment of Ms. Eliza Livadiotou, EDF and executive member of the Board, are mainly
based on the provisions of the collective agreement in place, which provide for notice or compensation
by the BOC PCL based on years of service and for a four-month prior written notice by the executive
director, in the event of a voluntary resignation.
Bonus (Short-Term Incentive Plan)
An amendment to the Directors’ Remuneration Policy was approved at the 2024 AGM to extend the STIP
to include the granting of share awards, subject to the terms and conditions of the Short-Term Incentive
Plan and any regulatory restrictions. The 2024 Remuneration Policy also clarifies that the variable
remuneration of Executive Directors is capped at the ratio set out in the Group-wide Remuneration Policy
in accordance with the applicable regulatory framework.
An amendment to the Directors’ Remuneration Policy was approved at the 2024 AGM to extend the STIP
to include the granting of share awards, subject to the terms and conditions of the Short-Term Incentive
Plan and any regulatory restrictions. The Revised Remuneration Policy also clarifies that the variable
remuneration of Executive Directors is capped at the ratio set out in the Group-wide Remuneration Policy
in accordance with the applicable regulatory framework (maximum 100% ratio variable to fixed
remuneration approved by the shareholders in May 2024). The STIP award may be granted either in
cash or a combination of cash and shares, and is subject to deferral, in case total variable pay for an
individual exceeds a certain threshold, in line with applicable regulatory requirements and other
remuneration restrictions. A retention period of 12 months will be applicable to each tranche of vested
shares. In 2023, the Board of Directors approved a proposal for the implementation of a Short-Term
Incentive Plan (STIP) across the organisation. The allocation criteria are to be decided on an annual basis
by the HRRC.
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II. Remuneration Policy Report for the year 2024 (continued)
5. Remuneration (continued)
5.3. Remuneration and Other Benefits of Executive Directors (continued)
The annual bonus pool will vary in accordance with the Group’s performance/profitability for each
financial year. Performance will typically be assessed based on a one-year performance period. The STIP
is at the discretion of the HRRC.
For the 2024 STIP, it was decided that this would be activated if the Group met a pre-defined financial
target threshold of ROTE.
Once the distribution of an STIP is approved and the relevant pool is determined, the individual STIP
awards for Executive Directors are set either as a percentage of salary or as a fixed amount, adjusted in
line with the Group’s performance as well as individual performance against their Objectives and Key
Results (OKRs). STIP awards are considered with amounts awarded under LTIP so that the total variable
remuneration for a performance year is within the approved fixed to variable remuneration threshold of
100%. In the context of establishing the final amount of variable remuneration for the performance year
2024, following the outcome of the assessment of the predetermined performance targets, the amounts
awarded under the relevant LTIP cycle were first determined, followed by the STIP amount to be awarded
so that the total is within the 100% threshold. Therefore, for year 2024, where for a participant the
whole of the 100% threshold was utilised for the LTIP, no STIP amount has been awarded.
At the end of FY2024, the STIP was activated once the Group met the target set relating to FY 2024
ROTE of 15.8% The STIP bonus pool, was calculated at 2% of the Group’s FY 2024 Profit After Tax
amounting to c.10 million.
The HRRC and the Board considered the Executive Directors’ STIP and LTIP outcomes (refer to Section
7 below for LTIP 2022-2024 outcome) in the context of the Group’s performance and the performance
of each Executive Director during 2024. The Committee concluded that the outcomes are appropriate in
the context of the performance achieved and that no discretionary adjustment was warranted. Before
finalising incentive outcomes, the Committee reflected on the appropriateness for both the 2024 annual
bonus (2024 STIP) and 2022-2024 LTIP and also at the total variable remuneration. For the performance
period ending 31 December 2024, the HRRC, following approval from the Board of Directors, set the
total variable pay award for both Executive Directors to 100% of fixed remuneration. The principal driver
of the increase in variable remuneration is the awarding of the first LTIP award (LTIP 2022-2024),
including the impact of the share price growth since the award was granted in 2022. As a result of the
share price growth the resulting value of the LTIP award (based on the average share price during the
period 1 December 2024 – 17 January 2025) is such that it makes up almost 100% of 2024 total fixed
remuneration figure and hence no STIP amount has been awarded to the CEO and for the EDF the STIP
amount has been set to 71.5 thousand.
The awards under the STIP granted to the Executive Director in respect of the performance for the financial
year ended 31 December 2024 are to be paid in cash and vest in tranches. It is noted that, in accordance
with the respective regulatory limits applicable on the deferral and payment in instruments for variable pay
(where this is above the minimum regulatory threshold), more than 50% of total variable pay (STIP plus
LTIP) awarded for the performance period ending 31 December 2024 is in the form of shares, and 60% of
the total variable pay awards (STIP plus LTIP) has been deferred as per the vesting cycle below:
2025 2026 2027 2028 2029 2030
40% 12% 12% 12% 12% 12%
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Annual Corporate Governance Report
Remuneration Policy Report
350
II. Remuneration Policy Report for the year 2024 (continued)
5. Remuneration (continued)
5.3. Remuneration and Other Benefits of Executive Directors (continued)
Retirement Benefit Schemes
The CEO participates in a defined contribution plan largely on the same basis as other employees. The
EDF participates in a defined contribution plan on the same basis as other employees.
The main characteristics of the retirement benefit schemes are presented in Note 14 of the Consolidated
Financial Statements for the year ended 31 December 2024.
Share Options
No share options were granted to the executive directors during 2024 or 2023.
Long-term incentive plan (‘LTIP’)
The LTIP was approved by the 2022 AGM, which took place on 20 May 2022. The LTIP involves the
granting of share awards and is driven by scorecard achievement, with measures and targets set to align
pay outcomes with the delivery of the Group’s strategy. Currently, under the plan, the employees eligible
for LTIP awards are the members of the Extended EXCO, including the executive directors.
The LTIP stipulates that performance will be measured over a 3-year period and sets financial and non-
financial objectives to be achieved. At the end of the performance period, the performance outcome will
be used to assess the percentage of the awards that will vest. The LTIP represents a further step in the
Group’s efforts to enhance its remuneration structure by introducing a variable pay component within
the total compensation package of the members of eligible group, as per best practice and in accordance
with EU banking industry regulations. As per the applicable regulatory framework, up to 100% of the
awards will be subject to malus and clawback provisions in accordance with applicable legislation and
regulations. For any award to vest the employee must be in the employment of the Group up until the
date of the vesting of such an award. Under certain circumstances the HRRC has the discretion to
recommend to the Board to determine whether the award will lapse and/or the extent to which the award
will be vested.
The AGM resolution that was approved by the shareholders in May 2024 gave the Group the flexibility to
increase the ratio of variable to fixed remuneration to up to a maximum of 100% of fixed remuneration
for Material Risk Takers (MRTs).
The LTIP is at the discretion of the HRRC.
Share awards have been granted under a long-term incentive plan to the executive directors during
2022, 2023 and 2024 as described further below.
Other Benefits
Other benefits provided to the executive directors (CEO & EDF) include other benefits provided to staff
(e.g. company car or car allowance, medical fund contributions and life insurance). The relevant costs
for the executive management are disclosed in Note 49 of the Consolidated Financial Statements for the
year ended 31 December 2024.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Annual Corporate Governance Report
Remuneration Policy Report
351
II. Remuneration Policy Report for the year 2024 (continued)
6. Information Regarding the Remuneration of Directors for Year 2024
6.1 Directors’ Total Remuneration
Notes:
* Exclusive of employer’s contributions to social security and related funds.
** Benefits include taxable amount for benefit in kind – car, medical.
*** Refers to amounts that were awarded for the reporting period in respect of the performance period FY2024 for the STIP and of the performance period FY2022-FY2024 for
the LTIP (2022 LTIP cycle awarded) and include both amounts expected to vest in 2025 and amounts to be deferred in following years.
(1) Constantine Iordanou passed away on 16 June 2024.
(2) Christian Hansmeyer’s and Stuart Birrell’s appointment to the Board of the Bank and the Company was approved by the ECB on 29 April 2024 and approved at the AGM on
17 May 2024.
2024
Remuneration
for services*
Remuneration
for participation
in the Board of
Directors and
its Committees*
Total
remuneration
for services
Remuneration
and benefits
from other
Group
companies
Assessment of
the value of
benefits that
are considered
to form
remuneration
**
Annual
contribution
to
retirement
benefits
Total Fixed
Remuneration
Remuneration
in the form of
Shared-based
payment
(LTIP)***
Remuneration
in the form of
Bonus
payment
(STIP)***
Total
Variable
remuneration
Total
Remuneration
Executive
Directors
Panicos Nicolaou 807,692 807,692 10,868 72,563 891,123 891,119 - 891,119 1,782,242
Eliza Livadiotou 325,066 325,066 6,954 29,256 361,276 289,277 71,500 360,777 722,053
Non-Executive
Directors
Efstratios -
Georgios (Takis)
Arapoglou
- 260,549 260,549 260,549 260,549
Lyn Grobler - 165,000 165,000 165,000 165,000
Monique
Hemerijck
- 152,047 152,047 152,047 152,047
Constantine
Iordanou
1
- 80,769 80,769 80,769 80,769
Adrian Lewis - 158,901 158,901 158,901 158,901
Christian
Hansmeyer
2
- 62,363 62,363 62,363 62,363
Stuart Birrell
2
- 62,363 62,363 62,363 62,363
-
1,132,758 941,992 2,074,750 0 17,822 101,819 2,194,391 1,180,396 71,500 1,251,896 3,446,287
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Annual Corporate Governance Report
Remuneration Policy Report
352
II. Remuneration Policy Report for the year 2024 (continued)
6. Information Regarding the Remuneration of Directors for Year 2024 (continued)
6.1 Directors’ Total Remuneration (continued)
Notes:
* Exclusive of employer’s contributions to social security and related funds.
** Benefits include taxable amount for benefit in kind – car.
*** Refers to amounts that were awarded for the reporting period in respect of the performance period FY2023 for the STIP. There were no amounts awarded under LTIP as no
LTIP cycle had ended in the year 2023. Amount reported includes both amounts expected to vest in 2024 and amounts to be deferred in following years.
(1) Arne Berggren resigned from the Board of the Bank and the Company on 31 March 2023.
(2) Monique Hemerijck’s appointment to the Board of the Bank and the Company was approved by the ECB on 10 August 2023
(3) Paula Hadjisotiriou and Ioannis Zographakis resigned from the Board of the Bank and the Company on 31 December 2023.
(4) Adrian Lewis’ appointment to the Board of the Bank and the Company was approved by the ECB on 17 November 2023.
(5) Maria Philippou resigned from the Board of the Bank and the Company on 13 October 2023.
(6) Nicolaos Sofianos resigned from the Board of the Bank and the Company on 11 December 2023.
2023
Remuneration
for
services*
Remuneration
for participation
in the Board of
Directors and
its Committees*
Total
remuneration
for services
Remuneration
and benefits
from other Group
companies
**
Assessment of
the value of
benefits that
are considered
to form
remuneration
Annual
contribution
to
retirement
benefits
Total Fixed
Remuneration
Remuneration
in the form of
Shared-based
payment
(LTIP)***
Remuneration
in the form of
Bonus
payment
(STIP)***
Total
Variable
remuneration
Total
Remuneration
Executive Directors
Panicos Nicolaou 750,000
-
750,000
-
10,868
67,500
828,368 -
300,000 300,000
1,128,368
Eliza Livadiotou 293,112
-
293,112
-
6,907
26,380
326,399 -
100,000 100,000 426,399
Non-Executive
Directors
Efstratios -Georgios
(Takis)Arapoglou
-
250,000
250,000
-
-
-
250,000
-
-
-
250,000
Lyn Grobler -
155,000 155,000
-
-
-
155,000
-
-
-
155,000
Arne Berggren
1
-
30,000
30,000
-
-
-
30,000
-
-
-
30,000
Monique Hemerijck
2
-
38,397 38,397
-
-
-
38,397
-
-
-
38,397
Paula Hadjisotiriou
3
-
140,706
140,706
-
-
-
140,706
-
-
-
140,706
Adrian Lewis
4
- 8,152 8,152 - 8,152 8,152
Constantine Iordanou -
148,288 148,288
-
-
-
148,288 -
-
-
148,288
Maria Philippou
5
-
76,753
76,753
-
-
-
76,753
-
-
-
76,753
Nicolaos Sofianos
6
-
117,112
117,112
-
-
-
117,112
-
-
-
117,112
Ioannis Zographakis
3
-
112,500
112,500
-
-
-
112,500 -
-
-
112,500
1,043,112 1,076,908 2,120,020 - 17,775 93,880 2,231,675 - 400,000 400,000 2,631,675
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Annual Corporate Governance Report
Remuneration Policy Report
353
II. Remuneration Policy Report for the year 2024 (continued)
6. Information Regarding the Remuneration of Directors for Year 2024 (continued)
6.2 Comparison of Directors’ and Employees’ remuneration
The following table provides information regarding the annual change in the total remuneration of
members of the Group’s Board of Directors, as compared with the Group performance as well as the
annual change in the remuneration, on a full-time equivalent basis, of the employees, between 2024
and 2020.
Annual Change
Note
*
%
change
in 2024
%
change
in 2023
%
change in
2022
%
change in
2021
%
change in
2020
Directors’ Remuneration
-
Executive Directors
Panicos Nicolaou, CEO 1 58% 37% 6% 42% 75%
Eliza Livadiotou, Executive
Director Finance
1 69% 39% 1% 39% 14%
Directors’ Remuneration
-
Non-Executive Directors
(NEDs)
2
Efstratios
-
Georgios
(Takis)
Arapoglou (Chairman)
4% 0% 20% 40% 81%
Lyn Grobler 6% -3% 7% 14% 46%
Monique Hemerijck 3 296% n/a n/a n/a n/a
Adrian Lewis 4 n/a n/a n/a n/a n/a
Christian Hansmeyer 5 n/a n/a n/a n/a n/a
Stuart Birrell 5 n/a n/a n/a n/a n/a
Constantine Iordanou 6 -46% 60% n/a n/a n/a
Paula Hadjisoteriou 7
-
100%
9% 12% 8% 12%
Nicolaos Sofianos 7
-
100%
-6% 29% n/a n/a
Ioannis Zographakis 7
-
100%
-26% -21% -4% 29%
Maria Philippou 7
-
100%
-27% -9% 16% 53%
Arne Berggren 7
-
100%
-75% 9% 1% -5%
Maksim Goldman 8
n/a
-
100%
-65% -3% -5%
Michael Heger 8
n/a
-
100%
-65% -3% -5%
Average Remuneration on a
full-time equivalent basis of
employees
Employees of the
Group
excluding STIP & LTIP
9 5.9% 9.2% 2.5% 5.8% -3.7%
Employees of the
Group
including STIP & LTIP
9 4.9% 16.0% 2.5% 5.8% -3.7%
Company performance
Operating profit as per
Underlying basis
10 -2.9% 136.9% 61.5% 2.2% -10%
Cost to Income Ratio
excluding
special levy on deposits and
other levies/contributions
11 +3 p.p. -18 p.p. -11 p.p. 0 p.p. +1 p.p
1. The % change in FY2024 relates mainly to the variable remuneration awards for the performance periods
ending 31/12/2024 and primarily due to the inclusion of the 2022 LTIP award being the first LTIP cycle
ended since the establishment of the LTIP Plan and includes amounts to vest in 2025 and deferred in the
following years. Please refer to Section 6.
2. The fees of the non-executive Directors include fees as members of the Board of Directors of the
Company and its subsidiaries, as well as of committees of the Board of Directors.
3. Appointed on 10 August 2023 hence the % change is higher for 2024.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Annual Corporate Governance Report
Remuneration Policy Report
354
II. Remuneration Policy Report for the year 2024 (continued)
6. Information Regarding the Remuneration of Directors for Year 2024 (continued)
6.2 Comparison of Directors’ and Employees’ remuneration (continued)
4. Appointed on 17 November 2023 hence the % change is n/a.
5. Appointed in 2024 hence the % change is n/a for years presented.
6. Passed away on 16 June 2024.
7. Resigned during 2023 hence % change is 100% for the year ended 31 December 2024.
8. Following the AGM 20 May 2022, Mr. Maksim Goldman and Dr. Michael Heger have not been re-elected
to the Board of Directors of the Company.
9. The change in average remuneration is based on annual employees’ cost (excluding employer’s
contributions) divided by the average number of employees (full time). Annual employees cost as per
Note 14.1 of the Consolidated Financial Statements (excluding Voluntary Staff Exit Plan Cost and Exit
cost and other termination benefits). The increase of 5,9% and 9.2% in the financial years 2024 and
2023 respectively relates primarily to the cost of living adjustments (COLA) and the annual salary
increments. When considering the accrual the variable remuneration, this increases to 16% in 2023 as
this was the first time the STIP was introduced.
10. Operating profit on the underlying basis comprises profit before loan credit losses (as defined),
impairments of other financial and non-financial assets, provisions for pending litigation, claims,
regulatory and other matters (net of reversals), tax, profit attributable to non-controlling interests and
non-recurring items (as defined). The reconciliation to the statutory information is included in section
‘Reconciliation of the Consolidated Income Statement for the year ended 31 December 2024 between
the audited statutory basis and the underlying basis’ of the Directors’ Report.
11. Defined as total expenses as per underlying basis, excluding special levy on deposits and other
levies/contributions divided by total income as per underlying basis. The definitions and reconciliations
between the audited statutory basis and the underlying basis are included in the ‘Alternative Performance
Measures Disclosures’ included within the 2024 Annual Financial Report.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Annual Corporate Governance Report
Remuneration Policy Report
355
II. Remuneration Policy Report for the year 2024 (continued)
7. Long-Term Incentive Plan
In December 2022, the Group granted to eligible employees being the members of the Extended EXCO
share awards under the long-term incentive plan.
The award cycle for the 3-year performance period for FY2022 – FY2024 is shown below:
In October 2023, the Group granted to eligible employees being the members of the Extended EXCO
share awards under the long-term incentive plan.
The award cycle for the 3-year performance period for FY2023 – FY2025 is shown below:
In April 2024, the Group granted to eligible employees being the members of the Extended EXCO share
awards under the long-term incentive plan.
The award cycle for the 3-year performance period for FY2024 – FY2026 is shown below:
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Annual Corporate Governance Report
Remuneration Policy Report
356
II. Remuneration Policy Report for the year 2024 (continued)
7. Long-Term Incentive Plan (continued)
7.1. 2024 LTIP awards for FY2024 - Executive Directors
LTIP awards for FY2024 Number of shares*
Face value at Award
Notification **
’000
Performance period
Panicos Nicolaou 101,350
375
2024-2026
Eliza Livadiotou 32,630
121
2024-2026
* This is the maximum number of shares that can be awarded to each of the Executive Directors and
is based on the share price that was applicable on the date of the Award Notification.
** Based on a share price of 3,7 at Award Notification.
The applicable scorecards for Executive Directors are presented below for the performance period
FY2024-2026. The scorecard for the executive directors is the same as for the rest of the senior
management, noting that a different scorecard applies to eligible participants of control functions. It is
noted that individual performance conditions are also applicable as per the Plan Rules and these provide
for a minimum performance appraisal score throughout the performance period.
7.2. 2022 LTIP award for FY2022 - FY2024 performance
Following the recommendation of the HRRC, the Board of Directors, having examined the performance
of the Group during the period 2022-2024 against the targets set at the beginning of the period, and
further to a risk assessment with respect to the liquidity and capital position of the Group, approved the
granting of the awards under the LTIP FY2022 - FY2024 cycle.
The achievement against the targets set was assessed to be at 95%, with the outcome for the individual
components of the corresponding scorecard included below.
The shares awarded in respect of this performance period will vest according to the deferral cycle
described in Section 6 of the Remuneration Policy Report and are subject to malus and claw back
conditions as per the applicable regulatory framework and the plan rules.
LTIP awards
for FY2022-
2024
Maximum
Number of
shares on
award
notification*
Scorecard
result
Maximum
Number of
shares adjusted
for scorecard
result
Actual
Number
of
shares
awarded
Value of
shares
awarded
excluding
share price
appreciation
’000*
Value of
shares
awarded
including
share price
appreciation
’000**
Panicos
Nicolaou
221,890 95% 210,796 192,883 326 891
Eliza
Livadiotou
65,910 95% 62,614 62,614 106 289
* Based on a share price of 1.69 at the time of award notification at the beginning of the performance period.
Maximum number of shares was set with reference to 50% of gross salary for the CEO and 40% of gross salary
for the EDF, at the time of the Award Notification, based on this share price.
** Based on the average closing share price on the CSE stock exchange for the period 1 December 2024 –17
January 2025 of 4.62.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Annual Corporate Governance Report
Remuneration Policy Report
357
II. Remuneration Policy Report for the year 2024 (continued)
7. Long-Term Incentive Plan (continued)
7.2. 2022 LTIP award for FY2022 - FY2024 performance (continued)
LTIP Outcome
Area KPI Weight
Target
(end of
FY2024)
Threshold
(end of
FY2024)
Actual
as at
31/12/24
Final
1
Score
Profitability
Return on Tangible Equity (ROTE) 20%
More or equal
to 10%
8% 21.4% 20%
Cost to Income (excluding levy &
SRF)
10%
Less or equal
to 50%
55% 34% 10%
Asset Quality
NPE Ratio 10%
Less than
5%
7% 2.5% 10%
REMU stock 10%
Less or
equal to
0,6bn
0.7bn 0.66 bn 5%
Arrears < 3dpd (excluding RRD) 10%
Less or equal
to 1%
2% 0.11% 10%
Capital
CET1 Ratio 10%
More or equal
to 14,5%
13.5% 19.2% 10%
MREL Ratio 5%
More or equal
to 23%
22% 28.4% 5%
Risk &
Compliance
Information Security and ICT
Controls Effectiveness
5%
More or equal
to 95%
90%
Target
Met
5%
Audit & ECB findings overall
completion rate
5%
More or equal
to 90%
85%
Target
Met
5%
RCSAs actions overall completion
rate
5%
More or equal
to 90%
85%
Target
Met
5%
Compliance findings/
recommendations overall
completion rate
5%
More or equal
to 90%
85%
Target
Met
5%
ESG
External ESG Ratings Score 5% AA rating n/a AA 5%
Achievement of Outcome
95%
1
For the assessment of the outcome at the end of the performance period
Where actual value for a KPI is equal or greater than the target KPI then 100% of the weight is applied
for the relevant KPI;
Where actual value for a KPI is equal or greater than the threshold but below the target value then
50% of the weight is applied for the relevant KPI;
Where actual value for a KPI is lower than the threshold or no threshold applies then 0% is assigned
for the KPI.
No ex-ante or ex-post risk adjustments (malus and clawback) of variable pay were made in 2024.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Annual Corporate Governance Report
Remuneration Policy Report
358
II. Remuneration Policy Report for the year 2024 (continued)
7. Long-Term Incentive Plan (continued)
7.3. General structure of performance criteria for LTIP Cycles for which the performance
period has not yet been concluded
Scorecard 2023 LTIP – Performance Period FY2023 - FY2025
Area KPI Weight
Target
(end of
FY2025)
1
Threshold
(end of
FY2025)
1
Profitability
Return on Tangible Equity
(ROTE)
20%
More or equal to
13%
11%
Cost to Income (excluding levy
& SRF)
10%
Less or equal to
45%
50%
Asset Quality
NPE Ratio 10%
Less than
3%
5%
REMU stock 10%
Less or
equal to
0.5bn
0.6bn
Arrears < 3dpd (excluding RRD)
10%
Less or equal to
1%
2%
Capital
CET1 Ratio 10%
More or equal to
15%
14%
MREL Ratio 5%
100bps Binding
Requirement
Binding
Requirement
Risk &
Compliance
Information Security and ICT
Controls Effectiveness
5%
More or equal to
95%
90%
Audit & ECB findings overall
completion rate
5%
More or equal to
90%
85%
RCSAs actions overall
completion rate
5%
More or equal to
90%
85%
Compliance findings/
recommendations overall
completion rate
5%
More or equal to
90%
85%
ESG External ESG Ratings Score 5% AA rating n/a
1
For the assessment of the outcome at the end of the performance period
Where actual value for a KPI is equal or greater than the target KPI then 100% of the weight is applied
for the relevant KPI;
Where actual value for a KPI is equal or greater than the threshold but below the target value then
50% of the weight is applied for the relevant KPI;
Where actual value for a KPI is lower than the threshold or no threshold applies then 0% is assigned
for the KPI.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Annual Corporate Governance Report
Remuneration Policy Report
359
II. Remuneration Policy Report for the year 2024 (continued)
7. Long-Term Incentive Plan (continued)
7.3. General structure of performance criteria for LTIP Cycles for which the performance
period has not yet been concluded (continued)
Scorecard 2024 LTIP – Performance Period FY2024 - FY2026
Area KPI Weight
Target
(end of
FY2026)
1
Threshold
(end of
FY2026)
1
Profitability
Return on Tangible Equity
(ROTE) on 15% CET1 ratio
20%
More or equal to
15%
13%
Cost to Income (excluding levy
& SRF)
10%
Less or equal
to 45%
50%
Asset Quality
NPE Ratio 10% Less than 3% 4%
REMU stock 10%
Less or equal
to 0.35bn
0.45bn
Capital
CET1 Ratio 10%
More or equal to
15%
14%
Organic Capital Generation 5%
More or equal to
250bps
200bps
MREL Ratio (% of RWAs) 5%
100 bps > Binding
requirement
Binding
requirement
Risk &
Compliance
Information Security and
ICT Controls Effectiveness
5%
More or equal to
95%
90%
Audit & ECB findings overall
completion rate
5%
More or equal to
90%
85%
RCSAs actions overall
completion rate
5%
More or equal to
90%
85%
Compliance findings/
recommendations overall
completion rate
5%
More or equal to
90%
85%
Customer
Experience
Net Promoter Score 5% Improvement Neutral
ESG External ESG Ratings Score 5% AA rating n/a
1
For the assessment of the outcome at the end of the performance period
Where actual value for a KPI is equal or greater than the target KPI then 100% of the weight is applied
for the relevant KPI;
Where actual value for a KPI is equal or greater than the threshold but below the target value then
50% of the weight is applied for the relevant KPI;
Where actual value for a KPI is lower than the threshold or no threshold applies then 0% is assigned
for the KPI.
360
Independent auditors’ report to the members of Bank of
Cyprus Holdings Public Limited Company
Report on the audit of the financial statements
Opinion
In our opinion, Bank of Cyprus Holdings Public Limited Company’s consolidated financial statements and
Company financial statements (the “financial statements”):
give a true and fair view of the Group’s and the Company’s assets, liabilities and financial position as at 31
December 2024 and of the Group's and the Company's profit and cash flows for the year then ended;
have been properly prepared in accordance with International Financial Reporting Standards (“IFRSs”) as
adopted by the European Union; and
have been properly prepared in accordance with the requirements of the Companies Act 2014 and, as regards
the consolidated financial statements, Article 4 of the IAS Regulation.
We have audited the financial statements, included within the Annual Financial Report 2024 (the “Annual
Report”), which comprise:
the Consolidated Balance Sheet and Company Balance Sheet as at 31 December 2024;
the Consolidated Income Statement and Consolidated and Company Statements of Comprehensive Income
for the year then ended;
the Consolidated Statement of Cash Flows and Company Statement of Cash Flows for the year then ended;
the Consolidated Statement of Changes in Equity and Company Statement of Changes in Equity for the year
then ended; and
the notes to the financial statements, which include a description of the accounting policies.
Our opinion is consistent with our reporting to the Audit Committee.
Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (Ireland) (“ISAs (Ireland)”) and
applicable law. Our responsibilities under ISAs (Ireland) are further described in the Auditors’ responsibilities for
the audit of the financial statements section of our report. We believe that the audit evidence we have obtained is
sufficient and appropriate to provide a basis for our opinion.
Independence
We remained independent of the Group in accordance with the ethical requirements that are relevant to our audit
of the financial statements in Ireland, which includes IAASA’s Ethical Standard as applicable to listed public
interest entities, and we have fulfilled our other ethical responsibilities in accordance with these requirements.
To the best of our knowledge and belief, we declare that non-audit services prohibited by IAASA’s Ethical
Standard were not provided to the Group or the Company.
Other than those disclosed in note 15 to the financial statements, we have provided no other services to the Group
or the Company in the period from 1 January 2024 to 31 December 2024.
361
Our audit approach
Overview
Overall materiality
€29.5 million (2023: €28.0 million) - Consolidated financial statements
Based on c. 5% of profit before tax.
27.7 million (2023: €24.1 million) - Company financial statements
Based on c. 0.85% (2023: c. 1%) of net assets.
Performance materiality
€22.1 million (2023: €21.0 million) - Consolidated financial statements.
20.8 million (2023: €18.0 million) - Company financial statements.
Audit scope
We audited the complete Consolidated financial information of Bank of
Cyprus Public Company Limited (PCL) which is the main trading entity of the
Group, and the financial information of Bank of Cyprus Holdings Public
Limited Company which is the holding company of the Group.
Our audit scope addressed in excess of 90% of the Group’s profit before tax
and the Group’s total assets.
Key audit matters
Impairment of loans and advances to customers.
Provision for pending litigation and claims
Valuation of stock of properties.
Privileged user access over financial reporting systems.
Carrying value of investment in Bank of Cyprus Public Company Limited
(Company only).
The scope of our audit
As part of designing our audit, we determined materiality and assessed the risks of material misstatement in the
financial statements. In particular, we looked at where the directors made subjective judgements, for example in
respect of significant accounting estimates that involved making assumptions and considering future events that
are inherently uncertain. As in all of our audits we also addressed the risk of management override of internal
controls, including evaluating whether there was evidence of bias by the directors that represented a risk of
material misstatement due to fraud.
Key audit matters
Key audit matters are those matters that, in the auditors’ professional judgement, were of most significance in the
audit of the financial statements of the current period and include the most significant assessed risks of material
misstatement (whether or not due to fraud) identified by the auditors, including those which had the greatest
effect on: the overall audit strategy; the allocation of resources in the audit; and directing the efforts of the
engagement team. These matters, and any comments we make on the results of our procedures thereon, were
addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon,
and we do not provide a separate opinion on these matters. This is not a complete list of all risks identified by our
audit.
362
Key audit matter
How our audit addressed the key audit matter
Impairment of loans and advances to customers
Refer to Note 2.17 “Impairment of financial assets”
within Note 2 “Summary of accounting policies”,
Note 5.1 “Calculation of expected credit losses” within
Note 5 “Significant and other judgements, estimates
and assumptions", Note 23 “Loans and advances to
customers” and Note 44 “Risk management Credit
risk”
The Group has developed complex models to calculate
expected credit losses (“ECL”) on its loans and
advances to customers. Impairment provisions are
calculated on a collective basis for portfolios of loans
of similar credit risk characteristics and on an
individual basis for loans that are individually
significant or which meet specific criteria determined
by management.
We determined this to be a key audit matter due to
the greater levels of management judgement
exercised in the following areas:
Methodology and model changes ;
Estimation uncertainty with respect to the future
cash flows of Stage 3 individually assessed
exposures;
The application of staging requirements to
identify a ‘significant increase in credit risk’ and
specifically in relation to the quantitative
thresholds and qualitative criteria used for
manual intervention; and
Incorporation of forward looking economic
scenarios and the related inputs, assumptions
and probability weights assigned to multiple
economic scenarios as used by the Group.
We understood and evaluated the design of the overall
control framework relevant to the measurement of
impairment of loans and advances to customers and
tested the operating effectiveness of key controls
across processes relevant to the calculation of ECL.
We assessed the appropriateness of the key
assumptions used in the methodologies and collective
ECL model developed by the Group and their
compliance with the requirements of IFRS 9.
We challenged the appropriateness and application of
the qualitative criteria used to assess significant
increase in credit risk in accordance with IFRS 9. We
assessed the quantitative thresholds and other triggers
identified by management to determine the
appropriate staging of loans within Stages 1, 2 or 3 and
tested, on a sample basis, the allocation of loans and
advances to customers to Stages 1, 2 or 3 with
reference to those thresholds and/or triggers.
We compared, with the assistance of PwC credit risk
experts, the forward-looking macroeconomic
assumptions used in the base, favourable and adverse
scenarios to publicly available information. We also
assessed the reasonableness of the adverse and
favourable assumptions together with the scenario-
weightings applied by management.
We tested, with the assistance of PwC credit risk
experts, the assumptions, inputs and formulas used in
the calculation of collective ECL. This included
considering the appropriateness of the collective ECL
model methodology (including changes in the current
year) and challenging the assumptions used (e.g.,
Exposure at Default, Loss Given Default and
Probability of Default).
We tested the completeness and accuracy of data
inputs to the collective ECL model on a sample basis.
We tested the mathematically accuracy of the
calculation of the collective ECL.
We evaluated the Group’s individual loan impairment
assessments for a sample of Stage 3 exposures for
compliance with IFRS 9 requirements; significant data
inputs were tested with reference to appropriate
supporting documentation, such as collateral
valuations and Land Registry records.
We evaluated the appropriateness of the Group's
disclosures particularly in relation to significant
judgements and estimates.
We concluded that the methodologies and judgements
used by management in determining the impairment
of loans and advances to customers were reasonable.
363
Key audit matter
How our audit addressed the key audit matter
Provision for pending litigation and claims
Refer to Note 2.36 “Provisions for pending
litigations, claims, regulatory and other matters”
within Note 2 “Summary of accounting policies”,
Note 5.3 "Provisions for pending litigation and
claims" within Note 5 “Significant and other
judgements, estimates and assumptions” and Note
38 “Provisions for pending litigations, claims,
regulatory and other matters”.
The Group is subject to various legal claims,
investigations and other proceedings. Provisions for
pending litigation, claims, regulatory and other
matters amounted to93 million as at 31 December
2024, of which 69 million amounts to provisions for
pending litigation and claims
Management together with the Group’s compliance
and legal departments and, where necessary, the risk
management department, review all existing and
potential legal cases, prepare an assessment of
potential outcomes for cases assessed individually
and collectively, and evaluate the probability of
economic outflow from the Group.
We determined this to be a key audit matter as the
recognition and measurement of provisions in respect
of pending litigation and claims requires a significant
level of judgement by management. The judgements
relate to the probability of obligating events requiring
an outflow of resources to settle the obligation and
estimation of the extent of any economic outflow.
We obtained an understanding of and evaluated the
design of controls relevant to the recognition and
measurement of pending litigation and claims. We
tested the operating effectiveness of controls we
sought to place reliance on.
We tested a risk based sample of management's
assessment of individual cases, including whether
economic outflow was assessed as probable. We
assessed management's proposed provisions against
information contained in case files, information
obtained from external legal advisors and where
applicable post year end information.
Where deemed necessary, we confirmed case facts and
judgements with external legal advisors. For a sample
of cases where management assessed economic
outflow as probable, and therefore a provision was
recorded, we recalculated the provision and performed
sensitivity analysis on key assumptions used by
management.
We understood the basis of management’s collective
provisions, in circumstances where these are applied,
assessed the key assumptions used by reference to
past experience and recalculated provisions booked.
We inspected the minutes of meetings of the Board of
Directors and certain of its committees for evidence of
any unidentified legal cases or relevant developments
in current cases, including the minutes of the
Settlement of Legal Cases Committee.
We evaluated whether the disclosures made addressed
significant uncertainties and assessed their adequacy
against the relevant accounting standards for both
provisions and contingencies as at 31 December 2024.
Based on evidence obtained, while noting the inherent
uncertainty in such matters, we concluded that the
recorded provisions for pending litigation and claims
were reasonable.
364
Key audit matter
How our audit addressed the key audit matter
Valuation of stock of properties
Refer to Note 2.28 “Stock of property”, within Note 2
“Summary of accounting policies”, Note 5.2 “Stock of
property - estimation of net realisable value” within
Note 5 “Significant and other judgements, estimates
and assumptions" and Note 27 “Stock of property”.
The Group has acquired a significant number of
properties as a result of restructuring agreements
with customers. These properties are accounted for as
stock of property and measured at the lower of their
cost or net realisable value in accordance with IAS 2.
Valuations obtained from external valuers and the
holding periods for assets are key inputs to determine
the appropriate carrying value.
We determined this to be a key audit matter in light of
the large volume of properties held and the
uncertainty around market conditions when
estimating the carrying amount.
We understood and evaluated the design of the overall
control framework relevant to repossessed properties
and tested the operating effectiveness of key controls
around their valuation.
We focused on the key inputs and assumptions
underlying the valuation of the properties. We
evaluated the competence, capability and objectivity of
management’s external experts (property valuers). For
a sample of external valuation reports, we assessed the
methodology and assumptions used with the
assistance of PwC valuation experts, where relevant.
We tested the accuracy of the application by
management of illiquidity discounts for a sample of
properties held at year end.
For a sample of properties acquired during the year,
we tested ‘cost’ by reference to signed ‘debt-for-asset’
agreements entered into with borrowers, and we
tested the ‘net realisable value’ at year end by
reference to external valuation reports.
We performed look-back procedures by comparing the
price achieved for disposals during 2025 to the
carrying values for those assets at 31 December 2024.
We evaluated whether the disclosures address
significant judgements and estimates and assessed
their adequacy against the relevant accounting
standards.
We concluded that estimates used by management in
determining the carrying amount of stock of property
were reasonable.
Privileged user access over financial reporting
systems
Refer to Section 2 XIV. Audit Committee in the
Corporate Governance Report.
The Group’s financial reporting is reliant on a number
of complex IT systems, some of which have been in
place for a number of years and which are inherently
complex.
Privileged user access management controls are an
integral part of the IT environment to ensure both
system access and changes made to systems are
authorised and appropriate. In the context of our
audit scope, we consider privileged user access
management controls contribute to mitigating the
risk of potential fraud or error and an integral part of
our audit testing is the effectiveness of the privilege
user access management controls.
We determined privileged user access to be a key
audit matter as our audit approach relies on IT
dependent controls and data.
With the assistance of PwC IT audit specialists, we
obtained an understanding of the Group’s IT
environment and changes made during the financial
year. We evaluated the design and tested the
operating effectiveness of those IT General Controls
(ITGCs) on IT systems that support financial
reporting.
We performed testing on the design, implementation
and operating effectiveness of IT General Controls
(ITGCs) over privileged user access provisioning,
revocation, recertification and authentication.
Where control deficiencies were identified we
considered the mitigating controls in place and/or
performed additional substantive audit procedures.
Having completed the additional audit procedures we
concluded that we obtained sufficient evidence for the
purpose of our audit.
365
Key audit matter
How our audit addressed the key audit matter
Carrying value of investment in Bank of Cyprus
Public Company Limited (Company only)
Refer to Note 2.3 “Investment in subsidiaries” within
Note 2 “Summary of accounting policies”, Note 3
“Significant accounting estimates, judgements and
assumptions", Note 7 “Investment in subsidiaries” to
the Company financial statements.
The carrying value of the investment in subsidiaries
exceeded the market capitalisation of Bank of Cyprus
Holdings Public Limited Company at 31 December
2024.
Having completed an impairment test, the directors
determined that the recoverable amount of the
investment, using a value-in-use approach (which is
considered to be higher than fair value less costs to
sell), exceeded the carrying value and a full write
back of previous impairment provisions of €801
million was recognised.
We considered this to be a key audit matter due to the
judgement associated with the assessment of the
recoverable amount of the investment at 31 December
2024 including, in particular, the expected cash flows,
the discount rate and the terminal value calculations.
We assessed the forecasts of expected cash flows
included in management’s value in use calculations at
31 December 2024 for consistency with the Group’s
recent trading performance and detailed Financial
Plan.
We evaluated the appropriateness of the discount rate
used by reference to external data sources used and we
assessed whether the calculation is in line with the
requirements of IFRS. We reperformed
management’s terminal value calculation and
considered the appropriateness of the long term
growth rate used by reference to external forecasts for
the Cypriot economy as at 31 December 2024.
We assessed the adequacy of the financial statement
disclosures in respect of the investment in the Bank of
Cyprus Holdings Public Limited Company-only
financial statements.
On the basis of the work performed we concluded that
the carrying value of the investment is reasonable.
How we tailored the audit scope
We tailored the scope of our audit to ensure that we performed enough work to be able to give an opinion on the
financial statements as a whole, taking into account the structure of the Group, the accounting processes and
controls, and the industry in which the Group operates.
Bank of Cyprus Public Company Limited is the main trading entity of the Group and prepares Consolidated
financial statements which consolidate all other subsidiaries of the Group. In establishing the overall approach to
scoping the Group audit engagement, we determined the type of work that needed to be performed by legal entity.
The Group team was responsible for the scope and direction of the audit. In determining our audit scope, we
considered the nature and extent of audit work that needed to be performed by us, as the Irish Group engagement
team, and PwC Cyprus, as component auditors. Where the work was performed by PwC Cyprus, we determined
the level of involvement the Group team needed to have to be able to conclude whether sufficient appropriate
audit evidence had been obtained as a basis for our opinion on the Consolidated financial statements as a whole.
We interacted regularly with PwC Cyprus during all stages of the audit. In addition to their formal audit report,
we reviewed a detailed memorandum of examination on work performed and relevant findings that supplemented
our understanding of the component.
For the Consolidated financial statements, an audit of the consolidated financial information of Bank of Cyprus
Public Company Limited was performed as this accounts for in excess of 90% of the Group’s profit before tax and
the Group’s total assets. The nature and extent of audit procedures were determined by our risk assessment.
366
Materiality
The scope of our audit was influenced by our application of materiality. We set certain quantitative thresholds for
materiality. These, together with qualitative considerations, helped us to determine the scope of our audit and the
nature, timing and extent of our audit procedures on the individual financial statement line items and disclosures
and in evaluating the effect of misstatements, both individually and in aggregate on the financial statements as a
whole.
Based on our professional judgement, we determined materiality for the financial statements as a whole as
follows:
Consolidated financial
statements
Company financial
statements
Overall materiality
€29.5 million (2023: €28.0 million).
€27.7 million (2023: €24.1 million).
How we determined it
c. 5% of profit before tax.
c. 0.85% (2023: c. 1%) of net assets.
Rationale for
benchmark applied
We applied this benchmark because in
our view, this is a metric against
which the recurring performance of
the Group is commonly measured by
its shareholders to assess its
performance.
The Company is a holding Company.
Consequently, we consider that net
assets is the most relevant measure to
reflect the nature of its activities and
transactions.
We use performance materiality to reduce to an appropriately low level the probability that the aggregate of
uncorrected and undetected misstatements exceeds overall materiality. Specifically, we use performance
materiality in determining the scope of our audit and the nature and extent of our testing of account balances,
classes of transactions and disclosures, for example in determining sample sizes. Our performance materiality was
75% of overall materiality, amounting to €22.1 million (Group audit) and 20.8 million (Company audit).
In determining the performance materiality, we considered a number of factors - the history of misstatements,
risk assessment and aggregation risk and the effectiveness of controls - and concluded that an amount at the
upper end of our normal range was appropriate.
We agreed with the Audit Committee that we would report to them misstatements identified during our audit
above €1.5 million (Group audit) (2023: €1.4 million) and €1.4 million (Company audit) (2023: €1.2 million) as
well as misstatements below that amount that, in our view, warranted reporting for qualitative reasons.
367
Conclusions relating to going concern
Our evaluation of the directors’ assessment of the Group and Company’s ability to continue to adopt the going
concern basis of accounting included:
Performing a risk assessment to identify factors that could impact the going concern assessment.
Considering the Group’s Financial Plan approved by the Board in February 2025. In evaluating
management’s base case forecasts and adverse scenarios we considered the Group’s financial position,
historic performance, its past record of achieving strategic objectives and management’s assessment of the
likely impact on financial performance, capital and liquidity for a period of 12 months from the date on
which the financial statements are authorised for issue.
Reading correspondence with the relevant regulators with regards to regulatory capital and liquidity
requirements of the Group, including in respect of the ECB’s Supervisory Review and Evaluation Process.
Considering the adequacy of relevant disclosures made in the financial statements.
Based on the work we have performed, we have not identified any material uncertainties relating to events or
conditions that, individually or collectively, may cast significant doubt on the Group’s or the Company’s ability to
continue as a going concern for a period of at least twelve months from the date on which the financial statements
are authorised for issue.
In auditing the financial statements, we have concluded that the directors’ use of the going concern basis of
accounting in the preparation of the financial statements is appropriate.
However, because not all future events or conditions can be predicted, this conclusion is not a guarantee as to the
Group’s or the Company’s ability to continue as a going concern.
In relation to the Company’s reporting on how they have applied the UK Corporate Governance Code, we have
nothing material to add or draw attention to in relation to the directors’ statement in the financial statements
about whether the directors considered it appropriate to adopt the going concern basis of accounting.
Our responsibilities and the responsibilities of the directors with respect to going concern are described in the
relevant sections of this report.
368
Reporting on other information
The other information comprises all of the information in the Annual Report other than the financial statements
and our auditors’ report thereon. The directors are responsible for the other information. Our opinion on the
financial statements does not cover the other information and, accordingly, we do not express an audit opinion or,
except to the extent otherwise explicitly stated in this report, any form of assurance thereon.
In connection with our audit of the financial statements, our responsibility is to read the other information and, in
doing so, consider whether the other information is materially inconsistent with the financial statements or our
knowledge obtained in the audit, or otherwise appears to be materially misstated. If we identify an apparent
material inconsistency or material misstatement, we are required to perform procedures to conclude whether
there is a material misstatement of the financial statements or a material misstatement of the other information.
If, based on the work we have performed, we conclude that there is a material misstatement of this other
information, we are required to report that fact. We have nothing to report based on these responsibilities.
With respect to the Directors’ Report, we also considered whether the disclosures required by the Companies Act
2014 (excluding the information included in the “Non Financial Statement” and the sustainability reporting
required by that Act on which we are not required to report) have been included.
Based on the responsibilities described above and our work undertaken in the course of the audit, ISAs (Ireland)
and the Companies Act 2014 require us to also report certain opinions and matters as described below.
In our opinion, based on the work undertaken in the course of the audit, the information given in the
Directors’ Report (excluding the information included in the “Non Financial Statement” and the
sustainability reporting on which we are not required to report) for the year ended 31 December 2024 is
consistent with the financial statements and has been prepared in accordance with the applicable legal
requirements.
Based on our knowledge and understanding of the Group and Company and their environment obtained in
the course of the audit, we did not identify any material misstatements in the Directors’ Report (excluding
the information included in the “Non Financial Statement” and the sustainability reporting on which we are
not required to report).
In our opinion, based on the work undertaken in the course of the audit of the financial statements,
the description of the main features of the internal control and risk management systems in relation to
the financial reporting process; and
the information required by Section 1373(2)(d) of the Companies Act 2014;
included in the Corporate Governance Statement, is consistent with the financial statements and has been
prepared in accordance with section 1373(2) of the Companies Act 2014.
Based on our knowledge and understanding of the Company and its environment obtained in the course of
the audit of the financial statements, we have not identified material misstatements in the description of the
main features of the internal control and risk management systems in relation to the financial reporting
process and the information required by section 1373(2)(d) of the Companies Act 2014 included in the
Corporate Governance Statement.
In our opinion, based on the work undertaken during the course of the audit of the financial statements, the
information required by section 1373(2)(a),(b),(e) and (f) of the Companies Act 2014 and regulation 6 of the
European Union (Disclosure of Non-Financial and Diversity Information by certain large undertakings and
groups) Regulations 2017 is contained in the Corporate Governance Statement.
369
Corporate Governance Statement
As a result of the directors voluntary reporting we are required by ISAs (Ireland) to review the directors’
statements in relation to going concern, longer-term viability and that part of the Corporate Governance
Statement relating to the Company’s compliance with the provisions of the UK Corporate Governance Code and
the Irish Corporate Governance Annex (the “Code”) specified for our review. Our additional responsibilities with
respect to the Corporate Governance Statement as other information are described in the Reporting on other
information section of this report.
Based on the work undertaken as part of our audit, we have concluded that each of the following elements of the
Corporate Governance Statement is materially consistent with the financial statements and our knowledge
obtained during the audit and we have nothing material to add or draw attention to in relation to:
The directors’ confirmation that they have carried out a robust assessment of the emerging and principal
risks;
The disclosures in the Annual Report that describe those principal risks, what procedures are in place to
identify emerging risks and an explanation of how these are being managed or mitigated;
The directors’ statement in the financial statements about whether they considered it appropriate to adopt
the going concern basis of accounting in preparing them, and their identification of any material
uncertainties to the Group’s and Company’s ability to continue to do so over a period of at least twelve
months from the date of approval of the financial statements;
The directors’ explanation as to their assessment of the Group’s and Company’s prospects, the period this
assessment covers and why the period is appropriate; and
The directors’ statement as to whether they have a reasonable expectation that the Company will be able to
continue in operation and meet its liabilities as they fall due over the period of its assessment, including any
related disclosures drawing attention to any necessary qualifications or assumptions.
Our review of the directors’ statement regarding the longer-term viability of the Group was substantially less in
scope than an audit and only consisted of making inquiries and considering the directors’ process supporting their
statement; checking that the statement is in alignment with the relevant provisions of the UK Corporate
Governance Code; and considering whether the statement is consistent with the financial statements and our
knowledge and understanding of the Group and Company and their environment obtained in the course of the
audit.
In addition, based on the work undertaken as part of our audit, we have concluded that each of the following
elements of the Corporate Governance Statement is materially consistent with the financial statements and our
knowledge obtained during the audit:
The directors’ statement that they consider the Annual Report, taken as a whole, is fair, balanced and
understandable, and provides the information necessary for the members to assess the Group’s and
Company’s position, performance, business model and strategy;
The section of the Annual Report that describes the review of effectiveness of risk management and internal
control systems; and
The section of the Annual Report describing the work of the Audit Committee.
We have nothing to report in respect of our responsibility to report when the directors’ statement relating to the
Company’s compliance with the Code does not properly disclose a departure from a relevant provision of the Code
specified under the Listing Rules for review by the auditors.
370
Responsibilities for the financial statements and the audit
Responsibilities of the directors for the financial statements
As explained more fully in the Statement of Directors’ Responsibilities set out on pages 39-40, the directors are
responsible for the preparation of the financial statements in accordance with the applicable framework and for
being satisfied that they give a true and fair view.
The directors are also responsible for such internal control as they determine is necessary to enable the
preparation of financial statements that are free from material misstatement, whether due to fraud or error.
In preparing the financial statements, the directors are responsible for assessing the Group’s and the Company’s
ability to continue as a going concern, disclosing as applicable, matters related to going concern and using the
going concern basis of accounting unless the directors either intend to liquidate the Group or the Company or to
cease operations, or have no realistic alternative but to do so.
Auditors’ responsibilities for the audit of the financial statements
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from
material misstatement, whether due to fraud or error, and to issue an auditors’ report that includes our opinion.
Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance
with ISAs (Ireland) will always detect a material misstatement when it exists. Misstatements can arise from fraud
or error and are considered material if, individually or in the aggregate, they could reasonably be expected to
influence the economic decisions of users taken on the basis of these financial statements.
Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures
in line with our responsibilities, outlined above, to detect material misstatements in respect of irregularities,
including fraud. The extent to which our procedures are capable of detecting irregularities, including fraud, is
detailed below.
Based on our understanding of the Group and industry, we identified that the principal risks of non-compliance
with laws and regulations related to breaches of banking laws and regulations, and we considered the extent to
which non-compliance might have a material effect on the financial statements. We also considered those laws
and regulations that have a direct impact on the preparation of the financial statements such as the Companies
Act 2014 and relevant tax legislation. We evaluated management’s incentives and opportunities for fraudulent
manipulation of the financial statements (including the risk of override of controls) and determined that the
principal risks were related to the potential for management bias through judgements and assumptions in
significant accounting estimates and manual journal entries being recorded in order to affect reported
performance.
Audit procedures performed by the engagement team included:
Enquiries of management as to any known or suspected instances of non-compliance with laws and
regulations or fraud;
Inspection of relevant reports presented to and minutes of meetings of the board of directors and of its
principal committees;
Inspection of key regulatory correspondence;
Challenging assumptions and judgements made by management in their significant accounting estimates,
particularly in relation to the key audit matters;
Incorporating an element of unpredictability into the nature, timing and/or extent of our testing; and
Applying risk-based criteria to journal entries posted in the audit period to determine journal entries for
testing purposes.
There are inherent limitations in the audit procedures described above. We are less likely to become aware of
instances of non-compliance with laws and regulations that are not closely related to events and transactions
reflected in the financial statements. Also, the risk of not detecting a material misstatement due to fraud is higher
than the risk of not detecting one resulting from error, as fraud may involve deliberate concealment by, for
example, forgery or intentional misrepresentations, or through collusion.
Our audit testing might include testing complete populations of certain transactions and balances, possibly using
data auditing techniques. However, it typically involves selecting a limited number of items for testing, rather than
testing complete populations. We will often seek to target particular items for testing based on their size or risk
characteristics. In other cases, we will use audit sampling to enable us to draw a conclusion about the population
from which the sample is selected.
Consolidated Financial Statements 2024
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Consolidated Financial Statements
for the year ended 31 December 2024
Contents
Page Page
Consolidated Income Statement 374
Consolidated Statement of Comprehensive Income
375
Consolidated Balance Sheet 376
Consolidated Statement of Changes in Equity
377
Consolidated Statement of Cash Flows 379
Notes to the Consolidated Financial Statements
1. Corporate information 381
2. Summary of accounting policies 381
2.1 Basis of preparation 381
2.2 Accounting policies and changes in accounting
policies and disclosures 382
2.3 Standards and Interpretations that are issued but
not yet effective 383
2.4 Basis of consolidation 384
2.5 Foreign currency translation
385
2.6 Segment reporting
385
2.7 Turnover 386
2.8 Revenue from contracts with customers 386
2.9 Recognition of interest income/expense and
income/expense similar to interest 388
2.10 Employee benefits 389
2.11 Tax 389
2.12 Financial instruments - initial recognition 390
2.13 Classification and measurement of financial assets
and financial liabilities 391
2.14 Reclassification of financial assets and liabilities 396
2.15 Derecognition of financial assets and financial
liabilities 396
2.16 Modification of financial assets 396
2.17 Impairment of financial assets
397
2.18 Write-offs 404
2.19 Financial guarantees, letters of credit and undrawn
loan commitments
405
2.20 Offsetting financial instruments
405
2.21 Hedge accounting
405
2.22 Cash and cash equivalents 406
2.23 Insurance business 406
2.24 Repurchase and reverse repurchase agreements 410
2.25 Leases 410
2.26 Property and equipment 412
2.27 Investment properties 412
2.28 Stock of property 413
2.29 Non-current assets held for sale and discontinued
operations 413
2.30 Intangible assets 414
2.31 Share capital 414
2.32 Share-based compensation plans
415
2.33 Other equity instruments
415
2.34 Treasury shares
415
2.35 Dividends on ordinary shares
415
2.36 Provisions for pending litigation, claims, regulatory
and other matters 416
2.37 Business combinations 416
3. Going concern 416
4. Economic and geopolitical environment
417
5. Significant and other judgements, estimates and
assumptions
417
6. Segmental analysis 430
7. Interest income and income similar to interest income
437
8. Interest expense and expense similar to interest expense 438
9. Fee and commission income and expense 438
10. Net foreign exchange gains 439
11. Net gains on financial instruments 439
12. Net insurance result 440
13. Other income 442
14. Staff costs 443
15. Other operating expenses 451
16. Credit losses on financial assets and impairment net of
reversals on non-financial assets 453
17. Income tax 454
18. Earnings per share
457
19. Cash, balances with central banks and loans and advances
to banks
457
20. Investments 458
21. Derivative financial instruments 463
22. Fair value measurement 468
23. Loans and advances to customers 476
24. Life insurance business assets attributable to
policyholders 478
25. Property and equipment 480
26. Intangible assets 481
27. Stock of property 482
28. Prepayments, accrued income and other assets 483
29. Funding from central banks 484
30. Customer deposits
485
31. Insurance and reinsurance contracts 486
32. Debt securities in issue and Subordinated liabilities 488
33. Accruals, deferred income, other liabilities and other
provisions 490
34. Share capital 490
35. Distributions 492
36. Retained earnings 492
37. Fiduciary transactions 493
38. Provisions for pending litigation, claims, regulatory and
other matters 493
39. Contingent liabilities and commitments
497
40. Additional information on cash flow statement 498
41. Cash and cash equivalents 499
42. Leases 499
43. Analysis of assets and liabilities by expected maturity 501
44. Risk management - Credit risk 502
45. Risk management - Market risk 529
46. Risk management - Liquidity and funding risk 536
47. Risk management - Insurance risk 544
48. Capital management 546
49. Related party transactions 548
50. Group companies 556
51. Investments in associates and joint venture 558
52. Offsetting financial assets and liabilities 558
53. Country by country reporting 560
54. Events after the reporting period 561
373
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Consolidated Income Statement
for the year ended 31 December 2024
2024 2023
Notes €000 €000
Interest income
7
999,920 930,877
Income similar to interest income
7
10,163 12,792
Interest expense 8 (187,330) (150,159)
Expense similar to interest expense
8
(1,289) (1,293)
Net interest income 821,464 792,217
Fee and commission income 9 184,418 188,343
Fee and commission expense 9 (7,475) (7,320)
Net foreign exchange gains 10 27,285 28,588
Net gains on financial instruments 11 10,672 12,780
Net (losses)/gains on derecognition of financial assets measured at amortised cost (13) 6,361
Net insurance finance income/(expense) and net reinsurance finance income/(expense) 12 (3,907) 960
Net insurance service result 12 76,791 73,528
Net reinsurance service result 12 (26,693) (21,000)
Net (losses)/gains from revaluation and disposal of investment properties (1,430) 1,043
Net gains on disposal of stock of property
27
216 8,972
Other income
13
14,381 18,337
Total operating income 1,095,709 1,102,809
Staff costs 14 (203,062) (192,266)
Special levy on deposits and other levies/contributions
15
(39,115) (42,380)
Provisions for pending litigation, claims, regulatory and other matters (net of reversals) 38 (11,775) (28,464)
Other operating expenses
15
(163,649) (151,093)
Operating profit before credit losses and impairment 678,108 688,606
Credit losses on financial assets 16 (31,797) (79,830)
Impairment net of reversals on non-financial assets 16
(56,040) (46,852)
Profit before tax
590,271 561,924
Income tax
17
(81,128) (72,980)
Profit after tax for the year
509,143 488,944
Attributable to:
Owners of the Company
508,188 487,207
Non-controlling interests
955 1,737
Profit for the year
509,143 488,944
Basic profit per share attributable to the owners of the Company (€ cent)
18
114.4 109.2
Diluted profit per share attributable to the owners of the Company (€ cent)
18
114.0 109.0
374
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Consolidated Statement of Comprehensive Income
for the year ended 31 December 2024
2024 2023
Notes €000 €000
Profit for the year
509,143 488,944
Other comprehensive income (OCI)
OCI that may be reclassified in the consolidated income statement
in subsequent periods
(5,011) 2,975
Fair value reserve (debt instruments)
(5,028) 3,069
Net (losses)/gains on investments in debt instruments measured at fair
value through OCI (FVOCI)
(5,028) 3,401
Transfer to the consolidated income statement on disposal
- (332)
Foreign currency translation reserve
17 (94)
Profit/(loss) on translation of net investments in foreign subsidiaries
17 (81)
Loss on hedging of net investments in foreign subsidiaries
21
- (13)
OCI not to be reclassified in the consolidated income statement in
subsequent periods
1,428 10,198
Fair value reserve (equity instruments)
1,070 (712)
Net gains/(losses) on investments in equity instruments designated at FVOCI
1,070 (712)
Property revaluation reserve
542 10,290
Net fair value gains before tax
25
522 13,524
Deferred tax credit/(charge)
17
20 (3,234)
Actuarial (losses)/gains on defined benefit plans
(184) 620
Remeasurement (losses)/gains on defined benefit plans
14
(184) 620
Other comprehensive (loss)/income for the year net of taxation
(3,583) 13,173
Total comprehensive income for the year
505,560 502,117
Attributable to:
Owners of the Company
504,627 500,156
Non-controlling interests
933 1,961
Total comprehensive income for the year
505,560 502,117
375
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Consolidated Balance Sheet
as at 31 December 2024
2024 2023
Assets
Notes €000 €000
Cash and balances with central banks 19 7,600,726 9,614,502
Loans and advances to banks 19 820,574 384,802
Reverse repurchase agreements 44.11 1,010,170 403,199
Derivative financial assets 21 95,273 51,055
Investments at FVPL 20 136,629 135,275
Investments at FVOCI 20 416,077 443,420
Investments at amortised cost 20 3,805,637 3,116,714
Loans and advances to customers 23 10,114,394 9,821,788
Life insurance business assets attributable to policyholders 24 772,757 649,212
Prepayments, accrued income and other assets 28 479,199 584,919
Stock of property
27
648,757 826,115
Investment properties 22 36,251 62,105
Deferred tax assets
17
166,844 201,268
Property and equipment
25
307,414 285,568
Intangible assets 26 49,747 48,635
Non-current assets and disposal groups held for sale
23
23,143 -
Total assets
26,483,592 26,628,577
Liabilities
Deposits by banks 364,231 471,556
Funding from central banks 29 - 2,043,868
Derivative financial liabilities 21 4,664 17,980
Customer deposits 30 20,519,276 19,336,915
Changes in the fair value of hedged items in portfolio hedges of interest rate risk 21 44,074 -
Insurance contract liabilities 31 743,684 658,424
Accruals, deferred income, other liabilities and other provisions 33 556,459 469,265
Provisions for pending litigation, claims, regulatory and other matters 38 92,620 131,503
Debt securities in issue 32 989,435 671,632
Subordinated liabilities 32 307,138 306,787
Deferred tax liabilities
17
31,943 32,306
Total liabilities
23,653,524 24,140,236
Equity
Share capital 34 44,050 44,620
Share premium 34 594,358 594,358
Revaluation and other reserves 86,139 89,920
Retained earnings
36
1,865,327 1,518,182
Equity attributable to the owners of the Company
2,589,874
2,247,080
Other equity instruments 34 220,000 220,000
Non-controlling interests
20,194 21,261
Total equity
2,830,068 2,488,341
Total liabilities and equity
26,483,592 26,628,577
376
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Consolidated Statement of Changes in Equity
for the year ended 31 December 2024
Attributable to the owners of the Company
Share
capital
(Note 34)
Share
premium
(Note 34)
Capital
redemption
reserve
(Note 34)
Treasury
shares
(Note 34)
Other
capital
reserves
(Note 14)
Retained
earnings
(Note 36)
Property
revaluation
reserve
Financial
instruments
fair value
reserve
Foreign
currency
translation
reserve
Total
Other equity
instruments
(Note 34)
Non-
controlling
interests
Total
equity
€000 €000 €000 €000 €000 €000 €000 €000 €000 €000 €000 €000 €000
1 January 2024
44,620 594,358 - (21,463) 917 1,518,182 84,239 9,553 16,674 2,247,080 220,000 21,261 2,488,341
Profit for the year - - - - - 508,188 - - - 508,188 - 955 509,143
Other comprehensive (loss)/income after tax for
the year
- - - - - (184) 564 (3,958) 17 (3,561) - (22) (3,583)
Total comprehensive income/(loss) after tax for the
year
- - - - - 508,004 564 (3,958) 17 504,627 - 933 505,560
Dividends (Note 35) - - - - - (111,550) - - - ( 111,550) - - (111,550)
Share-based benefits - cost (Note 14) - - - - 932 - - - - 932 - - 932
Payment of coupon to AT1 holders (Note 34) - - - - - (26,125) - - - (26,125) - - (26,125)
Share buyback-repurchase and cancellation of
shares (Note 34)
(570) - 570 - - (25,090) - - - (25,090) - - (25,090)
Dividends paid to non-controlling interest - - - - - - - - - - - (2,000) (2,000)
Transfer to retained earnings
- - - - - 1,906 66 (1,972) - - - - -
31 December 2024
44,050 594,358 570 (21,463) 1,849 1,865,327 84,869 3,623 16,691 2,589,874 220,000 20,194 2,830,068
377
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Consolidated Statement of Changes in Equity
for the year ended 31 December 2024
Attributable to the owners of the Company
Share
capital
(Note 34)
Share
premium
(Note 34)
Treasury
shares
(Note 34)
Other
capital
reserves
(Note 14)
Retained
earnings
(Note 36)
Property
revaluation
reserve
Financial
instruments
fair value
reserve
Foreign
currency
translation
reserve
Total
Other
equity
instruments
(Note 34)
Non-
controlling
interests
Total
equity
€000 €000 €000 €000 €000 €000 €000 €000 €000 €000 €000 €000
1 January 2023
44,620 594,358 (21,463) 322 1,090,349 74,170 7,142 16,768 1,806,266 220,000 22,300 2,048,566
Profit for the year - - - - 487,207 - - - 487,207 - 1,737 488,944
Other comprehensive income/(loss) after tax for the year
- - - - 620 10,066 2,357 (94) 12,949 - 224 13,173
Total comprehensive income/(loss) after tax for the year
- - - - 487,827 10,066 2,357 (94) 500,156 - 1,961 502,117
Shared-based benefits-cost (Note 14) - - - 595 - - - - 595 - - 595
Dividends (Note 35) - - - - (22,310) - - - (22,310) - - (22,310)
Payment of coupon to AT1 holders (Note 34) - - - - (27,339) - - - (27,339) - - (27,339)
Dividends paid to non-controlling interests - - - - - - - - - - (3,000) (3,000)
Issue of other equity instruments (Note 34) - - - - (3,530) - - - (3,530) 220,000 - 216,470
Repurchase of other equity instruments (Note 34) - - - - (6,820) - - - (6,820) (220,000) - (226,820)
Transfers to the consolidated income statement - - - - - 62 - - 62 - - 62
Transfers to retained earnings
- - - - 5 (59) 54 - - - - -
31 December 2023
44,620 594,358 (21,463) 917 1,518,182 84,239 9,553 16,674 2,247,080 220,000 21,261 2,488,341
378
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Consolidated Statement of Cash Flows
for the year ended 31 December 2024
2024 2023
Note €000 €000
Profit before tax 590,271 561,924
Adjustments for:
Depreciation of property and equipment and amortisation of intangible assets 36,171 34,253
Impairment net of reversals on non-financial assets
56,040 46,852
Credit losses on financial assets 31,797 79,830
Net gains on derecognition of financial assets measured at amortised cost 13 (6,361)
Amortisation of discounts/premiums and interest on debt securities (102,975) (64,185)
Dividend income (183) (856)
Net loss on disposal of investment in debt securities measured at FVOCI - 438
Loss/(gain) from revaluation of financial instruments designated as fair value hedges 40,312 (1,655)
Interest on subordinated liabilities and debt securities in issue 64,755 39,854
Interest on reverse repurchase agreements (27,012) (3,219)
Interest on funding from central banks 21,842 67,194
Share-based benefits cost 14 932 595
Net gains on disposal of stock of property and investment properties (1,225) (11,400)
Profit on sale and write offs of property and equipment and intangible assets (28) (53)
Interest expense on lease liability 493 1,453
Premium tax included in net insurance service result as directly attributable expense 2,558 2,222
Net losses from revaluation of investment properties 2,439 1,385
Net exchange differences
(18,136) 7,926
698,064 756,197
Change in:
Loans and advances to banks
(430,577) (30,478)
Deposits by banks
(107,325) (36,102)
Obligatory balances with central banks
(58,523) 55,358
Balances with central banks for ancillary services
(47,390) -
Customer deposits
1,182,361 338,596
Life insurance business assets attributable to policyholders and Insurance contract liabilities
(38,285) (46,448)
Loans and advances to customers
(379,509) 48,568
Prepayments, accrued income and other assets
91,854 65,668
Provisions for pending litigation, claims, regulatory and other matters
(38,883) 3,129
Accruals, deferred income, other liabilities and other provisions
65,732 59,878
Derivative financial instruments
(57,534) (1,091)
Investments measured at FVPL
(1,354) 54,934
Stock of property
152,450 132,979
1,031,081 1,401,188
Tax paid
(28,547) (20,142)
Net cash from operating activities
1,002,534 1,381,046
Cash flows from investing activities
Purchases of debt securities, treasury bills and equity securities
(1,433,813) (1,557,117)
Purchase of reverse repurchase agreements
(600,000) (400,000)
Proceeds on disposal/redemption of investments in debt and equity securities
834,618 555,666
Interest received from debt securities
66,125 36,334
Interest received from reverse repurchase agreements
20,032 -
Dividend income from equity securities
183 856
Payment for purchase of Velocity 2 - (3,649)
Purchases of property and equipment
25
(21,055) (7,454)
Additions to intangible assets
26
(19,736) (14,949)
Proceeds on disposal of property and equipment and intangible assets
44 77
Proceeds on disposal of investment properties
24,622 9,924
Net cash used in investing activities
(1,128,980) (1,380,312)
379
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Consolidated Statement of Cash Flows
for the year ended 31 December 2024
2024 2023
Note €000 €000
Cash flow from financing activities
Payment of coupon to AT1 holders 34 (26,125) (27,339)
Issue of other equity instruments (net of transaction costs) 34 - 216,470
Repurchase of other equity instruments 34 - (226,820)
Share buyback-repurchase of shares 34 (25,090) -
Repayment of funding from central banks (2,065,710) -
Proceeds from the issue of debt securities in issue (net of transaction costs) 297,767 347,689
Dividend paid on ordinary shares
(103,943) (20,345)
Interest on subordinated liabilities
(19,875) (19,875)
Interest on debt securities in issue
(33,313) (7,500)
Principal elements of lease payments
(9,741) (7,846)
Dividend paid by subsidiaries to non-controlling interests
(2,000) (3,000)
Net cash (used in)/from financing activities
(1,988,030) 251,434
Net (decrease)/increase in cash and cash equivalents
(2,114,476) 252,168
Cash and cash equivalents 1 January
9,838,321 9,586,153
Cash and cash equivalents 31 December
41
7,723,845 9,838,321
Additional information on the cash flow statement is provided in Note 40.
380
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
1. Corporate information
Bank of Cyprus Holdings Public Limited Company (the 'Company') was incorporated in Ireland on 11 July
2016, as a public limited company under company number 585903 in accordance with the provisions of the
Companies Act 2014 of Ireland (Companies Act 2014). Its registered office is 10 Earlsfort Terrace, Dublin 2,
D02 T380, Ireland. The Company is domiciled in Ireland and is tax resident in Cyprus.
Bank of Cyprus Holdings Public Limited Company is the holding company of Bank of Cyprus Public Company
Limited ('BOC PCL' or the 'Bank') with principal place of business in Cyprus. The Bank of Cyprus Holdings
Group (the 'Group') comprises the Company, its subsidiary, BOC PCL, and the subsidiaries of BOC PCL. Bank
of Cyprus Holdings Public Limited Company is the ultimate parent company of the Group.
The principal activities of BOC PCL and its subsidiary companies (the 'BOC Group') involve the provision of
banking services, financial services, insurance services and the management and disposal of property
predominately acquired in exchange of debt.
BOC PCL is a significant credit institution for the purposes of the SSM Regulation and has been designated
by the CBC as an 'Other Systemically Important Institution' (O-SII). The Group is subject to joint
supervision by the ECB and the CBC for the purposes of its prudential requirements.
The shares of the Company are listed and trading on the Cyprus Stock Exchange (CSE) and from 23
September 2024 the shares of the Company are also listed and trading on the Athens Stock Exchange
(ATHEX). During the year until 19 September 2024 the shares of the Company were also listed and trading
on London Stock Exchange (LSE). On 19 September 2024, the Company's shares were delisted and trading
was suspended from the LSE.
Consolidated Financial Statements
The Consolidated Financial Statements of the Company for the year ended 31 December 2024 (the
Consolidated Financial Statements) were authorised for issue by a resolution of the Board of Directors on 26
March 2025.
The statutory financial statements prepared in accordance with ESEF are published on the Group's website
www.bankofcyprus.com (Group/Investor Relations/Financial Results).
2. Summary of accounting policies
2.1 Basis of preparation
The Consolidated Financial Statements have been prepared on a historical cost basis, except for properties
held for own use and investment properties, investments at fair value through other comprehensive income
(FVOCI), financial assets (including loans and advances to customers and investments) at fair value through
profit or loss (FVPL) and derivative financial assets and derivative financial liabilities that have been
measured at fair value, non-current assets held for sale measured at fair value less costs to sell and stock of
property measured at net realisable value where this is lower than cost. The carrying values of recognised
assets and liabilities that are hedged items in fair value hedges, and otherwise carried at cost, are adjusted
to record changes in fair value attributable to the risks that are being hedged.
Statement of compliance
The Consolidated Financial Statements have been prepared in accordance with International Financial
Reporting Standards (IFRSs) as adopted by the European Union (EU) and with those parts of the Companies
Act 2014 applicable to companies reporting under IFRSs.
Presentation of the Consolidated Financial Statements
The Consolidated Financial Statements are presented in Euro (€) and all amounts are rounded to the
nearest thousand, except where otherwise indicated. A comma is used to separate thousands and a dot is
used to separate decimals.
The Group presents its balance sheet broadly in order of liquidity. An analysis regarding expected recovery
or settlement of assets and liabilities within twelve months after the balance sheet date and more than
twelve months after the balance sheet date is presented in Note 43.
381
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.1 Basis of preparation (continued)
Comparative information
Comparative information was restated following a change in the presentation of segmental analysis as
detailed in Note 6. This change led to a respective restatement in Notes 14, 23, 30, 44.2, 44.3 and 44.5
where analysis by business line is presented. The relevant tables are identified as restated.
The restatements did not have an impact on the results for the year or equity of the Group.
Change in presentation
The Group has changed the presentation of the interest component of fair value hedging derivatives used in
accounting hedges to more appropriately reflect the impact of the accounting hedges. As a result the net
interest income/expense on qualifying hedge derivatives designated as fair value hedges, is now presented
within ‘Interest income’ where the derivative is used to hedge an asset and as ‘Interest expense’ where the
derivative is used to hedge a liability, and is presented together with the interest component of the
respective hedged asset and hedged liability. This was previously presented in 'Income similar to interest
income' and 'Expense similar to interest expense'. The comparative amounts for 2023 have been
represented.
2.2 Accounting policies and changes in accounting policies and disclosures
The Consolidated Financial Statements contain a summary of the accounting policies adopted in the
preparation of the Consolidated Financial Statements.
The accounting policies adopted are consistent with those of the previous year, except for macro fair value
hedging as explained below in Note 2.21, which was applied in 2024. The adoption of new and amended
standards and interpretations that became effective on or after 1 January 2024 did not have an impact on
the financial statements as explained in Note 2.2.1.
2.2.1 New and amended standards and interpretations
The Group applied for the first time certain standards and amendments, which are effective for annual
periods beginning on or after 1 January 2024 and which are explained below. The Group has not early
adopted any other standard, interpretation or amendment that has been issued but is not yet effective.
IAS 7 Statement of Cash Flows and IFRS 7 Financial Instruments: Disclosures: Supplier Finance
Arrangements (amendments)
These amendments require the disclosures of an entity’s supplier finance arrangements that would enable
the users of financial statements to assess the effects of those arrangements on the entity’s liabilities and
cash flows and on the entity’s exposure to liquidity risk, thus enhancing the transparency of the supplier
finance arrangements. The amendments did not affect recognition or measurement principles. These
amendments did not have an impact on the financial position and results of the Group during the year
ended 31 December 2024.
IFRS 16 Leases: Lease Liability in a Sale and Leaseback (amendments)
The amendment to IFRS 16 Leases specifies the requirements that a seller-lessee uses in measuring the
lease liability arising in a sale and leaseback transaction, to ensure the seller-lessee does not recognise any
amount of the gain or loss that relates to the right of use it retains. A sale and leaseback transaction
involves the transfer of an asset by an entity (the seller-lessee) to another entity (the buyer-lessor) and the
leaseback of the same asset by the seller-lessee. The amendment did not have an impact on the financial
position and results of the Group during the year ended 31 December 2024.
IAS 1 Presentation of Financial Statements: classification of Liabilities as Current or Non-current
(amendments)
The IASB issued amendments to IAS 1 Presentation of Financial Statements to specify the requirements for
classifying liabilities as current or non-current. The amendments clarify: (a) what is meant by a right to
defer settlement, (b) that a right to defer must exist at the end of the reporting period and (c) that
classification is unaffected by the likelihood that an entity will exercise its deferral right. Terms of a liability
that could, at the option of the counterparty, result in its settlement by the transfer of the entity’s own
equity instruments do not affect its classification as current or non-current if, the entity classifies the option
as an equity instrument, recognising it separately from the liability as an equity component of a compound
financial instrument. These amendments did not have an impact on the financial position and results of the
Group during the year ended 31 December 2024.
382
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.3 Standards and Interpretations that are issued but not yet effective
2.3.1 Standards and Interpretations issued by the IASB and adopted by the EU
IAS 21 The Effects of Changes in Foreign Exchange Rates: Lack of Exchangeability (amendments)
These amendments help entities assess exchangeability between two currencies and determine the spot
exchange rate, when exchangeability is lacking. An entity is impacted by the amendments when it has a
transaction or an operation in a foreign currency that is not exchangeable into another currency at a
measurement date for a specified purpose. The amendments to IAS 21 do not provide detailed
requirements on how to estimate the spot exchange rate. Instead, they set out a framework under which an
entity can determine the spot exchange rate at the measurement date. When applying the new
requirements, it is not permitted to restate comparative information. Rather, it is required to translate the
affected amounts at estimated spot exchange rates at the date of initial application, with an adjustment to
retained earnings or to the reserve for cumulative translation differences. The amendments will be effective
for annual reporting periods beginning on or after 1 January 2025. Earlier application is permitted. The
Group does not expect these amendments to have a material impact on its results and financial position.
2.3.2 Standards and Interpretations issued by the IASB but not yet adopted by the EU
IFRS 18 Presentation and Disclosure in Financial Statements (new standard)
The new standard on presentation and disclosure in financial statements focuses on updates to the
statement of profit or loss. The key new concepts introduced in IFRS 18 relate to the structure of the
statement of profit or loss, required disclosures in the financial statements for certain profit or loss
performance measures that are reported outside an entity’s financial statements (that is, management-
defined performance measures) and enhanced principles on aggregation and disaggregation which apply to
the primary financial statements and notes in general. IFRS 18 will not impact the recognition or
measurement of items in the financial statements, but it might change what an entity reports as its
‘operating profit or loss’. IFRS 18 will apply for reporting periods beginning on or after 1 January 2027 and
will also apply to comparative information. The Group does not expect these amendments to have an
impact on its results and financial position; however, presentational changes and additional disclosures may
be required upon adoption.
IFRS 19 Subsidiaries without Public Accountability: Disclosures (new standard)
The IASB issued a new accounting standard for subsidiaries. IFRS 19 Subsidiaries without Public
Accountability will enable subsidiaries to keep only one set of accounting records in order to meet the needs
of both their parent company and the users of their financial statements. In addition, the IFRS 19 will
permit reduced disclosures better suited to the needs of the users of the financial statements while still
maintaining the usefulness of the information. The new standard will be effective for annual periods
beginning on or after 1 January 2027. The new standard does not apply to the financial statements of the
Group.
IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures (amendments)
The IASB issued targeted amendments to report the financial effects of nature-dependent electricity
contracts, which are often structured as power purchase agreements (PPAs). The amendments include
clarifying the application of the ‘own-use’ requirements, permitting hedge accounting if these contracts are
used as hedging instruments; and adding new disclosure requirements to enable investors to understand
the effect of these contracts on a company’s financial performance and cash flows. The amendments will be
effective for annual periods beginning on or after 1 January 2026. The Group does not expect these
amendments to have a material impact on its results and financial position.
383
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.3 Standards and Interpretations that are issued but not yet effective (continued)
2.3.2 Standards and Interpretations issued by the IASB but not yet adopted by the EU
(continued)
Annual Improvements to IFRS Accounting Standards — Volume 11
The amendments contained in the Annual Improvements relate to:
(i) IFRS 1 First-time Adoption of International Financial Reporting Standards - Hedge Accounting by
a First-time Adopter
(ii) IFRS 7 Financial Instruments: Disclosures and its accompanying Guidance on implementing IFRS
7
(iii) IFRS 9 Financial Instruments - Derecognition of lease liabilities and Transaction price
(iv) IFRS 10 Consolidated Financial Statements - Determination of a ‘de facto agent’
(v) IAS 7 Statement of Cash Flows - Cost Method.
These amendments will be effective for annual reporting periods beginning on or after 1 January 2026.
Earlier application is permitted. The Group will be assessing the impact that these amendments might have
on its results and financial position.
IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures - Classification and
Measurement of financial Instruments (amendments)
The IASB issued amendments to IFRS 9 and IFRS 7. The amendments: (a) clarify the date of recognition
and derecognition of some financial assets and liabilities, with a new exception for some financial liabilities
settled through an electronic cash transfer system, (b) add further guidance for assessing whether a
financial asset meets the solely payments of principal and interest (SPPI) criterion, (c) add new disclosures
for certain instruments with contractual terms that can change cash flows, (d) update the disclosures for
equity instruments designated at fair value through other comprehensive income (FVOCI). These
amendments to IFRS 9 and IFRS 7 will be effective for annual reporting periods beginning on or after 1
January 2026. Earlier application is permitted. The Group will be assessing the impact that these
amendments might have on its results and financial position.
2.4 Basis of consolidation
The Consolidated Financial Statements comprise the Consolidated Financial Statements of the Group as at
and for the year ended 31 December 2024. The financial statements of the subsidiaries are prepared as of
the same reporting date as that of the Company, using consistent accounting policies.
Subsidiaries are fully consolidated from the date on which control is transferred to the Group. Specifically,
the Group controls an investee only if the Group has:
i. power over an investee (i.e. existing rights that give it the current ability to direct the relevant
activities of the investee)
ii. exposure, or rights, to variable returns from its involvement with the investee
iii. the ability to use its power over the investee to affect its returns.
Generally, there is a presumption that a majority of voting rights results in control. To support this
presumption and in cases the Group has less than a majority of the voting rights of an investee, the Group
considers all relevant facts and circumstances in assessing whether it has power over an investee including
any contractual arrangements with the other vote holders, rights arising from other contractual
arrangements, and the Group’s voting and potential voting rights.
The Group re-assesses whether or not it controls an investee if facts indicate that there are changes to any
of the three elements of control.
Assets, liabilities, income and expenses of subsidiaries acquired or disposed of during the year are included
in the Consolidated Financial Statements from the date of acquisition or up to the date of disposal,
respectively. Profit or loss and each component of other comprehensive income (OCI) are attributed to the
equity holders of the parent of the Group and to the non-controlling interests, even if this results in the non-
controlling interests having a deficit balance. Non-controlling interests represent the portion of profit or loss
and net assets not held by the Group, directly or indirectly. The non-controlling interests are presented
separately in the consolidated income statement and within equity from the Company owners’ equity.
All intra-group balances and transactions are eliminated on consolidation.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.4 Basis of consolidation (continued)
A change in the ownership interest of a subsidiary, without loss of control, is accounted for as a transaction
between the owners, which affects equity. As a result, no goodwill arises and no gain/loss is recognised in
the consolidated income statement from such transactions. The foreign exchange differences which relate to
the share of non-controlling interests being sold/acquired are reclassified between the foreign currency
reserve and non-controlling interests.
2.5 Foreign currency translation
The Consolidated Financial Statements are presented in Euro (€), which is the functional and presentation
currency of the Company and its operating subsidiaries in Cyprus. Each subsidiary, overseas branch or
overseas subsidiary of the Group determines its own functional currency and items included in the financial
statements of each entity are measured using that functional currency. The Group uses the direct method of
consolidation and on disposal of a foreign operation, the gain or loss that is reclassified to profit or loss
reflects the amount that arises from using this method.
2.5.1 Transactions and balances
Transactions in foreign currencies are recorded using the functional currency rate of exchange ruling at the
date of the transaction.
Monetary assets and liabilities denominated in foreign currencies are translated at the functional currency
rate of exchange ruling at the reporting date. All differences are taken to ‘Net foreign exchange gains’ in the
consolidated income statement, with the exception of differences on foreign currency assets/liabilities that
provide a hedge against the net investments in subsidiaries and overseas branches. These differences are
recognised in other comprehensive income in the ‘Foreign currency translation reserve’ until the disposal or
liquidation of the net investment, at which time the cumulative amount is reclassified to the consolidated
income statement.
Non-monetary items that are measured at historic cost in a foreign currency are translated using the
exchange rates ruling as at the dates of the initial transactions. Non-monetary items measured at fair value
in a foreign currency are translated using the exchange rates ruling at the date when the fair value is
determined. The retranslation of non-monetary assets carried at fair value is reported as part of the fair
value change.
2.5.2 Subsidiary companies and branches
At the reporting date, the assets and liabilities of subsidiaries (including special purpose entities that the
Group consolidates) and branches whose functional currency is other than the Group’s presentation
currency are translated into the Group’s presentation currency at the rate of exchange ruling at the
reporting date, and their income statements are translated using the average exchange rates for the year.
Foreign exchange differences arising on translation are recognised in other comprehensive income in the
‘Foreign currency translation reserve’. On disposal or liquidation of a subsidiary or branch, the cumulative
amount of the foreign exchange differences relating to that particular overseas operation, is reclassified to
the consolidated income statement as part of the profit/loss on disposal/dissolution of subsidiaries.
2.6 Segment reporting
Operating segments are reported in a manner consistent with the internal reporting provided to the chief
operating decision-maker. The chief operating decision-maker is the person or group of persons that
allocate resources to and assess the performance of the operating segments.
The chief operating decision-maker of the Group is the Group Executive Committee.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.7 Turnover
Group turnover is represented by the Total operating income which comprises of net interest income, net
fee and commission income, net foreign exchange gains, net gains/(losses) on financial instruments, net
gains/(losses) on derecognition of financial assets measured at amortised cost, net insurance result, net
gains/(losses) from revaluation and disposal of investment properties, net gains/(losses) on disposal of
stock of property and other income as these are presented in the Consolidated Income Statement and is
presented in Note 6.
2.8 Revenue from contracts with customers
The Group recognises revenue when control of the promised goods or services is transferred to customers
in return of an amount that reflects the consideration to which the Group expects to be entitled in exchange
for those goods or services. The revenue recognition model applies the following five steps:
Step 1: Identify the contract(s) with a customer
Step 2: Identify the performance obligations in the contract
Step 3: Determine the transaction price
Step 4: Allocate the transaction price to the performance obligations in the contract
Step 5: Recognise revenue when (or as) the Group satisfies a performance obligation.
The performance obligation notion in effect represents a promise in a contract with a customer to transfer
to the customer either: (a) a good or service (or a bundle of goods or services) that is distinct; or (b) a
series of distinct goods or services that are substantially the same and that have the same pattern of
transfer to the customer.
Contract balances
A contract asset is the right to consideration in exchange for services transferred to the customer. If the
Group performs by transferring services to a customer before the customer pays consideration or before
payment is due, a contract asset is recognised for the earned consideration that is conditional.
Receivables are recorded where the Group provides services to clients, consideration is due immediately
upon satisfaction of a point in time service or at the end of a prespecified period for an over the time
service. It is the Group’s right to an amount of consideration that is unconditional (i.e. only the passage of
time is required before payment of the consideration is due). The initial recognition and subsequent
measurement of such receivables is disclosed in Notes 2.13 to 2.17.
Contract liabilities relate to payments received from customers where the Group is yet to satisfy its
performance obligation. Contract liabilities are recognised as revenue when the Group performs under the
contract.
Contract assets and receivables are recorded within ‘Prepayments, accrued income and other assets’ and
contract liabilities within ‘Accruals, deferred income, other liabilities and other provisions’ in the
consolidated balance sheet.
2.8.1 Fee and commission income
The Group earns fee income from a diverse range of services it provides to its clients. Fee income can be
divided into two broad categories:
i. fees earned from services that are provided over a certain period of time, such as asset or portfolio
management, custody services and certain advisory services; and
ii. fees earned from point in time services such as executing transactions and brokerage fees (e.g.
securities and derivative execution and clearing).
Over time services
For fees earned from services that are provided over a certain period of time revenue is recognised pro-rata
over the service period, provided the fees are not contingent on successfully meeting specified performance
criteria that are beyond the control of the Group. Costs to fulfil over time services are recorded in the
consolidated income statement immediately, because such services are considered to be a series of services
that are substantially the same from day to day and have the same pattern of transfer.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.8 Revenue from contracts with customers (continued)
2.8.1 Fee and commission income (continued)
Point in time services
For fees earned from providing transaction-type services, revenue is recognised when the service has been
completed, provided such fees are not subject to refund or another contingency beyond the control of the
Group. Incremental costs to fulfil services provided at a point in time are typically incurred and recorded at
the same time as the performance obligation is satisfied and revenue is earned, and are therefore not
recognised as an asset, e.g. brokerage commissions.
Fee and commission income is measured based on consideration specified in a legally enforceable contract
with a customer, excluding amounts such as taxes collected on behalf of third parties. Consideration can
include both fixed and variable amounts. Variable consideration includes refunds, discounts and other
amounts that are contingent on the occurrence or non-occurrence of a future event. Variable consideration
that is contingent on an uncertain event can only be recognised to the extent that it is highly probable that
a significant reversal in the amount of cumulative revenue for a contract will not occur.
In relation to sales of services for card processing activities the Group acts as an agent and therefore
income is recognised on a net basis.
2.8.2 Dividend income
Dividend income is recognised in the consolidated income statement when the Group’s right to receive
payment is established, i.e. upon approval by the general meeting of the shareholders.
2.8.3 Rental income
Rental income from investment properties and stock of property is accounted for on a straight-line basis
over the period of the lease and is recognised in the consolidated income statement in ‘Other income’.
2.8.4 Gains on disposal of investment property
Gains on disposal of investment property are recognised in the consolidated income statement in ‘Net
gains/(losses) from revaluation and disposal of investment properties’ when the buyer accepts delivery and
the control of the property is transferred to the buyer.
2.8.5 Gains on disposal of stock of property
Gains on disposal of stock of property are recognised in the consolidated income statement in 'Net gains on
disposal of stock of property' when the buyer accepts delivery and the control of the property is transferred
to the buyer.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.9 Recognition of interest income/expense and income/expense similar to interest
The Group calculates interest income/expense by applying the effective interest rate (EIR) to the gross
carrying amount of financial assets, unless the asset is credit-impaired. For financial assets and financial
liabilities measured at FVPL which accrue interest, the Group follows the principles of the effective interest
method with the only difference being the treatment of fees that are integral to the financial asset/financial
liabilities. That is, for financial assets and financial liabilities classified at FVPL the fees are recognised as
revenue or expense when the instrument is initially recognised and not as part of the EIR calculation.
When a financial asset becomes credit-impaired and is therefore classified as Stage 3, interest income is
calculated by applying the EIR to the amortised cost of the financial asset, being the gross carrying amount
of the financial asset less any loss allowance. If the financial asset cures and is no longer credit-impaired,
the Group reverts to calculating interest income on the gross carrying amount. In such cases, the Group
unwinds the discount on the expected credit losses (ECL) through the 'Credit losses on financial assets' line
in the consolidated income statement.
Interest income on purchased or originated credit-impaired (POCI) financial assets is recognised using the
credit adjusted effective interest rate (CAEIR) calculated at initial recognition. The CAEIR is applied on the
amortised cost of the financial asset, being the gross carrying amount of the financial asset less any loss
allowance.
Interest income from financial assets at amortised cost and financial assets at FVOCI is presented within the
caption ‘Interest income’, while interest income on financial instruments at FVPL is presented within the
caption ‘Income similar to interest income’ in the consolidated income statement. Interest expense on
financial liabilities at amortised cost is presented within the caption ‘Interest expense’, while interest
expense on financial instruments at FVPL is presented within the caption ‘Expense similar to interest
expense’ in the consolidated income statement. All form part of the ‘Net interest income’.
The effective interest rate method
Interest income and expense are recognised in the consolidated income statement by applying the effective
interest rate (EIR) for all financial instruments measured at amortised cost and debt instruments at FVOCI.
The EIR is the rate that exactly discounts estimated future cash payments or receipts through the expected
life of the financial instrument to the gross carrying amount of the financial asset or the amortised cost of
the financial liability.
The EIR, and therefore the amortised cost of the asset, is calculated by taking into account any discount or
premium on acquisition, fees and costs that are an integral part of the EIR. Fees and incremental costs that
are directly attributable to loans and advances to customers are also deferred and amortised as part of
interest income using the effective interest rate method.
For floating-rate financial instruments, periodic re-estimation of cash flows to reflect the movements in the
market rates of interest also alters the EIR, but when instruments were initially recognised at an amount
equal to the principal, re-estimating the future interest payments does not significantly affect the carrying
amount of the asset or the liability.
The carrying amount of a financial asset or liability is adjusted if the Group revises its estimates of
payments or receipts for reasons other than credit risk. The adjusted carrying amount is calculated based
on the original effective interest rate and the change in carrying amount is recorded in ‘Net gains/(losses)
on financial instruments' for debt securities, or in ‘Changes in expected cash flows’ component of the 'Credit
losses to cover credit risk on loans and advances to customers' for loans and advances to customers
included within 'Credit losses on financial assets'.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.10 Employee benefits
2.10.1 Retirement benefits
The Group operates both defined contribution and defined benefit retirement plans.
Defined contribution plans
The Group recognises obligations in respect of the accounting period in the consolidated income statement.
Any unpaid contributions at the reporting date are included as a liability.
Defined benefit plans
The cost of providing benefits for defined benefit plans is estimated separately for each plan using the
Projected Unit Credit Method of actuarial valuation.
The defined benefit asset or liability comprises the present value of the defined benefit obligations (using a
discount rate based on high quality corporate bonds), reduced by the fair value of plan assets out of which
the obligations are to be settled. Plan assets are assets that are held by a funded plan or qualifying
insurance policies. Any net defined benefit surplus is limited to the present value of available refunds and
reductions in future contributions to the plan. Fair value is based on market price information and in the
case of quoted securities it is the published bid price.
The net charge to the consolidated income statement mainly comprises the service costs and the net
interest on the net defined benefit asset or liability, and is presented in staff costs. Service costs comprise
current service costs, past service costs, gains and losses or curtailments and non-routine settlements. Re-
measurements, comprising actuarial gains and losses, the effect of the asset ceiling (excluding net interest),
and the return on plan assets (excluding net interest), are recognised immediately on the consolidated
balance sheet with a corresponding debit or credit in other comprehensive income. Re-measurements are
not reclassified to profit or loss in subsequent periods.
Actuarial gains and losses comprise experience adjustments (the effects of differences between the previous
actuarial assumptions and what has actually occurred), as well as the effects of changes in actuarial
assumptions.
2.10.2 Short-term employee benefits
Short-term employee benefits, such as salaries and other benefits, are accounted for on an accrual basis
over the period during which employees have provided services. Bonuses are recognised to the extent that
the Group has a legal or constructive obligation to its employees that can be measured reliably.
2.10.3 Exit cost benefits
Exit cost benefits refer to termination benefits and are recognised as an expense at the earlier of when the
Group can no longer withdraw the offer of those benefits and when the Group recognises costs for a
restructuring under IAS 37 Provisions, Contingent Liabilities and Contingent Assets, which includes the
payment of termination benefits.
For termination benefits which become payable as a result of an employee’s decision to accept an offer of
voluntary redundancy, which is not within the scope of IAS 37 Provisions, Contingent Liabilities and
Contingent Assets, the Group recognises the expense at the earlier of when the employee accepts the offer
and when a restriction on the Group’s ability to withdraw the offer takes effect.
2.11 Tax
Current income tax and deferred tax
Tax on income is provided in accordance with the fiscal regulations and rates which apply in the countries
where the Group operates and is recognised as an expense in the period in which the income arises.
Deferred tax is provided using the liability method. Current income tax assets and liabilities are measured
at the amount expected to be recovered from or paid to the tax authorities. Current income tax and
deferred tax relating to items recognised directly in equity is recognised directly in equity.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.11 Tax (continued)
Deferred tax liabilities are recognised for taxable temporary differences between the tax basis of assets and
liabilities and their carrying amounts at the reporting date, which will give rise to taxable amounts in future
periods. Deferred tax liabilities are recognised for taxable temporary differences associated with
investments in subsidiary and associate companies and branches, except where the timing of the reversal of
the temporary differences can be controlled and it is probable that the temporary differences will not
reverse in the foreseeable future.
Deferred tax assets are recognised for deductible temporary differences and carry-forward of unutilised tax
losses to the extent that it is probable that taxable profit will be available, against which the deductible
temporary differences and carry-forward of unutilised tax losses can be utilised. The carrying amount of
deferred tax assets is reviewed at each reporting date and reduced to the extent that it is no longer
probable that sufficient taxable profit will be available to utilise all or part of the deductible temporary
differences or tax losses. Unrecognised deferred tax assets are reassessed at each reporting date and are
recognised to the extent that it has become probable that future taxable profit will allow the deferred tax
asset to be recovered.
Deferred tax assets and liabilities are measured at the amount that is expected to be paid to or recovered
from the tax authorities, after taking into account the tax rates and legislation that have been enacted or
substantially enacted by the reporting date.
The deferred tax assets arising from specific tax losses and which are subject to the Income Tax Law
Amendment 28 (I) of 2019, are accounted for on the same basis as other deferred tax assets and can be
converted into tax credits. These tax losses are converted into 11 equal annual instalments and each
instalment could be claimed as a deductible expense in the determination of the taxable income for the
relevant year. Any amount of the annual instalment not utilised is converted into a tax credit and can be
utilised in the tax year following the tax year to which this tax credit relates to. Any unutilised tax credit in
the relevant year is converted into a receivable from the Cyprus Government. Further details are disclosed
in Note 17.
Current and deferred tax assets and liabilities are offset when they arise from the same tax reporting entity
and relate to the same tax authority and when the legal right to offset exists.
Indirect tax-Value Added Tax (VAT)
Expenses and assets are recognised net of the amount of VAT, except:
i. when the VAT incurred on a purchase of assets or services is not recoverable from the tax
authorities, in which case, the VAT suffered is recognised as part of the cost of acquisition of the
asset or as part of the expense item, as applicable.
ii. when receivables and payables are stated with the amount of VAT charged. The amount of VAT
recoverable from, or payable to the tax authorities, is included as part of receivables or payables in
the consolidated balance sheet.
2.12 Financial instruments - initial recognition
2.12.1 Date of recognition
‘Balances with central banks’, ‘Loans and advances to banks’, ‘Loans and advances to customers’, ‘Deposits
by banks’, ‘Funding from central banks’ and ‘Customer deposits’ are recognised when cash is received by
the Group or advanced to the borrowers. All other financial assets and financial liabilities are initially
recognised on the trade date. Purchases or sales of financial assets, where delivery is required within a time
frame established by regulations or by market convention, are also recognised on the trade date, i.e. the
date that the Group commits to purchase or sell the asset. Derivatives are also recognised on a trade date
basis.
2.12.2 Initial recognition and measurement of financial instruments
The classification of financial assets on initial recognition depends on their contractual terms and the
business model for managing the instruments, as described in Note 2.13.
All financial instruments are measured initially at their fair value plus, in the case of financial assets and
liabilities not measured at FVPL, any directly attributable incremental costs of acquisition or issue.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.12 Financial instruments - initial recognition (continued)
2.12.2 Initial recognition and measurement of financial instruments (continued)
When the fair value of financial instruments at initial recognition differs from the transaction price, the
Group accounts for the Day 1 profit or loss, as described in Note 2.12.3 below.
2.12.3 Day 1 profit or loss
When the transaction price of the instrument differs from the fair value at origination and the fair value is
based on a valuation technique using only inputs observable in market transactions, the Group recognises
the difference between the transaction price and fair value in 'Net gains/(losses) on financial instruments'
caption. In the cases, where the fair value is based on models for which some of the inputs are not
observable, the difference between the transaction price and the fair value is deferred and is only
recognised in profit or loss when the inputs become observable, or when the instrument is derecognised.
2.12.4 Measurement categories of financial assets and financial liabilities
Financial assets are measured either at amortised cost, FVOCI or FVPL.
The Group classifies and measures its derivatives and trading portfolios at FVPL. The Group may designate
financial instruments at FVPL, if doing so eliminates or significantly reduces measurement or recognition
inconsistencies.
Financial liabilities, other than loan commitments and financial guarantees, are measured at amortised cost
or at FVPL when they are held for trading or relate to derivative instruments.
2.13 Classification and measurement of financial assets and financial liabilities
The classification and measurement of financial assets depends on how these are managed as part of the
business models the Group operates and their contractual cash flow characteristics (whether the cash flows
represent solely payments of principal and interest (SPPI)).
Business model assessment
The Group assesses the business model at a portfolio level. The portfolio level is determined at the
aggregation level that reflects how the Group manages its financial assets and the business model is based
on observable factors which include:
i. How the performance of the business model and the financial assets held within that business model
are evaluated and reported to the Group's key management personnel;
ii. The risks that affect the performance of the business model (and the financial assets held within that
business model) and, in particular, the way in which those risks are managed;
iii. How managers of the business are compensated (for example, whether the compensation is based
on the fair value of the assets managed or on the contractual cash flows collected);
iv. The expected frequency, value and timing of sales are also important aspects of the Group’s
assessment.
If cash flows after initial recognition are realised in a way that is different from the Group’s original
expectations, the Group does not change the classification of the remaining financial assets held in that
business model, but incorporates such information when assessing newly originated or newly purchased
financial assets going forward.
Contractual cash flows characteristics assessment (SPPI test)
The Group assesses whether the individual financial assets’ cash flows represent solely payments of
principal and interest on the principal amount outstanding at origination (SPPI test).
For the purposes of this assessment, principal is defined as the fair value of the financial asset on initial
recognition and may change over the life of the financial asset (for example, if there are repayments of
principal or amortisation of the premium/discount).
Interest is defined as consideration for the time value of money, for the credit risk associated with the
principal amount outstanding during a particular period of time and for other basic lending risks and costs
(e.g. liquidity risk and administrative costs), as well as a profit margin.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.13 Classification and measurement of financial assets and financial liabilities (continued)
In assessing whether contractual cash flows are SPPI, the Group applies judgement and considers the terms
that could change the contractual cash flows so that they would not meet the condition for SPPI, and be
inconsistent to a basic lending arrangement, including: (i) contingent and leverage features, (ii) interest
rates which are beyond the control of the Group or variable interest rate consideration, (iii) features that
could modify the time value of money, (iv) prepayment and extension options, (v) non-recourse
arrangements, and (vi) convertibility features.
Where the contractual terms of a financial asset introduce a more than de-minimis exposure to risks or
volatility that are inconsistent with a basic lending arrangement, the related financial asset will be measured
at FVPL.
2.13.1 Derivative financial instruments
Derivatives are recorded at fair value and classified as assets when their fair value is positive and as
liabilities when their fair value is negative. Subsequently, derivatives are measured at fair value.
Revaluations of trading derivatives are included in the consolidated income statement in ‘Net foreign
exchange gains’ in the case of currency derivatives and in ‘Net gains/(losses) on financial instruments’ in
the case of all other derivatives. Interest income and expense for derivatives not in accounting hedges are
included in the ‘Income similar to interest income’ and ‘Expense similar to interest expense’ captions
respectively in the consolidated income statement.
An embedded derivative is a component of a hybrid instrument that also includes a non-derivative host
contract with the effect that some of the cash flows of the combined instrument vary in a way similar to a
stand-alone derivative.
For hybrid contracts where the host contract is a financial asset within the scope of IFRS 9, the classification
and measurement criteria are based on the business model and SPPI assessment as described in the
classification of financial assets section of Note 2.13 and applied to the entire hybrid instrument.
Derivatives embedded in financial liabilities and non-financial host contracts, are treated as separate
derivatives and recorded at fair value if their economic characteristics and risks are not closely related to
those of the host contract, and the host contract is not itself measured at fair value with revaluation
recognised in the consolidated income statement. The embedded derivatives separated from the host are
carried at fair value, with revaluations recognised in ‘Net gains/(losses) on financial instruments' in the
consolidated income statement. The host contract is accounted for in accordance with the relevant
standards.
2.13.2 Financial assets measured at amortised cost
Financial assets are measured at amortised cost if they meet both of the following conditions:
i. The financial asset is held within a business model with the objective to hold financial assets in order
to collect contractual cash flows;
ii. The contractual terms of the financial asset give rise on specified dates to cash flows that are SPPI
on the principal amount outstanding.
This classification relates to cash and balances with central banks, loans and advances to banks, reverse
repurchase agreements, loans and advances to customers that pass the SPPI test, debt securities held
under the ‘Hold to collect’ business model and other financial assets that pass the SPPI test.
After their initial recognition, financial instruments measured at amortised cost are measured at amortised
cost using the effective interest rate method, less allowances for expected credit losses (ECL). Amortised
cost is calculated by taking into account any discount or premium on acquisition and fees that are an
integral part of the effective interest rate. The amortisation is included in ‘Interest income’ in the
consolidated income statement. The losses arising from impairment are recognised in the consolidated
income statement in ‘Credit losses on financial assets'.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.13 Classification and measurement of financial assets and financial liabilities (continued)
2.13.3 Debt instruments measured at FVOCI
Debt instruments are measured at FVOCI if they meet both of the following conditions:
i. The financial asset is held within a business model the objective of which is achieved by both
collecting contractual cash flows and selling financial assets;
ii. The contractual terms of the financial asset give rise on specified dates to cash flows that are SPPI
on the principal amount outstanding.
This classification relates to debt securities held under the ‘Hold to collect and sell’ business model that pass
the SPPI test.
FVOCI debt instruments are subsequently measured at fair value with gains and losses due to changes in
fair value recognised directly in other comprehensive income in the ‘Net gains/(losses) on investments in
debt instruments measured at FVOCI’ caption. Upon derecognition of these instruments, any accumulated
balances in other comprehensive income are reclassified to the consolidated income statement and reported
within ‘Net gains/(losses) on financial instruments' caption. The interest income, foreign exchange
differences and ECL are recognised in the consolidated income statement in the respective lines in the same
manner as for financial assets at amortised cost.
2.13.4 Financial assets or financial liabilities held for trading
Financial assets or financial liabilities held for trading represent assets and liabilities acquired or incurred
principally for the purpose of selling or repurchasing them in the near term and are recognised in the
consolidated balance sheet at fair value. Changes in the fair value are recognised in ‘Net gains/(losses) on
financial instruments' in the consolidated income statement. Interest income and expense are included in
the captions ‘Income similar to interest income’ and ‘Expense similar to interest expense’ respectively in the
consolidated income statement according to the terms of the relevant contract, while dividend income is
recognised in ‘Other income’ when the right to receive payment has been established.
This classification relates to debt and equity instruments that have been acquired principally for the
purposes of sale or repurchase in the near term.
2.13.5 Financial assets or financial liabilities at FVPL
Financial assets and financial liabilities, other than those held for trading, classified in this category are
those that are designated by management on initial recognition or are mandatorily required to be measured
at fair value under IFRS 9.
Management only designates an instrument at FVPL at initial recognition when one of the following criteria
are met:
(a) the designation eliminates or significantly reduces the inconsistency that would otherwise arise
from the measurement of the assets or liabilities or the recognition of gains or losses on them on a
different basis, or
(b) the liabilities are part of a group of financial liabilities or financial assets and financial liabilities
which are managed and their performance is evaluated on a fair value basis, in accordance with a
documented risk management or investment strategy, or
(c) the liabilities contain an embedded derivative, unless the embedded derivative does not
significantly modify the cash flows of the instrument or it is clear, with little or no analysis, that the
embedded derivative could not be separated.
Such designation is determined on an instrument-by-instrument basis.
Assets held under unit-linked insurance contracts, certain non-linked insurance contracts and investment
contracts issued by insurance subsidiaries are designated at FVPL.
Financial assets mandatorily classified at FVPL include certain loans and advances to customers, certain
investment fund holdings and other securities and other assets for which the contractual cash flows do not
meet the SPPI test, or the financial assets are part of a portfolio held within a business model under which
they are managed and their performance is evaluated on a fair value basis.
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Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.13 Classification and measurement of financial assets and financial liabilities (continued)
2.13.5 Financial assets or financial liabilities at FVPL (continued)
Financial assets and financial liabilities at FVPL are recorded in the consolidated balance sheet at fair value.
Changes in the fair value are recognised in ‘Net gains/(losses) on financial instruments' in the consolidated
income statement. Interest income and expense are included in the captions ‘Income similar to interest
income’ and ‘Expense similar to interest expense’ respectively in the consolidated income statement.
Dividend income is recognised in ‘Other income’ in the consolidated income statement when the right to
receive payment has been established.
2.13.6 Equity instruments measured at FVOCI
At initial recognition, the Group can make an irrevocable election to classify an investment in an equity
instrument at FVOCI, when that meets the definition of equity under IAS 32 Financial Instruments:
'Presentation', and is not held for trading. Such classification is determined on an instrument-by-instrument
basis.
Fair value gains and losses on these equity instruments are recognised in other comprehensive income and
are not recycled to profit or loss upon derecognition, but are transferred directly to retained earnings.
Dividends on equity investments are recognised in the consolidated income statement and reported within
‘Other Income’ when the right to receive payment has been established, except when the Group benefits
from such proceeds as a recovery of part of the cost of the instrument, in which case it is recorded in other
comprehensive income. Equity instruments measured at FVOCI are not subject to an impairment
assessment.
2.13.7 Debt securities in issue and Subordinated liabilities
Debt securities in issue and Subordinated liabilities are initially measured at the fair value of the
consideration received, net of any issue costs. They are subsequently measured at amortised cost using the
effective interest rate method, in order to amortise the difference between the cost at inception and the
redemption value, over the period to the earliest date that the Group has the right to redeem those
instruments.
Interest on debt securities in issue and subordinated liabilities is included in ‘Interest expense’ in the
consolidated income statement.
2.13.8 Other financial liabilities
Other financial liabilities include ‘Customer deposits’, ‘Deposits by banks’, ‘Funding from central banks’ and
other financial liabilities.
Financial liabilities are recognised when the Group enters into the contractual provisions of the
arrangements with counterparties, which is generally on trade date, and initially measured at fair value,
which is normally the consideration received, net of directly attributable transaction costs incurred.
Subsequent measurement of other financial liabilities is at amortised cost, using the effective interest
method.
2.13.9 Determination of fair value - Valuation techniques
The following is a description of the determination of fair value for financial instruments which are recorded
at fair value and for financial instruments which are not measured at fair value but for which fair value is
disclosed, using valuation techniques. These incorporate the Group’s estimate of assumptions that a market
participant would make when valuing the instruments.
Derivative financial instruments
Derivative financial instruments valued using a valuation technique with market observable inputs are
mainly interest rate swaps, currency swaps, currency rate options, forward foreign exchange rate contracts
and interest rate collars. The most frequently applied valuation techniques include forward pricing and swap
models, using present value calculations. The models incorporate various inputs, including foreign exchange
spot and forward rates and interest rate curves.
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BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.13 Classification and measurement of financial assets and financial liabilities (continued)
2.13.9 Determination of fair value - Valuation techniques (continued)
Credit Valuation Adjustments (CVA) and Debit Valuation Adjustments (DVA)
The CVA and DVA are incorporated into derivative valuations to reflect the impact on fair value of
counterparty risk and BOC PCL’s own credit quality respectively.
The Group calculates the CVA by applying the PD of the counterparty, conditional on the non-default of the
Group, to the Group’s expected positive exposure to the counterparty and multiplying the result by the loss
expected in the event of default. Conversely, the Group calculates the DVA by applying BOC PCL's PD,
conditional on the non-default of the counterparty, to the expected positive exposure of the counterparty to
the Group and multiplying the result by the loss expected in the event of default.
The expected exposure of derivatives is calculated as per the CRR and takes into account the netting
agreements where they exist. A standard Loss Given Default (LGD) assumption in line with industry norm is
adopted. Alternative LGD assumptions may be adopted when both the nature of the exposure and the
available data support this.
The Group does not hold any significant derivative instruments which are valued using a valuation technique
with significant non-market observable inputs.
Investments at FVPL, investments at FVOCI and investments at amortised cost
Investments which are valued using a valuation technique or pricing models, primarily consist of unquoted
equity securities and debt securities. These assets are valued using valuation models which sometimes only
incorporate market observable data and at other times use both observable and non-observable data. The
rest of the investments are valued using quoted prices in active markets.
Loans and advances to customers
The fair value of loans and advances to customers is based on the present value of expected future cash
flows. Future cash flows have been based on the future expected loss rate per loan portfolio, taking into
account expectations for the credit quality of the borrowers. The discount rate includes components that
capture the risk-free rate per currency, funding cost, servicing cost and the cost of capital, considering the
risk weight of each loan.
Customer deposits
The fair value of customer deposits is determined by calculating the present value of future cash flows. The
discount rate takes into account current market rates and the credit profile of BOC PCL. The fair value of
deposits repayable on demand and deposits protected by the Deposit Protection Guarantee Scheme are
approximated by their carrying values.
Loans and advances to banks
Loans and advances to banks with maturity over one year are discounted using an appropriate risk-free rate
plus the appropriate credit spread. For short-term lending, the fair value is approximated by the carrying
value.
Reverse repurchase agreements
Fair values of reverse repurchase agreements that are held on a non-trading basis are determined by
calculating the present value of future cash flows. The cashflows are discounted using an appropriate risk-
free rate plus the appropriate credit spread.
Cash flows relating to reverse repurchase agreements (including interest received) are presented as
investing activities in the Consolidated Statement of Cash Flows.
Deposits by banks and funding from central banks
Deposits by banks and funding from central banks with maturity over one year are discounted using an
appropriate risk-free rate plus the appropriate credit spread. For short-term funding, the fair value is
approximated by the carrying value.
Debt securities in issue and Subordinated liabilities
Debt securities and subordinated liabilities issuances are traded in an active market with quoted prices.
Further details on the fair value of assets and liabilities are disclosed in Note 22.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.14 Reclassification of financial assets and liabilities
The Group does not reclassify its financial assets subsequent to their initial recognition, apart from
exceptional circumstances in which the Group changes its business model for managing financial assets and
acquires, disposes of, or terminates a business line. Reclassification is applied prospectively from the
reclassification date, which is the first day of the first reporting period following the change in business
model that results in the reclassification. Any previously recognised gains, losses or interest are not
restated.
Financial liabilities are never reclassified.
2.15 Derecognition of financial assets and financial liabilities
2.15.1 Financial assets
A financial asset (or, where applicable, a part of a financial asset or part of a group of similar financial
assets) is derecognised when the contractual rights to the cash flows from the financial asset have expired.
The Group also derecognises a financial asset if it has both transferred the financial asset and the transfer
qualifies for derecognition.
The Group transfers a financial asset if, and only if, either:
i. The Group transfers its contractual rights to receive cash flows from the financial asset; or
ii. The Group retains the rights to the cash flows, but assumes an obligation to pay the received cash
flows in full without material delay to a third party under a ‘pass-through’ arrangement.
A transfer only qualifies for derecognition if either:
i. The Group transfers substantially all the risks and rewards of the asset; or
ii. The Group neither transfers nor retains substantially all the risks and rewards of the asset, but it
transfers control of the asset.
2.15.2 Financial liabilities
A financial liability is derecognised when the obligation under the liability is discharged, cancelled or
expired. Modifications to, and exchanges of, financial liabilities are treated as extinguishments and
derecognised, when the revised terms are substantially different to the original term. The difference
between the carrying amount of the original financial liability and the consideration paid is recognised in
profit or loss.
2.16 Modification of financial assets
The contractual terms of a financial asset may be modified due to various reasons, either due to commercial
renegotiations or as a response to a borrower's financial difficulties (forborne modified loans) with a view to
maximise recovery.
In the event that the terms and conditions of a financial asset are renegotiated or otherwise modified, the
Group considers whether the modification results in derecognition of the existing financial asset and the
recognition of a new financial asset. A derecognition of a financial asset (or part of a financial asset) and a
recognition of a new financial asset would occur where there has been a substantial modification on the
revised terms to the original cash flows.
Judgement is required to assess whether a change in the contractual terms is substantial enough to lead to
derecognition. The Group considers a series of factors of both qualitative and quantitative nature when
making such judgements on a modification in the contractual cash flows, including change in the currency,
change in counterparty, introduction of substantially different terms such as addition of equity conversion
features, changes in the legal framework and other.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.16 Modification of financial assets (continued)
Where the modification does not result in derecognition, the Group recognises a modification gain or loss,
based on the difference between the modified cash flows discounted at the original EIR and the existing
gross carrying value of the financial asset. The financial asset continues to be subject to the same
assessments for significant increase in credit risk relative to initial recognition and credit-impairment. A
modified financial asset will transfer out of Stage 3 if the conditions that led to it being identified as credit-
impaired, as defined in Note 2.17.2, are no longer present. A modified financial asset will transfer out of
Stage 2 when it no longer meets the criteria for significant increase in credit risk such as it satisfies relative
thresholds, which are based on changes in its lifetime probability of default (PD), days past due are not
considered to be forborne, and other considerations. The financial asset continues to be monitored for
significant increases in credit risk and credit impairment.
Where the modification results in derecognition, the new financial asset is classified at amortised cost or
FVOCI and an assessment is performed on whether it should be classified as Stage 1 or POCI for ECL
measurement. For the purposes of assessing significant increases in credit risk, the date of initial
recognition for the new financial asset is the date of the modification.
2.17 Impairment of financial assets
2.17.1 Overview of ECL principle
The Group uses a forward looking ECL model, requiring judgement, estimates and assumptions in
determining the level of ECL. ECL is recorded for all financial assets measured at amortised cost and FVOCI,
lease receivables, loan commitments and financial guarantee contracts. Equity instruments are not subject
to impairment.
At initial recognition, impairment allowance (or provision in the case of commitments and guarantees) is
required for ECL resulting from default events that are possible within the next 12 months (12-month ECL),
unless assets are deemed as POCI whereby the ECL is measured on a lifetime basis. In the event of a
significant increase in credit risk since initial recognition, impairment allowance is required resulting from all
possible default events over the expected life of the financial instrument (lifetime ECL). The Group’s policies
for determining if there has been a significant increase in credit risk are set out in Note 2.17.3.
The Group categorises its financial assets into Stage 1, Stage 2, Stage 3 and POCI for ECL measurement as
described below:
Stage 1: Financial assets which did not have a significant increase in credit risk since initial recognition are
considered to be Stage 1 and 12-month ECL is recognised.
Stage 2: Financial assets which are considered to have experienced a significant increase in credit risk since
initial recognition are considered to be Stage 2 and lifetime ECL is recognised.
Stage 3: Financial assets which are considered to be credit-impaired (refer to Note 2.17.2 on how the Group
defines credit-impaired and default) and lifetime ECL is recognised.
POCI: These are purchased or originated financial assets that are credit-impaired on initial recognition. POCI
assets include loans purchased or originated at a deep discount that reflects incurred credit losses. Changes
in lifetime ECL since initial recognition are recognised until a POCI loan is derecognised.
ECL is recognised in profit or loss with a corresponding ECL allowance reported as a decrease in the carrying
value of financial assets measured at amortised cost on the balance sheet. For financial assets measured at
FVOCI the carrying value is not reduced, but the accumulated amount of ECL allowance is recognised in
OCI. For off-balance sheet instruments, accumulated provisions for ECL are reported in ‘Accruals, deferred
income, other liabilities and other provisions’, except in the case of loan commitments where ECL on the
loan commitment is recognised together with the loss allowance of the relevant on balance-sheet exposure,
as the Group cannot separately identify the ECL on the loan commitment from those on the on-balance
sheet exposure component. ECL for the period is recognised within the consolidated income statement in
'Credit losses on financial assets' and further analysed in Note 16 in ‘Credit losses to cover credit risk on
loans and advances to customers’ for loans and advances to customers and loan commitments and financial
guarantees, and in ‘Credit losses on other financial instruments’ for all other financial instruments.
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BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.17 Impairment of financial assets (continued)
2.17.2 Credit impaired and definition of default
Loans and advances to customers, loan commitments and financial guarantees
The Group considers loans and advances to customers that meet the non-performing exposure (NPE)
definition as per the European Banking Authority (EBA) standards to be in default and hence stage 3 (credit-
impaired). Therefore such loans have ECL calculated on a lifetime basis and are considered to be in default
for credit risk management purposes.
As per the EBA standards and European Central Bank’s (ECB) Guidance to Banks on Non-Performing Loans
(which was published in March 2017), NPEs are defined as those exposures that satisfy one of the following
conditions:
i. The borrower is assessed as unlikely to pay its credit obligations in full without the realisation of the
collateral, regardless of the existence of any past due amount or of the number of days past due.
ii. Defaulted or impaired exposures as per the approach provided in the Capital Requirement
Regulation (CRR), which would also trigger a default under specific credit adjustment, diminished
financial obligation and obligor bankruptcy.
iii. Material exposures as set by the Central Bank of Cyprus (CBC), which are more than 90 days past
due.
iv. Performing forborne exposures under probation for which additional forbearance measures are
extended.
v. Performing forborne exposures previously classified as NPEs that present more than 30 days past
due within the probation period.
From 1 January 2021 two regulatory guidelines came into force that affect NPE classification and Days-Past-
Due calculation. More specifically, these are the RTS on the Materiality Threshold of Credit Obligations Past-
Due (EBA/RTS/2016/06), and the Guideline on the Application of the Definition of Default under article 178
(EBA/RTS/2016/07).
The Days-Past-Due (DPD) counter begins counting DPD as soon as the arrears or excesses of an exposure
reach the materiality threshold (rather than as of the first day of presenting any amount of arrears or
excesses). Similarly, the counter will be set to zero when the arrears or excesses drop below the materiality
threshold. Payments towards the exposure that do not reduce the arrears/excesses below the materiality
threshold, will not impact the counter.
For retail debtors, when a specific part of the exposures of a customer that fulfils the NPE criteria set out
above is greater than 20% of the gross carrying amount of all on-balance sheet exposures of that customer,
then the total customer exposure is classified as non-performing; otherwise only the specific part of the
exposure is classified as non-performing.
For non-retail debtors, when an exposure fulfils the NPE criteria set out above, then the total customer
exposure is classified as non-performing.
Material arrears/excesses are defined as follows:
i. Retail exposures: Total arrears/excess amount greater than €100
ii. Exposures other than retail: Total arrears/excess amount greater than €500
and the amount in arrears/excess is at least 1% of the customer's total exposure.
The definitions of credit-impaired and default are aligned so that stage 3 represents loans which are
considered defaulted or otherwise credit-impaired.
Exposures are classified as forborne when concessions are made to debtors who are facing or about to face
financial difficulties and cannot meet their contractual obligations.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.17 Impairment of financial assets (continued)
2.17.2 Credit impaired and definition of default (continued)
Non-performing forborne exposures cease to be considered as NPEs and in such case are transferred out of
Stage 3, only when all of the following conditions are met:
i. The extension of forbearance measures does not lead to the recognition of impairment or default.
ii. A period of one year has passed since the latest of the following events:
a. The restructuring date
b. The date the exposure was classified as non-performing
c. The end of the grace period included in the restructuring arrangements.
iii. Following the forbearance measures and according to the post-forbearance conditions, there is no
past due amount or concerns regarding the full repayment of the exposure.
iv. No Unlikely-to-Pay criteria exist for the debtor.
v. The debtor has made post-forbearance payments of a non-insignificant amount of capital (different
capital thresholds exist according to the facility type).
Non-performing non-forborne exposures cease to be considered as NPEs only when all of the following
conditions are met:
i. At least three months have passed since the date that the conditions for which the exposure was
classified as non-performing cease to be met, and within these three months there are no default
triggers, and
ii. During the three-month period, the behaviour of the obligor should be taken into account, i.e. there
are no arrears/excesses and instalments are being repaid normally, and
iii. During the three-month period, the financial situation of the obligor should be taken into account,
i.e. the financial situation of the obligor has improved, and
iv. During the three-month period an Unlikely-to-Pay criteria assessment is carried out and it is
assessed that the obligor can fulfil their obligations without resorting to the liquidation of collateral
and there are no other Unlikely-to-Pay criteria, and
v. The obligor does not have any amount past due by more than 90 days.
When a loan facility exits Stage 3, it is transferred to Stage 2 for a probationary period of 6 months. At the
end of this period, the significant increase in credit risk (SICR) assessment is performed by comparing the
PD at the reporting date with the PD at initial recognition as described in Note 2.17.3 and if PD is assessed
to have deteriorated beyond the set thresholds, the loan remains in Stage 2, otherwise the loan is
transferred to Stage 1. The reversal of previous unrecognised interest on loans and advances to customers
that no longer meet Stage 3 criteria is presented in 'Credit losses to cover credit risk on loans and advances
to customers' within 'Credit losses on financial assets'.
Debt securities, reverse repurchase agreements, loans and advances to banks and balances with central
banks
Debt securities, reverse repurchase agreements, loans and advances to banks and balances with central
banks are considered defaulted and transferred to Stage 3 if the issuers have failed to pay either interest or
principal. Moody’s ratings indicate these exposures with a grade C which is the lowest Moody’s rating
category. In addition, a number of other criteria are considered such as adverse changes in business,
financial and economic conditions as well as external market indicators (credit spreads, credit default swap
(CDS) prices) in determining whether there has been a significant deterioration in the financial position that
could lead to unlikeliness to pay.
2.17.3 Significant increase in credit risk (SICR)
IFRS 9 requires that in the event of a significant increase in credit risk since initial recognition, the
calculation basis of the loss allowance would change from 12-month ECL to lifetime ECL.
The assessment of whether credit risk has increased significantly since initial recognition is performed at
each reporting date, by considering the change in the risk of default occurring over the remaining life of the
financial instrument since initial recognition.
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BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.17 Impairment of financial assets (continued)
2.17.3 Significant increase in credit risk (SICR) (continued)
Significant increase in credit risk for loans and advances to customers
Primarily, the Group uses the lifetime probability of default (PD) as the quantitative metric in order to
assess transition from Stage 1 to Stage 2 for all portfolios. The Group considers an exposure to have
experienced significant increase in credit risk (SICR) by comparing the PD at the reporting date with the PD
at initial recognition to compute the relative increase in regards to the corresponding threshold. The
threshold has been determined by using statistical analysis on historical information of credit migration
exposures on the basis of days past due, for the different segments. The Group applies the thresholds
presented in the table below to each portfolio/segment, based on the following characteristics: customer
type, product type and rating at origination. The threshold is then assigned to each facility according to the
facility's portfolio/segment.
The SICR trigger is activated based on the comparison of the ratio of current lifetime PD to the remaining
Lifetime PD at origination (PD@O) to the pre-established threshold. If the resulting ratio is higher than the
pre-established threshold then deterioration is assumed to have occurred and the exposure is transferred to
Stage 2. In addition, to minimize Stage 2 volatility caused by facilities with small PD, the Group introduced
during the first half of 2024 an absolute threshold where the annualized lifetime reporting PD of each facility
should increase more than 1,06% with respect to the corresponding origination PD. The PD cut-off is based
on the weighted PD of Stage 1.
The table below summarises the quantitative measure of the SICR trigger which varies depending on the
credit quality at origination as follows, applied on 31 December 2024 and 2023:
Segment
Rating at
origination
PD Deterioration
thresholds applied at
31 December 2024
(median across
IFRS 9 segments)
PD Deterioration
thresholds applied at
31 December 2023
(median across
IFRS 9 segments)
Retail 1-7 3 X PD@O 3 X PD@O
SME 1-7 3 X PD@O 6 X PD@O
Corporate 1-7 2 X PD@O 2 X PD@O
During the year ended 31 December 2024 PDs were calibrated and consequently the PD deterioration
thresholds were also updated.
For exposures which are subject to individual impairment assessment, the following qualitative factors in
addition to the ones incorporated in the PD calculation, are considered:
i. significant change in collateral value or guarantee or financial support provided by
shareholders/directors,
ii. significant adverse changes in business, financial and/or economic conditions in which the borrower
operates.
SICR is automatically triggered upon the granting of forbearance measures to performing borrowers. Stage
1 exposures that are classified as 'performing forborne' are automatically transferred to Stage 2.
The Group also considers, as a backstop criterion, that a significant increase in the credit risk occurs when
contractual payments are more than 30 days past due (past due materiality is applied). Loans that meet
this condition are classified in Stage 2. The transfer to Stage 2 does not take place in cases where certain
exposures are past due for more than 30 days but certain materiality limits are not met (such as arrears up
to €100 and the amount in arrears is lower than 1% of the customer's total exposure, in the case of retail
exposures and arrears up to €500 and the amount in arrears is lower than 1% of the customer's total
exposure, on all exposures other than retail). The materiality levels are set in accordance with the ECB
Regulation (EU) 2018/1845.
The thresholds for movement between Stage 1 and Stage 2 are symmetrical. After a financial asset has
been transferred to Stage 2, if its credit risk is no longer considered to have significantly increased relative
to its initial recognition, the financial asset will move back to Stage 1.
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Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.17 Impairment of financial assets (continued)
2.17.3 Significant increase in credit risk (SICR) (continued)
Significant increase in credit risk for financial instruments other than loans and advances to customers
Low credit risk simplification is adopted for debt securities, loans and advances to banks, reverse
repurchase agreements and balances with central banks with external credit ratings that are rated as
investment grade. The assessment of low credit risk is based on both the external credit rating and the
internal scoring (which considers latest available information on the instrument and issuer). The
combination of the two provides an adjusted credit rating. An adjusted credit rating which remains
investment grade is considered as having low credit risk.
For debt securities, loans and advances to banks, reverse repurchase agreements and balances with central
banks which are below investment grade, the low credit risk exemption does not apply and therefore an
assessment of significant credit deterioration takes place, by comparing their credit rating at origination
with the credit rating on the reporting date. Significant deterioration in credit risk is considered to have
occurred when the adjusted rating of the exposures drops to such an extent that the new rating relates to a
riskier category (i.e. from a non-investment grade to speculative and then to highly speculative), or when
the PD of the exposure at the origination date compared to the PD at the reporting date has increased by a
level greater than the pre-set threshold.
2.17.4 Measurement of ECLs
IFRS 9 ECL reflects an unbiased, probability-weighted estimate based on either loss expectations resulting
from default events either over a maximum 12-month period from the reporting date, or over the remaining
life of a financial instrument. The Group calculates lifetime ECL and 12-month ECL either on an individual
basis or a collective basis, depending on the nature of the underlying portfolio of financial instruments.
The Group calculates ECL based on three-weighted scenarios to measure the expected cash flow shortfalls,
discounted at an approximation to the EIR as calculated at initial recognition. A cash flow shortfall is the
difference between the cash flows that are due in accordance with the contract and the cash flows expected
to be received.
The Group calculates ECL using the following three components:
i. exposure at default (EAD),
ii. probability of default (PD), and
iii. loss given default (LGD).
Exposure at default (EAD)
EAD represents the expected exposure in the event of a default during the life of a financial instrument,
considering expected repayments, interest payments and accruals. EAD definition is differentiated for the
following categories: revolving and non-revolving exposures.
For non-revolving exposures the term is based on the contractual term of the exposure and both on-balance
sheet and off-balance sheet exposures are amortised in accordance with the principal contractual payment
schedule of each exposure. For revolving exposures, the projected EAD is the carrying value plus the credit
conversion factor applied on the undrawn amount. The credit conversion factor model is derived based on
empirical data from 2014 onwards.
In regards to the credit-impaired exposures, the EAD is equal to the on balance sheet amount as at the
reporting date.
Probability of default (PD)
PD represents the probability an exposure defaults and is calculated based on statistical rating models,
calculated per segment and taking into consideration each individual’s exposure rating as well as forward
looking information based on macroeconomic inputs.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.17 Impairment of financial assets (continued)
2.17.4 Measurement of ECLs (continued)
For each exposure, lifetime PD represents the probability of default within the lifetime horizon and is based
on the underlying models of marginal probability of default through the cycle (MPD TTC), MPD individual,
MPD individual (embedding also the NPE overlay), MPD point in time and Marginal Probability of Paid-off
(MPP). In particular, the first element, MPD TTC is constructed per segment, illustrating the probability of
default status depending on number of months since the origination date. The PD for each month since the
origination date is calculated under the condition that exposures survived until the prior month. The MPD
individual is allocated to linked individual exposures through a scaling factor constructed based on the
current individual risk assessment, which is represented by the Group’s PD per rating grade. It also embeds
the NPE overlay, which is an add-on factor that calibrates the underlying models, such that they are aligned
with the NPE definition. MPD is adjusted to reflect the current and forward looking information based on the
macroeconomic inputs. The MPP Component is the curve that shows the probability of full payment of a
particular exposure based on specific period in months since the open date of the exposure. MPP is
estimated for each particular segment and depends on the contractual terms of the exposure. For revolving
facilities where there is no contractual survival maturity, curves based on product type are developed. The
combination of these models gives rise to a PD value for each month for the lifetime of the exposure.
BOC PCL's internal rating process is summarised in Note 44.
Loss given default (LGD)
LGD represents an estimate of the loss if default occurs at a given time. It is usually expressed as a
percentage of the EAD. Two distinct paths are taken into consideration for the LGD parameter. The first one
is that of a cured facility where there is a full recovery thus no losses occur. In the second scenario, the
facility remains non-performing resulting in BOC PCL proceeding with collateral liquidation actions. To this
end, the LGD model considers parameters such as historical loss and/or recovery rates as well as the
collateral value which is discounted to the present value determining the amount of the expected shortfall.
LGD rates are estimated for the Stage 1, Stage 2, Stage 3 and POCI segments of each asset class.
The structure of the LGD model considers the following:
i. Curing where the probability of cure model was derived based on historical observations.
ii. Non-curing including cash recovery, realisation through portfolio sales or realisation of collaterals,
either voluntarily i.e. debt for asset swap, or through forced sale, auctions and foreclosure and
receivership.
A model monitoring process is followed for PD, EAD and LGD models, where model outputs are back-tested
against recent data points.
Individually assessed loans
The individual assessment is performed not only for individually significant performing and non-performing
exposures, but also for other exposures meeting specific criteria and thresholds determined by Credit Risk
Management. A risk-based approach is used on the selection criteria of the individually assessed population
which include, among others, forborne exposures, exposures with significant decrease in the yearly credit
turnover and/or in assigned collaterals. Also, significant Stage 1 exposures within sectors assessed by
Credit Risk Management to be highly impacted by one or more factors or events (such as a global or local
economic/market/regulatory/geopolitical development) are assessed for potential increase in credit risk and
significant exposures that have transitioned to Stage 2 from Stage 1 are assessed for potential indications
of unlikeness to pay.
The ECL for individually assessed Stage 3 assets is calculated on an individual basis and all relevant
considerations of the expected future cash flows are taken into account (for example, the business
prospects for the customer, the realisable value of collateral, the Group’s position relative to other
claimants, the reliability of customer information and the likely cost and duration of the work out process).
Collectively assessed loans
All customer exposures that are not individually assessed are assessed on a collective basis. For the
purposes of calculating ECL, exposures are grouped into granular portfolios/segments with shared risk
characteristics. The granularity is based on different levels of segmentation which, among other factors
include customer type, exposure class and portfolio type. The granularity of the IFRS 9 segments is aligned
with the Internal Rating Based (IRB) segmentation of the CRR.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.17 Impairment of financial assets (continued)
2.17.4 Measurement of ECLs (continued)
When a financial asset has been identified as credit-impaired, ECL are measured as the difference between
the asset’s gross carrying amount and the present value of estimated future cash flows discounted at the
instrument’s original effective interest rate.
2.17.5 Scenarios and scenario weights
The Group uses reasonable and supportable information, including forward-looking information, in the
calculation of ECL. ECL are the unbiased probability-weighted credit losses determined by evaluating a
range of possible outcomes and considering future economic conditions. ECL are calculated for three
macroeconomic scenarios, baseline, adverse and favourable and the output is the weighted average ECL
based on the assigned probability of each scenario (Note 44).
Macroeconomic scenarios impact both the probability of default (PD) and the loss given default (LGD).
Specifically, forward looking information is embedded in the PD based on regression equations derived on
the basis of historical data. Using statistical analysis, the most significant and relevant macro-variables have
been selected in order to predict more accurately the expected default rates. In regard to the LGD, the
forward looking information is incorporated via the property indices for the relevant categories of properties
(residential, commercial, industrial). In particular, for each collateral a forward-looking projection of the
realisable value is calculated before discounting back to reporting date to quantify the expected cash
shortfall.
Each macroeconomic scenario used in the ECL calculation includes a projection of all relevant
macroeconomic variables used in the models for a five-year period, subsequently reverting to projections of
long-run growth averages based on estimates of potential growth, and behavioural relationships between
the targeted variables.
Regarding the scenario weights, these are determined using probability theory and severity analysis.
Historical data for GDP growth (1995-2024) is analysed and a frequency distribution is produced. From that
distribution probabilities are derived for all possible outcomes. Deviations of actual outcomes from the mean
are calculated in terms of standard deviation ratios, and severity is higher at higher deviation ratios. The
baseline scenario is defined over the range of values that correspond to 50% probability of equidistant
deviations around the mean of the historical distribution. The favourable scenario is defined over the range
of values to the right of the distribution that correspond to 25% probability. The adverse scenario is defined
over the range of values to the left of the distribution that correspond to 25% probability. These benchmark
probability points (50%, 25% and 25%), are decided using severity analysis which incorporates the average
and standard deviation of the distribution.
The macroeconomic forecasts for the baseline, favourable and adverse scenarios are determined by the
Economic Research Department of BOC PCL. This process utilises a variety of external actual and forecast
information (International Monetary Fund (IMF), European Commission and other). The corresponding
weights are also determined by the Economic Research Department, as described above, by also applying
discretion and expert judgement where necessary. The resulting scenarios and weights are reviewed and
proposed by the Chief Risk Officer (CRO) and are submitted to the Provisions Committee for their
endorsement.
Qualitative adjustments or overlays are occasionally made when inputs calculated do not capture all the
characteristics of the market at the reporting date. Overlays performed are set out in Note 5.1 and are
assessed/reconfirmed at each reporting date.
2.17.6 ECL measurement period
The period for which expected credit losses are determined (either for 12-month or lifetime horizon) is
based on the stage classification of the facility and its contractual life. For non-revolving exposures the
expected lifetime is the period from the reporting date to the termination date of the facility. For irrevocable
loan commitments and financial guarantee contracts, the measurement period is determined similar to the
period of the revolving facilities.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.17 Impairment of financial assets (continued)
2.17.6 ECL measurement period (continued)
For revolving facilities, credit cards and corporate and retail overdrafts, BOC PCL has the right to cancel
and/or reduce the facilities with two months’ notice. BOC PCL does not limit its exposure to credit losses to
the contractual notice period, but instead a behavioural maturity model is utilised where each revolving
facility is assigned an expected time period to termination.
2.17.7 Purchased or originated credit-impaired financial assets (POCI)
POCI financial assets are recorded at fair value on initial recognition. ECL are only recognised or released to
the extent that there is a subsequent change in the lifetime expected credit losses. For POCI financial
assets, the Group only recognises the cumulative changes in lifetime ECL since initial recognition in the loss
allowance. POCI remain a separate category until derecognition.
2.18 Write-offs
The Group reduces the gross carrying amount of a financial asset when there is no reasonable expectation
of recovering it. In such case, financial assets are written-off either partially or in full. Write-off refers to
both contractual and non-contractual write-offs. A non-contractual write-off is defined as the accounting
reduction of a debt, without waiving the legal claim against the debtor. BOC PCL continues to seek recovery
of the debt (e.g. restructuring arrangements, debt-for-assets swaps, full settlement, etc.) and the amount
written-off for financial assets that are still subject to enforcement activity.
Indicative conditions for writing-off part or the full amount of the exposure include, but are not limited to,
the following list of criteria. The criteria are applicable to both contractual and non-contractual write-offs
and are not by default applicable to all cases, as individual assessment and judgement is required in order
to evaluate each case on its own merits.
i. Cases which are close to realisation of a security or collateral may be deemed necessary to be
considered for write-off. With regards to such financial assets for which the security or collateral has
not yet been realised (but may be close to agreement or other arrangement for realising), BOC PCL
forms a reasonable expectation of future cash flows which would also take into account the
collateral’s realisable value.
ii. When BOC PCL ceases all collection and debt enforcement actions, such remaining debt can be
assessed for write-off. However, debt can be written-off even while collection and enforcement
activities are proceeding.
iii. Debtor status is another indicator for assessment for write-off; for example, the debtor’s insolvency
status, or whether the debtor is deceased or cannot be traced. While such loans may already be
impaired, BOC PCL might be unable to form a reasonable expectation of future cash flows.
Nevertheless, BOC PCL takes all the legally available steps to recover the debt, where appropriate.
iv. Customers with exposures with significant number of days past due, provided that all other efforts
for restructuring are exhausted and the exposure or part of the exposure is deemed as
unrecoverable / uncollectable, are also assessed for write-off.
Write-offs are subject to the Groups internal governance process for review and approval.
Write-offs and partial write-offs represent derecognition/partial derecognition events. If the amount of
write-off is greater than the amount of accumulated loss allowance, the difference is first treated as an
addition to the allowance that is then applied against the gross carrying amount. Recoveries in part or in
full, of amounts previously written-off are credited to the consolidated income statement in 'Credit losses on
financial assets' and separately identified in Note 16 within ‘Credit losses to cover credit risk on loans and
advances to customers’.
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Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.19 Financial guarantees, letters of credit and undrawn loan commitments
The Group issues financial guarantees to its customers, consisting of letters of guarantee and acceptances.
Financial guarantees are initially recognised at fair value being the premium received, and presented on the
consolidated balance sheet within ‘Accruals, deferred income, other liabilities and other provisions’.
Subsequently, the Group’s liability under each guarantee is measured at the higher of: (a) the amount
initially recognised reduced by the cumulative amortised premium which is periodically recognised in the
consolidated income statement in ‘Fee and commission income’ in accordance with the terms of the
guarantee, and (b) the amount of ECL provision.
ECL relating to financial guarantees is recorded in 'Credit losses on financial assets' and further identified in
Note 16 in ‘Credit losses to cover credit risk on loans and advances to customers’. The balance of the
liability for financial guarantees that remains is recognised in ‘Fee and commission income’ in the
consolidated income statement when the guarantee is fulfilled, cancelled or expired.
Undrawn loan commitments and letters of credit are commitments under which, over the duration of the
commitment the Group is required to provide a loan with pre-specified terms to the customer.
Corresponding ECL are presented within ‘Accruals, deferred income, other liabilities and other provisions’ on
the Group’s balance sheet, except in the case of loan commitments where ECL on the loan commitment is
recognised together with the loss allowance of the relevant on balance-sheet exposure as the Group cannot
separately identify the ECL on the loan commitment from those on the on-balance sheet exposure
component. ECL relating to loan commitments and letters of credit is recorded in ‘Credit losses on financial
assets' and further identified in Note 16 in 'Credit losses to cover credit risk on loans and advances to
customers'.
When a customer draws on a commitment, the resulting loan is presented within (i) financial assets at fair
value held for trading, consistent with the associated derivative loan commitment, (ii) financial assets at fair
value not held for trading, following loan commitments designated at FVPL, or (iii) loans and advances to
customers, when the associated loan commitment is not fair valued through profit or loss.
2.20 Offsetting financial instruments
Financial assets and financial liabilities are offset and the net amount reported in the consolidated balance
sheet if there is a currently enforceable legal right to offset the recognised amounts and there is an
intention to settle on a net basis, or to realise the asset and settle the liability simultaneously. The legally
enforceable right must not be contingent on future events and must be enforceable in the normal course of
business and in the event of default, insolvency or bankruptcy of either party.
2.21 Hedge accounting
The Group elected, as a policy choice permitted by IFRS 9, to continue to apply hedge accounting in
accordance with IAS 39, including the provisions related to macro fair value hedge accounting (IAS 39
'carve-out').
The Group uses derivative financial instruments to hedge exposures to interest rate and foreign exchange
risks and in the case of the hedge of net investments, the Group uses also non-derivative financial liabilities.
The Group applies hedge accounting for transactions which meet the specified criteria.
Transactions that are entered into in accordance with the Group's hedging objectives, but do not qualify for
hedge accounting, are referred to as economic hedge relationships.
At inception of the hedging relationship, the Group formally documents the relationship between the hedged
item and the hedging instrument, including the nature of the risk and the objective and strategy for
undertaking the hedge. The method that will be used to assess the effectiveness, both at the inception and
at ongoing basis, of the hedging relationship also forms part of the Group’s documentation.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.21 Hedge accounting (continued)
At inception of the hedging relationship and at each hedge effectiveness assessment date, a formal
assessment is undertaken to ensure that the hedging relationship is highly effective regarding the offsetting
of the changes in fair value or the cash flows attributable to the hedged risk. A hedge is regarded as highly
effective if the changes in fair value or cash flows attributable to the hedged risk of the hedging instrument
and the hedged item during the period for which the hedge is designated, are expected to offset in a range
of 80% to 125%. In the case of cash flow hedges where the hedged item is a forecast transaction, the
Group assesses whether the transaction is highly probable and presents an exposure to variations in cash
flows that could ultimately affect the consolidated income statement.
Portfolio Hedging (Macro-Hedging)
The Group applies macro fair value hedging to non-maturing deposits (NMDs), in accordance with IAS 39,
as adopted by the EU (IAS 39 carve-out). The hedged items are determined through behavioural modelling
identifying the ‘core’ Non-Maturing Deposits (NMDs), which are stable demand deposits with behavioural
maturity of up to ten years. Deposits within the identified portfolios are allocated to repricing/maturity time
buckets based on expected, rather than contractual, maturity dates. The hedging instruments (pay
floating/receive fixed rate interest rate swaps) are designated appropriately to those repricing/maturity
time buckets. Hedge effectiveness is measured by comparing fair value movements of the hedged amount
attributable to the hedged risk, against the fair value movements of the hedging derivatives, to ensure that
they are within an 80% to 125% range.
2.21.1 Fair value hedges
In the case of fair value hedges that meet the criteria for hedge accounting, the change in the fair value of a
hedging instrument is recognised in the consolidated income statement in ‘Net gains/(losses) on financial
instruments'. The change in the fair value of the hedged item attributable to the risk hedged is recorded as
part of the carrying value of the hedged item and is also recognised in the consolidated income statement in
‘Net gains/(losses) on financial instruments'.
If the hedging instrument expires or is sold, terminated or exercised, or where the hedge no longer meets
the criteria for hedge accounting, the hedging relationship is discontinued prospectively. For hedged items
recorded at amortised cost, the difference between the carrying value of the hedged item on termination
and the face value is amortised to the consolidated income statement, over the remaining term of the
original hedge. If the hedged item is derecognised, the unamortised fair value adjustment is recognised
immediately in the consolidated income statement.
2.21.2 Hedges of net investments in foreign operations
Hedges of net investments in overseas branches or subsidiaries are accounted for in a way similar to cash
flow hedges. Gains or losses on the hedging instrument relating to the effective portion of the hedge are
recognised in other comprehensive income in the 'Foreign currency translation reserve', while gains or
losses relating to the ineffective portion are recognised in ‘Net foreign exchange gains’ in the consolidated
income statement.
On disposal or liquidation of an overseas branch or subsidiary, the cumulative gains or losses recognised in
other comprehensive income are transferred in the consolidated income statement as part of the gain/(loss)
on the disposal or liquidation.
2.22 Cash and cash equivalents
Cash and cash equivalents for the purposes of the consolidated statement of cash flows consist of cash,
non-obligatory balances with central banks, loans and advances to banks and other securities that are
readily convertible into known amounts of cash and are repayable within three months of the date of their
acquisition.
2.23 Insurance business
The Group undertakes both life insurance and non-life insurance business and issues insurance and
investment contracts. An insurance contract is a contract under which one party (the insurer) accepts
significant insurance risk from another party (the policyholder) by agreeing to compensate the policyholder
if a specified uncertain future event (the insured event) adversely affects the policyholder.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.23 Insurance business (continued)
Once a contract has been classified as an insurance contract, it remains an insurance contract until expiry or
until all the rights and obligations under the contract have been fulfilled, even if the insurance risk has been
significantly reduced during its term.
Investment contracts are those contracts that transfer financial risk. Investment contracts can, however, be
reclassified as insurance contracts after inception, if insurance risk becomes significant.
Identifying contracts
When identifying contracts there is a need to assess whether contracts need to be treated as a single
contract and whether embedded derivatives, investment components and goods and services components
need to be separated and accounted for under another standard.
Level of aggregation
Individual insurance contracts that are managed together and are subject to similar risks are identified as a
group.
Contracts that are managed together usually belong to the same product line and have similar
characteristics, such as being subject to a similar pricing framework or similar product management, and
are issued by the same legal entity. If a contract is exposed to more than one risk, the dominant risk of the
contract is used to assess whether the contract features similar risks.
Each group of contracts is then divided into annual cohorts (i.e. by year of issue) and each cohort into three
groups, based on expected profitability: (i) contracts that are onerous at initial recognition; (ii) contracts
that at initial recognition have no significant possibility of becoming onerous subsequently; and (iii) the
remaining contracts.
The groups of insurance contracts are established at initial recognition without subsequent reassessment
and form the unit of account at which the contracts are measured.
Recognition
Groups of insurance contracts issued are initially recognised from the earliest of the following:
i. the beginning of the coverage period;
ii. the date when the first payment from the policyholder is due or actually received, if there is no due
date; and
iii. when the Group determines that a group of contracts becomes onerous.
The Group adds new contracts to the group in the reporting period in which that contract meets one of the
criteria set out above.
Contract boundaries
The measurement of a group of insurance contracts includes all the future cash flows within the boundary of
each contract in the group. Cash flows are within the boundary of an insurance contract if they arise from
substantive rights and obligations that exist during the reporting period in which the Group can compel the
policyholder to pay the premiums, or in which the Group has a substantive obligation to provide the
policyholder with services. For multi-year (more than one year) non-life contracts, the Group has assessed
that they are expected to equal their duration as the Group cannot reprice or terminate the insurance
contract during the coverage period.
Measurement
The General Measurement Model (GMM) is the standard measurement model and the Premium Allocation
Approach (PAA) is the simplified approach for the measurement of the contracts that fall under the scope of
IFRS 17. The Variable Fee Approach (VFA) is mandatory to apply for insurance contracts with direct
participation features upon meeting the eligibility criteria. While the GMM is the default measurement
model, the Group applies the VFA primarily to insurance contracts in the unit-linked life portfolio. The PAA is
an optional simplification applicable for measuring the Liability for Remaining Coverage (LRC) for contracts
with coverage periods of one year or less, or when doing so approximates the GMM; it is primarily applied
by the Group to non-life insurance contracts and to non-individual life insurance contracts, as well as to
reinsurance contracts of the Group, except for the individual life reinsurance agreement, for which the GMM
is applied. For the rest of the insurance contracts (individual protection life contracts, the acquired portfolio
and health long-term portfolio), the Group applies the GMM approach.
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Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.23 Insurance business (continued)
Initial measurement
Groups of insurance contracts under the GMM or the VFA are initially measured as the total of:
a. Fulfilment cash flows, which comprise:
i. an estimate of the present value of future cash flows that are expected to arise as the Group
fulfils its service under the insurance contracts; and
ii. an explicit risk adjustment for non-financial risk (i.e., the risk adjustment held on balance
sheet).
b. Contractual Service Margin (CSM) which represents the unearned profit that the Group will recognise as
it provides insurance contract services.
The fulfilment cash flows comprise unbiased and probability-weighted estimates of future cash flows,
discounted to present value to reflect both the time value of money and financial risks, plus a risk
adjustment for non-financial risk. The discount rate applied reflects the time value of money, the
characteristics of the cash flows, the liquidity characteristics of the insurance contracts and, where
appropriate, is consistent with observable current market prices.
The risk adjustment for non-financial risk for a group of insurance contracts is the compensation required
for bearing the uncertainty in relation to the amount and timing of the cash flows that arises from non-
financial risk. The risk adjustment is explicit and determined separately from other fulfilment cash flows.
A CSM arises when, for a group of contracts, the sum of the discounted cash flows and the risk adjustment
is a net inflow. If the sum of these is a net outflow, then the group of contracts is onerous and a loss equal
to the net outflow is recognised in the consolidated income statement.
Under the PAA, the liability for remaining coverage is initially recognised as the premiums received at initial
recognition, minus any insurance acquisition cash flows.
Subsequent measurement
GMM
At the end of each reporting period, insurance contracts are measured as the sum of:
i. Liability for remaining coverage (LRC), comprising fulfilment cash flows related to future service and
the CSM at the reporting date; and
ii. Liability for incurred claims (LIC), comprising fulfilment cash flows related to past service at the
reporting date (claims and expenses not yet paid, including claims incurred but not yet reported).
The fulfilment cash flows of groups of insurance contracts are measured at the reporting date using current
estimates of future cash flows, current discount rates and current estimates of the risk adjustment for non-
financial risk. Changes in fulfilment cash flows are recognised as follows:
i. Changes related to future service are adjusted against the CSM, unless the group of contracts is
onerous, in which case such changes are recognised in the net insurance service result in the
consolidated income statement
ii. Changes related to past or current service are recognised in the net insurance service result in the
consolidated income statement
iii. The effects of the time value of money and financial risk are recognised as net insurance finance
income or expense in the consolidated income statement.
The amount of CSM recognised in income statement for services in a period is determined by the allocation
of the CSM remaining at the end of the reporting period (before any allocation) over the current and
remaining expected coverage period of the group of insurance contracts based on coverage units. These
coverage units reflect the quantity of benefits and the coverage duration. Adjustments relating to future
service and thus adjust the CSM using locked-in discount rates (i.e. those that reflect the characteristics of
the cash flows of initial recognition) except for changes in the risk adjustment for non-financial risk that
relate to future service.
VFA
The VFA is applied for contracts with direct participation features (contracts where returns are based on the
performance of underlying assets). For insurance contracts under the VFA, changes in the Group’s share of
the underlying items, and economic experience and economic assumption changes adjust the CSM, whereas
these changes do not adjust the CSM under the GMM but are recognised in profit or loss as they arise.
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Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.23 Insurance business (continued)
PAA
Subsequently to initial measurement, the carrying amount of the LRC is increased with premiums received
in the period, minus insurance acquisition cash flows, plus amortisation of acquisition cash flows, minus the
amount recognised as insurance revenue for coverage provided in that period. The LRC is not discounted,
since at initial recognition, it is expected that the time between providing each part of the coverage and the
due date of the related premium is not more than a year.
Reinsurance contracts
The Group applies the same accounting policies to measure a group of reinsurance contracts under PAA,
with the following modifications to reflect features that differ from those of insurance contracts. The Group
establishes a loss-recovery component on the carrying amount of the asset for remaining coverage for a
group of reinsurance contracts, depicting the recovery of losses, where the Group recognises a loss on initial
recognition of an onerous group of underlying insurance contracts or when further onerous underlying
insurance contracts are added to a group.
The Group calculates the loss-recovery component by multiplying the loss recognised on the underlying
insurance contracts and the percentage of claims on the underlying insurance contracts the Group expects
to recover from the group of reinsurance contracts. The loss-recovery component adjusts the carrying
amount of the asset for remaining coverage.
The subsequent measurement of reinsurance contracts follows the same principles as those for insurance
contracts issued and has been adapted to reflect the specific features of reinsurance. Where the Group has
established a loss-recovery component, the Group subsequently reduces the loss-recovery component to
zero in line with reductions in the onerous group of underlying insurance contracts in order to reflect that
the loss-recovery component shall not exceed the portion of the carrying amount of the loss component of
the onerous group of underlying insurance contracts that the entity expects to recover from the group of
reinsurance contracts.
The measurement of reinsurance contracts under the individual life reinsurance agreement follows the same
principles as those for insurance contracts measured under the GMM. The carrying amount of the
reinsurance contracts at each reporting date is the sum of the asset for remaining coverage and the asset
for incurred claims. The asset for remaining coverage comprises (a) the fulfilment cash flows that relate to
services that will be received under the contracts in future periods, and (b) any remaining CSM at that date.
The risk adjustment for non-financial risk represents the amount of risk being transferred by the Group to
the reinsurer.
The CSM of a group of reinsurance contracts represents a net cost or net gain on purchasing reinsurance.
The Group has made the below elections in relation to the measurement of insurance and reinsurance
contract assets and liabilities and related income/expense:
i. Recognition of total insurance finance income or expenses in the consolidated income statement in
the period in which they arise i.e. not to apply disaggregation,
ii. Deferral of insurance acquisition cash flows for non-life insurance business other than the health
insurance business, when applying the premium allocation approach, and
iii. Disaggregation of the change in risk adjustment for non-financial risk between the net insurance
service result and net insurance finance income/(expense).
Contract derecognition
The Group derecognises an insurance contract issued when the obligation specified in the contract expires,
is discharged, or is cancelled, or if its terms are modified significantly. When a contract is modified
significantly, a new contract based on the modified terms is recognised.
On derecognition of an insurance contract, the Group:
i. adjusts the fulfilment cash flows to eliminate the present value of future cash flows and risk
adjustment for non-financial risk relating to the rights and obligations that have been derecognised
from the group of contracts,
ii. adjusts the CSM of the group of contracts for the change in the fulfilment cash flows, except where
such changes are allocated to a loss component; and
iii. adjusts the number of coverage units for the expected remaining services, to reflect the number of
coverage units derecognised from the group of contracts.
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Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.23 Insurance business (continued)
Onerous groups of contracts
For portfolios measured under the PAA, the Company assumes that no contracts in the portfolio are onerous
at initial recognition unless facts and circumstances indicate otherwise. For contracts not measured under
the PAA, that are not onerous, the Group assesses, at initial recognition, that there is no significant
possibility of becoming onerous subsequently by assessing the likelihood of changes in applicable facts and
circumstances. The Group considers facts and circumstances to identify whether a group of contracts are
onerous based on:
i. major shifts in economic and regulatory environment;
ii. combined Loss Ratio (Claims plus expenses divided by premium);
iii. pricing strategy leading to loss;
iv. changes in claims handling policy (e.g. time – stamped period) etc.
The Group has based its assessment on the Combined Loss Ratio as one of the key indicators of whether
there are facts and circumstances to conclude that a group of contracts is onerous, as it takes into account
economic shifts, the Group’s decision on the pricing strategy, as well as the Group’s claims' handling
processes.
For the portfolios measured under GMM and VFA models, the Group performs profitability assessment to
assess the portfolio of insurance contracts issued into three profitability groups, if applicable, for the
purpose of calculating the CSM. The grouping is performed per set of contracts at initial recognition based
on assumed profitability (profit testing exercise).
Insurance acquisition cash flows
The Group includes the following acquisition cash flows within the insurance contract boundary that arise
from selling and starting a group of insurance contracts and that are:
a. costs directly attributable to individual contracts and groups of contracts; and
b. costs directly attributable to the portfolio of insurance contracts to which the group belongs, which
are allocated on a reasonable and consistent basis to measure the group of insurance contracts.
Directly attributable expenses
Expenses directly attributable to a group of insurance contracts, which include both acquisition and
maintenance costs, are incorporated in actual and estimated future cash flows and recognised in the net
insurance result. Insurance acquisition cash flows are amortised. Expenses that are not directly attributable
are excluded from the measurement of insurance contract liabilities and are recognised in profit and loss as
incurred.
2.24 Repurchase and reverse repurchase agreements
Securities sold under agreements to repurchase (repos) at a specific future date are not derecognised from
the consolidated balance sheet as the Group retains substantially all risks and rewards of ownership. The
corresponding cash received, including accrued interest, is recognised on the consolidated balance sheet as
‘Repurchase agreements’, reflecting its economic substance as a loan to the Group. The difference between
the sale price and repurchase price is treated as interest expense and is accrued over the life of the
agreement using the effective interest rate method. The investments pledged as security for the repurchase
agreements can be sold or repledged by the counterparty. When the counterparty has the right to sell or
repledge the securities, the Group discloses those securities as ‘Investments pledged as collateral’.
Securities purchased under agreements to resell (reverse repos) at a specific future date, are not
recognised on the consolidated balance sheet, rather are recorded as 'Reverse Repurchase agreements' on
the consolidated balance sheet. The difference between the purchase and the resale price is treated as
interest income and is accrued over the life of the agreement using the effective interest rate method.
Reverse repos outstanding at the reporting date relate to agreements with financial institutions. The
investments received as security under reverse repurchase agreements can either be sold or repledged by
the Group.
2.25 Leases
Group as a lessee
The Group recognises right of use assets (RoU assets) and lease liabilities for contracts that convey the
right to control the use of an identified asset for a period of time in exchange for consideration.
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Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.25 Leases (continued)
The Group has the right to direct the use of an identified asset throughout the period of use when it has the
right to direct how and for what purpose the asset is used and has the right to change the purpose,
throughout the period of use (i.e. the decision-making rights that most significantly affect the economic
benefits that can be derived from the use of the underlying asset). Essentially, this right permits the Group
to change its decisions throughout the contract term without approval from the lessor.
The lease liabilities are initially measured at the present value of the future lease payments, discounted at
the lessee’s incremental borrowing rate (IBR) given that the interest rate implicit in the lease cannot be
readily determined. Subsequently, the lease liability is adjusted for interest and lease payments, as well as
the impact of lease modifications. Interest is computed by unwinding the present value of the lease liability
and charged to the consolidated income statement within 'Interest expense'.
RoU assets are measured at cost, less any accumulated depreciation and impairment losses, and adjusted
for any remeasurement of lease liabilities. The cost of the RoU asset comprises the amount of the initial
measurement of the lease liability, initial direct costs and the provision for restoration costs, adjusted for
any related prepaid or accrued lease payments previously recognised. Depreciation is computed on a
straight line basis up to the end of the lease term, and recognised in the consolidated income statement
within 'Other operating expenses'. RoU assets are subject to impairment under IAS 36.
The Group elected to use the recognition exemption for lease contracts that, at the commencement date,
have a lease term of 12 months or less and do not contain a purchase option (‘short-term leases’), and
lease contracts for which the underlying asset is of low value (‘low value assets’). Payments associated with
short-term leases and leases of low value assets are recognised on a straight line basis as an expense in the
consolidated income statement.
Leases are monitored for significant changes that could trigger a change in the lease term and at the end of
each reporting period the impact on the lease liability and the RoU asset is reassessed. Lease liability is
remeasured if there is a change in future lease payments, a change in the lease term, or as appropriate, a
change in the assessment of whether an extension option is reasonably certain to be exercised or a
termination option is reasonably certain not to be exercised. When the lease liability is remeasured, a
corresponding adjustment is made to the RoU asset and/or profit or loss, as appropriate.
The lease term is calculated as the non-cancellable term of the lease, together with any periods covered by
an option to extend the lease (if reasonably certain to be exercised), or any periods covered by an option to
terminate the lease (if reasonably certain not to be exercised). The assessment of whether the Group is
reasonably certain to exercise such options impacts the lease term, which significantly affects the amount of
lease liabilities and RoU assets recognised. Judgement is used in calculating the lease term, as further
disclosed in Note 5.12.
Lease payments generally include fixed payments and variable payments that depend on an index (such as
an inflation index).
Variable lease payments that are determined by reference to an index or a rate are taken into account in
the lease liability only when there is a change in the cash flows resulting from a change in the reference
index or rate. In cases where the lease contract includes a term relating to increase in the lease payment
based on variable lease payments, this increase is applied on the lease when it becomes effective (when the
actual cash outflow occurs). The assessment is performed at each reporting date. In cases where the lease
contract includes a term with fixed increments in the lease payments, the increase is accounted for in the
initial recognition of lease liability.
When a lease contains an extension or termination option that the Group considers reasonably certain to be
exercised, the expected lease payments or costs of termination are included within the lease payments in
determining the lease liability.
Group as a lessor
Leases in which the Group does not transfer substantially all the risks and rewards incidental to ownership
of an asset are classified as operating leases. Rental income arising is accounted for on a straight-line basis
over the lease terms and is included in ‘Other income’ in the consolidated income statement due to its
operating nature. Initial direct costs incurred in negotiating and arranging an operating lease are added to
the carrying amount of the leased asset and recognised over the lease term on the same basis as rental
income.
411
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Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.26 Property and equipment
Owner-occupied property is property held by the Group for use in the supply of services or for
administrative purposes. Investment property is property held by the Group to earn rentals and/or for
capital appreciation, as further disclosed in Note 2.27. If a property of the Group includes a portion that is
owner-occupied and another portion that is held to earn rentals or for capital appreciation, the classification
is based on whether or not these portions can be sold separately. Otherwise, the whole property is classified
as owner-occupied property unless the owner-occupied portion is insignificant. The classification of property
is reviewed on a regular basis to account for major changes in its use.
Owner-occupied property is initially measured at cost and subsequently measured at fair value less
accumulated depreciation and impairment. Valuations are carried out periodically between 3 to 5 years,
(but more frequent revaluations may be performed where there are significant and volatile movement in
values), by independent, qualified valuers or by the internal qualified valuers of the Group applying a
valuation model recommended by internationally accepted valuation standards. At the date of the
revaluation, the accumulated depreciation is eliminated against the gross carrying amount of the property.
Depreciation is calculated on the revalued amount less the estimated residual value of each building on a
straight line basis over its estimated useful life. Gain from revaluations are recognised in other
comprehensive income in ‘Property revaluation reserve', however to the extent it reverses an impairment
previously recognised in the consolidated income statement, the increase is recognised in the consolidated
income statement. A revaluation loss is recognised in the consolidated income statement, except to the
extent it offsets an existing revaluation reserve surplus.
Useful life is in the range of 30 to 67 years. Freehold land is not depreciated. On disposal of freehold land
and buildings, the relevant revaluation reserve balance is transferred to ‘Retained earnings’.
The cost of adapting/improving leasehold property is amortised over 5 years.
Equipment is measured at cost less accumulated depreciation. Depreciation of equipment is calculated on a
straight line basis over its estimated useful life of 5 to 10 years.
RoU assets recognised as property are measured at cost less accumulated depreciation and adjusted for
certain remeasurements of lease liabilities. Depreciation of the recognised RoU assets is calculated on a
straight line basis over the lease term, as further disclosed in Note 2.25.
At the reporting date, when events or changes in circumstances indicate that the carrying value may not be
recovered, property and equipment is assessed for impairment. Where the recoverable amount is less than
the carrying amount, property and equipment is written down to its recoverable amount.
2.27 Investment properties
Investment properties comprise land and buildings that are not occupied for use by, or in the operations of
the Group, nor for sale in the ordinary course of business, but are held primarily to earn rental income
and/or for capital appreciation. Additionally, leased properties which are acquired in exchange for debt and
are leased out under operating leases are also usually classified as 'Investment properties'.
Investment properties are measured initially at cost, including transaction costs. Subsequent to initial
recognition, investment properties are measured at fair value as at the reporting date. Gains or losses
arising from changes in the fair values of investment properties are included in ‘Net gains/(losses) from
revaluation and disposal of investment properties’ in the consolidated income statement. Valuations are
carried out by independent, qualified valuers or by the Group's internal qualified valuers applying a
valuation model recommended by internationally accepted valuation standards.
Transfers are made to (or from) investment property only when there is a change in use. For a transfer
from owner-occupied property to investment property, the Group accounts for such property in accordance
with the policy described in Note 2.26Property and equipment’ up to the date of change in use. For a
transfer from investment property to stock of property, the property’s deemed cost for subsequent
accounting is its fair value at the date of change in use.
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Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.28 Stock of property
The Group in its normal course of business acquires properties in exchange of debt, which are held either
directly by BOC PCL or by entities set up and controlled by the Group for the sole purpose of managing
these properties with an intention to be disposed of. These properties are recognised in the Consolidated
Financial Statements as ‘Stock of property’, reflecting the substance of these transactions. Transfers from
stock of property are made at their carrying value when there is a change in use of property.
Stock of property is initially measured at cost and subsequently measured at the lower of cost and net
realisable value. Net realisable value is the estimated selling price, less the estimated costs necessary to
make the sale.
If net realisable value is below the cost of the stock of property, impairment is recognised in ‘Impairment
net of reversals on non-financial assets’ in the consolidated income statement.
2.29 Non-current assets held for sale and discontinued operations
The Group classifies non-current assets and disposal groups as held for sale if their carrying amounts will be
recovered principally through a sale or distribution rather than through continuing use.
The condition for such classification is regarded as met only when the sale is highly probable and the asset
or disposal group is available for immediate sale in its present condition. Actions required to complete the
sale should indicate that it is unlikely that significant changes to the plan will be made or that the plan will
be withdrawn. Management must be committed to the sale, which should be expected to qualify for
recognition as a completed sale within one year from the date of classification.
Such non-current assets and disposal groups held for sale are measured at the lower of their carrying
amount and fair value less costs to sell, except for those assets and liabilities that are not within the scope
of the measurement requirements of IFRS 5 ‘Non-current assets held for sale and discontinued operations’
such as deferred taxes, financial instruments, investment properties measured at fair value, insurance
contracts and assets and liabilities arising from employee benefits. These are measured in accordance with
the Group’s relevant accounting policies described elsewhere in this note.
Immediately before the initial classification as held for sale, the carrying amount of the asset (or assets and
liabilities in the disposal group) is measured in accordance with applicable IFRS Accounting Standards. On
subsequent remeasurement of a disposal group, the carrying amounts of the assets and liabilities noted
above that are not within the scope of the measurement requirements of IFRS 5 are remeasured in
accordance with applicable IFRS Accounting Standards.
Assets and liabilities classified as held for sale are presented separately in the consolidated balance sheet.
A disposal group qualifies as a discontinued operation if an entity or a component of an entity has been
disposed of or is classified as held for sale and a) represents a separate major line of business or
geographical area of operations, b) is part of a single coordinated plan to dispose of a separate major line of
business or geographical area of operations, or c) is a subsidiary acquired exclusively with a view to resale.
Net profit/loss from discontinued operations includes the net total of operating profit and loss before tax
from discontinued operations (including net gain or loss on sale before tax and gain or loss on measurement
to fair value less cost to sell of a disposal group constituting a discontinued operation) and discontinued
operations tax expense.
Discontinued operations are excluded from the results of continuing operations and are presented as a
single amount, as profit or loss after tax from discontinued operations in the consolidated income
statement.
413
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Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.30 Intangible assets
Intangible assets comprise computer software (including internally developed software). Intangible assets
acquired separately are measured on initial recognition at cost. The cost of intangible assets acquired in a
business combination is their fair value as at the date of acquisition. The Group recognises an intangible
asset that arises from development or the development phase of an internal project if, and only if, it can
demonstrate all of the following:
i. The technical feasibility of completing the intangible asset so that it will be available for use or sale;
ii. Its intention to complete the intangible asset and use or sell it;
iii. Its ability to use or sell the intangible asset;
iv. How the intangible asset will generate probable future economic benefits;
v. The availability of adequate technical, financial and other resources to complete the development and
to use or sell the intangible asset; and
vi. Its ability to reliably measure the expenditure attributable to the intangible asset during its
development.
The expenditure arising on research or the research phase of an internal project are expensed as incurred
and cannot be subsequently capitalised.
Following initial recognition, intangible assets are carried at cost less any accumulated amortisation and any
accumulated impairment losses.
Amortisation is calculated on a straight line basis over the estimated useful life of the assets which is 3 to 8
years for computer software, including internally developed computer software.
Intangible assets are reviewed for impairment when events relating to changes in circumstances indicate
that the carrying value may not be recoverable. If the carrying amount exceeds the recoverable amount
then the intangible assets are written down to their recoverable amount and an impairment loss is
recognised in 'Impairment net of reversals on non-financial assets' in the consolidated income statement.
2.31 Share capital
Ordinary shares are classified as equity.
Any difference between the issue price of share capital and the nominal value is recognised as share
premium. The costs incurred attributable to the issue of share capital are deducted from equity.
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Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.32 Share-based compensation plans
The Group recognises expenses for deferred compensation awards over the period that the employee is
required to provide service to become entitled to the award. Whereby employees render services in
exchange for equity instruments these arrangements are classified as equity-settled transactions.
Share-based compensation benefits are provided to employees (senior management of the Group) via the
Long-Term Incentive Plan, an employee share arrangement which satisfies an incentive based award
through the issue of shares (equity-settled).
Share-based compensation expense is measured by reference to the fair value of the equity instruments on
the date of grant, with a corresponding increase in equity (other capital reserves), taking into account the
terms and conditions inherent in the award, including, where relevant, dividend rights, transfer restrictions
in effect beyond the vesting date, market conditions, and non-vesting conditions. For equity-settled awards,
fair value is not remeasured unless the terms of the award are modified such that there is an incremental
increase in value.
The total expense is recognised on a per-tranche basis, over the service period based on an estimate of the
number of shares expected to vest and are adjusted to reflect the actual outcomes of service or
performance conditions. At the end of each reporting period, the Group revises its estimates of the number
of shares that are expected to vest and recognises the impact of the revision to original estimates, if any, in
the consolidated income statement, with a corresponding adjustment to equity (other capital reserves). The
cumulative expense recognised for equity-settled transactions at each reporting date until the vesting date
reflects the extent to which the vesting period has expired and the Group’s best estimate of the number of
shares that will ultimately vest. The expense or credit in the consolidated income statement for a period
represents the movement in cumulative expense recognised as at the beginning and end of that period. No
expense is recognised for awards that do not ultimately vest because non-market performance and/or
service conditions have not been met.
The vesting period for these schemes may commence before the legal grant date if the employees have
started to render services in respect of the award before the legal grant date, where there is a shared
understanding of the terms and conditions of the arrangement. Expenses are recognised when the
employee starts to render service to which the award relates.
2.33 Other equity instruments
An instrument is an equity instrument if the instrument includes no contractual obligation to deliver cash or
another financial asset to another entity, or to exchange financial assets or financial liabilities with another
entity under conditions that are potentially unfavourable to the issuer.
Other equity instruments are recorded at their residual amount and are not subject to any re-measurement
after initial recognition. The cost incurred attributable to the issue of other equity instruments is deducted
from retained earnings. Any subsequent write-down or write-up results to a credit or debit in retained
earnings respectively. Coupon payments are recorded directly in retained earnings.
2.34 Treasury shares
Own equity instruments which are acquired by the Company or by any of its subsidiaries are presented as
treasury shares at their acquisition cost. Treasury shares are deducted from equity until they are cancelled
or reissued. No gain or loss is recognised in the consolidated income statement on the purchase, sale, issue
or cancellation of the Company’s own equity shares.
2.35 Dividends on ordinary shares
Dividends on ordinary shares are recognised as a liability and deducted from equity when they are approved
by the Company’s shareholders. Interim dividends are deducted from equity when they are declared and
are no longer at the discretion of the Company. Dividends for the year that are approved after the reporting
date, are disclosed as an event after the reporting date.
415
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
2. Summary of accounting policies (continued)
2.36 Provisions for pending litigation, claims, regulatory and other matters
Provisions for pending litigation, claims, regulatory and other matters against the Group are made when:
(a) there is a present obligation (legal or constructive) arising from past events, (b) the settlement of the
obligation is expected to result in an outflow of resources embodying economic benefits, and (c) a reliable
estimate of the amount of the obligation can be made.
2.37 Business combinations
Business combinations are accounted for using the acquisition method. The cost of an acquisition is
measured as the aggregate of the consideration transferred, measured at the acquisition date fair value and
the amount of any non-controlling interests in the acquiree. For each business combination the Group elects
whether to measure the non-controlling interests in the acquiree at fair value or at the proportionate share
of the acquiree’s identifiable net assets. Any excess of the cost of acquisition over the Group’s share of the
fair values of the identifiable net assets acquired is recognised as goodwill on the consolidated balance
sheet. Where the Group’s share of the fair values of the identifiable net assets is greater than the cost of
acquisition (i.e. negative goodwill), the difference is recognised directly in the consolidated income
statement in the year of acquisition. Acquisition related costs are expensed as incurred and included in
other operating expenses.
If the business combination is achieved in stages, the previously held equity interest is remeasured at fair
value and any resulting gain or loss is recognised in the consolidated income statement.
When the Group acquires a business, it assesses the financial assets and liabilities assumed for appropriate
classification and designation in accordance with contractual terms, economic circumstances and pertinent
conditions as at the acquisition date.
3. Going concern
The Directors have made an assessment of the ability of the Group, the Company and BOC PCL to continue
as a going concern for a period of 12 months (the period of assessment) from the date of approval of these
Consolidated Financial Statements.
The Directors have concluded that there are no material uncertainties which would cast a significant doubt
over the ability of the Group, the Company and BOC PCL to continue to operate as a going concern for a
period of 12 months from the date of approval of the Consolidated Financial Statements and the Financial
Statements of the Company.
In making this assessment, the Directors have considered a wide range of information relating to present
and future conditions, including projections of profitability, cash flows, capital requirements and capital
resources, liquidity and funding position, taking also into consideration the Group’s Financial Plan approved
by the Board in February 2025 (the ‘Plan’) and the operating environment. The Group has sensitised its
projection to cater for a downside scenario and has used reasonable economic inputs to develop its
medium-term strategy.
Capital
The Directors and management have considered the Group’s forecasted capital position, including the
potential impact of a deterioration in economic conditions. The Group has developed capital projections
under a base and an adverse scenario and the Directors believe that the Group has sufficient capital to meet
its regulatory capital requirements throughout the period of assessment.
Funding and liquidity
The Directors and management have considered the Group’s funding and liquidity position and are satisfied
that the Group has sufficient funding and liquidity throughout the period of assessment. The Group
continues to hold a significant liquidity buffer at 31 December 2024 that can be monetised in a period of
stress.
416
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
4. Economic and geopolitical environment
Cyprus is a small, open, services-based economy, with a large external sector and high reliance on tourism
and international business and information and communication technology (ICT) services. As a result,
external factors which are beyond the control of the Group, including developments in the European Union
and in the global economy, or in specific countries with which Cyprus maintains close economic and
investment links, can have a significant impact on domestic economic activity. A number of macro and
market related risks, including weaker economic activity, a highly volatile interest rate environment, and
higher competition in the financial services industry, could negatively affect the Group’s business
environment, results, and operations.
There are heightened geopolitical tensions between the world’s largest economies adding uncertainty to the
global economy outlook. War and geopolitics can be very disruptive to the economy. Continued
uncertainties arise from the ongoing wars in Russia/Ukraine and the Middle East.
In this context, the Group is closely monitoring the developments, utilising dedicated governance structures
including a Crisis Management Committee as required, and has assessed the impact the crisis has on the
Group’s operations and financial performance. Furthermore, the Group in its models includes related events
in its stress testing scenarios in order to gain a better understanding of the potential capital impact.
Although, there have been distinct improvements in Cyprus’ risk profile after the banking crisis, substantial
risks remain. Cyprus’ overall country risk is a combination of sovereign, currency, banking, political and
economic structure risk, influenced by external developments. Given the above, the Group recognises that
unforeseen political events can have negative effects on the Group’s activities.
The Group is continuously monitoring the current affairs and the impact of the forecasted macroeconomic
conditions and geopolitical developments on the Group’s strategy to proactively manage emerging risks.
5. Significant and other judgements, estimates and assumptions
The preparation of the Consolidated Financial Statements requires the Company’s Board of Directors and
management to make judgements, estimates and assumptions that can have a material impact on the
amounts recognised in the Consolidated Financial Statements and the accompanying disclosures, as well as
the disclosures of contingent liabilities. Uncertainty about these assumptions and estimates could result in
outcomes that require a material adjustment to the carrying amount of assets or liabilities affecting future
periods.
The key assumptions concerning the future and other key sources of estimation uncertainty at the reporting
date that have a significant risk of causing a material adjustment to the carrying amounts of assets and
liabilities are described below. The Group based its assumptions and estimates on parameters available
when the Consolidated Financial Statements were prepared. Existing circumstances and assumptions about
future developments may, however, change due to market changes or circumstances beyond the control of
the Group. Such changes are reflected in the assumptions when they occur.
The most significant judgements, estimates and assumptions relate to the calculation of expected credit
losses (ECL), the estimation of the net realisable value of stock of property and the provisions for pending
litigation and claims, which are presented in Notes 5.1 to 5.3 below. Other judgements, estimates and
assumptions are disclosed in Notes 5.4 to 5.13.
5.1 Calculation of expected credit losses
The calculation of ECL requires management to apply significant judgement and make estimates and
assumptions, involving significant uncertainty at the time these are made. Changes to these estimates and
assumptions can result in significant changes to the timing and amount of ECL to be recognised. The
Group’s calculations are outputs of models, of underlying assumptions on the choice of variable inputs and
their interdependencies.
It has been the Group’s policy to regularly review its models in the context of actual loss experience and
adjust when necessary.
Elements of ECL models that are considered accounting judgements and estimates include:
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Annual Financial Report 2024
Notes to the Consolidated Financial Statements
5. Significant and other judgements, estimates and assumptions (continued)
5.1 Calculation of expected credit losses (continued)
Assessment of significant increase in credit risk (SICR)
IFRS 9 does not include a definition of significant increase in credit risk. The Group assesses whether
significant increase in credit risk has occurred since initial recognition using predominantly quantitative and
in certain cases qualitative information and backstop indicators. The determination of the relevant criteria to
determine whether a significant increase in credit risk has occurred, is based on statistical metrics and could
be subject to management judgement. The relevant criteria are set, monitored and updated on a yearly
basis by the Risk Management Division and endorsed by the Group Provisions Committee. Lifetime ECL
applies when a significant increase in credit risk has occurred on an individual or collective basis.
Determining the probability of default (PD) at initial recognition requires management estimates in
particular cases. Specifically, in the case of exposures existing prior to the adoption of IFRS 9, a
retrospective calculation of the PD is made in order to quantify the risk of each exposure at the time of the
initial recognition. In certain cases, estimates about the date of initial recognition might be required.
For the retail portfolio, the Group uses a PD at origination incorporating behavioural information (score
cards) whereas, for the corporate portfolio, the Group uses the internal credit rating information. For
revolving facilities, management estimates are required with respect to the lifetime and hence a behavioural
maturity model is utilised, assigning an expected maturity based on product and customer behaviour.
Scenarios and macroeconomic factors
The Group determines the ECL, which is a probability weighted amount, by evaluating a range of possible
outcomes. Management uses forward looking scenarios and assesses the suitability of weights used. These
are based on management’s assumptions taking into account macroeconomic, market and other factors.
Changes in these assumptions and in other external factors could significantly impact ECL. Macroeconomic
inputs and weights per scenario are monitored by the Economic Research Department and are based on
internal model analysis and expert judgement, considering also external forecasts.
The Cypriot economy has demonstrated remarkable resilience and growth in recent years, navigating
through global uncertainties and regional challenges. In 2024, the economy achieved a growth rate of
3.4%, driven by rising exports and strong economic activity in key sectors such as tourism, information and
communications, construction and trade. This follows a period of strong growth with an annual average of
5.1% in the period 2015-2023. The unemployment rate has remained low, dropping to 4.9% in 2024
indicating near-full employment conditions. Inflation has been successfully stabilized, with rates declining
from 3.9% in 2023 to 2.3% in 2024. General government debt metrics have significantly improved in recent
years. The government debt-to-GDP ratio dropped to 65.4% in December 2024 from 73.6% in 2023 and
113.6% at the end of 2020. Looking ahead, continued budgetary surpluses and favourable debt dynamics
are expected to further reduce the debt ratio, potentially dropping below 60% by 2026. Growth in the
medium term, is expected to continue to outpace eurozone peers. Growth is expected to average about 3%
annually in 2025-2027, driven by services exports and private consumption on the expenditure side and by
international business services and the ICT sector on the production side.
The credit profile of Cyprus has improved significantly in the more recent period, reflecting a solid medium-
term growth outlook, good institutional strength and effective policy making.
However, substantial risks remain in terms of the domestic operating environment, as well as the external
environment on which it depends. Public debt has dropped in relation to GDP, but government expenditures
need more rationalisation. In the banking sector non-performing exposures need to drop further. The
current account deficit remains sizable. At the same time long-term yields may remain elevated for longer,
despite interest rate cuts by the monetary policy, if inflation pressures increase and geopolitical
uncertainties escalate.
For the ECL, the Group updated its forward-looking scenarios, factoring in updated macroeconomic
assumptions and other monetary and fiscal developments at the national and the EU level based on
developments and events as at the reporting date.
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Notes to the Consolidated Financial Statements
5. Significant and other judgements, estimates and assumptions (continued)
5.1 Calculation of expected credit losses (continued)
For the ECL calculations, the Group uses an unbiased and probability-weighted amount that is determined
by evaluating a range of possible outcomes, as described in Note 2.17.5. The approach employed, involves
scenario generation, where the scenarios applied by the Group are anchored to the baseline scenario. All
scenarios are updated on a quarterly basis for the purposes of the ECL calculation in tandem with the
baseline scenario. The updated macroeconomic inputs (incorporating any uncertainties and downside risks)
are therefore reflected in the scenario parameters, starting from the baseline and updated in turn for the
adverse and the favourable scenarios accordingly. If the baseline becomes more pessimistic, then both the
favourable and downside scenarios would be adjusted accordingly, reflecting the fact that the economic
variables used in the scenarios are not constant but are conditional on the economy’s position in the
business cycle. A dynamic scenario approach is followed as explained above where the scenario parameters
derived, reflect the Group’s view of the economic conditions. The probability weights attached to the
scenarios are a function of their relative position on the distribution, with a lower probability weight
attached to the scenarios that were assessed to be more distant from the centre of the distribution. The
baseline scenario is defined over the range of values corresponding to 50% probability of equidistant
deviations around the mean of the historical distribution. The favourable and adverse scenarios are defined
over the range of values to the right and left of the distribution respectively, each corresponding to 25%
probability.
The most significant macroeconomic variables for each of the scenarios used by the Group as at 31
December 2024 and 2023 are presented in the table below. The Group uses three different economic
scenarios in the calculation of default probabilities and provisions. The scenarios factor-in updated
macroeconomic assumptions and other monetary and fiscal developments based on events as at the
reporting date. The Group has used the 30-50-20 probability structure for the adverse, baseline and
favourable scenarios respectively compared to the 25-50-25 structure derived using the method described
in Note 2.17.5 and above. This reflects management's view of specific characteristics of the Cyprus
economy that render it more vulnerable to external and internal shocks.
31 December 2024
Year Scenario Weight %
Real GDP (%
change)
Unemployment
rate (% of
labour force)
Consumer
Price Index
(average %
change)
RICS House
Properties
Price Index
(average %
change)
2025 Adverse 30.0 -1.4 5.4 -0.7 -3.9
Baseline 50.0 3.0 4.5 1.8 2.2
Favourable 20.0 4.2 4.4 2.5 3.8
2026 Adverse 30.0 -0.9 5.6 1.2 -0.2
Baseline 50.0 2.9 4.5 2.2 2.3
Favourable 20.0 3.1 4.3 2.1 2.7
2027 Adverse 30.0 2.0 5.3 1.8 2.3
Baseline 50.0 2.8 4.5 2.0 2.2
Favourable 20.0 2.5 4.4 2.0 2.6
2028 Adverse 30.0 3.4 5.2 1.9 2.9
Baseline 50.0 2.6 4.5 1.9 2.3
Favourable 20.0 2.4 4.4 1.9 2.6
2029 Adverse 30.0 2.8 5.2 1.9 2.5
Baseline 50.0 2.5 4.5 1.8 2.2
Favourable 20.0 2.4 4.4 1.9 2.3
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Notes to the Consolidated Financial Statements
5. Significant and other judgements, estimates and assumptions (continued)
5.1 Calculation of expected credit losses (continued)
31 December 2023
Year Scenario Weight %
Real GDP (%
change)
Unemployment
rate (% of
labour force)
Consumer
Price Index
(average %
change)
RICS House
Properties
Price Index
(average %
change)
2024 Adverse 30.0 -1.6 6.3 0.9 -3.1
Baseline 50.0 2.7 5.8 2.5 3.0
Favourable 20.0 3.5 5.6 3.1 3.7
2025 Adverse 30.0 -0.7 6.9 1.2 0.6
Baseline 50.0 2.6 5.4 2.5 2.3
Favourable 20.0 3.1 5.2 2.6 2.5
2026 Adverse 30.0 2.2 7.0 1.2 1.9
Baseline 50.0 2.6 5.1 2.1 2.2
Favourable 20.0 2.7 4.9 2.0 2.3
2027 Adverse 30.0 3.6 6.7 2.3 2.4
Baseline 50.0 2.4 4.9 2.3 2.2
Favourable 20.0 2.6 4.6 2.2 2.3
2028 Adverse 30.0 3.5 6.4 2.2 2.4
Baseline 50.0 2.3 4.6 2.2 2.3
Favourable 20.0 2.5 4.2 2.3 2.4
The adverse scenarios may outpace the base and favourable scenarios after the initial shock has been
adjusted to and the economy starts to expand from a lower base. Thus, in the adverse scenario GDP will
follow a growth trajectory that will ultimately equal and surpass the baseline before converging. Property
prices are determined by multiple factors with GDP growth featuring prominently.
The baseline scenario was updated for the 31 December 2024 reporting, considering available information
and relevant developments until then, and is described next. Growth moderated in 2023 following strong
recoveries in 2021-2022, but remained above the Euro area average, supported by the continued recovery
in tourism and expanding services activity. Real GDP increased by 2.6% on average in 2023 and growth
accelerated in 2024, averaging 3.4%. Tourist arrivals in Cyprus exceeded 4.0 million in 2024, up by an
annual 5.1%. Under the baseline scenario the economy is expected to advance by 3.0% in 2025 and
consumer price inflation will decelerate to 1.8%. House prices are expected to rise by 2.2% in 2025
following strong increases in 2022-2024.
The adverse scenario is consistent with assumptions for a global economic slowdown driven by geopolitical
tensions, tariff wars, elevated inflation expectations and the steepening of yield curves. The Cypriot
economy relies on services, particularly on tourism, international business, and information and
communication services with an outward orientation. This makes the Cypriot economy more exposed than
other economies to the international environment and terms of trade shocks. Weaker external demand will
lead to a slowdown of economic activity. The adverse scenario assumes a deeper impact of these conditions
on the real economy than under the baseline scenario. Under the adverse scenario, real GDP is expected to
drop by 1.4% in 2025 as a whole, and contract further by 0.9% in 2026. In the labour market the
unemployment rate will rise only modestly to 5.4% and inflation will actually turn negative by 0.7%. House
prices will also slow in line with the contraction in real GDP.
The Group uses actual values for the input variables. These values are sourced from the Cyprus Statistical
Service, the Eurostat, the Central Bank of Cyprus for the residential property price index, and the European
Central Bank for interest rates. Interest rates are also sourced from the Eurostat. In the case of property
prices, the Group additionally uses data from the Royal Institute of Chartered Surveyors. For the forward
reference period, the Group uses the forecast values for the same variables, as prepared by the BOC PCL's
Economic Research Department. The results of the internal forecast exercises are consistent with publicly
available forecasts from official sources including the European Commission, the International Monetary
Fund, the European Central Bank and the Ministry of Finance of the Republic of Cyprus.
Qualitative adjustments or overlays are occasionally made when inputs calculated do not capture all the
characteristics of the market. These are reviewed and adjusted, if considered necessary, by the Risk
Management Division, endorsed by the Group Provisions Committee and approved by the Board Risk and
Audit Committees. Qualitative adjustments or overlays are described in the below sections as applicable.
420
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
5. Significant and other judgements, estimates and assumptions (continued)
5.1 Calculation of expected credit losses (continued)
For Stage 3 customers, the calculation of individually assessed provisions is the weighted average of three
scenarios: base, adverse and favourable. The base scenario focuses on the following variables, which are
based on the specific facts and circumstances of each customer: the operational cash flows, the timing of
recovery of collaterals and the haircuts from the realisation of collateral. The base scenario is used to derive
additional either more favourable or more adverse scenarios. Under the adverse scenario, operational cash
flows are decreased by 50%, applied haircuts on real estate collateral are increased by 50% and the timing
of recovery of collaterals is increased by one year with reference to the baseline scenario, whereas under
the favourable scenario applied haircuts are decreased by 5%, with no change in the recovery period with
reference to the baseline scenario. Assumptions used in estimating expected future cash flows (including
cash flows that may result from the realisation of collateral) reflect current and expected future economic
conditions and are generally consistent with those used in the Stage 3 collectively assessed exposures.
The above assumptions are also influenced by the ongoing regulatory dialogue BOC PCL maintains with its
lead regulator, the ECB, and other regulatory guidance and interpretations issued by various regulatory and
industry bodies such as the ECB and the EBA.
Any changes in these assumptions or difference between assumptions made and actual results could result
in significant changes in the estimated amount of expected credit losses of loans and advances to
customers.
For collectively assessed customers the calculation is also the weighted average of three scenarios: base,
adverse and favourable.
Assessment of loss given default (LGD)
For the estimation of loss given default (LGD) key estimates are the timing and net recoverable amount
from repossession or realisation of collaterals (including through portfolio sales) which mainly comprise real
estate assets.
Assumptions have been made about the future changes in property values, as well as the timing for the
realisation of collateral, taxes and expenses on the repossession and subsequent sale of the collateral as
well as any other applicable haircuts. Indexation has been used as the basis to estimate updated market
values of properties, supplemented by management judgement where necessary, given the difficulty in
differentiating between short-term impacts and long-term structural changes and the shortage of market
evidence for comparison purposes. Assumptions were made on the basis of a macroeconomic scenario for
future changes in property prices and qualitative adjustments or overlays were applied to the projected
future property value increases to restrict the level of future property price growth to 0% for all scenarios
for loans and advances to customers which are secured by property collaterals.
At 31 December 2024, the weighted average haircut (including liquidity haircut and selling expenses) used
for the provision calculation for loans and advances to customers (for both Stage 1 and Stage 2 exposures
and collectively assessed Stage 3 exposures) is approximately 42% under the baseline scenario, excluding
those classified as held for sale (2023: approximately 31.3%). The increase in the haircut percentage is
primarily due to the calibration of the collateral realisation model during the first half of 2024, as explained
in section 'Calibration of IFRS 9 models and removal of overlays in relation to economic conditions'.
At 31 December 2024, the timing of recovery from real estate collaterals used for the provision calculation
for loans and advances to customers (for both Stage 1 and Stage 2 exposures and collectively assessed
Stage 3 exposures) has been estimated to be on average seven years under the baseline scenario,
excluding those classified as held for sale (2023: average of six years).
In the 2023 Financial Statements the above disclosures in relation to the weighted average haircut and
timing of recovery from real estate collaterals were by reference to exposures that were collectively
assessed and not including exposures which were assessed for staging purposes on an individual basis. The
comparative information presented above has been updated for aligning with the disclosure for the year
ended 31 December 2024.
For the calculation of individually assessed provisions of Stage 3 exposures, the timing of recovery of
collaterals as well as the haircuts used, are based on the specific facts and circumstances of each case. For
specific cases judgement may also be exercised over staging during the individual assessment.
421
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
5. Significant and other judgements, estimates and assumptions (continued)
5.1 Calculation of expected credit losses (continued)
Any changes in these assumptions or variance between assumptions made and actual results could result in
significant changes in the estimated amount of expected credit losses of loans and advances to customers.
Modelling adjustments
Forward looking models have been developed for ECL parameters (PD, EAD, LGD) for all portfolios and
segments sharing similar characteristics. Model validation (initial and periodic) is performed by the
independent validation unit within the Risk Management Division and involves assessment of a model under
both quantitative (i.e. stability and performance) and qualitative terms. The frequency and level of rigour of
model validation is commensurate to the overall use, complexity and materiality of the models, (i.e. risk
tiering). In certain cases, judgement is exercised in the form of expert judgment and/or management
overlay by applying adjustments on the modelled parameters. Governance of these models lies with the
Risk Management Division, where a governance process is in place around the determination of the
impairment measurement methodology including inputs, assumptions and overlays. Any management
overlays are prepared by the Risk Management Division, endorsed by the Group Provisions Committee and
approved by the Board Risk and Audit Committees.
Calibration of IFRS 9 models and removal of overlays in relation to economic conditions in 2024
During the year ended 31 December 2024, the Group performed a calibration of its IFRS 9 models which
involved the reassessment and update of the ECL model parameters (PDs, LGDs and cure rates) and SICR
thresholds so as to incorporate in the models the effects of the recent economic conditions and experience,
which were previously reflected in the ECL through the use of overlays. Further, the calibration involved the
Group updating and revising the LGD parameter, as part of the Group’s ongoing review and update of
models as to incorporate updated data information and to reflect an update on realisation paths and rates
applied.
More specifically, the Group proceeded with model calibrations affecting the probability of default parameter
(the ‘PD-macro’), the SICR parameter, the probability of cure model and the collateral realisation model and
introducing an LGD floor, as explained below:
i. The calibration of the PD-macro model included the introduction of inflation related variables and the
inclusion of post-COVID period data to capture the low-default environment as well as the
integration of a dynamic adjustment to calibrate (up or down) the model projection based on the
relationship between the past model projections and the actual observed defaults (structural breaks
in the relationship e.g. between a specific macro factor and the PD value). Refinement of the PD
adjustment factor was also made during 2024, to include a more extended observation period for the
SICR parameter. The net impact of this calibration was €4.2 million ECL release during the year
ended 31 December 2024.
ii. As a result of the PD-macro calibration, the SICR model was revisited following a statistical model
methodology calibration, whilst introducing an absolute threshold to increase stability. The
corresponding impact was €1.4 million ECL release during the year ended 31 December 2024 and
net transfer of related loans from Stage 2 to Stage 1.
iii. With respect to the probability of cure model, a different curability period was introduced for each
macro-economic scenario following a detailed statistical analysis examining the relationship of cure
rates with macro indicators and concluding that curability should differentiate at the level of the
scenario. The respective impact was an ECL charge of €2.1 million during the year ended 31
December 2024.
iv. As a result of calibrations (i)-(iii), the Group removed the prior year overlays applied in the context
of economic conditions with the resulting impact being €15.7 million ECL release during the year
ended 31 December 2024.
v. For the collateral realisation model, the Group has updated its LGD parameter with respect to the
path of realisation through portfolio sales, by increasing the likelihood of this realisation path. The
resulting impact was an ECL charge of €19.2 million during the year ended 31 December 2024.
vi. Lastly, the Group has incorporated a minimum LGD rate which provides for a minimum loss rate
(which acts as a floor) irrespective of the realisation path and value of collateral. This minimum LGD
was introduced as to capture the subjectivity and uncertainty involved in the value of recovery
assumptions (i.e. collateral recoverable amount, maximum recovery period, etc.) which impacts the
realisation amount. The corresponding impact was an ECL charge of €20.0 million during the year
ended 31 December 2024.
422
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
5. Significant and other judgements, estimates and assumptions (continued)
5.1 Calculation of expected credit losses (continued)
Overlays applied in the prior year:
i. Overlays introduced in prior years in the context of economic conditions from the consequences of
the Ukrainian crisis, in the collectively assessed population for exposures that were considered to be
the most vulnerable to the implications of the crisis, were removed during 2024. The impact on the
ECL from the application of these overlays was approximately €3.4 million ECL release during the
year ended 31 December 2023.
ii. In addition, the overlay on the PD (PD floored to the maximum of 2018/2019 level), introduced in
prior years to address specifically the high inflation environment affecting the economy, was
removed during 2024. The impact on the ECL from the application of this overlay was €7.2 million
charge during the year ended 31 December 2023.
iii. During the year ended 31 December 2023, an overlay for the LGD parameter has been integrated
through reduced curability period for Stage 2 and Stage 3 exposures with a resulting impact on the
ECL of €7 million charge during the year ended 31 December 2023.
The IFRS 9 models are reviewed regularly in order to incorporate the most recent information available and
to ensure that they perform adequately and that they are suitably representative when applied to the
current portfolio for the calculation of impairment loss allowances.
The Group has exercised critical judgement on a best effort basis, to consider all reasonable and
supportable information available at the time of the assessment of the ECL allowance as at 31 December
2024. The Group will continue to evaluate the ECL allowance and the related economic outlook each
quarter, so that any changes arising from the uncertainty on the macroeconomic outlook and geopolitical
developments, are timely captured.
Portfolio segmentation
The individual assessment is performed not only for individually significant assets but also for other
exposures meeting specific criteria determined by management. The selection criteria for the individually
assessed exposures are based on management judgement and are reviewed on a quarterly basis by the
Risk Management Division and are adjusted or enhanced, if deemed necessary. Following the wars in
Ukraine and the Middle East, the selection criteria were further enhanced to include significant exposures to
customers with passport of origin or residency in Russia, Ukraine or Belarus and/or business activity within
these countries and significant exposures with repayment deriving from Israel.
Further details on impairment allowances and related credit information are set out in Note 44.
In addition to the above significant judgments and assumptions made for the calculation of the ECL, the
Group also applies judgment for the following:
Expected lifetime of revolving facilities
The expected lifetime of revolving facilities is based on a behavioural maturity model for revolving facilities
based on BOC PCL's available historical data, where an expected maturity for each revolving facility based
on the customer's profile is assigned. The behavioural model was updated in the third quarter of 2023 to
reflect updates in customers' profile whilst maintaining the same model components.
Off-balance sheet credit exposures
ECL allowances also include allowances on off-balance sheet credit exposures represented by guarantees
given and by irrevocable commitments to disburse funds. Off-balance sheet credit exposures of the
individually assessed assets require assumptions on the probability, timing and amount of cash outflows.
For the collectively assessed off-balance sheet credit exposures, the allowance for provisions is calculated
using the Credit Conversion Factor (CCF) model.
5.2 Stock of property - estimation of net realisable value
Stock of property is measured at the lower of cost and net realisable value. The net realisable value is
determined through valuation techniques, requiring significant judgement, taking into account all available
reference points, such as expert valuation reports, current market conditions, applying an appropriate
illiquidity discount where considered necessary, taking into consideration observed sales, the holding period
of the asset, realisation strategy and any other relevant parameters. Selling expenses are deducted from
the realisable value.
More details on the stock of property are presented in Note 27.
423
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
5. Significant and other judgements, estimates and assumptions (continued)
5.3 Provisions for pending litigation and claims
The accounting policy for provisions for pending litigation, claims, regulatory and other matters is described
in Note 2.36.
Judgement is required in determining whether a present obligation exists and in estimating the probability,
timing and amount of any outflows. Provisions for pending litigation and claims usually require a higher
degree of judgement than other types of provisions. It is expected that the Group will continue to have a
material exposure to litigation and regulatory proceedings and investigations relating to legacy issues in the
medium term. The matters for which the Group determines that the probability of a future loss is more than
remote will change from time to time, as will the matters as to which a reliable estimate can be made and
the possible loss for such matters can be estimated. Actual results may prove to be significantly higher or
lower than the estimated possible loss in those matters, where an estimate was made. In addition, loss may
be incurred in matters with respect to which the Group believed the probability of loss was remote.
For a detailed description of the nature of uncertainties and assumptions and the effect on the amount and
timing of pending litigation and claims refer to Note 38.
5.4 Tax
The Group, is subject to tax in Cyprus and in the countries that it has run-down operations mainly in
Greece, Russia and Romania. Estimates are required in determining the provision for taxes at the reporting
date. The Group recognises income tax liabilities for transactions and assessments whose tax treatment is
uncertain. Where the final tax is different from the amounts initially recognised in the consolidated income
statement, such differences will impact the income tax expense, the tax liabilities and deferred tax assets or
liabilities of the period in which the final tax is agreed with the relevant tax authorities.
Deferred tax assets
In the absence of a specific accounting standard dedicated to the accounting of the asset that arose
pursuant to amendments in the Income Tax Law effected in March 2019 which provides for the
recoverability of tax assets arising from transfer of tax losses following resolution of a credit institution,
within the framework of 'The Resolution of Credit and Other Institutions', to be guaranteed (Note 17), BOC
PCL had exercised judgement in applying the guidance of IAS 12 as the most relevant available standard
and accounted for this asset item on the basis of IAS 12 principles relating to deferred tax assets.
For further details on such deferred tax assets refer to Note 17.
5.5 Fair value of investments and derivatives
The best evidence of fair value is a quoted price in an actively traded market. If the market for a financial
instrument is not active, a valuation technique is used. The majority of valuation techniques employed by
the Group use primarily observable market data and so the reliability of the fair value measurement is
relatively high.
However, certain financial instruments are valued on the basis of valuation techniques that feature one or
more significant inputs that are not observable. Valuation techniques that rely on non-observable inputs
require a higher level of management judgement to calculate a fair value than those based wholly on
observable inputs.
Valuation techniques used to calculate fair values include comparisons with similar financial instruments for
which market observable prices exist, discounted cash flow analysis and other valuation techniques
commonly used by market participants. Valuation techniques incorporate assumptions that other market
participants would use in their valuations, including assumptions about interest rate yield curves, exchange
rates, volatilities and default rates. When valuing instruments by reference to comparable instruments,
management takes into account the maturity, structure and rating of the instrument with which the position
held is being compared.
The Group uses models with only unobservable inputs for the valuation of certain unquoted equity
investments. In these cases, estimates are made to reflect uncertainties in fair values resulting from a lack
of market data inputs, for example, as a result of illiquidity in the market. Inputs into valuations based on
unobservable data are inherently uncertain because there is little or no current market data available from
which to determine the level at which an arm’s length transaction would occur under normal business
conditions. Unobservable inputs are determined based on the best information available.
424
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
5. Significant and other judgements, estimates and assumptions (continued)
5.5 Fair value of investments and derivatives (continued)
Further details on the fair value of assets and liabilities are disclosed in Notes 2.13.9 and 22.
5.6 Retirement benefits
The cost of defined benefit pension plans is determined using actuarial valuations. The actuarial valuations
involve making assumptions about discount rates, the expected rate of return on plan assets, future salary
increases, mortality rates as well as future pension increases where necessary. The Group’s management
sets these assumptions based on market expectations at the reporting date using its best estimates for
each parameter covering the period over which the obligations are to be settled. In determining the
appropriate discount rate, management considers the yield curve of high quality corporate bonds. In
determining other assumptions, a certain degree of judgement is required. Future salary increases are
based on expected future inflation rates for the specific country plus a margin to reflect the best possible
estimate relating to parameters such as productivity, workforce maturity and promotions. The expected
return on plan assets is based on the composition of each fund’s plan assets, estimating a different rate of
return for each asset class. Estimates of future inflation rates on salaries and expected rates of return of
plan assets represent management’s best estimates for these variables. These estimates are derived after
consultation with the Group’s advisors, and involve a degree of judgement. Due to the long-term nature of
these plans, such estimates are inherently uncertain.
Further details on retirement benefits are disclosed in Note 14.
5.7 Non-life insurance business
The Group is engaged in the provision of non-life insurance services. Risks under these policies usually
cover a period of 12 months.
A summary of the significant judgements and estimates made in the measurement of insurance and
reinsurance contract assets and liabilities is included in Note 5.9.
Further information on non-life insurance business is disclosed in Note 12.
5.8 Life insurance business
The Group is engaged in the provision of life insurance services. Whole life insurance plans (life plans) are
unit-linked contracts associated with assets where the amount payable in the case of death is the greater of
the sum insured and the value of investment units. Simple insurance or temporary term plans (term plans)
relate to fixed term duration plans for protection against death. In case of death within the coverage period,
the insured sum will be paid. Endowment insurance (such as investment plans/horizon plans/Capital builder
and Lifestart) refer to specific duration plans linked to investments, to create capital through systematic
investment in association with death insurance coverage whereby the higher of the sum insured and the
value of investment units is payable on death within the contract term.
A summary of the significant judgements and estimates made in the measurement of insurance and
reinsurance contract assets and liabilities is included in Note 5.9.
Further information on life insurance business is disclosed in Note 12.
5.9 Insurance and reinsurance contracts
The key assumptions concerning the future and other key sources of estimation uncertainty at the reporting
date, that have a significant risk of causing a material adjustment to the carrying amounts of insurance and
reinsurance assets and liabilities within the next financial year are discussed below. The Group based its
assumptions and estimates on parameters available by the reporting date. Existing circumstances and
assumptions about future developments, however, may change due to market changes or circumstances
arising that are beyond the control of the Group. Such changes are reflected in the assumptions when they
occur.
425
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
5. Significant and other judgements, estimates and assumptions (continued)
5.9 Insurance and reinsurance contracts (continued)
Estimates of future cash flows
In estimating future cash flows, the Group incorporates, in an unbiased way, all reasonable and supportable
information that is available without undue cost or effort at the reporting date. This information includes
both internal and external historical data about claims and other experience, updated to reflect current
expectations of future events.
Cash flows within the boundary of a contract are those that relate directly to the fulfilment of the contract,
including those for which the Group has discretion over the amount or timing. These include payments to
(or on behalf of) policyholders and other costs that are incurred in fulfilling contracts. These comprise both
an allocation of fixed and variable overheads.
The estimates of future cash flows reflect the Group’s view of current conditions at the reporting date, as
long as the estimates of any relevant market variables are consistent with observable market prices.
The following key assumptions were used when estimating future cash flows in relation to life insurance
contracts:
a) Mortality and morbidity rates
b) Expenses and inflation
c) Lapse and surrender rates
Mortality and morbidity rates
Assumptions are based on standard international tables of mortality and morbidity, according to the type of
contract. In addition, a study is performed based on the actual experience (actual deaths) of the insurance
company for comparison purposes and if sufficient evidence exists which is statistically reliable, the results
are incorporated in these tables. An increase in mortality rates will lead to a larger expected number of
claims (or claims could occur sooner than anticipated), which will increase the expenditure and reduce
profits for shareholders.
The table below sets out the percentage estimated to apply to industry mortality and morbidity tables in
estimating fulfilment cash flows:
Mortality Rates Mortality rates*
31 December
2024
31 December
2023
Males Smokers 61% A67/70 68% A67/70
Non-Smokers 43% A67/70 48.25% A67/70
Smokers
61% A67/70
rated down by 4
years
68% A67/70
rated down by 4
years
Females
Non-Smokers
43% A67/70
rated down by 4
years
48.25% A67/70
rated down by 4
years
* The Group uses A67/70 UK standard mortality table in setting the mortality assumption, since the Group’s
own claim experience is not sufficient to allow the development of its own mortality table. To reflect the
Group’s specific claims experience more accurately, a percentage is applied on the A67/70 UK standard
mortality table.
Expense and inflation
Expense assumptions are based on the actual costs of the insurance activities of the Group incurred within
the year. To derive the per-policy expense assumption, every year the Group performs an expense analysis
which is based on the Group’s insurance subsidiaries actual expenses. For the purpose of the expense
analysis, expenses are split into expenses which are attributable and non-attributable. The Group produces
various metrics/ratios to allocate the costs to the underlying products. Non-attributable expenses are
excluded from the analysis as these are not directly related to a group of insurance contracts.
An assumption is also made for the rate of increase in expenses in relation to the annual inflation rate. An
increase in the level of expenses would reduce profitability.
426
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
5. Significant and other judgements, estimates and assumptions (continued)
5.9 Insurance and reinsurance contracts (continued)
31 December
2024
31 December
2023
€000 €000
Inflation rate 4,00% 4,00%
Lapse and surrender rates
An analysis of contract termination rates is performed every year, using actual data from the insurance
company incorporation until the immediate preceding year. Rates vary according to the type and duration of
the plan.
Unit-Linked
(protection)
Unit-Linked
(savings)
Non-Linked
(term)
Non-Linked
(Cap. Builder &
Lifestart)
2024 2023 2024 2023 2024 2023 2024 2023
Year 1 3% 4% 6% 6% 5% 4% 3% 3%
Year 2 4% 5% 6% 6% 6% 6% 6% 7%
Year 3 4% 5% 5% 6% 5% 6% 6% 7%
Year 4 4% 5% 5% 6% 6% 7% 6% 6%
Year 5 4% 5% 4% 6% 6% 7% 6% 6%
Year 6+ 4% 5% 4% 5% 6% 8% 5% 6%
Discount rates
Discount rates are applied to adjust the estimates of future cash flows to reflect the time value of money
and the financial risks related to those cash flows, to the extent that the financial risks are not included in
the estimates of cash flows.
Discount rates should:
i. Reflect the time value of money, characteristics of the cash flows and liquidity characteristics of the
insurance contract
ii. Be consistent with observable current market prices (if any) for financial instruments with cash flows
whose characteristics are consistent with those of the insurance contracts (e.g., timing, currency and
liquidity)
iii. Exclude the effect of factors that influence such observable market prices, but do not affect the
future cash flows of the insurance contracts
IFRS 17 does not require a particular estimation technique for determining discount rates but provides two
alternative approaches that may be used to derive discount rates. The determination of discount rates may
be derived from a yield curve that reflects the current market rates of return of an actual or reference
portfolio of assets, adjusted to eliminate any factors that are not relevant to the insurance contracts (top-
down approach), or discount rates may be derived based on a liquid risk-free yield curve adjusted for an
illiquidity premium (bottom-up approach). The Group has elected to apply a bottom-up approach whereby
discount rates are derived based on a liquid risk free yield curve adjusted for an illiquidity premium which is
derived from each insurance subsidiary's own bond portfolio assets. Under the bottom-up approach, the risk
free yield curve should be based on interest rates that are risk-free without including any component of
credit risk and should be derived from each insurance subsidiary at which two parties are willing to
exchange interest obligations. It is therefore necessary for these to be available for different times
reflecting the liabilities of the insurance contracts. It should also be based on information from financial
markets. The Group has elected to use the EIOPA risk-free rate curve as the liquid risk-free curve as it
covers all the above requirements. An illiquidity premium is then added which is calculated by subtracting
the credit risk premium and risk-free rate from the Yield to Maturity ('YTM') of the own bond portfolio of
assets for each insurance subsidiary. The YTM represents the interest rate that would be required for the
portfolio’s future cash flows to equal its market price.
427
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
5. Significant and other judgements, estimates and assumptions (continued)
5.9 Insurance and reinsurance contracts (continued)
The rates applied for discounting future cash flows are listed below:
Year 1 Year 3 Year 5 Year 10 Year 20
31
December
2024
31
December
2023
31
December
2024
31
December
2023
31
December
2024
31
December
2023
31
December
2024
31
December
2023
31
December
2024
31
December
2023
Life insurance
contracts (unit-
linked) 2.5% 3.5% 2.4% 2.5% 2.4% 2.4% 2.5% 2.5% 2.5% 2.5%
Life insurance
contracts (non-
linked) 2.5% 3.5% 2.4% 2.6% 2.4% 2.5% 2.6% 2.5% 2.5% 2.5%
Non-life insurance
contracts 2.8% 4.6% 2.5% 3.8% 2.5% 3.7% 2.6% 3.7% 2.6% 3.7%
Investment return
The investment returns are the same as the discount rates applied.
Risk adjustment for non-financial risk
IFRS 17 provides limited prescriptive requirements as to the methodology to be used to calculate the risk
adjustment for non-financial risk and allows an entity to apply judgement in determining an appropriate
estimation technique.
Life insurance business and health insurance business
The Group has applied judgement in estimating the risk adjustment, in the following areas:
i. Risks included within the risk adjustment calculation the risk adjustment for non-financial risk is
the compensation that is required for bearing the uncertainty about the amount and timing of cash
flows that arises from insurance risk and other non-financial risks as the insurance contract is
fulfilled. In estimating the risk adjustment, the Group has considered the non-market risks which are
also allowed in the calculation of the Solvency II Risk Margin. These include life and health
underwriting risks whereas, as specified by the standard, counterparty and operational risks are
excluded.
ii. Method of calculation - the Group calculates a margin, above best estimate assumptions, for each
non-financial risk to which the Group is exposed through issuing insurance contracts. The margins
are set so that (in combination) they would cover potential losses from movements in non-financial
risks within a specified confidence level. The total of these margins is the risk adjustment. The Group
has applied judgement in setting the confidence level applied in the risk adjustment calculation,
based on the Group’s appetite for accepting the risk inherent in writing insurance contracts and the
compensation required for doing so.
The Group has estimated the risk adjustment using a hybrid of Cost of Capital (CoC) and Value at Risk
(VaR) techniques. The Group first uses the CoC technique to calculate Risk Adjustment, which is then scaled
up/down using the VaR technique, to reflect the Group’s risk appetite and overall strategy.
The CoC methodology assesses the cost of holding capital sufficient to cover the relevant risks over the
lifetime of the business. It determines a required compensation amount by discounting the projected cost of
the calculated capital and translating that compensation amount to a corresponding confidence level. The
Group uses the CoC technique to produce a normal distribution with:
i. the Best Estimate Liabilities (BEL) as the mean of the distribution, and
ii. the Best Estimate Liabilities plus the solvency capital requirement (SCR) as the 99,5% percentile of the
distribution.
The Group estimated the probability distribution of the expected present value of the future cash flows from
the contracts at each reporting date and calculates the risk adjustment for non-financial risk at value at risk
of the target confidence level. The Group uses a target 90% (2023: 90%) percentile for the confidence
level.
Non-life insurance business other than the health insurance business
For non-life insurance business the risk adjustment forms a key component of the LIC.
428
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
5. Significant and other judgements, estimates and assumptions (continued)
5.9 Insurance and reinsurance contracts (continued)
The risk adjustment for LRC forms part of the loss component calculation which is used to determine the
groupings of contracts that are expected to be onerous.
Risk adjustment for non-financial risk is determined to reflect the compensation that the Group would
require for bearing non-financial risk and its degree of risk aversion. It is determined separately for each
non-life line of business and allocated to groups of contracts based on the total premiums for each group. It
reflects the effects of the diversification benefits between the different lines of business, which are
determined using a correlation matrix technique available from EIOPA.
The risk adjustment for non-financial risk is determined using a confidence level technique which stems
from a hybrid CoC and VaR approach. To determine the risk adjustment for non-financial risk for non-life
reinsurance contracts, the Group applies this technique to the gross amounts and then by using gross to net
ratios it derives the amount of risk being transferred to the reinsurer as the difference between the two
results.
The Group estimates the probability distribution of the expected present value of the future cash flows from
the contracts at each reporting date and calculates the risk adjustment for non-financial risk at value at risk
of the target confidence level. The Group uses a target 75% (2023:75%) percentile for the confidence level.
CSM
The CSM of a group of contracts is recognised in the consolidated income statement to reflect services
provided in each year, by identifying the coverage units in the group, allocating the CSM remaining at the
end of the year equally to each coverage unit provided in the year and expected to be provided in future
years, and recognising in consolidated income statement the amount of the CSM allocated to coverage units
provided in the year. The number of coverage units is the quantity of services provided by the contracts in
the group, determined by considering for each contract the quantity of the benefits and its expected
coverage period. The coverage units are reviewed and updated at each reporting date.
Further details on insurance liabilities are disclosed in Note 31.
5.10 Classification of properties
The Group determines whether a property is classified as investment property or stock of property as
follows:
i. Investment properties comprise land and buildings that are not occupied for use by, or in the
operations of the Group, nor for sale in the ordinary course of business, but are held primarily to earn
rental income and/or capital appreciation. These buildings are substantially rented to tenants and not
intended to be sold in the ordinary course of business. Additionally, they comprise leased properties
which are acquired in exchange of debt and are leased out under operating leases.
ii. Stock of property comprises real estate assets held with an intention to be disposed of. This principally
relates to properties acquired through debt-for-property swaps and properties acquired through the
acquisition of certain operations of Laiki Bank in 2013 (except from those that are leased out and are
classified as investment properties).
5.11 Fair value of properties held for own use and investment properties
In accordance with the Group’s accounting policy, property held for own use, as well as investment
property, is measured at fair value. In the case of property held for own use, valuations are carried out
periodically so that the carrying value is not materially different from the fair value, whereas in the case of
investment property, the fair value is established at each reporting date. Valuations are carried out by
qualified valuers by applying valuation models recommended by internationally accepted valuation
standards.
In arriving at their estimates of the fair values of properties, the valuers use their market knowledge and
professional judgement and do not rely solely on historical transactional comparable information, taking into
consideration the greater degree of uncertainty that exists compared to a more active market. Depending
on the nature of the underlying asset and available market information, the determination of the fair value
of property may require the use of estimates such as future cash flows from assets and discount rates
applicable to those assets. All these estimates are based on local market conditions existing at the reporting
date.
429
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
5. Significant and other judgements, estimates and assumptions (continued)
5.11 Fair value of properties held for own use and investment properties (continued)
Further information on inputs used is disclosed in Note 22.
5.12 Leases
Incremental Borrowing Rate (IBR)
The determination of an IBR term structure which is used in the measurement of the present value of the
future lease payments as described in Note 2.25, inherently involves significant judgement. The IBR used
was based on the Cyprus Government yield curve, with no further adjustment, as a fair proxy for the
Group’s secured borrowing cost, for a time horizon in accordance to the lease term. The sensitivity analysis
on the yield curve performed by BOC PCL showed that the value of the lease liability and corresponding RoU
assets is relatively insensitive to changes in the IBR.
Lease term
In determining the lease term, management considers all facts and circumstances that could make a
contract enforceable, such as the economics of the contract. The following assumptions were made for the
duration of lease term depending on the contract terms:
i. For cancellable leases, an assessment was made at the initial application of the standard and
subsequently updated where considered appropriate, based on the horizon used in the Group’s
financial plan. The current medium term financial plan assessment is for a duration of 4 years. The
lease term was therefore based on an assessment of either 4 years (being the medium time horizon)
or 8 years (being an assessment of a longer time horizon).
ii. For non-cancellable leases, the lease term has been assessed to be the non-cancellable period.
iii. For leases with an option for renewal, the Group’s past practice regarding the period over which it
has typically used properties (whether leased or owned), and its economic reasons for doing so,
provide information that is helpful in assessing whether the lessee is reasonably certain to exercise,
or not to exercise, an option.
Low value assets
The Group has exercised judgement in determining the threshold of low value assets which was set at
€5,000.
Further details on the leases are disclosed in Note 42.
5.13 Classification of financial assets
The Group exercises judgement upon determining the classification of its financial assets, in relation to
business models and future cash flows.
Judgement is also required to determine the appropriate level at which the assessment of business models
needs to be performed. In general, the assessment for the classification of financial assets into the business
models is performed at the level of each business line. Further, the Group exercises judgement in
determining the effect of sales of financial instruments on its business model assessment.
The Group also applies judgement upon considering whether contractual features including interest rate
could significantly affect future cash flows. Furthermore, judgement is required when assessing whether
compensation paid or received on early termination of lending arrangements results in cash flows that are
not SPPI.
6. Segmental analysis
The Group’s activities are mainly concentrated in Cyprus. Cyprus operations are organised into operating
segments based on the line of business. The results of the overseas subsidiaries and branches of the Group,
namely in Greece, Romania and Russia, are presented within segment ‘Other’, given the size of these
operations which are in a run-down mode and relate to legacy operations of the Group. Further, the results
of certain small subsidiaries of the Group are allocated to the segments based on their key activities.
430
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
6. Segmental analysis (continued)
As from the first quarter of 2024, following an internal re-organisation, the activities previously reported
under segment ‘Wealth Management’ were reorganised and are now reported as follows: part of the
activities were undertaken by the newly set up unit, Affluent Banking which is presented and monitored
under ‘Retail’ and part of the activities are carried out by the Institutional Wealth Management and Custody,
which was transferred under and is now presented and monitored as part of ‘Treasury’. As a result of the
changes, ‘Wealth Management’ no longer comprises a separately reportable segment. The activities of the
subsidiary companies of the Group, CISCO and its subsidiary, which were part of the 'Wealth Management'
segment and whose activities relate to investment banking, brokerage, discretionary asset management
and investment advice services do not qualify as a material segment and are now presented within ‘Other’.
Comparative information in ‘Analysis by business line’, ‘Analysis of total revenue’ and ‘Analysis of assets and
liabilities’ in this note and comparative information in the ‘By business line’ analysis in Notes 14, 23, 30,
44.2, 44.3 and 44.5 was restated to reflect this change.
The operating segments are analysed below:
i. The Corporate, Small and Medium-sized Enterprises (SME) and Retail business lines are managing
loans and advances to customers. As from the first quarter of 2024, retail business line also includes
the Affluent Banking unit, which offers banking and investment services to its clients. Categorisation
of loans per customer group is detailed further below.
ii. IBU & International Corporate comprises of:
1. IBU, which specialises in the offering of banking services to the international corporate
customers based in Cyprus, particularly international business companies whose ownership
and business activities lie outside Cyprus, and non resident individual customers of BOC PCL.
2. International Corporate, which comprises of International Corporate Banking, Project Finance
& Loan Syndication and Shipping Centre. International Corporate Banking provides financing
from Cyprus in respect of projects based overseas with main focus being in Greece and the
United Kingdom. Project Finance & Loan Syndication acts as arranger or participant in large
international loan syndication transactions. Shipping Centre provides shipping financing
primarily for ocean-going cargo vessels.
iii. Restructuring and Recoveries is the specialised unit which was set up to tackle the Group’s loan
portfolio quality and manages exposures to borrowers in distress situation through innovative
solutions.
iv. The Real Estate Management Unit (REMU) manages properties acquired through debt-for-property
swaps and properties acquired through the acquisition of certain operations of Laiki Bank in 2013
and executes exit strategies in order to monetise these assets. REMU also includes other subsidiary
property companies of the Group.
v. Treasury is responsible for managing assets and liabilities within the Risk Appetite Framework set by
the Board of Directors. Treasury manages the Group’s liquid assets, investing in fixed income
securities and in the interbank market. This business line manages the interest rate and foreign
exchange risks to which the Group is exposed to and is also responsible for liquidity management
and for ensuring compliance with internal and regulatory liquidity guidelines. It is also responsible for
raising funding through the issuance of debt in the wholesale markets. As from the first quarter of
2024, Treasury also reports and monitors the Institutional Wealth Management and Custody unit,
which comprises of market execution and custody unit services along with asset management.
vi. The Insurance business line is involved in both life and non-life insurance business.
vii. Payment Services comprise the subsidiary company JCC, which is involved in the development of
inter-banking systems, acquiring and processing of debit and credit card transactions, other payment
services and other activities.
viii. The segment 'Other' includes central functions of BOC PCL such as finance, risk management,
compliance, legal, information technology, corporate affairs, human resources and other. These
functions provide services to the operating segments. Segment 'Other' also includes the subsidiary
company, CISCO and other small subsidiary companies in Cyprus (excluding the insurance
subsidiaries, property companies under REMU and the payment services subsidiary of the Group
(JCC)), as well as the overseas legacy activities of the Group.
BOC PCL broadly categorises its loans per customer group, in the following customer sectors:
i. Retail all individuals, regardless of the facility amount, and legal entities with facilities from BOC
PCL of up to €500 thousand, excluding business property loans, and/or annual credit turnover up to
€1 million.
ii. Small and medium-sized enterprises (SME) any company or group of companies (including
personal and housing loans to the directors or shareholders of a company) with facilities from BOC
PCL in the range of €500 thousand to €4 million and/or annual credit turnover in the range of €1
million to €10 million.
431
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
6. Segmental analysis (continued)
iii. Corporate any company or group of companies (including personal and housing loans to the
directors or shareholders of a company) with available credit lines with BOC PCL of over €4 million
and/or having a minimum annual credit turnover of over €10 million. These companies are either
local larger corporations or international companies or companies in the shipping sector. Lending
includes direct lending or through syndications.
Management monitors the operating results of each business segment separately for the purposes of
performance assessment and resource allocation. Segment performance is evaluated based on profit after
tax and non-controlling interests. Inter-segment transactions and balances are eliminated on consolidation.
Operating segment disclosures are provided as presented to the Group Executive Committee.
Income and expenses associated with each business line are included within the business line results for
determining its performance. Fund transfer pricing and internal charges methodologies are applied between
the business lines as to reflect the performance of each business line. Income and expenses incurred
directly by the business lines are allocated to the business lines as incurred. Indirect income and expenses
are re-allocated from the central functions to the business lines. For the purposes of the Cyprus analysis by
business line, notional tax rate is charged/credited to the profit or loss before tax of each business line.
The loans and advances to customers, the customer deposits and the related income and expense are
generally included in the segment where the business is managed, instead of the segment where the
transaction is recorded.
432
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
6. Segmental analysis (continued)
Analysis by business line
Corporate
IBU &
International
corporate
SME Retail
Restructuring
and recoveries
REMU Insurance Treasury
Payment
services
Other Total
2024
€000 €000 €000 €000 €000 €000 €000 €000 €000 €000 €000
Net interest income/(expense) 157,910 159,223 58,978 419,895 14,656 (23,185) 19 38,009 - (4,041) 821,464
Net fee and commission income/(expense) 20,203 48,744 9,698 66,834 2,178 (99) (8,796) 4,324 28,271 5,586 176,943
Net foreign exchange gains/(losses) 1,351 6,813 775 2,683 36 - - 15,546 (18) 99 27,285
Net gains on financial instruments 1,232 - - - - 4 2,372 - 2,587 4,477 10,672
Net (losses)/gains on derecognition of financial assets measured at amortised cost (8,843) (670) (309) (1,416) 11,559 - - (326) - (8) (13)
Net insurance result - - - - - - 46,191 - - - 46,191
Net losses from revaluation and disposal of investment properties - - - - - (118) (446) - - (866) (1,430)
Net gains/(losses) on disposal of stock of property - - - - - 693 - - - (477) 216
Other income
14 10 14 219 70 4,321 2,647 - 3,828 3,258 14,381
Total operating income 171,867 214,120 69,156 488,215 28,499 (18,384) 41,987 57,553 34,668 8,028 1,095,709
Staff costs (7,869) (14,513) (5,960) (59,808) (9,621) (3,408) (3,657) (3,017) (9,591) (85,618) (203,062)
Special levy on deposits and other levies/contributions (4,439) (7,843) (2,143) (24,355) (40) - - (295) - - (39,115)
Provisions for pending litigation, claims, regulatory and other matters (net of reversals) - - - - 13,651 - - - 1,721 (27,147) (11,775)
Other operating expenses
(32,501) (19,885) (15,170) (100,734) (8,900) (14,827) (5,058) (12,711) (13,974) 60,111 (163,649)
Operating profit/(loss) before credit losses and impairment 127,058 171,879 45,883 303,318 23,589 (36,619) 33,272 41,530 12,824 (44,626) 678,108
Credit losses on financial assets 10,879 (807) (847) (9,956) (30,580) (1,047) (312) 869 - 4 (31,797)
Impairment net of reversals on non-financial assets
- - - - - (50,041) - - - (5,999) (56,040)
Profit/(loss) before tax
137,937 171,072 45,036 293,362 (6,991) (87,707) 32,960 42,399 12,824 (50,621) 590,271
Income tax
(17,242) (21,384) (5,629) (36,670) 874 9,531 (2,894) (5,300) (1,381) (1,033) (81,128)
Profit/(loss) after tax
120,695 149,688 39,407 256,692 (6,117) (78,176) 30,066 37,099 11,443 (51,654) 509,143
Non-controlling interests-(profit)/loss
- - - - - 2,215 - - (2,856) (314) (955)
Profit/(loss) after tax attributable to the owners of the Company
120,695 149,688 39,407 256,692 (6,117) (75,961) 30,066 37,099 8,587 (51,968) 508,188
433
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
6. Segmental analysis (continued)
Analysis by business line (continued)
Corporate
IBU &
International
corporate
SME Retail
Restructuring
and recoveries
REMU Insurance Treasury
Payment
services
Other Total
2023 (restated)
€000 €000 €000 €000 €000 €000 €000 €000 €000 €000 €000
Net interest income/(expense) 165,640 155,678 56,351 394,125 17,702 (34,263) (2) 39,264 - (2,278) 792,217
Net fee and commission income/(expense) 19,798 51,679 10,452 65,020 2,844 (212) (8,350) 3,838 29,537 6,417 181,023
Net foreign exchange gains/(losses) 2,010 5,212 700 2,372 (171) (14) - 18,897 (287) (131) 28,588
Net gains on financial instruments 2,401 - - - - 7 5,648 3,583 1,007 134 12,780
Net gains/(losses) on derecognition of financial assets measured at amortised cost 4,400 (246) (2,299) (461) 6,770 - - (1,783) - (20) 6,361
Net insurance result - - - - - - 53,350 - - 138 53,488
Net gains/(losses) from revaluation and disposal of investment properties - - - - - 1,548 (331) - - (174) 1,043
Net gains on disposal of stock of property - - - - - 8,476 - - - 496 8,972
Other income
24 5 16 209 67 7,551 5,594 12 3,775 1,084 18,337
Total operating income 194,273 212,328 65,220 461,265 27,212 (16,907) 55,909 63,811 34,032 5,666 1,102,809
Staff costs (7,559) (13,156) (5,908) (52,548) (8,929) (3,917) (3,791) (4,272) (7,307) (84,879) (192,266)
Special levy on deposits and other levies/contributions (4,340) (8,765) (2,176) (26,789) (109) - - (201) - - (42,380)
Provisions for pending litigation, claims, regulatory and other matters (net of reversals) - - - - - - - - (380) (28,084) (28,464)
Other operating expenses
(36,392) (18,959) (14,597) (85,511) (11,506) (15,341) (4,591) (9,057) (12,342) 57,203 (151,093)
Operating profit/(loss) before credit losses and impairment 145,982 171,448 42,539 296,417 6,668 (36,165) 47,527 50,281 14,003 (50,094) 688,606
Credit losses on financial assets (36,553) (2,130) 625 (4,337) (30,419) (5,737) (229) 548 - (1,598) (79,830)
Impairment net of reversals on non-financial assets
- - - - - (46,307) - - - (545) (46,852)
Profit/(loss) before tax
109,429 169,318 43,164 292,080 (23,751) (88,209) 47,298 50,829 14,003 (52,237) 561,924
Income tax
(13,679) (21,165) (5,395) (36,512) 2,969 16,296 (4,201) (6,354) (2,070) (2,869) (72,980)
Profit/(loss) after tax
95,750 148,153 37,769 255,568 (20,782) (71,913) 43,097 44,475 11,933 (55,106) 488,944
Non-controlling interests-(profit)/loss
- - - - - 1,252 - - (2,984) (5) (1,737)
Profit/(loss) after tax attributable to the owners of the Company
95,750 148,153 37,769 255,568 (20,782) (70,661) 43,097 44,475 8,949 (55,111) 487,207
434
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
6. Segmental analysis (continued)
Analysis of total revenue
Total revenue includes net interest income, net fee and commission income, net foreign exchange gains, net gains/(losses) on financial instruments, net
gains/(losses) on derecognition of financial assets measured at amortised cost, net insurance result, net gains/(losses) from revaluation and disposal of
investment properties, net gains/(losses) on disposal of stock of property and other income. There was no revenue deriving from transactions with a single
external customer that amounted to 10% or more of Group revenue.
Corporate
IBU &
International
corporate
SME Retail
Restructuring
and recoveries
REMU Insurance Treasury
Payment
Services
Other Total
2024
€000 €000 €000 €000 €000 €000 €000 €000 €000 €000 €000
Revenue from third parties 193,280 118,263 60,097 255,129 29,720 5,707 50,580 343,314 28,801 10,818 1,095,709
Inter-segment (expense)/revenue
(21,413) 95,857 9,059 233,086 (1,221) (24,091) (8,593) (285,761) 5,867 (2,790) -
Total revenue
171,867 214,120 69,156 488,215 28,499 (18,384) 41,987 57,553 34,668 8,028 1,095,709
2023 (restated)
Revenue from third parties 219,193 124,579 56,574 250,424 27,719 17,778 64,101 307,002 28,889 6,550 1,102,809
Inter-segment (expense)/revenue
(24,920) 87,749 8,646 210,841 (507) (34,685) (8,192) (243,191) 5,143 (884) -
Total revenue
194,273 212,328 65,220 461,265 27,212 (16,907) 55,909 63,811 34,032 5,666 1,102,809
Analysis of assets and liabilities
Corporate
IBU &
International
corporate
SME Retail
Restructuring
and recoveries
REMU Insurance Treasury
Payment
Services
Other Total
2024
€000 €000 €000 €000 €000 €000 €000 €000 €000 €000 €000
Assets
Assets 3,506,922 1,078,202 960,321 4,544,575 113,338 742,194 1,053,971 13,640,957 133,198 914,216 26,687,894
Inter-segment assets
(65,959) - - - - (67,834) (19,446) - (24,883) (26,180) (204,302)
Total assets
3,440,963 1,078,202 960,321 4,544,575 113,338 674,360 1,034,525 13,640,957 108,315 888,036 26,483,592
2023 (restated)
Assets
Assets 3,469,090 880,219 942,490 4,351,607 213,477 895,374 919,427 13,971,313 93,536 1,055,699 26,792,232
Inter-segment assets
(35,367) - - - - (39,843) (19,443) - (33,058) (35,944) (163,655)
Total assets
3,433,723 880,219 942,490 4,351,607 213,477 855,531 899,984 13,971,313 60,478 1,019,755 26,628,577
435
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
6. Segmental analysis (continued)
Analysis of assets and liabilities (continued)
Corporate
IBU &
International
corporate
SME Retail
Restructuring
and recoveries
REMU Insurance Treasury
Payment
Services
Other Total
2024
€000 €000 €000 €000 €000 €000 €000 €000 €000 €000 €000
Liabilities
Liabilities 2,445,790 4,313,738 1,161,464 12,600,526 20,139 21,366 895,120 1,818,808 104,856 476,019 23,857,826
Inter-segment liabilities
(135,625) - - - - (14,636) (2,275) - (27,895) (23,871) (204,302)
Total liabilities
2,310,165 4,313,738 1,161,464 12,600,526 20,139 6,730 892,845 1,818,808 76,961 452,148 23,653,524
2023 (restated)
Liabilities
Liabilities 2,197,945 3,901,025 1,019,245 12,216,209 29,045 24,695 803,319 3,588,480 40,635 483,293 24,303,891
Inter-segment liabilities
(111,192) - - - - (11,667) (16,404) - - (24,392) (163,655)
Total liabilities
2,086,753 3,901,025 1,019,245 12,216,209 29,045 13,028 786,915 3,588,480 40,635 458,901 24,140,236
Segmental analysis of customer deposits and loans and advances to customers is presented in Notes 30 and Notes 23, 44.2 and 44.5 respectively.
436
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
6. Segmental analysis (continued)
Analysis of turnover
2024 2023
€000 €000
Net interest income 821,464 792,217
Net fee and commission income 176,943 181,023
Net foreign exchange gains 27,285 28,588
Net gains on financial instruments 10,672 12,780
Net (losses)/gains on derecognition of financial assets measured at amortised
cost
(13) 6,361
Net insurance result (Note 12) 46,191 53,488
Net (losses)/gains from revaluation and disposal of investment properties (1,430) 1,043
Net gains on disposal of stock of property 216 8,972
Other income
14,381 18,337
1,095,709 1,102,809
7. Interest income and income similar to interest income
Interest income
2024 2023
€000 €000
Financial assets at amortised cost:
- Loans and advances to customers 538,497 511,072
- Loans and advances to banks and central banks 297,255 321,828
- Reverse repurchase agreements 27,012 3,219
- Debt securities 97,628 56,906
- Other financial assets 16,877 19,774
Debt securities at FVOCI
22,651 18,078
999,920 930,877
Income similar to interest income
2024 2023
€000 €000
Loans and advances to customers measured at FVPL 8,841 11,489
Derivative financial instruments
1,322 1,303
10,163 12,792
437
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
8. Interest expense and expense similar to interest expense
Interest expense
2024 2023
Financial liabilities at amortised cost: €000 €000
- Customer deposits 84,199 32,358
- Funding from central banks and deposits by banks 30,549 74,393
- Debt securities in issue
50,686 22,091
- Subordinated liabilities 21,634 21,023
Interest expense on lease liabilities
262 294
187,330 150,159
Expense similar to interest expense
2024 2023
€000 €000
Derivative financial instruments
1,289 1,293
9. Fee and commission income and expense
Fee and commission income
2024 2023
€000 €000
Credit-related fees and commissions 55,939 54,020
Other banking commissions 86,885 92,086
Fees on servicing loans disposed of under Project Helix 3 - 646
Mutual funds and asset management fees 4,668 4,079
Brokerage commissions 1,375 1,146
Other commissions
35,551 36,366
184,418 188,343
Mutual funds and asset management fees relate to fiduciary and other similar activities.
Credit-related fees and commissions include commissions from credit card arrangements amounting to
€33,190 thousand (2023: €32,522 thousand). Other banking commissions include commissions from
payment orders amounting to €24,690 thousand (2023: €26,676 thousand) and account maintenance fees
of €29,462 thousand (2023: €29,420 thousand).
Fee and commission income is further divided into:
Fees earned from services that are provided over time:
2024 2023
€000 €000
Credit-related fees and commissions 25,132 26,879
Other banking commissions 43,710 44,150
Fees on servicing loans disposed of under Project Helix 3 - 646
Mutual funds and asset management fees
3,057 2,878
71,899 74,553
438
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
9. Fee and commission income and expense (continued)
Fees earned from point in time services:
2024 2023
€000 €000
Credit-related fees and commissions 30,807 27,141
Other banking commissions 43,175 47,936
Mutual funds and asset management fees 1,611 1,201
Brokerage commissions 1,375 1,146
Other commissions
35,551 36,366
112,519 113,790
Fee and commission expense
2024 2023
€000 €000
Banking commissions 6,681 6,784
Mutual funds and asset management fees 410 343
Brokerage commissions
384 193
7,475 7,320
10. Net foreign exchange gains
Net foreign exchange gains comprise of the conversion of monetary assets and liabilities in foreign currency
at the reporting date, realised exchange gains/(losses) from transactions in foreign currency settled during
the year, customer related foreign exchange and the revaluation of foreign exchange derivatives.
11. Net gains on financial instruments
2024 2023
€000 €000
Trading portfolio:
- derivative financial instruments 79 26
Other investments at FVPL:
- non-equity securities 6,942 1,268
- mutual funds 2,500 5,787
- equity securities (81) 1,618
Net losses on disposal of FVOCI debt securities - (438)
Net gains on loans and advances to customers measured at FVPL (Note 22) 1,232 2,401
Revaluation of financial instruments designated as fair value hedges:
- hedging instruments (Note 21) 44,132 (2,211)
- hedged items (Note 21)
(44,132) 4,329
10,672 12,780
439
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
12. Net insurance result
2024 2023
Life
insurance
Non-life
insurance
Total
Life
insurance
Non-life
insurance
Total
€000 €000 €000 €000 €000 €000
Insurance finance
income/(expense)
(60,640) (1,725) (62,365) (43,820) (1,269) (45,089)
Reinsurance finance
income/(expense)
(1,375) 647 (728) 2,114 449 2,563
Return on assets backing
insurance liabilities
59,186 - 59,186 43,486 - 43,486
Net insurance finance
income/(expense) and net
reinsurance finance
income/(expense)
(2,829) (1,078) (3,907) 1,780 (820) 960
Insurance revenue 54,150 95,920 150,070 57,081 88,694 145,775
Insurance service expenses (20,252) (52,921) (73,173) (25,259) (46,273) (71,532)
Other insurance related
income/(expense)
(106) - (106) (715) - (715)
Net insurance service result
33,792 42,999 76,791 31,107 42,421 73,528
Allocation of reinsurance
premiums
(18,340) (37,685) (56,025) (14,824) (34,498) (49,322)
Amounts recoverable from
reinsurers for incurred claims
12,325 17,007 29,332 11,853 16,469 28,322
Net reinsurance service result
(6,015) (20,678) (26,693) (2,971) (18,029) (21,000)
Net insurance result
24,948 21,243 46,191 29,916 23,572 53,488
The analysis of the insurance revenue recognised during the year is presented below:
2024 2023
€000 €000
Life insurance contracts
Amounts relating to the changes in the liability for remaining coverage
Expected incurred claims and insurance service expenses incurred in the year 34,183 37,129
Change in the risk adjustment for non-financial risk 1,047 1,306
Amount of CSM recognised in profit or loss 8,893 7,792
Other amounts, including experience adjustments for premium receipts 859 1,160
Amounts relating to recovery of insurance acquisition cash flows
Allocation of the portion of premiums that relate to the recovery of insurance
acquisition cash flows
349 228
Insurance revenue from contracts measured under GMM and VFA 45,331 47,615
Insurance revenue from contracts measured under PAA
8,819 9,466
Insurance revenue - life
54,150 57,081
Non-life insurance contracts
Insurance revenue from contracts measured under PAA
95,920 88,694
Insurance revenue - non-life
95,920 88,694
Insurance revenue
150,070 145,775
440
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
12. Net insurance result (continued)
The analysis of the insurance service expenses recognised during the year is presented below:
2024 2023
Life
insurance
Non-life
insurance
Total
Life
insurance
Non-life
insurance
Total
€000 €000 €000 €000 €000 €000
Incurred claims and directly
attributable expenses
(19,462) (39,840) (59,302) (24,446) (32,964) (57,410)
Amortisation of insurance
acquisition cash flows
(349) (6,945) (7,294) (227) (5,541) (5,768)
Insurance acquisition cash flows
expensed as incurred
(2,750) (6,317) (9,067) (2,581) (5,907) (8,488)
Reversals of losses/(losses) on
onerous contracts
413 (337) 76 1,145 (108) 1,037
Changes to liabilities for incurred
claims (LIC)
1,896 518 2,414 850 (1,753) (903)
Insurance service expenses
(20,252) (52,921) (73,173) (25,259) (46,273) (71,532)
The analysis of the net reinsurance service result from reinsurance contracts held, recognised during the
year is presented below:
2024 2023
Reinsurance contracts - life contracts €000 €000
Amounts relating to the changes in the assets for remaining coverage
Expected recovery for insurance service expenses incurred in the year (12,924) (10,087)
Change in the risk adjustment for non-financial risk (23) 41
Net cost/gain recognised in profit or loss
(2,665) (1,559)
Allocation of reinsurance premiums from contracts measured under GMM (15,612) (11,605)
Allocation of reinsurance premiums from contracts measured under PAA
(2,728) (3,219)
Allocation of reinsurance premiums
(18,340) (14,824)
Amounts recoverable for claims and other expenses incurred in the year 12,810 12,247
Changes in amounts recoverable arising from changes in liability for incurred
claims
(883) (394)
Changes in fulfilment cash flows which relate to onerous underlying contracts
398 -
Amounts recoverable from reinsurers for incurred claims
12,325 11,853
Net reinsurance service result - life
(6,015) (2,971)
Reinsurance contracts - non-life contracts
Allocation of reinsurance premiums from contracts measured under PAA
(37,685) (34,498)
Allocation of reinsurance premiums
(37,685) (34,498)
Amounts recoverable for claims and other expenses incurred in the year 12,106 13,346
Changes in amounts recoverable arising from changes in liability for incurred
claims
4,715 3,072
Changes in fulfilment cash flows which relate to onerous underlying contracts
186 51
Amounts recoverable from reinsurers for incurred claims
17,007 16,469
Net reinsurance service result - non-life
(20,678) (18,029)
Net reinsurance service result
(26,693) (21,000)
441
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
12. Net insurance result (continued)
The analysis of insurance finance income/(expense) and reinsurance finance income/(expense) recognised
during the year is presented below:
2024 2023
Life
insurance
Non-life
insurance
Total
Life
insurance
Non-life
insurance
Total
€000 €000 €000 €000 €000 €000
Changes in value of underlying
assets of direct participating
contracts
(59,346) - (59,346) (42,949) - (42,949)
Interest accreted to insurance
contracts using current financial
assumptions
(71) (1,371) (1,442) (307) (1,297) (1,604)
Interest accreted to insurance
contracts using locked-in rates
(60) - (60) 13 - 13
Changes in interest rates and
other financial assumptions
(1,163) (354) (1,517) (577) 28 (549)
Insurance finance
income/(expense)
(60,640) (1,725) (62,365) (43,820) (1,269) (45,089)
Interest accreted to reinsurance
contracts using current financial
assumptions
- 544 544 - 465 465
Interest accreted to reinsurance
contracts using locked-in rates
639 - 639 (85) - (85)
Changes in interest rates and
other financial assumptions
(2,014) 112 (1,902) 2,199 (19) 2,180
Changes in non-performance risk
of reinsurer
- (9) (9) - 3 3
Reinsurance finance
income/(expense)
(1,375) 647 (728) 2,114 449 2,563
13. Other income
2024 2023
€000 €000
Dividend income 183 856
Profit on sale and write-off of property and equipment and intangible assets 28 53
Rental income from investment properties 2,153 3,239
Rental income from stock of property 204 346
Income from hotel, golf and other leisure activities 2,036 3,463
Income from insurance compensation 1,889 5,093
Other income
7,888 5,287
14,381 18,337
The income from hotel, golf and other leisure activities primarily relates to activities of subsidiaries acquired
in debt satisfaction as part of loan restructuring activity.
442
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
14. Staff costs
Staff costs
2024 2023
€000 €000
Salaries 143,115 137,390
Employer's contributions 26,604 23,301
Variable compensation:
Accrual for short-term incentive award (Note 14.3) 10,090 11,488
Share-based benefits expense (Note 14.2) 932 595
Retirement benefit plan costs 12,782 12,072
Exit cost and other termination benefits
9,539 7,420
203,062 192,266
The number of persons employed by the Group as at 31 December 2024 was 2,880 (2023: 2,830).
Staff costs are presented in the Consolidated Income Statement net of software capitalisation costs and
costs included in the insurance contracts fulfilment cash flow liabilities under IFRS 17. An analysis of
expenses by nature incurred by the Group is included in Note 15.1.
The cost for the short-term incentive award comprises the cost for the short-term incentive award for the
performance year 2024 which amounts to €11,968 thousand (2023: €11,488 thousand), of which an
amount of €1,597 thousand (2023: €1,533 thousand) relates to employers' contributions accrual on 2024
STIP, and a credit amount of €1,878 thousand which relates to 2023 STIP.
During 2024, the Group provided for termination benefits to 57 (2023: 50) of the Group's full time
employees at a total cost of €9,539 thousand (2023: €7,420 thousand).
The following table shows the analysis per geographical location of the Group’s average number of
employees (full time) and analysis of the average number of employees in Cyprus per business line for 2024
and 2023.
2024
2023
(restated)
Corporate 52 53
IBU & International corporate
- IBU 212 211
- International corporate 7 14
Small and medium-sized enterprises 83 82
Retail 879 912
Restructuring and recoveries 120 132
REMU 39 41
Insurance 209 200
Treasury 37 30
Payment services 117 113
Other (primarily head office functions)
1,096 1,088
Total Cyprus 2,851 2,876
Other countries
7 7
2,858 2,883
443
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
14. Staff costs (continued)
14.1 Retirement benefits
In addition to the employer's contributions to state social insurance, the Group operates plans for the
provision of additional retirement benefits as described below:
2024 2023
€000 €000
Defined benefit plans 261 512
Defined contribution plans
13,624 12,226
13,885 12,738
During the year ended 31 December 2024 retirement benefit costs of €1,103 thousand are included within
net insurance service result as directly attributable expenses for the fulfilment of insurance contracts within
the scope of IFRS 17 (2023: €666 thousand) (Note 15.1).
Cyprus
The main retirement plan for the Group’s permanent employees in Cyprus (85% of total Group employees)
is a defined contribution plan. This plan provided for employer contributions of 9% for 2024 and 2023 and
employee contributions of 3%-10% of the employees’ gross salaries for both 2024 and 2023. This plan is
managed by an Administrative Committee appointed by the members.
A small number of employees of Group subsidiaries in Cyprus are also members of defined benefit plans.
These plans are funded with assets backing the obligations held in separate legal vehicles.
Greece
Following IFRIC’s decision in May 2021 about the periods of service to which an entity attributes benefit for
a particular defined benefit plan, the Group as at 31 December 2024 and 2023 does not have any
retirement benefits obligation for its employees in Greece, and as a result the accumulated actuarial
gains/losses attributable to these plans were derecognised since 31 December 2021.
United Kingdom
The Group has assumed in prior years the obligation of the defined benefit plan of employees of the former
subsidiary of the Group in the United Kingdom which was closed in December 2008 to future accrual of
benefits for active members. As at 31 December 2024 and 2023 the Group's remaining retirement benefit
obligation related to the UK pension plan.
In December 2024, the UK pension scheme undertook a bulk insurance buy-in transaction. The policy
purchased is designed to provide cash flows that match the amount and timing of the benefits payable to
the Scheme’s members giving protection against demographic and investment risks and meet the members’
corresponding defined benefit obligations. The buy-in policy is presented as a pension plan asset with the
fair value being equal to the present value of the scheme's defined benefit obligation.
Analysis of the results of the actuarial valuations for the defined benefit plans
2024 2023
Amounts recognised in the consolidated balance sheet €000 €000
Liabilities (Note 33) - 565
Assets (Note 28)
(1,767) (669)
(1,767) (104)
Total funded status at a surplus, amounts to €992 thousand (2023: total funded status at a surplus of
€7,141 thousand) that is not recognised as an asset on the basis that the Group has no unconditional right
to future economic benefits either via a refund or a reduction in future contributions.
444
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
14. Staff costs (continued)
14.1 Retirement benefits (continued)
The amounts recognised in the consolidated balance sheet and the movement in the net defined benefit obligation for the years ended 31 December 2024 and
2023 are presented below:
Present value of
obligation
Fair value of
plan assets
Net amount
before impact of
asset ceiling
Impact of
minimum
funding
requirement/
asset ceiling
Net defined
benefit liability
€000 €000 €000 €000 €000
1 January 2024
58,018 (65,263) (7,245) 7,141 (104)
Current service cost 119 - 119 - 119
Net interest expense/(income) 2,590 (2,637) (47) - (47)
Administration cost
- 189 189 - 189
Total amount recognised in the consolidated income
statement
2,709 (2,448) 261 - 261
Remeasurements:
Return on plan assets, excluding amounts included in
net interest expense
- 11,695 11,695 - 11,695
Actuarial gain from changes in financial assumptions (2,697) - (2,697) - (2,697)
Demographic assumptions (2,272) - (2,272) - (2,272)
Experience adjustments 298 - 298 - 298
Change in asset ceiling
- - - (6,840) (6,840)
Total amount recognised in the consolidated OCI
(4,671) 11,695 7,024 (6,840) 184
Exchange differences 2,806 (2,951) (145) 691 546
Contributions:
Employer - (2,654) (2,654) - (2,654)
Plan participants 180 (180) - - -
Benefits paid from the plans
(2,347) 2,347 - - -
31 December 2024
56,695 (59,454) (2,759) 992 (1,767)
445
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
14. Staff costs (continued)
14.1 Retirement benefits (continued)
Present value of
obligation
Fair value of plan
assets
Net amount before
impact of asset
ceiling
Impact of minimum
funding
requirement/ asset
ceiling
Net defined
benefit liability
€000 €000 €000 €000 €000
1 January 2023
54,743 (62,605) (7,862) 10,740 2,878
Current service cost 395 - 395 - 395
Net interest expense/(income)
2,624 (2,507) 117 - 117
Total amount recognised in the consolidated income
statement
3,019 (2,507) 512 - 512
Remeasurements:
Return on plan assets, excluding amounts included in
net interest expense
- 394 394 - 394
Actuarial loss from changes in financial assumptions 1,623 - 1,623 - 1,623
Demographic assumptions (605) - (605) - (605)
Experience adjustments 621 - 621 - 621
Asset adjustment - 1,600 1,600 - 1,600
Change in asset ceiling
- - - (4,253) (4,253)
Total amount recognised in the consolidated OCI
1,639 1,994 3,633 (4,253) (620)
Exchange differences 889 (1,465) (576) 654 78
Contributions:
Employer - (2,952) (2,952) - (2,952)
Plan participants 177 (177) - - -
Benefits paid from the plans
(2,449) 2,449 - - -
31 December 2023
58,018 (65,263) (7,245) 7,141 (104)
446
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
14. Staff costs (continued)
14.1 Retirement benefits (continued)
The actual return on plan assets for year 2024 was a loss of €9,247 thousand (2023: gain of €2,113
thousand) mainly due to the assets for the UK pension fund measured so that the fair value matches the
present value of the liability following the buy-in insurance policy.
The assets of funded plans are generally held in separately administered entities, either as specific assets or
as a proportion of a general fund, or as insurance contracts and are governed by local regulations and
practice in each country.
Pension plan assets are invested in different asset classes in order to maintain a balance between risk and
return. Investments are well diversified to limit the financial effect of the failure of any individual
investment. Through its defined benefit plans, the Group is exposed to a number of risks as outlined below:
Interest rate risk
The Group is exposed to interest rate risk due to the mismatch of the duration
of assets and liabilities.
Changes in bond yields
A decrease in corporate bond yields will increase the liabilities, although this
will be partially offset by an increase in the value of bond holdings.
Inflation risk
The Group faces inflation risk, since the liabilities are either directly (through
increases in pensions) or indirectly (through wage increases) exposed to
inflation risks. Investments to ensure inflation-linked returns (i.e. real returns
through investments such as equities, index-linked bonds and assets whose
return increases with increasing inflation) could be used to better match the
expected increases in liabilities.
Asset volatility
The liabilities are calculated using a discount rate set with reference to
corporate bond yields; if assets underperform this yield, a deficit will be
created.
The fair value of insurance policy related to buy-in transaction was estimated as the present value of the
underlying obligations covered by the insurance policy, hence the fair value of this asset at each reporting
date is impacted by the measurement uncertainty of the related scheme liabilities.
The major categories of plan assets as a percentage of total plan assets are as follows:
2024 2023
Equity securities 8% 10%
Debt securities 11% 66%
Loans and advances to banks 6% 21%
Funds 4% 3%
Buy-in insurance policy
71% -%
100% 100%
The assets held by the funded plans include equity securities issued by the Company, the fair value of which
as at 31 December 2024 is €257 thousand (2023: €186 thousand).
The Group expects to make additional contributions to defined benefit plans of €622 thousand during 2025.
At the end of the reporting period, the average duration of the defined benefit obligations was 13 years
(2023: 14 years).
447
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
14. Staff costs (continued)
14.1 Retirement benefits (continued)
Principal actuarial assumptions used in the actuarial valuations
The present value of the defined benefit obligations of the retirement plans is estimated annually using the
Projected Unit Credit Method of actuarial valuation, carried out by independent actuaries. The principal
actuarial assumptions used for the valuations of the retirement plans of the Group during 2024 and 2023 are
set out below:
2024 Cyprus UK
Discount rate 3.35% 5.15%
Inflation rate 2.00% 3.05%
Future salary increases 2.00% n/a
Rate of pension increase n/a 2.90%
Life expectancy for pensioners at age 60 n/a n/a
Life expectancy for pensioners at age 65
n/a
22.6 years M
24.3 years F
2023
Discount rate 3.27% 4.75%
Inflation rate 2.25% 3.00%
Future salary increases 2.25% n/a
Rate of pension increase n/a 2.80%
Life expectancy for pensioners at age 60
23.5 years M
29.6 years F n/a
Life expectancy for pensioners at age 65
n/a
23.0 years M
24.7 years F
The discount rate used in the actuarial valuations reflects the rate at which liabilities could effectively be
settled and is set by reference to market yields at the reporting date of high quality corporate bonds of
suitable maturity and currency. For the Group’s plans in the Eurozone which comprise 21% of the defined
benefit obligations, the Group adopted a full yield curve approach using AA- rated corporate bond data from
the iBoxx Euro Corporates AA10+ index. For the Group’s plan in the UK which comprises 79% of the defined
benefit obligations, the Group adopted a full yield curve approach using the discount rate that has been set
based on the yields on AA- rated corporate bonds with duration consistent with the scheme’s liabilities.
Under this approach, each future liability payment is discounted by a different discount rate that reflects its
exact timing.
To develop the assumptions relating to the expected rates of return on plan assets, the Group, in
consultation with its actuaries, uses forward-looking assumptions for each asset class reflecting market
conditions and future expectations at the reporting date. Adjustments are made annually to the expected
rate of return assumption based on revised expectations of future investment performance of asset classes,
changes to local legislation that may affect investment strategy, as well as changes to the target strategic
asset allocation.
The impact of significant assumptions' fluctuations on the defined benefit obligation as at 31 December
2024 and 2023 is presented below:
2024 2023
Variable
Change
+0.5%
Change
-0.5%
Change
+0.5%
Change
-0.5%
Discount rate -5.8% 6.2% -6.4% 6.8%
Inflation growth rate 3.8% -3.7% 4.2% -4.1%
Salary growth rate 0.9% -0.8% 1.1% -1.0%
Pension growth rate 0.1% -0.1% 0.1% -0.1%
Plus 1 year Minus 1 year Plus 1 year Minus 1 year
Life expectancy 3.3% -3.3% 3.8% -3.8%
448
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
14. Staff costs (continued)
14.1 Retirement benefits (continued)
The above sensitivity analysis (with the exception of the inflation sensitivity) is based on a change in one
assumption while holding all other assumptions constant. In practice this is unlikely to occur and some
changes of the assumptions may be correlated. The inflation sensitivity includes changes to any inflation-
linked benefit increases. When calculating the sensitivity of the defined benefit obligation to significant
assumptions, the same method has been applied as when calculating the pension liability recognised on the
consolidated balance sheet. The methods and types of assumptions used in preparing the sensitivity
analysis did not change compared to previous years.
14.2 Share-based compensation plan
Long-Term Incentive Plan
At the Annual General Meeting of the shareholders of the Company which took place on 20 May 2022, a
special resolution was approved for the establishment and implementation of the share based Long-Term
Incentive Plan (the ‘LTIP’) of Bank of Cyprus Holdings Public Limited Company.
The LTIP is an equity-settled share-based compensation plan for executive directors and senior
management of the Group. The LTIP provides for an award in the form of ordinary shares of the Company
based on certain non-market performance and service vesting conditions. Performance is measured over a
three-year period. The performance conditions are set by the Human Resources & Remuneration Committee
(HRRC) each year and may be differentiated at the HRRC's discretion to reflect the Group's strategic targets
and employees' personal performance. Performance will be assessed against an evaluation scorecard
consistent with the Group’s Medium-Term Strategic Targets containing both financial and non-financial
objectives, and including targets in the areas of: (i) Profitability; (ii) Asset quality; (iii) Capital adequacy;
(iv) Risk control & compliance; (v) Environmental, Social and Governance ('ESG'); and (vi) Customer
Experience (targets in the area of Customer Experience have been introduced for non-control functions from
2024). The awards ordinarily vest in six tranches, with 40% vesting in the year following the year the
performance period ends and the remaining 60% vesting in tranches (12%), on each of the first, second,
third, fourth and fifth anniversary of the first vesting date. For any award to vest the employee must be in
the employment of the Group up until the date of the vesting of such an award. Awards are subject to
potential forfeiture under certain leaver scenarios. Under certain circumstances the HRRC has the discretion
to determine whether the award will lapse and/or the extent to which the award will be vested.
The maximum number of shares that may be issued pursuant to the LTIP until the tenth anniversary of the
relevant resolution shall not exceed 5% of the issued ordinary share capital of the Company as at the date
of the resolution (being 22,309,996 ordinary shares of €0.10 each), as adjusted for any issuance or
cancellation of shares subsequently to the date of the resolution (excluding any issuances of shares
pursuant to the LTIP).
Under the LTIP the following share awards were outstanding as of 31 December 2024:
i. On 3 April 2024 (grant date) a maximum of 403,990 share awards were granted by the Company to 21
eligible employees, comprising the Extended Executive Committee of the Group. The awards granted in
April 2024 are subject to a three-year performance period 2024-2026 (with all performance conditions
being non-market performance conditions).
ii. On 3 October 2023 (grant date) a maximum of 479,160 share awards were granted by the Company to
21 eligible employees, comprising the Extended Executive Committee of the Group. The awards granted
in October 2023 are subject to a three-year performance period 2023-2025 (with all performance
conditions being non-market performance conditions).
iii. On 22 December 2022 (grant date) a maximum of 819,860 share awards were granted by the Company
to 22 eligible employees, comprising the Extended Executive Committee of the Group. The awards
granted in December 2022 were subject to a three-year performance period 2022-2024 (with all
performance conditions being non-market performance conditions). The amounts awarded under this
2022 LTIP cycle in early 2025 are disclosed in Note 49 of the Consolidated Financial Statements.
The following table presents movements in outstanding share-based awards during 2024 and 2023.
449
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
14. Staff costs (continued)
14.2 Share-based compensation plan (continued)
2024 2023
Number of
shares
Weighted
average grant
date fair value
Number of
shares
Weighted
average grant
date fair value
As at 1 January 1,209,036 2.15 819,860 1.69
Granted during the year 403,990 3.70 479,160 2.95
Change in estimate of number of awards to
vest
39,004 - - -
Vested during the year - - - -
Forfeited during the year
-
n/a
(89,984)
n/a
31 December
1,652,030 1,209,036
Assumptions
The fair value calculations as of the granting date for each of the share awards are calculated using the
Black-Scholes model. As the award is a share award (and does not contain any market-based performance
conditions) the fair value is based on the share price at the date of the grant.
14.3 Short-term incentive plan
Short-term incentive award refers to a Short-Term Incentive Plan first introduced by the Group in 2023.
This is an annual incentive which involves variable remuneration in the form of cash, or a combination of
cash and shares, to selected employees, and is driven by both delivery of the Group's Strategy, as well as
individual performance, in the relevant year. Executive Management are also eligible to be considered for
the short-term incentive award. The short-term incentive award is generally paid in cash and is non-
deferred, however, in cases where the total variable remuneration in a year (i.e including both amounts
under STIP and LTIP) of an employee exceeds a specified threshold as per regulatory guidelines, then at
least 50% of the total variable remuneration is awarded in shares. In cases where the total variable
remuneration threshold is exceeded, the STIP award (both the cash and share component, if any) vests
similarly to the vesting of LTIP award, i.e., 40% vests in the year following the performance year to which
the incentive award relates to, and the remaining 60% vests in tranches (12%) over five years.
Shares vesting as part of the short-term incentive award are subject to one-year retention period and 100%
of the award is subject to clawback provisions.
For the short-term incentive award for the performance year 2024 no amount is to be granted in the form
of shares (2023: €250 thousand of the total STIP for 2023 was granted in the form of shares). Further
information on the amounts awarded under the short-term incentive award for the performance year 2024
to Executive Directors and other key management personnel is disclosed in Note 49.
450
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
15. Other operating expenses
2024 2023
€000 €000
Technology and systems 34,684 31,159
Property-related costs 14,348 14,392
Consultancy, legal and other professional services fees 23,904 19,467
Insurance 6,121 7,096
Advertising and marketing 13,281 9,000
Incentives to performing customers 2,300 2,500
Depreciation of property and equipment (Note 15.1) 16,075 13,760
Amortisation of intangible assets (Note 15.1) 14,901 15,740
Communication expenses 5,936 6,119
Printing and stationery 1,685 1,641
Cash transfer expenses 3,352 3,193
Other operating expenses
27,062 24,773
163,649 148,840
Advisory and other transformation costs (non-recurring)
- 2,253
163,649 151,093
The Group has changed the description of the first line item in the table above to more appropriately reflect
the nature of this expense and has changed this to 'Technology and systems' from 'Repairs and
Maintenance'. As a result of this change, expenses of €2,678 thousand have been included in 'Property-
related costs' and €31,159 thousand in 'Technology and systems' in respect of the comparative information.
Advisory and other transformation costs comprise mainly fees to external advisors in relation to the
transformation program and other strategic projects of the Group and are considered to be non-recurring.
During the year ended 31 December 2024, the Group recognised €56 thousand relating to rent expense for
short-term leases, included within 'Property-related costs' (2023: €57 thousand).
Incentives to performing customers of €2,300 thousand during the year ended 31 December 2024 (2023:
€2,500 thousand relate to the Reward Programme launched in June 2023) relate to the Reward Programme
launched in August 2024 to reward performing borrowers through the Antamivi reward scheme.
Within total other operating expenses, an amount of €542 thousand (2023: €777 thousand) relates to
investment property that generated rental income.
Special levy on deposits and other levies/contributions as presented in the consolidated income statement
are set out below:
2024 2023
€000 €000
Special levy on deposits of credit institutions in Cyprus 29,448 23,300
Single Resolution Fund contribution - 5,477
Guarantee fee on annual deferred tax credit (Note 17) 5,364 5,364
Contribution to Deposit Guarantee Fund
4,303 8,239
39,115 42,380
The special levy on credit institutions in Cyprus (the Special Levy) is imposed on the level of deposits as at
the end of the previous quarter, at the rate of 0.0375% per quarter. Following an amendment of the
Imposition of Special Credit Institution Tax Law in 2017, the Single Resolution Fund ('SRF') contribution,
which is charged annually by the Single Resolution Board ('SRB'), reduces the charge of the Special Levy up
to the level of the total annual Special Levy charge. In February 2024, the SRB announced that no regular
annual contributions would be collected in 2024 from the institutions falling in scope of the SRF and
contributions would only be collected in the event of specific circumstances.
451
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
15. Other operating expenses (continued)
As from 1 January 2020 and until 3 July 2024 BOC PCL was subject to a contribution to the Deposit
Guarantee Fund (DGF) on a semi-annual basis. The contributions were calculated based on the Risk Based
Methodology (RBM) as approved by the management committee of the Deposit Guarantee and Resolution of
Credit and Other Institutions Schemes (DGS) and is publicly available on the CBC’s website. In line with the
RBM, the contributions are broadly calculated on the covered deposits of all authorised institutions and the
target level was to reach at least 0.8% of covered deposits by 3 July 2024. The management committee of
the DGS can decide to collect additional ex-ante contributions to achieve a higher return.
Fees to the independent auditors of the Group for audit and other professional services provided both in
Cyprus and overseas are presented in the table below:
PwC Ireland PwC Network firms
2024 2023 2024 2023
€000 €000 €000 €000
Audit of the individual and the Group financial
statements
318 433 1,793 1,684
Other assurance services 247 117 779 545
Tax compliance and advisory services - - 193 169
Other non-assurance services
35 - 448 326
282 117 1,420 1,040
600 550 3,213 2,724
Fees are exclusive of VAT.
Other assurance services fees relate primarily to the fees for limited assurance review of the Sustainability
Statement (2024 only), letters of comfort and interim review.
15.1 Expenses by nature
Analysis of staff costs and other operating expenses incurred by the Group by nature, is presented in the
table below:
2024
Directly
attributable
expenses
(Note 12)
Capitalised
as
internally
developed
computer
software
(Note 26)
Staff
costs
(Note 14)
Other
operating
expenses
(Note 15)
Total
€000 €000 €000 €000 €000
Salaries and employer's contributions 11,193 2,337 169,719 - 183,249
Variable compensation:
Accrual for short-term incentive award - - 10,090 - 10,090
Share-based benefits expense - - 932 - 932
Retirement benefit plan costs (Note 14.1) 1,103 - 12,782 - 13,885
Exit cost and other termination benefits - - 9,539 - 9,539
Depreciation (Note 25) 453 - - 7,698 8,151
Depreciation of RoU assets (Note 25) 1,451 - - 8,377 9,828
Amortisation of intangible assets (Note 26) 3,291 - - 14,901 18,192
Other operating expenses
4,148 - - 132,673 136,821
Total
21,639 2,337 203,062 163,649 390,687
452
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
15. Other operating expenses (continued)
15.1 Expenses by nature (continued)
2023
Directly
attributable
expenses
(Note 12)
Capitalised
as internally
developed
computer
software
(Note 26)
Staff
costs
(Note 14)
Other
operating
expenses
(Note 15)
Total
€000 €000 €000 €000 €000
Salaries and employer's contributions 9,898 2,202 160,691 - 172,791
Variable compensation:
Accrual for short-term incentive award - - 11,488 - 11,488
Share-based benefits expense - - 595 - 595
Retirement benefit plan costs (Note 14.1) 666 - 12,072 - 12,738
Exit cost and other termination benefits - - 7,420 - 7,420
Depreciation (Note 25) 387 - - 8,270 8,657
Depreciation of RoU assets (Note 25) 1,246 - - 5,490 6,736
Amortisation of intangible assets (Note 26) 3,120 - - 15,740 18,860
Other operating expenses
4,088 - - 121,593 125,681
Total
19,405 2,202 192,266 151,093 364,966
Directly attributable expenses are expenses incurred by the insurance subsidiaries of the Group that relate
directly to the fulfilment of insurance and re-insurance contracts within the scope of IFRS 17.
16. Credit losses on financial assets and impairment net of reversals on non-financial assets
2024 2023
Credit losses on financial assets €000 €000
Credit losses to cover credit risk on loans and advances to customers
Impairment net of reversals on loans and advances to customers (Note 44.5) 47,519 81,764
Recoveries of loans and advances to customers previously written off (13,520) (15,057)
Changes in expected cash flows (1,080) 4,824
Financial guarantees and commitments (Notes 44.6.1 and 44.6.2)
(1,006) 1,763
31,913 73,294
Credit losses on other financial instruments
Amortised cost debt securities (Note 20) (256) (531)
FVOCI debt securities (Note 20) (242) (380)
Loans and advances to banks (Note 19) 19 1
Balances with central banks (Note 19) (403) 330
Reverse repurchase agreements 9 20
Other financial assets
757 7,096
(116) 6,536
31,797 79,830
2024 2023
Impairment net of reversals on non-financial assets €000 €000
Stock of property (Note 27) 55,612 46,026
Other non-financial assets
428 826
56,040 46,852
453
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
17. Income tax
2024 2023
€000 €000
Current tax:
- Cyprus 45,214 46,319
Cyprus special defence contribution 121 47
Deferred tax charge 34,081 26,001
Prior years’ tax adjustments 515 (52)
Other tax charges
1,197 665
81,128 72,980
The reconciliation between the income tax expense and the profit before tax as estimated using the current
income tax rates is set out below:
2024 2023
€000 €000
Profit before tax
590,271 561,924
Income tax at the normal tax rates in Cyprus 73,784 70,241
Income tax effect of:
- expenses not deductible for income tax purposes 21,423 12,862
- income not subject to income tax (9,644) (7,366)
- other allowable deductions
(6,268) (3,417)
79,295 72,320
Cyprus special defence contribution 121 47
Prior years' tax adjustments 515 (52)
Other tax charges
1,197 665
81,128 72,980
The corporate income tax rate in Cyprus is 12.5% on taxable income (2023: 12.5%). The tax rates
prevailing in the countries the Group has entities incorporated, in the year ended 31 December 2024 were:
Greece 22% (2023: 22%), Romania 16% (2023: 16%) and Russia 20% (2023: 20%).
For life insurance business there is a minimum income tax charge of 1.5% on gross premiums (this is
included within 'Net insurance service result'), which amounted to €2,494 thousand for the year ended 31
December 2024 (2023: €2,148 thousand). Special defence contribution is payable on the 75% of rental
income at a rate of 3% (2023: 3%) and on interest income from activities outside the ordinary course of
business at a rate of 17% (2023: 30%).
The Group is subject to income tax in the various jurisdictions in which it operates and the calculation of the
Group’s income tax charge, top-up tax liability under Cyprus Pillar Two Law and provisions for income tax
necessarily involves a degree of estimation and judgement. There are transactions and calculations for
which the ultimate income tax treatment is uncertain and cannot be determined until resolution has been
reached with the relevant tax authority. The Group has a number of open income tax returns with various
income tax authorities and liabilities relating to these judgemental matters which are based on estimates of
whether additional income taxes will be due. In case the final income tax outcome of these matters is
different from the amounts that were initially recorded, such differences will impact the current and
deferred income tax assets and liabilities in the period in which such determination is made.
On 22 December 2022, the European Commission approved Directive 2022/2523 which provides for a
minimum effective tax rate of 15% for the global activities of large multinational groups (Pillar Two tax).
The Directive (EU) 2022/2523 that follows closely the OECD Inclusive Framework on Base Erosion and Profit
Shifting was voted into Law 151(Ι)/2024 (the 'Cyprus Pillar Two Law') in December 2024, effective for
financial years starting from 31 December 2023. The Group is in scope of the Cyprus Pillar Two Law for the
year ended 31 December 2024. The Group is eligible for the transitional provision under Article 55 of the
Cyprus Pillar Two Law which results in zeroing any top-up tax liability in Cyprus computed in accordance
with the rules laid out in the Cyprus Pillar Two Law for the year ended 31 December 2024. The Group does
not anticipate any top-up tax liability arising from the foreign jurisdictions in which it has subsidiary entities.
454
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
17. Income tax (continued)
Deferred tax
The movement of the net deferred tax assets is set out below:
Differences
between
capital
allowances
and
depreciation
Own property
revaluation
Stock of
property and
investment
properties
Unutilised
income tax
losses
carried
forward
(guaranteed
deferred tax
asset)
Other
temporary
differences
(net)
Total
2024 €000 €000 €000 €000 €000 €000
Net Deferred tax asset/(liability) as
at 1 January 2024
(10,329) (16,546) 7,542 189,546 (1,251) 168,962
Income Statement - tax
(charge)/credit
(762) - 3,004 (37,909) 1,586 (34,081)
Other comprehensive income - tax
credit
- 20 - - - 20
31 December 2024
(11,091) (16,526) 10,546 151,637 335 134,901
Deferred tax assets 87 29 13,393 151,637 1,698 166,844
Deferred tax liabilities
(11,178) (16,555) (2,847) - (1,363) (31,943)
31 December 2024
(11,091) (16,526) 10,546 151,637 335 134,901
2023
Net Deferred tax asset/(liability) as
at 1 January 2023
(10,528) (13,338) (2,847) 227,455 (7,442) 193,300
Income Statement - tax
credit/(charge)
199 - 10,389 (37,909) 1,320 (26,001)
Other comprehensive income - tax
charge
- (3,234) - - - (3,234)
Other transfers - 26 - - - 26
Transfer to current tax payables
following the adoption of IFRS 17
- - - - 4,871 4,871
31 December 2023
(10,329) (16,546) 7,542 189,546 (1,251) 168,962
Deferred tax assets 56 29 10,389 189,546 1,248 201,268
Deferred tax liabilities
(10,385) (16,575) (2,847) - (2,499) (32,306)
31 December 2023
(10,329) (16,546) 7,542 189,546 (1,251) 168,962
The deferred tax assets (DTA) relate to Cyprus operations.
455
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
17. Income tax (continued)
The Group offsets income tax assets and liabilities only if it has a legally enforceable right to set-off current
income tax assets and current income tax liabilities.
Income Tax Law Amendment 28(I) of 2019
On 1 March 2019, the Cyprus Parliament adopted legislative amendments to the Income Tax Law (the
'Law') which were published in the Official Gazette of the Republic on 15 March 2019 ('the amendments').
BOC PCL has DTA that meets the requirements of the Income Tax Law Amendment 28(I) of 2019 relating to
income tax losses transferred to BOC PCL as a result of the acquisition of certain operations of Laiki Bank,
on 29 March 2013, under ‘The Resolution of Credit and Other Institutions Law’. The DTA recognised upon
the acquisition of certain operations of Laiki in 2013 amounted to €417 million (corresponding to €3.3 billion
tax losses) for which BOC PCL paid a consideration as part of the respective acquisition. The period of
utilisation of the tax losses which may be converted into tax credits is eleven years following the
amendment of the Law in 2019, starting from 2018 i.e., by end of 2028.
As a result of the above Law, the Group has DTA amounting to €151,637 thousand as at 31 December 2024
(2023: €189,546 thousand) that meet the requirements under this Law, the recovery of which is
guaranteed. On an annual basis, an amount is either converted to annual tax credit and is reclassified from
the DTA to current tax receivables or it is used in the determination of the taxable income of the relevant
year, as the annual instalment can be claimed as a deductible expense. The annual instalment is reflected
as a charge in the Consolidated Income Statement.
The DTA subject to the Law is accounted for on the same basis as described in Note 2.11.
The Law, provides that an annual fee is charged on an annual basis until expiration of such losses in 2028.
The Group estimates that such fees could range to approximately €5,300 thousand per year (for each tax
year in scope i.e., since 2018) although the Group understands that such fee may fluctuate annually as to
be determined by the Ministry of Finance. An amount of €5,364 thousand that relates to the tax credit of
year 2024 (2023: €5,364 thousand) was recorded during the year ended 31 December 2024.
Accumulated income tax losses
The accumulated income tax losses are presented in the table below:
Total income
tax losses
Income tax
losses for
which a
deferred tax
asset was
recognised
Income tax
losses for
which no
deferred tax
asset was
recognised
2024 €000 €000 €000
Expiring within 5 years 464 - 464
Utilisation in annual instalments up to 2028
1,213,091 1,213,091 -
1,213,555 1,213,091 464
2023
Expiring within 5 years 45,851 - 45,851
Utilisation in annual instalments up to 2028
1,516,364 1,516,364 -
1,562,215 1,516,364 45,851
456
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
18. Earnings per share
Basic earnings per share
2024 2023
Profit for the year attributable to the owners of the Company
(€ thousand) (basic)
508,188 487,207
Weighted average number of shares in issue during the year, excluding
treasury shares (thousand)
444,090 446,058
Basic profit per share attributable to the owners of the Company
(€ cent)
114.4 109.2
Diluted earnings per share
2024 2023
Profit for the year attributable to the owners of the Company
(€ thousand)
508,188 487,207
Weighted average number of shares in issue during the year, excluding
treasury shares, adjusted for the dilutive effect of all rights on shares
(thousand)
445,687 447,158
Diluted profit per share attributable to the owners of the Company
(€ cent)
114.0 109.0
For diluted earnings per share the weighted average number of ordinary shares in issue is adjusted for the
dilutive effect of ordinary shares that may arise in respect of share awards granted to executive directors
and senior management of the Group under the Long-Term Incentive Plan (LTIP) for the performance years
2022-2024, 2023-2025 and 2024-2026 and the STIP award granted for the performance year 2023.
19. Cash, balances with central banks and loans and advances to banks
2024 2023
€000 €000
Cash 94,991 92,541
Balances with central banks 7,505,855 9,522,484
Allowance for expected credit losses (Note 16)
(120) (523)
7,600,726 9,614,502
2024 2023
€000 €000
Loans and advances to banks 820,615 384,824
Allowance for expected credit losses (Note 16)
(41) (22)
820,574 384,802
Balances with central banks are classified as Stage 1.
The ECL release (Note 16) on balances with central banks for the year ended 31 December 2024 amounted
to €403 thousand (2023: ECL charge of €330 thousand).
An analysis of the movement of the gross carrying amount before ECL and ECL of loans and advances to
banks is presented in the table below:
2024 2023
Gross carrying
amount
ECL
Gross carrying
amount
ECL
€000 €000 €000 €000
1 January 384,824 (22) 204,832 (21)
Net increase/(decrease) 435,792 - 180,043 -
Changes to models and inputs used for ECL
calculation (Note 16)
- (19) - (1)
Foreign exchange adjustments
(1) - (51) -
31 December
820,615 (41) 384,824 (22)
457
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
19. Cash, balances with central banks and loans and advances to banks (continued)
All loans and advances to banks are classified as Stage 1.
Balances with central banks include obligatory deposits for liquidity purposes which amount to €117,702
thousand as at 31 December 2024 (2023: €59,179 thousand) (Note 41). The average balance of obligatory
deposits that should be maintained with central banks was set at €194,636 thousand for the period of
December 2024 to February 2025 (2023: €186,794 thousand for the period December 2023 to January
2024).
The credit rating analysis of balances with central banks and loans and advances to banks by independent
credit rating agencies is set out in Note 44.11.
Loans and advances to banks earn interest based on the interbank rate of the relevant term and currency.
20. Investments
The analysis of the Group’s investments is presented in the table below:
2024 2023
€000 €000
Investments at FVPL 136,629 135,275
Investments at FVOCI 416,077 443,420
Investments at amortised cost
3,805,637 3,116,714
4,358,343 3,695,409
Out of these, the amounts pledged as collateral are shown below:
2024 2023
Investments pledged as collateral €000 €000
Investments at FVOCI - 25,458
Investments at amortised cost
39,958 234,553
39,958 260,011
Investments pledged as collateral as at 31 December 2024 are mainly used as supplementary assets for the
covered bond (Note 46). As at 31 December 2023, debt securities collateralised were primarily used for the
amounts borrowed from the ECB Targeted Longer-Term Refinancing Operations (TLTRO III) (Note 29) which
was fully repaid in the year ended 31 December 2024. Encumbered assets are disclosed in Note 46.
The maximum exposure to credit risk for debt securities is disclosed in Note 44.1 and the debt securities
price risk sensitivity analysis is disclosed in Note 45.
The increase in the investment portfolio as at 31 December 2024 is consistent with the strategy of the
Group to grow the fixed income portfolio.
The credit rating analysis of investments is disclosed in Note 44.11.
Investments at fair value through profit or loss
2024 2023
€000 €000
Other non-equity securities 10,702 3,611
Equity securities 837 903
Mutual funds
125,090 130,761
136,629 135,275
458
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
20. Investments (continued)
Investments at FVOCI
2024 2023
€000 €000
Debt securities 406,540 431,068
Equity securities
9,537 12,352
416,077 443,420
Investments at amortised cost
2024 2023
€000 €000
Debt securities
3,805,637 3,116,714
Further analysis of the Group's investments is provided in the tables below.
Equity securities
FVPL FVOCI Total
2024
€000 €000 €000
Listed on the Cyprus Stock Exchange - 6 6
Listed on other stock exchanges 837 60 897
Unlisted
- 9,471 9,471
837 9,537 10,374
FVPL FVOCI Total
2023
€000 €000 €000
Listed on the Cyprus Stock Exchange - 728 728
Listed on other stock exchanges 903 58 961
Unlisted
- 11,566 11,566
903 12,352 13,255
The Group irrevocably made the election to classify its equity investments as equity investments at FVOCI
on the basis that these are not held for trading. Their carrying value amounts to €9,537 thousand at 31
December 2024 and is equal to their fair value (2023: €12,352 thousand).
Equity investments at FVOCI comprise mainly investments in private Cyprus registered companies, acquired
through loan restructuring activity and specifically through debt for equity swaps.
Dividend income amounting to €183 thousand has been received and recognised during the year ended 31
December 2024 in other income (2023: €856 thousand) (Note 13).
During the year ended 31 December 2024, holdings of equity investments measured at FVOCI with a
carrying value of €812 thousand have been disposed of (2023: €702 thousand).
459
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
20. Investments (continued)
Mutual funds
FVPL
2024 €000
Listed on other stock exchanges 30,740
Unlisted
94,350
125,090
FVPL
2023 €000
Listed on other stock exchanges 35,192
Unlisted
95,569
130,761
The majority of the unlisted mutual funds relate to investments whose underlying assets are listed on stock
exchanges and are therefore presented in Level 2 hierarchy in Note 22.
Debt securities and other non-equity securities
Analysis by issuer type FVPL FVOCI
Amortised
cost
Total
2024 €000 €000 €000 €000
Cyprus government - 287,590 735,617 1,023,207
Other governments - 24,735 1,056,915 1,081,650
Financial institutions - 65,822 1,084,888 1,150,710
Other financial corporations 10,702 - 57,258 67,960
Supranational organisations - 23,462 696,260 719,722
Other non-financial corporations - 4,972 175,431 180,403
Allowance for expected credit losses
- (41) (732) (773)
10,702 406,540 3,805,637 4,222,879
FVPL FVOCI
Amortised
cost
Total
2023 €000 €000 €000 €000
Cyprus government - 315,844 611,199 927,043
Other governments - 10,317 751,399 761,716
Financial institutions - 81,803 1,046,525 1,128,328
Other financial corporations 3,611 - 47,483 51,094
Supranational organisations - 18,439 550,441 568,880
Other non-financial corporations - 4,948 110,655 115,603
Allowance for expected credit losses
- (283) (988) (1,271)
3,611 431,068 3,116,714 3,551,393
460
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
20. Investments (continued)
Geographic dispersion by country of issuer FVPL FVOCI
Amortised
cost
Total
2024 €000 €000 €000 €000
Cyprus - 287,590 737,640 1,025,230
Greece - 11,097 78,492 89,589
Germany - 2,934 217,589 220,523
France - 23,140 344,597 367,737
Other European Union countries - 31,201 1,129,546 1,160,747
United Kingdom - - 18,094 18,094
USA and Canada 10,702 4,091 291,982 306,775
Other countries - 23,066 292,169 315,235
Supranational organisations - 23,462 696,260 719,722
Allowance for expected credit losses
- (41) (732) (773)
10,702 406,540 3,805,637 4,222,879
FVPL FVOCI Amortised cost Total
2023 €000 €000 €000 €000
Cyprus - 315,844 621,617 937,461
Greece - 18,793 60,516 79,309
Germany - - 210,519 210,519
France - 31,662 283,256 314,918
Other European Union countries - 20,345 741,331 761,676
United Kingdom - - 18,098 18,098
USA and Canada 3,611 4,078 273,471 281,160
Other countries - 22,190 358,453 380,643
Supranational organisations - 18,439 550,441 568,880
Allowance for expected credit losses
- (283) (988) (1,271)
3,611 431,068 3,116,714 3,551,393
'Other countries' include exposures in Israel amounting to €31,065 thousand as at 31 December 2024
(2023: €46,715 thousand).
Analysis by currency
FVPL FVOCI
Amortised
cost
Total
2024 €000 €000 €000 €000
Euro - 387,000 3,510,264 3,897,264
US dollar 10,702 19,581 283,963 314,246
Pound sterling - - 12,142 12,142
Allowance for expected credit losses
- (41) (732) (773)
10,702 406,540 3,805,637 4,222,879
FVPL FVOCI Amortised cost Total
2023 €000 €000 €000 €000
Euro - 412,913 2,877,334 3,290,247
US dollar 3,611 18,438 228,779 250,828
Pound sterling - - 11,589 11,589
Allowance for expected credit losses
- (283) (988) (1,271)
3,611 431,068 3,116,714 3,551,393
461
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
20. Investments (continued)
Listing analysis FVPL FVOCI
Amortised
cost
Total
2024 €000 €000 €000 €000
Listed on the Cyprus Stock Exchange - - 33,884 33,884
Listed on other stock exchanges - 406,581 3,772,485 4,179,066
Unlisted 10,702 - - 10,702
Allowance for expected credit losses
- (41) (732) (773)
10,702 406,540 3,805,637 4,222,879
FVPL FVOCI Amortised cost Total
2023 €000 €000 €000 €000
Listed on the Cyprus Stock Exchange - - 4,567 4,567
Listed on other stock exchanges - 431,351 3,113,135 3,544,486
Unlisted 3,611 - - 3,611
Allowance for expected credit losses
- (283) (988) (1,271)
3,611 431,068 3,116,714 3,551,393
The Group uses fair value hedging to manage the interest rate risk in relation to its FVOCI bonds (Note 21).
An analysis of the movement of the gross debt securities at FVOCI and ECL of debt securities at FVOCI is
presented in the table below:
2024 2023
Gross debt
securities
ECL
Gross debt
securities
ECL
€000 €000 €000 €000
1 January 431,351 (283) 454,438 (663)
New assets acquired in the year 45,316 - 84,700 -
Assets derecognised and/or redeemed in the
year (Note 16)
(75,871) 68 (128,929) 39
Interest accrued and amortisation (2,959) - (1,728) -
Foreign exchange adjustments 1,188 - (640) -
Changes to models and inputs used for ECL
calculations (Note 16)
- 174 - 341
Changes in fair value
7,556 - 23,510 -
31 December
406,581 (41) 431,351 (283)
All debt securities measured at FVOCI are classified as Stage 1 as at 31 December 2024 and 31 December
2023.
462
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
20. Investments (continued)
An analysis of the movement in the gross carrying amount and ECL of the debt securities at amortised cost
is presented in the table below:
2024 2023
Gross debt
securities ECL
Gross debt
securities ECL
€000 €000 €000 €000
1 January 3,117,702 (988) 2,047,638 (1,519)
New assets acquired in the year 1,388,497 - 1,472,417 -
Assets derecognised and/or redeemed in the
year (Note 16)
(758,747) 177 (428,958) 102
Fair value due to hedging relationship 2,362 - 2,674 -
Interest accrued and amortisation 39,809 - 31,326 -
Changes to models and inputs used for ECL
calculation (Note 16)
- 79 - 429
Foreign exchange adjustments
16,746 - (7,395) -
31 December
3,806,369 (732) 3,117,702 (988)
All debt securities measured at amortised cost are classified as Stage 1 as at 31 December 2024 and 31
December 2023.
There were no reclassifications of investments during the year ended 31 December 2024 and 2023.
The fair value of the financial assets that have been reclassified out of FVPL to FVOCI on transition to IFRS
9, amounts to €6,932 thousand at 31 December 2024 (2023: €7,149 thousand). The fair value gain that
would have been recognised in the consolidated income statement during the year ended 31 December
2024 if these financial assets had not been reclassified as part of the transition to IFRS 9, amounts to €6
thousand (2023: loss of €140 thousand). The effective interest rate of these instruments is 1.6%-5.0%
(2023: 1.6%-5.0%) per annum and the respective interest income during the year ended 31 December
2024 amounts to €206 thousand (2023: €227 thousand).
21. Derivative financial instruments
The contract amount and fair value of the derivative financial instruments is set out below:
2024 2023
Fair value Fair value
Contract
amount
Assets Liabilities
Contract
amount
Assets Liabilities
€000 €000 €000 €000 €000 €000
Trading derivatives
Forward exchange rate contracts 23,232 171 126 23,960 205 184
Currency swaps 926,195 7,662 517 986,259 136 13,278
Interest rate swaps - - - 13,460 189 181
Currency options 472 455 17 44 2 42
Interest rate caps/floors
18,130 945 945 166,075 1,843 1,844
968,029 9,233 1,605 1,189,798 2,375 15,529
Derivatives qualifying for hedge
accounting
Fair value hedges - interest rate
swaps
1,637,500 58,299 2,918 1,401,531 48,679 2,451
Portfolio fair value hedges - interest
rate swaps
2,914,362 27,741 140 - - -
Net investments - forward exchange
rate contracts
985 - 1 1,200 1 -
4,552,847 86,040 3,059 1,402,731 48,680 2,451
Total
5,520,876 95,273 4,664 2,592,529 51,055 17,980
463
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
21. Derivative financial instruments (continued)
The use of derivatives is an integral part of the Group’s activities. Derivatives are used to manage the
Group’s own exposure to fluctuations in interest rates and foreign currency exchange rates. Derivatives are
also sold to customers as risk management products.
Credit risk for derivatives arises from the possibility of the counterparty’s failure to meet the terms of any
contract. In the case of derivatives, credit losses are a significantly smaller amount compared to the
derivatives’ notional amount. In order to manage credit risk, the Group sets derivative limits based on the
creditworthiness of the involved counterparties and uses credit mitigation techniques such as netting,
collateralisation, margin calls and clearing through Central Clearing House (CCP) where applicable.
Interest rate risk is explained in Note 45. The interest rate risk is managed through the use of own balance
sheet solutions such as plain vanilla interest rate swaps and interest rate options. In fair value hedging of
interest rate risk, fixed rate assets/liabilities are converted to floating. In cash flow hedging of interest rate
risk, the Group converts floating rate assets/liabilities to fixed.
Currency risk is explained in Note 45. In order to manage currency risk, the Group hedges its open position
by entering into foreign exchange deals such as: foreign exchange spot, foreign exchange forwards, foreign
exchange swaps or foreign exchange options. The foreign currency risk mainly arises from customer-driven
transactions on deposits and loans and advances.
Forward exchange rate contracts are irrevocable agreements to buy or sell a specified quantity of foreign
currency on a specified future date at an agreed rate.
Currency swaps involve the exchange of two currencies at the current market rate and the commitment to
re-exchange them at a specified rate upon maturity of the swap. Cross-currency swaps are interest rate
swaps in which the cash flows are in different currencies.
Interest rate swaps are contractual agreements between two parties to exchange fixed rate and floating
rate interest, by means of periodic payments, based upon a notional principal amount and the interest rates
defined in the contract.
Currency options are contracts that grant the holder the right, but not the obligation, to buy or sell currency
at a specified exchange rate during a specified period of time.
Interest rate caps/floors protect the buyer from fluctuations of interest rates above or below a specified
interest rate for a specified period of time.
The credit exposure of derivative financial instruments represents the cost to replace these contracts at the
reporting date. The exposure arising from these transactions is managed as part of the Group’s credit risk
management process for credit facilities granted to customers and financial institutions.
The contract amount of certain types of derivative financial instruments provides a basis for comparison
with other instruments recognised on the consolidated balance sheet, but does not necessarily indicate the
amount of future cash flows involved or the current fair value of the instruments and, consequently, does
not indicate the Group’s exposure to credit or market risk.
The fair value of the derivatives can be either positive (asset) or negative (liability) as a result of
fluctuations in market interest rates and foreign currency exchange rates in accordance with the terms of
the relevant contract. The aggregate net fair value of derivatives may fluctuate significantly over time.
Hedge accounting
The Group elected, as a policy choice permitted by IFRS 9, to continue to apply hedge accounting in
accordance with IAS 39.
The Group applies hedge accounting using derivatives when the required criteria for hedge accounting are
met. The Group also uses derivatives for economic hedging (hedging the changes in interest rates, foreign
currency exchange rates or other risks) which do not meet the criteria for hedge accounting. As a result,
these derivatives are accounted for as trading derivatives and the gains or losses arising from revaluation
are recognised in the consolidated income statement.
464
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
21. Derivative financial instruments (continued)
Derivatives held for trading comprise derivatives entered into with economic hedging intent to which the
Group does not apply hedge accounting or derivative positions arise as a result of activity generated by
corporate customers. Derivatives classified as held for hedging comprise only those derivatives to which the
Group applies hedge accounting.
Fair value hedges
The Group uses interest rate swaps to hedge the interest rate risk arising as a result of the possible adverse
movement in the fair value of fixed rate debt securities measured at FVOCI, debt securities in issue and
subordinated liabilities, as well as customer deposits.
As part of its structural interest rate risk management, during the year ended 31 December 2024, the
Group has contracted fixed-rate receiver swaps to hedge interest rate risk by setting up fair value hedges
for a portfolio of liabilities being the core NMDs. This strategy is designated as a fair value hedge, under the
IAS 39 as adopted by the EU (IAS 39 carve-out) and its effectiveness is assessed by comparing changes in
the fair value of the designated hedged item, attributable to changes in the benchmark interest rate, with
the respective changes in the fair value of the interest rate swaps used as hedging instruments.
Changes in the fair value of derivatives designated as fair value hedges (both for micro hedges and macro
hedges) and the fair value of the hedged items in relation to the risk being hedged are recognised in the
consolidated income statement.
In the case of fair value macro hedges, fair value changes of the hedged portfolios are recognised in the
liability side of the consolidated balance sheet under caption ‘Changes in the fair value of hedged items in
portfolio hedges of interest rate risk’, which as at 31 December 2024 amounted to a cumulative fair value
change of €44,074 thousand (2023: n/a).
Hedges of net investments
The Group’s consolidated balance sheet is impacted by foreign currency exchange differences between Euro
and all non-Euro functional currencies of overseas subsidiaries and other foreign operations. The Group
hedges its structural currency risk when it considers that the cost of such hedging is within an acceptable
range (in relation to the underlying risk). This hedging is done through the use of forward exchange rate
contracts.
As at 31 December 2024, forward exchange rate contracts amounting to €985 thousand (2023: €1,200
thousand) have been designated as hedging instruments and have given rise to approximately nil loss
(2023: loss of €13 thousand) which was recognised in the ‘Foreign currency translation reserve’ in the
consolidated statement of comprehensive income, against the profit or loss from the retranslation of the net
assets of the overseas subsidiaries and other foreign operations.
Gains/(losses) attributable to
hedged risk
Hedge in-
effectiveness
2024
Hedged items
Hedging
instruments
Derivatives qualifying for hedge accounting €000 €000 €000
Fair value hedges - interest rate swaps
-debt securities - investment 8,763 (8,763) -
-debt securities in issue (8,914) 8,914 -
-subordinated liabilities 93 (93) -
-customer deposits (macro hedge)
(44,074) 44,074 -
Total
(44,132) 44,132 -
465
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
21. Derivative financial instruments (continued)
Gains/(losses) attributable
to hedged risk
Hedge in-
effectiveness
2023
Hedged items
Hedging
instruments
Derivatives qualifying for hedge accounting €000 €000 €000
Fair value hedges - interest rate swaps
-debt securities - investments 22,840 (20,722) 2,118
-debt securities in issue (14,274) 14,274 -
-subordinated liabilities (4,237) 4,237 -
Net investments
-forward exchange rate contracts
13 (13) -
Total
4,342 (2,224) 2,118
The accumulated fair value adjustment arising from the hedging relationships is presented in the table
below:
Carrying amount of hedged
items
Accumulated amount of fair
value hedging adjustments
gains/(losses) on the
hedged item
2024 Assets Liabilities Assets Liabilities
Derivatives qualifying for hedge
accounting €000 €000 €000 €000
Fair value hedges - interest rate swaps
-debt securities - investments 379,937 - (28,498) -
-debt securities in issue - 989,435 - (18,335)
-subordinated liabilities - 307,138 - (4,144)
-customer deposits (macro hedge) - 2,914,362 - (44,074)
Net investments - forward exchange rate
contracts
Net assets/liabilities
- 985 - 1
Total
379,937 4,211,920 (28,498) (66,552)
Carrying amount of hedged
items
Accumulated amount of fair
value hedging adjustments
gains/(losses) on the hedged
item
2023 Assets Liabilities Assets Liabilities
Derivatives qualifying for hedge
accounting €000 €000 €000 €000
Fair value hedges - interest rate swaps
-debt securities - investments 439,043 - (43,441) -
-debt securities in issue - 671,632 - (9,421)
-subordinated liabilities - 306,787 - (4,237)
Net investments - forward exchange rate
contracts
Net assets/liabilities
1,200 - 1 -
Total
440,243 978,419 (43,440) (13,658)
For assets hedged using fair value hedges the applicable average rates of hedging instruments is 2.35%
fixed rate as at 31 December 2024 (2023: 2.05%). For liabilities hedged using fair value hedges, the
average fixed rate is 3.55% as at 31 December 2024 (2023: 5.44%).
466
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
21. Derivative financial instruments (continued)
The maturity of the Group's contract amount of the derivatives is presented in the table below:
On demand
and up to one
month
Between one
and three
months
Between
three months
and one year
Between one
and five
years
Over five
years
Total
contract
amount
2024 €000 €000 €000 €000 €000 €000
Trading
derivatives
Forward exchange
rate contracts
8,040 9,870 5,322 - - 23,232
Currency swaps 719,764 206,213 218 - - 926,195
Currency options 472 - - - - 472
Interest rate
caps/floors
- - - 18,130 - 18,130
728,276 216,083 5,540 18,130 - 968,029
Derivatives
qualifying for
hedge
accounting
Fair value hedges
- interest rate
swaps
- - 69,000 1,404,000 164,500 1,637,500
Portfolio fair value
hedges - interest
rate swaps
- - - 2,914,362 - 2,914,362
Net investments -
forward exchange
rate contracts
985 - - - - 985
985 - 69,000 4,318,362 164,500 4,552,847
Total
729,261 216,083 74,540 4,336,492 164,500 5,520,876
On demand
and up to one
month
Between one
and three
months
Between three
months and
one year
Between one
and five years
Over five
years
Total contract
amount
2023 €000 €000 €000 €000 €000 €000
Trading
derivatives
Forward exchange
rate contracts
9,734 9,657 4,569 - - 23,960
Currency swaps 852,963 132,603 693 - - 986,259
Interest rate
swaps
- 4,372 9,088 - - 13,460
Currency options 44 - - - - 44
Interest rate
caps/floors
- - - 166,075 - 166,075
862,741 146,632 14,350 166,075 - 1,189,798
Derivatives
qualifying for
hedge
accounting
Fair value hedges
- interest rate
swaps
- 15,000 56,031 1,166,000 164,500 1,401,531
Net investments -
forward exchange
rate contracts
1,200 - - - - 1,200
1,200 15,000 56,031 1,166,000 164,500 1,402,731
Total
863,941 161,632 70,381 1,332,075 164,500 2,592,529
467
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
22. Fair value measurement
The following table presents the carrying value and fair value of the Group's financial assets and liabilities.
2024 2023
Carrying
value
Fair value
Carrying
value
Fair value
Financial assets €000 €000 €000 €000
Cash and balances with central banks 7,600,726 7,600,726 9,614,502 9,614,502
Loans and advances to banks 820,574 813,239 384,802 370,853
Investments at FVPL 136,629 136,629 135,275 135,275
Investments at FVOCI 416,077 416,077 443,420 443,420
Investments at amortised cost 3,805,637 3,837,774 3,116,714 3,119,618
Reverse repurchase agreements 1,010,170 1,026,046 403,199 411,654
Derivative financial assets 95,273 95,273 51,055 51,055
Loans and advances to customers 10,114,394 10,114,750 9,821,788 9,972,249
Life insurance business assets attributable to
policyholders
761,127 761,127 637,562 637,562
Financial assets classified as held for sale 23,143 23,143 - -
Other financial assets
295,632 300,606 388,244 406,602
25,079,382 25,125,390 24,996,561 25,162,790
Financial liabilities
Funding from central banks and deposits by
banks
364,231 334,156 2,515,424 2,472,718
Derivative financial liabilities 4,664 4,664 17,980 17,980
Customer deposits 20,519,276 20,494,544 19,336,915 19,300,867
Debt securities in issue 989,435 1,024,400 671,632 655,428
Subordinated liabilities 307,138 314,195 306,787 300,098
Other financial liabilities and lease liabilities
441,445 441,445 362,152 362,152
22,626,189 22,613,404 23,210,890 23,109,243
The fair value of financial assets and liabilities in the above table is as at the reporting date and does not
represent any expectations about their future value.
The Group uses the following hierarchy for determining and disclosing fair value:
Level 1: investments valued using quoted prices in active markets.
Level 2: investments valued using models for which all inputs that have a significant impact on fair value
are market observable.
Level 3: investments valued using models for which inputs that have a significant impact on fair value are
not based on market observable data.
Observable inputs to the models for the valuation of unquoted equity and debt securities include, where
applicable, current and expected market interest rates, market expected default rates, market implied
country and counterparty credit risk and market liquidity discounts.
For assets and liabilities that are recognised in the Consolidated Financial Statements at fair value, the
Group determines whether transfers have occurred between levels in the hierarchy by re-assessing
categorisation at the end of each reporting period.
468
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
22. Fair value measurement (continued)
The following table presents the fair value measurement hierarchy of the Group's assets and liabilities
recorded at fair value and financial assets and financial liabilities for which fair value is disclosed, by level of
the fair value hierarchy.
Level 1 Level 2 Level 3 Total
2024 €000 €000 €000 €000
Assets measured at fair value
Investment properties
Residential - - 4,584 4,584
Offices and other commercial properties - - 20,715 20,715
Manufacturing and industrial properties - - 8,662 8,662
Land (fields and plots)
- - 2,290 2,290
- - 36,251 36,251
Freehold property
Offices and other commercial properties
- - 240,185 240,185
Loans and advances to customers measured
at FVPL
- - 131,008 131,008
Trading derivatives
Forward exchange rate contracts - 171 - 171
Currency swaps - 7,662 - 7,662
Interest rate swaps - - - -
Currency options - 455 - 455
Interest rate caps/floors
- 945 - 945
- 9,233 - 9,233
Derivatives qualifying for hedge accounting
Fair value hedges-interest rate swaps - 58,299 - 58,299
Portfolio fair value hedges - interest rate
swaps
- 27,741 - 27,741
- 86,040 - 86,040
Investments at FVPL
31,577 94,350 10,702 136,629
Investments at FVOCI
406,600 6 9,471 416,077
Prepayments, accrued income and other
assets
- - 25,500 25,500
438,177 189,629 453,117 1,080,923
Financial assets not measured at fair
value
Loans and advances to banks - 813,239 - 813,239
Investments at amortised cost 3,604,367 233,407 - 3,837,774
Reverse repurchase agreements - 1,026,046 - 1,026,046
Loans and advances to customers
- - 9,983,742 9,983,742
3,604,367 2,072,692 9,983,742 15,660,801
The discount rate used in the determination of the fair value of the loans and advances to customers
measured at FVPL as at 31 December 2024 is 6.79% (2023: 7.56%).
For loans and advances to customers measured at FVPL categorised as Level 3 as at 31 December 2024, an
increase in the discount factor by 10% would result in a decrease of €2,460 thousand in their fair value and
a decrease in the discount factor by 10% would result in an increase of €591 thousand in their fair value.
For one investment included in other non-equity securities mandatorily measured at FVPL as a result of the
SPPI assessment and categorised as Level 3 with a carrying amount of €10,702 thousand as at 31
December 2024, a change in the conversion factor by 10% would result in a change in the value of the
other non-equity securities by €1,070 thousand.
For additional disclosures on sensitivity analysis of equity securities refer to Note 45.
469
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
22. Fair value measurement (continued)
The fair value measurement hierarchy for life insurance business assets attributable to policy holders is
disclosed in Note 24.
Level 1 Level 2 Level 3 Total
2024 €000 €000 €000 €000
Liabilities measured at fair value
Trading derivatives
Forward exchange rate contracts - 126 - 126
Currency swaps - 517 - 517
Currency options - 17 - 17
Interest rate caps/floors
- 945 - 945
- 1,605 - 1,605
Derivatives qualifying for hedge accounting
Fair value hedges-interest rate swaps - 2,918 - 2,918
Portfolio fair value hedges - interest rate
swaps
- 140 - 140
Net investments - forward exchange rate
contracts
- 1 - 1
- 3,059 - 3,059
- 4,664 - 4,664
Financial liabilities not measured at fair
value
Deposits by banks - 334,156 - 334,156
Customer deposits - - 20,494,544 20,494,544
Debt securities in issue 1,024,400 - - 1,024,400
Subordinated liabilities
314,195 - - 314,195
1,338,595 334,156 20,494,544 22,167,295
470
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
22. Fair value measurement (continued)
Level 1 Level 2 Level 3 Total
2023 €000 €000 €000 €000
Assets measured at fair value
Investment properties
Residential - - 5,933 5,933
Offices and other commercial properties - - 34,369 34,369
Manufacturing and industrial properties - - 19,513 19,513
Land (fields and plots)
- - 2,290 2,290
- - 62,105 62,105
Freehold property
Offices and other commercial properties
- - 232,235 232,235
Loans and advances to customers measured
at FVPL
- - 138,727 138,727
Trading derivatives
Forward exchange rate contracts - 205 - 205
Currency swaps - 136 - 136
Interest rate swaps - 189 - 189
Currency options - 2 - 2
Interest rate caps/floors
- 1,843 - 1,843
- 2,375 - 2,375
Derivatives qualifying for hedge accounting
Fair value hedges-interest rate swaps - 48,679 - 48,679
Net investments-forward exchange rate
contracts
- 1 - 1
- 48,680 - 48,680
Investments at FVPL
36,095 95,569 3,611 135,275
Investments at FVOCI
431,854 - 11,566 443,420
467,949 146,624 448,244 1,062,817
Financial assets not measured at fair
value
Loans and advances to banks - 370,853 - 370,853
Investments at amortised cost 2,958,793 160,825 - 3,119,618
Reverse repurchase agreements - 411,654 - 411,654
Loans and advances to customers
- - 9,833,522 9,833,522
2,958,793 943,332 9,833,522 13,735,647
For loans and advances to customers measured at FVPL categorised as Level 3 as at 31 December 2023, an
increase in the discount factor by 10% would result in a decrease of €2,714 thousand in their fair value and
a decrease in the discount factor by 10% would result in an increase of €622 thousand in their fair value.
For one investment included in other non-equity securities mandatorily measured at FVPL as a result of the
SPPI assessment and categorised as Level 3 with a carrying amount of €3,611 thousand as at 31 December
2023, a change in the conversion factor by 10% would result in a change in the value of the other non-
equity securities by €361 thousand.
471
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
22. Fair value measurement (continued)
Level 1 Level 2 Level 3 Total
2023 €000 €000 €000 €000
Liabilities measured at fair value
Trading derivatives
Forward exchange rate contracts - 184 - 184
Currency swaps - 13,278 - 13,278
Interest rate swaps - 181 - 181
Currency options - 42 - 42
Interest rate caps/floors
- 1,844 - 1,844
- 15,529 - 15,529
Derivatives qualifying for hedge accounting
Fair value hedges-interest rate swaps
- 2,451 - 2,451
- 17,980 - 17,980
Financial liabilities not measured at fair
value
Funding from central banks - 2,043,868 - 2,043,868
Deposits by banks - 428,850 - 428,850
Customer deposits - - 19,300,867 19,300,867
Debt securities in issue 655,428 - - 655,428
Subordinated liabilities
300,098 - - 300,098
955,526 2,472,718 19,300,867 22,729,111
The cash and balances with central banks are financial instruments whose carrying value is a reasonable
approximation of fair value because they are mostly short-term in nature or are repriced to current market
rates frequently. The carrying value of other financial assets, other than the deferred purchase payment
consideration (Note 28), and other financial liabilities is a close approximation of their fair value and they
are categorised as Level 3.
During the years ended 31 December 2024 and 2023 there were no significant transfers between Level 1
and Level 2.
472
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
22. Fair value measurement (continued)
Movements in Level 3 assets measured at fair value
Transfers from Level 3 to Level 2 occur when the market for some securities becomes more liquid, which eliminates the need for the previously required
significant unobservable valuation inputs. Following a transfer to Level 2 the instruments are valued using valuation models incorporating observable market
inputs. Transfers into Level 3 reflect changes in market conditions as a result of which instruments become less liquid and consequently, the Group requires
significant unobservable inputs to calculate their fair value.
The movement in Level 3 assets which are measured at fair value is presented below:
2024 2023
Investment
properties
Own use
properties
Other
financial
assets
Loans and
advances to
customers
Financial
instruments
Investment
properties
Own use
properties
Loans and
advances to
customers
Financial
instruments
€000 €000 €000 €000 €000 €000 €000 €000 €000
1 January
62,105 232,235 - 138,727 15,177 85,099 203,658 214,359 21,233
Additions 198 9,549 25,500 - - 1,390 836 - -
Disposals (23,613) - - - - (23,797) - - -
Transfers from own use properties to investment properties (Note 25) - - - - - 798 (798) - -
Net transfers from stock of property (Note 25) - - - - - - 17,827 - -
Conversion of instruments into common shares - - - - - - - - (6,521)
Depreciation charge for the year - (2,121) - - - - (2,047) - -
Impairment (Note 25) - - - - - - (765) - -
Fair value (losses)/gains (2,439) 522 - - 4,847 (1,385) 13,524 - 569
Net gains on loans and advances to customers measured at FVPL (Note 11) - - - 1,232 - - - 2,401 -
Repayments/derecognition of loans - - - (17,792) - - - (89,522) -
Interest on loans (Note 7) - - - 8,841 - - - 11,489 -
Foreign exchange adjustments
- - - - 149 - - - (104)
31 December
36,251 240,185 25,500 131,008 20,173 62,105 232,235 138,727 15,177
Valuation policy and sensitivity analysis
Investment properties and own use properties
The valuation technique mainly applied by the Group is the market comparable approach, adjusted for market and property specific conditions. In certain
cases, the Group also utilises the income capitalisation approach. The key inputs used for the valuations of the investment properties and own use properties
are presented in the tables below:
473
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
22. Fair value measurement (continued)
Valuation policy and sensitivity analysis (continued)
Analysis of investment properties
Type and country
2024
Estimated
rental value
per m
2
per
annum
Estimated
building cost
per m
2
Yield
Estimated fair
value per m
2
Estimated
land value per
m
2
Land Building area
Age of
building
Residential
€000
m
2
m
2
Years
Cyprus 1,638 €41-€108 €1,250-€1,542 3.0%-5.0% €473-€1,886 €130-€380 607-725 142-420 12-59
Greece
2,946
€15-€118 €229-€3,018 2.7%-9.4% €45-€2,038 €26-€479 24-5,147 51-825 19-52
4,584
Offices and other commercial properties
Cyprus 17,942 €47-€349 n/a 4.0%-7.0% €579-€5,833 €500-€3,900 348-1,872 16-3,292 18-70
Greece
2,773
€9-€219 €193-€1,161 4.9%-8.8% €73-€3,648 €558-€3,451 100-8,582 6-4,692 20-66
20,715
Manufacturing and industrial
Cyprus 2,679 €45-€67 €709 6.0%-7.0% €920-€956 €150-€400 2,935-3,410 1,608-1,713 31
Greece
5,983
€1-€71 €214-€1,199 4.5%-10.3% €12-€464 €52-€521 57-34,495 349-5,858 15-86
8,662
Land (fields and plots)
Cyprus
2,290
n/a n/a n/a n/a €989 2,316 n/a n/a
2,290
Total
36,251
Analysis of own use properties
Type and country
2024
Estimated
rental value
per m
2
per
annum
Estimated
building cost
per m
2
Yield
Estimated fair
value per m
2
Estimated
land value per
m
2
Land Building area
Age of
building
Offices and other commercial properties
€000
m
2
m
2
Years
Cyprus
240,185
€36-€264 €1,063-€3,162 5.5%-6.0% €383-€5,254 €150-€2,757 390-51,947 210-24,035 17-100
Total
240,185
474
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
22. Fair value measurement (continued)
Valuation policy and sensitivity analysis (continued)
Analysis of investment properties
Type and country
2023
Estimated
rental value
per m
2
per
annum
Estimated
building cost
per m
2
Yield
Estimated fair
value per m
2
Estimated
land value per
m
2
Land Building area
Age of
building
Residential
€000
m
2
m
2
Years
Cyprus 2,024 €41-€98 €1,090-€1,673 4.5%-5.5% €380-€2,338 €130-€380 607-725 89-594 10-58
Greece
3,909
€6-€113 €164-€2,961 2%-9.4% €46-€1,878 €16-€1,910 24-5,147 51-825 16-51
5,933
Offices and other commercial properties
Cyprus 31,297 €36-€289 €470 3.9%-6.7% €578-€5,781 €150-€3,900 348-11,301 0-4,605 11-68
Greece
3,072
€9-€219 €193-€1,404 4.9%-8.8% €72-€3,648 €261-€289 100-8,582 6-4,692 19-65
34,369
Manufacturing and industrial
Cyprus 12,583 €23-€67 €205-€709 4.5%-7.0% €266-€1,225 €165-€500 2,202-14,590 743-8,007 20-37
Greece
6,930
€1-€99 €172-€684 4.4%-10.4% €12-€439 €10-€191 57-34,495 349-5,858 14-85
19,513
Land (fields and plots)
Cyprus
2,290
n/a n/a n/a n/a €989 2,316 n/a n/a
2,290
Total
62,105
Analysis of own use properties
Type and country
2023
Estimated
rental value
per m
2
per
annum
Estimated
building cost
per m
2
Yield
Estimated fair
value per m
2
Estimated
land value per
m
2
Land Building area
Age of
building
Offices and other commercial properties
€000
m
2
m
2
Years
Cyprus
232,235
€30-€315 €1,063-€3,162 6%-6.5% €65-€5,254 €65-€2,756 390-51,947 210-24,035 16-100
Total
232,235
475
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
22. Fair value measurement (continued)
Valuation policy and sensitivity analysis (continued)
Sensitivity analysis
The fair value of the Group’s properties have been classified as Level 3 in the fair value measurement
hierarchy. Significant increases/decreases in estimated values per square meter for properties valued with
the comparable approach or significant increases/decreases in estimated rental values or yields for
properties valued with the income capitalisation approach could result in a significantly higher/lower fair
value of the properties.
23. Loans and advances to customers
2024 2023
€000 €000
Gross loans and advances to customers at amortised cost 10,130,405 9,862,514
Allowance for ECL for impairment of loans and advances to customers (Note 44.5)
(147,019) (179,453)
9,983,386 9,683,061
Loans and advances to customers measured at FVPL
131,008 138,727
10,114,394 9,821,788
The following tables present the Group’s gross loans and advances to customers at amortised cost by
staging.
Stage 1 Stage 2 Stage 3 POCI Total
2024 €000 €000 €000 €000 €000
Gross loans at amortised cost
before residual fair value
adjustment on initial recognition
9,176,411 785,674 169,189 59,810 10,191,084
Residual fair value adjustment on
initial recognition
(49,916) (10,594) 1,579 (1,748) (60,679)
Gross loans at amortised cost
9,126,495 775,080 170,768 58,062 10,130,405
2023
Gross loans at amortised cost
before residual fair value
adjustment on initial recognition
8,334,929 1,168,745 328,177 100,197 9,932,048
Residual fair value adjustment on
initial recognition
(59,340) (7,474) (1,294) (1,426) (69,534)
Gross loans at amortised cost
8,275,589 1,161,271 326,883 98,771 9,862,514
Residual fair value adjustment
The residual fair value adjustment on initial recognition mainly relates to the loans and advances to
customers acquired as part of the acquisition of certain operations of Laiki Bank in 2013. In accordance with
the provisions of IFRS 3, this adjustment decreased the gross balance of loans and advances to customers.
The residual fair value adjustment is included within the gross balances of loans and advances to customers
as at each balance sheet date. However, for credit risk monitoring, the residual fair value adjustment as at
each balance sheet date is presented separately from the gross balances of loans and advances, as shown
in the tables above.
Loans and advances to customers measured at FVPL are managed in Cyprus.
476
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
23. Loans and advances to customers (continued)
The following tables present the Group’s gross loans and advances to customers at amortised cost by
staging and by business line concentration.
2024 Stage 1 Stage 2 Stage 3 POCI Total
By business line €000 €000 €000 €000 €000
Corporate 2,897,542 409,697 30,103 9,879 3,347,221
IBU & International corporate
- IBU 104,327 16,124 126 117 120,694
- International corporate 935,383 25,634 - 4 961,021
SMEs 886,864 68,843 8,094 4,270 968,071
Retail
- housing 3,327,631 179,619 18,206 9,893 3,535,349
- consumer, credit cards and
other
959,787 61,415 8,463 10,729 1,040,394
Restructuring
- corporate 1,424 3,184 2,469 10,357 17,434
- SMEs 6,447 3,928 8,205 1,966 20,546
- retail housing 5,062 5,898 24,281 1,143 36,384
- retail other 2,014 738 11,698 754 15,204
Recoveries
- corporate - - 3,873 307 4,180
- SMEs - - 8,671 993 9,664
- retail housing - - 30,358 4,494 34,852
- retail other
14 - 16,221 3,156 19,391
9,126,495 775,080 170,768 58,062 10,130,405
2023 (restated) Stage 1 Stage 2 Stage 3 POCI Total
By business line €000 €000 €000 €000 €000
Corporate 2,709,523 519,134 96,289 32,799 3,357,745
IBU & International corporate
- IBU 99,009 21,409 320 140 120,878
- International corporate 744,955 17,220 38 15 762,228
SMEs 824,503 109,865 5,583 9,042 948,993
Retail
- housing 3,038,339 345,135 23,508 9,897 3,416,879
- consumer, credit cards and
other
836,679 103,710 9,814 13,839 964,042
Restructuring
- corporate 3,770 21,747 13,461 10,073 49,051
- SMEs 9,831 8,089 13,715 2,431 34,066
- retail housing 6,450 12,429 39,696 1,912 60,487
- retail other 2,471 2,533 13,474 733 19,211
Recoveries
- corporate - - 6,378 967 7,345
- SMEs - - 15,812 1,587 17,399
- retail housing - - 65,070 10,255 75,325
- retail other
59 - 23,725 5,081 28,865
8,275,589 1,161,271 326,883 98,771 9,862,514
During 2023, BOC PCL entered into an agreement with Cyprus Asset Management Company ('KEDIPES') to
acquire a portfolio of performing and restructured loans with gross book value of approximately €58 million
with reference date 31 December 2022 (the 'Transaction'). The Transaction was completed in March 2024.
Loans and advances to customers pledged as collateral are disclosed in Note 46.
477
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
23. Loans and advances to customers (continued)
Additional analysis and information on loans and advances to customers and related allowance for ECL are
set out in Note 44.
The following portfolio of loans and advances to customers was classified as held for sale as at 31 December
2024. There were no loans and advances to customers classified as held for sale as at 31 December 2023.
2024 2023
€000 €000
Disposal group
23,143 -
23,143 -
2024 2023
€000 €000
Gross loans and advances to customers (Note 44.3) 54,921 -
Allowance for ECL for impairment of loans and advances to customers (Note
44.5)
(31,778) -
23,143 -
Disposal Group
Disposal group comprises a portfolio of loans and advances to customers known as Project River, classified
as held for sale as at 31 December 2024. The Group entered into agreement with funds associated with
Cerberus Global Investments B.V. to sell two non-performing loan portfolios with a total gross book value of
approximately €55 million as at 31 December 2024 (the ‘Sale transaction’). The Sale transaction is subject
to the necessary approvals and is expected to be completed within the first half of 2025.
The analysis of the gross book value and the allowance for ECL of loans and advances to customers
classified as held for sale by staging is provided below:
Stage 3 POCI
Total
2024 €000 €000 €000
Gross loans and advances to customers 49,589 5,332 54,921
Allowance for ECL for impairment of loans and advances to
customers
(29,003) (2,775) (31,778)
31 December
20,586 2,557 23,143
The disposal portfolio relates mainly to corporate and retail exposures under the Restructuring & Recoveries
business line.
24. Life insurance business assets attributable to policyholders
2024 2023
€000 €000
Equity securities 2,145 1,982
Debt securities 81,299 58,688
Mutual funds 639,321 549,592
Bank deposits and other receivables
38,362 27,300
761,127 637,562
Property
11,630 11,650
772,757 649,212
Financial assets of life insurance business attributable to policyholders are classified as investments at FVPL.
Bank deposits and other receivables include other financial receivables of €8,550 thousand (2023: €2,957
thousand).
478
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
24. Life insurance business assets attributable to policyholders (continued)
In addition to the above assets, the life insurance subsidiary of the Group holds shares of the Company, as
part of the assets attributable to policyholders with a carrying value as at 31 December 2024 of €654
thousand (2023: €476 thousand). Such shares are presented in the Consolidated Financial Statements as
treasury shares (Note 34).
The analysis of the financial assets of life insurance business attributable to policyholders measured at fair
value by level of the fair value hierarchy is presented below:
Level 1 Level 2 Level 3 Total
2024 €000 €000 €000 €000
Equity securities 2,145 - - 2,145
Debt securities 61,699 - 19,600 81,299
Mutual funds
636,240 - 3,081 639,321
700,084 - 22,681 722,765
2023
Equity securities 1,982 - - 1,982
Debt securities 38,378 - 20,310 58,688
Mutual funds
546,475 - 3,117 549,592
586,835 - 23,427 610,262
Bank deposits are financial instruments whose carrying amount is a reasonable approximation of fair value,
because they are short-term in nature or are repriced to current market rates frequently. The carrying value
of other financial receivable is a close approximation of their fair value and they are categorised as Level 3.
The movement of financial assets classified as Level 3 is presented below:
2024 2023
€000 €000
1 January 23,427 22,503
Unrealised (losses)/gains recognised in the consolidated income statement
(746) 924
31 December
22,681 23,427
During the years ended 31 December 2024 and 2023 there were no significant transfers between Level 1
and Level 2.
The property asset of life insurance business attributable to policyholders is measured at fair value and is
categorised as Level 3 in the fair value hierarchy.
479
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
25. Property and equipment
Property Equipment Total
2024 €000 €000 €000
Net book value at 1 January 255,905 29,663 285,568
Additions 10,591 10,464 21,055
Revaluation 522 - 522
Disposals and write-offs - (11) (11)
Depreciation charge for the year (Note 15.1) (9,347) (8,632) (17,979)
New leases (Note 42) 1,575 895 2,470
Re-assessment of RoU assets (Note 42) 16,158 - 16,158
Derecognition of RoU assets (Note 42)
(369) - (369)
Net book value at 31 December
275,035 32,379 307,414
1 January 2024
Cost or valuation 327,251 123,677 450,928
Accumulated depreciation
(71,346) (94,014) (165,360)
Net book value
255,905 29,663 285,568
31 December 2024
Cost or valuation 354,363 134,622 488,985
Accumulated depreciation
(79,328) (102,243) (181,571)
Net book value
275,035 32,379 307,414
Property Equipment Total
2023 €000 €000 €000
Net book value at 1 January 235,538 17,840 253,378
Additions 396 7,058 7,454
Revaluation 13,524 - 13,524
Impairment (765) - (765)
Transfers to investment properties (Note 22) (798) - (798)
Net transfers from stock of property (Note 27) 17,827 - 17,827
Disposals and write-offs - (24) (24)
Depreciation charge for the year (Note 15.1) (8,997) (6,396) (15,393)
New leases (Note 42) 168 11,185 11,353
Re-assessment of RoU assets (Note 42)
(988) - (988)
Net book value at 31 December
255,905 29,663 285,568
1 January 2023
Cost or valuation 303,891 142,787 446,678
Accumulated depreciation
(68,353) (124,947) (193,300)
Net book value
235,538 17,840 253,378
31 December 2023
Cost or valuation 327,251 123,677 450,928
Accumulated depreciation
(71,346) (94,014) (165,360)
Net book value
255,905 29,663 285,568
480
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
25. Property and equipment (continued)
As at 31 December 2024 the net book value of the Group's equipment includes an amount of €9,169
thousand that relates to RoU asset - Computer hardware (2023: €11,462 thousand).
The net book value of the Group's property comprises:
2024 2023
€000 €000
Freehold property 240,185 232,235
Improvements on leasehold property 1,726 1,270
RoU assets (Note 42)
33,124 22,400
Total
275,035 255,905
Freehold property includes land amounting to €93,409 thousand (2023: €92,751 thousand) for which no
depreciation is charged. Further, freehold property includes an amount of €22,507 thousand (2023:
€20,876 thousand) which relates to a property under construction.
The Group’s policy is to revalue its properties periodically (between 3 to 5 years) but more frequent
revaluations may be performed where there are significant and volatile movements in values. The Group
performed revaluations during the year ended 31 December 2023. The valuations were carried out by
independent qualified valuers, on the basis of market value using observable prices and/or recent market
transactions depending on the location of the property. Details on valuation techniques and inputs are
presented in Note 22.
There were no charges against the freehold property of the Group as at 31 December 2024 and 2023.
The net book value of freehold property, on a cost less accumulated depreciation basis, as at 31 December
2024 amounts to €166,126 thousand (2023: €158,900 thousand).
26. Intangible assets
2024 2023
€000 €000
Net book value at 1 January 48,635 52,546
Additions 19,736 14,949
Disposals and write-offs (432) -
Amortisation charge for the year (Note 15.1)
(18,192) (18,860)
Net book value at 31 December
49,747 48,635
1 January
Cost 268,268 253,353
Accumulated amortisation and impairment
(219,633) (200,807)
Net book value
48,635 52,546
31 December
Cost 287,208 268,268
Accumulated amortisation and impairment
(237,461) (219,633)
Net book value
49,747 48,635
Computer software includes internally developed computer software with a net carrying amount of €5,570
thousand as at 31 December 2024 (2023: €4,679 thousand).
481
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
27. Stock of property
The carrying amount of stock of property is determined as the lower of cost and net realisable value.
Impairment is recognised if the net realisable value is below the cost of the stock of property. During the
year ended 31 December 2024 an impairment loss of €55,612 thousand (2023: €46,026 thousand) was
recognised in 'Impairment net of reversals on non-financial assets' in the consolidated income statement. At
31 December 2024, stock of property of €405,520 thousand (2023: €445,009 thousand) is carried at net
realisable value.
There is no stock of property pledged as collateral.
The carrying amount of the stock of property is analysed in the tables below:
2024 2023
€000 €000
Net book value at 1 January 826,115 1,041,032
Additions 30,488 19,531
Disposals (152,234) (170,595)
Net transfer to property and equipment (Note 25) - (17,827)
Impairment for the year (Note 16)
(55,612) (46,026)
Net book value at 31 December
648,757 826,115
The result on the disposal of stock of property in the year is presented in the table below:
2024 2023
€000 €000
Net consideration 152,450 179,567
Carrying value of stock of property disposed of
(152,234) (170,595)
Net gains on disposal of stock of property
216 8,972
Analysis by type and country Cyprus Greece Total
2024 €000 €000 €000
Residential properties 44,327 3,216 47,543
Offices and other commercial properties 59,650 5,060 64,710
Manufacturing and industrial properties 12,532 3,993 16,525
Hotels 7,005 339 7,344
Land (fields and plots)
509,547 3,088 512,635
Total
633,061 15,696 648,757
2023 €000 €000 €000
Residential properties 47,841 8,091 55,932
Offices and other commercial properties 91,114 9,978 101,092
Manufacturing and industrial properties 23,373 9,263 32,636
Hotels 17,345 437 17,782
Land (fields and plots)
614,990 3,683 618,673
Total
794,663 31,452 826,115
482
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
28. Prepayments, accrued income and other assets
2024 2023
€000 €000
Financial assets
Debtors 33,340 34,662
Insurance contract assets (Note 31) - 1,255
Receivable relating to tax 2,772 3,263
Deferred purchase payment consideration 143,604 243,013
Other assets
115,916 106,051
295,632 388,244
Non-financial assets
Insurance and reinsurance contract assets (Note 31) 50,612 56,239
Current tax receivable 61,890 73,943
Prepaid expenses 1,222 867
Retirement benefit plan assets (Note 14.1) 1,767 669
Other assets
68,076 64,957
183,567 196,675
479,199 584,919
An analysis of the movement of the gross carrying amount of the financial assets included in prepayments,
accrued income and other assets measured at amortised cost is presented in the table below:
Stage 1 Stage 3
Simplified
method
Total
2024 €000 €000 €000 €000
1 January 381,151 35,934 5,872 422,957
Net (decrease)/increase
(116,822) (504) (427) (117,753)
31 December
264,329 35,430 5,445 305,204
2023
1 January 394,814 37,512 4,919 437,245
Net (decrease)/increase
(13,663) (1,578) 953 (14,288)
31 December
381,151 35,934 5,872 422,957
An analysis of the movement of the ECL of the above financial assets is presented in the table below:
Stage 1 Stage 3
Simplified
method
Total
2024 €000 €000 €000 €000
1 January 2,101 31,876 736 34,713
Changes to models and inputs used for ECL
calculations
229 8 122 359
31 December
2,330 31,884 858 35,072
2023
1 January 2,107 32,181 495 34,783
Write-offs - (82) - (82)
Changes to models and inputs used for ECL
calculations
(6) (223) 241 12
31 December
2,101 31,876 736 34,713
There were no financial assets classified as Stage 2 as at 31 December 2024 and 2023. In addition, financial
assets amounting to €25,500 thousand were measured at FVPL as at 31 December 2024 (2023: nil).
483
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
28. Prepayments, accrued income and other assets (continued)
Within other non-financial assets an amount of €18,550 thousand as at 31 December 2024 (2023: €18,550
thousand) relates to contract assets from contracts with customers.
On the completion date of the sale of Project Helix 2 (the ‘Transaction’) in June 2021, the Group recognised
an amount of €381,567 thousand in other financial assets, which represented the fair value of the deferred
consideration receivable from the Transaction (the ‘DPP’). The remaining amount outstanding is payable by
December 2025. An amount of €16,042 thousand, which represents the interest income on the DPP has
been recognised in the Consolidated Income Statement for the year ended 31 December 2024 (2023:
€19,774 thousand) within 'Interest income - Financial assets at amortised cost - Other financial assets'
(Note 7). There are no other conditions attached. The DPP is classified as Stage 1 as at 31 December 2024
and 2023.
29. Funding from central banks
Funding from central banks comprises funding from the ECB under Eurosystem monetary policy operations
as set out in the table below:
2024 2023
€000 €000
Targeted Longer-Term Refinancing Operations (TLTRO IΙI)
- 2,043,868
As at 31 December 2024, there was no outstanding ECB funding (2023: €2 billion) as the amount
outstanding as at 31 December 2023 was fully repaid during the year ended 31 December 2024.
Details on encumbered assets are disclosed in Note 46.
484
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
30. Customer deposits
2024 2023
€000 €000
By type of deposit
Demand 10,737,484 10,167,622
Savings 3,091,475 2,979,275
Time or notice
6,690,317 6,190,018
20,519,276 19,336,915
By geographical area
Cyprus 16,422,089 15,355,445
Greece 1,558,482 1,473,491
United Kingdom 396,972 386,057
United States 129,823 166,673
Germany 80,796 77,288
Romania 38,408 29,729
Russia 88,710 128,489
Ukraine 212,662 183,316
Belarus 1,583 3,762
Israel 214,547 195,580
Other countries
1,375,204 1,337,085
20,519,276 19,336,915
Deposits by geographical area are based on the country of residence of the Ultimate Beneficial Owner.
2024 2023
€000 €000
By currency
Euro 18,559,339 17,514,400
US Dollar 1,589,240 1,448,753
British Pound 309,083 300,867
Russian Rouble 1,080 1,322
Swiss Franc 8,315 8,947
Other currencies
52,219 62,626
20,519,276 19,336,915
2024
2023
(restated)
By business line €000 €000
Corporate 2,310,165 2,086,753
IBU & International corporate
- IBU 4,139,368 3,779,571
- International corporate 174,370 121,454
SMEs 1,161,464 1,019,245
Retail 12,600,526 12,216,209
Restructuring
– corporate 10,000 12,565
– SMEs 2,854 5,954
– retail other 6,306 9,428
Recoveries
– corporate 979 1,098
Institutional Wealth Management and Custody
113,244 84,638
20,519,276 19,336,915
485
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
31. Insurance and reinsurance contracts
The breakdown of groups of insurance and reinsurance contracts, that are in an asset position and those in a liability position is set out in the table below:
2024 2023
Assets Liabilities Net Assets Liabilities Net
Insurance contracts €000 €000 €000 €000 €000 €000
Life insurance - (682,830) (682,830) 6,472 (604,233) (597,761)
Non-life insurance
- (60,854) (60,854) - (54,191) (54,191)
Total insurance contracts
- (743,684) (743,684) 6,472 (658,424) (651,952)
Reinsurance contracts
Life insurance 24,039 - 24,039 26,350 - 26,350
Non-life insurance
26,573 - 26,573 24,672 - 24,672
Total reinsurance contracts
50,612 - 50,612 51,022 - 51,022
Total insurance and reinsurance contracts
50,612 (743,684) (693,072) 57,494 (658,424) (600,930)
The table below presents a reconciliation of the measurement components of insurance and reinsurance contract balances showing estimates of the present
value of future cash flows, risk adjustment and CSM for portfolios in the life insurance business measured under GMM and VFA.
2024 2023
Estimates of
the present
value of
future cash
flows
Risk
adjustment
for
non-
financial
risk
Contractual
Service
Margin
Total
Estimates of
the present
value of
future cash
flows
Risk
adjustment
for
non-financial
risk
Contractual
Service
Margin
Total
Insurance contracts
€000 €000 €000 €000 €000 €000 €000 €000
Insurance contracts liabilities (586,145) (17,302) (75,615) (679,062) (528,955) (13,940) (58,331) (601,226)
Insurance contracts assets - - - - 10,411 (2,004) (1,935) 6,472
Reinsurance contracts
Reinsurance contracts assets (915) 15 23,654 22,754 7,896 220 16,979 25,095
486
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
31. Insurance and reinsurance contracts (continued)
The roll-forward of the net asset or liability for insurance contracts issued, showing the liabilities for remaining coverage and the liabilities for incurred claims
for portfolio included in life and non-life insurance, is disclosed in the table below:
2024 2023
Liabilities for remaining coverage
LRC
Liabilities for
incurred claims
LIC
Total
Liabilities for remaining coverage
LRC
Liabilities for
incurred claims
LIC
Total
Excluding loss
component
Loss component
Excluding loss
component
Loss component
€000 €000 €000 €000 €000 €000 €000 €000
Insurance contract liabilities as at 1 January (580,410) (5,713) (72,301) (658,424) (522,191) (6,278) (69,512) (597,981)
Insurance contract assets as at 1 January
7,175 (305) (398) 6,472 4,110 (1,540) (300) 2,270
Net insurance contract assets/(liabilities) as at 01 January
(573,235) (6,018) (72,699) (651,952) (518,081) (7,818) (69,812) (595,711)
Insurance revenue 150,070 - - 150,070 145,775 - - 145,775
Insurance service expenses
Incurred claims and directly attributable expenses 3,976 545 (63,823) (59,302) - 815 (58,225) (57,410)
Amortisation of insurance acquisition cash flows (7,294) - - (7,294) (5,768) - - (5,768)
Insurance acquisition cash flows expensed as incurred (9,067) - - (9,067) (8,488) - - (8,488)
Reversals of losses/(losses) on onerous contracts - 76 - 76 - 1,037 - 1,037
Changes to liabilities for incurred claims (LIC) - - 2,414 2,414 - - (903) (903)
Investment component 65,973 - (65,973) - 55,325 - (55,325) -
Insurance finance income/(expense)
(60,630) (10) (1,725) (62,365) (43,778) (42) (1,269) (45,089)
Total changes in the statement of profit or loss
143,028 611 (129,107) 14,532 143,066 1,810 (115,722) 29,154
Premiums received (266,547) - - (266,547) (234,913) - - (234,913)
Claims and other directly attributable expenses paid - - 119,760 119,760 - - 112,670 112,670
Insurance acquisition cash flows
40,302 - 221 40,523 36,693 (10) 165 36,848
Total cash flows
(226,245) - 119,981 (106,264) (198,220) (10) 112,835 (85,395)
Net insurance contract assets/(liabilities) as at 31 December
(656,452) (5,407) (81,825) (743,684) (573,235) (6,018) (72,699) (651,952)
Insurance contract liabilities as at 31 December (656,452) (5,407) (81,825) (743,684) (580,410) (5,713) (72,301) (658,424)
Insurance contract assets as at 31 December
- - - - 7,175 (305) (398) 6,472
Net insurance contract assets/(liabilities) as at 31 December
(656,452) (5,407) (81,825) (743,684) (573,235) (6,018) (72,699) (651,952)
487
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
31. Insurance and reinsurance contracts (continued)
The table below presents a roll-forward of the net asset or liability for insurance contacts issued, showing
CSM for portfolios included in the life insurance business.
2024 2023
€000 €000
Insurance contract liabilities as at 1 January (58,331) (41,863)
Insurance contract assets as at 1 January
(1,935) (180)
Contractual Service Margin as at 1 January
(60,266) (42,043)
Changes that relate to current services
Contractual service margin recognised for services provided 8,893 7,792
Changes that relate to future services
Contracts initially recognised in the period (2,492) (282)
Changes in estimates that adjust the contractual service margin
(21,691) (25,150)
Insurance service result
(15,290) (17,640)
Insurance finance expenses
(59) (583)
Total changes in the consolidated income statement
(15,349) (18,223)
Contractual Service Margin as at 31 December
(75,615) (60,266)
Insurance contract liabilities as at 31 December (75,615) (58,331)
Insurance contract assets as at 31 December
- (1,935)
Contractual Service Margin as at 31 December
(75,615) (60,266)
32. Debt securities in issue and Subordinated liabilities
2024 2023
Nominal
value
Carrying
value
Nominal
value
Carrying
value
Subordinated
liabilities
Contractual interest
rate
Issuer
€000 €000 €000 €000
Subordinated Tier 2
Capital Note - April
2021
6.625% up to
23 October 2026
BOCH
300,000 307,138 300,000 306,787
Debt securities in
issue
Senior Preferred Notes
- June 2021
2.50% up to
24 June 2026
BOC PCL
300,000 305,274 300,000 303,466
Senior Preferred
Notes - July 2023
7.375% up to
25 July 2027
BOC PCL
350,000 368,714 350,000 368,166
Green Senior Preferred
Notes - May 2024
5% up to
2 May 2028
BOC PCL
300,000 315,447 - -
950,000 989,435 650,000 671,632
BOCH and BOC PCL maintain a Euro Medium Term Note (ΕΜΤΝ) Programme with an aggregate nominal
amount up to €4,000 million.
Subordinated Liabilities
Subordinated Tier 2 Capital Note - April 2021
In April 2021, BOCH issued a €300 million unsecured and subordinated Tier 2 Capital Note under the EMTN
Programme. The note was priced at par with a coupon of 6.625% per annum payable annually in arrear and
resettable on 23 October 2026 at the then prevailing 5-year swap rate plus a margin of 6.902% per annum
up to 23 October 2031, payable annually. The note matures on 23 October 2031. BOCH has the option to
redeem the note early on any day during the six-month period from 23 April 2026 to 23 October 2026,
subject to applicable regulatory consents. The note is listed on the Luxembourg Stock Exchange’s Euro MTF
market.
The fair value of the subordinated liabilities as at 31 December 2024 and 2023 is disclosed in Note 22.
488
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
32. Debt securities in issue and Subordinated liabilities (continued)
Debt securities in issue
Senior Preferred Notes - June 2021
In June 2021, BOC PCL issued a €300 million senior preferred note under the EMTN Programme. The note
was priced at par with a fixed coupon of 2.50% per annum, payable annually in arrear and resettable on 24
June 2026. The note matures on 24 June 2027. BOC PCL has the option to redeem the note early on 24
June 2026, subject to applicable regulatory consents. The note is listed on the Luxembourg Stock
Exchange’s Euro MTF market. The note complies with the criteria for the minimum requirement for own
funds and eligible liabilities (MREL) and contributes towards BOC PCL’s MREL requirements.
Senior Preferred Notes - July 2023
In July 2023, BOC PCL issued a €350 million senior preferred note under the EMTN Programme. The note
was priced at par with a fixed coupon of 7.375% per annum, payable annually in arrear and resettable on
25 July 2027. The note matures on 25 July 2028. BOC PCL has the option to redeem the note early on 25
July 2027, subject to applicable regulatory consents. The note is listed on the Luxembourg Stock Exchange’s
Euro MTF market. The note complies with the criteria for the minimum requirement for own funds and
eligible liabilities (MREL) and contributes towards BOC PCL’s MREL requirements.
Green Senior Preferred Notes - May 2024
In May 2024, BOC PCL issued a €300 million green senior preferred note under the EMTN Programme. The
note was priced at par with a fixed coupon of 5.00% per annum, payable annually in arrear and resettable
on 2 May 2028. The note matures on 2 May 2029. BOC PCL has the option to redeem the note early on 2
May 2028, subject to applicable regulatory consents. The note is listed on the Luxembourg Stock
Exchange’s Euro MTF market. The note complies with the criteria for the minimum requirement for own
funds and eligible liabilities (MREL) and contributes towards BOC PCL’s MREL requirements.
The fair value of the debt securities in issue as at 31 December 2024 and 2023 is disclosed in Note 22.
489
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
33. Accruals, deferred income, other liabilities and other provisions
2024 2023
€000 €000
Income tax payable and related provisions 74,470 66,479
Special defence contribution payable 1,322 1,308
Retirement benefit plan liabilities (Note 14.1) - 565
Provisions for financial guarantees and commitments (Note 44.6.1) 17,893 19,192
Liabilities arising from non-participating investment contracts 119,636 87,756
Accrued expenses and other provisions 93,538 83,738
Deferred income 20,130 19,569
Items in the course of settlement 61,078 69,519
Lease liabilities (Note 42) 36,903 30,217
Other liabilities
131,489 90,922
556,459 469,265
Other liabilities include an amount of €10,385 thousand (2023: €10,385 thousand) relating to the
guarantee fee for the conversion of DTA into tax credits (Note 17) and an amount of €13,367 thousand
(2023: €19,354 thousand) relating to card processing transactions. As at 31 December 2024, other
liabilities include an amount of €9,572 thousand (2023: €1,965 thousand) which relates to dividends
declared in May 2024 in respect of earnings for the year ended 31 December 2023 and in May 2023 in
respect of earnings for the year ended 31 December 2022. As at 31 December 2024, other liabilities include
an amount of €19,495 thousand for the ancillary guarantee fund (2023: nil).
34. Share capital
2024 2023
Number of
shares
(thousand)
€000
Number of
shares
(thousand)
€000
Authorised
Ordinary shares of €0.10 each
10,000,000 1,000,000 10,000,000 1,000,000
Issued
1 January 446,200 44,620 446,200 44,620
Share buyback - repurchase and cancellation
of shares
(5,698) (570) - -
31 December
440,502 44,050 446,200 44,620
Authorised and issued share capital
All issued ordinary shares carry the same rights.
The authorised capital of the Company is €1,000,000 thousand divided into 10,000,000 thousand ordinary
shares of a nominal value €0.10 each. There were no changes to the authorised share capital during the
year ended 31 December 2024 and 2023.
As of 31 December 2024, the Company had 440,502 thousand issued shares (2023: 446,200 thousand
issued shares) of a nominal value of €0.10 each. During the year ended 31 December 2024, the number of
shares issued decreased by 5,698 thousand shares and the value of the issued share capital decreased by
€570 thousand, as shares were repurchased and cancelled under the share repurchase programme. As a
result, an equivalent amount of €570 thousand has been transferred to the Company's capital redemption
reserve by 31 December 2024.
490
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
34. Share capital (continued)
Share premium reserve
There were no changes to the share premium reserve during the years ended 31 December 2024 and 2023.
Share repurchase programme (Buyback)
In April 2024, the Group launched its inaugural programme to buy back ordinary shares of the Company for
an aggregate consideration of up to €25 million (the ‘Programme’). The purpose of the Programme was to
reduce the Company’s issued share capital and therefore the shares purchased under the Programme were
cancelled. On 29 November 2024, the Programme has been completed. 5,698 thousand shares were
repurchased and cancelled under the Programme at a total consideration (including transaction costs) of
€25,090 thousand.
Capital redemption reserve
The capital redemption reserve is a legal reserve arising as a result of the acquisition and cancellation of the
Company’s ordinary shares under a buyback programme, and represents transfers from share capital. The
capital redemption reserve is not distributable. As at 31 December 2024, the capital redemption reserve
amounted to €570 thousand representing 5,698 thousand shares in the Company which have been
cancelled as a result of the buyback programme.
Treasury shares of the Company
The consideration paid, including any directly attributable incremental costs (net of income taxes), for
shares of the Company held by the Company and by entities controlled by the Group is deducted from
equity attributable to the owners of the Company as treasury shares, until these shares are cancelled or
reissued. No gain or loss is recognised in the consolidated income statement on the purchase, sale, issue or
cancellation of such shares.
The life insurance subsidiary of the Group, as at 31 December 2024, held a total of 142 thousand ordinary
shares of the Company of a nominal value of €0.10 each (2023: 142 thousand ordinary shares of a nominal
value of €0.10 each), as part of its financial assets which are invested for the benefit of insurance
policyholders. The cost of acquisition of these shares was €21,463 thousand (2023: €21,463 thousand).
Other equity instruments
2024 2023
€000 €000
2023 Reset Perpetual Additional Tier 1 Capital Securities
220,000 220,000
220,000 220,000
In June 2023, the Company issued €220,000 thousand Fixed Rate Reset Perpetual Additional Tier 1 Capital
Securities (the 'Capital Securities'). The Capital Securities constitute unsecured and subordinated
obligations of the Company, are perpetual and issued at par. They carry an initial coupon of 11.875% per
annum, payable semi-annually, and resettable on 21 December 2028 and every five years thereafter. The
Company may elect to cancel any interest payment for an unlimited period, on a non-cumulative basis,
whereas it mandatorily cancels interest payment under certain conditions. The Capital Securities are
perpetual and have no fixed date of redemption, but can be redeemed (in whole but not in part) at the
Company's option from, and including, 21 June 2028 to, and including, 21 December 2028 and on each
interest payment date thereafter, subject to applicable regulatory consents and the relevant conditions to
redemption. The Capital Securities are listed on the Luxembourg Stock Exchange's Euro Multilateral Trading
Facility (MTF) market.
Transaction costs of €3,530 thousand in relation to the issuance of the Capital Securities were recorded
directly in equity during the year ended 31 December 2023.
491
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
34. Share capital (continued)
In addition, in June 2023 the Company invited the holders of its outstanding €220,000 thousand 2018 Reset
Perpetual Additional Tier 1 Capital Securities (the ‘2018 Capital Securities’) to tender for cash purchase by
the Company at a price equal to 103% of the principal amount. As a result of the tender offer, €204,483
thousand in aggregate nominal amount were purchased and cancelled by the Company as at 30 June 2023.
In July 2023, the Company purchased in the open market approximately €7,000 thousand of the
outstanding nominal amount of such capital securities. In November 2023, the Board of Directors resolved
to exercise the Company’s option to redeem the remaining nominal amount outstanding of the 2018 Capital
Securities in December 2023. As a result of the buy-back, a total cost of €6,820 thousand was recorded
directly in equity during the year ended 31 December 2023.
During the year ended 31 December 2024, coupon payments for the total amount of €26,125 thousand
(2023: €27,339 thousand) were made to the holders of the AT1 instrument and have been recognised in
retained earnings.
35. Distributions
Based on the relevant SREP decisions applicable in the years 2023 and 2024, any equity dividend
distribution was subject to regulatory approval, both for the Company and BOC PCL. The requirement for
approval did not apply if the distributions were made via the issuance of new ordinary shares to the
shareholders which were eligible as Common Equity Tier 1 Capital nor to the payment of coupons on any
AT1 capital instruments issued by the Company or BOC PCL. Following the SREP decision received in
December 2024 the requirement for approval was lifted effective from 1 January 2025.
In March 2024, the Company obtained the approval of the European Central Bank to pay a cash dividend
and to conduct a share buyback (together the ‘2023 Distribution’) in respect of earnings for the year ended
31 December 2023. The 2023 Distribution amounted to €137 million in total, comprising a cash dividend of
€112 million and a share buyback of up to €25 million (Note 34-Share repurchase programme (Buyback)).
The AGM, on 17 May 2024, approved a final cash dividend of €0.25 per ordinary share in respect of
earnings for the year ended 31 December 2023.
In April 2023, the Company obtained the approval of the European Central Bank to pay a dividend in
respect of earnings for the year ended 31 December 2022. The AGM, on 26 May 2023, declared a final cash
dividend of €0.05 per ordinary share in respect of earnings for the year ended 31 December 2022. The
dividend amounted to €22,310 thousand in total.
Information on distribution in respect of 2024 earnings is disclosed in Note 54 of the Consolidated Financial
Statements.
36. Retained earnings
For the purpose of dividend distribution, retained earnings determined at the Company level are the only
distributable reserve.
Companies, tax resident in Cyprus, which do not distribute at least 70% of their profits after tax as defined
by the Special Defence Contribution Law during the two years after the end of the year of assessment to
which the profits refer, will be deemed to have distributed this amount as dividend. Special defence
contribution (SDC) at 17% is payable on such deemed dividend distribution to the extent that the
shareholders of the Company at the end of the period of two years from the end of the year of assessment
to which the profits refer, are directly or indirectly Cyprus tax residents and/or individuals who are Cyprus
tax resident and domiciled in Cyprus. Deemed dividend distribution does not apply in respect of profits that
are directly or indirectly attributable to shareholders that are non-Cyprus tax residents and individual
shareholders who are not domiciled in Cyprus. The deemed dividend distribution is subject to 2.65%
contribution to the General Health System (GHS).
The amount of this deemed dividend distribution is reduced by any actual dividend paid out of the profits of
the relevant year.
This SDC and GHS are paid by the Company on account of the shareholders. During the year ended 31
December 2024, no SDC and GHS on deemed dividend distribution were accrued by the Company and BOC
PCL (2023: SDC and GHS of €42 thousand and €313 thousand were accrued by the Company and BOC PCL
respectively).
492
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
37. Fiduciary transactions
The Group offers fund management and custody services that result in holding or investing financial assets
on behalf of its customers. The Group is not liable to its customers for any default by other banks or
organisations. The assets under management and custody are not included in the consolidated balance
sheet of the Group unless they are placed with the Group. Total assets under management at 31 December
2024, measured at fair value, amounted to €2,183,775 thousand (2023: €1,967,686 thousand).
38. Provisions for pending litigation, claims, regulatory and other matters
The Group, in the ordinary course of business, is involved in various disputes and legal proceedings and is
subject to enquiries and examinations, requests for information, audits, investigations and other
proceedings by regulators, governmental and other public bodies, actual and threatened, relating to the
suitability and adequacy of advice given to clients or the absence of advice, lending and pricing practices,
selling and disclosure requirements, reporting and information security requirements and a variety of other
matters. In addition, as a result of the deterioration of the Cypriot economy and banking sector in 2012 and
the subsequent restructuring of BOC PCL in 2013 as a result of the bail-in Decrees, BOC PCL is subject to a
number of proceedings that either precede or result from the events that occurred during the period of the
bail-in Decrees.
Apart from what is described below, the Group considers that none of these matters are material, either
individually or in aggregate. Nevertheless, provisions have been made where: (a) there is a present
obligation (legal or constructive) arising from past events, (b) the settlement of the obligation is expected
to result in an outflow of resources embodying economic benefits, and (c) a reliable estimate of the amount
of the obligation can be made. The Group has not disclosed an estimate of the potential financial effect on
its contingent liabilities arising from these matters where it is not practicable to do so, because it is too
early or the outcome is too uncertain or, in cases where it is practicable, where disclosure could prejudice
conduct of the matters. Provisions have been recognised for those cases where the Group is able to reliably
estimate probable losses (Note 5.3). Where an individual provision is material, the fact that a provision has
been made is stated except to the extent that doing so would be prejudicial. Any provision recognised does
not constitute an admission of wrongdoing or legal liability. There are also situations where the Group may
enter into a settlement agreement. This may occur only if such settlement is in the Group's interest (such
settlement does not constitute an admission of wrongdoing) and only takes place after obtaining legal
advice and all approvals by the appropriate bodies of management. While the outcome of these matters is
inherently uncertain, management believes that, based on the information available to it, appropriate
provisions have been made in respect of legal proceedings, regulatory and other matters as at 31 December
2024 and hence it is not believed that such matters, when concluded, will have a material impact upon the
financial position of the Group.
38.1 Pending litigation and claims
Investigations and litigation relating to securities issued by BOC PCL
A number of institutional and retail customers have filed various separate actions against BOC PCL alleging
that BOC PCL is guilty of misselling in relation to securities issued by BOC PCL between 2007 and 2011.
Remedies sought include the return of the money investors paid for these securities. Claims are currently
pending before the courts in Cyprus and in Greece.
The bonds and capital securities in respect of which claims have been brought are the following: 2007
Capital Securities, 2008 Convertible Bonds, 2009 Convertible Capital Securities (CCS) and 2011 Convertible
Enhanced Capital Securities (CECS).
BOC PCL is defending these claims, particularly with respect to institutional investors and retail purchasers
who received investment advice from independent investment advisors. In the case of retail investors, if it
can be demonstrated that the relevant BOC PCL's officers 'persuaded' them to proceed with the purchase
and/or purported to offer 'investment advice', BOC PCL may face significant difficulties.
To date, a number of cases have been tried in Greece. BOC PCL has appealed against any such cases which
were not ruled in its favour, except for cases adjudicated against BOC PCL at Areios Pagos (Supreme Court
of Greece) which are deemed as concluded.
Similarly, a number of cases have been tried in Cyprus and some are pending at appeal. It is to be noted
that the statutory limitation period for filing claims in the courts of Cyprus with respect to this for which the
cause of action arose prior and up to 31 December 2015, expired on 31 December 2021.
493
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
38. Provisions for pending litigation, claims, regulatory and other matters (continued)
38.1 Pending litigation and claims (continued)
The resolution of the claims brought in the courts of Greece and Cyprus is expected to take a number of
years.
Provision has been made based on management's best estimate of probable outflows for capital securities
related litigation.
Bail-in related litigation
Depositors
A number of BOC PCL's depositors, who allege that they were adversely affected by the bail-in, filed claims
against BOC PCL and other parties (such as the CBC and the Ministry of Finance of Cyprus) including against
BOC PCL as the alleged successor of Laiki Bank on the grounds that, inter alia, the ‘Resolution Law of 2013’
and the Bail-in Decrees were in conflict with the Constitution of the Republic of Cyprus and the European
Convention on Human Rights. They are seeking damages for their alleged losses resulting from the bail-in of
their deposits. Cases could relate to bail-in related litigation (on failure to follow instructions), bail-in decree
related cases and bail-in wrongful application. BOC PCL is defending these actions. In relation to the bail-in
decree related cases, the court ruled in favour of BOC PCL on the grounds that the measures that the
government implemented were necessary to prevent the collapse of the financial sector, which would have
detrimental consequences for the country’s economy. Under the circumstances the government could rely
on the doctrine of necessity when it imposed the bail-in. To date, a number of cases have been tried
however the resolution of the claims brought is expected to take a number of years.
Provision has been made based on management's best estimate of probable outflows for depositors related
litigation.
Shareholders
A number of actions for damages have been filed with the District Courts of Cyprus alleging either the
unconstitutionality of the Resolution Law and the Bail-in Decrees, or a misapplication of same by BOC PCL
(as regards the way and methodology whereby such Decrees have been implemented), or that BOC PCL
failed to follow instructions promptly prior to the bail-in coming into force. As at the present date, both the
Resolution Law and the Bail-in Decrees have not been annulled by a court of law and thus remain legally
valid and in effect. BOC PCL contests all of these claims.
Legal position of the Group
All of the above claims are being vigorously disputed by the Group, in close consultation with the
appropriate state and governmental authorities. The position of the Group is that the Resolution Law and
the Decrees take precedence over all other laws. As matters now stand, both the Resolution Law and the
Decrees issued thereunder are constitutional and lawful, in that they were properly enacted and have not so
far been annulled by any court.
Provident fund case
In December 2015, the Bank of Cyprus Employees Provident Fund (the Provident Fund) filed an action
against BOC PCL claiming €70 million allegedly owed as part of BOC PCL's contribution by virtue of an
agreement with the Union dated 31 December 2011. Towards the end of 2024, the Group has reached a
final settlement arrangement, which has received final court approval so that the case was permanently
withdrawn with no right to be reinstated, and as a result of which, the Group has recognised a provision as
at 31 December 2024. The financial settlement took place early in 2025. This matter is now concluded,
without anything pending at court.
Employment litigation
Former employees of the Group have instituted a number of employment claims including unfair dismissals.
The Group does not consider that the pending cases in relation to employment will have a material impact
on its financial position. A judgment has been issued in one of the unfair dismissal cases and BOC PCL lost.
BOC PCL has filed an appeal with respect to this case and similarly, the plaintiff has also filed an appeal. The
facts of this case are unique and it is not expected to affect the rest of the cases where unfair dismissal is
claimed.
Additionally, a number of former employees have filed claims against BOC PCL contesting entitlements
received relating to the various voluntary exit plans. As at the reporting date, most of these cases have
been withdrawn with only two such cases remaining. The Group does not expect that these actions will have
a material impact on its financial position.
494
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
38. Provisions for pending litigation, claims, regulatory and other matters (continued)
38.1 Pending litigation and claims (continued)
Banking business cases
There is a number of banking business cases where the amounts claimed are significant. These cases
primarily concern allegations as to BOC PCL's standard policies and procedures allegedly resulting to
damages and other losses for the claimants (including cases where it is alleged that BOC PCL misled
borrowers and/or misrepresented matters, in violation of applicable laws for matters such as foreign
currency lending and advancing/misselling loans for the purchase of property in Cyprus by UK nationals).
Further, there are several other banking claims, where the amounts involved are not as significant.
Management has assessed either the probability of loss as remote and/or does not expect any future
outflows with respect to these cases to have a material impact on the financial position of the Group. Such
matters arise as a result of the Group’s activities and management appropriately assesses the facts and the
risks of each case accordingly.
General criminal investigations and proceedings
The Attorney General and the Cypriot Police (the Police) are conducting various investigations and inquiries
following and relating to the financial crisis which culminated in March 2013. BOC PCL is cooperating fully
with the Attorney General and the Police and is providing all information requested of it. Based on the
currently available information, the Group is of the view that any further investigations or claims resulting
from these investigations will not have a material impact on its financial position.
Others
An investigation is in process related to potentially overstated and/or fictitious claims paid by the non-life
insurance subsidiary of the Group. The information usually required by IAS 37 'Provisions, Contingent
Liabilities and Contingent Assets' is not disclosed on the grounds that it is expected to seriously prejudice
the outcome of the investigation and/or the possible taking of legal action. Based on the information
available at present, management considers that it is unlikely for this matter to have a material adverse
impact on the financial position and capital adequacy of the non-life insurance subsidiary and thereby the
Group, also taking into account that it is virtually certain that compensations will be received from a
relevant insurance coverage, upon the settlement of any obligation that may arise.
38.2 Regulatory matters
The Hellenic Capital Market Commission (HCMC) Investigation
The HCMC has been in the process of investigating matters concerning the Group's investment in Greek
Government Bonds from 2009 to 2011, including, inter alia, related non-disclosure of material information
in BOC PCL's CCS, CECS and rights issue prospectuses (tracking the investigation carried out by CySEC in
2013), Greek government bonds' reclassification, ELA disclosures and allegations by some investors
regarding BOC PCL's non-compliance with Markets in Financial Instruments Directive (MiFID) in respect of
investors' direct investments in Greek Government Bonds.
A specific estimate of the outcome of the investigations or of the amount of possible fines cannot be given
at this stage, though it is not expected that any resulting liability or damages will have a material impact on
the financial position of the Group.
Central Bank of Cyprus (CBC)
The CBC had conducted an investigation in the past into BOC PCL's issuance of capital securities and
concluded that BOC PCL breached certain regulatory requirements concerning the issuance of Convertible
Capital Securities (Perpetual) in 2009, but not in relation to the CECS in 2011. The CBC had, in 2013,
imposed a fine of €4 thousand upon BOC PCL, who filed a recourse. The Administrative Court cancelled both
the CBC’s decision and the fine that was imposed upon BOC PCL in a respective judgment dated in 2020. In
2021, CBC decided to re-examine this matter and to re-open the investigation. This matter is still pending
as at the year end.
495
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
38. Provisions for pending litigation, claims, regulatory and other matters (continued)
38.2 Regulatory matters (continued)
Commission for the Protection of Competition Investigation (CPC)
In April 2014, following an investigation which began in 2010, CPC issued a statement of objections,
alleging violations of Cypriot and EU competition law relating to the activities and/or omissions in respect of
card payment transactions by, among others, BOC PCL and JCC Payment Systems Ltd (JCC), a card
processing business currently 75% owned by BOC PCL. There was also an allegation concerning BOC PCL's
arrangements with American Express, namely that such exclusive arrangements violated Cypriot and EU
competition law. On both matters, the CPC has concluded that BOC PCL (in common with other banks and
JCC) has breached the relevant provisions of the applicable law for the protection of competition and
imposed a fine of €18 million upon BOC PCL. BOC PCL filed a recourse against the decision and the fine. In
June 2018, the Administrative Court accepted BOC PCL’s position and cancelled the decision as well as the
fine imposed upon BOC PCL. During 2018, the Attorney General has filed an appeal before the Supreme
court with respect to such decision. Following the decision of the appeal court in a CySEC case, the Attorney
General acting on behalf of CPC withdrew his appeal. In July 2024, the Group was informed that the CPC
had resolved to refrain from re-opening the investigation and the matter is now considered closed.
Consumer Protection Service (CPS)
In July 2017, CPS imposed a fine of €170 thousand upon BOC PCL after concluding an ex officio
investigation regarding some terms in both BOC PCL's and Marfin Popular Bank's loan documentation, that
were found to constitute unfair commercial practices. Decisions of the CPS (according to rulings of the
Administrative Court) are not binding but merely an expression of opinion. BOC PCL has filed a recourse
before the Administrative Court against this decision. The Administrative Court has issued its judgment in
2022 in favour of BOC PCL, and the CPS decision along with the fine have been cancelled. An appeal has
been submitted by CPS with regards to this judgment, which is still pending as at 31 December 2024.
In March 2020, BOC PCL has been served with an application by the director of CPS seeking for an order of
the court, with immediate effect, the result of which will be for BOC PCL to cease the use of a number of
terms in the contracts of BOC PCL relating to 2006-2007 deemed to be unfair under the said order. This
application was withdrawn in November 2024 and the matter is considered closed.
In April 2021, the director of CPS filed an application for the issuance of a court order against BOC PCL,
prohibiting the use of a number of contractual terms included in BOC PCL’s consumer contracts and
requiring the amendment of any such contracts (present and future) so as to remove such unfair terms.
This matter is still pending before the court as at 31 December 2024.
Cyprus Consumers’ Association (CCA)
In March 2021, BOC PCL was served with an application filed by the CCA for the issuance of a court order
prohibiting the use of a number of contractual terms included in BOC PCL’s consumer contracts and
requiring the amendment of any such contracts (present and future) so as to remove such terms deemed as
unfair. The said contractual terms were determined as unfair pursuant to the decisions issued by the
Consumer Protection Service of the Ministry of Energy, Commerce, Industry and Tourism against BOC PCL
in 2016 and 2017. BOC PCL will take all necessary steps for the protection of its interests. This matter is
still pending before the court as at 31 December 2024.
The Consumer Protection Law 2021 brings under one umbrella the existing legislation on unfair contract
terms and practices with some enhanced powers vested in the Consumer Protection Service, i.e. power to
impose increased fines which are immediately payable. The Consumer Protection Law 2021 has a
retrospective effect in that it also applies to all contracts/practices entered into and/or terminated prior to
this law coming into effect as opposed to contracts/practices which are only entered into/adopted as from
the date of publication of the new Law on Consumer Protection.
There are many factors that may affect the range of outcomes and the resulting financial impact of these
matters is unknown.
UK regulatory matters
During the year ended 31 December 2024, the obligation undertaken in regards to UK regulatory matters as
part of the sale of Bank of Cyprus UK Ltd expired and was terminated, thus the respective provision balance
was released.
496
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
38. Provisions for pending litigation, claims, regulatory and other matters (continued)
38.3 Οther matters
Other matters include among others, provisions for various other open examination requests by
governmental and other public bodies, legal matters and provisions for warranties and indemnities related
to the disposal process of certain operations of the Group.
The provisions for pending litigation and claims, regulatory and other matters described above and provided
in the tables below do not include insurance claims arising in the ordinary course of business of the Group’s
insurance subsidiaries as these are included in ‘Insurance contract liabilities’.
38.4 Provisions for pending litigation, claims, regulatory and other matters
Pending
litigation and
claims
(Note 38.1)
Regulatory
matters
(Note 38.2)
Other matters
(Note 38.3)
Total
2024 €000 €000 €000 €000
1 January 60,968 14,741 55,794 131,503
Net increase in provisions including unwinding
of discount
42,714 - 11,374 54,088
Utilisation of provisions (24,274) (58) (29,802) (54,134)
Release of provisions (10,896) (11,618) (16,601) (39,115)
Transfer - - 234 234
Foreign exchange adjustments
- 44 - 44
31 December
68,512 3,109 20,999 92,620
Provisions expected to be settled within 12
months post reporting date
39,897 - 7,661 47,558
2023
1 January 63,947 14,918 48,742 127,607
Net increase in provisions including unwinding
of discount
36,227 527 4,940 41,694
Utilisation of provisions (28,777) (727) (108) (29,612)
Release of provisions (10,429) - - (10,429)
Transfer - - 2,220 2,220
Foreign exchange adjustments
- 23 - 23
31 December
60,968 14,741 55,794 131,503
Provisions expected to be settled within 12
months post reporting date
24,814 - 29,606 54,420
Provisions for pending litigation, claims, regulatory and other matters recorded in the consolidated income
statement during the year ended 31 December 2024 amounted to €11,775 thousand (2023: €28,464
thousand), include a credit amount of €3,198 thousand representing an amount recovered on the conclusion
of open examinations of governmental bodies and amounts from litigation settled, directly recognised in the
consolidated income statement (2023: €2,801 thousand).
Some information required by IAS 37 'Provisions, Contingent Liabilities and Contingent Assets' is not
disclosed on the grounds that it can be expected to prejudice seriously the outcome of the litigation or the
outcome of the negotiation in relation to provisions for warranties and indemnities related to the disposal
process of certain operations of the Group.
39. Contingent liabilities and commitments
As part of the services provided to its customers, the Group enters into various irrevocable commitments
and contingent liabilities. These consist of financial and other guarantees, letters of credit and other
undrawn commitments to lend.
Even though these obligations may not be recognised on the consolidated balance sheet, they do entail
credit risk and are therefore part of the overall credit risk exposure of the Group (Notes 44.1 and 44.6).
497
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
39. Contingent liabilities and commitments (continued)
39.1 Capital commitments
Capital commitments for the acquisition of property, equipment and intangible assets as at 31 December
2024 amount to 22,456 thousand (2023: 20,139 thousand).
39.2 Contingent liabilities
The Group, as part of the disposal process of certain of its operations, has provided various representations,
warranties and indemnities to the buyers. These relate to, among other things, the ownership of the loans,
the validity of the liens, tax exposures and other matters agreed with the buyers. As a result, the Group
may be obliged to compensate the buyers in the event of a valid claim by the buyers with respect to the
above representations, warranties and indemnities.
A provision has been recognised, based on management’s best estimate of probable outflows, where it was
assessed that such an outflow is probable (Note 38.3).
40. Additional information on cash flow statement
Non-cash transactions
Repossession of collaterals
During the year ended 31 December 2024, the Group acquired properties by taking possession of collaterals
held as security for loans and advances to customers of €25,833 thousand (2023: €20,921 thousand).
Recognition of RoU assets and lease liabilities
During 2024 the Group recognised RoU assets and corresponding lease liabilities of €2,470 thousand (2023:
€11,353 thousand).
Net cash flow from operating activities - interest and dividends
2024 2023
€000 €000
Interest paid (157,284) (121,785)
Interest received 994,849 1,038,442
Dividends received (Note 13)
183 856
837,748 917,513
Changes in liabilities arising from financing activities
Funding from
central banks
(Note 29)
Debt
securities in
issue and
Subordinated
liabilities
(Note 32)
Total
2024 €000 €000 €000
1 January 2,043,868 978,419 3,022,287
Cash flows (2,065,710) 244,579 (1,821,131)
Other non-cash movements
21,842 73,575 95,417
31 December
- 1,296,573 1,296,573
2023
1 January 1,976,674 599,740 2,576,414
Cash flows - 320,314 320,314
Other non-cash movements
67,194 58,365 125,559
31 December
2,043,868 978,419 3,022,287
Further information relating to the change in lease liabilities is disclosed in Note 42.
498
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
41. Cash and cash equivalents
Cash and cash equivalents comprise:
2024 2023
€000 €000
Cash and non-obligatory balances with central banks 7,435,634 9,555,323
Loans and advances to banks with original maturity less than three months
288,211 282,998
7,723,845 9,838,321
Analysis of cash and balances with central banks and loans and advances to banks
2024 2023
€000 €000
Cash and non-obligatory balances with central banks 7,435,634 9,555,323
Obligatory balances with central banks (Note 19) 117,702 59,179
Balances with central banks for ancillary systems (restricted)
47,390 -
Total cash and balances with central banks (Note 19)
7,600,726 9,614,502
Loans and advances to banks with original maturity less than three months 288,211 282,998
Loans and advances to banks with original maturity more than three months 472,163 -
Restricted loans and advances to banks
60,200 101,804
Total loans and advances to banks (Note 19)
820,574 384,802
Restricted loans and advances to banks include nil collaterals under derivative transactions (2023: €13,970
thousand) which are not immediately available for use by the Group, but are released once the transactions
are terminated. As at 31 December 2024, €6,685 thousand were placed as collateral for the reverse
repurchase agreements (2023: €29,524 thousand) (Note 44.11).
42. Leases
The Group is a lessee for commercial properties such as office and branch buildings. The basic terms for
lease contracts relating to the branch network are primarily uniform, irrespective of lessors, with the non-
cancellable rental period being two years. The Group has the option to extend the tenancy for four further
periods of two years each. The Group has the right at any time after the expiry of the initial term to
terminate the present rental agreement by providing notice (usually 3 or 6 months’ notice) to the lessor.
Depending on the terms agreed, the rent is adjusted at the end of each renewal period, according to the
current rates of the area and considering the relevant legislation.
Office buildings are leased by the Group for the operation of administrative functions. The basic terms for
new lease contracts and the current practice are substantially the same with those for lease contracts of
branches.
As at 31 December 2024, the lease term for branches and other buildings was re-assessed using the
assumptions as detailed in Note 5.12, resulting in a remeasurement of the lease liability for those contracts.
499
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
42. Leases (continued)
The carrying amounts of the Group’s RoU assets and lease liabilities and the movement during the year
ended 31 December 2024 and the year ended 31 December 2023 is presented in the table below:
2024
RoU assets
(Note 25)
Lease
Liabilities
(Note 33)
€000 €000
1 January 33,862 (30,217)
Depreciation charge for the year (Note 15.1) (9,828) -
New leases (Note 25) 2,470 (1,489)
Re-assesment of lease terms (Note 25) 16,158 (16,158)
Assets derecognised (Note 25) (369) 1,713
Interest expense - (493)
Cash outflows-payments
- 9,741
31 December
42,293 (36,903)
2023
RoU assets
(Note 25)
Lease
Liabilities
(Note 33)
€000 €000
1 January 30,233 (30,190)
Depreciation charge for the year (Note 15.1) (6,736) -
New leases (Note 25) 11,353 (7,113)
Re-assesment of lease terms (Note 25) (988) 693
Interest expense - (1,453)
Cash outflows-payments
- 7,846
31 December
33,862 (30,217)
As at 31 December 2024 RoU assets comprised of leases of buildings of a carrying amount of €33,124
thousand (2023: €22,400 thousand) and computer hardware of a carrying amount of €9,169 thousand
(2023: €11,462 thousand), and are presented within Property and equipment in Note 25.
Interest expense on lease liabilities of €231 thousand is included within net insurance service result as it is
directly attributable expense for the fulfilment of insurance contracts within IFRS 17 scope (2023: €1,159
thousand).
Cash outflows relate to lease payments made during the year.
The analysis of lease liabilities based on remaining contractual maturity is disclosed in Note 46.
500
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
43. Analysis of assets and liabilities by expected maturity
2024 2023
Less than
one year
Over one
year
Total
Less than
one year
Over one
year
Total
Assets €000 €000 €000 €000 €000 €000
Cash and balances with
central banks
7,435,634 165,092 7,600,726 9,555,323 59,179 9,614,502
Loans and advances to
banks
760,374 60,200 820,574 282,998 101,804 384,802
Derivative financial assets 8,742 86,531 95,273 859 50,196 51,055
Investments 714,954 3,643,389 4,358,343 736,664 2,958,745 3,695,409
Reverse repurchase
agreements
- 1,010,170 1,010,170 - 403,199 403,199
Loans and advances to
customers
1,214,221 8,900,173 10,114,394 1,192,800 8,628,988 9,821,788
Life insurance business
assets attributable to
policyholders
34,373 738,384 772,757 27,632 621,580 649,212
Prepayments, accrued
income and other assets
379,085 100,114 479,199 350,152 234,767 584,919
Stock of property 155,015 493,742 648,757 191,818 634,297 826,115
Investment properties 11,985 24,266 36,251 10,605 51,500 62,105
Deferred tax assets 37,909 128,935 166,844 37,909 163,359 201,268
Property, equipment and
intangible assets
- 357,161 357,161 - 334,203 334,203
Non-current assets and
disposal groups held for
sale
23,143 - 23,143 - - -
10,775,435 15,708,157 26,483,592 12,386,760 14,241,817 26,628,577
Liabilities
Deposits by banks 140,694 223,537 364,231 202,850 268,706 471,556
Funding from central
banks
- - - 2,043,868 - 2,043,868
Derivative financial
liabilities
798 3,866 4,664 14,079 3,901 17,980
Customer deposits 6,528,640 13,990,636 20,519,276 5,984,800 13,352,115 19,336,915
Changes in the fair value
of hedged items in
portfolio hedges of
interest rate risk
- 44,074 44,074 - - -
Insurance liabilities 100,390 643,294 743,684 88,616 569,808 658,424
Accruals, deferred income
and other liabilities and
provisions for pending
litigation, claims,
regulatory and other
matters
393,195 255,884 649,079 371,498 229,270 600,768
Debt securities in issue
and subordinated
liabilities
- 1,296,573 1,296,573 - 978,419 978,419
Deferred tax liabilities
- 31,943 31,943 1,622 30,684 32,306
7,163,717 16,489,807 23,653,524 8,707,333 15,432,903 24,140,236
The main assumptions used in determining the expected maturity of assets and liabilities are set out below.
Cash and balances with central banks, loans and advances to banks and reverse repurchase agreements are
classified in the relevant time band based on the contractual maturity, with the exception of obligatory
balances with central banks and balances with central banks for ancillary systems and restricted balances
with other banks which are classified in the 'Over one year' time band.
501
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
43. Analysis of assets and liabilities by expected maturity (continued)
The investments and life insurance assets attributable to policy holders are classified in the relevant time
band based on expectations as to their realisation. In most cases this is the maturity date, unless there is
an indication that the maturity will be prolonged or there is an intention to sell, roll or replace the security
with a similar one.
Performing loans and advances to customers in Cyprus are classified based on the contractual repayment
schedule. Overdraft accounts are classified in the ‘Over one year’ time band. The Stage 3 Loans are
classified in the ‘Over one year’ time band except cash flows from expected receipts which are included
within time bands, according to historic amounts of receipts in the recent months.
Stock of property and investment property are classified in the relevant time band based on expectations as
to their realisation.
A percentage of customer deposits maturing within one year is classified in the ‘Over one year’ time band,
based on the observed behavioural analysis.
Deposits by banks are classified based on contractual maturity.
The expected maturity of all prepayments, accrued income and other assets and accruals, deferred income
and other liabilities is the same as their contractual maturity. If they do not have a contractual maturity, the
expected maturity is based on the timing the asset is expected to be realised and the liability is expected to
be settled.
44. Risk management - Credit risk
Credit risk is the risk that arises from the possible failure of one or more customers to discharge their credit
obligations towards the Group, together with the counterparty credit risk arising from investment in debt
securities.
In the ordinary course of its business the Group is exposed to credit risk which is monitored through various
control mechanisms across all Group entities in order to identify and measure credit risk, control risk taking
including preventing undue risk concentrations.
In order to manage this risk, management has in place established credit risk policies on which the Group's
lending and investment procedures are based on. The credit risk policies are complemented by the
methods/models used for the assessment of the customers' credit worthiness (credit rating and credit
scoring systems) as disclosed in Note 44.4.
Management and structure
The Credit Risk Management department, develops and sets credit risk policies, guidelines and approval
limits which are necessary to manage and control or mitigate the credit and concentration risk of the Group.
The Credit Risk Control and Monitoring department monitors compliance with credit risk policies applicable
to each business line and the quality of the Group's loans and advances portfolio. The credit exposures of
related accounts are aggregated and monitored on a consolidated basis.
The Credit Risk Management department, in co-operation with the Credit Risk Control and Monitoring
department, also safeguards the effective management of credit risk at all stages of the credit cycle,
monitors the quality of decisions and processes and ensures that the credit sanctioning function is being
properly managed.
The credit risk exposure of the Group is diversified across the various sectors of the economy. Credit Risk
Management department determines concentration limits for each sector, sets prohibited sectors and
defines sectors which may require prior approval before credit applications are submitted.
The loan portfolio is analysed on the basis of the customers' creditworthiness, their economic sector of
activity and geographical concentration.
The debt securities portfolio is managed by the Treasury Division in line with limits and parameters set in
the various policies and frameworks. The Market & Liquidity Risk department assesses the credit risk
relating to exposures to credit institutions and governments and other exposures of both the debt securities
portfolio as well as reverse repurchase agreements.
The Group sets credit risk control limits and country risk exposure limits to mitigate concentration risk.
502
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
Models and limits are presented to and approved by the Board of Directors, through the relevant authority
based on the authorisation level limits.
The Group’s significant judgements, estimates and assumptions regarding the determination of the level of
provisions for impairment are described in Note 5.
Monitoring process and credit risk mitigation
Loans and advances to customers
The Credit Risk Management department determines the effective credit standards required for the granting
of new loans to customers. The assessment of financial position/repayment ability is the determining factor
when assessing the granting of a new loan. Furthermore, post-approval monitoring is in place to ensure
adherence to both terms and conditions set in the approval process and credit risk policies and procedures.
A key aspect of credit risk is credit risk concentration which is defined as the risk that arises from the
uneven distribution of exposures to individual borrowers, specific industry or economic sectors, geographical
regions, product types or currencies. The monitoring and control of concentration risk is achieved by limit
setting (e.g. sector and name limits) and reporting them to senior management. In addition, the Group
obtains collaterals which are used for risk mitigation, as they act as a secondary source of repayment.
The main types of collateral obtained by the Group are mortgages on real estate, cash collateral/blocked
deposits, bank guarantees, government guarantees, pledges of equity securities and debt instruments of
public companies, fixed and floating charges over corporate assets, assignment of life insurance policies,
assignment of rights on contracts of sale and personal and corporate guarantees.
The Group regularly monitors the changes in the market value of the collateral and, where necessary,
requests the pledging of additional collateral in accordance with the relevant agreement.
The Group's requirements on obtaining collateral, valuation and management of collateral are set out in
relevant policies of the Group.
Off-balance sheet exposures
The Group enters into various irrecoverable commitments and contingent liabilities, by offering guarantee
facilities, documentary credits and other commitments to extend credit lines of its customers to secure their
liquidity needs. Even though these obligations may not be recognised on the statement of financial position,
such commitments expose the Group to risks similar to those of loans and advances and are therefore
monitored by the same policies and control processes.
The Group makes available to its customers guarantees that may require that the Bank makes payments on
their behalf. The Group also enters into commitments, such as documentary credits which commit the
Group to make payments on behalf of customers in the event of a specific act, generally related to the
import or export of goods.
Policies and procedures for managing, monitoring and mitigating credit risk on off-balance sheet exposures
apply as for loans and advances to customers.
Other financial instruments
Collateral held as security for financial assets other than loans and advances to customers and off-balance
sheet exposures is determined by the nature of the financial instrument. Debt securities and other eligible
bills are generally unsecured with the exception of asset-backed securities and similar instruments, which
are secured by pools of financial assets. In addition, some debt securities are government-guaranteed.
Reverse repurchase agreements are generally secured by bonds.
The Market & Liquidity Risk Unit monitors the debt security investment and reverse repo arrangement limits
in place for governing the level of riskiness of the overall portfolio, as well as the credit limits per issuer.
Analysis of the positions the Group maintains per issuer type is presented in Note 20 and information for
the credit quality is presented in Note 44.11.
503
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
The Group has chosen the ISDA Master Agreement for documenting its derivatives activity. It provides the
contractual framework within which dealing activity across a full range of over-the-counter (OTC) products
is conducted and contractually binds both parties to apply close-out netting across all outstanding
transactions covered by an agreement, if either party defaults. In most cases the parties execute a Credit
Support Annex (CSA) in conjunction with the ISDA Master Agreement. Under a CSA, the collateral is passed
between the parties in order to mitigate the market contingent counterparty risk inherent in their open
positions. As at 31 December 2024, the majority of derivative exposures are covered by ISDA netting
arrangements. The effect of potential effect of netting arrangements on the Group's financial position is
presented in Note 52. An analysis of derivative asset and liability exposures is available in Note 21.
Information about the Group’s level of collateral under derivative transactions as at 31 December is
provided in Note 41.
44.1 Maximum exposure to credit risk and collateral and other credit enhancements
The table below presents the maximum exposure to credit risk, the tangible and measurable collateral and
credit enhancements held and the net exposure to credit risk, that is the exposure after taking into account
the impairment loss and tangible and measurable collateral and credit enhancements held. Personal
guarantees are an additional form of collateral, but are not included in the information below since it is
impracticable to estimate their fair value.
The fair value of the collateral presented in the tables below is capped to the carrying value of the loans and
advances to customers.
504
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.1 Maximum exposure to credit risk and collateral and other credit enhancements (continued)
Fair value of collateral and credit enhancements held by the Group
Maximum
exposure to
credit risk
Cash Securities
Letters of credit/
guarantee
Property Other Surplus collateral Net collateral
Net exposure to
credit risk
2024
€000 €000 €000 €000 €000 €000 €000 €000 €000
Balances with central banks (Note 19) 7,505,735 - - - - - - - 7,505,735
Loans and advances to banks (Note 19) 820,574 - - - - - - - 820,574
Reverse repurchase agreements (Note 44.11) 1,010,170 13,068 1,006,856 - - - (9,754) 1,010,170 -
FVPL non-equity securities (Note 20) 10,702 - - - - - - - 10,702
Debt securities classified at amortised cost and
FVOCI (Note 20)
4,212,177 - - - - - - - 4,212,177
Derivative financial instruments (Note 21) 95,273 - - - - - - - 95,273
Loans and advances to customers (Note 23) 10,114,394 577,972 659,723 233,160 17,141,516 292,621 (10,037,307) 8,867,685 1,246,709
Loans and advances to customers classified as
held for sale (Note 23)
23,143 - - - - - - - 23,143
Debtors (Note 28) 33,340 - - - - - - - 33,340
Insurance and reinsurance contract assets
(Note 28)
50,612 - - - - - - - 50,612
Deferred purchase payment consideration
(Note 28)
143,604 - - - - - - - 143,604
Other financial assets (Note 28)
118,688 57,481 - - - - - 57,481 61,207
On-balance sheet total
24,138,412 648,521 1,666,579 233,160 17,141,516 292,621 (10,047,061) 9,935,336 14,203,076
Contingent liabilities
Acceptances and endorsements 5,271 - - - 5,269 2 - 5,271 -
Guarantees 705,774 72,744 209 4,099 148,199 224 - 225,475 480,299
Commitments
Documentary credits 14,768 844 - - 166 - - 1,010 13,758
Undrawn formal stand-by facilities, credit lines
and other commitments to lend
2,009,698 26,529 20,349 2,459 439,691 22,722 - 511,750 1,497,948
Off-balance sheet total
2,735,511 100,117 20,558 6,558 593,325 22,948 - 743,506 1,992,005
26,873,923 748,638 1,687,137 239,718 17,734,841 315,569 (10,047,061) 10,678,842 16,195,081
505
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.1 Maximum exposure to credit risk and collateral and other credit enhancements (continued)
Fair value of collateral and credit enhancements held by the Group
Maximum
exposure to
credit risk
Cash Securities
Letters of credit/
guarantee
Property Other Surplus collateral Net collateral
Net exposure to
credit risk
2023
€000 €000 €000 €000 €000 €000 €000 €000 €000
Balances with central banks (Note 19) 9,521,961 - - - - - - - 9,521,961
Loans and advances to banks (Note 19) 384,802 39,344 - - - - - 39,344 345,458
FVPL non-equity securities (Note 20) 3,611 - - - - - - - 3,611
Debt securities classified at amortised cost and FVOCI
(Note 20)
3,547,782 - - - - - - - 3,547,782
Reverse repurchase agreements (Note 44.11) 403,199 - 426,419 - - - (29,524) 396,895 6,304
Derivative financial instruments (Note 21) 51,055 - - - - - - - 51,055
Loans and advances to customers (Note 23) 9,821,788 475,241 743,890 149,415 16,755,799 275,344 (9,615,735) 8,783,954 1,037,834
Debtors (Note 28) 34,662 - - - - - - - 34,662
Insurance and reinsurance contract assets (Note 28) 57,494 - - - - - - - 57,494
Deferred purchase payment consideration (Note 28) 243,013 - - - - - - - 243,013
Other financial assets (Note 28)
109,314 - - - - - - - 109,314
On-balance sheet total
24,178,681 514,585 1,170,309 149,415 16,755,799 275,344 (9,645,259) 9,220,193 14,958,488
Contingent liabilities
Acceptances and endorsements 2,580 8 - - 2,570 2 - 2,580 -
Guarantees 703,044 71,752 1,874 6,797 145,545 255 - 226,223 476,821
Commitments
Documentary credits 10,251 140 - - 21 - - 161 10,090
Undrawn formal stand-by facilities, credit lines and
other commitments to lend
1,948,482 22,980 10,648 9,764 455,964 17,231 - 516,587 1,431,895
Off-balance sheet total
2,664,357 94,880 12,522 16,561 604,100 17,488 - 745,551 1,918,806
26,843,038 609,465 1,182,831 165,976 17,359,899 292,832 (9,645,259) 9,965,744 16,877,294
506
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.2 Credit risk concentration of loans and advances to customers
There are restrictions on loan concentrations which are imposed by the Banking Law in Cyprus, the relevant
CBC Directives and CRR. The Group’s Risk Appetite Statement may impose stricter concentration limits
which are monitored by the Group.
The credit risk concentration, which is based on industry (economic activity) and business line, as well as
the geographical concentration, is presented below.
The geographical analysis, for credit risk concentration purposes, is based on the Group’s Country Risk
Policy which is followed for monitoring the Group's exposures. Market and Liquidity Risk department is
responsible for analysing the country risk of exposures. ALCO reviews the country risk of exposures on a
quarterly basis and the Board, through its Risk Committee, reviews the country risk of exposures and any
breaches of country risk limits on a regular basis and at least annually.
The table below presents the geographical concentration of loans and advances to customers by country of
risk based on the country of residency for individuals and the country of registration for companies.
2024
Cyprus Greece
United
Kingdom
Russia
Other
countries
Gross loans at
amortised cost
By economic activity
€000 €000 €000 €000 €000 €000
Trade 880,142 8,405 1 - 15,283 903,831
Manufacturing 275,779 9,691 193 - 31,412 317,075
Hotels and catering 914,460 33,500 38,355 - 36,329 1,022,644
Construction 453,362 36,629 - - 297 490,288
Real estate 757,099 114,289 2 - 34,565 905,955
Private individuals 4,670,608 7,842 34,513 7,534 40,083 4,760,580
Professional and other services 568,294 567 5,171 6 61,550 635,588
Shipping 36,874 12 - - 302,279 339,165
Other sectors
606,598 106,116 - 5 42,560 755,279
9,163,216 317,051 78,235 7,545 564,358 10,130,405
2024
Cyprus Greece
United
Kingdom
Russia
Other
countries
Gross loans at
amortised cost
By business line
€000 €000 €000 €000 €000 €000
Corporate 3,286,902 59,961 195 - 163 3,347,221
IBU & International corporate
- IBU 92,206 1,638 4,769 5,214 16,867 120,694
- International corporate 147,180 251,140 43,245 - 519,456 961,021
SMEs 964,412 402 1,054 - 2,203 968,071
Retail
- housing 3,496,469 2,544 22,185 80 14,071 3,535,349
- consumer, credit cards and other 1,033,208 1,339 337 - 5,510 1,040,394
Restructuring
- corporate 16,015 - 1,241 112 66 17,434
- SMEs 20,289 - 157 - 100 20,546
- retail housing 35,644 - 534 126 80 36,384
- retail other 15,169 2 3 - 30 15,204
Recoveries
- corporate 3,627 - 32 144 377 4,180
- SMEs 7,760 4 390 876 634 9,664
- retail housing 25,795 5 3,571 907 4,574 34,852
- retail other
18,540 16 522 86 227 19,391
9,163,216 317,051 78,235 7,545 564,358 10,130,405
507
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.2 Credit risk concentration of loans and advances to customers (continued)
2023
Cyprus Greece
United
Kingdom
Russia
Other
countries
Gross loans at
amortised cost
By economic activity
€000 €000 €000 €000 €000 €000
Trade 868,039 277 40 - 15,340 883,696
Manufacturing 287,524 43,971 192 - 31,194 362,881
Hotels and catering 928,910 29,454 36,704 - 39,368 1,034,436
Construction 486,622 8,332 14 - 331 495,299
Real estate 871,544 108,635 1,863 - 51,349 1,033,391
Private individuals 4,543,985 9,680 56,074 12,075 48,080 4,669,894
Professional and other services 535,994 572 5,242 352 54,846 597,006
Shipping 20,622 15 - - 222,422 243,059
Other sectors
512,666 - - 2 30,184 542,852
9,055,906 200,936 100,129 12,429 493,114 9,862,514
2023 (restated)
Cyprus Greece
United
Kingdom
Russia
Other
countries
Gross loans at
amortised cost
By business line
€000 €000 €000 €000 €000 €000
Corporate 3,326,556 30,487 193 324 185 3,357,745
IBU & International corporate
- IBU 87,127 1,688 6,544 6,901 18,618 120,878
- International corporate 115,212 164,103 43,401 - 439,512 762,228
SMEs 945,018 482 1,177 - 2,316 948,993
Retail
- housing 3,369,111 2,320 27,728 86 17,634 3,416,879
- consumer, credit cards and other 956,834 1,775 480 - 4,953 964,042
Restructuring
- corporate 48,440 - 611 - - 49,051
- SMEs 33,212 - 261 532 61 34,066
- retail housing 57,685 - 2,468 122 212 60,487
- retail other 19,164 22 2 - 23 19,211
Recoveries
- corporate 6,079 - 182 173 911 7,345
- SMEs 13,419 1 1,173 1,623 1,183 17,399
- retail housing 50,927 50 14,718 2,399 7,231 75,325
- retail other
27,122 8 1,191 269 275 28,865
9,055,906 200,936 100,129 12,429 493,114 9,862,514
The loans and advances to customers include lending exposures in Cyprus with collaterals in Greece with a
carrying value as at 31 December 2024 of €176,890 thousand (2023: €128,705 thousand).
The loans and advances to customers reported within 'Other countries' as at 31 December 2024 include
exposures of €0,6 million in Ukraine (2023: €1,7 million) and €4,9 million in Israel (2023: €4,9 million).
508
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.3 Analysis of loans and advances to customers
The movement of the gross loans and advances to customers at amortised cost by staging, including the
loans and advances to customers classified as held for sale is presented in the tables below:
Stage 1 Stage 2 Stage 3 POCI Total
2024 €000 €000 €000 €000 €000
1 January 8,275,589 1,161,271 326,883 98,771 9,862,514
Transfers to stage 1 565,289 (564,134) (1,155) - -
Transfers to stage 2 (228,889) 265,111 (36,222) - -
Transfers to stage 3 (14,037) (19,442) 33,479 - -
Foreign exchange and other
adjustments
- - (5) - (5)
Write offs (801) (619) (47,106) (4,951) (53,477)
Interest accrued and other
adjustments
417,918 74,717 43,137 7,703 543,475
New loans originated or
purchased and drawdowns of
existing facilities
2,252,251 69,200 1,877 11,336 2,334,664
Loans derecognised or repaid
(excluding write offs)
(2,140,595) (212,439) (100,651) (49,241) (2,502,926)
Changes to contractual cash flows
due to modifications
(230) 1,415 120 (224) 1,081
31 December
9,126,495 775,080 220,357 63,394 10,185,326
Stage 1 Stage 2 Stage 3 POCI Total
2023 €000 €000 €000 €000 €000
1 January 7,867,256 1,565,603 371,018 113,458 9,917,335
Transfers to stage 1 786,990 (785,026) (1,964) - -
Transfers to stage 2 (514,415) 546,249 (31,834) - -
Transfers to stage 3 (38,959) (83,436) 122,395 - -
Foreign exchange and other
adjustments
- - 10 - 10
Write offs (594) (588) (79,286) (5,282) (85,750)
Interest accrued and other
adjustments
388,970 39,662 47,804 8,001 484,437
New loans originated or
purchased and drawdowns of
existing facilities
1,827,530 89,118 8,125 1,847 1,926,620
Loans derecognised or repaid
(excluding write offs)
(2,038,389) (210,331) (107,490) (22,753) (2,378,963)
Changes to contractual cash flows
due to modifications
(2,800) 20 (1,895) (149) (4,824)
Acquisition of Velocity 2 portfolio
- - - 3,649 3,649
31 December
8,275,589 1,161,271 326,883 98,771 9,862,514
As at 31 December 2023 no loans and advances to customers were classified as held for sale.
For revolving facilities, overdrafts and credit cards, the net positive change in balance by stage excluding
write-offs is reported in ‘New loans originated’ and the net negative change is reported in ‘Loans
derecognised or repaid'.
The analysis of gross loans and advances to customers at amortised cost by staging and by business line
concentration is included in Note 23.
509
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.3 Analysis of loans and advances to customers (continued)
The movement of gross loans and advances to customers at amortised cost, in the Corporate, IBU &
International corporate, SME and Retail business lines in Cyprus (the country where the loans are
managed), are presented in the tables below:
Corporate
IBU &
International
corporate
SME Retail
2024 €000 €000 €000 €000
1 January 3,357,421 883,106 948,624 4,380,921
Transfers (out of)/in business line (19,487) (3,596) 21,822 (5,792)
Write offs (4,597) (189) (144) (1,458)
Interest accrued 179,997 77,373 44,709 201,869
New loans originated or purchased 933,201 426,906 204,860 761,804
Loans derecognised or repaid (excluding write
offs)
(1,098,155) (302,429) (252,530) (762,789)
Changes to contractual cash flows due to
modifications not resulting in derecognition
(1,159) 544 396 1,188
31 December
3,347,221 1,081,715 967,737 4,575,743
Corporate
IBU &
International
corporate
SME Retail
2023 (restated) €000 €000 €000 €000
1 January 3,398,475 823,182 1,026,608 4,264,777
Transfers in/(out of) business line 111,905 (35,005) (38,809) 36,081
Write offs (25,277) (173) (142) (1,165)
Interest accrued 166,290 56,142 59,465 159,108
New loans originated or purchased 748,197 218,979 192,439 696,146
Loans derecognised or repaid (excluding write
offs)
(1,037,422) (179,763) (291,534) (775,774)
Changes to contractual cash flows due to
modifications not resulting in derecognition
(4,747) (256) 597 1,748
31 December
3,357,421 883,106 948,624 4,380,921
44.4 Credit quality of loans and advances to customers based on the internal credit rating
Credit scoring is the primary risk rating system for assessing obligor and transaction risk for the key
portfolios of BOC PCL. For the purposes of credit scoring, these portfolios are Corporate, Retail and SMEs.
Corporate and SME portfolios include legal entities. Retail portfolio includes individuals.
Scoring models use internal and external data to assess and 'score' borrowers and their credit quality, in
order to provide further input on managing limits for existing loans and collection activities. The data is
specific to the borrower but additional data which could affect the borrower’s behaviour is also used.
Credit score is one of the factors employed on new clients and management of existing clients. The credit
score of the borrower is used to assess the credit quality for each independent acquisition or account
management action, leading to an automated decision or guidance for an adjudicator. Credit scoring
enhances the credit decision quality and facilitates risk-based pricing where feasible.
Borrower score defines the rating of the borrower from a range of 1-8 where 8 is defined as defaulted. The
12-months probability of default (PD) is calculated per rating. The following table presents weighted PD per
risk level's rating for corporate, retail and SME exposures.
Unrated corporate exposures are assessed using the Group's in-house behavioural scorecard model for
corporate legal entities. Unrated retail exposures include qualifying revolving facilities without scoring (i.e.
prepaid cards) and other revolving facilities (i.e. financial guarantees) which are assigned a more generic
curve. Similarly unrated SME exposures are assigned a more generic segment curve.
510
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.4 Credit quality of loans and advances to customers based on the internal credit rating
(continued)
New customers' lending to corporate and SME legal entities and new lending to retail individuals are
separately disclosed since a time span of seven months is necessary in order to provide an accurate rating.
The portfolios weighted PD per rating is presented below.
2024 12-month PD
Rating
Corporate legal entities
%
Retail individuals
%
SME legal entities
%
1 0.52 0.04 0.08
2 0.55 0.06 0.17
3 0.71 0.11 0.35
4 0.98 0.16 1.26
5 1.43 0.50 3.73
6 1.74 3.34 8.44
7 2.07 8.80 15.62
2023 12-month PD
Rating
Corporate legal entities
%
Retail individuals
%
SME legal entities
%
1 1.32 0.10 0.18
2 1.42 0.17 0.46
3 1.75 0.28 0.96
4 2.38 0.42 3.37
5 3.68 0.89 8.92
6 3.82 7.20 18.16
7 4.88 15.21 36.65
Lower rating exposures demonstrate a better capacity to meet financial commitments, with lower
probability of default, whereas higher rating exposures require varying degrees of special attention and
default risk is of greater concern.
As disclosed in Note 5.1 under section ‘Calibration of IFRS 9 models and removal of overlays in relation to
economic conditions', the Group during 2024 proceeded with model calibrations affecting the probability of
default parameter (the ‘PD-macro’) which led to a reduction in portfolios weighted PDs, when compared to
last year.
The tables below show the gross loans and advances to customers at amortised cost which are managed in
Cyprus, using the corporate legal entities, SMEs legal entities and retail individuals definition as per the
internal rating of BOC PCL.
2024 2023
Stage 1 Stage 2 Total Stage 1 Stage 2 Total
Corporate legal entities €000 €000 €000 €000 €000 €000
Rating 1 795,970 7,675 803,645 654,192 8,681 662,873
Rating 2 414,627 12,266 426,893 404,127 2,604 406,731
Rating 3 840,468 17,460 857,928 857,583 17,943 875,526
Rating 4 617,084 181,452 798,536 420,299 75,912 496,211
Rating 5 446,603 85,994 532,597 593,987 210,143 804,130
Rating 6 58,029 61,365 119,394 97,182 176,247 273,429
Rating 7 6,217 21,329 27,546 30,182 10,713 40,895
Unrated 231,861 22,225 254,086 230,024 34,157 264,181
New customers
654,183 48,048 702,231 397,922 14,956 412,878
4,065,042 457,814
4,522,856
3,685,498 551,356
4,236,854
Total Stage 3 and POCI
58,171 157,455
4,581,027 4,394,309
511
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.4 Credit quality of loans and advances to customers based on the internal credit rating
(continued)
2024 2023
Stage 1 Stage 2 Total Stage 1 Stage 2 Total
Retail individuals €000 €000 €000 €000 €000 €000
Rating 1 404,639 1,263 405,902 410,510 886 411,396
Rating 2 309,996 898 310,894 296,784 1,182 297,966
Rating 3 539,982 1,155 541,137 531,271 8,583 539,854
Rating 4 1,523,523 12,369 1,535,892 1,387,960 59,067 1,447,027
Rating 5 1,107,575 48,957 1,156,532 915,585 195,178 1,110,763
Rating 6 59,245 81,998 141,243 63,506 91,634 155,140
Rating 7 82,361 120,555 202,916 104,288 121,092 225,380
Unrated - 2,215 2,215 - 2,099 2,099
New customers
380,491 6,629 387,120 308,043 13,166 321,209
4,407,812 276,039
4,683,851
4,017,947 492,887
4,510,834
Total Stage 3 and POCI
146,115 230,837
4,829,966 4,741,671
2024 2023
Stage 1 Stage 2 Total Stage 1 Stage 2 Total
SMEs legal entities €000 €000 €000 €000 €000 €000
Rating 1 125,714 1,235 126,949 120,165 3,360 123,525
Rating 2 260,609 2,266 262,875 210,856 47,818 258,674
Rating 3 125,330 8,654 133,984 108,742 29,117 137,859
Rating 4 47,228 15,261 62,489 45,841 14,490 60,331
Rating 5 10,668 4,285 14,953 13,021 5,771 18,792
Rating 6 3,414 4,361 7,775 5,300 3,328 8,628
Rating 7 3,172 1,415 4,587 3,324 2,534 5,858
Unrated - 670 670 - 6,312 6,312
New customers
77,368 3,080 80,448 64,722 4,298 69,020
653,503 41,227
694,730
571,971 117,028
688,999
Total Stage 3 and POCI
24,348 36,842
719,078 725,841
512
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.5 Credit losses of loans and advances to customers
The movement in ECL of loans and advances to customers, including those classified as held for sale, is as
follows:
Stage 1 Stage 2 Stage 3 POCI Total
2024 €000 €000 €000 €000 €000
1 January 24,205 30,257 103,996 20,995 179,453
Transfers to stage 1 11,706 (11,386) (320) - -
Transfers to stage 2 (660) 4,411 (3,751) - -
Transfers to stage 3 (131) (984) 1,115 - -
Impact on transfer between
stages during the year*
(8,970) 1,221 7,638 (173) (284)
Foreign exchange and other
adjustments
- - 41 - 41
Write offs (801) (619) (47,106) (4,951) (53,477)
Interest (provided) not
recognised in the income
statement
- - 4,156 1,105 5,261
New loans originated or
purchased*
5,043 - - 385 5,428
Loans derecognised or repaid
(excluding write offs)*
(4,390) (1,177) (14,213) (801) (20,581)
Write offs* 748 325 12,193 295 13,561
Changes to models and inputs
(changes in PDs, LGDs and EADs)
used for ECL calculations*
(14,380) 15,373 43,693 3,684 48,370
Changes to contractual cash flows
due to modifications not resulting
in derecognition*
(365) 1,318 77 (5) 1,025
31 December
12,005 38,739 107,519 20,534 178,797
Individually assessed 3,378 17,069 21,286 10,485 52,218
Collectively assessed
8,627 21,670 86,233 10,049 126,579
12,005 38,739 107,519 20,534 178,797
* Individual components of the ‘Impairment net of reversals on loans and advances to customers’ (Note
16).
The main driver of the ECL charge are the ‘Changes to models and inputs (changes in PDs, LGDs and EADs)
used for ECL calculations’ which includes the calibration of the provisioning models as set out in Note 5.1
together with the impact of the agreement for disposal of NPE portfolio (Project River).
As at 31 December 2023 no loans and advances to customers were classified as held for sale.
513
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.5 Credit losses of loans and advances to customers (continued)
Stage 1 Stage 2 Stage 3 POCI Total
2023 €000 €000 €000 €000 €000
1 January 22,288 27,041 113,573 15,540 178,442
Transfers to stage 1 10,985 (10,504) (481) - -
Transfers to stage 2 (1,532) 6,677 (5,145) - -
Transfers to stage 3 (481) (2,576) 3,057 - -
Impact on transfer between
stages during the year*
(8,860) 3,450 24,888 - 19,478
Foreign exchange and other
adjustments
- - 91 - 91
Write offs (594) (588) (79,286) (5,282) (85,750)
Interest (provided) not
recognised in the income
statement
- - 3,827 1,079 4,906
New loans originated or
purchased*
5,953 - - 992 6,945
Loans derecognised or repaid
(excluding write offs)*
(2,798) (782) (5,433) (162) (9,175)
Write offs* 455 340 7,981 1,118 9,894
Changes to models and inputs
(changes in PDs, LGDs and EADs)
used for ECL calculations*
258 7,021 39,891 7,935 55,105
Changes to contractual cash flows
due to modifications not resulting
in derecognition*
(1,469) 178 1,033 (225) (483)
31 December
24,205 30,257 103,996 20,995 179,453
Individually assessed 8,287 11,983 45,178 13,480 78,928
Collectively assessed
15,918 18,274 58,818 7,515 100,525
24,205 30,257 103,996 20,995 179,453
* Individual components of the ‘Impairment net of reversals on loans and advances to customers’ (Note
16).
The analysis of credit losses of loans and advances to customers by business line, excluding those classified
as held for sale is presented in the table below:
Stage 1 Stage 2 Stage 3 POCI Total
2024 €000 €000 €000 €000 €000
Corporate 4,468 17,645 14,830 323 37,266
IBU & International corporate
- IBU 84 378 51 5 518
- International corporate 1,925 1,070 - - 2,995
SMEs 958 3,209 3,303 142 7,612
Retail
- housing 2,604 10,895 4,911 526 18,936
- consumer, credit cards and
other
1,836 4,856 4,790 750 12,232
Restructuring
- corporate 2 127 1,627 10,178 11,934
- SMEs 47 123 2,997 515 3,682
- retail housing 53 371 10,686 341 11,451
- retail other 28 65 7,524 475 8,092
Recoveries
- corporate - - 2,053 158 2,211
- SMEs - - 4,714 470 5,184
- retail housing - - 11,686 2,600 14,286
- retail other
- - 9,344 1,276 10,620
12,005 38,739 78,516 17,759 147,019
514
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.5 Credit losses of loans and advances to customers (continued)
Stage 1 Stage 2 Stage 3 POCI Total
2023 (restated) €000 €000 €000 €000 €000
Corporate 12,993 11,727 32,761 5,169 62,650
IBU & International corporate
- IBU 161 323 40 5 529
- International corporate 1,498 816 38 6 2,358
SMEs 2,424 2,403 1,200 303 6,330
Retail
- housing 3,098 6,435 3,804 486 13,823
- consumer, credit cards and
other
3,693 5,665 4,969 1,164 15,491
Restructuring
- corporate 21 1,635 6,962 9,964 18,582
- SMEs 134 589 4,334 553 5,610
- retail housing 75 440 12,393 204 13,112
- retail other 108 224 7,060 489 7,881
Recoveries
- corporate - - 3,342 267 3,609
- SMEs - - 4,794 150 4,944
- retail housing - - 13,772 1,094 14,866
- retail other
- - 8,527 1,141 9,668
24,205 30,257 103,996 20,995 179,453
The movement of the ECL allowance for the loans and advances to customers in the Corporate, IBU &
International corporate, SME and Retail business lines in Cyprus (the country where the loans are
managed), is presented in the table below:
Corporate
IBU &
International
corporate
SME Retail
2024 €000 €000 €000 €000
1 January 62,425 2,887 6,134 29,314
Transfer (out of)/in the business line (10,684) 91 921 (1,409)
Write offs (4,597) (189) (144) (1,458)
Interest (provided) not recognised in the income
statement
987 2 116 458
New loans originated or purchased 1,998 1,029 287 1,688
Loans derecognised or repaid (excluding write offs)
(10,004) (487) (216) (2,183)
Write offs 10 21 79 979
Changes to models and inputs (changes in PDs,
LGDs and EADs) used for ECL calculations
(1,078) (52) 105 4,317
Changes to contractual cash flows due to
modifications not resulting in derecognition
800 (2) 174 64
Impact on transfer between stages during the year
(2,591) 213 (40) (602)
31 December
37,266 3,513 7,416 31,168
515
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.5 Credit losses of loans and advances to customers (continued)
Corporate
IBU &
International
corporate
SME Retail
2023 (restated) €000 €000 €000 €000
1 January 56,359 1,087 5,879 24,827
Transfer in/(out of) the business line (660) 112 76 (1,813)
Write offs (25,276) (173) (142) (1,165)
Interest (provided) not recognised in the income
statement
287 - - 464
New loans originated or purchased 4,058 470 616 1,804
Loans derecognised or repaid (excluding write offs)
(2,627) (315) - (1,615)
Write offs 18 28 135 740
Changes to models and inputs (changes in PDs,
LGDs and EADs) used for ECL calculations
12,120 885 242 6,236
Changes to contractual cash flows due to
modifications not resulting in derecognition
481 4 (469) (283)
Impact on transfer between stages during the year
17,665 789 (203) 119
31 December
62,425 2,887 6,134 29,314
During the year ended 31 December 2024 the total non-contractual write-offs recorded by the Group
amounted to €25,391 thousand (2023: €66,547 thousand). The contractual amount outstanding on financial
assets that were written off during the year ended 31 December 2024 and that are still subject to
enforcement activity is €187,288 thousand (2023: €566,451 thousand).
Sensitivity analysis
The Group has performed sensitivity analysis relating to the loan portfolio in Cyprus, which represents more
than 99% of the total loan portfolio of the Group with reference date 31 December 2024 and 2023.
The Group has applied sensitivity analysis to the below parameters and the impact on the ECL, for both
individually and collectively assessed ECL calculations, is presented in the table below:
Increase/(decrease) on ECL for
loans and advances to customers
at amortised cost
2024 2023
€000 €000
Increase the adverse weight by 5% and decrease the favourable weight by 5% 1,560 1,297
Decrease the adverse weight by 5% and increase the favourable weight by 5% (1,677) (1,629)
Increase the expected recovery period by 1 year 1,965 6,090
Decrease the expected recovery period by 1 year (2,047) (7,863)
Increase the collateral realisation haircut by 5% 4,429 8,816
Decrease the collateral realisation haircut by 5% (3,771) (9,495)
Increase in the PDs of stages 1 and 2 by 20%* 18,232 5,424
Decrease in the PDs of stages 1 and 2 by 20%* (8,273) (5,880)
516
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.5 Credit losses of loans and advances to customers (continued)
The increase/(decrease) on ECL, for loans and advances to customers at amortised cost is presented per
stage in the table below:
Stage 1 Stage 2 Stage 3 Total
2024 €000 €000 €000 €000
Increase the adverse weight by 5% and decrease the
favourable weight by 5%
186 931 443 1,560
Decrease the adverse weight by 5% and increase the
favourable weight by 5%
(213) (522) (942) (1,677)
Increase the expected recovery period by 1 year 139 870 956 1,965
Decrease the expected recovery period by 1 year (111) (687) (1,249) (2,047)
Increase the collateral realisation haircut by 5% 265 1,579 2,585 4,429
Decrease the collateral realisation haircut by 5% (182) (1,067) (2,522) (3,771)
Increase in the PDs of stages 1 and 2 by 20%* 1,810 16,422 - 18,232
Decrease in the PDs of stages 1 and 2 by 20%* (2,059) (6,214) - (8,273)
Stage 1 Stage 2 Stage 3 Total
2023 €000 €000 €000 €000
Increase the adverse weight by 5% and decrease the
favourable weight by 5%
295 204 798 1,297
Decrease the adverse weight by 5% and increase the
favourable weight by 5%
(235) (267) (1,127) (1,629)
Increase the expected recovery period by 1 year 727 1,201 4,162 6,090
Decrease the expected recovery period by 1 year (695) (1,121) (6,047) (7,863)
Increase the collateral realisation haircut by 5% 1,037 1,692 6,087 8,816
Decrease the collateral realisation haircut by 5% (900) (1,406) (7,189) (9,495)
Increase in the PDs of stages 1 and 2 by 20%* 2,624 2,800 - 5,424
Decrease in the PDs of stages 1 and 2 by 20%* (1,325) (4,555) - (5,880)
*The impact on the ECL also includes the transfer between stages of the loans and advances to customers
following the increase/decrease in the PD.
517
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.5 Credit losses of loans and advances to customers (continued)
The sensitivity analysis performed on the collateral realisation haircut and its impact on the ECL by business
line is presented in the table below:
Increase the
collateral
realisation
haircut by
5%
Decrease the
collateral
realisation
haircut by
5%
Increase the
collateral
realisation
haircut by 5%
Decrease the
collateral
realisation
haircut by 5%
2024 2024
2023
(restated)
2023
(restated)
€000 €000 €000 €000
Corporate 553 (1,061) 2,708 (2,521)
IBU & International corporate
- IBU 3 (2) 9 (6)
- International corporate 17 (14) 65 (55)
SMEs 464 (382) 365 (324)
Retail
- housing 940 (638) 1,128 (811)
- consumer, credit cards and other 200 (137) 336 (286)
Restructuring
- corporate 34 (29) 1,029 (3,337)
- SMEs 109 (88) 233 (300)
- retail housing 660 (576) 694 (616)
- retail other 148 (140) 196 (175)
Recoveries
- corporate 22 (87) 123 (111)
- SMEs 209 (146) 932 (319)
- retail housing 671 (346) 693 (455)
- retail other
399 (125) 305 (179)
4,429 (3,771) 8,816 (9,495)
44.6 Contingent liabilities and commitments
The Group enters into various irrevocable commitments and contingent liabilities. These consist of
acceptances and endorsements, guarantees, documentary credits and undrawn formal stand-by facilities,
credit lines and other commitments to lend.
44.6.1 Contingent liabilities
An analysis of changes in the outstanding nominal amount of exposures and the corresponding ECL are
disclosed in the tables below:
Stage 1 Stage 2 Stage 3 Total
2024 €000 €000 €000 €000
Exposures
1 January 483,831 184,827 36,966 705,624
Transfers to stage 1 51,626 (51,626) - -
Transfers to stage 2 (16,549) 17,453 (904) -
Transfers to stage 3 (147) (3,121) 3,268 -
Net increase/(decrease)
45,157 (32,736) (7,000) 5,421
31 December
563,918 114,797 32,330 711,045
518
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.6 Contingent liabilities and commitments (continued)
44.6.1 Contingent liabilities (continued)
Stage 1 Stage 2 Stage 3 Total
2023 €000 €000 €000 €000
Exposures
1 January 509,186 110,626 36,582 656,394
Transfers to stage 1 8,820 (8,755) (65) -
Transfers to stage 2 (88,817) 91,722 (2,905) -
Transfers to stage 3 (585) (3,763) 4,348 -
Net increase/(decrease)
55,227 (5,003) (994) 49,230
31 December
483,831 184,827 36,966 705,624
Stage 1 Stage 2 Stage 3 Total
2024 €000 €000 €000 €000
ECL
1 January - 18 19,174 19,192
Net decrease - - (293) (293)
Credit for the year
- (4) (1,002) (1,006)
31 December
- 14 17,879 17,893
Individually assessed - - 17,879 17,879
Collectively assessed
- 14 - 14
- 14 17,879 17,893
Stage 1 Stage 2 Stage 3 Total
2023 €000 €000 €000 €000
ECL
1 January 119 110 17,013 17,242
Transfers to stage 3 (35) (4) 39 -
Charge/(credit) for the year
(84) (88) 2,122 1,950
31 December
- 18 19,174 19,192
Individually assessed - - 19,174 19,174
Collectively assessed
- 18 - 18
- 18 19,174 19,192
The credit quality of contingent liabilities as per the internal rating system of BOC PCL is disclosed in the
table below.
2024 2023
Stage 1 Stage 2 Total Stage 1 Stage 2 Total
Corporate legal entities €000 €000 €000 €000 €000 €000
Rating 1 98,192 2,161 100,353 130,436 266 130,702
Rating 2 17,055 151 17,206 16,168 2 16,170
Rating 3 92,078 63 92,141 33,253 29,663 62,916
Rating 4 27,905 421 28,326 26,279 2,686 28,965
Rating 5 73,886 17,939 91,825 25,253 30,270 55,523
Rating 6 1,768 5,700 7,468 19,494 281 19,775
Rating 7 1,817 66 1,883 6,485 33 6,518
Unrated 64,565 23,683 88,248 26,003 33,737 59,740
New customers
56,061 500 56,561 102,235 6,174 108,409
433,327 50,684
484,011
385,606 103,112
488,718
Total Stage 3
6,038 8,314
490,049 497,032
519
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.6 Contingent liabilities and commitments (continued)
44.6.1 Contingent liabilities (continued)
2024 2023
Stage 1 Stage 2 Total Stage 1 Stage 2 Total
SME legal entities €000 €000 €000 €000 €000 €000
Rating 1 57,714 1,147 58,861 42,683 2,796 45,479
Rating 2 20,390 74 20,464 6,435 8,181 14,616
Rating 3 3,149 536 3,685 1,599 1,950 3,549
Rating 4 672 916 1,588 329 907 1,236
Rating 5 6 2 8 31 7 38
Rating 6 17 2 19 3 14 17
Rating 7 27 136 163 4 137 141
Unrated - 43,046 43,046 - 50,393 50,393
New customers
48,616 1,213 49,829 47,141 122 47,263
130,591 47,072
177,663
98,225 64,507
162,732
Total Stage 3
26,190 28,232
203,853 190,964
2024 2023
Stage 1 Stage 2 Total Stage 1 Stage 2 Total
Retail individuals €000 €000 €000 €000 €000 €000
Unrated
- 17,041 17,041 - 17,208 17,208
- 17,041
17,041
- 17,208
17,208
Total Stage 3
102 420
17,143 17,628
44.6.2 Commitments
An analysis of changes in the outstanding exposures and the corresponding ECL are disclosed in the tables
below:
Stage 1 Stage 2 Stage 3 Total
2024 €000 €000 €000 €000
Exposure
1 January
1,665,479 271,766 21,488
1,958,733
Transfers to stage 1
156,132 (155,983) (149)
-
Transfers to stage 2
(23,419) 23,754 (335)
-
Transfers to stage 3
(441) (2,736) 3,177
-
Net increase/(decrease)
62,616 7,353 (4,236)
65,733
31 December
1,860,367 144,154 19,945 2,024,466
Stage 1 Stage 2 Stage 3 Total
2023 €000 €000 €000 €000
Exposure
1 January 1,564,964 319,114 43,033 1,927,111
Transfers to stage 1 121,814 (121,602) (212) -
Transfers to stage 2 (100,140) 102,838 (2,698) -
Transfers to stage 3 (4,872) (3,783) 8,655 -
Net increase/(decrease)
83,713 (24,801) (27,290) 31,622
31 December
1,665,479 271,766 21,488 1,958,733
520
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.6 Contingent liabilities and commitments (continued)
44.6.2 Commitments (continued)
Stage 1 Stage 2 Stage 3 Total
2023 €000 €000 €000 €000
ECL
1 January 90 97 - 187
Charge/(credit) for the year
(90) (97) - (187)
31 December
- - - -
There is no ECL on commitments as at 31 December 2024 and 2023.
The credit quality of commitments, as per the internal rating system of BOC PCL is disclosed in the table
below.
2024 2023
Stage 1 Stage 2 Total Stage 1 Stage 2 Total
Corporate legal entities €000 €000 €000 €000 €000 €000
Rating 1 287,501 4,488 291,989 280,836 10,252 291,088
Rating 2 48,996 2,543 51,539 63,694 1,672 65,366
Rating 3 90,481 1,897 92,378 78,107 8,560 86,667
Rating 4 106,090 6,608 112,698 77,465 3,669 81,134
Rating 5 63,889 12,487 76,376 45,954 22,251 68,205
Rating 6 1,691 4,919 6,610 14,720 4,892 19,612
Rating 7 1,883 555 2,438 2,074 336 2,410
Unrated 131,778 45,041 176,819 90,986 51,113 142,099
New customers
91,060 2,359 93,419 86,953 707 87,660
823,369 80,897
904,266
740,789 103,452
844,241
Total Stage 3
11,035 11,981
915,301 856,222
2024 2023
Stage 1 Stage 2 Total Stage 1 Stage 2 Total
SME legal entities €000 €000 €000 €000 €000 €000
Rating 1 306,438 17,151 323,589 275,684 34,643 310,327
Rating 2 104,628 1,473 106,101 54,993 56,903 111,896
Rating 3 18,280 1,916 20,196 11,146 13,215 24,361
Rating 4 3,529 1,196 4,725 2,698 1,811 4,509
Rating 5 558 100 658 530 322 852
Rating 6 128 152 280 173 152 325
Rating 7 13 9 22 7 192 199
Unrated - 5,242 5,242 - 8,577 8,577
New customers
11,375 692 12,067 16,658 915 17,573
444,949 27,931
472,880
361,889 116,730
478,619
Total Stage 3
5,125 5,742
478,005 484,361
521
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.6 Contingent liabilities and commitments (continued)
44.6.2 Commitments (continued)
2024 2023
Stage 1 Stage 2 Total Stage 1 Stage 2 Total
Retail individuals €000 €000 €000 €000 €000 €000
Rating 1 143,334 8,115 151,449 145,977 11,477 157,454
Rating 2 83,886 4,617 88,503 85,690 5,503 91,193
Rating 3 136,728 6,649 143,377 135,923 10,084 146,007
Rating 4 88,827 3,502 92,329 90,081 6,541 96,622
Rating 5 27,224 1,519 28,743 22,724 5,899 28,623
Rating 6 4,704 1,778 6,482 5,317 2,645 7,962
Rating 7 931 1,213 2,144 1,142 1,459 2,601
Unrated 30 7,038 7,068 - 6,832 6,832
New customers
106,385 895 107,280 75,947 1,144 77,091
592,049 35,326
627,375
562,801 51,584
614,385
Total Stage 3
3,785 3,765
631,160 618,150
44.7 Collateral and other credit enhancements obtained
The carrying value of assets obtained during 2024 and 2023 by taking possession of collateral held as
security, was as follows:
2024 2023
€000 €000
Residential property 7,968 5,980
Commercial and other property 11,388 14,560
Land (fields and plots)
6,477 -
25,833 20,540
The total carrying value of stock of property and investment properties obtained over the years by taking
possession of collateral held as security for customer loans and advances and held by the Group as at 31
December 2024, including any expenses capitalised during the year, amounted to €659,976 thousand
(2023: €861,675 thousand).
The disposals of repossessed assets during 2024 amounted to 174,840 thousand (2023: 173,587
thousand).
44.8 Currency concentration of loans and advances to customers
The following table presents the currency concentration of the Group's loans and advances to customers at
amortised cost.
2024 2023
Gross loans at amortised cost €000 €000
Euro 9,475,479 9,336,828
US Dollar 573,140 409,555
British Pound 72,361 87,610
Russian Rouble - 324
Swiss Franc 8,935 27,358
Other currencies
490 839
10,130,405 9,862,514
522
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.9 Modified loans and advances to customers
Modified loans and advances to customers are those loans where the original contractual terms of the loans
i. have been modified due to financial difficulties of the borrower and are considered as
forborne/restructured (as explained in Note 44.10), and
ii. have been modified due to commercial renegotiations and such loans are considered as non-
forborne.
Customers classified as Stage 2 and Stage 3 as at 31 December 2023, that had facilities modified (in a prior
or the current period), and are classified as Stage 1 as at 31 December 2024 amount to €157,066 thousand
(2023: €137,357 thousand) and their corresponding ECL amount to €251 thousand (2023: €547 thousand).
Previously classified Stage 2 and Stage 3 customers (with a carrying amount as at 31 December 2023 of
€95,331 thousand (2022: €30,012 thousand)) that had facilities modified during the year and are classified
as Stage 1 at 31 December 2024 amount to €88,935 thousand (2023: €19,113 thousand) and their
corresponding ECL amount to €118 thousand (2023: €36 thousand). Their related modification loss
amounted to €277 thousand (2023: €55 thousand).
Stage 2 and Stage 3 loans that were forborne during the year amounted to €148,112 thousand (2023:
€44,827 thousand). Their related modification loss amounted to €5,941 thousand (2023: €3,036 thousand).
Facilities that reverted to Stage 2 and Stage 3 having once cured during the year amount to €44,655
thousand (2023: €51,720 thousand) and their corresponding ECL amount to €3,243 thousand (2023:
€1,984 thousand) as at 31 December 2024.
44.10 Forbearance/Restructuring
Forborne/restructured loans and advances are those loans and advances that have been modified because
the borrower is considered unable to meet the terms and conditions of the contract due to financial
difficulties. Taking into consideration these difficulties, the Group decides to modify the terms and
conditions of the contract to provide the borrower with the ability to service the debt or refinance the
contract, either partially or fully. They include the facilities for which the Group has modified the repayment
programme (e.g. provision of a grace period, suspension of the obligation to repay one or more
instalments, reduction in the instalment amount and/or elimination of overdue instalments relating to
capital or interest).
The practice of extending forbearance/restructuring measures constitutes a grant of a concession whether
temporarily or permanently to that borrower. A concession may involve restructuring the contractual terms
of a debt or payment in some form other than cash, such as an arrangement whereby the borrower
transfers collateral pledged to the Group.
For an account to qualify for forbearance/restructuring it must meet certain criteria including the viability of
the customer. The extent to which the Group reschedules accounts that are eligible under its existing
policies may vary depending on its view of the prevailing economic conditions and other factors which may
change from year to year. In addition, exceptions to policies and practices may be allowed in specific
situations in response to legal or regulatory requirements.
Forbearance/restructuring activities may include measures that restructure the borrower's business
(operational restructuring) and/or measures that restructure the borrower's financing (financial
restructuring).
Forbearance/restructuring options may be of a short or long-term nature or a combination thereof. The
Group has developed and deployed sustainable restructuring solutions, which are suitable for the borrower
and acceptable for the Group.
Short-term restructuring solutions are defined as restructured repayment solutions of duration of less than
two years. In the case of loans for the construction of commercial property and project finance, a short-
term solution may not exceed one year.
Short-term restructuring solutions can include the following:
i. Suspension of capital or capital and interest: granting to the borrower a grace period in the payment of
capital (i.e. during this period only interest is paid) or capital and interest, for a specific period of time.
523
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.10 Forbearance/Restructuring (continued)
ii. Reduced payments: decrease of the amount of repayment instalments over a defined short-term period
in order to accommodate the borrower’s new cash flow position.
iii. Arrears and/or interest capitalisation: capitalisation of the arrears and of any unpaid interest to the
outstanding principal balance for repayment under a rescheduled program.
Long-term restructuring solutions can include the following:
i. Interest rate reduction: permanent or temporary reduction of interest rate (fixed or variable) into a fair
and sustainable rate.
ii. Extension of maturity: extension of the maturity of the loan which allows a reduction in instalment
amounts by spreading the repayments over a longer period.
iii. Sale of Assets: Part of the restructuring can be the agreement with the borrower for immediate or over
time sale of assets (mainly real estate) to reduce borrowing.
iv. Modification of existing terms of previous decisions: In the context of the new sustainable restructuring
solution, any terms of previous decisions that are assessed not feasible to be met are revisited.
v. Consolidation/refinancing of existing facilities that: In cases where the borrower maintains several
separate loans with different collaterals, these can be consolidated and a new repayment schedule can
be set and the new loan can be secured with all existing collaterals.
vi. Hard Core Current Account Limit: In such cases a loan with a longer repayment may be offered to
replace/reduce the current account limit.
vii. Split and freeze: the customer’s debt is split into sustainable and unsustainable parts. The sustainable
part is restructured to a sustainable repayment program. The unsustainable part is ‘frozen’ for the
restructured duration of the sustainable part. At the maturity of the restructuring, the frozen part is
either forgiven pro rata (based on the actual repayment of the sustainable part) or restructured.
viii. Rescheduling of payments: the existing contractual repayment schedule is adjusted to a new
sustainable repayment program based on a realistic, current and forecasted assessment of the cash flow
generation of the borrower.
ix. Liquidation Collateral: An agreement between BOC PCL and a borrower for the voluntary sale of
mortgaged assets, for partial or full repayment of the debt.
x. Currency Conversion: This solution is provided to match the credit facility currency and the borrower's
income currency.
xi. Additional Financing: This solution can be granted, simultaneously with the restructuring of the existing
credit facilities of the borrower, to cover any financing gap.
xii. Partial or total write off: This solution corresponds to the Group forfeiting the right to legally recover
part or the whole of the amount of debt outstanding by the borrower.
xiii. Debt/equity swaps: debt restructuring that allows partial or full repayment of the debt in exchange of
obtaining an equivalent amount of equity in the company by the Group, with the remaining debt right
sized to the cash flows of the borrower to allow repayment. This solution is used only in exceptional
cases and only where all other efforts for restructuring are exhausted and after ensuring compliance
with the banking law.
xiv. Debt/asset swaps: agreement between the Group and the borrower to voluntarily transfer the
mortgaged asset or other immovable property to the Group, to partially or fully repay the debt. Any
residual debt may be restructured with an appropriate repayment schedule in line with the borrower’s
reassessed repayment ability.
The loans forborne continue to be classified as Stage 3 in the case they are performing forborne exposures
under probation for which additional forbearance measures are extended, or performing forborne
exposures, previously classified as NPEs that present more than 30 days past due within the probation
period.
Forbearance modifications of loans and advances that do not affect payment arrangements, such as
restructuring of collateral or security arrangements, are not regarded as sufficient to categorise the facility
as credit impaired, as by themselves do not necessarily indicate credit distress affecting payment ability
such that would require the facility to be classified as NPE.
The forbearance characteristic contributes in two specific ways for the calculation of lifetime ECL for each
individual facility. Specifically, it is taken into consideration in the scorecard development, where, if this
characteristic is identified as statistically significant, it affects negatively the rating of each facility. It also
contributes in the construction through the cycle probability of default and cure curves, where, when
feasible, a specific curve for the forborne products is calculated and assigned accordingly.
524
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.10 Forbearance/Restructuring (continued)
The below table presents the movement of the Group’s forborne loans and advances to customers
measured at amortised cost.
2024 2023
€000 €000
1 January 455,740 1,106,298
New loans and advances forborne in the year 148,348 47,366
Loans no longer classified as forborne and repayments (249,742) (705,103)
Write off of forborne loans and advances (11,983) (41,996)
Interest accrued on forborne loans and advances 24,427 49,102
Foreign exchange adjustments
49 73
31 December
366,839 455,740
The forborne loans classification is discontinued when all EBA criteria for the discontinuation of the
classification as forborne exposure are met. The criteria are set out in the EBA Final draft Implementing
Technical Standards (ITS) on supervisory reporting and non-performing exposures.
The below tables present the Group’s forborne loans and advances to customers by staging, economic
activity and business line classification, as well as the ECL allowance and tangible collateral held for such
forborne loans.
2024 2023
€000 €000
Stage 1 - -
Stage 2 253,862 261,091
Stage 3 86,639 173,728
POCI
26,338 20,921
366,839 455,740
Fair value of collateral
2024 2023
€000 €000
Stage 1 - -
Stage 2 234,794 241,983
Stage 3 75,515 154,051
POCI
24,965 19,734
335,274 415,768
The fair value of collateral presented above has been computed to the extent that the collateral mitigates
credit risk.
525
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.10 Forbearance/Restructuring (continued)
Credit risk concentration
2024 2023
By economic activity €000 €000
Trade 10,155 15,578
Manufacturing 3,325 10,195
Hotels and catering 6,058 60,129
Construction 132,011 82,849
Real estate 26,614 61,550
Private individuals 116,063 187,537
Professional and other services 36,621 35,197
Other sectors
35,992 2,705
366,839 455,740
2024 2023
By business line €000 €000
Corporate 224,271 207,534
IBU & International corporate
- IBU 944 2,386
- International corporate 653 768
SMEs 19,046 20,823
Retail
- housing 47,506 67,087
- consumer, credit cards and other 8,411 17,265
Restructuring
- corporate 12,555 33,098
- SMEs 7,726 11,749
- retail housing 18,818 34,538
- retail other 4,764 7,399
Recoveries
- corporate 966 2,480
- SMEs 2,511 6,157
- retail housing 13,960 34,496
- retail other
4,708 9,960
366,839 455,740
526
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.10 Forbearance/Restructuring (continued)
2024 Stage 1 Stage 2 Stage 3 POCI Total
By business line €000 €000 €000 €000 €000
Corporate - 189,064 25,745 9,462 224,271
IBU & International corporate
- IBU - 943 1 - 944
- International corporate - 653 - - 653
SMEs - 13,519 5,527 - 19,046
Retail
- housing - 34,818 10,508 2,180 47,506
- consumer, credit cards and
other
- 5,942 2,413 56 8,411
Restructuring
- corporate - 1,431 1,006 10,118 12,555
- SMEs - 2,507 4,350 869 7,726
- retail housing - 4,444 13,458 916 18,818
- retail other - 541 3,825 398 4,764
Recoveries
- corporate - - 934 32 966
- SMEs - - 2,280 231 2,511
- retail housing - - 12,356 1,604 13,960
- retail other
- - 4,236 472 4,708
- 253,862 86,639 26,338 366,839
2023 Stage 1 Stage 2 Stage 3 POCI Total
By business line €000 €000 €000 €000 €000
Corporate - 136,097 71,330 107 207,534
IBU & International corporate
- IBU - 2,091 295 - 2,386
- International corporate - 768 - - 768
SMEs - 19,414 1,409 - 20,823
Retail
- housing - 51,588 13,479 2,020 67,087
- consumer, credit cards and
other
- 13,047 4,089 129 17,265
Restructuring
- corporate - 21,254 1,807 10,037 33,098
- SMEs - 3,686 6,760 1,303 11,749
- retail housing - 11,341 21,633 1,564 34,538
- retail other - 1,805 5,249 345 7,399
Recoveries
- corporate - - 2,250 230 2,480
- SMEs - - 5,668 489 6,157
- retail housing - - 30,643 3,853 34,496
- retail other
- - 9,116 844 9,960
- 261,091 173,728 20,921 455,740
527
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.10 Forbearance/Restructuring (continued)
ECL allowance
2024 2023
€000 €000
Stage 1 - -
Stage 2 9,525 8,643
Stage 3 36,503 47,840
POCI
12,462 11,510
58,490 67,993
44.11 Credit quality of Group assets exposed to credit risk other than loans and advances to
customers - analysis by rating agency designation
Balances with central banks and loans and advances to banks
Balances with central banks and loans and advances to banks are analysed by Moody’s Investors Service
rating as follows:
2024 2023
€000 €000
Aaa - Aa3 468,981 227,075
A1 - A3 7,743,265 23,647
Baa1 - Baa3 17,983 9,550,286
Ba1 - Ba3 3,642 4,545
B1 - B3 - 254
Caa - C - 2,148
Unrated 23,910 64,276
Other receivables from banks
68,528 34,532
8,326,309 9,906,763
All balances with central banks and loans and advances to banks are classified as Stage 1 (Note 19).
Reverse repurchase agreements
Reverse repurchase agreements counterparties are analysed by Moody's Investors Service rating as follows:
2024 2023
€000 €000
A1 - A3 306,053 -
Unrated
704,117 403,199
1,010,170 403,199
The average rating of the collateral received was Aa2 as at 31 December 2024 (2023: Aa1).
In accordance with the terms of the reverse repurchase agreements of a carrying value of €1,010 million
(2023: €403 million) that are held by the Group as at 31 December 2024, the Group accepts collateral that
it is permitted to sell. At 31 December 2024, the total fair value of the collateral received was €1,007
million (2023: €426 million), none of which had been resold or repledged. As at 31 December 2024, cash
collateral of €7 million has been placed with counterparties and €13 million has been received from the
counterparties (2023: cash collateral of €30 million was placed with the counterparties). The effective yield
of the reverse repurchase agreements is approximately 3% p.a. (2023: 3% p.a.) and the average duration
is estimated at approximately 2.1 years (2023: 2.8 years).
528
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
44. Risk management - Credit risk (continued)
44.11 Credit quality of Group assets exposed to credit risk other than loans and advances to
customers - analysis by rating agency designation (continued)
Debt securities and other non-equity securities
Investments in debt securities and other non-equity securities are analysed by Moody's Investors Service
rating as follows:
2024 2023
Moody's rating €000 €000
Aaa - Aa3 2,459,365 1,969,693
A1 - A3 1,506,802 442,968
Baa1 - Baa3 254,698 1,049,328
Ba1 - Ba3
2,014 89,404
4,222,879 3,551,393
The tables below present the Moody's Investors Service rating of the Group's investments in debt securities:
FVOCI Amortised cost
Stage 1 Stage 1
2024 €000 €000
Aaa - Aa3 75,598 2,373,065
A1 - A3 319,855 1,186,947
Baa1 - Baa3 11,087 243,611
Ba1 - Ba3
- 2,014
406,540 3,805,637
FVOCI Amortised cost
Stage 1 Stage 1
2023 €000 €000
Aaa - Aa3 62,469 1,903,613
A1 - A3 34,234 408,734
Baa1 - Baa3 315,640 733,688
Ba1 - Ba3
18,725 70,679
431,068 3,116,714
The ratings are provided for the ISIN or if not available for the specific issuance, the rating of the
counterparty is used.
45. Risk management - Market risk
Market risk is the risk of loss from adverse changes in market prices namely from changes in interest rates,
credit spreads, foreign currency exchange rates, property and security prices. The Market and Liquidity Risk
department is responsible for monitoring the risk on financial instruments resulting from such changes with
the objective to minimise the impact on earnings and capital. The department also monitors property price
risk, liquidity risk and credit risk from counterparties and countries. It is also responsible for monitoring
compliance with the various market risk policies and procedures.
529
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
45. Risk management - Market risk (continued)
Interest rate risk
Interest rate risk refers to the current or prospective risk to Group's capital and earnings arising from
adverse movements in interest rates that affect the Group's banking book positions.
Interest rate fluctuations affect the economic value of the Group’s assets, liabilities and off-balance sheet
items, through corresponding changes in the cash flow amounts and discount rates and therefore their
present value. Changes in interest rates also affect the earnings by increasing or decreasing the net interest
income of other interest rate-sensitive items. As such, interest rate risk is measured primarily by reference
to the impact on net interest income and impact on economic value.
The Group’s balance sheet composition is characterized by floating rate assets and fixed or non-rate
sensitive liabilities, resulting in an increased volatility on net interest income, with a negative impact when
interest rates decrease and a positive impact when interest rates increase. In addition, this balance sheet
composition results in relatively low volatility of the Economic Value. This is due to the floating rate nature
of assets which are longer term in terms of maturity such as loans and advances and the short term nature
of the sizable central bank balances. On the liability side, term deposits, although fixed rate in nature, have
short contractual maturities (mainly up to one year). In addition, the economic value impact from fixed rate
assets is mitigated by the impact of core NMDs which behave as fixed rate liabilities.
Interest rate risk is managed through internal and regulatory limits on the change in net interest income
and economic value of equity under various adverse interest rate shock scenarios. Internal limits on net
interest income are set as a percentage of the annualised net interest income while regulatory limits on net
interest income and economic value of equity are set as a percentage of the Group Tier 1 regulatory capital.
Treasury is responsible for the management of the interest rate risk arising from the banking book and
asset and liability positions, effected through the hedging strategy. This involves the set of techniques and
the financial instruments used to manage the risk of adverse changes in interest rates, affecting the net
interest income and the economic value of the Group and aims to ensure financial stability and robust risk
management. The Group uses derivatives and currently applies fair value hedge accounting. The Group
applies macro fair value hedging to NMDs and micro fair value hedging to fixed rate debt securities
measured at FVOCI, debt securities in issue and subordinated liabilities. For fair value hedges the Group
uses interest rate swaps to manage the fair value movements of fixed rate financial instruments due to
changes in the benchmark rate.
The Group assesses and measures hedge effectiveness of a hedging relationship based on the change in the
fair value of the derivative instrument relative to the change in the fair value of the hedged item
attributable to the hedged risk.
The Market and Liquidity Risk department is responsible to measure, monitor and control the interest rate
risk on the banking book (IRRBB) based on the established Risk Appetit Framework (RAF) of the Group. One
of the risk metrics that Market and Liquidity Risk department uses for monitoring and controlling the IRRBB
is the Net Interest Income Sensitivity, which measures changes to net interest income under varying
interest rate scenarios over a one-year horizon and assuming a constant balance sheet over this period. Its
main purpose is to measure the vulnerability of the profitability to changing interest rate conditions. In
addition, another risk metric employed by the Group for this purpose is the Economic Value of Equity
Sensitivity. This represents the change in the net present value of all cash flows in the balance sheet under
a set of interest rate stress scenarios and is calculated on the entire balance sheet under a run-off
assumption, i.e., no replenishment of matured transactions.
The Group does not maintain a trading book.
Sensitivity analysis
The table below sets out the impact on the Group’s net interest income, over a one-year period, from
reasonably possible changes in the interest rates of the Euro and the US Dollar, being the main currencies,
using the assumptions of the prevailing market risk policy as at 31 December 2024 and 2023 respectively.
530
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
45. Risk management - Market risk (continued)
Impact on Net Interest Income
€000
Currency Interest Rate Scenario
2024
(+135 bps/-100
bps for Euro and
+160 bps/-100 bps
for US Dollar)
2023
(+140 bps/-120 bps
for Euro and +170
bps/-110 bps for US
Dollar)
All Parallel up 102,061 147,348
All Parallel down (84,200) (135,973)
All Steepening (51,175) (81,265)
All Flattening 79,770 112,104
All Short up 106,190 150,679
All Short down (88,788) (140,778)
Euro Parallel up 98,728 142,318
Euro Parallel down (82,267) (132,297)
Euro Steepening (51,731) (79,595)
Euro Flattening 79,588 108,998
Euro Short up 104,647 145,795
Euro Short down (88,085) (137,046)
US Dollar Parallel up 3,333 5,030
US Dollar Parallel down (1,932) (3,676)
US Dollar Steepening 556 (1,670)
US Dollar Flattening 182 3,106
US Dollar Short up 1,543 4,884
US Dollar Short down (703) (3,732)
The above sensitivities incorporate assumptions on the pass-through rate of time deposits of 40% for the
upside scenario and 50% for the downside scenario for Euro denominated deposits for the year ended 31
December 2024 (2023: 40% for the upside scenario and 50% for the downside scenario for Euro
denominated deposits). The above sensitivities are computed under the assumption of a constant balance
sheet and that all market rates move upwards or downwards in parallel.
531
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
45. Risk management - Market risk (continued)
The table below sets out the impact on the Group’s equity, from reasonably possible changes in the interest
rates under various interest rate scenarios for the Euro and the US Dollar in line with the EBA guidelines.
Impact on Equity
€000
Currency Interest Rate Scenario
2024
(+135 bps/-100
bps for Euro and
+160 bps/-100 bps
for US Dollar)
2023
(+140 bps/-120 bps
for Euro and +170
bps/-110 bps for US
Dollar)
All Parallel up (16,380) 62,584
All Parallel down 613 (89,615)
All Steepening 41,074 (511)
All Flattening (113,840) (11,035)
All Short up (112,972) 14,117
All Short down 40,990 (40,727)
Euro Parallel up (15,355) 114,640
Euro Parallel down 953 (60,469)
Euro Steepening 78,258 6,669
Euro Flattening (107,390) 20,775
Euro Short up (106,983) 48,756
Euro Short down 78,078 (27,450)
US Dollar Parallel up (1,025) 10,529
US Dollar Parallel down 273 (29,146)
US Dollar Steepening 3,890 (3,846)
US Dollar Flattening (6,450) (21,422)
US Dollar Short up (5,990) (10,261)
US Dollar Short down 3,903 (13,277)
The aggregation of the impact on equity was performed as per the EBA guidelines by adding the negative
and 50% of the positive impact of each scenario. The increased IRRBB hedging that took place during the
year ended 31 December 2024 and the different magnitude of the shocks impact the sensitivity scenarios
year-on-year.
In addition to the above fluctuations in net interest income, interest rate changes can result in fluctuations
in the fair value of investments at FVPL (including investments held for trading) and in the fair value of
derivative financial instruments impacting the profit and loss of the Group.
The equity of the Group is also affected by changes in market interest rates. The impact on the Group’s
equity arises from changes in the fair value of mainly fixed rate debt securities classified at FVOCI.
The sensitivity analysis is based on the assumption of a parallel shift of the yield curve. The table below sets
out the impact on the Group’s profit/loss before tax and equity as a result of reasonably possible changes in
the interest rates of the major currencies.
Parallel change in interest rates
Impact on profit/loss
before tax
Impact on equity
2024 €000 €000
+1.6% for US Dollar
+1.35% for Euro
+3% for British Pound
(934) (1,982)
-1% for US Dollar
-1% for Euro
-3% for British Pound
692 1,468
532
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
45. Risk management - Market risk (continued)
Impact on profit/loss
before tax
Impact on equity
Parallel change in interest rates €000 €000
2023
+1.7% for US Dollar
+1.4% for Euro
+3% for British Pound
(2,468) (773)
-1.1% for US Dollar
-1.2% for Euro
-3% for British Pound
2,115 663
The hedging relationships have been taken into account in the Net Interest Income (NII) and Economic
Value of Equity (EVE) Sensitivity tables.
Currency risk
Currency risk is the risk that the fair value of future cash flows of a financial instrument will fluctuate
because of changes in foreign currency exchange rates.
In order to manage currency risk, the ALCO has approved open position limits for the total foreign currency
positions. The foreign currency position limits are lower than those prescribed by the regulator. These limits
are managed by Treasury Division and monitored daily by Market and Liquidity Risk department.
The Group does not maintain a currency trading book.
The table below sets out the Group's currency risk resulting from the Group's open FX position. The analysis
assumes reasonably possible changes in the exchange rates of major currencies against the Euro, based
mainly on historical price fluctuations. The impact on profit/loss after tax includes the change in net interest
income that arises from the change of currency rate.
The impact on equity arises from the hedging instruments that are used to hedge part of the net assets of
the subsidiaries whose functional currency is not the Euro. The net assets of foreign operations are also
revalued and affect equity (by an approximately equal and opposite impact), but their impact is not taken
into account in the below sensitivity analysis as the below relates only to financial instruments which have a
direct impact either on profit/loss after tax or on equity.
Change in foreign
exchange rate
Impact on profit/loss
after tax
Impact on equity
2024 % €000 €000
US Dollar +5 1,566 -
Russian Rouble +60 1,231 -
Romanian Lei +5 4 (49)
Swiss Franc +5 91 -
British Pound +5 235 -
Japanese Yen +5 1 -
Other currencies +5 54 -
US Dollar -5 (1,417) -
Russian Rouble -30 (189) -
Romanian Lei -5 (4) 44
Swiss Franc -5 (82) -
British Pound -5 (212) -
Japanese Yen -5 (1) -
Other currencies -5 (49) -
533
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
45. Risk management - Market risk (continued)
Change in foreign
exchange rate
Impact on profit/loss
after tax
Impact on equity
2023 % €000 €000
US Dollar +5 1,622 -
Russian Rouble +60 1,364 -
Romanian Lei +5 3 (63)
Swiss Franc +5 92 -
British Pound +5 307 -
Japanese Yen +5 2 -
Other currencies +5 48 -
Change in foreign
exchange rate
Impact on profit/loss
after tax
Impact on equity
US Dollar -5 (1,467) -
Russian Rouble -30 (210) -
Romanian Lei -5 (3) 57
Swiss Franc -5 (84) -
British Pound -5 (278) -
Japanese Yen -5 (2) -
Other currencies -5 (53) -
Price risk
Equity securities price risk
The risk of loss from changes in the price of equity securities arises when there is an unfavourable change in
the prices of equity securities held by the Group as investments.
Investments in equities are outside the Group’s risk appetite, but may be acquired in the context of
delinquent loan workouts. The Group monitors the current portfolio mostly acquired by the Group as part of
the acquisition of certain operations of Laiki Bank, or through delinquent loan workouts, with the objective
to gradually liquidate all positions for which there is a market. Equity securities are disposed of by the
Group as soon as practicable.
Changes in the prices of equity securities that are classified as investments at FVPL affect the results of the
Group, whereas changes in the value of equity securities classified as FVOCI affect directly the equity of the
Group.
The table below shows the impact on the profit/loss before tax and on equity of the Group from a change in
the price of the equity securities held, as a result of reasonably possible changes in the relevant stock
exchange indices.
Change in index
Impact on profit/loss
before tax
Impact on equity
2024 % €000 €000
Cyprus Stock Exchange +40 - 575
Athens Exchange +50 419 -
New York Exchange +40 - -
Other stock exchanges and
unlisted
+40 - 1,343
Non-listed (Real Estate) +10 - 693
Cyprus Stock Exchange -40 - (575)
Athens Exchange -50 (419) -
New York Exchange -10 - -
Other stock exchanges and
unlisted
-40 - (1,343)
Non-listed (Real Estate) -10 - (693)
534
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
45. Risk management - Market risk (continued)
Change in index
Impact on profit/loss
before tax
Impact on equity
2023 % €000 €000
Cyprus Stock Exchange +40 1 900
Athens Exchange +50 419 -
New York Exchange +45 - -
Other stock exchanges and
unlisted
+40 26 1,270
Non-listed (Real Estate) +25 - 1,732
Cyprus Stock Exchange -40 (1) (900)
Athens Exchange -50 (419) -
New York Exchange -10 - -
Other stock exchanges and
unlisted
-40 (26) (1,270)
Non-listed (Real Estate) -10 - (693)
Debt securities price risk
Debt securities price risk is the risk of loss as a result of adverse changes in the prices of debt securities
held by the Group. Debt security prices change as the credit risk of the issuer changes and/or as the market
interest rates change mainly for fixed rate securities. The Group invests a significant part of its liquid assets
in highly rated debt securities. The average Moody’s Investors Service rating of the debt securities portfolio
of the Group as at 31 December 2024 was Aa2 (2023: A1). Further information on ratings of debt securities
is disclosed in Note 44.11.
Changes in the prices of debt securities classified as investments at FVPL, affect the profit or loss of the
Group, whereas changes in the value of debt securities classified as FVOCI affect directly the equity of the
Group.
The table below indicates how the profit/loss before tax and equity of the Group will be affected from
reasonably possible changes in the price of the debt securities held, based on Value at Risk.
Impact on profit/loss
before tax
Impact on equity
2024 €000 €000
Up scenario:
Aa3 and above rated bonds 1,250 2,168
A3 and above rated bonds 281 655
Baa1 and below rated bonds 6 437
Cyprus Government bonds - 12,273
Down scenario:
Aa3 and above rated bonds (1,250) (2,168)
A3 and above rated bonds (281) (655)
Baa1 and below rated bonds (6) (437)
Cyprus Government bonds - (12,273)
535
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
45. Risk management - Market risk (continued)
Impact on profit/loss
before tax
Impact on equity
2023 €000 €000
Up scenario:
Aa3 and above rated bonds 2,614 4,068
A3 and above rated bonds 151 1,938
Baa1 and below rated bonds 53 430
Cyprus Government bonds - 27,618
Down scenario:
Aa3 and above rated bonds (2,614) (4,068)
A3 and above rated bonds (151) (1,938)
Baa1 and below rated bonds (53) (430)
Cyprus Government bonds - (27,618)
Other non-equity instruments price risk
The table below shows the impact on the profit/loss before tax and equity of the Group from a change in the
price of other non-equity instruments held, as a result of reasonably possible changes in the price index of
the relevant instruments.
Change in index
Impact on profit/loss
before tax
Impact on equity
2024 % €000 €000
Other non-equity instruments +40 4,281 -
Other non-equity instruments -10 (1,070) -
2023
Other non-equity instruments +45 1,625 -
Other non-equity instruments -10 (361) -
Property price risk
A significant part of the Group’s loan portfolio is secured by real estate, the majority of which is located in
Cyprus. Furthermore, the Group holds a substantial number of properties mainly arising from loan
restructuring activities; the enforcement of loan collateral and debt for asset swaps. These properties are
held by the Group primarily as stock of property and some are held as investment properties.
Property risk is the risk that the Group’s business and financial position will be affected by adverse changes
in the demand for, and prices of, real estate, or by regulatory capital requirements relating to increased
charges with respect to the stock of property held.
46. Risk management - Liquidity and funding risk
Liquidity Risk
Liquidity risk is the risk that the Group is unable to fully or promptly meet current and future payment
obligations as and when they fall due. This risk includes the possibility that the Group may have to raise
funding at high cost or sell assets at a discount to fully and promptly satisfy its obligations.
It reflects the potential mismatch between incoming and outgoing payments, taking into account
unexpected delays in repayment and unexpectedly high payment outflows. Liquidity risk involves both the
risk of unexpected increases in the cost of funding of the portfolio of assets and the risk of being unable to
liquidate a position in a timely manner on reasonable terms.
In order to limit this risk, management has in place an established Liquidity Risk Policy of managing assets,
taking liquidity into consideration and monitoring cash flows and liquidity on a regular basis. The Group has
developed internal control processes and contingency plans for managing liquidity risk.
536
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
46. Risk management - Liquidity and funding risk (continued)
Management and structure
The Board of Directors sets the Group's Liquidity Risk Appetite which defines the level of risk at which the
Group should operate.
The Board of Directors, through its Risk Committee, approves the Liquidity Risk Policy and reviews at
frequent intervals the liquidity position of the Group.
The ALCO is responsible for setting the policies for the effective management and monitoring of liquidity risk
across the Group.
The Treasury Division is responsible for liquidity management at Group level, ensuring compliance with
internal policies and regulatory liquidity requirements and providing direction as to the actions to be taken
regarding liquidity needs. The Treasury Division assesses on a regular basis the adequacy of the liquid
assets and takes the necessary actions to ensure adequate liquidity position.
Liquidity is also monitored by Market and Liquidity Risk department, to ensure compliance with both internal
policies and limits, and with the limits set by the regulatory authorities. Market and Liquidity Risk
department reports the liquidity position to ALCO at least monthly. It also provides the results of various
stress tests to ALCO and the Board Risk Committee at least quarterly.
Liquidity is monitored and managed on an ongoing basis through:
(i) Risk appetite: establishes the Group's Risk Appetite Statement together with the appropriate limits
for the management of all risks including liquidity risk.
(ii) Liquidity Risk Policy: sets the principles, the roles and responsibilities for managing liquidity risk as
well as the liquidity and funding risk management framework, stress testing and the reporting on
liquidity and funding.
(iii) Liquidity limits: a number of internal and regulatory limits are monitored on a regular basis. Where
applicable, a traffic light system (RAG) is used for ratios, in order to raise flags and take action
when the ratios deteriorate.
(iv) Early Warning Indicators: monitoring of a range of indicators for early signs of liquidity risk in the
market or specific to the Group. These are designed to immediately identify the emergence of
increased liquidity risk so as to maximise the time available to execute appropriate mitigating
actions.
(v) Liquidity Contingency Plan: maintenance of a Liquidity Contingency Plan (LCP) which is designed to
provide a framework where a liquidity stress could be effectively identified and managed. The LCP
provides a communication plan and includes management actions to respond to liquidity stresses.
(vi) Recovery Plan: the Group has developed a Recovery Plan (RP), the key objectives of which are,
among others, to set key Recovery and Early Warning Indicators and to set in advance a range of
recovery options to enable the Group to be adequately prepared to respond to stressed conditions
and restore the Group’s liquidity position.
Monitoring process
Daily
The daily monitoring of the stock of highly liquid assets is important to safeguard and ensure the
uninterrupted operations of the Group’s activities. Market and Liquidity Risk department prepares a daily
report analysing the internal liquidity buffer and comparing it to the previous day’s buffer. Results are made
available to members of the Risk and Treasury Divisions. In addition, Treasury monitors daily and intraday
the customer inflows and outflows in the main currencies used by the Group.
The liquidity buffer is made up of: Banknotes, CBC balances (excluding the Minimum Reserve Requirements
(MRR)), unpledged cash and nostro current accounts, as well as money market placements up to the stress
horizon, available ECB credit line and market value net of haircut of unencumbered/available liquid bonds.
537
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
46. Risk management - Liquidity and funding risk (continued)
The designing of the stress tests follows guidance and is based on the liquidity risk drivers which are
recognised internationally by both the Prudential Regulation Authority (PRA) and EBA. In addition, it takes
into account SREP recommendations, as well as the Annual Risk Identification Process of the Group. The
stress test assumptions are reviewed on an annual basis and approved by the Board of Directors through its
Risk Committee. Whenever it is considered appropriate to amend the assumptions during the year, approval
is requested from ALCO and the Board Risk Committee. The main items shocked in the different scenarios
are: deposit outflows, wholesale funding, loan repayments, off balance sheet commitments, marketable
securities, own issue covered bond, additional credit claims, interbank takings and cash collateral for
derivatives and repos.
Weekly
Market and Liquidity Risk department prepares a report indicating the level of liquid assets including Credit
Institutions Money-Market Placements as per LCR definitions.
Market and Liquidity Risk department also prepares the liquidity stress testing for bank specific, market
wide and combined scenarios on a weekly basis. The requirement is to have sufficient liquidity buffer to
enable BOC PCL to survive a twelve-month stress period, including capacity to raise funding under all
scenarios.
Furthermore, a report is submitted to the regulator on a weekly basis. The report includes information on
deposits breakdown, cash flow information, survival period, LCR ratio, rollover of funding, funding gap
(through the Maturity Ladder analysis), concentration of funding and collateral details. It concludes on the
overall liquidity position of BOC PCL and describes the measures already implemented and those which will
be implemented in the short-term to improve liquidity position if needed.
Monthly
Market and Liquidity Risk department prepares reports monitoring compliance with internal and regulatory
liquidity requirements and submits them to the ALCO, the Executive Committee and the Board Risk
Committee. It also calculates the surplus liquidity buffer following stress outflows. The fixed deposit renewal
rates, the percentage of International business unit deposits over total deposits and the percentage of
instant access deposits are also presented. The liquidity mismatch in the form of the Maturity Ladder report
(for both contractual and behavioural flows) is presented to ALCO and the resulting mismatch between
assets and liabilities is compared to previous month’s mismatch.
Market and Liquidity Risk department also reports the Liquidity Coverage Ratio (LCR) and Additional
Liquidity Monitoring Metrics (ALMM) to the CBC/ECB on a monthly basis.
Quarterly
The results of the stress testing scenarios are reported to ALCO and the Board Risk Committee quarterly as
part of the quarterly Internal Liquidity Adequacy Assessment Process (ILAAP) review. Market and Liquidity
Risk department also reports the Net Stable Funding Ratio (NSFR) to the CBC/ECB quarterly.
Annually
The Group prepares on an annual basis its ILAAP package. The ILAAP package provides a holistic view of the
Group’s liquidity adequacy under normal and stress conditions. Within ILAAP, the Group evaluates its
liquidity risk in the context of established policies and processes for the identification, measurement,
management and monitoring of liquidity risk as implemented by the Group.
The Market and Liquidity Risk department also prepares annually an ECB/SRB liquidity report, the 'Joint
liquidity template' that runs for five consecutive days. The report includes information on deposits
breakdown, cash flow information, survival period, LCR ratio, rollover of funding, funding gap (through the
Maturity Ladder analysis), concentration of funding and collateral details. It concludes on the overall
liquidity position of BOC PCL and describes the measures implemented and to be implemented in the short-
term to improve liquidity position if needed.
As part of the Group’s procedures for monitoring and managing liquidity risk, there is a Group Liquidity
Contingency Plan (LCP) for handling liquidity difficulties. The LCP details the steps to be taken in the event
that liquidity problems arise, which escalate to a special meeting of the Crisis Management Committee for
LCP (CMC-LCP). The LCP sets out the members of this committee and a series of the possible actions that
can be taken. The LCP is reviewed and tested at least annually.
538
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
46. Risk management - Liquidity and funding risk (continued)
Liquidity ratios
The Group LCR is calculated based on the Delegated Regulation (EU) 2015/61. It is designed to establish a
minimum level of high quality liquid assets sufficient to meet an acute stress lasting for 30 calendar days.
Τhe minimum regulatory requirement is 100%. The Group also calculates its NSFR as per Capital
Requirements Regulation II (CRR II), with the limit set at 100%. The NSFR is the ratio of available stable
funding to required stable funding. NSFR has been developed to promote a sustainable maturity structure of
assets and liabilities.
Funding risk
Funding risk is the risk that the Group does not have sufficiently stable sources of funding or access to
sources of funding may not always be available at a reasonable cost, and thus the Group may fail to meet
its obligations, including regulatory ones (e.g. MREL).
Main sources of funding
As at 31 December 2024, the Group’s main sources of funding were its deposit base and wholesale funding.
Wholesale funding is becoming an important source of funding, with the issuance of Tier 2 of a nominal
amount of €300 million, the issuances of senior preferred debt of an aggregate nominal amount of €950
million and the AT1 issuance for €220 million. As at 31 December 2024, the wholesale funding nominal
amount was €1,470 million (2023: €1,170 million) as further described in Notes 32 and 34.
With respect to funding from TLTRO III operations, this was fully repaid in the year ended 31 December
2024.
Funding to subsidiaries
The funding provided by BOC PCL to its subsidiaries for liquidity purposes is repayable as per the terms of
the respective agreements.
The subsidiaries may proceed with dividend distributions in the form of cash to BOC PCL, provided that they
are not in breach of their regulatory capital and liquidity requirements, where applicable.
Collateral requirements and other disclosures
Collateral requirements
The carrying values of the Group's encumbered assets as at 31 December 2024 and 2023 are summarised
below:
2024 2023
€000 €000
Cash and other liquid assets 55,434 72,800
Investments 39,958 260,011
Loans and advances
3,470,859 3,349,118
3,566,251 3,681,929
Cash is mainly used to cover collateral required for derivatives, trade finance transactions and guarantees
issued. It may also be used as part of the supplementary assets for the covered bond.
As at 31 December 2024 investments are used as supplementary assets for the covered bond. As at 31
December 2023 investments were mainly used as collateral for ECB funding or as supplementary assets for
the covered bond.
As at 31 December 2024, loans and advances indicated as encumbered are mainly pledged for any potential
use of the funding facilities of the ECB and for the covered bond. As at 31 December 2023, loans and
advances indicated as encumbered were mainly used as collateral for funding from the ECB and the covered
bond.
539
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
46. Risk management - Liquidity and funding risk (continued)
Loans and advances to customers include mortgage loans of a nominal amount of €1,010 million as at 31
December 2024 (2023: €1,008 million) in Cyprus, pledged as collateral for the covered bond issued by BOC
PCL in 2011 under its Covered Bond Programme. As at 31 December 2024, although there is no outstanding
funding from the ECB, housing loans of a nominal amount of €2,431 million (2023: €2,329 million) in
Cyprus, remain in the collateral pool of the CBC part of the available credit line.
BOC PCL maintains a Covered Bond Programme set up under the Cyprus Covered Bonds legislation and the
Covered Bonds Directive of the CBC. Under the Covered Bond Programme, BOC PCL has in issue covered
bonds of €650 million secured by residential mortgages originated in Cyprus. The Covered Bonds have a
maturity date of 12 December 2026 and pay an interest rate of 3-month Euribor plus 1.25% on a quarterly
basis. On 9 August 2022, BOC PCL proceeded with an amendment to the terms and conditions of the
covered bonds following the implementation of Directive (EU) 2019/2162 in Cyprus. The covered bonds are
listed on the Luxemburg Bourse. The covered bonds have a conditional Pass-Through structure. All the
bonds are held by BOC PCL. The covered bonds are eligible collateral for the Eurosystem credit operations
and are placed as collateral for accessing funding from the ECB.
In addition to the encumbered assets presented above, as at 31 December 2024 cash collateral of €7
million has been placed with counterparties in relation to the reverse repurchase agreements (2023: €30
million) (Note 44.11).
Other disclosures
Deposits by banks include balances of €13,870 thousand as at 31 December 2024 (2023: €20,462
thousand) relating to borrowings from international financial and similar institutions for funding, aiming to
facilitate access to finance and improve funding conditions for small or medium sized enterprises, active in
Cyprus. The carrying value of the respective loans and advances granted to such enterprises serving this
agreement amounts to €27,341 thousand as at 31 December 2024 (2023: €40,049 thousand).
Analysis of financial assets and liabilities based on remaining contractual maturity
The analysis of the Group’s financial assets and liabilities based on the remaining contractual maturity at 31
December is based on undiscounted cash flows, analysed in time bands according to the number of days
remaining from 31 December to the contractual maturity date.
Financial assets
The analysis of financial assets does not include any interest receivable cash flows. Financial assets have a
much longer duration than financial liabilities and non-discounted interest receivable cash flows are higher
than non-discounted interest payable cash flows (based on remaining contractual maturity). As a result,
non-discounted cash inflows from interest receivable would have greatly exceeded non-discounted cash
outflows on interest payable, thus artificially improving liquidity.
Cash and balances with central banks are classified in the relevant time band based on the contractual
maturity, with the exception of obligatory balances with central banks and balances with central banks for
ancillary systems. Obligatory balances with central banks are assigned to different time bands
proportionally according to the allocation of customer deposits and deposits by banks. Balances with central
banks for ancillary systems are classified in the 'over five years' time band.
Current accounts, overdrafts and amounts in arrears are included within the first maturity time band which
reflects their contractual maturity. All other loans and advances to customers are analysed according to
their contractual repayment schedule.
Loans and advances to banks are analysed in the time bands according to the number of days remaining
from 31 December until their contractual maturity date. Amounts placed as collateral (primarily for
derivatives) are assigned to different time bands based on either their maturity, or proportionally according
to the maturities of derivatives (where the collateral had no fixed maturity).
Financial assets with no contractual maturity (such as equity securities) are included in the 'Over five years'
time band, unless classified as at FVPL, in which case they are included in the 'On demand and up to one
month' time band.
The investments are classified in the relevant time band according to their contractual maturity.
540
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
46. Risk management - Liquidity and funding risk (continued)
Financial liabilities
All financial liabilities for the repayment of which notice is required, are included in the relevant time bands
as if notice had been given on 31 December, despite the fact that the Group expects that the majority of its
customers will not demand repayment of such liabilities on the earliest possible date. Fixed deposits are
classified in time bands based on their remaining contractual maturity. Although customers may demand
repayment of time deposits (subject to penalties depending on the type of the deposit account), the Group
has the discretion not to accept such early termination of deposits.
Debt securities in issue and subordinated liabilities are classified in the relevant time band according to the
remaining contractual maturity.
The amounts presented in the table below are not equal to the amounts presented on the balance sheet,
since the table below presents all cash flows (including interest to maturity) on an undiscounted basis.
Derivative financial instruments
The fair value of the derivatives is included in financial assets or in financial liabilities in the time band
corresponding to the remaining maturity of the derivative.
Gross settled derivatives are presented in a separate table and the corresponding cash flows are classified
accordingly in the time bands which relate to the number of days until their receipt or payment.
Contingent liabilities and Commitments
Amounts of contingent liabilities and commitments are included in the time band on the basis of their
remaining contractual maturities except for amounts of undrawn facilities and guarantees which are
included in the earliest date on which the Group can be required to pay. For guarantees to give rise to a
payment obligation to the Group, certain conditions must be met specific to the guarantee contract in order
for an outflow to arise. Given that guarantees could be called at any time by the counterparty, subject to
the occurrence of the relevant event, they are included in the 'On demand and up to one month' time band.
The analysis in the time bands of the amounts for the guarantees for the comparative period has been
changed from being included in the time bands on the basis of their remaining contractual maturities to the
‘On demand and up to one month’ time band to align to the above. The total amount presented for
guarantees for the comparative period is not impacted.
As a significant portion of the contingent liabilities and commitments expire without being utilised the total
of the nominal principal amounts is not indicative of future liquidity requirements.
541
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
46. Risk management - Liquidity and funding risk (continued)
On demand
and up to one
month
Between one
and three
months
Between three
months and
one year
Between one
and five years
Over five years Total
2024
€000 €000 €000 €000 €000 €000
Financial assets
Cash and balances with
central banks
7,512,616 14,685 23,759 2,061 47,605 7,600,726
Loans and advances to
banks
289,133 1,566 472,188 57,687 - 820,574
Reverse repurchase
agreements
- - - 1,010,170 - 1,010,170
Fair value of derivative
assets
7,907 332 503 75,197 11,334 95,273
Investments at FVPL 128,996 - 5,335 2,298 - 136,629
Investments not at FVPL 119,238 97,899 400,429 1,965,335 1,638,813 4,221,714
Loans and advances to
customers
1,057,005 214,529 744,076 3,078,961 5,019,823 10,114,394
Other assets
73,560 4,214 158,119 49,289 10,450 295,632
9,188,455 333,225 1,804,409 6,240,998 6,728,025 24,295,112
Financial liabilities
Deposits by banks 100,558 11,533 32,434 207,342 23,284 375,151
Customer deposits 16,439,268 1,550,780 2,535,228 15,440 - 20,540,716
Debt securities in issue - - 48,313 1,104,057 - 1,152,370
Subordinated liabilities - - 19,875 102,615 356,162 478,652
Fair value of derivative
liabilities
585 34 178 2,077 1,790 4,664
Lease liabilities 870 1,269 4,383 22,127 9,911 38,560
Other liabilities
283,609 543 188 33,972 86,230 404,542
16,824,890 1,564,159 2,640,599 1,487,630 477,377 22,994,655
Net financial
(liabilities)/assets
(7,636,435) (1,230,934) (836,190) 4,753,368 6,250,648 1,300,457
542
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
46. Risk management - Liquidity and funding risk (continued)
On demand
and up to one
month
Between one
and three
months
Between three
months and
one year
Between one
and five
years
Over five years Total
2023
€000 €000 €000 €000 €000 €000
Financial assets
Cash and balances with
central banks
9,571,884 14,810 23,159 3,995 654 9,614,502
Loans and advances to
banks
292,546 1,609 467 79,899 10,281 384,802
Reverse repurchase
agreements
- - - 403,199 - 403,199
Fair value of derivative
assets
220 99 540 35,263 14,933 51,055
Investments at FVPL 131,664 - - 3,611 - 135,275
Investments not at FVPL 86,322 76,184 483,759 1,816,464 1,097,405 3,560,134
Loans and advances to
customers
1,100,174 188,261 723,535 2,798,404 5,011,414 9,821,788
Other assets
95,211 2,649 123,783 151,298 15,303 388,244
11,278,021 283,612 1,355,243 5,292,133 6,149,990 24,358,999
Financial liabilities
Deposits by banks 153,942 18,737 35,481 210,135 69,494 487,789
Funding from central banks - 1,752,836 313,174 - - 2,066,010
Customer deposits 15,175,687 1,538,792 2,424,392 214,190 - 19,353,061
Debt securities in issue - - 33,323 779,464 - 812,787
Subordinated liabilities - - 19,885 94,663 384,739 499,287
Fair value of derivative
liabilities
13,362 516 201 2,515 1,386 17,980
Lease liabilities 1,710 2,193 4,583 20,304 1,427 30,217
Other liabilities
184,487 17,640 35,090 32,836 61,882 331,935
15,529,188 3,330,714 2,866,129 1,354,107 518,928 23,599,066
Net financial
(liabilities)/assets
(4,251,167) (3,047,102) (1,510,886) 3,938,026 5,631,062 759,933
On demand
and up to one
month
Between one
and three
months
Between three
months and
one year
Between one
and five years
Over five years Total
2024
€000 €000 €000 €000 €000 €000
Gross settled derivatives
Financial assets
Contractual amounts
receivable
667,289 181,962 2,991 - - 852,242
Contractual amounts payable
(659,663) (181,323) (2,927) - - (843,913)
7,626 639 64 - - 8,329
Financial liabilities
Contractual amounts
receivable
144,527 34,120 2,549 - - 181,196
Contractual amounts payable
(144,633) (34,119) (2,605) - - (181,357)
(106) 1 (56) - - (161)
543
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
46. Risk management - Liquidity and funding risk (continued)
On demand
and up to one
month
Between one
and three
months
Between three
months and
one year
Between one
and five years
Over five years Total
2024
€000 €000 €000 €000 €000 €000
Contingent liabilities and
commitments
Contingent liabilities
Acceptances and
endorsements
4,097 711 463 - - 5,271
Guarantees 705,774 - - - - 705,774
Commitments
Documentary credits 7,318 1,539 5,911 - - 14,768
Undrawn formal standby
facilities, credit lines and
other commitments to lend
2,009,698 - - - - 2,009,698
2,726,887 2,250 6,374 - - 2,735,511
On demand
and up to one
month
Between one
and three
months
Between three
months and
one year
Between one
and five years
Over five years Total
2023
€000 €000 €000 €000 €000 €000
Gross settled derivatives
Financial assets
Contractual amounts
receivable
56,545 6,059 2,646 - - 65,250
Contractual amounts payable
(56,310) (5,992) (2,599) - - (64,901)
235 67 47 - - 349
Financial liabilities
Contractual amounts
receivable
907,453 136,201 2,617 - - 1,046,271
Contractual amounts payable
(920,105) (136,063) (2,637) - - (1,058,805)
(12,652) 138 (20) - - (12,534)
On demand
and up to one
month
Between one
and three
months
Between three
months and
one year
Between one
and five years
Over five years Total
2023
€000 €000 €000 €000 €000 €000
Contingent liabilities and
commitments
Contingent liabilities
Acceptances and
endorsements
1,321 879 380 - - 2,580
Guarantees 703,044 - - - - 703,044
Commitments
Documentary credits 1,242 3,830 5,179 - - 10,251
Undrawn formal standby
facilities, credit lines and
other commitments to lend
1,948,482 - - - - 1,948,482
2,654,089 4,709 5,559 - - 2,664,357
47. Risk management - Insurance risk
Insurance risk is the risk that an insured event under an insurance contract occurs and the related
uncertainty of the amount and the timing of the resulting claim. By the very nature of an insurance
contract, this risk is largely random and therefore unpredictable.
544
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
47. Risk management - Insurance risk (continued)
For a portfolio of insurance contracts where the theory of probability is applied to pricing and provisioning,
the principal risk that the Group faces is that the actual claims and benefit payments will exceed the
carrying amount of insurance liabilities. This could occur because the frequency or severity of claims and
benefits are greater than estimated. Insurance events are largely random and the actual volume and cost of
claims and benefits will vary from year to year compared to the estimate established using statistical or
actuarial techniques.
The above risk exposure is mitigated by the Group through the diversification across a large portfolio of
insurance contracts. The variability of risks is also reduced by careful selection and implementation of
underwriting strategy guidelines, as well as the use of reinsurance arrangements. Although the Group has
reinsurance coverage, it is not relieved of its direct obligations to policyholders and is thus exposed to credit
risk with respect to ceded insurance, to the extent that any reinsurer is unable to meet the obligations
assumed under such reinsurance arrangements. For that reason, the creditworthiness of reinsurers is
evaluated by considering their solvency and credit rating.
Life and Accident and Health insurance contracts
The main factors that could affect the overall frequency of claims are epidemics, major lifestyle changes,
pandemics and natural disasters.
The underwriting strategy and risk assessment is designed to ensure that risks are diversified in terms of
type of risk and level of insured benefits. This is largely achieved through the use of medical screening in
order to ensure that pricing takes account of the current medical conditions and family medical history and
through the regular review of actual claims and product pricing. The Group has the right to decline policy
applications, it can impose additional charges and it has the right to reject the payment of fraudulent
claims.
The most significant risks relating to accident and health insurance contracts result from lifestyle changes
and from climate and environmental changes. The risks are mitigated by the use of strategic selection and
risk-taking at the underwriting stage and by thorough investigation for possible fraudulent claims.
The following sensitivity analysis shows the impact on profit before tax and equity for reasonably possible
movements in key assumptions, with all other assumptions held constant. The correlation of assumptions
will have a significant effect in determining the ultimate impacts, but to demonstrate the impact due to
changes in each assumption, assumptions are changed on an individual basis while holding all other
assumptions constant. Movements in these assumptions are non–linear. Sensitivity information also varies
according to the current economic assumptions.
2024
Change in
assumptions
Impact on profit
before tax
Impact on
equity
% €000 €000
Change in mortality rates -10% 609 533
Change in lapsation and surrender rates +10% (419) (479)
Change in expenses +5% (1,107) (1,265)
Change in inflation +1% (2,210) (2,526)
Change in discount rate curve at each projection
year
-0,25% 221 193
2023
Change in
assumptions
Impact on Profit
before tax
Impact on
equity
% €000 €000
Change in mortality rates -10% 1,956 1,711
Change in lapsation and surrender rates +10% (143) (163)
Change in expenses +5% (891) (1,019)
Change in inflation +1% (1,673) (1,912)
Change in discount rate curve at each projection
year
-0,25% 119 104
Some of the sensitivity scenarios shown in respect of changes to both economic and non–economic
variables may have a consequential effect on the valuation basis when a product is valued on an active
basis which is updated to reflect current economic conditions.
545
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
47. Risk management - Insurance risk (continued)
Non-life insurance contracts other than accident and health
Non-life insurance business is concentrated in Cyprus and the main claims during the year ended 31
December 2024 and 2023 related to fire and natural forces and other damage to property, motor vehicle
liability and general liability.
Risks under these policies are usually covered for a period of 12 months, with the exception of the goods in
transit class that covers shorter periods and the contractors all risks class that covers longer periods.
The liabilities for outstanding claims arising from insurance contracts issued by the Group are based on
experts’ estimates and facts known at the balance sheet date. With time, these estimates are reconsidered
and any adjustments are recognised in the financial statements in the period in which they arise.
The principal assumptions underlying the estimates for each claim are based on experience and market
trends, taking into consideration claims handling costs, inflation and claim numbers for each accident year.
Also, external factors that may affect the estimate of claims, such as recent court rulings and the
introduction of new legislation, are taken into consideration.
The insurance contract liabilities are sensitive to changes in the above key assumptions. The sensitivity of
certain assumptions, such as the introduction of new legislation and the rulings of court cases, is very
difficult to be quantified. Furthermore, the delays that arise between the occurrence of a claim and its
subsequent notification and eventual settlement increase the uncertainty over the cost of claims at the
reporting date.
The risk of a non-life insurance contract occurs from the uncertainty of the amount and time of presentation
of the claim. Therefore, the level of risk is determined by the frequency of such claims, their severity and
their evolution from one period to the next.
The main risks for the non-life insurance business arise from major catastrophic events like natural
disasters. These risks vary depending on location, type and nature. The variability of risks is mitigated by
the diversification of risk of loss to a large portfolio of insurance contracts, as a more diversified portfolio is
less likely to be affected by changes in any subset of the portfolio. The Group’s exposure to insurance risks
from non-life insurance contracts is also mitigated by the following measures: adherence to underwriting
policies, frequent review and processing of claims to minimise the possibility of negative developments in
the future, and use of effective reinsurance arrangements to minimise the impact of risks, especially for
catastrophic events.
48. Capital management
The primary objective of the Group’s capital management is to ensure compliance with the relevant
regulatory capital requirements and to maintain healthy capital adequacy ratios to cover the risks of its
business, support its strategy and maximise shareholders’ value.
The capital adequacy framework, as in force, was incorporated through the Capital Requirements Regulation
(CRR) and Capital Requirements Directive (CRD) which came into effect on 1 January 2014 with certain
specified provisions implemented gradually. The CRR and CRD transposed the capital, liquidity and leverage
standards of Basel III into the European Union’s legal framework. CRR establishes the prudential
requirements for capital, liquidity and leverage for credit institutions. It is directly applicable in all EU
member states. CRD governs access to deposit taking activities and internal governance arrangements
including remuneration, board composition and transparency. Unlike the CRR, member states were required
to transpose the CRD into national law and national regulators were allowed to impose additional capital
buffer requirements.
On 27 June 2019, the revised rules on capital and liquidity (Regulation (EU) 2019/876 (CRR II) and
Directive (EU) 2019/878 (CRD V)) came into force. As an amending regulation, the existing provisions of
CRR apply unless they are amended by CRR II. Certain provisions took immediate effect (primarily relating
to Minimum Requirement for Own Funds and Eligible Liabilities (MREL)), but most changes became effective
as of June 2021. The key changes introduced consist of, among others, changes to qualifying criteria for
Common Equity Tier 1 (CET1), Additional Tier 1 (AT1) and Tier 2 (T2) instruments, introduction of
requirements for MREL and a binding Leverage Ratio requirement (as defined in the CRR) and a Net Stable
Funding Ratio (NSFR).
546
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
48. Capital management (continued)
The amendments that came into effect on 28 June 2021 are in addition to those introduced in June 2020
through Regulation (EU) 2020/873, which among other, brought forward certain CRR II changes in light of
the COVID-19 pandemic. The main adjustments of Regulation (EU) 2020/873 that had an impact on the
Group’s capital ratio relate to the acceleration of the implementation of the new SME discount factor (lower
RWAs), extending the IFRS 9 transitional arrangements and introducing further relief measures to CET1
allowing to fully add back to CET1 any increase in ECL recognised in 2020 and 2021 for non-credit impaired
financial assets and phasing-in this starting from 2022 (phasing-in at 25% in 2022, 50% in 2023 and 75%
in 2024) and advancing the application of prudential treatment of software assets as amended by CRR II
(which came into force in December 2020).
In October 2021, the European Commission adopted legislative proposals for further amendments to the
CRR, CRD and the BRRD (the ‘2021 Banking Package’). Amongst other things, the 2021 Banking Package
would implement certain elements of Basel III that had not yet been transposed into EU law. In addition, in
the case of the proposed amendments to CRD and the BRRD, their terms and effect will depend, in part, on
how they are transposed in each member state. In December 2023, the preparatory bodies of the Council
and European Parliament endorsed the amendments to the CRR and the CRD and the legal texts were
published on the Council and the Parliament websites. In April 2024, the European Parliament voted to
adopt the amendments to the CRR and the CRD; Regulation (EU 2024/1623 (known as CRR III) and
Directive (EU) 2024/1619 (known as CRD VI) were published in the EU's official journal in June 2024, with
entry into force 20 days from the date of the publication. Most provisions of CRR III have become effective
on 1 January 2025 with certain measures subject to transitional arrangements or to be phased in over time.
Member states shall adopt and publish, by 10 January 2026, the laws, regulations and administrative
provisions necessary to comply with CRD VI and shall apply most of those measures by 11 January 2026.
The Group and BOC PCL have complied with the minimum capital requirements (Pillar I and Pillar II).
The insurance subsidiaries of the Group, the General Insurance of Cyprus Ltd and EuroLife Ltd, comply with
the requirements of the Superintendent of Insurance including the minimum solvency ratio. The regulated
Cyprus Investment Firm (CIF) of the Group, The Cyprus Investment and Securities Corporation Ltd (CISCO)
complies with the minimum capital adequacy ratio requirements. The payment services subsidiary of the
Group, JCC Payment Services Ltd, complies with regulatory capital requirements under the Provision and
Use of Payment Services and Access to Payment Systems Laws of 2018 to 2023.
547
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
49. Related party transactions
Related parties of the Group include associates and joint ventures, key management personnel, members of
the Board of Directors and their connected persons. Connected persons for the purpose of this disclosure
include spouses, minor/dependent children and companies in which the directors/key management
personnel, hold directly or indirectly, at least 50% of the voting shares in a general meeting, or act as
executive director or exercise control of the entities in any way.
(a) Transactions with subsidiaries
The Company is the holding company of the Group. The Company enters into transactions with its
subsidiaries in the normal course of business. Balances and transactions between the Company and its
subsidiaries are disclosed in Note 17 of the Company’s financial statements. Transactions with the
subsidiaries have been eliminated on consolidation.
(b) Transactions with associates
From time to time, the Group provides to and receives from its associates certain banking and financial
services. These are not material to the Group and all the transactions are made on normal business terms
as for comparable transactions with other customers of a similar type.
(c) Compensation of the Board of Directors and key management personnel
The following disclosures are made in accordance with the provisions of IAS 24 Related Party Disclosures
and sections 305 and 306 of the Companies Act 2014, in respect of the compensation of the Board of
Directors and key management personnel.
Fees and emoluments of members of the Board of Directors and key management personnel
2024 2023
Directors' emoluments €000 €000
Executives
Salaries and other short-term benefits 1,151 1,061
Variable remuneration - STIP 72 400
Variable remuneration - LTIP 1,180 -
Retirement benefit plan costs
102 94
2,505 1,555
Non-executives
Fees
942 1,077
Total directors' emoluments
3,447 2,632
Key management personnel emoluments
Salaries and other short-term benefits 3,241 3,058
Termination benefits - 200
Variable remuneration - STIP 600 610
Variable remuneration - LTIP 2,161 -
Retirement benefit plan costs
275 262
Total key management personnel emoluments
6,277 4,130
Total
9,724 6,762
Fees and emoluments of members of the Board of Directors and key management personnel are included
for the period that they serve as members of the Board of Directors and as key management personnel
respectively.
The retirement benefit plan costs relate to contributions paid for defined contribution plans.
548
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
49. Related party transactions (continued)
Variable remuneration amounts (amounts for STIP and LTIP) presented in the tables above and further
below in the tables in this Note represent the award amount awarded in respect of the performance year
2024 for STIP and of the performance period 2022-2024 for the 2022 LTIP (2022 LTIP cycle awarded), and
include both amounts expected to vest in 2025 and amounts to be deferred in following years. In respect of
the 2022 LTIP, the amount of the award disclosed is different from the annual cost amount recorded in the
consolidated income statement as the annual cost is calculated under the IFRS 2 provisions as per the
accounting policy disclosed in Note 2.32. The LTIP amount included in the tables in this Note represents the
amount awarded, calculated as the final amount of shares to be delivered (subject to continuing
employment) (determined by reference to the performance scorecard assessment outcome) based on the
average closing share price on the Cyprus Stock Exchange for the period from 1 December 2024 to 17
January 2025 of €4.62. The final number of shares to be delivered to the CEO have been set to 192,883, to
the EDF to 62,614 and for the key management personnel to 467,662. No LTIP cycle had a performance
period ending in the year ended 31 December 2023 and therefore no amounts are included in the tables in
respect of variable remuneration under LTIP for the comparative period. The annual expense amounts
recorded in the consolidated income statement for the year ended 31 December 2024 and 2023 in
accordance with IFRS 2 in respect of the Executive Directors and key management personnel are disclosed
below.
As disclosed in Note 14.3, the short-term incentive award is primarily awarded in the form of cash. Where
the total amount of variable remuneration for a financial year awarded under STIP and LTIP for an individual
exceeds a threshold as per regulatory guidelines, then at least 50% of the variable remuneration must be
awarded in the form of shares. In the case of the Executive Directors and key management personnel for
the year ended 31 December 2024, the amounts awarded under STIP will be in the form of cash as the LTIP
award is awarded in the form of shares and it is in excess of 50% of the variable remuneration for 2024
(2023: in the case of the Executive Directors, the 2023 STIP award was 50% in the form of cash and 50%
in the form of shares and in the case of the other key management personnel an amount of €560 thousand
was in the form of cash and an amount of €50 thousand in the form of shares). In the context of
establishing the final amount of variable remuneration for the performance year 2024, following the
outcome of the assessment of the predetermined performance targets, the amounts awarded under the
2022 LTIP cycle were determined first, followed by the STIP amount to be awarded so that the total variable
remuneration is within the 100% fixed to variable remuneration ratio threshold. Therefore, for year 2024,
where for a participant the entire of the 100% threshold was utilised for the LTIP, no STIP amount has been
awarded.
In case the total variable remuneration award to an individual exceeds a certain regulatory threshold, then
vesting conditions as described in Note 14.3, apply for both the cash and the share component and remain
subject to malus and clawback conditions as per the applicable regulatory framework and the LTIP Plan
rules.
Executive Directors' emoluments
A cost of €317 thousand has been recorded by the Group in its Consolidated Income Statement in relation
to awards granted in 2022, 2023 and 2024 to the Executive Directors under the Long-Term Incentive Plan
(LTIP) as described in Note 14.2 (2023: cost of €235 thousand for awards granted in 2022 and 2023). The
recognition of such cost is in accordance with the Group accounting policy described in Note 2.32.
Key management personnel
The emoluments of key management personnel include the remuneration of the members of the Executive
Committee and the emoluments of other members of the Senior Management team (Extended EXCO) since
the date of their appointment to the Committees.
Further, employer's contributions in relation to the emoluments of key management personnel of €391
thousand have been recorded in the Consolidated Income Statement during the year ended 31 December
2024 (2023: €351 thousand). Such amounts are not considered part of the remuneration, but rather an
incremental cost to the Group, and as such not included in the table above.
Further, a cost of €615 thousand has been recorded by the Group in its Consolidated Income Statement in
relation to awards granted in 2022, 2023 and 2024 to the key management personnel under the Long-Term
Incentive Plan (LTIP) as described in Note 14.2 (2023: cost of €360 thousand for awards granted in 2022
and 2023). The recognition of such cost is in accordance with the Group accounting policy described in Note
2.32.
549
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
49. Related party transactions (continued)
Executive Directors
The fees and emoluments of the Executive Directors are analysed as follows:
2024 2023
€000 €000
Panicos Nicolaou (Chief Executive Officer)
Salaries and other short-term benefits 819 761
Variable remuneration - STIP - 300
Variable remuneration - LTIP 891 -
Retirement benefit plan costs
73 68
1,783 1,129
Eliza Livadiotou (Executive Director Finance)
Salaries and other short-term benefits 332 300
Variable remuneration - STIP 72 100
Variable remuneration - LTIP 289 -
Retirement benefit plan costs
29 26
722 426
Total
2,505 1,555
The share-based benefits expense recorded in the Consolidated Income Statement during the year ended
31 December 2024 for the share awards granted under the LTIP for LTIP Cycles 2022, 2023 and 2024
amounts to €240 thousand (2023: €186 thousand) for the Chief Executive Officer and to €77 thousand
(2023: €49 thousand) for the Executive Director Finance.
Further, employer's contributions of €63 thousand have been recorded in the Consolidated Income
Statement during the year ended 31 December 2024, of which €34 thousand relate to the Chief Executive
Officer and €29 thousand relate to the Executive Director Finance (2023: total employer's contributions of
€64 thousand, of which €38 thousand relate to the Chief Executive Officer and €26 thousand to the
Executive Director Finance). Such amounts are not considered part of the remuneration of Directors, but
rather an incremental cost to the Group, and as such have not been included in the table above.
Non-executive Directors
The fees of Non-executive Directors are analysed as follows:
2024 2023
€000 €000
Efstratios-Georgios Arapoglou 261 250
Lyn Grobler 165 155
Constantine Iordanou
(1)
81 148
Monique Eugenie Hemerijck
(2)
152 38
Adrian John Lewis
(3)
159 8
Christian Philipp Hansmeyer
(4)
62 -
William Stuart Birrell
(4)
62 -
Arne Berggren
(5)
- 30
Ioannis Zographakis
(6)
- 113
Nicolaos Sofianos
(7)
- 117
Paula Hadjisotiriou
(6)
- 141
Maria Philippou
(8)
- 77
942 1,077
Further, employer's contributions in relation to non-executive Directors of €24 thousand have been recorded
in the Consolidated Income Statement during the year ended 31 December 2024 (2023: €31 thousand).
Such amounts are not considered part of the remuneration of Directors, but rather an incremental cost to
the Group, and as such have not been included in the table above.
550
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
49. Related party transactions (continued)
(1)
Passed away on 16 June 2024.
(2)
ECB approved the appointment of Mrs Monique Eugenie Hemerijck on 10 August 2023.
(3)
ECB approved the appointment of Mr Adrian John Lewis on 17 November 2023.
(4)
On 29 April 2024, ECB approved the appointment of Mr Christian Philipp Hansmeyer and Mr William Stuart
Birrell as members of the Board of Directors and during the AGM on 17 May 2024, they were appointed to
the Board of Directors.
(5)
On 31 March 2023, Mr Arne Berggren resigned as a member of the Board of Directors.
(6)
On 31 December 2023, both Mrs Paula Hadjisotiriou and Mr Ioannis Zographakis resigned from their
respective positions as members of the Board of Directors.
(7)
On 11 December 2023, Mr Nicolaos Sofianos resigned as a member of the Board of Directors.
(8)
On 13 October 2023, Mrs Maria Philippou resigned as a member of the Board of Directors.
The fees of the non-executive Directors include fees as members of the Board of Directors of the Company
and its subsidiaries, as well as fees as members of committees of the Board of Directors. Fees are included
for the period that they serve as members of the Board of Directors, upon approval of appointment by the
ECB, and for the period that they serve as members of the committees of the Board of Directors, upon their
appointment in the respective committee.
(d) Transactions with Directors and key management personnel
The tables below show the deposits, loans and advances and other credit balances held by the members of
the Board of Directors and key management personnel and their connected persons, as at the balance sheet
date and other relevant information as required by the Companies Act 2014 and the provisions of IAS 24
Related Party Disclosures.
Loans to Directors
The following information is presented in accordance with the Companies Act 2014. For the purposes of the
Companies Act 2014 disclosures, ‘Directors’ means the current Board of Directors of the Company and any
past Directors who were members of the Board of Directors of the Company during the year.
All transactions with members of the Board of Directors and their connected persons are made on normal
business terms as for comparable transactions, including interest rates, with customers of a similar credit
standing.
There were nine Directors in office during the year (2023: twelve Directors), two of whom availed of credit
facilities (2023: three Directors). Two of the Directors who availed of credit facilities had balances
outstanding at 31 December 2024 (2023: two of the Directors who availed of credit facilities had balances
outstanding). The balances outstanding are disclosed below.
The value of arrangements at the beginning and end of the current and preceding financial years as stated
below, expressed as a percentage of the net assets of the Group at the beginning and end of the current
and preceding financial years is less than 1% in accordance with section 307 of the Companies Act 2014. No
amounts have been waived during the year ended 31 December 2024.
551
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
49. Related party transactions (continued)
Board of Directors
Details of transactions with the Directors and their connected persons, where indicated, for the years ended
31 December 2024 and 2023 are as follows:
Balance as
at 1 January
Amounts
advanced
during the
year
Amounts
repaid
during the
year
Balance as at
31 December
Aggregate
maximum
amount
outstanding
during the
year
Unused
credit
facilities
Panicos Nicolaou
€000 €000 €000 €000 €000 €000
2024
Overdrafts/ credit cards
2
n/a n/a
3 5 54
Panicos Nicolaou
2023
Overdrafts/ credit cards
2
n/a n/a
2 4 54
Balance as
at 1 January
Amounts
advanced
during the
year
Amounts
repaid
during the
year
Balance as at
31 December
Aggregate
maximum
amount
outstanding
during the
year
Unused
credit
facilities
Eliza
Livadiotou
€000 €000 €000 €000 €000 €000
2024
Loans 71 - 14 60 71 -
Overdrafts/ credit cards
4
n/a n/a
8 8 55
75 68 79 55
Eliza
Livadiotou
2023
Loans 87 - 19 71 87 -
Overdrafts/ credit cards
14
n/a n/a
4 14 59
101 75 101 59
Balance as
at 1 January
Amounts
advanced
during the
year
Amounts
repaid
during the
year
Balance
as at
31 December
Aggregate
maximum
amount
outstanding
during the
year
Unused
credit
facilities
Ioannis Zographakis
€000 €000 €000 €000 €000 €000
2023
Overdrafts/ credit cards
2
n/a n/a n/a
2 -
The balances included in the table above include principal and interest. Also, amounts approved and repaid
are not shown for overdraft and credit card facilities as these are revolving in nature. The aggregate
maximum amount outstanding includes credit card exposures at the maximum statement balance.
No other Directors had any loan facilities or overdraft/credit card balances with the Group during the year
ended 31 December 2024 (2023: nil).
The aggregate expected credit loss allowance on the above loans and credit facilities is below €5 thousand
as at 31 December 2024 (2023: below €5 thousand). All principal and interest that has fallen due on these
loans or credit facilities has been paid.
552
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
49. Related party transactions (continued)
Connected persons of the Board of Directors
The aggregate of loans to connected persons of Directors in office at 31 December 2024, as defined in
section 220 of the Companies Act 2014, are as follows (2024: aggregate of two persons; 2023: aggregate
of two persons):
Balance as at
1 January
Amounts
advanced
during the year
Amounts
repaid during
the year
Balance as at
31 December
Aggregate
maximum
amount
outstanding
during the year
Panicos Nicolaou
€000 €000 €000 €000 €000
2024
Overdrafts/credit cards
1
n/a n/a
1 3
2023
Overdrafts/credit cards
2
n/a n/a
1 2
Balance as at
1 January
Amounts
advanced
during the year
Amounts
repaid during
the year
Balance as at
31 December
Aggregate
maximum
amount
outstanding
during the year
Eliza Livadiotou
€000 €000 €000 €000 €000
2024
Loans 66 - 13 57 66
Overdrafts/credit cards
18
n/a n/a
15 18
84 72 84
2023
Loans 74 - 13 66 74
Overdrafts/credit cards
10
n/a n/a
18 18
84 84 92
The balances included in the table above include principal and interest. Also, amounts approved and repaid
are not shown for overdraft and credit card facilities as these are revolving in nature. The aggregate
maximum amount outstanding includes credit card exposures at the maximum statement balance.
The aggregate expected credit loss allowance on the above loans and credit facilities is below €5 thousand
as at 31 December 2024 (2023: below €5 thousand). All principal and interest that has fallen due on these
loans or credit facilities has been paid.
Key management personnel in office during the year and their connected persons
There were 19 key management personnel in office during the year (2023: 20 key management personnel),
19 of whom availed of credit facilities (2023: 20 key management personnel). All of the key management
personnel who availed of credit facilities had balances outstanding at 31 December 2024 and 2023.
A number of loans and advances have been extended to key management personnel on the same terms as
those applicable to the rest of the Group’s employees and to their connected persons on the same terms as
those of customers of a similar credit standing.
Where no amount is shown in the tables below, this indicates a credit balance, a nil balance, or a balance of
less than €500.
553
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
49. Related party transactions (continued)
Details of transactions with key management personnel and their connected persons for the years ended 31
December 2024 and 2023 are as follows:
Balance as
at 1 January
Balances of
key
management
personnel
appointed in
the year
Other
movements
on balances
of key
management
personnel and
their
connected
persons
during the
year
Amounts
advanced
during the year
Amounts repaid
during the year
Balance as at
31 December
Aggregate
maximum
amount
outstanding
during the
year (since
appointment
date)
2024
€000 €000 €000 €000 €000 €000 €000
Loans 2,092 n/a - 142 477 1,967 2,303
Overdrafts/credit cards
249
n/a n/a n/a n/a
269 437
2,341 2,236 2,740
2023
Loans 2,400 - - 605 490 2,092 2,439
Overdrafts/credit cards
386
n/a n/a n/a n/a
249 568
2,786 2,341 3,007
The balances included in the table above include principal and interest. Also, amounts approved and repaid
are not shown for overdraft and credit card facilities as these are revolving in nature. The aggregate
maximum amount outstanding includes credit card exposures at the maximum statement balance.
The aggregate expected credit loss allowance on the above loans and credit facilities is below €26 thousand
as at 31 December 2024 (2023: below €11 thousand). All principal and interest that has fallen due on these
loans or credit facilities has been paid.
Aggregate amounts outstanding at year end and additional transactions
2024 2023
€000 €000
Loans and advances as at 31 December
Board of Directors 71 77
Key management personnel 1,706 1,849
Connected persons - Board of Directors 73 85
Connected persons - Key management personnel
530 492
2,380 2,503
Deposits as at 31 December
Board of Directors 644 1,919
Key management personnel 2,945 2,004
Connected persons - Board of Directors 308 969
Connected persons - Key management personnel
4,541 2,402
8,438 7,294
Interest income for the year
113 119
Interest expense for the year
37 9
Insurance premium income for the year
487 497
Insurance expenses for the year
6 5
The above table does not include year-end balances for members of the Board of Directors, key
management personnel and their connected persons who resigned during the year, nor balances of
customers that do not meet the definition of connected persons as at 31 December 2024.
554
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
49. Related party transactions (continued)
As at 31 December 2024 there were nine Directors in office (2023: seven) and 19 key management
personnel in office (2023: 18).
Interest income and expense are disclosed for the period during which they were members of the Board of
Directors or served as key management personnel.
During the year ended 31 December 2024 an amount of €871 thousand has been paid to connected persons
of key management personnel for the cost of services capitalised within property and equipment. These
services were rendered on normal business terms as for comparable services received from third parties.
In addition to loans and advances, there were contingent liabilities and commitments in respect of members
of the Board of Directors and their connected persons, mainly in the form of documentary credits,
guarantees and commitments to lend, amounting to €114 thousand as at 31 December 2024 (2023: €116
thousand).
There were also contingent liabilities and commitments to key management personnel and their connected
persons amounting to €1,379 thousand as at 31 December 2024 (2023: €1,197 thousand).
The total unsecured amount of the loans and advances and contingent liabilities and commitments to
members of the Board of Directors, key management personnel and their connected persons (using forced-
sale values for tangible collaterals and assigning no value to other types of collaterals) at 31 December
2024 amounted to €1,485 thousand (2023: €1,489 thousand).
During the year ended 31 December 2024 premiums of €177 thousand (2023: €220 thousand) and nil
claims (2023: nil) were paid by/to the members of the Board of Directors of the Company and their
connected persons to/from the insurance subsidiaries of the Group.
There were no other transactions during the year ended 31 December 2024 and 2023 with connected
persons of the current members of the Board of Directors or with any members who resigned during the
years.
555
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
50. Group companies
The main subsidiary companies and branches included in the Consolidated Financial Statements of the
Company, their registered office, their activities and the percentage held by the Company (directly or
indirectly) as at 31 December 2024 are:
Company Registered office Activities
Percentage
holding (%)
Bank of Cyprus Holdings Public
Limited Company
10 Earlsfort Terrace, Dublin 2,
D02 T380, Ireland
Holding company n/a
Bank of Cyprus Public Company Ltd
51 Stasinos Street, Ayia
Paraskevi, Strovolos, CY-2002,
Nicosia, Cyprus
Commercial bank 100
EuroLife Ltd
4 Evrou Street, CY-2003,
Strovolos, Nicosia, Cyprus
Life insurance 100
General Insurance of Cyprus Ltd
2-4 Themistokli Dervis Street,
CY-1066, Nicosia, Cyprus
Non-life insurance 100
JCC Payment Systems Ltd
1 Stadiou Street, CY-2571,
Nisou, Cyprus
Development of inter-banking
systems, acquiring and
processing of card transactions,
other payment services and
other activities
75
The Cyprus Investment and
Securities Corporation Ltd (CISCO)
1 Agiou Prokopiou and
Poseidonos Street, CY-2406,
Engkomi, Nicosia, Cyprus
Investment banking,
brokerage, discretionary asset
management and investment
advice services
100
Jinius Ltd
51 Stasinos Street, Ayia
Paraskevi, Strovolos, CY-2002,
Nicosia, Cyprus
Digital Economy Platform 100
LCP Holdings and Investments Public
Ltd
1 Agiou Prokopiou and
Poseidonos Street, CY-2406,
Engkomi, Nicosia, Cyprus
Investments in securities and
participations in companies and
schemes that are active in
various business sectors and
projects
67
Kermia Ltd
51 Stasinos Street, Ayia
Paraskevi, Strovolos, CY-2002,
Nicosia, Cyprus
Property trading and
development
100
Kermia Properties & Investments Ltd
51 Stasinos Street, Ayia
Paraskevi, Strovolos, CY-2002,
Nicosia, Cyprus
Property trading and
development
100
S.Z. Eliades Leisure Ltd
51 Stasinos Street, Ayia
Paraskevi, Strovolos, CY-2002,
Nicosia, Cyprus
Land development and
operation of a golf resort
70
Auction Yard Ltd
51 Stasinos Street, Ayia
Paraskevi, Strovolos, CY-2002,
Nicosia, Cyprus
Auction company 100
BOC Secretarial Company Ltd
51 Stasinos Street, Ayia
Paraskevi, Strovolos, CY-2002,
Nicosia, Cyprus
Secretarial services 100
Bank of Cyprus Public Company Ltd
(branch of BOC PCL)
192 Alexandras Avenue,
11521 Athens, Greece
Administration of guarantees
and holding of real estate
properties
n/a
BOC Asset Management Romania
S.A.
Calea Dorobonti 187B, Sector 1,
Bucharest, Romania
In run-down 100
MC Investment Assets Management
LLC
19-1 Zvezdnyi building, Moscow,
Russia
Problem asset management
company - In run-down
100
Fortuna Astrum Ltd
Internacionalnih Brigada 69,
11104, Grad Beograd, Serbia
Problem asset management
company - In run-down
100
556
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
50. Group companies (continued)
In addition to the above companies, as at 31 December 2024, BOC PCL had 100% shareholding, either
directly or indirectly, in the companies listed below, whose activity is the ownership and management of
immovable property:
Cyprus: Tolmeco Properties Ltd, Pelika Properties Ltd, Cobhan Properties Ltd, Nalmosa Properties Ltd,
Emovera Properties Ltd, Blodar Properties Ltd, Cranmer Properties Ltd, Les Coraux Estates Ltd, Natakon
Company Ltd, Oceania Ltd, Dominion Industries Ltd, Ledra Estate Ltd, Laiki Lefkothea Center Ltd, Labancor
Ltd, Joberco Ltd, Domita Estates Ltd, Memdes Estates Ltd, Kernland Properties Ltd, Jobelis Properties Ltd,
Melsolia Properties Ltd, Spacous Properties Ltd, Solomaco Properties Ltd, Linaland Properties Ltd, Unital
Properties Ltd, Neraland Properties Ltd, Wingstreet Properties Ltd, Nolory Properties Ltd, Lisbo Properties
Ltd, Mantinec Properties Ltd, Provezaco Properties Ltd, Hillbay Properties Ltd, Forenaco Properties Ltd,
Hovita Properties Ltd, Astromeria Properties Ltd, Barosca Properties Ltd, Fogland Properties Ltd, Tebasco
Properties Ltd, Valecross Properties Ltd, Altco Properties Ltd, Olivero Properties Ltd, Jaselo Properties Ltd,
Elosa Properties Ltd, Flona Properties Ltd, Toreva Properties Ltd, Resoma Properties Ltd, Mostero Properties
Ltd, Helal Properties Ltd, Pendalo Properties Ltd, Frontyard Properties Ltd, Bonsova Properties Ltd,
Thermano Properties Ltd, Venicous Properties Ltd, Lorman Properties Ltd, Eracor Properties Ltd, Rulemon
Properties Ltd, Maledico Properties Ltd, Balasec Properties Ltd, Diafor Properties Ltd, Kartama Properties
Ltd, Paramina Properties Ltd, Nouralia Properties Ltd, Resocot Properties Ltd, Soblano Properties Ltd,
Talamon Properties Ltd, Weinar Properties Ltd, Zemialand Properties Ltd, Coeval Properties Ltd, Finevo
Properties Ltd, Mazima Properties Ltd, Riveland Properties Ltd, Rosalica Properties Ltd, Secretsky Properties
Ltd, Senadaco Properties Ltd, Tasabo Properties Ltd, Venetolio Properties Ltd, Zandexo Properties Ltd,
Odolo Properties Ltd, Molemo Properties Ltd, Samilo Properties Ltd, Alezia Properties Ltd, Enelo Properties
Ltd, Monata Properties Ltd, Amary Properties Ltd, Aparno Properties Ltd, Lomenia Properties Ltd, Midelox
Properties Ltd, Montira Properties Ltd, Orilema Properties Ltd, Carilo Properties Ltd, Olisto Properties Ltd,
Holstone Properties Ltd, Gelimo Properties Ltd, Larizemo Properties Ltd and Philiki Ltd.
Romania: Otherland Properties Dorobanti SRL.
Further, at 31 December 2024, BOC PCL had 100% shareholding in Stamoland Properties Ltd, Unoplan
Properties Ltd, Petrassimo Properties Ltd and Gosman Properties Ltd.
The main activities of the above companies are the holding of shares and other investments and the
provision of services.
At 31 December 2024, BOC PCL had 100% shareholding in BOC Terra AIF V.C.I.C. Plc which is a real estate
alternative investment fund, currently inactive.
At 31 December 2024, BOC PCL had 100% shareholding, either directly or indirectly, in the companies
listed below which are reserved to accept property:
Cyprus: Rifelo Properties Ltd, Dadela Properties Ltd, Leziga Properties Ltd, Bavara Properties Ltd, Fernia
Properties Ltd, Wolfenia Properties Ltd, Ortizelo Properties Ltd and Ellagio Properties Ltd.
In addition, BOC PCL holds 100% of the following intermediate holding companies:
Cyprus: Otherland Properties Ltd, Battersee Properties Ltd, Bonayia Properties Ltd, Janoland Properties Ltd,
Imoreth Properties Ltd, Inroda Properties Ltd, Zunimar Properties Ltd, Nikaba Properties Ltd, Allioma
Properties Ltd and Hydrobius Ltd.
BOC PCL also holds 100% of the following companies which are inactive:
Cyprus: Laiki Bank (Nominees) Ltd, Paneuropean Ltd, Nelcon Transport Co. Ltd, Canosa Properties Ltd,
Hοmirova Properties Ltd and Finerose Properties Ltd.
Greece: Kyprou Zois (branch of EuroLife Ltd), Kyprou Asfalistiki (branch of General Insurance of Cyprus
Ltd), Kyprou Commercial SA and Kyprou Properties SA.
BOC PCL also holds indirectly 75% of Settle Cyprus Ltd, which is inactive.
All Group companies are accounted for as subsidiaries using the full consolidation method. All companies
listed above have share capital consisting of ordinary shares.
557
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
50. Group companies (continued)
Acquisitions of subsidiaries
During the years ended 31 December 2024 and 2023 there were no acquisitions of subsidiaries.
Dissolution and disposal of subsidiaries
There were no material disposals of subsidiaries during the year ended 31 December 2024. CYCMC IV Ltd,
Blindingqueen Properties Ltd, Prodino Properties Ltd, Ensolo Properties Ltd, Fairford Properties Ltd, Sylvesta
Properties Ltd and Iperi Property Ltd were dissolved during the year ended 31 December 2024. Regetona
Properties Ltd, Soluto Properties Ltd, Camela Properties Ltd, Baleland Properties Ltd, Ramendi Properties
Ltd, Fitrus Properties Ltd, Estaga Properties Ltd, Avaleto Properties Ltd, Zecomex Ltd, Bendolio Properties
Ltd, Cramonco Properties Ltd, Zenoplus Properties Ltd, Hamura Properties Ltd, Vertilia Properties Ltd, Colar
Properties Ltd, Koralmon Properties Ltd and Skellom Properties Ltd were disposed of during the year ended
31 December 2024.
As at 31 December 2024, the following subsidiaries were in the process of dissolution or in the process of
being struck off: Fantasio Properties Ltd, Demoro Properties Ltd, Bramwell Properties Ltd, Battersee Real
Estate SRL,Thryan Properties Ltd, Obafemi Holdings Ltd, Birkdale Properties Ltd, Green Hills Properties SRL,
Imoreth Properties SRL, Inroda Properties SRL, Zunimar Properties SRL, Allioma Properties SRL,
Landanafield Properties Ltd and Nikaba Properties SRL.
51. Investments in associates and joint venture
Percentage
holding
Investments in associates (%)
Aris Capital Management LLC 30.0
Fairways Automotive Holdings Ltd 45.0
During the year ended 31 December 2024, Rosequeens Properties Limited (33.3% holding) was dissolved.
The carrying values of the investments in associates are assessed as fully impaired and their value has been
restricted to zero.
Percentage
holding
Investment in joint venture (%)
Tsiros (Agios Tychon) Ltd 50.0
The carrying value of the investment in the joint venture is assessed as fully impaired and its value has
been restricted to zero.
52. Offsetting financial assets and liabilities
The following tables set out the effect or potential effect of netting arrangements on the Group's financial
position. This includes the effect or potential effect of rights of set off associated with the Group's
recognised financial assets and recognised financial liabilities that are subject to an enforceable master
netting arrangement, irrespective of whether they are set off in accordance with paragraph 42 of IAS 32.
The 'Amounts subject to master netting agreements' column identifies financial assets and liabilities that are
subject to set off under netting provisions included in counterparties' agreements such as an ISDA Master
Agreement.
The agreement between the Group and the counterparty allows for net settlement of the relevant financial
assets and liabilities when both elect to settle on a net basis. In the absence of such an election, financial
assets and liabilities are settled on a gross basis; however each party, for which the netting provisions apply
under an ISDA Master Agreement, has the option to settle all such amounts on a net basis in the event of
default of the other party.
558
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
52. Offsetting financial assets and liabilities (continued)
Related amounts
not set off in the
balance sheet
Gross
amounts of
recognised
financial
assets
Gross
amounts of
recognised
financial
liabilities
set off in
the balance
sheet
Net
amounts of
financial
assets
presented
in the
balance
sheet
Amounts
subject to
master
netting
agreements
Financial
collateral
(including
cash
collateral)
Net
amount
Assets
€000 €000 €000 €000 €000 €000
2024
Derivative financial assets 95,273 - 95,273 (3,421) (91,202) 650
Reverse repurchase agreements
1,010,170 - 1,010,170 - (13,068) 997,102
Total
1,105,443 - 1,105,443 (3,421) (104,270) 997,752
2023
Derivative financial assets 51,055 - 51,055 (3,705) (47,179) 171
Reverse repurchase agreements
403,199 - 403,199 - - 403,199
Total
454,254 - 454,254 (3,705) (47,179) 403,370
The gross amounts of recognised derivative financial assets, include amounts of €3,421 thousand that do
not meet the offsetting criteria, but are subject to enforceable master netting arrangements (2023: €3,705
thousand). Financial collateral (including cash collateral) disclosed is limited to the net position exposure
and hence may differ from the maximum collateral available for offset and is reported in 'Deposits by
banks'.
Related amounts
not set off in the
balance sheet
Gross
amounts of
recognised
financial
liabilities
Gross
amounts of
recognised
financial
assets set
off in the
balance
sheet
Net
amounts of
financial
liabilities
presented
in the
balance
sheet
Amounts
subject to
master
netting
agreements
Financial
collateral
(including
cash
collateral)
Net
amount
Liabilities
€000 €000 €000 €000 €000 €000
2024
Derivative financial liabilities
4,664 - 4,664 (3,421) - 1,243
Total
4,664 - 4,664 (3,421) - 1,243
2023
Derivative financial liabilities
17,980 - 17,980 (3,705) (11,896) 2,379
Total
17,980 - 17,980 (3,705) (11,896) 2,379
The gross amounts of recognised derivative financial liabilities, include amounts of €3,421 thousand that do
not meet the offsetting criteria, but are subject to enforceable master netting arrangements (2023: €3,705
thousand). Financial collateral (including cash collateral) disclosed is limited to the net position exposure
and hence may differ from the maximum collateral available for offset and is reported in 'Loans and
advances to banks'.
559
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
53. Country by country reporting
Article 89 of CRD IV requires banks to disclose on a consolidated basis the following information for all countries where the Group operates. The table below
provides information on the following items of the Group for year 2024:
Total operating
income/(expense)
Average number
of employees
Profit/(loss)
before tax
Accounting tax
expense on
profit/(loss)
Corporation tax
paid/(refunded)
Public subsidies
received
Country €000 €000 €000 €000 €000
Cyprus 1,095,980 2,851 599,993 45,214 28,547 -
Russia - 1 (250) - - -
Romania 10 - (269) - - -
Greece
(281) 6 (9,203) - - -
Total
1,095,709 2,858 590,271 45,214 28,547 -
Total operating income/(expense), profit/(loss) before tax and accounting tax expense on profit/(loss) are prepared on the same basis as the figures reported
elsewhere in these financial statements.
The activities of Group companies by geographical area are disclosed in Note 50.
Total operating income/(expense): comprises net interest income, net fee and commission income, net foreign exchange gains, net gains on financial
instruments, net losses on derecognition of financial assets measured at amortised cost, net insurance result, net losses from revaluation and disposal of
investment properties, net gains on disposal of stock of property and other income.
Number of employees: the number of employees has been calculated as the average number of employees, on a quarterly basis, who were employed by the
Group during the year ended 31 December 2024.
Profit/(loss) before tax: profit/(loss) before tax represents profits/(losses) after the deduction of inter-segment revenues/(expenses).
Accounting tax expense on profit/(loss): represents the corporation tax expense for the current year and excludes deferred taxes, adjustments in respect of
prior years and other tax provisions.
Corporation tax paid/(refunded) includes actual payments made during 2024 for corporation tax (including insurance premium taxes) and Cyprus special
defence contribution.
560
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY
Annual Financial Report 2024
Notes to the Consolidated Financial Statements
54. Events after the reporting period
Distribution in respect of 2024 earnings
In February 2025, the Company announced its proposal to make a total distribution of €241 million in
respect of 2024 earnings, comprising an aggregate cash dividend of €211 million (calculated by reference to
the number of shares in issue as at 31 December 2024) and a share buyback in an aggregate consideration
amount of up to €30 million (together, the ‘2024 Distribution’) as described below.
Cash dividend
The Board of Directors of the Company has resolved to propose to the AGM that will be held on 16 May
2025 for approval, a final cash dividend of €0.48 per ordinary share in respect of earnings for the year
ended 31 December 2024. The financial statements for the year ended 31 December 2024 do not reflect
this dividend, which will be accounted for in shareholders’ equity as an appropriation of retained earnings in
the year ending 31 December 2025.
Share Buyback Programme
Following approval by the Board of Directors, on 24 February 2025 the Company launched a programme to
buy back ordinary shares of the Company for an aggregate consideration of up to €30 million, for which
approval by the ECB has been received. The shares will be repurchased on the Main Market of the Regulated
Securities Market of the ATHEX and the CSE and will be cancelled. The financial statements for the year
ended 31 December 2024 do not reflect the impact of the share buyback programme, which will be
accounted for as and when the shares are repurchased by the Company.
During the period from 24 February 2025 to 20 March 2025, 1,035 thousand ordinary shares have been
bought back at a total cost of €5,744 thousand. As at 20 March 2025, the Company holds 1,035 thousand
ordinary shares, all arising from the share repurchase programme.
Dividends and share buybacks are funded out of distributable reserves.
No other significant non-adjusting events have taken place since 31 December 2024.
561
Company Financial Statements
2024
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Company Financial Statements
for the year ended 31 December 2024
563
Contents
Page
Company Statement of Comprehensive Income 564
Company Balance Sheet 565
Company Statement of Changes in Equity 566
Company Statement of Cash Flows 567
Notes to the Company Financial Statements 568-581
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Company Statement of Comprehensive Income
for the year ended 31 December 2024
564
Notes
2024 2023
000 000
Income
Income from equity instruments 8 26,125
27,339
Income from debt instruments 8 19,875
19,875
Total income from investments 46,000
47,214
Dividend income from subsidiary 7 136,590
22,310
Other income 4 7,957
13,153
Total income 190,547
82,677
Administrative and other operating expenses 5 (9,730)
(5,700)
180,817
76,977
Interest expense on subordinated liabilities 14 (20,320)
(20,318)
Finance costs (215)
(531)
Reversal of credit losses on financial instruments 8 968
3,073
Reversal of impairment of investment in subsidiary 7 801,068
573,405
Profit before tax 962,318
632,606
Tax 6 -
(42)
Profit after tax for the year 962,318
632,564
Other comprehensive income (OCI)
OCI not to be reclassified in the income statement in
subsequent periods
Fair value reserve (equity instruments)
Net gains on investments in equity instruments measured at
fair value through OCI (FVOCI)
8 27,241
27,915
Total OCI not to be reclassified in the income statement
in subsequent periods
27,241
27,915
Other comprehensive income for the year 27,241
27,915
Total comprehensive income for the year 989,599
660,479
The notes on pages 568 to 581 form an integral part of these Company’s financial statements.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Company Balance Sheet
as at 31 December 2024
565
Notes
2024 2023
000 000
Assets
Non-current assets
Investment in subsidiaries 7 2,975,000
2,173,000
Investments 8 565,565
537,357
3,540,565
2,710,357
Current assets
Cash at bank 9 9,572
1,965
Other assets 245
103
Receivables from related parties 10 2,261
843
12,078
2,911
Total assets 3,552,643
2,713,268
Equity and liabilities
Equity and reserves
Share capital 11 44,050
44,620
Share premium 11 594,358
594,358
Capital redemption reserve 11 570
-
Revaluation and other reserves 13 43,832
15,659
Retained earnings 12 2,330,608
1,531,055
Equity attributable to the owners of the Company 3,013,418
2,185,692
Other equity instruments 11 220,000
220,000
Total equity 3,233,418
2,405,692
Non-current liabilities
Subordinated liabilities 14 302,995
302,550
Current liabilities
Bank overdraft 9 2,774
1,339
Other payables 15 13,456
3,687
16,230
5,026
Total liabilities 319,225
307,576
Total liabilities and equity 3,552,643
2,713,268
26 March 2025
The notes on pages 568 to 581 form an integral part of these Company’s financial statements.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Company Statement of Changes in Equity
for the year ended 31 December 2024
566
Share
capital
(Note 11)
Share
premium
(Note 11)
Capital
redemption
reserve
(Note 11)
Retained
earnings
(Note 12)
Financial
instruments
fair value
reserve
(Note 8)
Other
reserves
(Note 13)
Total equity
attributable to
the owners of
the Company
Other equity
instruments
(Note 11)
Total
equity
000 000 000 000 000 000 000 000 000
Balance at 1 January 2023 44,620 594,358 - 951,671 (6,354) 322 1,584,617 220,000 1,804,617
Profit after tax for the year - - - 632,564 - 632,564 - 632,564
Other comprehensive income after
tax for the year
- - - - 27,915 - 27,915 - 27,915
Total comprehensive income after
tax for the year
- - - 632,564 27,915 - 660,479 - 660,479
Dividends (Note 18) - - - (22,310) - - (22,310) - (22,310)
Payment of coupon to AT1 holders
(Note 11)
- - - (27,339) - (27,339) (27,339)
Share-based benefits – cost (Note
13)
- - - - - 595 595 - 595
Issue of other equity instruments
(Note 11)
- - - (3,530) - - (3,530) 220,000 216,470
Repurchase of other equity
instruments (Note 11)
- - - (6,820) - (6,820) (220,000) (226,820)
Transfer to retained earnings - - - 6,819 (6,819) - - - -
Balance at 31 December 2023/1
January 2024
44,620 594,358 - 1,531,055 14,742 917 2,185,692 220,000 2,405,692
Profit after tax for the year - - - 962,318 - - 962,318 - 962,318
Other comprehensive income after
tax
for the year
- - - - 27,241 - 27,241 - 27,241
Total comprehensive income after
tax for the year
- - - 962,318 27,241 - 989,559 - 989,559
Dividends (Note 18) - - - (111,550) - - (111,550) - (111,550)
Payment of coupon to AT1 holders
(Note 11)
- - - (26,125) - - (26,125) - (26,125)
Share-based benefits – cost (Note
13)
- - - - 932 932 - 932
Share buyback-repurchase and
cancellation
of shares
(Note 11)
(570) - 570 (25,090) - - (25,090) - (25,090)
Balance at 31 December 2024 44,050 594,358 570 2,330,608 41,983 1,849 3,013,418 220,000 3,233,418
The notes on pages 568 to 581 form an integral part of these Company’s financial statements.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Company Statement of Cash Flows
for the year ended 31 December 2024
567
Notes
2024 2023
000 000
Cash flows from operating activities
Profit before tax
962,318
632,606
Adjustments for:
Income from equity instruments 8 (26,125)
(27,339)
Income from debt instruments 8 (19,875)
(19,875)
Dividend income from subsidiary 7 (136,590)
(22,310)
Reversal of credit losses of financial instruments 8 (968)
(3,073)
Interest expense on subordinated liabilities 14 20,320
20,318
Reversal of impairment of investment in subsidiary 7 (801,068)
(573,405)
(1,988)
6,922
Changes in working capital:
Other assets (142) (31)
Receivables from related parties 10 (1,418) 2,892
Other payables 15 2,211 838
Tax paid 15 (48) (40)
Net cash flows (used in)/from operating activities (1,385) 10,581
Cash flows from investing activities
Income received from equity instruments 8 26,125
27,339
Purchase of other equity instruments 8 -
(220,000)
Proceeds from redemption of other equity instruments 8 -
226,820
Income received from debt instruments 8 19,875
19,875
Dividend income received 7 136,590
22,310
Net cash flows from investing activities
182,590
76,344
Cash flows from financing activities
Payment of AT1 coupon 11 (26,125) (27,339)
Payment of interest on subordinated liabilities 14 (19,875) (19,875)
Issue of other equity instruments (net of transaction costs) 11 - 216,470
Repurchase of other equity instruments 11 - (226,820)
Dividends paid (103,943) (20,345)
Repurchase of shares (25,090) -
Net cash flows used in financing activities
(175,033) (77,909)
Net increase in cash and cash equivalents
6,172
9,016
Cash and cash equivalents:
At beginning of the year
626
(8,390)
At end of the year 9 6,798
626
The notes on pages 568 to 581 form an integral part of these Company’s financial statements.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
568
1. Corporate information
Bank of Cyprus Holdings Public Limited Company (the ‘Company’) was incorporated in Ireland on 11 July 2016,
as a public limited company under company number 585903 in accordance with the provisions of the Companies
Act 2014 of Ireland (Companies Act 2014). Its registered office is 10 Earlsfort Terrace, Dublin 2, D02 T380,
Ireland.
The Company owns 100% of the share capital of Bank of Cyprus Public Company Limited (‘BOC PCL’) whose
principal activities, together with BOC PCL’s subsidiaries, involve the provision of banking services, financial
services, insurance services and the management and disposal of property predominately acquired in exchange
of debt. The Board of Directors does not expect that the Company’s activities will change in the foreseeable
future. The Company is tax resident in Cyprus.
The Bank of Cyprus Holdings Group (the ‘Group’) comprises the Company, its subsidiary BOC PCL and the
subsidiaries of BOC PCL.
The shares of the Company are listed and trading on the Cyprus Stock Exchange (CSE). As of 23 September
2024, the shares of the Company are also listed and trading on the Athens Stock Exchange (ATHEX). On 19
September 2024, the Company’s shares were delisted and trading was suspended from the London Stock
Exchange (LSE).
The Company financial statements are available at the Company’s registered office (at 10 Earlsfort Terrace,
Dublin 2, D02 T380, Ireland) and on the Group’s website http://www.bankofcyprus.com (Group/Investor
Relations/Financial Results).
Company financial statements
The Company financial statements for the year ended 31 December 2024 were authorised for issue by a resolution
of the Board of Directors on 26 March 2025. The financial statements are available at the Company’s registered
office and on the Group’s website.
The Company financial statements are originally issued in English. The Greek translation of the Company financial
statements will be available on the Group’s website by 4 April 2025. In case of a difference or inconsistency
between the English document and the Greek document, the English document prevails.
2. Summary of accounting policies
2.1 Basis of preparation
The Company financial statements have been prepared in accordance with International Financial Reporting
Standards (IFRSs) as adopted by the European Union (EU) and with those parts of the Companies Act 2014
applicable to companies reporting under IFRSs.
Presentation of the Company financial statements
The Company financial statements are presented in Euro () and all amounts are rounded to the nearest
thousand, except where otherwise indicated. A comma is used to separate thousands and a dot is used to separate
decimals.
2.2 Going concern
The going concern assessment of the Company is consistent with the going concern assessment of the Group,
which is presented in Note 3 of the consolidated financial statements of the Company for the year ended 31
December 2024.
2.3 Changes in accounting policies and disclosures
The accounting policies adopted in preparing the financial statements of the Company are consistent with those
adopted in preparing the consolidated financial statements of the Company, a summary of which is presented in
Note 2 of the consolidated financial statements of the Company for the year ended 31 December 2024.
In addition, the following policies are applied:
Investment in subsidiaries
The investment in subsidiaries is measured at cost less impairment.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
569
2. Summary of accounting policies (continued)
2.3 Changes in accounting policies and disclosures (continued)
Investment in subsidiaries (continued)
The Company periodically evaluates the recoverability of the investment in subsidiaries whenever indicators of
impairment are present. Indicators of impairment include items such as declines in revenues, earnings or cash
flows of the subsidiary or material adverse changes in the economic or political stability of the country in which
the subsidiary operates, which may indicate that the carrying amount of the investment in subsidiary is not
recoverable. If facts and circumstances indicate that the investment in a subsidiary may be impaired, the
Company determines the recoverable amount of the investment in the subsidiary as the higher of its fair value
less costs to sell and its value-in-use. Value-in-use is calculated by estimating the future cash inflows and outflows
to be derived from continuing use of the asset and applying the appropriate discount rate.
If the recoverable amount is lower than the carrying value of the investment in subsidiary, an impairment loss is
recognised equal to the excess of the carrying value over the recoverable amount. In the case where the
recoverable amount is higher than the carrying value of the subsidiary, that increase is recognised by the
Company as a reversal of the impairment loss recognised in prior periods, to the extent that the increased carrying
amount attributable to the reversal of the impairment does not exceed the carrying amount that would have been
determined had no impairment loss been recognised in prior years.
Further details on the determination of the recoverable amount of the investment in subsidiary are disclosed in
Note 7.
The accounting policies adopted are consistent with those of the previous financial year. The adoption of new and
amended standards and interpretations as explained in Note 2.2 of the consolidated financial statements of the
Company for the year ended 31 December 2024, did not have an impact on the Company financial statements.
3. Significant accounting estimates, judgements and assumptions
The preparation of the Company financial statements requires the Company’s Board of Directors and management
to make judgements, estimates and assumptions that can have a material impact on the amounts recognised in
the Company financial statements and the accompanying disclosures, as well as the disclosures of contingent
liabilities. Uncertainty about these assumptions and estimates could result in outcomes that may require a
material adjustment to the carrying amount of assets or liabilities affecting future periods. The Board of Directors
has made the following judgements and estimates:
Fair value of investments
The best evidence of fair value is a quoted price in an actively traded market. If the market for a financial
instrument is not active, a valuation technique is used. The majority of valuation techniques employed by the
Company use only observable market data and so the objectivity of the fair value measurement is relatively high.
However, certain financial instruments are valued on the basis of valuation techniques that feature one or more
significant inputs that are not observable. Valuation techniques that rely on non-observable inputs require a
higher level of management judgement to calculate a fair value than those based wholly on observable inputs.
Valuation techniques used to calculate fair values include comparisons with similar financial instruments for which
market observable prices exist, discounted cash flow analysis and other valuation techniques commonly used by
market participants. Valuation techniques incorporate assumptions that other market participants would use in
their valuations, including assumptions about interest rate yield curves, exchange rates, volatilities and default
rates. When valuing instruments by reference to comparable instruments, management takes into account the
maturity, structure and rating of the instrument with which the position held is being compared.
The Company only uses models with unobservable inputs for the valuation of certain unquoted equity
investments. In these cases, estimates are made to reflect uncertainties in fair values resulting from a lack of
market data inputs, for example, as a result of illiquidity in the market. Inputs into valuations based on
unobservable data are inherently uncertain because there is little or no current market data available from which
to determine the level at which an arm’s length transaction would occur under normal business conditions.
Unobservable inputs are determined based on the best information available.
Further details on the Company’s fair value of assets and liabilities are disclosed in Note 16.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
570
3. Significant accounting estimates, judgements and assumptions (continued)
Impairment review of the subsidiary undertaking
The Company carries the investment in its subsidiary undertaking at cost less impairment and reviews whether
there is any indication of impairment at each reporting date. Impairment testing involves comparing the carrying
value of the investment to its recoverable amount. The recoverable amount is the higher of the investment’s fair
value less costs to sell or its value-in-use. If the recoverable amount is lower than the carrying value of the
subsidiary, an impairment loss is recognised equal to the excess of the carrying value over the recoverable
amount. If the recoverable amount is higher than the carrying value of the investment in subsidiary, that increase
is recognised by the Company as a reversal of the impairment loss recognised in prior periods as explained in
Note 2.3. Further details on the Company’s key estimates for the recoverable amount of the investment in
subsidiary are disclosed in Note 7.
4. Other income
2024 2023
000 000
Management consultancy services 1,000
1,170
Reimbursement of expenses and fees 6,957
11,983
7,957
13,153
The above transactions were carried out between the Company and its subsidiary, BOC PCL.
5. Administrative and other operating expenses
2024 2023
000 000
Directors’ fees (including employer’s contributions) (Note 17) 966
1,108
Insurance 1,051
1,357
Consultancy and other professional fees 3,804
2,142
Stock exchange fees 1,915
680
Audit fees and other assurance fees 846
260
Other expenses 1,148
153
9,730
5,700
The Company did not employ any staff during the years 2024 and 2023.
Consultancy and other professional fees with respect to directors of 24 thousand during the year ended 31
December 2024 (2023: 23 thousand) were carried out between the Company and its subsidiary, BOC PCL.
Section 322 of the Companies Act 2014 mandates disclosure of remuneration paid/payable to the Group Auditor
only (PricewaterhouseCoopers) for services relating to the audit of the Group and relevant subsidiary financial
statements. An amount of 37 thousand was paid to the Group Auditor for services relating to the audit of the
financial statements of the Company during the year to 31 December 2024 (2023: 37 thousand). No fees were
paid/payable to overseas auditors (2023: Nil).
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
571
6. Tax
The reconciliation between the income tax expense and the profit before tax as estimated using the current
income tax rates is set out below:
2024 2023
000 000
Profit before tax 962,318
632,606
Income tax at the normal tax rates in Cyprus 120,290
79,076
Income tax effect of:
- expenses not deductible for income tax purposes 1,174
687
- income not subject to income tax (118,198)
(76,346)
- other allowable deductions (3,266)
(3,417)
Other tax charges
-
42
-
42
Income tax in Cyprus is calculated at the rate of 12.5% on taxable income (2023: 12.5%).
On 22 December 2022, the European Commission approved Directive 2022/2523 which provides for a minimum
effective tax rate of 15% for the global activities of large multinational groups (Pillar Two tax). The Directive (EU)
2022/2523 that follows closely the OECD Inclusive Framework on Base Erosion and Profit Shifting was voted into
Law 151(Ι)/2024 (the 'Cyprus Pillar Two Law') in December 2024, effective for financial years starting from 31
December 2023. The Group is in scope of the Cyprus Pillar Two Law for the year ended 31 December 2024. The
Group is eligible for the transitional provision under Article 55 of the Cyprus Pillar Two Law which results in zeroing
any top-up tax liability in Cyprus computed in accordance with the rules laid out in the Cyprus Pillar Two Law for
the year ended 31 December 2024.
7. Investment in subsidiaries
2024 2023
000 000
1 January 2,173,000
1,599,002
Increase – share-based payment (Note 13) 932
595
Reversal of impairment of investment in subsidiary 801,068
573,405
Transfer of subsidiary* -
(2)
31 December 2,975,000
2,173,000
*In December 2022 the Company incorporated Jinius Ltd, a 100% subsidiary, which has been set up to provide
and administrate a digital economy platform. During the year ended 31 December 2023, the Company
transferred its 100% shareholding in Jinius Ltd to BOC PCL.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
572
7. Investment in subsidiaries (continued)
2024 2023
Company Activities
Percentage
holding %
000 000
Bank of Cyprus Public Company
Ltd
Commercial
bank
100 2,975,000
2,173,000
The investment in BOC PCL represents a 100% investment in the share capital of BOC PCL, a company registered
in Cyprus and its activities are presented in Note 1. Its registered office is at 51 Stasinos Street, 2002, Strovolos,
Nicosia, Cyprus.
During the year ended 31 December 2024 the Company received dividend income of 136,590 thousand (2023:
22,310 thousand) from its subsidiary BOC PCL.
As at 31 December 2024, the Company performed an assessment of the carrying value of the investment in BOC
PCL resulting in a full reversal of previously recognised impairment loss of 801,068 thousand (2023: partial
reversal of previously recognised impairment loss of 573,405 thousand).
The assessment involved the determination of the recoverable amount of the investment in subsidiary as the
higher of its fair value less costs to sell and the value-in-use (VIU). As at 31 December 2024, the VIU exceeded
the carrying value by 801,068 thousand. The increase in VIU was principally due to the impact from BOC PCL’s
actual performance, which was better than previous estimates and the revisions to management's best estimates
of BOC PCL’s future earnings in the short to medium term, as well as the discount rate used.
In future periods, the VIU may increase or decrease depending on the effect of changes to model inputs. The
main model inputs are described below and are based on factors observed at year-end. The factors that could
result in a change in the VIU and lead to an impairment include a short-term underperformance by BOC PCL, a
change in regulatory capital requirements or an increase in uncertainty regarding the macroeconomic conditions
and future performance of BOC PCL, resulting in a lower forecast of future asset growth or profitability. An
increase in the discount rate could also result in a reduction of VIU and an impairment.
To determine the VIU of the investment in subsidiary, the future cash flows to be derived from continuing use of
the asset were estimated with the use of a dividend discount model. For the assessment as at 31 December 2024,
projections until the end of 2028 were considered in line with the Group’s internal planning horizon. The key
assumptions and factors taken into consideration include:
- Forecasted net lending growth, forecasted net interest income and non-interest income which is based on
historical experience of the Group and key KPIs of the Group.
- Level of interest rates and yield curves.
- Impairment charge based on historical experience and forecasted general macroeconomic outlook. NPE
expected coverage ratio is also considered.
- Operating cost is impacted by inflationary pressures and the envisaged operating model.
- Deposits projections and issuances/redemptions based on the liquidity and funding needs of the Group, as
well as projected MREL requirement.
- Capital requirements: This was based on the current minimum regulatory requirements, incorporating known
changes such as the phasing-in of the O-SII buffer and incorporating an additional capital cushion over the
minimum capital requirements.
The assumptions are based on both internal and external information including the Group’s actual and historic
performance, the key objectives of the Group’s strategy as well as the macroeconomic environment in Cyprus.
From year 2028 onwards, a terminal growth rate has been assumed in the valuation. Growth rate is determined
by reference to long-term economic growth, taking into consideration both Cyprus GDP growth projections and
brokers’ consensus. A long-term growth rate of 2% (2023: 2%) was used and does not exceed the relevant long-
term average growth rate of the economy in which BOC PCL operates.
An appropriate discount rate has been applied which reflects the estimated cost of equity of 12.5% (2023: 13.5%)
determined on the basis of CAPM model and brokers’ consensus, which take into consideration various risks as
at 31 December 2024.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
573
7. Investment in subsidiaries (continued)
The impact of changes in the growth rate and the discount rate by reference to the carrying value of the
investment has been assessed by Management:
- An increase of 1% in the discount rate would result in a lower reversal of impairment by 256 million (2023:
174 million);
- A decrease of 1% in the discount rate would result in an increase in the VIU by 310 million, however as the
value of the investment has reverted to the initial cost as at 31 December 2024 there would be no impact on
the carrying amount (2023: an additional reversal of impairment by 208 million);
- An increase of 1% in the long-term growth rate would result in an increase in the VIU by 58 million, however
as the value of the investment has reverted to the initial cost as at 31 December 2024 there would be no
impact on the carrying amount (2023: an additional reversal of impairment by 14 million);
- A decrease of 1% in the long-term growth rate would result in a lower reversal of impairment by 49 million
(2023: 12 million).
8. Investments
Counterparty
2024 2023
000 000
Equity instruments at fair value through other
comprehensive income – 2023 issuance
BOC PCL 261,983
234,742
Debt instruments measured at amortised cost BOC PCL 303,582
302,615
565,565
537,357
Equity instruments
In June 2023, the Company successfully launched and priced an issue of 220,000 thousand Fixed Rate Reset
Perpetual Additional Tier 1 Capital Securities (the ‘Capital Securities') (Note 11). On the same date, the Company
and BOC PCL entered into an agreement pursuant to which the Company on-lent to BOC PCL the entire 220,000
thousand proceeds of the issue of the Capital Securities (the ‘AT1 Loan’) on terms substantially identical to the
terms and conditions of the AT1 issued by the Company. The AT1 Loan constitutes an unsecured and subordinated
obligation of BOC PCL. It carries an initial coupon of 11.875% per annum, payable semi-annually, and resettable
on 21 December 2028 and every five years thereafter. BOC PCL may elect to cancel any interest payment for an
unlimited period, on a non-cumulative basis, whereas it mandatorily cancels interest payment under certain
conditions. The AT1 Loan is perpetual and has no fixed date of redemption but can be redeemed (in whole but
not in part) at BOC PCL's option from, and including, 21 June 2028 to, and including, 21 December 2028 and on
each interest payment date thereafter.
The AT1 Loan has been classified as an equity instrument at fair value through other comprehensive income.
During the year ended 31 December 2024 an income of 26,125 thousand (2023: 27,339 thousand) has been
recognised in profit and loss in respect of these investments.
The fair value of equity instruments held by the Company is determined using models for which all inputs that
have a significant effect on fair value are market observable. Equity instruments are financial instruments whose
fair value is categorised as Level 2 instruments in fair value hierarchy.
There were no transfers in and out of Level 2 during 2024 and 2023.
During the year ended 31 December 2024 a gain of 27,241 thousand (2023: gain of 27,915 thousand) has
been recognised in other comprehensive income in respect of the fair value measurement of these investments.
Debt instruments
In April 2021, the Company issued 300,000 thousand unsecured and subordinated Tier 2 Capital Notes (the
‘Notes’) (Note 14) and immediately after, the Company and BOC PCL entered into an agreement pursuant to
which the Company on-lent to BOC PCL the entire 300,000 thousand proceeds of the issue of the Notes (the ‘T2
Loan’) on terms substantially identical to the terms and conditions of the Notes issued by the Company. The
interest is 6.625% per annum payable annually in arrear and resettable on 23 October 2026 at the then prevailing
5-year swap rate plus a margin of 6.902% per annum up to 23 October 2031, payable annually. The note matures
on 23 October 2031. BOC PCL has the option to redeem the T2 Loan early on any day during the six-month period
from 23 April 2026 to 23 October 2026.
The T2 Loan has been classified as a debt instrument measured at amortised cost.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
574
8. Investments (continued)
During the year ended 31 December 2024 an income of 19,875 thousand (2023: income 19,875 thousand)
has been recognised in profit and loss in respect of this instrument.
As at 31 December 2024 the T2 Loan is classified as Stage 1 with corresponding ECL of 229 thousand (2023:
ECL balance of 1,197 thousand). During the year ended 31 December 2024, an amount of 968 thousand that
relates to partial reversal of 12-months ECL has been recognised in the Company’s statement of comprehensive
income (2023: credit of 3,073 thousand).
9. Bank balances
Bank balances include the following for the purpose of the statement of cash flows:
2024 2023
000 000
Cash at bank
9,572
1,965
Bank overdraft 2,774
1,339
Both the cash at bank and the bank overdraft of the Company are held with its subsidiary BOC PCL.
10. Receivables from related parties
2024 2023
000 000
Current assets
Receivables from related parties - BOC PCL 2,261
843
The receivables from related parties as at 31 December 2024 and 2023 related to income outstanding from
management consultancy services and reimbursement of expenses.
The above balances represent the maximum exposure to credit risk at the balance sheet date.
11. Share capital
2024 2023
Number of
shares
(thousand)
000
Number of
shares
(thousand)
000
Authorised
Ordinary shares of 0.10 each 10,000,000
1,000,000
10,000,000
1,000,000
Issued and fully paid
1 January 446,200
44,620
446,200
44,620
Share buyback
repurchase
and
cancellation of shares
(5,698)
(570)
-
-
31 December 440,502
44,050
446,200
44,620
The Company did not provide financial assistance permitted by section 82 of the Companies Act 2014 of Ireland
for the purchase of its shares.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
575
11. Share capital (continued)
Authorised and issued share capital
All issued ordinary shares are fully paid and carry the same rights.
The authorised capital of the Company is 1,000,000 thousand divided into 10,000,000 thousand ordinary shares
of a nominal value 0.10 each. There were no changes to the authorised share capital during the years ended 31
December 2024 and 2023.
As of 31 December 2024, the Company had 440,502 thousand issued shares (2023: 446,200 thousand issued
shares) of a nominal value of 0.10 each. During the year ended 31 December 2024, the number of shares issued
decreased by 5,698 thousand shares and the value of the issued share capital decreased by 570 thousand, as
shares were repurchased and cancelled under the share repurchase programme. As a result, an equivalent
amount of 570 thousand has been transferred to the Company's capital redemption reserve by 31 December
2024.
Share premium reserve
There were no changes to the share premium reserve during the years ended 31 December 2024 and 2023.
Share repurchase programme (Buyback)
In April 2024, the Company launched its inaugural programme to buy back ordinary shares of the Company for
an aggregate consideration of up to 25 million (the ‘Programme’). The purpose of the Programme was to reduce
the Company’s issued share capital and therefore the shares purchased under the Programme were cancelled.
On 29 November 2024, the Programme has been completed. 5,698 thousand shares were repurchased and
cancelled under the Programme at a total consideration (including transaction costs) of 25,090 thousand.
Capital redemption reserve
The capital redemption reserve is a legal reserve arising as a result of the acquisition and cancellation of the
Company’s ordinary shares under a buyback programme and represents transfers from share capital. The capital
redemption reserve is not distributable. As at 31 December 2024, the capital redemption reserve amounted to
570 thousand representing 5,698 thousand shares in the Company which have been cancelled as a result of the
buyback programme.
Treasury shares of the Company
The consideration paid, including any directly attributable incremental costs (net of income taxes), for shares of
the Company held by the Company is deducted from equity attributable to the owners of the Company as treasury
shares, until these shares are cancelled or reissued. No gain or loss is recognised in the income statement on the
purchase, sale, issue or cancellation of such shares.
Other equity instruments
2024 2023
000 000
2023 Reset Perpetual Additional Tier 1 Capital Securities 220,000
220,000
220,000
220,000
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
576
11. Share capital (continued)
Other equity instruments (continued)
In June 2023, the Company issued 220,000 thousand Fixed Rate Reset Perpetual Additional Tier 1 Capital
Securities (the 'Capital Securities'). The Capital Securities constitute unsecured and subordinated obligations of
the Company, are perpetual and are issued at par. They carry an initial coupon of 11.875% per annum, payable
semi-annually, and resettable on 21 December 2028 and every five years thereafter. The Company may elect to
cancel any interest payment for an unlimited period, on a non-cumulative basis, whereas it mandatorily cancels
interest payment under certain conditions. The Capital Securities are perpetual and have no fixed date of
redemption, but can be redeemed (in whole but not in part) at the Company's option from, and including, 21
June 2028 to, and including, 21 December 2028 and on each interest payment date thereafter, subject to
applicable regulatory consents and the relevant conditions to redemption. The Capital Securities are listed on the
Luxembourg Stock Exchange's Euro Multilateral Trading Facility (MTF) market.
Transaction costs of 3,530 thousand in relation to the issuance of the Capital Securities were recorded directly
in equity during the year ended 31 December 2023.
In addition, in June 2023 the Company invited the holders of its outstanding 220,000 thousand 2018 Reset
Perpetual Additional Tier 1 Capital Securities (the ‘2018 Capital Securities’) to tender for cash purchase by the
Company at a price equal to 103% of the principal amount. As a result of the tender offer, 204,483 thousand
in aggregate nominal amount were purchased and cancelled by the Company as at 30 June 2023. In July 2023,
the Company purchased in the open market approximately 7,000 thousand of the outstanding nominal amount
of such capital securities. In November 2023, the Board of Directors resolved to exercise the Company’s option
to redeem the remaining nominal amount outstanding of the 2018 Capital Securities in December 2023. As a
result of the buy-back, a total cost of 6,820 thousand was recorded directly in equity during the year ended 31
December 2023.
During the year ended 31 December 2024, coupon payments for the total amount of 26,125 thousand (2023:
27,339 thousand) were made to the holders of the AT1 instrument and have been recognised in retained
earnings.
12. Retained earnings
For the purpose of dividend distribution, retained earnings determined at Company level, are the only
distributable reserve.
Companies, tax resident in Cyprus, which do not distribute at least 70% of their profits after tax as defined by
the Special Defence Contribution Law during the two years after the end of the year of assessment to which the
profits refer, will be deemed to have distributed this amount as dividend. Special defence contribution (SDC) at
17% is payable on such deemed dividend distribution to the extent that the shareholders of the Company at the
end of the period of two years from the end of the year of assessment to which the profits refer, are directly or
indirectly Cyprus tax residents or individuals who are domiciled in Cyprus. Deemed dividend distribution does not
apply in respect of profits that are directly or indirectly attributable to shareholders that are non-Cyprus tax
residents and individual shareholders who are not domiciled in Cyprus. The deemed dividend distribution is
subject to 2.65% contribution to the General Health System (GHS).
The amount of this deemed dividend distribution is reduced by any actual dividend paid out of the profits of the
relevant year.
This SDC and GHS are paid by the Company on account of the shareholders. During the year ended 31 December
2024, no SDC and GHS on deemed dividend distribution were accrued by the Company (2023: 42 thousand was
accrued by the Company).
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
577
13. Other reserves
Share-based benefits - cost
At the Annual General Meeting of the shareholders of the Company which took place on 20 May 2022, a special
resolution was approved for the establishment and implementation of the share-based Long-Term Incentive Plan
of the Company (the ‘LTIP’).
The LTIP is an equity-settled share-based compensation plan for executive directors and senior management of
the Group. The LTIP provides for an award in the form of ordinary shares of the Company based on certain non-
market performance and service vesting conditions. Performance will be measured over a three-year period. The
performance conditions are set by the Human Resources & Remuneration Committee (HRRC) each year and may
be differentiated at the HRRC's discretion to reflect the Group's strategic targets and employees' personal
performance. Performance will be assessed against an evaluation scorecard consistent with the Group’s Medium
Term Strategic Targets containing both financial and non-financial objectives and including targets in the areas
of: (i) Profitability; (ii) Asset quality; (iii) Capital adequacy; (iv) Risk control & compliance; (v) Environmental,
Social and Governance ('ESG'); and (iv) Customer Experience (targets in the area of customer experience have
been introduced for non-control functions from 2024). The awards ordinarily vest in six tranches, with 40%
vesting in the year following the year the performance period ends and the remaining 60% vesting in tranches
(12%), on each of the first, second, third, fourth and fifth anniversary of the first vesting date. For any award to
vest the employee must be in the employment of the Group up until the date of the vesting of such an award.
Awards are subject to potential forfeiture under certain leaver scenarios. Under certain circumstances the HRRC
has the discretion to determine whether the award will lapse and/or the extent to which the award will be vested.
Under the LTIP the following share awards were outstanding as of 31 December 2024:
i. On 3 April 2024 (grant date) a maximum of 403,990 share awards were granted by the Company to 21
eligible employees, comprising the Extended Executive Committee of the Group. The awards granted in
April 2024 are subject to a three-year performance period 2024-2026 (with all performance conditions
being non-market performance conditions).
ii. On 3 October 2023 (grant date) a maximum of 479,160 share awards were granted by the Company to
21 eligible employees, comprising the Extended Executive Committee of the Group. The awards granted
in October 2023 are subject to a three-year performance period 2023-2025 (with all performance
conditions being non-market performance conditions).
iii. On 22 December 2022 (grant date) a maximum of 819,860 share awards were granted by the Company
to 22 eligible employees comprising the Extended Executive Committee of the Group. The awards granted
in December 2022 were subject to a three-year performance period 2022-2024 (with all performance
conditions being non-market performance conditions). The amounts awarded under this 2022 LTIP cycle
in early 2025 are disclosed in Note 49 of the consolidated financial statements of the Company for the
year ended 31 December 2024.
As the award relates to services received by subsidiary entities of the Company and will be settled in shares of
the Company, it qualifies as an equity-settled transaction and hence the cost of the award relating to the financial
year has been recognised as an addition to the cost of the investment of the subsidiary BOC PCL and the
respective credit in the Statement of Changes in Equity at an amount of 932 thousand for the year ended 31
December 2024 (2023: 595 thousand).
Further details are provided in Note 14.2 of the consolidated financial statements of the Company for the year
ended 31 December 2024.
14. Subordinated liabilities
Contractual
interest rate
2024 2023
000 000 000 000
Nominal
value
Carrying
value
Nominal
value
Carrying
value
Subordinated Tier 2
Capital Note – April 2021
6.625% up to
23 October
2026
300,000
302,995
300,000
302,550
300,000
302,995
300,000
302,550
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
578
14. Subordinated liabilities (continued)
Subordinated Tier 2 Capital Note - April 2021
In April 2021, the Company issued a 300 million unsecured and subordinated Tier 2 Capital Note under the
EMTN Programme. The note was priced at par with a coupon of 6.625% per annum payable annually in arrear
and resettable on 23 October 2026 at the then prevailing 5-year swap rate plus a margin of 6.902% per annum
up to 23 October 2031, payable annually. The Note matures on 23 October 2031. The Company has the option
to redeem the note early on any day during the six-month period from 23 April 2026 to 23 October 2026, subject
to applicable regulatory consents. The Note is listed on the Luxembourg Stock Exchange’s Euro MTF market.
During the year ended 31 December 2024 an amount of 20,320 thousand has been recognised as interest
expense on these subordinated liabilities (2023: 20,318 thousand).
15. Other payables
2024 2023
000 000
Accruals 3,565
1,329
VAT payable 8
34
Corporation tax payable 311
359
Dividends payable 9,572
1,965
13,456
3,687
Dividends payable of 9,572 thousand as at 31 December 2024 relate to dividends declared in May 2024 and
May 2023 (Note 18) out of Group profits for the years ended 31 December 2023 and 2022 respectively and are
outstanding as at 31 December 2024 (2023: 1,965 thousand that relate to dividends declared in May 2023 out
of Group profits for the year ended 31 December 2022).
Other payables are due within 12 months from the balance sheet date.
16. Fair value measurement
The fair value of the financial assets and financial liabilities approximates their carrying value as at 31 December
2024 and 2023, except for the investments in debt instruments measured at amortised cost (Note 8) and the
subordinated liabilities (Note 14), whose fair value is disclosed below:
202
4
202
3
Fair value
measurement
hierarchy
Carrying
value
Fair
value
Fair value
measurement
hierarchy
Carrying
value
Fair
value
000 000
000 000
Financial assets
Debt instruments
measured at amortised
cost (Note 8)
Level 2 303,582
312,318
Level 2 302,615
296,762
Financial liabilities
Subordinated liabilities
(Note 14)
Level 1 302,995
314,195
Level 1 302,550
300,098
The fair value of the debt instruments measured at amortised cost has been classified as Level 2 in the fair value
hierarchy because it has been estimated using market observable inputs of financial instruments with similar
characteristics.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
579
17. Related party transactions
Related parties of the Company include its subsidiary company, BOC PCL, the subsidiary companies, associates
and joint ventures of BOC PCL, members of the Board of Directors and their connected persons. Connected
persons for the purpose of this disclosure include spouses, minor/dependent children and companies in which the
directors, hold directly or indirectly, at least 50% of the voting shares in a general meeting, or act as executive
director or exercise control of the entities in any way.
(i) Transactions with subsidiary company
The Company enters into transactions with its subsidiary company, BOC PCL, in the normal course of business.
Balances and transactions between the Company and its subsidiary are disclosed in Notes 4, 5, 7, 8, 9 and 10 of
these financial statements.
(ii) Directors’ remuneration
The Directors’ fees amount to 942 thousand (2023: 1,077 thousand). In addition, employer’s contributions of
24 thousand have been recorded in the Income Statement during the year ended 31 December 2024
(2023: 31 thousand). Such amounts are not considered part of the remuneration of Directors, but rather an
incremental cost to the Group, and as such have not been included in the table below. Both directors’ fees and
employer’s contributions were reimbursed by BOC PCL and included in other income in Note 4 above.
Fees are included for the period that Directors serve as members of the Board of Directors.
Non-executive Directors
The fees of non-executive Directors are analysed as follows:
2024 2023
000 000
Efstratios-Georgios Arapoglou 261
250
Lyn Grobler 165
155
Constantine Iordanou (passed away on 16 June 2024) 81
148
Monique Eugenie Hemerijck
(approved by ECB on 10 August 2023) 152
38
Adrian John Lewis
(approved by ECB on 17 November 2023) 159
8
Christian Philipp Hansmeyer (approved by ECB on 29 April 2024) 62
-
William Stuart Birrell (approved by ECB on 29 April 2024) 62
-
Arne Berggren (resigned on 31 March 2023) -
30
Ioannis Zographakis (resigned on 31 December 2023) -
113
Nicolaos Sofianos (resigned on 11 December 2023) -
117
Paula Hadjisotiriou (resigned on 31 December 2023) -
141
Maria Philippou
(resigned on 13 October 2023) -
77
942
1,077
The fees of the non-executive Directors include fees as members of the Board of Directors of the Company, as
well as of members of the committees of the Board of Directors.
There were no other significant transactions with related parties of the Company and no information to be
disclosed under section 307 of the Companies Act 2014 of Ireland for the years 2024 and 2023.
18. Distributions
Based on the relevant SREP decisions applicable for years 2023 and 2024, any equity dividend distribution was
subject to regulatory approval for the Company. The requirement for approval did not apply if the distributions
were made via the issuance of new ordinary shares to the shareholders which were eligible as Common Equity
Tier 1 Capital nor to the payment of coupons on any AT1 capital instruments issued by the Company. Following
the SREP Decision received in December 2024, the requirement for prior regulatory approval for the declaration
of dividends has been lifted, effective from 1 January 2025.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
580
18. Distributions (continued)
Distribution in respect of 2024 earnings
In February 2025, the Company announced its
proposal to make a total distribution of 241 million in respect of
2024 earnings, comprising an aggregate cash dividend of 211 million
(by reference to the number of shares in
issue as at 31 December 2024)
and a share buyback in an aggregate consideration amount of up to 30 million
(together, the ‘2024 Distribution’).
Cash dividend
The Board of Directors of the Company has resolved to propose to the AGM that will be held on 16 May 2025 for
approval, a final cash dividend of 0.48 per ordinary share in respect of earnings for the year ended 31 December
2024. The financial statements f
or the year ended 31 December 2024 do not reflect this dividend, which will be
accounted for in shareholders’ equity as an appropriation of retained earnings in the year ending 31 December
2025.
Share Buyback Programme
Following approval by the Board of Directors, on 24 February 2025 the Company launched a programme to buy
back ordinary shares of
the Company for an aggregate consideration of up to 30 million, for which approval by
the ECB has been received. The shares will be repurchased on the Main Market of the Regulated Securities Market
of the ATHEX and the CSE and will be cancelled. The fina
ncial statements for the year ended 31 December 2024
do not reflect the impact of the share buyback programme, which will be ac
counted for as and when the shares
are repurchased by the Company.
Distribution in respect of 2023 earnings
In March 2024, the Company obtained the approval of the European Central Bank to pay a cash
dividend and to
conduct a share buyback (together the ‘2023
Distribution’) in respect of earnings for the year ended 31 December
2023. The 2023
Distribution amounted to 137 million in total, comprising a cash dividend of 112 million and a
share buyback of up to 25 million (Note 11-
Share repurchase programme (Buyback)). The AGM, on 17 May
2024, approved a final cash dividend of 0.25 per ordinary share in respect of earnings for the year ended 31
December 2023.
Distribution in respect of 2022 earnings
In April 2023, the Company obtained the approval of the European Central Bank to pay a dividend in respect of
earnings for the year ended 31 December 2022. The AGM, on 26 May 2023, approved a final cash dividend of
0.05 per ordinary share in respect of earnings for the year ended 31 December 2022. The dividend amounted
to 22,310 thousand in total.
19. Financial risk management
The Company is exposed to risks the most significant of which are liquidity risk and market risk.
19.1 Liquidity risk
Liquidity risk refers to probable losses that the Company may face, in case of repayment difficulties to its cash
flow obligations. The Company does not consider the liquidity risk as significant, since the level of operational
costs is low.
19.2 Market risk
Market risk is the risk of loss from adverse changes in market prices. The Market and Liquidity Risk department
is responsible for monitoring the risk resulting from such changes with the objective to minimise the impact on
earnings and capital. The department also monitors liquidity risk and credit risk with counterparties and countries.
It is also responsible for monitoring compliance with the various market and liquidity risk policies and procedures.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Notes to the Company Financial Statements
581
19. Financial risk management (continued)
19.2 Market risk (continued)
Price risk
Equity securities price risk
The risk of loss from changes in the price of equity securities arises when there is an unfavourable change in the
prices of equity securities held by the Company as investments.
Investments in equities issued by external parties are outside the Company’s risk appetite.
Changes in the prices of equity securities that are classified as FVOCI affect the equity of the Company.
The table below shows the impact on the equity of the Company from a change in the price of the equity
instruments held, as a result of reasonably possible changes on the price of the underlying assets for the year
ended 31 December 2024. The relevant asset price change is based on a Monte Carlo value-at-risk (VaR) analysis.
2024
Change in
asset price
Impact on equity
% 000
Other stock exchanges and unlisted +7.0 19,192
Other stock exchanges and unlisted -7.0 (19,192)
2023
Other stock exchanges and unlisted +5.0 11,737
Other stock exchanges and unlisted -5.0 (11,737)
20. Capital management
The capital management of the Company is consistent with the capital management of the Group as presented
in Note 48 of the consolidated financial statements of the Company for the year ended 31 December 2024.
21. Events after the reporting date
There were no material events which occurred after the reporting date other than as disclosed in Note 18 of the
financial statements of the Company and in Note 54 of the consolidated financial statements of the Company for
the year ended 31 December 2024 with respect to the 2024 Distribution.
Alternative Performance Measures Disclosures
2024
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
583
DEFINITIONS
Adjusted recurring
profitability
The Group’s profit after tax before non
-
recurring items (attributable to the
owners of the Company) taking into account distributions under other equity
instruments such as the annual AT1 coupon.
Advisory and other
transformation costs -
organic
Comprise mainly of fees of external advisors in relation to the transformation
program and other strategic projects of the Group.
Allowance for
expected loan credit
losses
Comprises (i) allowance for expected credit losses (ECL) on loans and advances
to customers (including allowance for expected credit losses on loans and
advances to customers held for sale, where applicable), (ii) the residual fair value
adjustment on initial recognition of loans and advances to customers (including
residual fair value adjustment on initial recognition of loans and advances to
customers classified as held for sale, where applicable), (iii) allowance for
expected credit losses on off-balance sheet exposures (financial guarantees and
commitments) disclosed on the balance sheet within other liabilities, and (iv) the
aggregate fair value adjustment on loans and advances to customers classified
and measured at FVPL.
Basic
profit
per share
(attributable to the
owners of the
Company)
Basic
profit
per share (attributable to the owners of the Company) is the
Profit/(loss) after tax (attributable to the owners of the Company) divided by the
weighted average number of ordinary shares in issue during the period/year,
excluding treasury shares. The term ‘Basic earnings per share (attributable to
the owners of the Company)’ is used interchangeably with this term in the
Annual Financial Report.
Carbon neutral
The reduction and
balancing (through a combination of offsetting investments
or emission credits) of greenhouse gas emissions from own operations.
Cost to Income ratio
Cost
to
income ratio is calculated as total expenses (as defined), divided by total
income (as defined).
Digital transactions
ratio
This is the ratio of the number of digital transactions performed by individuals
and legal entity customers to the total number of transactions. Transactions
include deposits, cash withdrawals, internal and external transfers. Digital
channels include mobile banking app, browser and ATMs.
Digitally engaged
customers ratio
This is the ratio of digitally engaged individual customers to the total number of
individual customers. Digitally engaged customers are the individuals who use
the digital channels of the Bank (mobile banking app, browser and ATMs) to
perform banking transactions, as well as digital enablers such as a bank-issued
card to perform online card purchases, based on an internally developed
scorecard.
Diluted earnings per
share (attributable to
the owners of the
Company)
Diluted earnings per share is
the
Profit/(loss) after tax (attributable to the
owners of the Company) divided by the weighted average number of ordinary
shares in issue during the period/year, excluding treasury shares, adjusted to
take into account the potential dilutive effect for the ordinary shares that may
arise in respect of share awards granted to executive directors and senior
management of the Group under the Long-Term Incentive Plan and Short-Term
Incentive Plan, where applicable. The term ‘Diluted profit per share (attributable
to the owners of the Company)’ is used interchangeably with this term in the
Annual Financial Report.
Green Asset ratio
The proportion of a credit institution’s assets financing and invested in EU
Taxonomy-aligned economic activities as a share of total covered assets.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
584
Green Mortgage ratio
The proportion of a credit institution’s assets financing EU
Taxonomy
-
aligned
mortgages (acquisition, construction or renovation of buildings) as a share of
total mortgage assets.
Gross loans
Gross loans comprise: (i) gross loans and advances to customers measured at
amortised cost before the residual fair value adjustment on initial recognition
(including loans and advances to customers classified as non-current assets held
for sale, where applicable) and (ii) loans and advances to customers classified and
measured at FVPL adjusted for the aggregate fair value adjustment.
The residual fair value adjustment on initial recognition relates mainly to loans
acquired from Laiki Bank (calculated as the difference between the outstanding
contractual amount and the fair value of loans acquired at acquisition date).
Interest earning
assets
Interest earning assets include: cash and balances with central banks, loans and
advances to banks, reverse repurchase agreements, net loans and advances to
customers (as defined), net loans and advances to customers classified as non-
current assets held for sale (where applicable), deferred consideration receivable
(‘DPP’), and investments (excluding equities, mutual funds and other non-interest
bearing investments).
Legacy exposures
Legacy exposures
are exposures relating to (i) Restructuring and Recoveries
Division (RRD), (ii) Real Estate Management Unit (REMU), and (iii) Non-core
overseas exposures.
Leverage ratio
The leverage ratio is the ratio of tangible total equity to total assets as
presented
on the balance sheet. Tangible total equity comprises of equity attributable to the
owners of the Company and other equity instruments minus intangible assets.
Loan credit losses
(PL)
Loan credit losses comprise: (i) credit losses to cover credit risk on loans and
advances to customers (including credit losses on loans and advances to
customers classified as non-current assets held for sale, where applicable), (ii)
net gains/(losses) on derecognition of financial assets measured at amortised cost
relating to loans and advances to customers and (iii) net gains/(losses) on loans
and advances to customers at FVPL, for the reporting period/year.
Loan credit losses
charge (cost of risk)
Loan credit losses charge (cost of risk) (year
-
to
-
date) is calculated as the loan
credit losses (as defined) (annualised based on year-to-date days) divided by the
average gross loans. The average gross loans are calculated as the average of the
opening balance and the closing balance of Gross loans (as defined), for the
reporting period/year.
Market Shares
Both deposit and loan market shares are based on data from the CBC.
Net Interest Margin
Net interest margin is calculated as the net
interest income (
annuali
s
ed
based on
year-to-date days) divided by the quarterly average interest earning assets (as
defined).
Net loans and
advances to
customers
Net loans and advances to customers comprise gross loans (as defined) net of
allowance for expected loan credit losses (as defined, but excluding allowance
for expected credit losses on off-balance sheet exposures disclosed on the
balance sheet within other liabilities).
Net loans to
deposits ratio
Net loans to deposits
ratio is calculated as gross loans (as defined) net of
allowance for expected loan credit losses (as defined), divided by customer
deposits.
Net performing loan
book
Net performing loan book is the total net loans and advances to customers (as
defined) excluding net loans included in the legacy exposures (as defined).
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
585
Net zero emissions
The reduction of greenhouse gas emissions to net zero through a combination of
reduction activities and offsetting investments.
New lending
New lending includes the disbursed amounts of the new and existing non
-
revolving facilities (excluding forborne or re-negotiated accounts) as well as the
average year-to-date change (if positive) of the current accounts and overdraft
facilities between the balance at the beginning of the period and the end of the
period. Recoveries are excluded from this calculation since their overdraft
movement relates mostly to accrued interest and not to new lending.
Non
-
interest income
Non
-
interest income comprises: Net fee and commission income, Net foreign
exchange gains/(losses) and net gains/(losses) on financial instruments
(excluding net gains/(losses) on loans and advances to customers at FVPL), Net
insurance result, Net gains/(losses) from revaluation and disposal of investment
properties and on disposal of stock of properties, and Other income.
Non
-
performing
exposures (NPEs)
As per the EBA standards and the ECB’s Guidance to Banks on Non
-
Performing
Loans (which was published in March 2017), NPEs are defined as those exposures
that satisfy one of the following conditions:
(i) The borrower is assessed as unlikely to pay its credit obligations in full
without the realisation of the collateral, regardless of the existence of
any past due amount or of the number of days past due.
(ii) Defaulted or impaired exposures as per the approach provided in the
Capital Requirement Regulation (CRR), which would also trigger a
default under specific credit adjustment, diminished financial obligation
and obligor bankruptcy.
(iii) Material exposures as set by the CBC, which are more than 90 days
past due.
(iv) Performing forborne exposures under probation for which additional
forbearance measures are extended.
(v) Performing forborne exposures previously classified as NPEs that
present more than 30 days past due within the probation period.
From 1 January 2021 two regulatory guidelines came into force that affect NPE
classification and Days-Past-Due calculation. More specifically, these are the RTS
on the Materiality Threshold of Credit Obligations Past-Due (EBA/RTS/2016/06)
and the Guideline on the Application of the Definition of Default under article 178
(EBA/RTS/2016/07).
The Days-Past-Due (DPD) counter begins counting DPD as soon as the arrears
or excesses of an exposure reach the materiality threshold (rather than as of the
first day of presenting any amount of arrears or excesses). Similarly, the counter
will be set to zero when the arrears or excesses drop below the materiality
threshold. Payments towards the exposure that do not reduce the
arrears/excesses below the materiality threshold, will not impact the counter.
For retail debtors, when a specific part of the exposures of a customer that fulfils
the NPE criteria set out above is greater than 20% of the gross carrying amount
of all on balance sheet exposures of that customer, then the total customer
exposure is classified as non-performing; otherwise only the specific part of the
exposure is classified as non-performing. For non-retail debtors, when an
exposure fulfils the NPE criteria set out above, then the total customer exposure
is classified as non-performing.
Material arrears/excesses are defined as follows:
- Retail exposures: Total arrears/excess amount greater than 100,
- Exposures other than retail: Total arrears/excess amount greater than
500
and the amount in arrears/excess is at least 1% of the customer’s total exposure.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
586
The NPEs are reported before the deduction of allowance for expected loan credit
losses (as defined).
Non
-
recurring
items
Non
-
recurring
items as presented in the ‘Consolidated Income Statement
Underlying basis’ relate to ‘Advisory and other transformation costs - organic’, if
applicable.
NPE coverage ratio
The NPE coverage ratio is
calculated as the allowance for expected loan credit
losses (as defined) over NPEs (as defined).
NPE ratio
NPE ratio is calculated as the NPEs (as defined) divided by Gross loans (as
defined).
Operating profit
Operating profit on the underlying basis comprises profit before loan credit losses
(as defined), impairments of other financial and non-financial assets, provisions
for pending litigation, claims, regulatory and other matters (net of reversals),
tax, (profit)/loss attributable to non-controlling interests and non-recurring
items (as defined).
Operating profit
return on average
assets
Operating
profit return on average assets is calculated as the operating profit
(as defined) (annualised based on year-to-date days) divided by the quarterly
average of total assets for the relevant period. Average total assets exclude
total assets of discontinued operations at each quarter end, if applicable.
Profit
/(loss)
after tax
and before non-
recurring items
(attributable to the
owners of the
Company)
Profit/(loss) after tax and before non
-
recurring items (attributable to the owners
of the Company) is the operating profit (as defined) adjusted for loan credit
losses (as defined), impairments of other financial and non-financial assets,
provisions for litigation, claims, regulatory and other matters (net of reversals),
tax and (profit)/loss attributable to non-controlling interests.
Profit/(loss) after tax
– organic
(attributable to the
owners of the
Company)
Profit/(loss) after tax
-
organic (attributable to the owners of the Company) is
the profit/(loss) after tax and before non-recurring items (attributable to the
owners of the Company) (as defined), adjusted for the ‘Advisory and other
transformation costs – organic’, if applicable.
Return on Tangible
equity (ROTE)
Return on Tangible Equity (ROTE) is calculated as Profit/(loss) after tax
(attributable to the owners of the Company) (annualised based on year-to-date
days), divided by the quarterly average of Shareholders’ equity (as defined)
minus intangible assets at each quarter end.
Return on Tangible
equity (ROTE)
excluding amounts
reserved for
distributions
Return on Tangible equity (ROTE) excluding amounts reserved for distributions
is calculated as Profit/(loss) after tax (attributable to the owners of the
Company) (as defined) (annualised based on year-to-date days), divided by the
quarterly average of Shareholders’ equity (as defined) minus intangible assets
and the amounts approved/recommended for distribution in respect of earnings
of the relevant year the distribution relates to.
Return on Tangible
equity (ROTE) on
15% CET1 ratio
Return on Tangible equity (ROTE)
on 15% CET1 ratio is calculated as
Profit/(loss) after tax (attributable to the owners of the Company) (annualised
based on year-to-date days), divided by the quarterly average of Shareholders’
equity (as defined) minus intangible assets and after deducting the excess CET1
capital on a 15% CET1 ratio from the tangible book value at each quarter end.
Shareholders’ equity
Shareholders’ equity comprise
s
total equity adjusted for non
-
controlling interest
and other equity instruments. It is represented by equity attributable to the
owners of the Company (as per statutory basis).
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
587
Tangible book value
per share
Tangible book
value per share is calculated as Shareholders’ equity
(
as defined
)
less intangible assets at each quarter end, divided by the number of ordinary
shares in issue at the end of the period/year, excluding treasury shares.
Tangible equity
Tangible equity comprises of equity attributable to the owners of the
C
ompany
(as per statutory basis) and other equity instruments minus intangible assets.
Time deposits
pass-through
Calculated as a percentage of the cost (interest expense) of Time and Notice
deposits over the average 6-month Euribor rate for the period.
Total expenses
Total expenses on the underlying basis comprise
the total staff costs, special
levy on deposits and other levies/contributions and other operating expenses
(excluding ‘Advisory and other transformation costs-organic’, (on an underlying
basis)).
Total income
Total income on the underlying basis comprises the total of
N
et interest income,
Net fee and commission income, Net foreign exchange gains/(losses), Net
gains/(losses) on financial instruments (excluding net gains/(losses) on loans and
advances to customers at FVPL), Net insurance result, Net gains/(losses) from
revaluation and disposal of investment properties and on disposal of stock of
property and Other income (on an underlying basis). A reconciliation of these
amounts between the statutory and the underlying basis is disclosed in the
Directors’ Report under section ‘Group financial results on the underlying basis’.
Underlying basis
The underlying basis is computed by adjusting the results as per the statutory
basis for the reclassification of certain items as explained in the ‘Reconciliation
of the Consolidated Income Statement for the year ended 31 December 2024
between the statutory basis and the underlying basis’ within the Directors’
Report.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
588
Reconciliations
Reconciliation between the Consolidated Income Statement under the statutory basis and the underlying
basis in the Directors’ Report is included in Section ‘Reconciliation of the Consolidated Income Statement
for the year ended 31 December 2024 between the statutory basis and the underlying basis’ of the Directors’
Report.
Reconciliations between the non-IFRS performance measures and the most directly comparable IFRS
measures which allow for the comparability of the underlying basis to the statutory basis are disclosed
below.
For the purpose of the ‘Alternative Performance Measures Disclosures’, reference to ‘Note’ relates to the
respective note in the Consolidated Financial Statements for the year ended 31 December 2024.
1. Reconciliation of Gross loans and advances to customers
2024 2023
000 000
Gross loans and
advances to customers as per the underlying basis (
as
defined above)
10,374,056
10,069,828
Reconciling items:
Residual fair value adjustment on initial recognition (Note 23) (60,679)
(69,534)
Loans and advances to customers classified as held for sale (Note 23) (54,921)
-
Residual fair value adjustment on initial recognition on loans and
advances to customers classified as held for sale
778
-
Loans and advances to customers measured at FVPL (Note 23) (131,008)
(138,727)
Aggregate fair
value adjustment on loans and advances to customers
measured at FVPL
2,179
947
Gross loans and advances to customers at amortised cost as per
the Consolidated Financial Statements (Note 23)
10,130,405
9,862,514
2. Reconciliation of Allowance for expected credit losses (ECL) on loans and advances to
customers
2024 2023
000 000
Allowance for expected credit losses
(ECL)
on loans and advances to
customers as per the underlying basis (as defined above)
254,412
267,232
Reconciling items:
Residual fair value adjustment on initial recognition (Note 23) (60,679)
(69,534)
Allowance for expected credit losses on loans and advances to
customers classified as held for sale
(31,778)
-
Residual fair value adjustment on initial recognition on loans and
advances to customers classified as held for sale
778
-
Aggregate fair value adjustment on loans and advances to customers
measured at FVPL
2,179
947
Provisions for financial guarantees and commitments (Note 33) (17,893)
(19,192)
Allowance for ECL
for
loans and advances to customers as per
the Consolidated Financial Statements (Note 23)
147,019
179,453
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
589
Reconciliations (continued)
3. Reconciliation of NPEs
2024 2023
000 000
NPEs as per the underlying basis (as defined above) 255,251
365,450
Reconciling items:
Loans and advances to customers (NPEs) classified as held for sale (
as
per table 1 above)
(54,921)
-
Residual fair value adjustment on initial
recognition of loans and
advances to customers (NPEs) classified as held for sale (as per table 1
above)
778
-
POCI (NPEs) (Note 1 below) (31,919)
(37,273)
Residual fair value adjustment on initial recognition on loans and
advances to customers (NPEs) classified as Stage 3 (Note 23)
1,579
(1,294)
Stage 3 gross loans and advances to customers at amortised
cost as per the Consolidated Financial Statements (Note 23)
170,768
326,883
NPE ratio 2024 2023
NPEs (as per table above) (000) 255,251
365,450
Gross loans and advances to customers (as per table 1 above) (000) 10,374,056
10,069,828
Ratio of NPEs/Gross loans (%) 2.5%
3.6%
NPE Coverage ratio 2024 2023
Allowance for expected credit losses
(ECL)
on loans and advances to
customers (as per table 2 above) (000)
254,412
267,232
NPEs (as per table above) (000) 255,251
365,450
NPE Coverage ratio (%) 100%
73%
Note 1: Gross loans and advances to customers at amortised cost before residual fair value adjustment on
initial recognition include an amount of 31,919 thousand POCI - NPEs (out of a total of 59,810 thousand
POCI loans) (2023: 37,273 thousand POCI - NPEs (out of a total of 100,197 thousand POCI loans)) as
disclosed in Note 23.
4. Reconciliation of Gross Loans – Pro forma
2024
000
Gross Loans (as per table 1 above) 10,374,056
Reconciling items:
Loans and advances to customers classified as held for sale (as per table 1 above) (54,921)
Residual fair value adjustment on initial recognition on loans and advances to
customers classified as held for sale (as per table 1 above)
778
Gross loans and advances to customers – pro forma 10,319,913
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
590
Reconciliations (continued)
5. Reconciliation of NPEs – Pro forma
2024
000
NPEs (as per table 3 above) 255,251
Reconciling items:
Loans and advances to customers (NPEs) classified as held for sale (
as per
table 3
above)
(54,921)
Residual fair value adjustment on initial recognition on loans and advances to
customers (NPEs) classified as held for sale (as per table 3 above)
778
NPEs - pro forma 201,108
NPE ratio – Pro forma 2024
NPEs - Pro forma (as per table above) (000) 201,108
Gross loans and advances to customers - Pro forma (as per table 4 above) (000) 10,319,913
Ratio of NPE/Gross loans – Pro forma (%) 1.9%
6. Reconciliation of Loan credit losses
2024 2023
000 000
Loan credit losses as per the underlying basis 30,368
62,749
Loan credit losses (as defined) are reconciled to the statutory
basis as follows:
Credit losses to cover credit risk on loans and advances to customers
(Note 16)
31,913
73,294
Net gains on derecognition of financial assets measured at amortised
cost – loans and advances to customers (see further below)
(313)
(8,144)
Net gains on loans and advances to customers measured at FVPL
(Note 11)
(1,232)
(2,401)
30,368
62,749
Net losses on derecognition of financial assets measured at amortised cost in the Consolidated Income
Statement amount to 13 thousand (2023: net gains of 6,361 thousand) and comprise 313 thousand
(2023: 8,144 thousand) net gains on derecognition of loans and advances to customers and 326 thousand
(2023: 1,783 thousand) net losses on derecognition of debt securities measured at amortised cost.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
591
Reconciliations (continued)
7. Reconciliation of Adjusted recurring profitability to Profit after tax for the year
attributable to the owners of the Company
2024 2023
000 000
Adjusted recurring profitability as per the underlying basis (
as defined
above)
482,063
455,301
Reconciling items:
Payment of coupon to AT1 holders (Note 34) 26,125
27,339
Cost for repurchase of other instruments* (Note 34) -
6,820
Advisory and other transformation costs (non-recurring) (Note 15) -
(2,253)
Profit after tax for the
year
attributable to the owners of the
Company as per the Consolidated Income Statement
508,188
487,207
* Comprises accrued AT1 coupon as at the date of the repurchase and amount paid for the repurchase in
excess of the nominal price
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
592
Key Performance Ratios Information
For the purpose of the ‘Alternative Performance Measures Disclosures’, reference to ‘Note’ relates to the
respective note in the Consolidated Financial Statements for the year ended 31 December 2024.
1. Net Interest Margin (NIM)
The components for the calculation of net interest margin are provided below:
2024 2023
1.1. Net interest income used in the calculation of NIM 000 000
Net interest income as per the underlying basis/statutory basis 821,464
792,217
1.2. Interest earning
assets
31 December
2024
30 September
2024
30 June
2024
31 March
2024
31 December
2023
000 000 000 000 000
Cash and balances with
central banks (Note 19)
7,600,726
7,517,002
7,287,221
7,217,046
9,614,502
Loans and advances to banks
(Note 19)
820,574
337,399
384,112
383,707
384,802
Reverse repurchase
agreements
1,010,170
1,022,515
1,014,858
707,526
403,199
Loans and advances to
customers (Note 23)
10,114,394
10,031,306
10,084,967
10,027,893
9,821,788
Loans and advances to
customers held for sale
(Note 23)
23,143
12,290
-
-
-
Prepayments, accrued
income and other assets –
Deferred consideration
receivable (‘DPP’) (Note 28)
143,604
255,400
251,244
247,107
243,013
Investments
Debt securities (Note 20) 4,212,177
4,061,291
3,828,083
3,742,838
3,547,782
Total interest earning
assets
23,924,788
23,237,203
22,850,485
22,326,117
24,015,086
1.3.
Quarterly average
interest earning
assets (000)
- 2024
23,270,736
- 2023
23,211,496
1.4. Net Interest Margin (NIM) 2024 2023
Net interest income (as per table 1.1. above) (000) 821,464
792,217
Quarterly average interest earning assets (
as per table 1.3. above
)
(000)
23,270,736
23,211,496
NIM (%) 3.53%
3.41%
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
593
Key Performance Ratios Information (continued)
2. Cost to income ratio
2.1 Reconciliation of the components of total expenses used in the cost to income ratio calculation from
the underlying basis to the statutory basis is provided below:
2.1.1 Reconciliation of Staff costs
2024 2023
000 000
Staff costs as per the underlying basis/statutory basis 203,062
192,266
2.1.2 Reconciliation of Other operating expenses
2024 2023
000 000
Other operating expenses as per the underlying basis 163,649
148,840
Reclassifications for:
Advisory and other transformation costs
organic, separately presented
under the underlying basis (Note 15)
-
2,253
Other operating expenses as per the statutory basis (Note 15) 163,649
151,093
2.1.3 Total Expenses as per the underlying basis
2024 2023
000 000
Staff costs as per the underlying basis/statutory basis (
as per table
2.1.1 above)
203,062
192,266
Special levy on deposits and other levies/contributions as per the
underlying basis/statutory basis
39,115
42,380
Other operating expenses as per the underlying basis
(as per table
2.1.2 above)
163,649
148,840
Total Expenses as per the underlying basis 405,826
383,486
2.2 Reconciliation of the components of total income used in the cost to income ratio calculation from
the underlying basis to the statutory basis is provided below:
2.2.1 Total Income as per the underlying basis
2024 2023
000 000
Net interest income as per the underlying basis/statutory basis (
as per
table 1.1 above)
821,464
792,217
Net fee and commission income
as per the underlying basis/statutory
basis
176,943
181,023
Net foreign exchange gains, Net gains on financial instruments and Net
gains on derecognition of financial assets measured at amortised cost
as per the underlying basis (as per table 2.2.2 below)
36,399
37,184
Net insurance result* (as per the statutory basis) 46,191
53,488
Net
(
losses
)/gains
from revaluation and disposal of investment
properties and Net gains on disposal of stock of properties (as per the
statutory basis)
(1,214)
10,015
Other income (as per the statutory basis) 14,381
18,337
Total Income as per the underlying basis 1,094,164
1,092,264
*Net insurance result comprises the aggregate of captions ‘Net insurance finance income/(expense) and net reinsurance
finance income/(expense)’, ‘Net insurance service result’ and ‘Net reinsurance service result’ per the statutory basis.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
594
Key Performance Ratios Information (continued)
2. Cost to income ratio (continued)
2.2.2 Reconciliation of Net foreign exchange gains, Net gains on
financial instruments and Net gains on derecognition of
financial assets measured at amortised cost between the
statutory basis and the underlying basis
2024 2023
000 000
Net foreign exchange gains, Net gains on financial
instruments and Net
gains on derecognition of financial assets measured at amortised cost as
per the underlying basis
36,399
37,184
Reclassifications for:
Net gains on loans and advances to customers measured at FVPL
disclosed within ‘Loan credit losses’ per the underlying basis (as per table
6 in Section ‘Reconciliations’ above)
1,232
2,401
Net gains on derecognition of financial assets measured at amortised
cost - loans and advances to customers, disclosed within ‘Loan credit
losses’ per the underlying basis (as per table 6 in Section ‘Reconciliations’
above)
313
8,144
Net foreign exchange gains, Νet gains on financial instruments and Net
gains on derecognition of financial assets measured at amortised cost as
per the statutory basis (see below)
37,944
47,729
Net foreign exchange gains, Net gains on financial instruments and Net
gains on derecognition of financial assets measured at amortised cost (as
per table above) are reconciled to the statutory basis as follows:
Net foreign exchange gains 27,285
28,588
Net gains on financial instruments 10,672
12,780
Net
(losses)/
gains on derecognition of financial assets measured at
amortised cost
(13)
6,361
37,944
47,729
2024 2023
Cost to income ratio 000 000
Total expenses (as per table 2.1.3 above) (000) 405,826
383,486
Total income (as per table 2.2.1 above) (000) 1,094,164
1,092,264
Total expenses / Total income (%) 37%
35%
Cost to income ratio excluding special levy on deposits and other
levies/contributions
Total expenses (as per table 2.1.3 above) (000) 405,826
383,486
Less: Special levy on deposits and other levies/contributions (
as per
table 2.1.3 above) (000)
(39,115)
(42,380)
Total expenses excluding special levy on
deposits and other
levies/contributions (000)
366,711
341,106
Total income (as per table 2.2.1 above) (000) 1,094,164
1,092,264
Total expenses excluding special levy on deposits and other
levies/contributions / Total income (%)
34%
31%
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
595
Key Performance Ratios Information (continued)
3. Operating profit return on average assets
The components used in the determination of the operating profit return on average assets are provided
below:
31 December
2024
30 September
2024
30 June
2024
31
March
2024
31 December
2023
000 000 000 000
Total assets used in the
computation of the
operating profit return
on average assets per
the Consolidated
Balance Sheet
26,483,592
25,863,097
25,466,170
24,940,672
26,628,577
Quarterly
average total
assets (000)
- 2024
25,876,422
- 2023
25,872,440
2024 2023
Total income (as per table 2.2.1 above) (000) 1,094,164
1,092,264
Total expenses (as per table 2.1.3 above) (000) (405,826)
(383,486)
Operating profit (000) 688,338
708,778
Quarterly average total assets (as per table above) (000) 25,876,422
25,872,440
Operating profit return on average assets (%) 2.7%
2.7%
4. Cost of Risk
2024 2023
000 000
Loan credit losses (as per table 6 in Section ‘Reconciliations’ above) 30,368
62,749
Average gross loans (as per table 1 in Section ‘Reconciliations’ above) 10,221,942
10,143,641
Cost of Risk (CoR) % 0.30%
0.62%
5. Basic profit per share attributable to the owners of the Company
The components used in the determination of the ‘Basic profit per share attributable to the owners of the
Company ( cent)’ are provided below:
2024 2023
Profit after tax (attributable to the owners of the Company) per the
underlying basis/statutory basis for the year ended 31 December (000)
508,188
487,207
Weighted average number of shares in issue during the
year
, excluding
treasury shares (thousand) (Note 18)
444,090
446,058
Basic profit per share attributable to the owners of the Company ( cent) 114.4
109.2
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
596
Key Performance Ratios Information (continued)
6. Return on tangible equity (ROTE)
The components used in the determination of ‘Return on tangible equity (ROTE)’ are provided below:
2024 2023
Profit after tax (attributable to the owners of the Company) per the
underlying basis/statutory basis for the year ended 31 December
(000)
508,188
487,207
Quarterly average tangible shareholders’ equity as at 3
1
December
(
as
per table 6.2 below) (000)
2,375,434
1,961,194
ROTE (%) 21.4%
24.8%
6.1 Tangible
shareholders’
equity
31 December
2024
30 September
2024
30 June
2024
31 March
2024
31 December
2023
000 000 000 000
Equity attributable to
the owners of the
Company (as per the
statutory basis)
2,589,874
2,508,085
2,387,383 2,380,876 2,247,080
Less: Intangible assets
(as per the statutory
basis)
(49,747)
(45,451)
(45,686) (46,609) (48,635)
Total tangible
shareholders’ equity
2,540,127
2,462,634
2,341,697 2,334,267 2,198,445
6.2 Quarterly
average
tangible
shareholders’
equity (000)
- 2024
2,375,434
- 2023
1,961,194
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
597
Key Performance Ratios Information (continued)
7. Return on tangible equity (ROTE) on 15% CET1 ratio
The components used in the determination of ‘Return on tangible equity (ROTE) on 15% CET1 ratio’, are
provided below:
2024 2023
Profit after tax
(attributable to the owners of the Company) per the
underlying basis/statutory basis for the year ended 31 December
(000)
508,188
487,207
Quarterly average tangible shareholders’ equity adjusted for excess
CET1 capital on a 15% CET1 ratio as at 31 December (as per table 7.2
below) (000)
1,839,293
1,779,597
ROTE on 15% CET1 (%) 27.6%
27.4%
7.1 Tangible
shareholders’
equity on 15%
CET1 ratio
31 December
2024
30 September
2024
30 June
2024
31 March
2024
31 December
2023
000 000
000
000
000
Equity attributable to the
owners of the Company
(as per the statutory
basis)
2,589,874
2,508,085
2,387,383
2,380,876
2,247,080
Less: Intangible assets
(as per the statutory
basis)
(49,747)
(45,451)
(45,686)
(46,609)
(48,635)
Less:
proposed FY2024/
approved FY2023
distribution**
(241,032)
(9,871)
(19,011)
(136,590)
(136,590)
Less:
excess CET1
capital* on a 15% CET1
ratio
(450,371)
(619,625)
(479,000)
(341,460)
(247,153)
Total tangible
shareholders’ equity
on 15% CET1 ratio
1,848,724
1,833,138
1,843,686
1,856,217
1,814,702
*Includes amount of foreseeable charge for shareholders’ distribution accrual at the top-end range of the Group’s
approved distribution policy deducted from CET1 ratio as applicable.
**Approved FY2023 distribution is adjusted to the extent not already deducted from the Equity attributable to the owners
of the Company (as per the statutory basis) at each period end. As at 30 September 2024 and 30 June 2024, only an
amount relating to the approved share buyback of 25 million not yet executed is adjusted. For prior periods, the full
amount of the FY2023 distribution is adjusted.
7.2 Quarterly average tangible
shareholders’ equity on 15% CET1 ratio
(000)
- 2024 1,839,293
- 2023 1,779,597
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Alternative Performance Measures Disclosures
598
Key Performance Ratios Information (continued)
8. Tangible book value per share
2024 2023
000 000
Tangible shareholder’s equity (as per table 6.1 above) (000) 2,540,127
2,198,445
Number of shares in issue
at the end of
the
year
, excluding treasury
shares (thousand) (Note 34)
440,360
446,058
Tangible book value per share () 5.77
4.93
9. Leverage ratio
2024 2023
Tangible total equity (including Other equity instruments) (
as per table
9.1 below) (000)
2,760,127
2,418,445
Total assets as per the statutory basis (000) 26,483,592
26,628,577
Leverage ratio 10.4%
9.1%
9.1 Tangible total equity
2024 2023
000 000
Equity attributable to the owners of the Company (as per the statutory
basis)
2,589,874
2,247,080
Other equity instruments per the Statutory basis 220,000
220,000
Less: Intangible assets per the statutory basis (49,747)
(48,635)
Tangible total equity 2,760,127
2,418,445
Additional Information – EU Taxonomy Disclosure
Tables
2024
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
600
EU Taxonomy Disclosure Tables
Introduction
These disclosures represent the EU Taxonomy disclosures of Bank of Cyprus Holdings Public Limited Company
('the Group') as at 31 December 2024 and 31 December 2023. They have been prepared in accordance with the
requirements of Article 8 of Regulation (EU) 2020/852 which requires undertakings that are subject to Articles
19a or 29a of Directive 2013/34/EU of the European Parliament and of the Council to disclose how and to what
extent their activities are associated with environmentally sustainable economic activities.
Information based on Annex VI in the Disclosures Delegated Act - Regulation (EU) 2021/2178
Credit institutions shall disclose the information referred to in Article 8(1) of Regulation (EU) 2020/852 as
specified in Annexes V and XI of the Disclosures Delegated Act - Regulation (EU) 2021/2178 which supplements
Regulation (EU) 2020/852. Article 8(1) of Regulation (EU) 2020/852 requires undertakings that are subject to
Articles 19a or 29a of Directive 2013/34/EU of the European Parliament and of the Council to disclose how and
to what extent their activities are associated with environmentally sustainable economic activities. Article 8(2) of
Regulation (EU) 2020/852 requires non-financial undertakings to disclose information on the proportion of the
turnover, capital expenditure and operating expenditure of their activities related to assets or processes
associated with environmentally sustainable economic activities. That provision, however, does not specify
equivalent key performance indicators for financial undertakings, that is credit institutions, asset managers,
investment firms and insurance and reinsurance undertakings. For credit institutions this information shall be
presented in tabular form by using the template set out in Annex VI in the Disclosures Delegated Act - Regulation
(EU) 2021/2178.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
601
EU Taxonomy Disclosure Tables (continued)
1.
1
Assets for the calculation of GAR (Turnover Based
)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
Key:
31 December 2024
Total gross
carrying amount
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + 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 towards taxonomy relevant sectors (Taxonomy
-
eligible)
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 (Taxonomy
-
aligned)
Of which
environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
`
GAR
-
Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity
instruments not HfT eligible for
GAR calculation
8,416 4,188 90 91 79 12 0 0 0 0 - - - - 1 - - - 3 - - - - - - - 4,193 91 90 79 12
2 Financial undertakings 3,224 393 72 72 72 - - - - - - - - - - - - - - - - - - - - - 393 72 72 72 -
3
Credit institutions
2,854
358
66
66
66
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
358
66
66
66
-
4 Loans and advances 1,235 118 7 7 7 - - - - - - - - - - - - - - - - - - - - - 118 7 7 7 -
5 Debt securities, including UoP 1,619 240 59 59 59 - - - - - - - - - - - - - - - - - - - - 240 59 59 59 -
6 Equity instruments - - - - - - - - - - - - - - - - - - - - - - = -
7 Other financial corporations 370 35 6 6 6 - - - - - - - - - - - - - - - - - - - - - 35 6 6 6 -
8 of which investment firms - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
9 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
10 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
11 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - -
12
of which management
companies
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
13 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
14 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
15 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - -
16
of which insurance
undertakings
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
17 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
18 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
19 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - -
20
Non
-
financial undertakings
(subject to NFRD disclosure
obligations)
261 22 19 19 7 12 0 0 0 0 - - - - 1 - - 3 - - - - - - - 26 19 19 7 12
21
Loans and advances
85
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
3
-
-
-
-
-
-
-
3
-
-
-
-
22
Debt securities, including UoP
175
2
2
19
19
7
12
0
0
0
0
-
-
-
-
1
-
-
-
-
-
-
-
-
-
-
-
22
19
19
-
12
23
Equity instruments
1
0
0
-
0
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
0
0
-
0
24 Households 4,862 3,773 - - - - - - - - - - - - 3,773 - - - -
25
of which loans collateralised by
residential immovable property
3,762 3,761 - - - - - - - - - - - - 3,762 - - - -
26 of which building renovation loans - - - - - - - - - - - - - - - - - - -
27 of which motor vehicle loans 152 11 - - - - 11 - - - -
28 Local governments financing 69 1 - - - - - - - - - - - - - - - - - - - - - - - - 1 - - - -
29 Housing financing 1 1 - - - - - - - - - - - - - - - - - - - - - - - - 1 - - - -
30 Other local government financing 68 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
31
Collateral obtained by taking
possession: residential and
commercial immovable
properties
408 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
32 TOTAL GAR ASSETS 8,824 4,188 91 90 79 12 0 0 0 0 - - - - 1 - - - 3 - - - - - - - 4,193 91 90 79 12
Of which use of proceeds
Of which transitional
Of which enabling
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
602
EU Taxonomy Disclosure Tables (continued)
1.1 Assets for the calculation of GAR (Turnover Based) (continued)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
Key:
31 December 2024
Total gross carrying
amount
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + 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 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
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Assets excluded from the numerator for GAR calculation (covered
in the denominator)
6,951 - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - -
33Non-financial undertakings 4,957
34
EU SMEs and NFCs (other than SMEs) not subject to NFRD
disclosure obligations
4,570
35
Loans and advances
4,562
36 of which loans collateralised by commercial immovable property 3,500
37 of which building renovation loans -
38 Debt securities -
39 Equity instruments 8
40
Non-EU country counterparties not subject to NFRD disclosure
obligations
387
41 Loans and advances 387
42Debt securities -
43
Equity instruments
-
44Derivatives 86
45On demand interbank loans 283
46Cash and cash-related assets 95
47 Other categories of assets (e.g. Goodwill, commodities etc.) 1,530
48TOTAL ASSETS IN THE DENOMINATOR (GAR) 15,774 4,188 91 90 79 12 0 0 0 0 - - - - 1 - - - 3 - - - - - - - 4,193 91 90 79 12
49Assets not covered for GAR calculation 9,846
50Central governments and Supranational issuers 2,331
51Central banks exposure 7,506
52Trading book 9
53Total assets 25,621
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54 Financial guarantees 451 4 - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
55 Assets under management
1
4,299 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
56 Of which debt securities
57 Of which equity instruments
1 For the 2024 report Assets Under Management has been provided. Future reports will provide detail on AUM split across Debt Securities and Equity Instruments. In addition, EU Taxonomy Eligible and EU Taxonomy Aligned information will be provided, where possible, after collaboration with third party data vendors regarding existing data limitations faced in the area of
EU Taxonomy.
Of which use of proceeds
Of which transitional
Of which enabling
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
603
EU Taxonomy Disclosure Tables (continued)
1.
2
Assets for the calculation of GAR (
CapEx
Based
)
a
b
c
D
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
Key:
31 December 2024
Total gross
carrying amount
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + 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 towards taxonomy relevant sectors (Taxonomy
-
eligible)
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
(Taxonomy
-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
`
GAR
-
Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity
instruments not HfT eligible for
GAR calculation
8,416 4,028 40 40 30 10 1 0 0 0 - - - - 1 - - - - - - - - - - - 4,030 40 40 30 10
2 Financial undertakings 3,224 227 23 23 23 - - - - - - - - - - - - - - - - - - - - - 227 23 23 23 -
3
Credit institutions
2,854
189
18
18
18
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
189
18
18
18
-
4 Loans and advances 1,235 41 2 2 2 - - - - - - - - - - - - - - - - - - - - - 41 2 2 2 -
5 Debt securities, including UoP 1,619 148 16 16 16 - - - - - - - - - - - - - - - - - - - - 148 16 16 16 -
6 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - -
7 Other financial corporations 370 38 5 5 5 - - - - - - - - - - - - - - - - - - - - - 38 5 5 5 -
8 of which investment firms - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
9 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
10 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
11 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - -
12
of which management
companies
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
13 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
14 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
15 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - -
16
of which insurance
undertakings
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
17 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
18 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
19 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - -
20
Non
-
financial undertakings
(subject to NFRD disclosure
obligations)
261 27 17 17 8 10 1 0 0 0 - - - - 1 - - - - - - - - - - 29 17 17 8 10
21
Loans and advances
85
4
0
0
0
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
4
0
0
0
-
22
Debt securities, including UoP
175
2
4
1
7
17
7
1
0
1
0
0
0
-
-
-
-
1
-
-
-
-
-
-
-
-
-
-
-
25
1
7
1
7
7
1
0
23
Equity instruments
1
0
0
0
0
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
0
0
0
-
24 Households 4,862 3,773 - - - - - - - - - - - - 3,773 - - - -
25
of which loans collateralised by
residential immovable property
3,762 3,761 - - - - - - - - - - - - 3,762 - - - -
26 of which building renovation loans - - - - - - - - - - - - - - - - - - -
27 of which motor vehicle loans 152 11 - - - - 11 - - - -
28 Local governments financing 69 1 - - - - - - - - - - - - - - - - - - - - - - - - 1 - - - -
29 Housing financing 1 1 - - - - - - - - - - - - - - - - - - - - - - - - 1 - - - -
30 Other local government financing 68 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
31
Collateral obtained by taking
possession: residential and
commercial immovable
properties
408 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
32 TOTAL GAR ASSETS 8,824 4,028 40 40 30 10 1 0 0 0 - - - - 1 - - - - - - - - - - - 4,030 40 40 30 10
Of which use of proceeds
Of which transitional
Of which enabling
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1.2 Assets for the calculation of GAR (CapEx Based) (continued)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
Key:
31 December 2024
Total gross carrying
amount
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + 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 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
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Assets excluded from the numerator for GAR calculation (covered
in the denominator)
6,951 - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - -
33Non-financial undertakings 4,957
34
EU SMEs and NFCs (other than SMEs) not subject to NFRD
disclosure obligations
4,570
35
Loans and advances
4,562
36 of which loans collateralised by commercial immovable property 3,500
37 of which building renovation loans -
38 Debt securities -
39 Equity instruments 8
40
Non-EU country counterparties not subject to NFRD disclosure
obligations
387
41 Loans and advances 387
42Debt securities -
43
Equity instruments
-
44Derivatives 86
45On demand interbank loans 283
46Cash and cash-related assets 95
47 Other categories of assets (e.g. Goodwill, commodities etc.) 1,530
48TOTAL ASSETS IN THE DENOMINATOR (GAR) 15,774 4,028 40 40 30 10 1 0 0 0 - - - - 1 - - - - - - - - - - - 4,030 40 40 30 10
49Assets not covered for GAR calculation 9,846
50Central governments and Supranational issuers 2,331
51Central banks exposure 7,506
52Trading book 9
53Total assets 25,621
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
451 4 - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
55
Assets under management
1
4,299 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
56
Of which debt securities
57
Of which equity instruments
1 For the 2024 report Assets Under Management has been provided. Future reports will provide detail on AUM split across Debt Securities and Equity Instruments. In addition, EU Taxonomy Eligible and EU Taxonomy Aligned information will be provided, where possible, after collaboration with third party data vendors regarding existing data limitations faced in the area of
EU Taxonomy.
Of which use of proceeds
Of which transitional
Of which enabling
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EU Taxonomy Disclosure Tables (continued)
1.3 GAR sector information (Turnover Based)
A b e f i j m n q r u v y z
31 December 2024
Breakdown by sector - NACE 4 digits level (code
and label)
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC +
BIO)
Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD)
Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount
Mn EUR
Of which environmentally
sustainable (CCM)
Mn EUR
Of which environmentally
sustainable (CCA)
Mn EUR
Of which environmentally
sustainable (WTR)
Mn EUR
Of which environmentally
sustainable (CE)
Mn EUR
Of which environmentally
sustainable (PPC)
Mn EUR
Of which environmentally
sustainable (BIO)
Mn EUR
Of which environmentally
sustainable (CCM + CCA +
WTR + CE + PPC + BIO)
1
C.24.2 -
Manufacture of tubes, pipes, hollow
profiles and related fittings, of steel
0 0 - - - - - - - - - - 0 0
2
D.35.1 - Electric power generation,
transmission and distribution
17 17 - - - - - - - - - - 17 17
3 J.61.9 - Other Telecommunications activities 5 2 0 0 - - 1 - - - - - 6 2
4 Q.86.9 - Other human health activities - - - - - - - - 4 - - - 4 -
1.4 GAR sector information (CapEx Based)
A b e f i j m n q r u v y z
31 December 2024
Breakdown by sector - NACE 4 digits level (code and
label)
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC +
BIO)
Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD)
Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount
Mn EUR
Of which environmentally
sustainable (CCM)
Mn EUR
Of which environmentally
sustainable (CCA)
Mn EUR
Of which environmentally
sustainable (WTR)
Mn EUR
Of which environmentally
sustainable (CE)
Mn EUR
Of which environmentally
sustainable (PPC)
Mn EUR
Of which environmentally
sustainable (BIO)
Mn EUR
Of which environmentally
sustainable (CCM + CCA +
WTR + CE + PPC + BIO)
1
C.14.1 - Manufacture of wearing apparel,
except fur apparel
4 0 - - - - - - - - - - 4 0
2
C.24.2 - Manufacture of tubes, pipes,
hollow profiles and related fittings, of steel
0 0 - - - - - - - - - - 0 0
3
D.35.1 - Electric power generation,
transmission and distribution
17 16 - - - - - - - - - - 17 16
4
J.61.9 - Other Telecommunications
activities
2 1 1 0 - - 1 - - - - - 4 1
5 Q.86.1 - Hospital activities 1 0 - - - - - - - - - - 1 0
6 Q.86.9 - Other human health activities 3 0 - - - - - - - - - - 3 0
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EU Taxonomy Disclosure Tables (continued)
1
.
5
GAR KPI stock (Turnover Based)
A b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
% (compared to total covered
assets in the denominator)
Key:
31 December 2024
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) 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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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
assets covered
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 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)
GAR
-
Covered assets in
both numerator and
denominator
1
Loans and advances, debt
securities and equity
instruments not HfT
eligible for GAR calculation
50% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 50% 1% 1,07% 1% 0,14% 33%
2 Financial undertakings 12% 2% 2% 2% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 12% 2% 2% 2% 0% 13%
3 Credit institutions 13% 2% 2% 2% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 13% 2% 2% 2% 0% 11%
4 Loans and advances 10% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 10% 1% 1% 1% 0% 5%
5 Debt securities, including UoP 15% 4% 4% 4% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 15% 4% 4% 4% 0% 6%
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
Other financial
corporations
9% 2% 2% 2% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 9% 2% 2% 2% 0% 1%
8 of which investment firms 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
9 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%
10 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%
11 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%
12
of which management
companies
0% 0% 0% 0% 0% 0% 0% 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 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%
14 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%
15 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%
16
of 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%
17 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%
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%
19 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%
20
Non-
financial undertakings
(subject to NFRD
disclosure obligations)
8% 7% 7% 3% 4% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 10% 7% 7% 3% 4% 1%
21 Loans and advances 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 4% 0% 0% 0% 0% 0% 0% 0% 4% 0% 0% 0% 0% 0%
22 Debt securities, including UoP 12% 11% 11% 4% 7% 0% 0% 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 13% 11% 11% 4% 7% 1%
23 Equity instruments 41% 25% 0% 25% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 41% 25% 0% 25% 0%
24 Households 78% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 78% 0% 0% 0% 0% 19%
25
of which loans collateralised
by residential immovable
property
100% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 100% 0% 0% 0% 0% 15%
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%
27 of which motor vehicle loans 7% 0% 0% 0% 0% 7% 0% 0% 0% 0% 1%
28
Local governments
financing
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% 1% 0% 0% 0% 0% 0%
29 Housing financing 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%
30
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%
31
Collateral obtained by
taking possession:
residential and commercial
immovable properties
0% 0% 0% 0% 0% 0% 0% 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 Total GAR assets 27% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 27% 0,6% 0,57% 1% 0,07% 62%
Of which use of proceeds
Of which transitional
Of which enabling
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EU Taxonomy Disclosure Tables (continued)
1.6
GAR KPI stock (Turnover Based)
A b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
% (compared to total covered
assets in the denominator)
Key:
31 December 2024
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) 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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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
assets covered
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 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)
GAR
-
Covered assets in
both numerator and
denominator
1
Loans and advances,
debt securities and equity
instruments not HfT
eligible for GAR calculation
48% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 48% 0% 0% 0% 0% 33% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 48%
2 Financial undertakings 7% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 7% 1% 1% 0% 0% 13% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 7%
3 Credit institutions 7% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 7% 1% 1% 0% 0% 11% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 7%
4 Loans and advances 3% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 3% 0% 0% 0% 0% 5% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 3%
5 Debt securities, including UoP 9% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 9% 1% 1% 0% 0% 6% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 9%
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
Other financial
corporations
10% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 10% 1% 1% 0% 0% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 10%
8 of which investment firms 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
9 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%
10 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%
11 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%
12
of which management
companies
0% 0% 0% 0% 0% 0% 0% 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 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%
14 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%
15 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%
16
of 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%
17 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%
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%
19 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%
20
Non-
financial undertakings
(subject to NFRD
disclosure obligations)
10% 7% 7% 0% 4% 0% 0% 0% 0% 0% 0% 0% 0% 11% 7% 7% 0% 4% 1% 7% 0% 4% 0% 0% 0% 0% 0% 0% 0% 0% 11%
21 Loans and advances 5% 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% 0% 0% 0% 5%
22 Debt securities, including UoP 13% 10% 10% 0% 5% 0% 0% 0% 0% 1% 0% 0% 0% 14% 10% 10% 0% 6% 1% 10% 0% 5% 0% 0% 0% 0% 1% 0% 0% 0% 14%
23 Equity instruments 46% 37% 0% 0% 0% 0% 0% 0% 0% 0% 46% 37% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 46%
24 Households 78% 0% 0% 0% 0% 0% 0% 0% 0% 78% 0% 0% 0% 0% 0% 0% 0% 0% 78%
25
of which loans collateralised
by residential immovable
property
100% 0% 0% 0% 0% 0% 0% 0% 0% 100% 0% 0% 0% 0% 0% 0% 0% 0% 100%
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%
27 of which motor vehicle loans 7% 0% 0% 0% 0% 0% 0% 0% 0% 0% 7%
28
Local governments
financing
1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 1%
29 Housing financing 100% 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% 100%
30
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%
31
Collateral obtained by
taking possession:
residential and commercial
immovable properties
0% 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% 0% 0%
32 Total GAR assets 26% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 26% 0% 0% 0% 0% 62% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 26%
Of which use of proceeds
Of which transitional
Of which enabling
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EU Taxonomy Disclosure Tables (continued)
1.7
GAR KPI flow (Turnover Based)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to total covered assets in the
denominator)
Key:
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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 assets
covered
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 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)
GAR
-
Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity instruments
not HfT eligible for GAR calculation
33% 2% 2% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 33% 2% 2% 1% 1% 55%
2 Financial undertakings 16% 2% 2% 2% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 16% 2% 2% 2% 0% 32%
3 Credit institutions 18% 2% 2% 2% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 18% 2% 2% 2% 0% 24%
4 Loans and advances 25% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 25% 1% 1% 1% 0% 12%
5 Debt securities, including UoP 11% 2% 2% 2% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 11% 2% 2% 2% 0% 12%
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 Other financial corporations 10% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 10% 1% 1% 1% 0% 8%
8 of which investment firms 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
9 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%
10 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%
11 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%
12 of which management companies 0% 0% 0% 0% 0% 0% 0% 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 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%
14 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%
15 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%
16 of 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%
17 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%
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%
19 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%
20 Non-financial undertakings 14% 13% 13% 5% 8% 0% 0% 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 15% 13% 13% 5% 8% 4%
21 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% 2%
22 Debt securities, including UoP 25% 22% 22% 8% 14% 1% 0% 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 26% 22% 22% 8% 14% 2%
23 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%
24 Households 65% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 65% 0% 0% 0% 0% 19%
25
of which loans collateralised by
residential immovable property
100% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 100% 0% 0% 0% 0% 12%
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%
27 of which motor vehicle loans 11% 0% 0% 0% 0% 11% 0% 0% 0% 0% 2%
28 Local governments 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%
29 Housing 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%
30 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%
31
Collateral obtained by taking
possession: residential and
commercial immovable properties
0% 0% 0% 0% 0% 0% 0% 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 Total GAR assets 21% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 21% 1% 1% 1% 0% 88%
Of which use of proceeds
Of which transitional
Of which enabling
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
609
EU Taxonomy Disclosure Tables (continued)
1
.
8
GAR KPI flow (CapEx Based)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to total covered assets in the
denominator)
Key:
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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
assets
covered
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 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)
GAR
-
Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity instruments
not HfT eligible for GAR
calculation
29% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 29% 1% 1% 1% 0% 55%
2 Financial undertakings 9% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 9% 1% 1% 1% 0% 32%
3 Credit institutions 9% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 9% 1% 1% 1% 0% 24%
4 Loans and advances 9% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 9% 0% 0% 0% 0% 12%
5 Debt securities, including UoP 9% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 9% 1% 1% 1% 0% 12%
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 Other financial corporations 11% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 11% 1% 1% 1% 0% 8%
8 of which investment firms 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
9 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%
10 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%
11 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%
12 of which management companies 0% 0% 0% 0% 0% 0% 0% 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 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%
14 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%
15 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%
16 of 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%
17 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%
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%
19 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%
20 Non-financial undertakings 14% 12% 12% 5% 7% 1% 0% 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 16% 12% 12% 5% 7% 4%
21 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% 2%
22 Debt securities, including UoP 24% 20% 20% 8% 12% 1% 0% 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 27% 20% 20% 8% 12% 2%
23 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%
24 Households 65% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 65% 0% 0% 0% 0% 19%
25
of which loans collateralised by
residential immovable property
100% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 100% 0% 0% 0% 0% 12%
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%
27 of which motor vehicle loans 11% 0% 0% 0% 0% 11% 0% 0% 0% 0% 2%
28 Local governments 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%
29 Housing 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%
30 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%
31
Collateral obtained by taking
possession: residential and
commercial immovable properties
0% 0% 0% 0% 0% 0% 0% 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 Total GAR assets 18% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 18% 1% 1% 1% 0% 88%
Of which use of proceeds
Of which transitional
Of which enabling
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
610
EU Taxonomy Disclosure Tables (continued)
1.9
KPI stock off
-
balance sheet exposures (Turnover Based)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off
-
balance
sheet assets)
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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 (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
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)
1
Financial guarantees (FinGuar KPI)
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%
1
%
0%
0%
0%
0%
2
Assets under management (AuM KPI)
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%
1.10
KPI stock off
-
balance sheet exposures (CapEx Based)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off
-
balance
sheet assets)
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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 (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
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)
1
Financial guarantees (FinGuar KPI)
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%
1
%
0%
0%
0%
0%
2
Assets under management (AuM
KPI)
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%
1.11
KPI flow off
-
balance sheet exposures (Turnover Based)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off
-
balance
sheet assets)
1
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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 (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
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)
1
Financial
guarantees (FinGuar KPI)
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%
1
%
0%
0%
0%
0%
2
Assets under management (AuM KPI)
0
%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0
%
0%
0%
0%
0%
1.12
KPI flow off
-
balance sheet exposures (CapEx Based)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off
-
balance sheet
assets)
1
31 December 2024
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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 (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
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)
1
Financial guarantees (FinGuar KPI)
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%
1
%
0%
0%
0%
0%
2
Assets under management (AuM KPI)
0
%
0%
0%
0%
0%
0%
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 Future reports will provide detail on AUM EU Taxonomy Eligible and Aligned information, where possible, after collaboration with third party data vendors regarding existing data limitations.
Of which use of proceeds
Of which transitional
Of which enabling
Of which use of proceeds
Of which transitional
Of which enabling
Of which use of proceeds
Of which transitional
Of which enabling
Of which use of proceeds
Of which transitional
Of which enabling
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
611
EU Taxonomy Disclosure Tables (continued)
1.
1
Assets for the calculation of GAR (Turnover Based
)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
Key:
31 December 2023
Total gross
carrying amount
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + 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 towards taxonomy relevant sectors (Taxonomy
-
eligible)
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 (Taxonomy
-
aligned)
Of which
environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
`
GAR
-
Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity
instruments not HfT eligible for
GAR calculation
7,249 3,881 - - - - - - - - - - - - - - - - - - - - - - - - 3,881 - - - -
2 Financial undertakings 2,279 148 - - - - - - - - - - - - - - - - - - - - - - - - 148 - - - -
3
Credit institutions
1,971
146
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
146
-
-
-
-
4 Loans and advances 505 5 - - - - - - - - - - - - - - - - - - - - - - - - 5 - - - -
5 Debt securities, including UoP 1,465 141 - - - - - - - - - - - - - - - - - - - - - - - - 141 - - - -
6 Equity instruments 1 - - - - - - - - - - - - - - - - - - - - - - -
7 Other financial corporations 308 2 - - - - - - - - - - - - - - - - - - - - - - - - 2 - - - -
8 of which investment firms 1 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
9 Loans and advances 1 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
10 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
11 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - -
12
of which management
companies
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
13 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
14 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
15 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - -
16
of which insurance
undertakings
6 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
17 Loans and advances 4 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
18 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
19 Equity instruments 2 - - - - - - - - - - - - - - - - - - - - - - -
20
Non
-
financial undertakings
(subject to NFRD disclosure
obligations)
154 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
21
Loans and advances
43
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Debt securities, including UoP
111
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
24 Households 4,781 3,732 - - - - - - - - - - - - 3,732 - - - -
25
of which loans collateralised by
residential immovable property
3,726 3,726 - - - - - - - - - - - - 3,726 - - - -
26 of which building renovation loans - - - - - - - - - - - - - - - - - - -
27 of which motor vehicle loans 139 6 - - - - 6 - - - -
28 Local governments financing 35 1 - - - - - - - - - - - - - - - - - - - - - - - - 1 - - - -
29 Housing financing 1 1 - - - - - - - - - - - - - - - - - - - - - - - - 1 - - - -
30 Other local government financing 34 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
31
Collateral obtained by taking
possession: residential and
commercial immovable
properties
560 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
32 TOTAL GAR ASSETS 7,809 3,881 - - - - - - - - - - - - - - - - - - - - - - - - 3,881 - - - -
Of which use of proceeds
Of which transitional
Of which enabling
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
612
EU Taxonomy Disclosure Tables (continued)
1.1 Assets for the calculation of GAR (Turnover Based) (continued)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
Key:
31 December 202
3
Total gross
carrying amount
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + 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 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 (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Assets excluded from the
numerator for GAR
calculation (covered in the
denominator)
6,688 - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - -
33Non-
financial undertakings
4,900
34
EU SMEs and NFCs (other
than SMEs) not subject to
NFRD disclosure
obligations
4,576
35
Loans and advances
4,56
5
36
of which loans collateralised
by commercial immovable
property
3,706
37
of which building renovation
loans
-
38 Debt securities -
39 Equity instruments 11
40
Non
-
EU country
counterparties not subject
to NFRD disclosure
obligations
324
41 Loans and advances 324
42Debt securities -
43
Equity instruments
-
44Derivatives 49
45
On demand interbank
loans
275
46
Cash and cash-related
assets
93
47
Other categories of assets
(e.g. Goodwill,
commodities etc.)
1,371
48
TOTAL ASSETS IN THE
DENOMINATOR (GAR)
14,497 3,881 - - - - - - - - - - - - - - - - - - - - - - - - 3,881 - - - -
49
Assets not covered for GAR
calculation
11,444
50
Central governments and
Supranational issuers
1,920
51Central banks exposure 9,522
52Trading book 2
53Total assets 25,941
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
451 3 - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
55
Assets under management
4,031 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
56
Of which debt securities
57
Of which equity instruments
Of which use of proceeds
Of which transitional
Of which enabling
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
613
EU Taxonomy Disclosure Tables (continued)
1.
1
Assets for the calculation of GAR (
CapEx
Based
)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
Key:
31 December 2023
Total gross
carrying amount
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + 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 towards taxonomy relevant sectors
(Taxonomy
-
eligible)
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 (Taxonomy
-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
`
GAR
-
Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity
instruments not HfT eligible for
GAR calculation
7,249 3,886 1 1 1 - - - - - - - - - - - - - - - - - - - - - 3,886 1 1 1 -
2 Financial undertakings 2,279 150 - - - - - - - - - - - - - - - - - - - - - - - - 150 - - - -
3
Credit institutions
1,971
146
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
146
-
-
-
-
4 Loans and advances 505 5 - - - - - - - - - - - - - - - - - - - - - - - - 5 - - - -
5 Debt securities, including UoP 1,465 141 - - - - - - - - - - - - - - - - - - - - - - - - 141 - - - -
6 Equity instruments 1 - - - - - - - - - - - - - - - - - - - - - - -
7 Other financial corporations 308 4 - - - - - - - - - - - - - - - - - - - - - - - - 4 - - - -
8 of which investment firms 1 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
9 Loans and advances 1 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
10 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
11 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - -
12
of which management
companies
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
13 Loans and advances - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
14 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
15 Equity instruments - - - - - - - - - - - - - - - - - - - - - - - -
16
of which insurance
undertakings
6 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
17 Loans and advances 4 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
18 Debt securities, including UoP - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
19 Equity instruments 2 - - - - - - - - - - - - - - - - - - - - - - -
20
Non
-
financial undertakings
(subject to NFRD disclosure
obligations)
154 4 1 1 1 - - - - - - - - - - - - - - - - - - - - - 4 1 1 1 -
21
Loans and advances
43
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Debt securities, including UoP
111
4
1
1
1
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
4
1
1
1
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
24 Households 4,781 3,732 - - - - - - - - - - - - 3,732 - - - -
25
of which loans collateralised by
residential immovable property
3,726 3,726 - - - - - - - - - - - - 3,726 - - - -
26 of which building renovation loans - - - - - - - - - - - - - - - - - - -
27 of which motor vehicle loans 139 6 - - - - 6 - - - -
28 Local governments financing 35 1 - - - - - - - - - - - - - - - - - - - - - - - - 1 - - - -
29 Housing financing 1 1 - - - - - - - - - - - - - - - - - - - - - - - - 1 - - - -
30 Other local government financing 34 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
31
Collateral obtained by taking
possession: residential and
commercial immovable
properties
560 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
32 TOTAL GAR ASSETS 7,809 3,886 1 1 1 - - - - - - - - - - - - - - - - - - - - - 3,886 1 1 1 -
Of which use of proceeds
Of which transitional
Of which enabling
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
614
EU Taxonomy Disclosure Tables (continued)
1.1 Assets for the calculation of GAR (CapEx Based) (continued)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
Million EUR
Key:
31 December 202
3
Total gross
carrying amount
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO) TOTAL (CCM + CCA + WTR + CE + PPC + 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 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 (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Assets excluded from the numerator for GAR calculation (covered in the
denominator)
6,688 - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - -
33Non-financial undertakings 4,900
34
EU SMEs and NFCs (other than SMEs) not subject to NFRD disclosure
obligations
4,576
35
Loans and advances
4,56
5
36 of which loans collateralised by commercial immovable property 3,706
37 of which building renovation loans -
38 Debt securities -
39 Equity instruments 11
40 Non-EU country counterparties not subject to NFRD disclosure obligations 324
41 Loans and advances 324
42Debt securities -
43
Equity instruments
-
44Derivatives 49
45On demand interbank loans 275
46Cash and cash-related assets 93
47 Other categories of assets (e.g. Goodwill, commodities etc.) 1,371
48TOTAL ASSETS IN THE DENOMINATOR (GAR) 14,497 3,886 1 1 1 - - - - - - - - - - - - - - - - - - - - - 3,886 1 1 1 -
49Assets not covered for GAR calculation 11,444
50Central governments and Supranational issuers 1,920
51Central banks exposure 9,522
52Trading book 2
53Total assets 25,941
Off-balance sheet exposures - Undertakings subject to NFRD disclosure obligations
54
Financial guarantees
451 3 - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
55
Assets under management
4,031 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
56
Of which debt securities
57
Of which equity instruments
Of which use of proceeds
Of which transitional
Of which enabling
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
615
EU Taxonomy Disclosure Tables (continued)
1.3 GAR sector information (Turnover Based) - Restated
a b e f i j m n q r u v y z
31 December 2023
Breakdown by sector -
NACE 4 digits level (code and
label)
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC +
BIO)
Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD)
Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount
Mn EUR
Of which environmentally
sustainable (CCM)
Mn EUR
Of which environmentally
sustainable (CCA)
Mn EUR
Of which environmentally
sustainable (WTR)
Mn EUR
Of which environmentally
sustainable (CE)
Mn EUR
Of which environmentally
sustainable (PPC)
Mn EUR
Of which environmentally
sustainable (BIO)
Mn EUR
Of which environmentally
sustainable (CCM + CCA +
WTR + CE + PPC + BIO)
Note:
1. There were no EU taxonomy eligible or aligned exposures as at 31 December 2023.
2. The 1.3 GAR sector information (Turnover Based) has been restated to disclose only NFRD taxonomy eligible and aligned sectors.
1.4 GAR sector information (CapEx Based) - - Restated
a b e f i j m n q r u v y z
31 December 2023
Breakdown by sector - NACE 4 digits level (code and
label)
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) Pollution (PPC) Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC +
BIO)
Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD) Non-Financial corporates (Subject to NFRD)
Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount Gross carrying amount
Mn EUR
Of which environmentally
sustainable (CCM)
Mn EUR
Of which environmentally
sustainable (CCA)
Mn EUR
Of which environmentally
sustainable (WTR)
Mn EUR
Of which environmentally
sustainable (CE)
Mn EUR
Of which environmentally
sustainable (PPC)
Mn EUR
Of which environmentally
sustainable (BIO)
Mn EUR
Of which environmentally
sustainable (CCM + CCA +
WTR + CE + PPC + BIO)
1
C.14.1 - Manufacture of wearing apparel,
except fur apparel
3 0 - - - - - - - - - - 3 -
2
C.21.1 - Manufacture of basic
pharmaceutical products
1 0 - - - - - - - - - - 1 -
Note:
1. The 1.3 GAR sector information (CapEx Based) has been restated to disclose only NFRD taxonomy eligible and aligned sectors.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
616
EU Taxonomy Disclosure Tables (continued)
1.5
GAR KPI stock (Turnover Based)
A b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
% (compared to total covered assets
in the denominator)
Key:
31 December 202
3
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) 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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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
assets covered
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 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)
GAR
-
Covered assets in
both numerator and
denominator
1
Loans and advances, debt
securities and equity
instruments not HfT eligible
for GAR calculation
54% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 54% 0% 0% 0% 0% 28%
2 Financial undertakings 6% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 6% 0% 0% 0% 0% 9%
3 Credit institutions 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% 8%
4 Loans and advances 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% 1% 0% 0% 0% 0% 1%
5 Debt securities, including UoP 10% 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% 0% 0% 6%
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 Other financial corporations 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% 1% 0% 0% 0% 0% 1%
8 of which investment firms 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
9 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%
10 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%
11 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%
12
of which management
companies
0% 0% 0% 0% 0% 0% 0% 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 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%
14 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%
15 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%
16 of 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%
17 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%
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%
19 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%
20
Non-financial undertakings
(subject to NFRD disclosure
obligations)
0% 0% 0% 0% 0% 0% 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%
21 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%
22 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%
23 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%
24 Households 78% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 78% 0% 0% 0% 0% 18%
25
of which loans collateralised by
residential immovable property
100% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 100% 0% 0% 0% 0% 14%
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%
27 of which motor vehicle loans 4% 0% 0% 0% 0% 4% 0% 0% 0% 0% 1%
28 Local governments financing 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% 2% 0% 0% 0% 0% 0%
29 Housing financing 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%
30
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%
31
Collateral obtained by taking
possession: residential and
commercial immovable
properties
0% 0% 0% 0% 0% 0% 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%
32 Total GAR assets 27% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 27% 0% 0% 0% 0% 30%
Of which use of proceeds
Of which transitional
Of which enabling
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EU Taxonomy Disclosure Tables (continued)
1.6
GAR KPI stock (
CapEx
Based)
A b c d e f g h i j k l m n o p q r s t u v w x z aa ab ac ad ae af
% (compared to total covered assets in
the denominator)
Key:
31 December 202
3
Climate Change Mitigation (CCM) Climate Change Adaptation (CCA) Water and marine resources (WTR) Circular economy (CE) 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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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
assets covered
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
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)
GAR
-
Covered assets in both
numerator and denominator
1
Loans and advances, debt
securities and equity
instruments not HfT eligible
for GAR calculation
54% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 54% 0% 0% 0% 0% 28%
2 Financial undertakings 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% 9%
3 Credit institutions 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% 8%
4 Loans and advances 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% 1% 0% 0% 0% 0% 2%
5 Debt securities, including UoP 10% 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% 0% 0% 6%
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 Other financial corporations 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% 1% 0% 0% 0% 0% 1%
8 of which investment firms 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
9 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%
10 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%
11 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%
12
of which management
companies
0% 0% 0% 0% 0% 0% 0% 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 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%
14 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%
15 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%
16 of 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%
17 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%
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%
19 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%
20
Non-financial undertakings
(subject to NFRD disclosure
obligations)
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% 2% 0% 0% 0% 0% 1%
21 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%
22 Debt securities, including UoP 3% 1% 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 3% 1% 1% 1% 0% 0%
23 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%
24 Households 78% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 78% 0% 0% 0% 0% 18%
25
of which loans collateralised by
residential immovable property
100% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 100% 0% 0% 0% 0% 14%
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%
27 of which motor vehicle loans 4% 0% 0% 0% 0% 4% 0% 0% 0% 0% 1%
28 Local governments financing 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% 2% 0% 0% 0% 0% 0%
29 Housing financing 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%
30 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%
31
Collateral obtained by taking
possession: residential and
commercial immovable
properties
0% 0% 0% 0% 0% 0% 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%
32 Total GAR assets 27% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 27% 0% 0% 0% 0% 30%
Of which use of proceeds
Of which transitional
Of which enabling
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
618
EU Taxonomy Disclosure Tables (continued)
1.7
GAR KPI flow (Turnover Based)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to total covered assets in the
denominator)
Key:
31 December 202
3
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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 assets
covered
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 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)
GAR
-
Covered assets in both numerator
and denominator
1
Loans and advances, debt securities
and equity instruments not HfT eligible
for GAR calculation
30% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 30% 0% 0% 0% 0% 45%
2 Financial undertakings 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% 4% 0% 0% 0% 0% 24%
3 Credit institutions 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% 4% 0% 0% 0% 0% 22%
4 Loans and advances 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% 1% 0% 0% 0% 0% 13%
5 Debt securities, including UoP 9% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 9% 0% 0% 0% 0% 9%
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 Other financial corporations 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% 2% 0% 0% 0% 0% 2%
8 of which investment firms 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
9 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%
10 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%
11 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%
12 of which management companies 0% 0% 0% 0% 0% 0% 0% 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 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%
14 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%
15 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%
16 of 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%
17 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%
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%
19 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%
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% 1%
21 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% 1%
22 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% 1%
23 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%
24 Households 64% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 64% 0% 0% 0% 0% 20%
25
of which loans collateralised by residential
immovable property
100% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 100% 0% 0% 0% 0% 13%
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%
27 of which motor vehicle loans 12% 0% 0% 0% 0% 12% 0% 0% 0% 0% 1%
28 Local governments 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%
29 Housing 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%
30 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%
31
Collateral obtained by taking
possession: residential and commercial
immovable properties
0% 0% 0% 0% 0% 0% 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%
32 Total GAR assets 18% 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% 0% 0% 0% 0% 46%
Of which use of proceeds
Of which transitional
Of which enabling
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
619
EU Taxonomy Disclosure Tables (continued)
1
.
8
GAR KPI flow (CapEx Based)
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
af
% (compared to total covered assets in the
denominator)
Key:
31 December 202
3
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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 assets
covered
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 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)
GAR
-
Covered assets in both
numerator and denominator
1
Loans and advances, debt securities
and equity instruments not HfT
eligible for GAR calculation
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% 1% 0% 45%
2 Financial undertakings 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% 4% 0% 0% 0% 0% 24%
3 Credit institutions 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% 4% 0% 0% 0% 0% 22%
4 Loans and advances 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% 1% 0% 0% 0% 0% 13%
5 Debt securities, including UoP 9% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 9% 1% 0% 0% 0% 9%
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 Other financial corporations 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% 2%
8 of which investment firms 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
9 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%
10 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%
11 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%
12 of which management companies 0% 0% 0% 0% 0% 0% 0% 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 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%
14 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%
15 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%
16 of 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%
17 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%
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%
19 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%
20 Non-financial undertakings 10% 2% 2% 2% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 10% 2% 2% 2% 0% 1%
21 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% 1%
22 Debt securities, including UoP 20% 3% 3% 3% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 20% 3% 3% 3% 0% 1%
23 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%
24 Households 64% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 64% 0% 0% 0% 0% 20%
25
of which loans collateralised by residential
immovable property
100% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 100% 0% 0% 0% 0% 13%
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%
27 of which motor vehicle loans 12% 0% 0% 0% 0% 12% 0% 0% 0% 0% 1%
28 Local governments 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%
29 Housing 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%
30 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%
31
Collateral obtained by taking
possession: residential and
commercial immovable properties
0% 0% 0% 0% 0% 0% 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%
32 Total GAR assets 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% 19% 0% 0% 0% 0% 46%
Of which use of proceeds
Of which transitional
Of which enabling
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
620
EU Taxonomy Disclosure Tables (continued)
1.9
KPI stock off
-
balance sheet exposures (Turnover Based)
-
Restated
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off
-
balance sheet
assets)
31 December 2023
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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 (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
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)
1 Financial guarantees (FinGuar KPI) 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% 1% 0% 0% 0% 0%
2
Assets under management (AuM KPI)
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%
Note: The 1.9 KPI stock off-balance sheet exposures (Turnover Based) has been restated to reflect minor updates in 2023 counterparty’s taxonomy eligibility and alignment ratios.
1.10
KPI stock off
-
balance sheet exposures (CapEx Based)
Restated
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off
-
balance sheet
assets)
31 December 202
3
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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 (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
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)
1
Financial guarantees (FinGuar KPI)
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%
1
%
0%
0%
0%
0%
2
Assets under management (AuM KPI)
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%
Note: The 1.9 KPI stock off-balance sheet exposures (Turnover Based) has been restated to reflect minor updates in 2023 counterparty’s taxonomy eligibility and alignment ratios.
1.11
KPI flow off
-
balance sheet exposures (Turnover Based)
-
Restated
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off
-
balance sheet
assets)
1
31 December 202
3
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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 (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
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)
1 Financial guarantees (FinGuar KPI) 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% 1% 0% 0% 0% 0%
2 Assets under management (AuM KPI) 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
Note: The 1.9 KPI stock off-balance sheet exposures (Turnover Based) has been restated to reflect minor updates in 2023 counterparty’s taxonomy eligibility and alignment ratios.
1.12
KPI flow off
-
balance sheet exposures (CapEx Based)
-
Restated
a
b
c
d
e
f
g
h
i
j
k
l
m
n
o
p
q
r
s
t
u
v
w
x
z
aa
ab
ac
ad
ae
% (compared to total eligible off
-
balance sheet
assets)
1
31 December 202
3
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Circular economy (CE)
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 (Taxonomy-eligible)
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 (Taxonomy-eligible)
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 (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
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)
1 Financial guarantees (FinGuar KPI) 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% 1% 0% 0% 0% 0%
2 Assets under management (AuM KPI) 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%
Note: The 1.9 KPI stock off-balance sheet exposures (Turnover Based) has been restated to reflect minor updates in 2023 counterparty’s taxonomy eligibility and alignment ratios.
1 Future reports will provide detail on AUM EU Taxonomy Eligible and Aligned information, where possible, after collaboration with third party data vendors regarding existing data limitations.
Of which use of proceeds
Of which transitional
Of which enabling
Of which use of proceeds
Of which transitional
Of which enabling
Of which use of proceeds
Of which transitional
Of which enabling
Of which use of proceeds
Of which transitional
Of which enabling
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
621
EU Taxonomy Disclosure Tables (continued)
Information based on Annex XII in the Disclosures Delegated Act - Regulation (EU) 2021/2178
The disclosure requirements of Article 8(6) and (7) along with Annex XII of Regulation (EU) 2021/2178 were
inserted by the Complimentary Climate Delegated Act and applied from 1 January 2023. This Act included specific
nuclear and gas energy activities in the list of economic activities covered by the EU taxonomy. The criteria for
the specific gas and nuclear activities are in line with EU climate and environmental objectives and will help
accelerate the shift from solid or liquid fossil fuels, including coal, towards a climate-neutral future.
Row
Nuclear energy
related activities
1
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.
NO
2
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.
NO
3
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
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
The Group does not carry out any nuclear and fossil gas related activities. The Group has limited funding to fossil
gas related activities.
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
622
EU Taxonomy Disclosure Tables (continued)
Template 2 Taxonomy
-
aligned economic
activities (denominator)
31 December 2024
Economic activities based on KPI Turnover
Amount and proportion (the information is to be presented in monetary amounts
and as percentages)
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
million
%
million
%
million
%
1
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 the applicable KPI
- - - - - -
2
Amount 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 the applicable KPI
- - - - - -
3
Amount 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 the applicable KPI
- - - - - -
4
Amount 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 the applicable KPI
- - - - - -
5
Amount 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 the applicable KPI
- - - - - -
6
Amount 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 the applicable KPI
- - - - - -
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
91 2% 91 1% 0 0%
8
Total applicable KPI
91
2%
91
1%
0
0%
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
623
EU Taxonomy Disclosure Tables (continued)
Template 2 Taxonomy
-
aligned economic activities (denominator)
31 December 2024
Economic activities based on KPI CapEx
Amount and proportion (the information is to be presented in monetary amounts
and as percentages)
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
million
%
million
%
million
%
1
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 the applicable KPI
- - - - - -
2
Amount 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 the applicable KPI
- - - - - -
3
Amount 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 the applicable KPI
- - - - - -
4
Amount 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 the applicable KPI
- - - - - -
5
Amount 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 the applicable KPI
- - - - - -
6
Amount 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 the applicable KPI
- - - - - -
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
40 0% 40 0% 0 0%
8
Total applicable KPI
40
0%
40
0%
0
0%
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
624
EU Taxonomy Disclosure Tables (continued)
Template
3
Taxonomy
-
aligned economic activities (numerator)
31 December 2024
Economic activities based on KPI Turnover
Amount and proportion (the information is to be presented in monetary amounts
and as percentages)
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
million
%
million
%
million
%
1
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 the applicable KPI
- - - - - -
2
Amount 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 the applicable KPI
- - - - - -
3
Amount 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 the applicable KPI
- - - - - -
4
Amount 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 the applicable KPI
- - - - - -
5
Amount 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 the applicable KPI
- - - - - -
6
Amount 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 the applicable KPI
- - - - - -
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
91 100% 91 100% 0 0%
8
Total applicable KPI
91
100%
91
100%
0
0%
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
625
EU Taxonomy Disclosure Tables (continued)
Template
3
Taxonomy
-
aligned economic activities (numerator)
31 December 2024
Economic activities based on KPI CapEx
Amount and proportion (the information is to be presented in monetary amounts
and as percentages)
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
million
%
million
%
million
%
1
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 the applicable KPI
- - - - - -
2
Amount 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 the applicable KPI
- - - - - -
3
Amount 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 the applicable KPI
- - - - - -
4
Amount 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 the applicable KPI
- - - - - -
5
Amount 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 the applicable KPI
- - - - - -
6
Amount 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 the applicable KPI
- - - - - -
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
40 100% 40 100% 0 0%
8
Total applicable KPI
40
100%
40
1
0
0
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
626
EU Taxonomy Disclosure Tables (continued)
Template 4 Taxonomy
-
eligible but not taxonomy
-
aligned economic activities
31 December 2024
Economic activities based on KPI Turnover
Amount and proportion (the information is to be presented in monetary
amounts and
as percentages)
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
million
%
million
%
million
%
1
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 the applicable KPI
- - - - - -
2
Amount 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 the applicable KPI
- - - - - -
3
Amount 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 the applicable KPI
- - - - - -
4
Amount 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 the applicable KPI
- - - - - -
5
Amount 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 the applicable KPI
- - - - - -
6
Amount 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 the applicable KPI
- - - - - -
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
4,097 100% 4,097 100% 0 0%
8
Total amount and proportion of taxonomy eligible but not
taxonomy aligned economic activities in the denominator of the
applicable KPI
4,097 100% 4,097 100% 0 0%
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
627
EU Taxonomy Disclosure Tables (continued)
Template 4 Taxonomy-eligible but not taxonomy-aligned economic activities
31 December 2024
Economic activities based on KPI CapEx
Amount and proportion (the information is to be presented in monetary amounts and
as percentages)
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
million % million % million %
1
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 the applicable KPI
- - - - - -
2
Amount 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 the applicable KPI
- - - - - -
3
Amount 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 the applicable KPI
- - - - - -
4
Amount 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 the applicable KPI
- - - - - -
5
Amount 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 the applicable KPI
- - - - - -
6
Amount 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 the applicable KPI
- - - - - -
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
3,989 100% 3,988 100% 1 0%
8
Total amount and
proportion of taxonomy eligible but not taxonomy
aligned economic activities in the denominator of the applicable KPI
3,989 100% 3,988 100% 79% 0%
BANK OF CYPRUS HOLDINGS PUBLIC LIMITED COMPANY Annual Financial Report 2024
Additional Information – EU Taxonomy Disclosure Tables
628
EU Taxonomy Disclosure Tables (continued)
Template 5 Taxonomy non-eligible economic activities (Turnover)
31 December 2024
million %
1
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.26 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable KPI
- -
2
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.27 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable KPI
- -
3
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.28 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable KPI
- -
4
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.29 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable KPI
53 0%
5
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.30 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable KPI
- -
6
Amount and proportion of taxonomyaligned 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
- -
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
11,529 100%
8
Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of
theapplicable KPI
11,582 100%
Template 5 Taxonomy non-eligible economic activities (CapEx)
31 December 2024
million %
1
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.26 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable KPI
- -
2
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.27 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable KPI
- -
3
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.28 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable KPI
- -
4
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.29 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable KPI
53 0%
5
Amount and proportion of taxonomyaligned economic activity referred to in Section 4.30 of Annexes I and II to
Delegated Regulation 2021/2139 in the denominator of the applicable KPI
- -
6
Amount and proportion of taxonomyaligned 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
- -
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
11,692 100%
8
Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the
applicable KPI 11,745 100%
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