Integrity & Business Conduct Program (European Sustainability Reporting Standards – ESRS G1): Mandatory training on anti-corruption and anti-bribery practices, whistleblowing, and the Code of Ethics and Business Conduct.

BUSINESS: 453 PRACTICES

The initiative aims to systematically strengthen corporate integrity and responsible business conduct through a comprehensive framework of prevention, awareness, and compliance measures that spans the entire organization. Specifically, it seeks to: (a) enable the timely identification and prevention of corruption, bribery, and related risks; (b) foster a strong speak-up culture and enhance awareness of whistleblowing mechanisms; and (c) ensure the continuous alignment of all employees and governing bodies with the principles and values set out in the Code of Ethics and Business Conduct.

The initiative is addressed to the Bank’s/Group’s entire workforce, including senior management and members of the Board of Directors, ensuring a consistent understanding of integrity and compliance requirements across all levels of decision-making.
The initiative is of an annual and recurring nature, with a training cycle on the Code of Ethics and Business Conduct delivered each year. Training on Anti-Bribery and Whistleblowing is provided to every new employee upon joining the organization and is repeated annually for all employees.
CrediaBank implements a comprehensive Corporate Integrity Program, which forms an integral part of its annual structured training framework, as well as its updated corporate policies and guidance provided through the Code of Ethics and Business Conduct.
CrediaBank has been certified against internationally recognized management system standards, including ISO 37002 (Whistleblowing Management System), ISO 37301 (Compliance Management System), and ISO 37001 (Anti-Bribery Management System).
During the reporting year, specialized training courses were delivered through the Group’s e-learning platform, covering topics such as Anti-Bribery and Anti-Corruption, the Submission and Management of Named and Anonymous Reports (ISO 37002 – Whistleblowing), the Code of Ethics and Business Conduct, and Environmental, Social and Governance (ESG) principles. These training programs are part of the annual mandatory learning curriculum required under the applicable regulatory framework and are addressed to all employees, including senior executives.
At the same time, the Code of Ethics and Business Conduct is approved by the Bank’s Board of Directors, while any amendments or updates are formally adopted by the Boards of Directors of the Bank’s subsidiaries. The Code is reviewed annually to ensure its continued relevance and alignment with the principles and standards applied across the Group. Where revisions are deemed necessary, the Compliance and Corporate Governance Division submits recommendations to the Executive Committee and the Audit Committee of the Bank’s Board of Directors.
Furthermore, the Bank and all Group companies ensure, on an annual basis, that the Code is communicated to employees and formally acknowledged and accepted by all personnel, reinforcing a culture of integrity, accountability, and ethical conduct throughout the organization.

This initiative strengthens, in a practical and measurable way, employees’ awareness and capacity to identify, prevent, and address risks associated with unethical conduct and misconduct, while also promoting the responsible and secure use of whistleblowing mechanisms. Through annual mandatory training programs, a common understanding and a consistent baseline level of knowledge are established across the organization, including its governing bodies and senior management.
Key Performance Indicators (2025):
Τraining completion rate (total workforce): 99%
Τraining completion rate (senior management): 97%
Number of training modules/seminars delivered in 2025: 5 Code of Ethics and Conduct; Submission and Management of Identified and Anonymous Whistleblowing Reports (ISO Whistleblowing Framework); Anti-Bribery and Corruption; Employee Awareness on the Prevention and Management of Workplace Violence and Harassment; and Environmental, Social and Governance (ESG) principles.
The initiative is implemented at Group level, ensuring consistent coverage across the workforce and delivery through an online platform, thereby guaranteeing equal access regardless of geographical location.
Participation is structured and organization-wide, encompassing all employees, with particular emphasis placed on the involvement of senior management. This approach reinforces a strong “tone from the top” culture and ensures that the principles of integrity are applied consistently and cohesively across all business functions.
Participation is structured and comprehensive, encompassing all employees, with particular emphasis on the participation of senior executives. This approach strengthens the “tone from the top” and ensures that integrity principles are applied consistently and horizontally across all functions.
The initiative strengthens the Group’s institutional credibility and stakeholders’ trust, as it demonstrates a systematic and preventive approach to business conduct and compliance culture. Furthermore, the governance cycle of the Code of Ethics (approval, communication, publication, and oversight by the Board of Directors) ensures its continuous updating and ongoing alignment with evolving governance standards.
