Banco Comercial Portugues SA

### Governance and supervision model

Sustainability matters at the BCP Group are supervised by the Board of Directors (BoD), supported by the Committee for Corporate Governance, Ethics and Sustainability (CGSES), a body responsible for recommending the adoption by the Board of Directors of policies in line with ethical and social responsibility principles and best practices in corporate governance and sustainability matters and issuing opinions on the Sustainability Master Plan (SMP), Corporate Social Responsibility Plan (CSRP) and annual corporate governance and sustainability reports, with the Committee for Risk Assessment (CAvR) being responsible for identifying, assessing and monitoring ESG risks, including climate risk.

The Executive Committees (EC) of the Banks that make up the BCP Group are responsible for managing themes related to Sustainability, as an organisation and financing entity, with an impact on the value proposition, on the offer of products and services and on the support processes and operations, being assisted, in these functions, by the Sustainability Commissions (SC), bodies responsible for evaluating the integration of Sustainability principles in the Bank's decision-making and management processes, analyse and approve the initiatives necessary for the implementation of the actions defined to materialise the strategic axes of the Sustainability Master Plan and monitor their progress.

The Sustainability Units of the Banks that make up the BCP Group are responsible for proposing and implementing global and coherent sustainability and corporate social responsibility policies, which promote business development and risk management with the incorporation of environmental, social and governance principles and enhance the growth of the institution's reputation and its ability to add social and environmental value and respond to the needs and expectations of Stakeholders.

BCP's Sustainability Unit in Portugal (Office for Economic Studies, Sustainability and Supervision) is also responsible for ensuring the adequacy and compliance of the BCP Group's Sustainability practices with legal and regulatory requirements and with the expectations and recommendations of supervisory entities.

Sustainability matters at the BCP Group are supervised by the Board of Directors (BoD), supported by the Committee for Corporate Governance, Ethics and Sustainability (CGSES), a body responsible for recommending the adoption by the Board of Directors of policies in line with ethical and social responsibility principles and best practices in corporate governance and sustainability matters and issuing opinions on the Sustainability Master Plan (SMP), Corporate Social Responsibility Plan (CSRP) and annual corporate governance and sustainability reports, with the Committee for Risk Assessment (CAvR) being responsible for identifying, assessing and monitoring ESG risks, including climate risk. [...] The Executive Committees (EC) of the Banks that make up the BCP Group are responsible for managing themes related to Sustainability, as an organisation and financing entity, with an impact on the value proposition, on the offer of products and services and on the support processes and operations, being assisted, in these functions, by the Sustainability Commissions (SC), bodies responsible for evaluating the integration of Sustainability principles in the Bank's decision-making and management processes, analyse and approve the initiatives necessary for the implementation of the actions defined to materialise the strategic axes of the Sustainability Master Plan and monitor their progress. [...] The Sustainability Units of the Banks that make up the BCP Group are responsible for proposing and implementing global and coherent sustainability and corporate social responsibility policies, which promote business development and risk management with the incorporation of environmental, social and governance principles and enhance the growth of the institution's reputation and its ability to add social and environmental value and respond to the needs and expectations of Stakeholders. [...] BCP's Sustainability Unit in Portugal (Office for Economic Studies, Sustainability and Supervision) is also responsible for ensuring the adequacy and compliance of the BCP Group's Sustainability practices with legal and regulatory requirements and with the expectations and recommendations of supervisory entities.

In 2020, Millennium bcp revised its governance model, creating a Sustainability Commission, which emanates from the Executive Committee and is being chaired by the CEO. The Sustainability Commission is responsible for the evaluation, debate and supervision of the implementation of the Bank's Sustainability Strategy; [...] Already in 2021, the Bank reinforced the prioritization of the incorporation of Environmental, Social and Governance ("ESG") aspects into the business model by setting up a ESG dedicated division, reporting directly to the CEO, to support the formulation and implementation of business strategy, governance and risk management structures in accordance with ESG regulations and targets.

## Governance Model

According to the Bank's governance model, the Sustainability Commission, that emanates from the Executive Committee (EC) and is chaired by the CEO, is the body responsible for the appraisal, discussion and supervision of the implementation of the organization-wide sustainability strategy, which includes the economic, social, environmental, and climate changes components, having, among other, the following responsibilities:

- To assist the EC in integrating the principles of Sustainability (Environmental, Social and Corpora-te Governance) in the decision and management processes of the Bank;

- To assess and approve the initiatives required to implement the actions defined to materialize the strategic axes of the Sustainability Master Plan in force, as well as other changes or adapta-tions necessary to meet the defined objectives;

- To follow-up and monitor the progress of approved initiatives, compliance with the respective deadlines and budgets and the evolution of the results achieved, as well as the key performance indicators of the plan's multiple dimensions.

## Governance Model

According to the Bank's governance model, the Sustainability Commission, that emanates from the Executive Committee (EC) and is chaired by the CEO, is the body responsible for the appraisal, discussion and supervision of the implementation of the organization-wide sustainability strategy, which includes the economic, social, environmental, and climate changes components, having, among other, the following responsibilities:

- To assist the EC in integrating the principles of Sustainability (Environmental, Social and Corpora-te Governance) in the decision and management processes of the Bank;

- To assess and approve the initiatives required to implement the actions defined to materialize the strategic axes of the Sustainability Master Plan in force, as well as other changes or adapta-tions necessary to meet the defined objectives;

- To follow-up and monitor the progress of approved initiatives, compliance with the respective deadlines and budgets and the evolution of the results achieved, as well as the key performance indicators of the plan's multiple dimensions.

## Modelo de Governo

O Conselho de Administração (CA) tem a responsabilidade global pela estratégia, gestão e quadro de controlo ESG (Environmental, Social and _Governance) do Grupo BCP, incluindo a definição, aprovação e supervisão da_ implementação efetiva da estratégia ESG e do quadro de risco e respetiva agenda de implementação. O CA delega as competências específicas de gestão e controlo ESG em comissões especializadas, emanadas do CA, que supervisionam a gestão do risco e a sustentabilidade corporativa.

O Comité de Sustentabilidade, que emana da CE e é presidido pelo Chief Executive _Officer (CEO), é o órgão responsável pela avaliação, discussão e monitorização_ da implementação da estratégia de sustentabilidade em toda a organização.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]The role of the bank is indirect by promoting efficient business and creating awareness towards these topics. BCP promotes climate change and public awareness through several ways, namely: Support of community affairs projects aiming at climate change mitigation and adaptation; Private/public partnerships to encourage research and development of low carbon technologies; Engages with financial sector to discuss the integration of environmental and social risks; Developing credit lines for the acquisition of micro production of renewable energy equipment; Financing renewable energy projects; Promoting better availability and quality of climate change related company data; Discussion of climate change related topics in meetings/contacts with investors, clients and suppliers; among others. Millennium BCP also has sustainability guidelines addressed to suppliers and assessment of the compliance with the proposed socioenvironmental requirements.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes