ACRA CONFIRMED THE COMPLIANCE OF THE PLANNED ISSUE OF GAZPROMBANK (JOINT STOCK COMPANY) BONDS WITH THE ICMA GREEN BONDS PRINCIPLES AND THE NATIONAL GREEN BONDS STANDARD

ACRA HAS CONFIRMED THE COMPLIANCE OF THE PLANNED BOND ISSUE OF bank gpb (jsc) WITH THE GREEN BOND PRINCIPLES OF THE INTERNATIONAL CAPITAL MARKET ASSOCIATION (ICMA) AND the NATIONAL STANDARD; IT HAS CONFIRMED THE COMPLIANCE OF THE PROJECT REFINANCED AS PART OF THE ISSUE WITH INTERNATIONALLY RECOGNIZED PRINCIPLES, STANDARDS IN THE FIELD OF ECOLOGY AND GREEN FINANCe and the national standard

COMPLIANCE OF THE ISSUE WITH REGULATION OF THE BANK OF RUSSIA NO. 706-P DATED DECEMBER 19, 2019

As part of the planned bond issue of Bank GPB (JSC) (hereinafter, Gazprombank, the Bank, the Issuer, or the Initiator) ACRA verified the compliance of the bond issue with the internationally recognized goals, principles, standards, and criteria in the field of ecology and green finance (Green Bond Principles (GBP) of the ICMA), criteria for green financial instruments in accordance with Decree of the Government of the Russian Federation No. 1587 dated September 21, 2021 (hereinafter, the National Standard, or the Green Project Taxonomy), as well as compliance of the project refinanced using the proceeds from the bond issue with internationally recognized principles, standards in the field of ecology and green finance, and the National Standard.

The project being refinanced includes seven apartment building complexes with a living area of 582,800 sq. m and energy efficiency classes from A to A++ (hereinafter, the project), funds for the construction of which were previously allocated by the Issuer in the form of lending to its borrowers.

The project (see below) presented by the Issuer corresponds to the following areas of the Green Project Taxonomy:

• Green buildings.

The project corresponds to the following areas of the Green Project Taxonomy:

• 3.4. Construction of energy efficient buildings and structures.

The total volume of the issue in monetary terms had not been determined as of verification, but the Issuer confirmed to the Agency that it will not exceed the total amount of funds previously provided by the Issuer to finance the specified project.

The use of apartments in the seven analyzed apartment buildings allows positive effects to be achieved in terms of impact on the environment, which is expressed in the following (see Key assumptions for calculating environmental effects)¹:

• Reduction of annual consumption of heat compared to the base level (energy efficiency class D) — by 57,730,217.3 kWh;

• Reduction of annual consumption of electricity for general apartment building needs compared to the base level (energy efficiency class D) — by 2,566,114.0 kWh;

• Reduction of annual greenhouse gas emissions from the generation of heat compared to the base level (energy efficiency class D) — by 13,359.4 tons of CO₂ equivalent;

• Reduction of annual greenhouse gas emissions from the generation of electricity compared to the base level (energy efficiency class D) — by 893.0 tons of CO₂ equivalent.

ACRA confirms that the project refinanced using the proceeds from the green bond issue comply with all of the ICMA’s basic internationally recognized principles and standards in the field of ecology and green finance as amended in 2021 (2021 GBP) and the National Standard.

¹ Since the final volume of the issue in monetary terms was not determined at the time of verification, the environmental effect indicated in this press release may be adjusted based on the final volume of the placement. The issuer undertakes to present the final environmental effect in the report on the use of funds.

COMPLIANCE OF THE ISSUE WITH THE ICMA’S GREEN BOND PRINCIPLES

ACRA confirms that the Issuer’s planned bond issue complies with all the basic components of the 2021 GBP. The area in which proceeds will be used (project that is refinanced through the issue of bonds to achieve objectives that comply with ICMA project categories and has a positive environmental effect), process of evaluating and selecting projects, and management of proceeds and reporting presented in the Sustainable Finance Framework of Bank GPB (JSC) (hereinafter, the Framework)² are fully in line with 2021 GBP criteria and the National Standard, and consequently the planned bond issue can be considered as green.

² The document was submitted to the verifier as of verification. The Framework was adopted by the Bank of October 31, 2023 (Minutes No. 59, registration number No. VND-400-1 dated October 31, 2023) and posted on the Issuer’s website at https://www.gazprombank.ru/sustainability/management/corporate-governance-system-doc/.

KEY ISSUE PROPERTIES

Sources: ACRA, Issuer’s data

Gazprombank is one of Russia’s largest universal financial institutions that specializes in lending and other banking services for large businesses.

The Agency notes that the Bank is one of the leaders among Russian banks in terms of the volume of financial resources used to finance projects in the area of renewable energy, green construction, and increasing energy efficiency.

Gazprombank is a member of the United Nations Environment Program Finance Initiative (UNEP FI)³ and “undertakes to respect and fully comply with the principles of this initiative, integrating it into its own activities”.

The Bank’s key internal document of the in the field of sustainable development is the Sustainable Development Policy of Bank GPB (JSC)⁴, approved by the decision of the Bank’s board dated February 16, 2021 (hereinafter, the Policy). This Policy enshrines and formulates the principles of the Bank’s activities in the field of sustainable development.

The Bank has also approved a number of internal regulatory documents that determine different areas of sustainable development and their integration into the Bank’s activities, including the following:

–           Private Policy of Environmental Responsibility of Bank GPB (JSC), approved by the decision of the Bank’s management board on June 9, 2021;

–           Corporate Governance Code of GPB (JSC), approved by the decision of the Bank’s annual general meeting of shareholders on June 28, 2017;

–           Code of Corporate Ethics of GPB (JSC), approved by the decision of the Bank’s management board on May 19, 2021;

–           Sustainable Office Concept of GPB (JSC), approved by the decision of the Bank’s management board on August 26, 2022;

–           Anti-corruption Policy of GPB (JSC), approved by the decision of the Bank’s management board on December 10, 2014;

–           Information Security Policy of GPB (JSC), approved by the decision of the Bank’s management board on November 3, 2022;

–           Private Policy for the Processing and Protection of Personal Data at GPB (JSC), approved by the Deputy Chairman of the Bank’s management board on May 21, 2021.

The Issuer has developed and approved the Framework, which outlines its approaches to the procedure for preparing and placing green bonds: it describes the process of preliminary assessment and selection of projects, provides the requirements for green projects financed (refinanced) by issuing green bond; indicates permitted areas for the use of funds (as per the National Green Project Taxonomy and the ICMA’s eligible project categories), and describes the approaches to managing attracted funds, as well as the principles of verification and reporting.

KEY ASSESSMENT FACTORS

The Issuer provided ACRA with documents containing project eligibility criteria that can be included in the green bond issue, project selection process, and the approaches to managing proceeds and reporting. ACRA drew conclusions on the compliance of the bond issue with the four components of the 2021 GBP based on these documents.

Use of proceeds

The Issuer plans to use the proceeds from the issuance of the analyzed issue of green bonds to refinance (replenish the funds previously assigned for financing) the project that is aimed at preventing climate change, and are consistent with internationally recognized goals, principles, standards and criteria in the field of ecology and green finance, as well as the goals and main areas of sustainable (including green) development of the Russian Federation and criteria for sustainable (including green) development projects in the Russian Federation (Green Project Taxonomy).

The Issuer plans to refinance the project specified on page 1 of this press release using funds from the bond issuance.

All of the proceeds from the analyzed green bond issue will be used solely to refinance the abovementioned project, which can be included in the following ICMA project category as per the 2021 GBP:

• Green buildings.

The project being refinanced includes seven apartment building complexes with a living area of 582,800 sq. m and energy efficiency classes from A to A++. Three complexes have energy efficiency class A, one complex has energy efficiency class A+, three complexes have combined energy efficiency classes for different objects — from A to A++. Data on energy efficiency classes were confirmed by extracts from the Unified Information System for Housing Construction (hereinafter, the UISHS).

The Agency confirms that, based on the above information, the analyzed project corresponds to the following area of the green project taxonomy:

• 3.4. Construction of energy-efficient buildings and structures (compliance criteria: for apartment buildings, energy efficiency classes A (very high), A+ (highest) and A++ (highest), determined by the state construction supervision body in accordance with the rules approved by the authorized federal executive body for determining the energy efficiency class of apartment buildings).

The Issuer provided the Agency with:

(1)    The final version of the Framework;

(2)    ACRA’s questionnaire filled out by the Issuer;

(3)    Information about project implementation, including goals and short descriptions, as well as environmental impact and the stages of readiness.

(4)    Calculation of the climate and environmental effects;

(5)    The draft report on the use of proceeds;

(6)    Information about the volume of financial resources previously provided by the Issuer to carry out the project;

(7)    Draft decision on the issue of securities;

(8)    Model report on the placement of funds raised from the green bond issue;

(9)    Additional materials provided at the Agency’s request

According to the information provided by the Issuer, the analyzed project does not have federal or regional significance and therefore is not subject to mandatory state ecological expertise.

ACRA notes that the project refinanced by the Issuer does not have any significant side effects for the environment (Do No Significant Harm principle): environmental protection law of the Russian Federation is observed when implementing the project.

According to data provided by the Issuer, as of the date of publication of this press release, six out of seven apartment building complexes are under construction and have not been put into operation, for one complex the start of construction is planned for Q1 2024.

ACRA considers the calculations and key assumptions made by the Issuer to calculate the expected environmental effect produced by the project to be acceptable.

Process of evaluating and selecting projects

The Issuer has confirmed to ACRA that the evaluation and selection of project refinanced using the proceeds from the analyzed issue are carried out as per the procedure specified in the Framework.

In general, the assessment and selection of potential projects that can be financed and/or refinanced through the issuance of green bonds is carried out by the Bank’s Committee for Business Development and the Introduction of New Products that Comply with Sustainable Development Principles (hereinafter, the Committee). The Committee is formed on a cross-functional basis and includes representatives of the Bank’s structural divisions whose activities are related to various aspects of sustainable development. The Committee’s Commission are set out in the Framework.

After the Committee develops criteria for the Bank’s green and social projects, they are approved by the Council for the Implementation of Sustainable Development Principles in the Bank’s Activities (hereinafter, the Council).

As per the approved criteria for green and social projects of the Bank, an independent structural division of the Bank, the Center for Implementing Sustainable Development Principles (hereinafter, the CISDP), selects sustainability projects and includes them in the Sustainable Development Project Register (hereinafter, the Register).

The CISDP and the Committee regularly monitor the Register for compliance with the stated goals and criteria for included sustainable development projects that are targeted for financing and/or refinancing at the expense of the Bank’s funds received as a result of issuing green bonds or implementing other sustainable development financing instruments.

If at any stage of selection a project is recognized as not complying with the requirements for sustainable development projects, further work on including the project in the list of sustainable development projects for financing and/or refinancing at the expense of the Bank’s funds received as a result of issuing green bonds (including inclusion in the Register) is suspended and the Bank is required to replace it with a different project that complies with the requirements.

In accordance with the data provided by the Issuer, the project refinanced using the proceeds from the analyzed issue was selected in accordance with the procedure outlined above.

In accordance with the data provided by the Issuer, during the life of the project, regular monitoring is carried out to ensure that there is no significant level of risk in accordance with the early warning system and other internal documents of the Bank as part of the Bank’s general corporate risk management system.

The issuer also assesses the conformity of the project based on information from open sources and documentation received from the developer, which may include, among other things: information about the stage of implementation of each building, the compliance of the buildings with the specified energy efficiency classes, the presence of external certificates, etc.

The target indicators of the environmental effect from the implementation of the project, which are analyzed during the internal risk assessment, are:

• Reduction of annual consumption of heat compared to the base level (energy efficiency class D);

• Reduction of annual consumption of electricity for general apartment building needs compared to the base level (energy efficiency class D);

• Reduction of annual greenhouse gas emissions from the generation of heat compared to the base level (energy efficiency class D);

• Reduction of annual greenhouse gas emissions from the generation of electricity compared to the base level (energy efficiency class D).

Social risks are managed as part of the overall corporate ESG risk management system. The following risks are taken into account as part of regular monitoring of the Project’s social risks:

Risk of non-compliance with Russian law in terms of labor law and legal requirements for such social aspects as human rights, discrimination, absence of forced labor, etc.;

• Risk of negative impact on the regions of presence and local communities;

• Mass layoffs or information about a significant reduction in personnel numbers;

• Unstable political or economic situation in the region;

• Presence of social unrest or strikes and other factors.

If risks, non-compliance with the initially selected parameters, or failure to achieve target effects are identified at any stage of project implementation, measures are taken to assess the significance of this risk and the applicability of the green criteria approved by the Bank to this project is reviewed. If a project does not meet the criteria, it may be excluded from the register.

ACRA also confirms that the project refinanced using the assessed green bond issue is consistent with the Policy, which, in particular, states “encouraging the implementation of the Sustainable Development Principles, Responsible Financing and Investment Mechanisms and promoting economic activity for the shared prosperity of current and future generations”. In addition, the implementation of the analyzed project correlates with the following objectives of the Bank’s activities in the field of sustainable development specified in the Policy:

• 2.2.6. Minimizing the negative impact of the Bank’s internal and external activities on the environment;

• 2.2.8. Participating in the creation of a low-carbon economy, developing green investment and finance instruments;

• 2.2.9. Promoting the development of responsible financing and investment instruments, including, but not limited to, sustainable development bonds and green lending;

• 2.2.12. Improving ESG project support measures.

The calculations of environmental effects were carried out directly by the Issuer without the involvement of external experts. At the same time, the Agency notes that the structuring of the issue, preparation of the Sustainable Finance Framework and calculation of the environmental effect were carried out by a dedicated consultancy division of the Bank (ESG Advisory Department), which possesses sufficient expertise in structuring financial instruments for sustainable development and calculating environmental effects.

The project selected by the Issuer for the analyzed issue falls under the following 2021 GBP category:

• Green buildings.

The project correlates with the following UN Sustainable Development Goals (SDGs):

• SDG 9: Build resilient infrastructure, promote inclusive and sustainable industrialization and foster innovation;

• SDG 11: Make cities and human settlements inclusive, safe, resilient and sustainable.

In ACRA’s opinion, the described algorithm generally evidences that the project evaluation and selection procedure is effective.

Management of proceeds

The Issuer has confirmed to the Agency that proceeds from the analyzed green bond issue will be managed in accordance with the mechanism outlined in the Framework. The Issuer plans to use the funds from the placement of the analyzed green bonds in full to refinance the above project. There are no temporarily unused funds for the analyzed issue. Subsequent management of the portfolio of green projects will be carried out by the Issuer in accordance with the procedure outlined below.

In accordance with the Framework, authorized employees and internal divisions of the Bank will regularly monitor the amount of green bond issue proceeds and the amount of funds allocated by the Bank to finance and/or refinance relevant sustainable development projects.

The main tool for regular monitoring of the volume of these funds is the Register, which is maintained by the CISDP jointly with the Committee. The Register contains sustainable development projects that have passed the evaluation and selection procedures, and transactions with any issue proceeds and allocated by the Bank to finance and/or refinance relevant sustainable development projects.

If a financed and/or refinanced project ceases to meet the sustainable development criteria established in the Framework, or if a loan issued by the Bank for the implementation of a relevant sustainable development project has been repaid early, the Bank will substitute the project with another sustainable development project that meets these criteria. At the same time, the amount of funds allocated for financing and/or refinancing sustainable development projects should not be less than the amount raised by the Bank from the issue of green bonds.

In accordance with the Framework, the Bank strives to maintain the volume of financing and/or refinancing of relevant sustainable development projects at a level not lower than the nominal value of the green bonds.

If during the circulation period the nominal value of the green bonds exceeds the value of the financed and/or refinanced sustainable development projects, excess funds will be invested in the Bank’s liquidity management instruments denominated in Russian rubles.

In addition, the Issuer undertakes to disclose information on the facts and volume of misuse of funds from the placement of green bonds in the form of a message on a material fact regarding the misuse of funds from the placement of exchange-traded bonds, published on the website https://www.gazprombank.ru/.

The Issuer undertakes to ensure verification and disclosure of information about the intended use of funds from the placement of exchange-traded bonds in the report on the use of funds, which is a green tool for monitoring the intended use of funds.

In addition, the Issuer undertakes to disclose, in the form of a statement of material fact, information about identifying and the essence of a violation of the National Standard and GBP-2021 during the implementation of the project for the refinancing of which funds from the placement of Exchange-traded bonds will be used. The Issuer undertakes to disclose statements of material fact about the misuse of funds in the News Feed no later than 1 (one) business day from the date on which the Issuer learned or should have learned about the fact of misuse of funds from the placement of green bonds, and a notice of a material fact must contain, among other things:

• Identification features of green bonds;

• Description of the fact(s) of misuse of funds from the placement of exchange-traded bonds, including the amount of funds that were allocated for purposes not provided for by the Decision on the Issue, the period of time during which the misuse of funds took place, the reason (reasons) for violation of the condition on the intended use of funds from the placement of exchange-traded bonds, and information on the fact and volume of misuse of funds from the placement of green bonds.

The consequences of misuse of funds from the placement of exchange-traded bonds are not provided for by the Issue Decision.

The Issuer also undertakes to disclose information about the fact of inclusion of bonds in the list of financial instruments for sustainable development and the fact of exclusion of these bonds from the list of financial instruments for sustainable development, indicating the date of such inclusion or exclusion in the report on the use of funds.

In accordance with the data provided by the Issuer, the specified control mechanisms are applied for the analyzed issue and the refinanced project.

In ACRA’s opinion, the procedure for managing the green bond issue proceeds generally complies with the 2021 GBP and the National Standard.

Reporting

The Issuer will prepare reports on the use of proceeds from the bond issue and engage a third-party verifier to conduct an independent external assessment of these reports.

The Issuer undertakes to disclose a report on the use of funds from the placement of green bonds on the website https://www.gazprombank.ru/ no later than 2 (two) business days from the date the Issuer signs the report on use of funds from the placement of green bonds, but no later than 150 days from the end of the corresponding reporting year.

The Issuer has prepared and presented to ACRA a draft report on the use of issue proceeds, which includes the following:

(1)    Project name;

(2)    Project description (subject to confidentiality requirements);

(3)    Approved volume of project refinancing from issue proceeds;

(4)    Share of project refinancing from other sources;

(5)    Information on spending (allocation) of bond issue proceeds;

(6)    Information on spending (allocation) of bond issue proceeds in the reporting period;

(7)    Information on managing any non-allocated proceeds;

(8)    Information on the achievement of qualitative and quantitative goals of the project, as specified in the green bond issue decision;

(9)    Confirmations that the project described in the green bond issue decision is being implemented and information on actual allocation of issue proceeds;

(10) Project progress as of the reporting date.In ACRA’s opinion, the reporting procedure fully complies with the 2021 GBP and the National Standard.

Organizational structure and strategy

According to the Issuer, to support the execution of the Board’s decisions, as well as to coordinate the work of the Bank’s divisions for sustainable development and internal expertise, the CISDP has been established. In addition, the Bank has established a Department for Consulting on Credit Ratings and Sustainable Development, whose employees have sufficient experience in developing models for assessing environmental and climate effects from project implementation, as well as experience in preparing documents in the field of responsible financing.

The Issuer has developed and approved the Framework and adopted a number of documents regulating the Issuer’s sustainable development and ESG risk management practices (see pages 2–3 of this press release).

ACRA highly assesses the degree of integration of the sustainable development principles into the Issuer’s policies and procedures. The issuer has joined a global initiative (see page 3 of this press release) — the United Nations Environment Program Finance Initiative (UNEP FI), which has a positive impact on the assessment.

The Agency assesses the overall quality of the Issuer’s corporate governance and strategic planning as high.

Financial feasibility of the project

ACRA assesses the financial feasibility of the project as high. At the same time, the Agency will assess the project implementation as part of the standard monitoring procedure.

key assumptions for calculating environmental effects

The expected environmental effect is characterized by green apartment buildings with energy efficiency classes A, A+, A++⁵, which ensures reduced energy consumption compared to buildings with the base energy efficiency class (D), and reduces indirect energy emissions of greenhouse gasses associated with the generation of consumed energy resources.

The following indicators were selected for the quantitative evaluation of the environmental effect:

• Reduction of annual heat energy consumption for heating, ventilation, hot water supply in apartment buildings compared to the base energy efficiency class D, kWh or Gcal;

• Reduction of annual electric energy consumption for general apartment building needs compared to the base energy efficiency class D, kWh;

• Annual reduction in greenhouse gas emissions (CO₂ equivalent) from heat energy generation by reducing the consumption of heat energy in apartment buildings compared to the base energy efficiency class D, tons of CO₂ equivalent;

• Reduction of annual GHG emissions (CO₂ equivalent) from electric energy generation by reducing the consumption of electric energy in apartment buildings compared to the basic energy efficiency class D, tons of CO₂ equivalent.

The greenhouse gas emission factor from heat energy generation was estimated using the regional method in accordance with the approaches set out in the Methodological Guidelines for Quantifying the Volume of Indirect Energy Emissions of Greenhouse Gases approved by Order of the Ministry of Natural Resources and Ecology of the Russian Federation No. 330 dated June 29, 2017. The greenhouse gas emission factor from electricity generation was determined using data from ATS JSC (the Trading System Administrator).

For the purposes of quantitative assessment, based on conservative assumptions, it was assumed that all green buildings have energy efficiency class A, which ensures a reduction in energy consumption by 40% compared to the base energy efficiency class D.

The calculations of the environmental effect take into account the reduction of greenhouse gas emissions only from the generation of energy resources consumed by residential buildings. The calculations do not include the reduction of emissions from the full life cycle of energy resources (extraction, transportation and processing of energy resources, design, construction, operation and dismantling of generation facilities, etc.).

⁵ In accordance with Order of the Ministry of Construction and Utilities of the Russian Federation dated June 6, 2016 No. 399/pr “On approval of the Rules for determining the energy efficiency classes of apartment buildings” (registered with the Ministry of Justice of Russia on August 8, 2016 No. 43169).

assessment components

Compliance of the issue with the 2021 GBP: yes.

Assessment score: GR1.

Appendix 1. Compliance of the bond issue with the criteria in Decree of the Government of the Russian Federation No. 1587 dated September 21, 2021 “On approval of the criteria for sustainable (including green) development projects in the Russian Federation and requirements for the system for verifying sustainable development finance instruments in the Russian Federation”

ACRA has also verified the bond issue and the project refinanced using the proceeds from the issue for compliance with the criteria set by Decree of the Government of the Russian Federation dated September 21, 2021 No. 1587 and the criteria for green projects (Green Project Taxonomy).

Conclusion

The assessed financial instrument (bonds) complies with the abovementioned criteria.

Verification methodology

The assessment of the bonds for compliance with internationally recognized environmental and/or green finance principles and standards and the project to be refinanced using the bond issue proceeds was carried out using the Methodology for Green Debt Obligation Assessment with regard to green bonds.

Activities performed

Documents and other information presented by the Issuer were reviewed by the Agency for compliance with the abovementioned criteria, as well as for correctness and reliability.

The Issuer provided the Agency with:

(1)    The final version of the Framework;

(2)    The Agency’s questionnaire filled out by the Issuer;

(3)    Information about project implementation, including goals and short descriptions, as well as environmental impact and the stages of readiness.

(4)    Calculation of the climate and environmental effects;

(5)    The draft report on the use of proceeds;

(6)    Information about the volume of financial resources previously provided by the Issuer to carry out the project;

(7)    Draft decision on the issue of securities;

(8)    Model report on the placement of funds raised from the green bond issue;

(9)    Additional materials provided at the Agency’s request.

A number of interviews were held with the Initiator.

Confirmation of independence of judgment and absence of conflicts of interest or other circumstances that impede proper, objective and impartial analysis and judgment

See page 14 of this press release.

Confirmation of the type of sustainable development financial instrument declared by the Initiator

Green finance instrument (green bond).

Is the Initiator liable for non-compliance of the sustainable development financial instrument with the requirements?

No.

Compliance of the sustainable development projects with one or more areas stipulated by the criteria for sustainable development projects

–           3.4. Construction of energy efficient buildings and structures.

Information about the Initiator and the sustainable development projects

See p. 2–3 of this press release.

Areas and goals of refinancing the selected portfolio of green projects

Area: Construction.

Goal 1: reduction of greenhouse gas emissions.

Goal 2: energy saving and higher resource consumption efficiency.

Compliance of the bond issue with the requirements set by the Bank of Russia in line with the law of the Russian Federation on securities issues for bonds whose issue or prospectus contains additional identification using the words “green bonds”

Complies (for extended confirmation, see pages 1–3 of this press release).

Assessment of the compliance of the financed sustainable development projects with the criteria for sustainable development projects

Complies (see p. 2–4 of this press release).

Analysis of the purposes for which the proceeds are used and the procedures for providing recommendations on the use and management of proceeds

Complies (see pages 5–11 of this press release).

Analysis of procedures for selection and approval of sustainable development projects

Complies (see p. 4–5 of this press release).

Analysis of control over the implementation of sustainable development projects

Complies (see p. 4–5 of this press release).

Values of indicators and independent confirmation of the expected environmental effect from the implementation of the sustainable development projects

The Issuer presented the calculations of the following environmental effects:

The expected environmental effect from the use of apartments in the seven apartment buildings under review is expressed in the following (see Key assumptions for calculating environmental effects):

• Reduction of annual consumption of heat compared to the base level (energy efficiency class D) — by 57,730,217.3 kWh;

• Reduction of annual consumption of electricity for general apartment building needs compared to the base level (energy efficiency class D) — by 2,566,114.0 kWh;

• Reduction of annual greenhouse gas emissions from the generation of heat compared to the base level (energy efficiency class D) — by 13,359.4 tons of CO₂ equivalent;

• Reduction of annual greenhouse gas emissions from the generation of electricity compared to the base level (energy efficiency class D) — by 893.0 tons of CO₂ equivalent.

Expected environmental effects of green projects

See page 2 of this press release.

Information about the presence (absence) of conflicts of interest and independence of judgment

No conflicts of interest were identified as part of the assessment process (see page 14 of this press release).

ADDITIONAL INFORMATION

The assessment of the bond issue of Bank GPB (JSC) and the project by the bond issue for compliance with internationally recognized goals, principles, standards, and criteria in the field of ecology and green finance (2021 GBP), as well as with requirements for the verification of sustainable (including green) development projects in the Russian Federation has been performed based on the Methodology for Green Debt Obligation Assessment with regard to green bond assessment and the Key Concepts Used by the Analytical Credit Rating Agency within the Scope of Its Rating Activities.

The compliance assessment may be revised within one year following the publication date of this press release.

ACRA’s opinion on the compliance of the bond issue of Bank GPB (JSC) and the project refinanced by the bond issue with internationally recognized goals, principles, standards, and criteria in the field of ecology and green finance (2021 GBP) is based on data provided by Bank GPB (JSC), information from publicly available sources, and ACRA’s own databases.

The assessment of compliance of the bonds of Bank GPB (JSC), as well as the project refinanced by the bond issue with internationally recognized goals, principles, standards, and criteria in the field of ecology and green financing (2021 GBP) was solicited and Bank GPB (JSC) participated in the assessment process.

In assigning the assessment, ACRA used only information, the quality and reliability of which were, in ACRA’s opinion, appropriate and sufficient to apply the methodologies.

No conflicts of interest were discovered in the course of the assessment process.

The assigned assessment is not a credit rating.