Please note that in accordance with the requirements of Art. Art. 8, 11 of the Law of Ukraine "On prevention and counteraction of legalization (laundering) of proceeds obtained through crime, financing of terrorism and financing of proliferation of weapons of mass destruction" No. 361-IX dated 06.12.2019. (hereinafter referred to as the Law) the Bank, as a subject of primary financial monitoring, is obliged to carry out due diligence of new clients, as well as existing clients (representatives of clients).

Due diligence - measures that include:

• identification* and verification** of the client (his representative);
• establishing the ultimate beneficial owner of the client or its absence, including obtaining the ownership structure for the purpose of understanding it, and data that make it possible to establish the ultimate beneficial owner, and taking measures to verify his identity (if available);
• establishing (understanding) the purpose and nature of future business relations or carrying out a financial transaction;
• conducting on an ongoing basis monitoring of the client's business relations and financial transactions carried out in the course of such relations, regarding the compliance of such financial transactions with the information available to the subject of primary financial monitoring about the client, his activities and risk (including, if necessary, about the source of funds related to financial transactions);
• ensuring the relevance of received and existing documents, data and information about the client;

Identification and verification of the client is carried out before establishing business relations, making transactions, carrying out a financial transaction, opening an account.

The Bank is obliged to update*** data about the client in the process of servicing the client. The frequency of information clarification depends on the type of activity and type of financial operations carried out by the client, and is carried out by the Bank on a periodic basis. In addition, mandatory updating of identification data is carried out in the event of:

• expiration (termination) of validity, loss of validity or recognition of invalidity of the submitted documents (including in the case of pasting a new photo card in the client's passport upon reaching the age of 25 or 45 or the expiration of the validity period of the ID card);
  Also, it is necessary to inform the bank about:
• change of persons who have the right to dispose of accounts and change of their identification data;
• change of place of residence or place of stay or place of temporary stay in Ukraine of the client - a natural person (client's representative);
• acquisition by the client (client representative) of the status of a politically significant person, a person close to or connected with a politically significant person

In this regard, if there are any of the above-mentioned grounds or if the Bank is notified of the need to update identification information, please find an opportunity and provide the Bank with a completed questionnaire**** and relevant supporting documents.

In the event that the Bank does not receive a completed survey letter and/or relevant supporting documents from the client, which will testify to the failure to identify or update information about the client, the Bank will be forced, in accordance with the requirements of Art. Art. 15 of the Law, as well as Art. 64 of the Law of Ukraine "On Banks and Banking Activity" N 2121-III dated December 7, 2000 (as amended), to suspend further financial operations on the client's accounts, including refuse to maintain business relations (including by terminating business relations).

If you have any questions, please contact the contact center of Piraeus Bank in Ukraine 0 800 30 888 0 (calls within Ukraine are free) or the Bank's service department.

*Identification - measures taken by the bank to establish a person by obtaining his identification data

**Verification - measures taken by the bank for the purpose of checking (confirming) the ownership of the identification data received by the subject of primary financial monitoring to the relevant person and/or for the purpose of confirming data that make it possible to establish the ultimate beneficial owners or their absence;

***Update of information about the client - update of data about the client, including identification data, by obtaining documentary confirmation of the presence (absence) of changes in them.

• "ultimate beneficial owner (controller)", "national public figures", "foreign public figures" and others, are used in the meanings given in the Law of Ukraine "On prevention and counteraction of legalization (laundering) of proceeds obtained through crime, financing of terrorism and financing the proliferation of weapons of mass destruction";
• "controlled foreign companies" (CFCs) are used in the meaning given in the Tax Code of Ukraine.

Other terms, including, but not limited to, "FATCA", "CRS" are used in the meanings given in the relevant acts of legislation and/or international treaties, the binding consent of which was given by the Verkhovna Rada of Ukraine and/or the treaty.

The ultimate beneficial owner (controller) is any natural person who exercises decisive influence (control) on the client's activities and/or the natural person on whose behalf a financial transaction is conducted.

The ultimate beneficial owner is:

• for legal entities - any natural person who exerts a decisive influence on the activities of a legal entity (including through the chain of control/ownership);
• for trusts formed in accordance with the legislation of the country of their formation - the founder, trustee, protector (if any), beneficiary (beneficiary) or a group of beneficiaries (beneficiaries), as well as any other natural person who exerts a decisive influence on the activities of the trust (including through the chain of control/possession);
• for other similar legal entities - a person who has a status equivalent or similar to the persons specified for trusts.

Direct ownership by a natural person of a share of at least 25 percent of the authorized (compounded) capital or voting rights of a legal entity is a sign of direct decisive influence on the activity.

Signs of exercising indirect decisive influence on the activity are at least ownership by a natural person of a share of at least 25 percent of the authorized (composite) capital or voting rights of a legal entity through related natural or legal persons, trusts or other similar legal entities, or exercising decisive influence by exercise the right to control, own, use or dispose of all assets or their share, the right to receive income from the activities of a legal entity, trust or other similar legal entity, the right to have a decisive influence on the formation of the composition, the voting results of management bodies, as well as the execution of transactions that give the opportunity determine the basic conditions of the economic activity of a legal entity, or the activity of a trust or other similar legal entity, make binding decisions that have a decisive impact on the activity of a legal entity, trust or other similar legal entity, regardless of formal ownership.

At the same time, the ultimate beneficial owner cannot be a person who has a formal right to 25 percent or more of the authorized capital or voting rights in a legal entity, but is a commercial agent, nominal owner or nominal holder, or only an intermediary in relation to such a right.

National public figures are natural persons who perform or have performed important public functions in Ukraine, namely:

• The President of Ukraine, the Prime Minister of Ukraine, members of the Cabinet of Ministers of Ukraine and their deputies;
• the head of the permanent auxiliary body established by the President of Ukraine, his deputies;
• the head and deputy heads of the State Administration of Affairs;
• heads of offices (secretariats) of state bodies, who are not civil servants, whose positions belong to category "A";
• Secretary and Deputy Secretary of the National Security and Defense Council of Ukraine;
• people's deputies of Ukraine;
• Chairman and members of the Board of the National Bank of Ukraine, members of the Council of the National Bank of Ukraine;
• chairmen and judges of the Constitutional Court of Ukraine, the Supreme Court, higher specialized courts;
• members of the High Council of Justice, members of the High Qualification Commission of Judges of Ukraine, members of the Qualification and Disciplinary Commission of Prosecutors;
• Prosecutor General and his deputies;
• Head of the Security Service of Ukraine and his deputies;
• Director of the National Anti-Corruption Bureau of Ukraine and his deputies;
• Director of the State Bureau of Investigation and his deputies;
• Director of the Bureau of Economic Security of Ukraine and his deputies;
• Chairman and members of the National Council of Ukraine on Television and Radio Broadcasting, Chairman and members of the Antimonopoly Committee of Ukraine, Chairman of the National Agency for the Prevention of Corruption and his deputies,
• Chairman and members of the Accounting Chamber, Chairman and members of the Central Election Commission, chairs and members of other state collegial bodies;
• ambassadors extraordinary and plenipotentiary;
• chief of the General Staff - Commander-in-Chief of the Armed Forces of Ukraine, commanders of the Ground Forces of the Armed Forces of Ukraine, Air Forces of the Armed Forces of Ukraine, Naval Forces of the Armed Forces of Ukraine;
• civil servants whose positions belong to category "A";
• heads of prosecutor's offices, heads of regional territorial bodies of the Security Service of Ukraine, chairmen and judges of appeal courts;
• heads of administrative, management or supervisory bodies of state and state-owned enterprises, business associations, the state share in the authorized capital of which directly or indirectly exceeds 50 percent;
• members of governing bodies of political parties;

Foreign public figures are natural persons who perform or have performed significant public functions in foreign countries, namely:

• head of state, government, ministers (deputies);
• members of parliament or other bodies performing the functions of the legislative body of the state;
• heads and members of boards of central banks or accounting chambers;
• members of the Supreme Court, the Constitutional Court or other judicial bodies whose decisions are not subject to appeal, except for appeals in connection with exceptional circumstances;
• ambassadors extraordinary and plenipotentiary, chargé d'affaires and heads of central military administration bodies;
• heads of administrative, management or supervisory bodies of state-owned enterprises;
• members of governing bodies of political parties;

Officials who perform public functions in international organizations - officials of international organizations who hold or have held the position of head (director, chairman of the board or other) or deputy head in such organizations or perform or have performed any other leading (significant public) functions on at the highest level, including in international intergovernmental organizations, members of international parliamentary assemblies, judges and leading officials of international courts.

Family members - husband/wife or persons equivalent to them, son, daughter, stepson, stepdaughter, adopted person, person under guardianship or guardianship, son-in-law and daughter-in-law and persons equivalent to them, father, mother, stepfather, stepmother , adoptive parents, guardians or custodians.

Persons related to politically significant persons are natural persons who meet at least one of the following criteria:

• such persons are known to have joint beneficial ownership of a legal entity, trust or other similar legal entity with a politically significant person or to have any other close business ties with politically significant persons;
• are the ultimate beneficial owners of a legal entity, trust or other similar legal entity known to have been created de facto for the benefit of politically significant individuals;

"Controlled foreign companies" (CFCs) are any legal entity or entity without the status of a legal entity, registered in a foreign country or territory, which is recognized as being under the control of a natural person - a resident of Ukraine or a legal entity - a resident of Ukraine, respectively to the rules defined by the PKU

A passive NFO is an organization that meets the following criteria:

• Passive income ≥ 50% of gross income and ≥ 50% of assets generate passive income for the previous calendar year
• Is not a public or related company
• Not owned or owned by a government, international organization, central bank
• It is not a holding NFO – a member of a group that performs activities other than financial
• Is not a newly formed NFO that does not plan to carry out financial activities
• Is not an NFO that is at the stage of liquidation / in the bankruptcy procedure;
• Is not a center of financial management - a member of a group that carries out activities other than financial
• Is not a non-profit NFO

Business relations should be considered relations between the client and his counterparty, related to the client's business, professional or commercial activities, which arose on the basis of a contract, including a public one, and provide for the duration of existence after their establishment

Signs of belonging to a tax resident of another jurisdiction (country) other than Ukraine and the USA, by which it is determined whether the account is accountable for

1. Data that the client is a resident
2. current postal address (including a post office box);
3. one or more telephone numbers of another jurisdiction except Ukraine and the USA and no number in Ukraine;
4. permanent instructions regarding the transfer of funds to an account maintained in another jurisdiction of Ukraine and the USA
5. a valid power of attorney to a person with an address in another jurisdiction other than Ukraine and the USA;
   or
6. an instruction to withhold/not send correspondence or an address for forwarding to a jurisdiction other than Ukraine and the USA, if there is no other address in the documents regarding the client.

You are legally responsible for providing us with documents with inaccurate information. In accordance with Clause 118¹.8 of the Tax Code of Ukraine, the account owner's intentional provision of CRS self-assessment documents regarding himself and/or regarding his controlling persons in the cases provided for by Article 39-3 of the Tax Code of Ukraine, with inaccurate information that led to failure to establish account accountability for the account owner and/or for its controlling persons, - entails the imposition of a fine equal to 100 times the minimum wage established by law on January 1 of the reporting (tax) year. Payment of such a fine does not release the account holder from the obligation to provide CRS self-assessment documents with reliable information. More information about the CRS General Reporting Standard can be obtained at the following links: https://mof.gov.ua/uk/crs-578

FATCA (Foreign Account Tax Compliance Act) is a section of the US Tax Code aimed at combating tax evasion by US tax residents.

The bank is registered with the US Internal Revenue Service as a Participating FFI and takes all measures to comply with FATCA requirements.

The Client certifies and warrants that the Client, the Client's Authorized Persons are not US tax residents (unless the Client/Client's Authorized Person has provided the Bank with other information together with the W9 form completed in accordance with the requirements of the US Internal Revenue Service and other forms indicating the taxpayer's tax number USA (GIIN) of the Client or the Client's Authorized Person), the Client is not a US citizen, unless other information is provided to the Bank, the Client has not stayed for more than 183 or more days during the last 3 years, including 31 or more days in the current calendar year, the Client does not have addresses in the USA, was not born in the USA, the Client has not issued a power of attorney for a person with an address in the USA, unless other information is provided by the Client to the Bank in writing in prescribed forms and official documents.

The Client and his Authorized Persons are obliged to provide the Bank with information and documents related to their Tax Status at the Bank's request, including at the Bank's request to provide W8, W9 and other forms filled out in accordance with the requirements of the US Internal Revenue Service.

The Client and his Authorized Persons are obliged to inform the Bank within 30 days of a change in the information provided regarding their Tax Status, and in the case of acquiring the status of a US Tax Resident, to provide the Bank with a W9 form or other forms in accordance with the legislation of the relevant jurisdiction that regulates these social relations, with specifying the US Taxpayer Identification Number (TIN).

The Client and the Client's Authorized Person give the Bank Consent to transfer personal data of the Client and the Client's Authorized Persons, disclosure of bank secrecy, personal data and other confidential information under the Agreement for the purpose of the Bank's fulfillment of FATCA requirements, in particular, in the following cases:

• to the US Tax Administration (InternalRevenueService, IRS) when providing reporting in the manner and scope defined by FATCA;
• persons participating in the transfer of funds to the Client's Accounts (for example, correspondent banks, payment systems and their participants, senders and recipients of transfers, other institutions carrying out authorization or processing of transfers), as well as in other cases provided for by FATCA.

If the Client or the Client's Authorized Person did not provide the necessary information for FATCA identification, the forms that were provided to the client to fill out, or the inauthenticity or violation of certificates and guarantees was discovered, the Bank has the right to close all or individual Accounts of the Client for the purpose of FATCA compliance and/ or refuse to provide Services under the Agreement, from signing Statements, conducting operations on the Client's Accounts or suspend (temporarily) operations on them, and/or terminate the Agreement.

The Client understands and accepts all risks, including financial risks, related to the Client's or its Authorized Person's non-compliance with FATCA requirements and the Client's refusal to provide information requested by the Bank or timely notification of changes in its Tax Status.

The Bank is not liable to the Client, the Client's Authorized Persons, its counterparties for any withholding, sanctions, restrictions and other negative consequences regarding the Accounts, funds and transactions on the Accounts, if such consequences are related to the fulfillment of FATCA requirements by the Tax Service USA, correspondent banks and other persons participating in transfers, as well as for any related losses, expenses, moral damage and/or lost income.

Common Reporting Standard CRS (Common Reporting Standard) or CRS Standard is an international standard approved by the OECD Council on July 15, 2014, which requires countries that implement it to collect information from financial institutions about the financial accounts of account holders and annually on an automatic basis exchange such information with exchange partner jurisdictions under the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.