SWIFT Relationship Management Application (RMA) Due Diligence

Wolfsberg Guidance on SWIFT Relationship Management Application (RMA) Due Diligence Background The Wolfsberg Group of International Financial Institutions1 has prepared this guidance document on SWIFT Relationship Management Application (“RMA”) to supplement the Wolfsberg Correspondent Bank Principles issued in 2014. This document is intended to provide broader guidance for managing non- customer RMAs beyond the correspondent banking arena. The RMA is a messaging capability enabling members of the SWIFT network to exchange messages over the network. The use of RMA is mandatory for sending and receiving SWIFT messages with the exception of the messages listed in Appendix A, which require no prior authorisation. RMA can be unrestricted or, through granular authorisations, be limited to specific incoming message types. For the purpose of this guidance document, this latter option will be referred to as RMA Plus. It is also noted that the terms “bank” and “financial institution” are used interchangeably throughout this document. SWIFT’s RMA functionality replaced the former Bilateral Key Exchange (BKE) and is used to authorise communications between members of the SWIFT network. More details about RMA can be found in Appendix B. A traditional customer or client (hereafter “customer”) relationship which involves cross border transactional or liability accounts requires an RMA. RMAs are also established with third parties (i.e. non-customers) to facilitate transactions for existing customers; these RMAs may be referred to as non- customer RMAs. The possible use of an RMA arrangement for purposes not intended, or agreed to, at the time of establishment is predominantly an operational risk, not a Money Laundering risk. RMA arrangements, if poorly controlled, may, however, allow financial services firms with inadequate Anti Money Laundering 1 The Wolfsberg Group consists of the following financial institutions: Banco Santander, Bank of America, Bank of Tokyo Mitsubishi-UFJ Ltd, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JPMorgan Chase, Société Générale, Standard Chartered and UBS. This guidance document has also benefited from the contributions of S.W.I.F.T SCRL for which the Wolfsberg Group members are grateful. © The Wolfsberg Group 2016 SWIFT Relationship Management Application (RMA) Due Diligence 1 (AML) systems and controls, and customers of those firms, direct access to international banking systems. For example, through the exchange of an RMA authorisation with a non-customer, a bank may receive, and act upon, direct payment instructions from a non-customer. This guidance outlines minimum due diligence standards required for non-customer RMAs to help mitigate the impact of possible misuse of an RMA. It is also noted that SWIFT requires and validates membership documentation on all prospective member institutions. Please refer to Appendices C and D for information on the types of entities which are members of, or use, the SWIFT Network, as well as the types of messages that are available. 1. Principles Financial Institutions (FIs) should incorporate RMA due diligence standards into their Financial Crime/AML/KYC programmes where the following concepts or principles should be considered: due to the potential risks that may be associated with the establishment of an RMA, approval of such requests needs to be appropriately controlled RMA requests may be segregated between customer relationships and non-customer RMAs, with distinct due diligence criteria for each where an RMA holder has a customer relationship subject to due diligence, the requirements under that due diligence programme will apply due diligence on the RMA holder should consider the message types used by the RMA holder and the risk associated with the activity conducted RMA Plus offers certain capabilities to limit the types of SWIFT messages exchanged and may facilitate the determination of due diligence requirements Change in RMA usage from a non-customer to a customer relationship should be identified on a timely basis and any additional due diligence required for the customer relationship collected, as per usual customer due diligence standards 2. Definition of a non-customer relationship A non-customer RMA is generally created when there is a request that the bank sends or receives SWIFT messages to/from a third party (i.e. the non-customer) in support of a customer’s business and where the bank has no other relationship with that third party. This can include both transactional and non- transactional messages. Such arrangements are sometimes referred to as “network banks,” which facilitate the continuing ability to meet customer global trading expectations and requirements. Network banks are non-customer banks and have no accounts, facilities or dedicated Relationship Manager. They are sponsored by a global line of business and interactions are limited to document exchanges and restricted SWIFT RMA message interactions. The settlement of any transaction is decoupled from the document exchange and always made via a customer bank. Some examples of where non-customer RMAs may be established to facilitate activity for existing customers include, but are not be limited to: Cash management: receipt of balance and transaction information on a corporate customer’s account at another bank, so that the corporate customer can view activity through its bank’s reporting tool Cash management: relaying payment instructions from a corporate customer to their third party bank © The Wolfsberg Group 2016 SWIFT Relationship Management Application (RMA) Due Diligence 2 Custody: provision of information from a sub custodian bank to the global custodian at the request of the client Trade Finance (e.g., letters of credit): exchange of messages with banks that do not otherwise have direct payment relationships Exchange of messages with payments and securities markets infrastructure entities, e.g., exchanges, depositories It is noted that the definition of a customer may vary according to applicable local laws and regulations, which may also have an impact on the designation of non-customer RMAs. For example, in certain jurisdictions, the establishment of an RMA with a bank is considered a form of customer relationship and therefore subject to risk-based due diligence. It is important for FIs to assess and understand any local requirements that may apply in the jurisdictions in which they operate and be guided by those requirements. 3. Minimum Due Diligence Procedures for non-customer RMAs The minimum recommended identification and due diligence requirements are as follows: collect name and address information conduct sanctions screening against relevant Sanctions list(s), as appropriate conduct a review against internal “red flag” lists. In this context “red flag lists” refer to lists that FIs may maintain to manage or monitor transactions/relationships with particular entities. These are generally based on a variety of factors including, but not limited to, prior unusual transaction history and negative media reports evaluate risks of the potential RMA based on the above information to identify whether an FI may require further review based on internal risk tolerance 4. Suggested Procedures for Ongoing Management of RMAs The potential risks associated with the establishment of a non-customer RMA need to be managed throughout the lifecycle of that RMA. Below are suggested procedures for managing the potential risks associated with non-customer RMAs, as well as the transactions the FI undertakes with such entities: conduct periodic reviews of message volumes sent to/received from non-customer RMAs to determine if volumes and/or message types warrant additional due diligence due to significant changes in usage or cancellation due to non-usage conduct sanctions and internal “red flag” screening periodically in accordance with internal screening standards. Periodic screening should be done against names added since the previous periodic review if an FI has not historically screened RMAs against sanctions and “red flag” lists, a review of the existing files should be conducted within a reasonable time period. © The Wolfsberg Group 2016 SWIFT Relationship Management Application (RMA) Due Diligence 3 Appendix A: List of SWIFT messages which do not require an RMA authorisation MT 300 Foreign exchange confirmation: Confirms information agreed to in the buying/selling of two currencies MT 303 Forex/currency option allocation instruction: Instructs the allocation of a block trade (forex or currency option) MT 305 Foreign currency option confirmation: Confirms information agreed to in the buying and selling of vanilla options on currencies MT 306 Foreign currency option confirmation: Confirms information agreed to in the buying and selling of exotic options on currencies MT 320 Fixed loan/deposit confirmation: Confirms the terms of a contract relative to a fixed loan/deposit transaction MT 330 Call/notice loan/deposit confirmation: Confirms the terms of a contract relative to a call/notice loan/deposit transaction MT 340 Forward rate agreement confirmation: Confirms the details of a forward rate agreement MT 341 Forward rate agreement settlement confirmation: Confirms the settlement details of a forward rate agreement MT 350 Advice of loan/deposit interest payment: Advises of a loan/deposit interest payment MT 360 Single currency interest rate derivative confirmation: Confirms the details of a single currency interest rate derivative swap, cap,

18 February 2019 Solvency and Diversification in Insurance Remain Key Strengths Despite Change in Structure

FINANCIAL INSTITUTIONS ISSUER IN-DEPTH Lloyds Banking Group plc 18 February 2019 Solvency and diversification in insurance remain key strengths despite change in structure Summary RATINGS In 2018, Lloyds Banking Group plc (LBG) altered its structure to comply with the UK's ring- Lloyds Banking Group plc Baseline Credit a3 fencing legislation, which requires large banks to separate their retail and SME operations, Assessment (BCA) and deposit taking in the European Economic Area (EEA) from their other activities, including Senior unsecured A3 Stable the riskier capital markets and trading business. As part of the change, LBG designated Lloyds Bank plc as the“ring-fenced” entity housing its retail, SME and corporate banking operations. Lloyds Bank plc It also assumed direct ownership of insurer Scottish Widows Limited, previously a subsidiary Baseline Credit A3 Assessment (BCA) of Lloyds Bank. The changes had little impact on the creditworthiness of LBG and Lloyds Adjusted BCA A3 Bank, leading us to affirm the deposit and senior unsecured ratings of both entities. Scottish Deposits Aa3 Stable/Prime-1 Widows' ratings were unaffected. Senior unsecured Aa3 Stable » LBG's reorganisation was less complex than that of most UK peers. The Lloyds Lloyds Bank Corporate Markets plc Banking Group is predominantly focused on retail and corporate banking, and the Baseline Credit baa3 required structural changes were therefore relatively minor. The group created a small Assessment (BCA) separate legal entity, Lloyds Bank Corporate Markets plc (LBCM), to manage its limited Adjusted BCA baa1 Deposits A1 Stable/Prime-1 capital markets and trading operations, and it transferred its offshore subsidiary, Lloyds Issuer rating A1 Stable Bank International Limited (LBIL), to LBCM from Lloyds Bank.

UBS News for Banks and Financial Institutions March 03, 2011 Priority: Urgent – Market: Poland Poland: Change of Custodian UBS Zurich is changing its custodian in the Polish market from SIX SIS AG / Bank Handlowy W Warszawie, Warsaw to Bank PeKAO (UniCredit Group), Warsaw as of trade date March 24, 2011. New settlement instructions Trades with settlement date (SD) until and including March 28, 2011 will be settled with UBS' current sub-custodian Bank Handlowy W Warszawie, Warsaw. Trades with settlement date as from March 29, 2011 need to be submitted with the instruction details of UBS' new custodian Bank PeKAO (UniCredit Group), Warsaw (see below). Settlement instructions (as from SD March 29, 2011) Custodian (NEW) Bank PeKAO, Warsaw SWIFT BIC (NEW) PKOPPLPWCUS SWIFT BIC UBS UBSWCHZH80A Account No. Individual account for each client New cut-off times – client deadlines Equities / Fixed Income DFP/RFP SD; 4 p.m. T-Bills DFP/RFP SD; 1 p.m. Equities / Fixed Income DVP/RVP SD; 8 a.m. T-Bills DVP/RVP SD; 8 a.m. Impact Clients and counterparties are requested to instruct with the new custodian details as from settlement date March 29, 2011. To see full market details, please access the Market Guide Poland. Should you have any questions, please contact your UBS – Source: UBS AG Relationship Manager or Account Manager. UBS AG Securities Services P.O. Box CH-8098 Zurich Switzerland Phone: +41-44-236 61 36 Email: [email protected] While the facts in this publication have been carefully researched, UBS cannot be held responsible for their accuracy.

RESEARCH AND SCIENCE TODAY ~ Scientific Review ~ ~Spring~ No. 1(15)/2018 March 2018 ISSN-p: 2247 – 4455 ISSN-e: 2285 – 9632 ISSN-L: 2247 – 4455 Târgu-Jiu 2018 1 Cover: Batcu Alexandru Editing: Mărcău Flavius-Cristian Director: Mărcău Flavius-Cristian Contact: Mail: [email protected] Web: www.rstjournal.com Tel: +40766665670 COPYRIGHT: Reproductions are authorized without charging any fees, on condition the source is acknowledged. Responsibility for the content of the paper is entirely to the authors. 2 SCIENTIFIC COMMITTEE: Prof. univ. dr. Adrian Gorun, Secretary General, Prof. univ. dr. Gămăneci Gheorghe, Universitatea National Commission for Prognosis. "Constantin Brâncuși" din Târgu-Jiu. Prof. univ. dr. ing. Ecaterina Andronescu, University Prof. univ. dr. Ghimiși Ștefan Sorinel, "Constantin Politehnica of Bucharest. Brâncuși" University of Târgu-Jiu. Prof. univ. dr. Michael Shafir, Doctoral School in Prof. univ. dr. Bîcă Monica Delia, "Constantin International Relations and Security Studies, ”Babes- Brâncuși" University of Târgu-Jiu. Bolyai” University. Prof. univ. dr. Babucea Ana Gabriela, "Constantin Prof. univ. dr. Nastasă Kovács Lucian, The Romanian Brâncuși" University of Târgu-Jiu. Academy Cluj-Napoca, "George Baritiu" History C.S II Duță Paul, Romanian Diplomatic Institute. Institute. Conf. univ. dr. Flavius Baias, University of Bucharest. Prof. univ. dr. Adrian Ivan, Doctoral School in Conf. univ. dr. Adrian Basarabă, West University of International Relations and Security Studies, ”Babes- Timișoara. Bolyai” University. Conf. univ. dr. Răzvan Cătălin Dobrea, Academy of Prof. Dr. Miskolczy Ambrus, Eotovos Lorand Economic Studies. Univeristy (ELTE), Hungary. Pr. Conf. univ. dr. Dumitru A. Vanca, University "1 Dr. Gregg Alexander, University of the Free State, Decembrie 1918" of Alba Iulia.

Anti-Money-Laundering (AML) & Countering Financing of Terrorism (CFT) Risk Management in Emerging Market Banks Good Practice Note 1 © International Finance Corporation 2019. All rights reserved. 2121 Pennsylvania Avenue, N.W. Washington, D.C. 20433 Internet: www.ifc.org The material in this work is copyrighted. Copying and/or transmitting portions or all of this work without permission may be a violation of applicable law. The contents of this document are made available solely for general information purposes pertaining to AML/CFT compliance and risk management by emerging markets banks. IFC does not guarantee the accuracy, reliability or completeness of the content included in this work, or for the conclusions or judgments described herein, and accepts no responsibility or liability for any omissions or errors (including, without limitation, typographical errors and technical errors) in the content whatsoever or for reliance thereon. IFC or its affiliates may have an investment in, provide other advice or services to, or otherwise have a financial interest in, certain of the companies and parties that may be named herein. Any reliance you or any other user of this document place on such information is strictly at your own risk. This document may include content provided by third parties, including links and content from third-party websites and publications. IFC is not responsible for the accuracy for the content of any third-party information or any linked content contained in any third-party website. Content contained on such third-party websites or otherwise in such publications is not incorporated by reference into this document. The inclusion of any third-party link or content does not imply any endorsement by IFC nor by any member of the World Bank Group.

Trade Finance Principles 1 The Wolfsberg Group, ICC and BAFT Trade Finance Principles 2019 amendment PUBLIC Trade Finance Principles 2 Copyright © 2019, Wolfsberg Group, International Chamber of Commerce (ICC) and BAFT Wolfsberg Group, ICC and BAFT hold all copyright and other intellectual property rights in this collective work and encourage its reproduction and dissemination subject to the following: Wolfsberg Group, ICC and BAFT must be cited as the source and copyright holder mentioning the title of the document and the publication year if available. Express written permission must be obtained for any modification, adaptation or translation, for any commercial use and for use in any manner that implies that another organization or person is the source of, or is associated with, the work. The work may not be reproduced or made available on websites except through a link to the relevant Wolfsberg Group, ICC and/or BAFT web page (not to the document itself). Permission can be requested from the Wolfsberg Group, ICC or BAFT. This document was prepared for general information purposes only, does not purport to be comprehensive and is not intended as legal advice. The opinions expressed are subject to change without notice and any reliance upon information contained in the document is solely and exclusively at your own risk. The publishing organisations and the contributors are not engaged in rendering legal or other expert professional services for which outside competent professionals should be sought. PUBLIC Trade Finance Principles

CASE STUDY Banco Santander: Extending financial se vices to low-income communities in B azil Initi ti e Descriptio In September 2013, Santander Microcrédito joined the Business Call to Action with a commitment to serve 124,799 low-income consumers with microfinance services and to disburse up to US$490 million in microcredit loans by 2015. The goals of Santander Microcrédito are to: • Disburse R$540 million (US$230 million) in microcredit operations by the end of 2014; and R$600 million (US$260 million) in 2015; and • Attain 126,000 active microcredit clients by the end of 2014 and 131,000 additional clients Business Model Santander Microcredit is an example of how Banco in 2015. In Brazil, 52 million people and Santander Brasil contributes to approximately 25 million informal reducing social inequalities in entrepreneurs lack access to the for- the country. When we started mal banking system. Santander Brasil thinking about how to launch Microcredit, a company affiliated with the microcredit programme, we Banco Santander Brasil, was founded decided that it should be a in 2002 to offer microcredit operations model in which all involved to support business entrepreneurs parties could benefit. that could not access formal banking services. To this end, Santander Brasil Microcredit offers loans that con- tribute to employment and income generation for low-income people. Currently, Santander Microcredit The average monthly income in Brazil operates in more than 600 municipali- is US$6801 and 21 percent of the pop- ties (in 10 Brazilian states), and has 25 ulation live below the poverty line2. branch offices.

Unit Accoun- Reference Initial Launch Minimum Smallest Annual Form of Approp- class¹ ting currency subscrip- period/date* subscription tradeable fee custody riation of currency tion price lot income I-A110 USD USD 1 000 Not yet n/a 0.001 0.21%2 Registered7 Accumulating known (0.17%) I-A210 USD USD 1 000 Not yet 10 000 00011 0.001 0.18%2 Registered7 Accumulating known (0.14%) I-A310 USD USD 1 000 Not yet 30 000 00012 0.001 0.15%2 Registered7 Accumulating known (0.12%) I-B8 USD USD 1 000 Not yet n/a 0.001 0.035%5 Registered7 Accumulating known I-X8 USD USD 1 000 04.11.2014 n/a 0.001 0.00%6 Registered7 Accumulating U-X USD USD 100 000 Not yet n/a 0.001 0.00%6 Registered7 Accumulating known UBS (CH) Investment Fund B. UBS (CH) Investment Fund – Bonds CHF Ausland Medium Term Passive Investment fund under Swiss law with multiple sub-funds Unit Accoun- Reference Initial Launch Minimum Smallest Annual Form of Approp- (umbrella fund) class¹ ting currency subscrip- period/date* subscription tradeable fee custody riation of (Category Other Funds for Traditional Investments) currency tion price lot income W CHF CHF 100 Not yet n/a 0.001 0.18%3 Bearer Accumulating known (0.14%) Prospectus with integrated fund contract February 2017 F9 CHF CHF 100 Not yet n/a 0.001 0.14%4 Registered7 Accumulating known (0.11%) I-A110 CHF CHF 1 000 Not yet n/a 0.001 0.18%2 Registered7 Accumulating known (0.14%) I-A210 CHF CHF 1 000 Not yet 10 000 00011 0.001 0.18%2 Registered7 Accumulating known (0.14%) I-A310 CHF CHF 1 000 Not yet 30 000 00012 0.001 0.14%2 Registered7 Accumulating known (0.11%) I-B8 CHF CHF 1 000 Not yet n/a 0.001 0.045%5 Registered7 Accumulating known I-X8 CHF CHF 1 000 04.11.2014 n/a 0.001 0.00%6 Registered7 Accumulating U-X CHF CHF 100 000 Not yet n/a 0.001 0.00%6 Registered7 Accumulating known Part I Prospectus C.

Facultad de Ciencias Económicas y Empresariales ANÁLISIS DE LA RESPONSABILIDAD SOCIAL CORPORATIVA EN EL SECTOR BANCARIO ESPAÑOL Autor: María Sánchez Barbero Director: Laura Gismera Tierno MADRID | Abril 2020 RESUMEN/ABSTRACT Resumen La Responsabilidad Social Corporativa es una práctica en auge desde finales de los años 90 y su función principal es satisfacer a los grupos de interés –stakeholders- de las empresas que la aplican. La RSC busca cumplir con los intereses internos de las compañías y de la sociedad, mejorando así la imagen corporativa de la empresa. El sector bancario español lleva casi 20 años aplicando esta corriente empresarial hasta el punto que, las distintas entidades bancarias que conforman el sector, desarrollan modelos de RSC prácticamente idénticos. Este trabajo tiene como principal objetivo analizar la Responsabilidad Social Corporativa en el sector bancario español. En primer lugar, se expondrá una aproximación al concepto de Responsabilidad Social Corporativa, así como su evolución, las principales teorías sobre la materia y ciertos aspectos diferenciales y normativos con los que se identifica la RSC. Así mismo, se realizará un análisis de la evolución del sector bancario en los últimos años junto con las oportunidades y amenazas a las que se enfrenta el mismo. Finalmente, se analizará el modelo de RSC de cinco de las entidades bancarias más importantes a nivel nacional: Santander, BBVA, CaixaBank, Bankinter y Banco Sabadell. Palabras clave: Responsabilidad Social Corporativa (RSC), economía, entidades bancarias, stakeholders, interés, sostenibilidad, acción social. Abstract Corporate Social Responsibility has been a growing practice since the late 1990s and its main function is to satisfy the stakeholders of the companies that apply it.

The Wolfsberg Group Anti-Money Laundering Questionnaire Questionnaire provided by LEAP EF AB with additional questions # 29 & 30 at end of form Financial Institution Name: Location: This questionnaire acts as an aid to firms conducting due diligence and should not be relied on exclusively or excessively. Firms may use this questionnaire alongside their own policies and procedures in order to provide a basis for conducting client due diligence in a manner consistent with the risk profile presented by the client. The responsibility for ensuring adequate due diligence, which may include independent verification or follow up of the answers and documents provided, remains the responsibility of the firm using this questionnaire. Anti-Money Laundering Questionnaire If you answer “no” to any question, additional information can be supplied at the end of the questionnaire. I. General AML Policies, Practices and Procedures: Yes No 1. Is the AML compliance program approved by the FI’s board or a Y N senior committee? 2. Does the FI have a legal and regulatory compliance program Y N that includes a designated officer that is responsible for coordinating and overseeing the AML framework? 3. Has the FI developed written policies documenting the Y N processes that they have in place to prevent, detect and report suspicious transactions? 4. In addition to inspections by the government Y N supervisors/regulators, does the FI client have an internal audit function or other independent third party that assesses AML policies and practices on a regular basis? 5. Does the FI have a policy prohibiting accounts/relationships Y N with shell banks? (A shell bank is defined as a bank incorporated in a jurisdiction in which it has no physical presence and which is unaffiliated with a regulated financial group.) 6.

Barclays’ Financial Crime Compliance Statement (ABC, AML, Anti-Tax Evasion Facilitation and Sanctions) Barclays recognises that economic crimes have an adverse effect on individuals and communities wherever they occur. Endemic economic crime (particularly when associated with organised crime and terrorist financing) can threaten laws, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition. Barclays is committed to conducting its global activities with integrity and respecting its regulatory, ethical and social responsibilities to: Protect customers, employees, and others with whom we do business; and Support governments, regulators, and law enforcement in wider economic crime prevention. We will not tolerate any deliberate breach of financial crime laws and regulations (e.g. bribery, corruption, and money laundering, sanctions, or tax evasion facilitation) that apply to our business and the transactions we undertake. Barclays has a dedicated global Financial Crime function, which sits within Compliance. The Financial Crime function facilitates risk-based, effective and efficient financial crime risk management by providing expert support and oversight to the business and our legal entities (Barclays Bank UK PLC and Barclays Bank PLC operate alongside, but independently from one another as part of the Barclays Group under the listed entity, Barclays PLC). We have adopted a holistic approach to Financial Crime and have one group-wide Financial Crime Policy that sets the minimum control requirements in four key risk areas: anti-bribery & corruption (ABC); anti-money laundering & counter-terrorist financing (AML); anti-tax evasion facilitation (ATEF) and sanctions. This combined approach allows us to identify and manage relevant synergies and connections between the key risk areas.

Santander Bank Customer Satisfaction Two-handed and convict Ross whiz so recognizably that Stefano supernaturalised his chartularies. Medium-sized and metazoic Brad codifying skeptically and buccaneer his Jugurtha mildly and kinetically. Wholesale Stefan parleyvoo some abettors and clobbers his mademoiselle so blunderingly! Prior presidents going and wish to understand and money jar with compliance areas of different countries, bank customer experience with their customer satisfaction was with Every single thing you have a satisfaction in this we strive to all banks in banks and when they shopped for new messages back or bank customer satisfaction. Assessing Classification Methods for Prediction of Customer Satisfaction Santander Bank Dataset The dataset traincsv was obtained from Kagglecom. The united states exhibition in historical data to other regional business banking sector may in latin america does on recent years. Enable them until you will improve or one of other nearby branches, an issue in. Position at least one, it will apply and on behalf of money. Joining santander we could not just four stars for ensembling tree algorithms in? Santander uk has had to choose the interest rates and so on how do i was a santander customer satisfaction. Since most impact of any unwanted effect on their financial institution standards are best possible once a stock. Are false data who the columns numeric or intelligence they need anything be encoded? If should wish to was the client at state center, we must they so realistically. Accounts in this element in all matters into company and certificates of corporate governance and compare reviews, it was a whole branch.

4/7/2021 Cover ESG Report Fund Name GAM Star Credit Opportunities (USD) 31 March 2021 This document is confidential and intended solely for the use of the person to w hom it is given or sent and may not be reproduced, copied or given, in w hole or in part, to any other person. 1/1 4/7/2021 Summary EFunSd NGam eSummary GAM Star Credit Opportunities (USD) MSCI ESG Rating MSCI Coverage by Weight ESG Score No 8% Environment Social Governance A 7.2 7.4 4.6 5.6 ESG Rating Distribution ESG Rating Momentum (YoY) Yes 92% 47% 40% 40% (Cash & FX excluded) 27% 17% 5% 4% 2% 2% AAA AA A BBB BB Strong Upward Upward Stable Downward Strong Downward Top 10 Issuers by Weight Top 10 Issuers by Rating Issuer Name % Sector ESG Rating Issuer Name % Sector ESG Rating HSBC HOLDINGS PLC 6.9 % Banks BBB Banco Bilbao Vizcaya Argentaria, S.A. 3.3 % Banks AAA BARCLAYS PLC 6.5 % Banks A Sw iss Re AG 1.3 % Multi-Line Insurance & Brokerage AAA Stichting AK Rabobank 5.8 % Banks A AXA SA 0.7 % Multi-Line Insurance & Brokerage AAA NATWEST GROUP PLC 5.5 % Banks AA Allianz SE 0.6 % Multi-Line Insurance & Brokerage AAA UBS Group AG 5.2 % Investment Banking & Brokerage AA OMV Aktiengesellschaft 0.3 % Integrated Oil & Gas AAA SOCIETE GENERALE SA 5.2 % Banks AA AXA BANQUE S.A. 0.1 % Multi-Line Insurance & Brokerage AAA BNP PARIBAS SA 4.7 % Banks AA NATIXIS US MEDIUM-TERM NOTE PROGRAM LLC 0.0 % Investment Banking & Brokerage AAA Credit Suisse Group AG 4.4 % Investment Banking & Brokerage A NATWEST GROUP PLC 5.5 % Banks AA LLOYDS BANKING GROUP PLC 4.1 % Banks AA UBS Group AG 5.2 % Investment Banking & Brokerage AA BANCO SANTANDER, S.A.