CAIXA GERAL DE DEPÓSITOS, SA

Anti- Money Laundering and Counter- Terrorism Financing

Disclosure Statement

1. Administrative Information

o Legal name: Caixa Geral de Depósitos, SA (CGD)

o Principal place of business / legal address:

Av. João XXI, nº 63

1000- 300 Lisboa, Portugal

o Place of incorporation: Lisboa, Portugal

o SWIFT 7 BIC Code: CGDI PT PL

o Legal status: 100% State owned company, plc

o Shareholder: State of the Portuguese Republic

o Regulators: Banco de Portugal [Link], Comissão do Mercado de

Valores Mobiliários [Link]

o Financial Institution Register: 35

o External Auditors: Deloitte & Associados, SROC SA

o AML contact: Head of Compliance Office

Address: Av. João XXI, nº 63

1000- 300 Lisboa, Portugal

Phone number: 351 21 8456077

Fax number: 351 21 7905471

Email address: [Link]@[Link]

2. Relevant International and National Framework

International Framework:

40 Recom m endat ions of FAFT/ GAFI ( developed in 1990, revised in 1996,

2003 e 2004) t hat provide a com plet e set of count er- m easures against
m oney laundering covering t he crim inal j ust ice syst em and law enforcem ent ,
the financial system and its regulation, and international co- operation;

9 Special Recom m endat ions of FAFT/ GAFI ( issued in 2001, updat ed in 2004)
t hat set out principles for act ion t o det ect , prevent and suppress t he
financing of terrorism;

3rd AML European Directive where the main principles and provisions, about
prevent ion of t he use of t he financial syst em for t he purpose of m oney
laundering and t errorist financing, enforced upon all EU Mem ber St at es, are
defined;

EC Regulat ion 1889/ 2005 of t he European Parliam ent and t he Council, of 26

October 2005;

EC Regulation 1781/2006 of the European Parliament and of the Council of 15

November 2006;

Council of Europe convent ion on laundering, search, seizure and confiscat ion
of t he proceeds from crim e and on t he financing of t errorism ( Warsaw,
16.V.2005).

National Framework:

Law 25/ 2008 ( issued in June, 5) port uguese law t hat t ransposes t he 3rd
AML Directive;

Official Not ice 11/ 2005, updat ed by Official Not ice 2/ 2007, and I nst ruction
26/ 2005 ( issued by port uguese banking supervisor, Bank of Port ugal)
where t he procedures t o be put in place by banks are defined, regarding
cust om er ident ificat ion, record keeping and t he report ing of suspicious
transaction;

Criminal Code Article 11 (as approved by law 59/2007 of 4th September);

Law 52/ 2003 of 22nd August ( as am ended by law 59/ 2007 of 4th
September);

Decree- law 61/2007 of 14th March;

Decree- law 125/2008 of 21st June;

Securit ies Code Art icles 304 t o 305- E ( as am ended by Decree- law
357- A/2007 of 31st October);

Decree- law 144/2006, of 31st July Articles 13 and 29.

3. AML / CTF Measures in International Operations of CGD

I n t he I nt ernat ional operat ions t hat CGD has a cont rolling int erest in, policies and
procedures are in place, which assist t he operat ions t o com ply wit h t heir respect ive
domestic AML/CTF laws.

Under CGD I nt ernal Policy ( based on art icle 29 of law 25/ 2008) it s branches and
majority- owned subsidiaries in t hird count ries apply m easures equivalent t o t hose
laid down by portuguese law , regarding ident ificat ion, due diligence, correspondent
banking, record keeping and training.

We also im plem ent ed t he policies and int ernal procedures defined in com pliance,
nam ely int ernal cont rol, evaluat ion and risk assessm ent and m anagem ent and
int ernal audit , in order t o effect ively prevent m oney laundering and t errorism
financing.

Where t he legislat ion of t he t hird count ry does not allow t he whole applicat ion of t he
m easures in t he financial institutions, CGD had inform ed it s com pet ent supervisory
aut horit y ( Bank of Port ugal) of t hat fact and t ook addit ional m easures t o prevent t he
risk of money laundering and terrorism financing.

4 . Ant i- M one y La u nde r in g a nd Count e r - Te r r or ism Fina ncing ( AM L/ CTF)

Measures in CGD

CGD has adopted internal policies, procedures and controls to ensure that it complies
with AML/CTF obligations in existing legislation and regulations.

CGD has adopt ed an AML/ CFT program t hat reasonably ident ifies, m it igat es and
m anages t he risk of m oney laundering and t errorism financing according t o t he
legislat ion. This program has been approved by CGD s Board of Direct ors and is
implemented in its branches and majority- owned subsidiaries in third countries.

Being Portugal a member country of the EU and of the Financial Action Task Force on
Money Laundering ( FAFT/ GAFI ) , CGD and all it s dom est ic and int ernat ional branches
and represent at ive offices, adhere t o and apply t he following policies and
procedures:

Customer D ue D ilige nce / Kn ow Your Customer: CGD has policies and

procedures in place t o com ply w it h t he obligat ion t o ident ify and perform due
diligence on cust om ers which includes a filt ering I T solut ion ( t o check and wat ch
proscribed list s) and is im plem ent ing an I T solut ion t o score cust om er s profile based
on ML/TF risk.

Polit ica lly Ex pose d Pe r sons ( PEPs) : CGD has enhanced due diligence and
transaction screen towards customers or beneficial owners who are PEPs.

Anon ym ou s a nd n um be r e d a ccou nt s: CGD does not provide cust om ers wit h

anonymous or numbered accounts.
Re cor d Ke e ping: Records relating to customer identification and original documents,
copies, references or any ot her durable support syst em s, equally adm issible in court
proceedings as evidence, of t he dem onst rat ive docum ent s and of t he records of t he
t ransact ions, are kept t o enable t he reconst ruct ion of t he t ransact ion, for a period of
seven ( 7) years aft er it s execut ion, even if t he t ransact ion is part of a business
relationship that has already ended.

M onit or ing of Suspicious Act ivit ie s: Screening of cust om er s t ransact ions is

carried out by an I T solut ion t hrough a risk- based approach and also by t he CGD s
workers.

Re por t s of Suspiciou s Tr a nsa ct ions: CGD is required t o report any suspicious

cust om er act ivit ies or t ransact ions t o PGR Procurador Geral da República
( Republic s General At t orney) and t o UI F Unidade de I nform ação Financeira
( Financial I nt elligence Unit ) . I nt ernal policies and procedures are in place t o ensure
compliance with the applicable legislation and regulatory requirements.

Re por t s of significa n t a ccount a n d non- a ccou nt ba se d ca sh t r a nsa ct ions a nd

a ll I M Ts: CGD is required t o report significant account cash t ransact ions over
15.000 ( or less, if suspicious) t o t hose ent it ies and t o t he regulat ory aut horit y I MT
t o offshore j urisdict ions. Det ails of all I MTs ( wire t ransfers) such as sender and
beneficiary nam es and address are checked against wat ch list s. I nt ernal policies and
procedures are in place t o ensure com pliance wit h t he applicable legislat ion and
regulatory requirements.

Em ploye e Tr a ining Pr ogr a m : AML/ CFT t raining is provided t o all unit s.

St aff involved in cust om er facing areas receive special t raining and rem inders on t he
detection and reporting process for suspicious activities.

Employee due dilige nce : CGD has processes t hat provide reasonable assurance of
the identity, honesty and integrity of prospective and existing employees.

I nde pe nde nt a u dit a nd com plia nce r e vie w funct ion: Our internal audit ors and
the com pliance depart m ent conduct program s of audit and com pliance t est s of all
CGD s policies and operat ional procedures including t hose applicable t o AML.
The audit and compliance programs are approved by senior management.

Cor r e spon de nt Ba nk s: CGD has im plem ent ed risk based due diligence procedures
that include the following underst anding t he nat ure of t he correspondent s business,
its license t o operat e, t he qualit y of it s m anagem ent , ownership and effect ive cont rol,
it s AML policies, ext ernal oversight and prudent ial supervision including it s AML/ CFT
regim e. Addit ionally, ongoing due diligence of correspondent account s is perform ed
on a regular basis or when circum st ances change. All correspondent banking
relationships are approved by senior management.

She ll Ba n k s: CGD does not conduct business wit h shell banks, as defined in t he
AML/CFT law.

Payable- t hr ou gh a ccou nt s: CGD doesn t provide payable t hrough account s

because our policies and procedures prohibit offering t his kind of services as defined
in the AML/CFT regime.
Asse ssm e nt of pa ym e nt s a ga inst w a t ch list s a nd pr oscr ibe d list s ( TF a nd
sanctions): CGD has an I T solut ion t o filt er all inward and out ward paym ent s
against UN, EU and OFAC proscribed lists.

Please find CGD Wolfsberg AML Quest ionnaire in the website ([Link]).

5 . USA Patriot Act Certificate

Under t he Unit ing and St rengt hening Am erica by Providing Appropriat e Tools
Required t o I nt ercept and Obst ruct Terrorism ( USA Pat riot Act ) Act 2001, CGD m ay
be required from t im e t o t im e t o provide Certification Regarding Account s for Foreign
banks.

Please find USA Patriot Act Certificate in the website ([Link]).