CAIXA GERAL DE DEPSITOS, SA

Anti- Money Laundering and Counter- Terrorism Financing Disclosure Statement

1. Administrative Information o Legal name: Caixa Geral de Depsitos, SA (CGD) o Principal place of business / legal address: Av. Joo XXI, n 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 , Comisso do Mercado de o Regulators: Banco de Portugal www.bportugal.pt Valores Mobilirios www.cmvm.pt o Financial Institution Register: 35 o External Auditors: Deloitte & Associados, SROC SA o AML contact: Head of Compliance Address: Av. Joo XXI, n 63 1000- 300 Lisboa, Portugal Phone number: 351 21 8456077 Fax number: 351 21 7905471 Email address: gfc.branqueamentocapitais@cgd.pt Office

Caixa Geral de Depsitos, SA - Sede Social: Av. Joo XXI, 63 1000-300 LISBOA - Capital Social 5.150.000.000-CRCL e Contribuinte sob o n 500 960 046

2. Relevant International and National Framework International Framework: 40 Recom m endat ions of FAFT/ GAFI ( developed in 1990, revised in 1996, t hat provide a com plet e set of count er- m easures against 2003 e 2004) 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 52/ 2003 September); of 22nd August ( as am ended by law 59/ 2007 of 4th

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; Decree- law 144/2006, of 31st July Decree- law 61/2007 of 14th March; Law 25/ 2008 ( issued in June, 5) AML Directive; Decree- law 125/2008 of 21st July; Law 88/2009 of 31st August; Criminal Code Criminal Code Article 11 (as approved by law 59/2007 of 4th September); Article 368- A; port uguese law t hat t ransposes t he 3rd Articles 13 and 29.

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

Caixa Geral de Depsitos, SA - Sede Social: Av. Joo XXI, 63 1000-300 LISBOA - Capital Social 5.150.000.000-CRCL e Contribuinte sob o n 500 960 046

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 Measures in CGD

Fina ncing ( AM L/ CTF)

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. Politically 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.

Caixa Geral de Depsitos, SA - Sede Social: Av. Joo XXI, 63 1000-300 LISBOA - Capital Social 5.150.000.000-CRCL e Contribuinte sob o n 500 960 046

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 Procurador Geral da Repblica cust om er act ivit ies or t ransact ions t o PGR Unidade de I nform ao Financeira ( Republic s General At t orney) and t o UI F ( 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.

Caixa Geral de Depsitos, SA - Sede Social: Av. Joo XXI, 63 1000-300 LISBOA - Capital Social 5.150.000.000-CRCL e Contribuinte sob o n 500 960 046

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 (www.cgd.pt). 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 (www.cgd.pt).

Caixa Geral de Depsitos, SA - Sede Social: Av. Joo XXI, 63 1000-300 LISBOA - Capital Social 5.150.000.000-CRCL e Contribuinte sob o n 500 960 046