CONDITIONS OF ESTABLISHING BUSINESS RELATIONSHIP OR ACCOUNT OPENING IN SLOVENIA Instead of identification done by UniCredit Banka Slovenija d.d. for establishing business relationship or opening the account, identification can be done by third party if the third party is a bank a branch or a daughter company of the bank, a brokerage house, a branch or a daughter company of the brokerage house an investment fund manager, a branch or a daughter company of the investment fund manager founders and managers of pension funds an insurance company a branch or a daughter company of the insurance company a consulate of Republic of Slovenia a notary with the seat in EU, a bank an investment fund manager an insurance company a consulate of Republic of Slovenia a notary with the seat in a third country, if company is regulator and if all mentioned third persons apply AML standards accepted by the EU or similar EEA country or in a third equal countries (Australia, Brazil, Canada, Hong Kong, Japan, Singapore, Switzerland, Republic of South Africa, USA, South Korea and India). Identification by third party cannot be done if client is a legal person, which is not allowed to perform a commercial or manufacturing activity in the country, in which it is registered, or if a client is a fiduciary or similar company of foreign law with unknown owners and managers ACCOUNT STRUCTURE Two types of accounts can be opened in Slovenia: segregate securities account fiduciary securities account Segregated securities accounts are opened in the beneficial owner’s name at the KDD level. The segregated securities accounts can be opened for: individuals, legal entities, branches (also identification of the legal entity is required), Sub-funds (also identification of the legal entity which manages the assets is required). UniCredit Banka Slovenija d.d. Šmartinska 140 SI-1000 Ljubljana, Slovenia Tel.: +386 1 5876 600 Faks: + 386 1 5876 684 Registered at the District Court of Ljubljana under entry no. 1/10521/00; Share capital: 20.383.764,81 EUR, Reg. no.: SI59622806; 5446546; Settlement 01000-0002900092. Tax no.: account: A fiduciary securities account is a type of client account with the following characteristics: 1. the holder of the securities account is the legal holder of book-entry securities credited to such account, 2. the holder of the securities account does not exercise the rights arising from book-entry securities credited to such account for themselves but for an account of one or more other persons. Fiduciary securities account can be opened by a notary public, a lawyer, legacy custodian, special custodian, insolvency manager or another person providing custodian services in the scope of its regular activity or occupation. Securities account in Slovenia can be opened within 2-3 business days after receipt of required documentation. ACCOUNT PROCEDURES There are three different account opening procedures and requirements for different types of investors: Simplified procedure Standard procedure Comprehensive procedure SIMPLIFIED PROCEDURE: “Face to face” identification is not required for clients entitled for simplified procedure. Simplified procedure is applicable for: Institutional Underlying Clients (banks, saving banks, posts, investment fund managers, founders and managers of pension funds, pension fund companies, brokerage houses, insurance companies) from countries specified in the enclosure List of Countries by Geographical Risk Area (ENCLOSED IN APPENDIX I) for simplified procedure. State authorities, local communities, public agencies, public funds, public institutions, chambers of commerce located in Slovenia, Joint Stock Companies which securities are listed on an organised market in EU and other EEA countries (Iceland, Liechtenstein and Norway) including Serbia, Turkey and Macedonia. EU Institutions such as: European Central Bank, European Investment Bank, EU Council, EU Parliament, EU Commission and others. UniCredit Banka Slovenija d.d. Šmartinska 140 SI-1000 Ljubljana, Slovenia Tel.: +386 1 5876 600 Faks: + 386 1 5876 684 Registered at the District Court of Ljubljana under entry no. 1/10521/00; Share capital: 20.383.764,81 EUR, Reg. no.: SI59622806; 5446546; Settlement 01000-0002900092. Tax no.: account: STANDARD PROCEDURE: “Face to face” identification is required for clients in a case of Standard and Comprehensive procedure. Standard procedure is applicable for all clients, which don’t fulfil criteria for simplified procedure or Comprehensive procedure. Countries specified for each procedure are specified in the enclosure List of Countries by Geographical Risk Area (ENCLOSED IN APPENDIX I). COMPREHENSIVE PROCEDURE: Comprehensive procedure is applicable for: - if beneficial owner, legal representatives or authorized person of legal entity is politically exposed person. -Clients from countries with higher possibility of money laundering. Please see the List of Countries by Geographical Risk Area (ENCLOSED IN APPENDIX I). - if beneficial owner, legal representatives or authorized person of legal entity is a national or resident of the country with higher possibility of money laundering. A politically exposed person is any natural person (individual, statutory representative or authorized person) who is or has been entrusted with prominent public function in the previous year, including his/her immediate family members and close associates. DOCUMENTATION REQUIREMENT List of documents required for all three procedures: Certificate of Registration or Extract from Court or other public Register of companies or other official document issued by authority institution. This document should prove the existence and legal status of the Client in whose name account will be opened or business relationship established. The document could be provided either as a copy not older than three months or as a link to web page of the official register. The company name, seat have to be seen on the document. A copy of prospectus is needed for account opening for funds, which are not legal entities. In such case a Certificate of Registration (CoR) of Management company or similar document is required to be provided either as a copy not older than three months or as a link to web page of the official register signed by the person who viewed and printed the data. The prospectus should prove the connection between fund Management Company and the fund. Specimen Signature List or Client’s List of Authorised Signatures This document could be provided as a copy. Legal Representatives (Top Management) A certificate from the trade registrar, the company’s statute or any similar official document that list the persons that can legally represent the company, is required in order to support the eligibility of the signatories on the Client Evidence Sheet. As an alternative, a notarized UniCredit Banka Slovenija d.d. Šmartinska 140 SI-1000 Ljubljana, Slovenia Tel.: +386 1 5876 600 Faks: + 386 1 5876 684 Registered at the District Court of Ljubljana under entry no. 1/10521/00; Share capital: 20.383.764,81 EUR, Reg. no.: SI59622806; 5446546; Settlement 01000-0002900092. Tax no.: account: letter of incumbency carrying the notary affirmation of the signor authorization, an annual report, an establishment act, articles of association or minutes from the Standard assembly may suffice. In case that data on Legal Representative are not required by AML legislation in a domicile country of Custodian, data on a person opening the security account (an authorised person) are sufficient. As a proof the Custodian is obliged to provide English translation of AML legislation. Power of Attorney (ENCLOSED IN APPENDIX II) Power of Attorney is provided to Custodian by UniCredit Banka Slovenija d.d. and is requested to be duly signed by the Client and notarized. The purpose of Power of Attorney is to empower the Custodian and the Sub-custodian in accordance with local regulation. Broker Authorization and Acknowledgement of Settlement Procedures in Slovenia (ENCLOSED IN APPENDIX III) Above stated document is not mandatory for account opening. In order to make account operative for trading on a stock exchange market and to ensure that client is aware of mandatory settlement institute in Slovenia, UniCredit Banka Slovenija d.d. requests also the Broker Authorization document. Copy of ID document or passport of Legal Representative and Authorised person, who signed the Client Evidence Sheet The copy isn’t necessary required at the account opening but upon request. If the copy isn’t provided within 1 month after request, the bank will block the security account and will not execute any transactions, payments and corporate actions. ADDITIONAL DOCUMENTS SPECIFIC TO EACH PROCEDURE: Simplified procedure: Proof, that a company is entitled for simplified procedure, if this is not proved by the certificate of registration. If the company is listed on an organised market in EU countries and other EEA countries (Iceland, Liechtenstein and Norway including Serbia, Turkey and Macedonia, we need the name of stock exchange. In a case that above listed documentation for the client can’t be provided, the Custodian can provide documents, which the Custodian has used for client identification. The provided documentation should state: o company name and seat, o legal status, o tax number, o proof that the client is entitled for simplified procedure. If the Certificate of Registration (CoR) or similar document is older than 3 months then the statement of the custodian that CoR is still valid, has to be provided. UniCredit Banka Slovenija d.d. Šmartinska 140 SI-1000 Ljubljana, Slovenia Tel.: +386 1 5876 600 Faks: + 386 1 5876 684 Registered at the District Court of Ljubljana under entry no. 1/10521/00; Share capital: 20.383.764,81 EUR, Reg. no.: SI59622806; 5446546; Settlement 01000-0002900092. Tax no.: account: Client’s Evidence Sheet for simplified procedure (ENCLOSED IN APPENDIX IV) The document is provided to Custodian by UniCredit Banka Slovenija d.d. and needs to be fulfilled and duly signed by the Client’s legal representative and by an authorised signatory of the Custodian. The Custodian is required to authenticate the information provided in the Client’s Evidence Sheet. Standard Procedure: Client’s Evidence Sheet for Standard procedure (ENCLOSED IN APPENDIX V) The document is provided to the Custodian by UniCredit Banka Slovenija d.d. and needs to be fulfilled and duly signed by the Client’s legal representative and by an authorised signatory of the Custodian. The Custodian is required to authenticate the information provided in the Client’s Evidence Sheet. Ownership Structure Ownership structure has to be provided in form of Certificate of Registration or Extract from Court or other public Register of companies or other official document. Document could be provided as a copy not older than three months or as a link to web page of the official register. In a case that the data from the official register are not available a contract of partnership, other contract of establishment, an annual report or a statement, signed by the legal representative can be presented. The provided documentation shall disclose the natural person(s) who owns, controls or otherwise exercises control over the management of a legal entity including through bearer share holdings. Following data are required for owners with share of more than 25%: a name and a surname, a permanent and a temporary address, a date of birth, a citizenship and ownership share, For open-end funds the ownership structure of the Management Company is required. While for close-end funds, a disclosure of final beneficial owner of the fund unit is required. Comprehensive procedure: In a case of Comprehensive procedure all documents as for Standard procedure are required. Additionally: The source of funds, which are or will be the subject of the business relation or transaction, shall be disclosed. If not already published in the Bankers Almanac, bank type entities must provide a completed anti-money laundering questionnaire based on the Wolfsberg Group designed template. ADDITIONAL DOCUMENT SPECIFIC TO FIDUCIARY ACCOUNT: Statement that client is authorized to perform custody services (ENCLOSED IN APPENDIX VI). UniCredit Banka Slovenija d.d. Šmartinska 140 SI-1000 Ljubljana, Slovenia Tel.: +386 1 5876 600 Faks: + 386 1 5876 684 Registered at the District Court of Ljubljana under entry no. 1/10521/00; Share capital: 20.383.764,81 EUR, Reg. no.: SI59622806; 5446546; Settlement 01000-0002900092. Tax no.: account: RENEWAL OF DOCUMENTATION: The renewal of documentation (except for the Power of Attorney and the Broker Authorization and Acknowledgement of Settlement Procedures in Slovenia) is required for active security accounts on a periodic basis with the following frequency: for Comprehensive procedure (high risk client or those with higher risk classification)every two years; for Standard procedure (medium risk customers) - every three years; for Simplified procedure (low risk customers- every five year. If there were no transactions and assets on the securities account more than 12 month, such securities account is no longer listed as active account. In accordance with the Slovene law and internal banking policies, bank will not allow reactivation of dormant securities accounts in its books unless all documentation, required under the Slovene Know Your Customer and AntiMoney Laundering legislation, is in a place. Consequently, in order to ensure future trading activity is not impacted, UCB Slovenia requires the review of documentation for dormant account every five years. The list of active security accounts and inactive accounts due for up-date would be provided monthly at least 3 months in advance. Required documentation for up-date will be specified for each client in line with valid account opening requirements. MISSING DATA OF EXISTING CLIENTS Additionally required data by new AML legislation for existing clients should be provided up to 19th of November 2018 at latest. The clients, due for renewal, are obliged to provide additional data already at first due renewal. UniCredit Banka Slovenija d.d. Šmartinska 140 SI-1000 Ljubljana, Slovenia Tel.: +386 1 5876 600 Faks: + 386 1 5876 684 Registered at the District Court of Ljubljana under entry no. 1/10521/00; Share capital: 20.383.764,81 EUR, Reg. no.: SI59622806; 5446546; Settlement 01000-0002900092. Tax no.: account: APPENDIX I: LIST OF COUNTRIES BY GEOGRAPHICAL RISK AREA List of Countries (updated 27.02.2017).docx APPENDIX II: POWER OF ATTORNEY 1. Power of Attorney (POA).doc APPENDIX III: BROKER AUTHORIZATION 3. Broker 3. List of local Authorization.doc brokers - January 2017.pdf APPENDIX IV: CLIENT EVIDENCE SHEET FOR SIMPLIFIED PROCEDURE 2A. Client Evidence Sheet (CES) Simpl..docx APPENDIX V: CLIENT EVIDENCE SHEET FOR STANDARD/COMPREHENSIVE PROCEDURE 2B. Client Evidence Sheet (CES) Stand. Comp..docx APPENDIX VI: STATEMENT FOR FODUCIARY ACCOUNT Microsoft Word 97 - 2003 Document UniCredit Banka Slovenija d.d. Šmartinska 140 SI-1000 Ljubljana, Slovenia Tel.: +386 1 5876 600 Faks: + 386 1 5876 684 Registered at the District Court of Ljubljana under entry no. 1/10521/00; Share capital: 20.383.764,81 EUR, Reg. no.: SI59622806; 5446546; Settlement 01000-0002900092. Tax no.: account:
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