BNU - Macau

Compliance

BANCO NACIONAL ULTRAMARINO, SA, MACAU

Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT)

Disclosure Statement

1. Administrative Information

Legal name: Banco Nacional Ultramarino, SA (BNU)

Main place of business / legal address: Avenida Almeida Ribeiro, No. 22, Macau (China)

Place of incorporation: Macau (China)

SWIFT BIC Code: BNULMOMX

Legal status: Private Bank

Shareholders: Caixa Geral de Depositos, SA., Lisbon (97.12%)

Cia.de Seguros Fidelidade-Mundial, SA, Lisbon (1.88%)

Caixa-Participacoes, SA, Lisbon (1%)

Regulators: Monetary Authority of Macau (AMCM)

Financial Intelligence Office (GIF)

Financial Institution Register: Macau - 13548

External Auditors: Deloitte Touche Tohmatsu

AML / CFT contact:

Name: Joao Albuquerque (Compliance Officer)

Address: Avenida Almeida Ribeiro, No.22, Macau (China)

Phone Number: (853) 28355175 (Direct Line) / (853) 83989108

Fax Number: (853) 28323712

Email address: joaoalbq@bnu.com.mo

2. Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT)

International Framework:

Macao China became a member of the Asia Pacific Group on Money Laundering (APG) in May 2001.

The AML/CTF policies of BNU are based in the UN Instruments and Resolutions and Other Relevant International Standards on Money-Laundering and Terrorist Financing, such as the following:

• 40 Recommendations of FAFT/GAFI (developed in 1990, revised in 1996, 2003 e 2004) - that provide a complete set of counter-measures against money laundering covering the criminal justice system and law enforcement, the financial system and its regulation, and international co-operation;

• 9 Special Recommendations of FAFT/GAFI (issued in 2001, updated in 2004) that set out principles for action to detect, prevent and suppress the financing of terrorism;

BNU (Macao) is a Bank of CGD Group (Portugal). Portugal is a European Union (EU) State Member and a Member Country of the Financial Action Task Force on Money Laundering (FAFT/GAFI). In accordance with that BNU and all its domestic branches and representative office (in Shanghai), adhere to and apply the European Union (EU) legislation and standards on Money-Laundering and Terrorist Financing, specific the following:

• the 3rd AML Directive (to address the revised FAFT standards), that was transposed to Portuguese law in 2007.

Local Framework:

The AML/CFT policies of BNU are based not only in International legal instruments in accordance with the above International Framework, but also in local legislation (laws and regulations issued by Macau SAR) and regulatory obligations (guidelines issued by Monetary Authority of Macau/AMCM), specific in the following domestic AML/CTF legal rules:

• Laws and regulations issued by Macao SAR on AML / CFT:

• Law No. 2/2006 on Prevention and Suppression of the Crime of Money Laundering (4^th April, 2006);

• Law No. 3/2006 on Prevention and Suppression of Crimes of Terrorism (11^th April, 2006);

• Administrative Regulation No. 7/2006 on Preventative Measures for the Crimes of Money Laundering and Financing of Terrorism (12^th November, 2006);

• Related laws and regulations issued by Macao SAR:

• Decree-Law no. 5/91/M of 28^th January on Drugs Control (Articles 22 and 34);

• Decree-Law no. 32/93/M, that approves the FSA (Article 9; Paragraph 1 (d) of Article 22; Articles 40, 41, 47, 48 and 53; Paragraph 1 (b) of Article 79 and Article 106);
• Criminal Code, approved by Decree-Law no. 58/95/M of 14^th November (Paragraph 2 of Article 103, Articles 166, 167, 168, 169, 170, 171 and 227);

• Law 6/97/M of 30^th July on Organized Crime

• Decree-Law no. 24/98/M of 1^st June that establishes a Preventive Measure on Crimes involving Converting, Transferring or Dissimulating Illegally obtained Funds or Properties, referred in Article 10 of Law 6/97/M;

• Law no. 4/2002 that implements measures under the international conventions signed and ratified by the Central Government applicable to Macao SAR, specific the anti-terrorism measures under Resolution no. 1373 and other relevant resolutions of the United Nations Security Council;

• Law no. 6/2008 on Combating the People Traffic Crime

• Guidelines issued by AMCM:

• Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Guideline for Financial Institutions;
• Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Guideline on Large Cash Transactions

BNU is committed to adopted policies, procedures and controls to ensure that complies with all AML/CFT obligations.

For more information please see: BNU Anti-Money Laundering Controls

3. AML / CFT Measures in International Operations of BNU

In the International operations that BNU has a controlling interest in, policies and procedures are in place, which assist the operations to comply with their respective domestic AML/CTF laws.

BNU has a policy prohibiting accounts / relationships with shell banks

For more information please see: BNU Wolfsberg AML Questionnaire

4. USA PATRIOT ACT CERTIFICATE

Under the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA Patriot Act) Act 2001, BNU may be required to provide Certification Regarding Accounts for Foreign banks. For that purpose, please see the attached document for a copy of this Certificate.

For more information please see: USA Patriot Act Certificate

This declaration is provided to you for information purposes only and is without legal recourse to BNU or any of its branches, officers or agents.