KOMMUNAL KREDIT

Annex 2 AML Ordung v. 1.7 / Stand Jan. 2016

AML QUESTIONNAIRE

01/02/2016

General Information

1. Financial Institution (FI) name: Kommunalkredit Austria AG

2. Legal Form: Aktiengesellschaft, registered under Companies Register Number 439528 s, Commercial Court of Vienna

3. Address of Incorporation (head office): Tuerkenstrasse 9, 1092 Vienna, Austria

4. Web address: www.kommunalkredit.at

5. S.W.I.F.T. code: I NVOATWW

6. Name of the regulatory body which supervises the bank: Financial Market Authority (FMA), Otto Wagner-Platz 5, 1090 Vienna, Austria

7. Name of the authority to which you must report in case of suspicion of money laundering or terrorism financing: FederaI Ministry of the Intenor / Directorate General for Public Security / Federal Criminal Police Office / Registration Office Money Laundering, Josef Holaubek-Platz 1, 1090 Vienna, Austria

8. The main business activities of the bank: Structuring and financing of public infrastructure projects

9. Name of external auditors: PwC Wirtschaftsprüfung GmbH, Erdbergstraße 200, 1030 Vienna, Austria

10. Number of branches domestic: none

11. Management/Names of Board of Directors: Mag. Alois Steinbichler (CEO) and Mag. Wolfgang Meister Jörn Engelmann

foreign: none

LACompliance\02_AML\04_Geldwäsche Richtlinien\KA\Stand 01 2016 Page 1/6

ln:errdus Ltd.

54 879%

Tiinity Invesments Limited

44,931%

12. Persons appointed for Anti Money Laundering Work/Name(s) of anti money laundering officer(s):

- Mag. Wolfgang Sorger (Compliance and AML Officer), E-Mail: w.sorger@kommunalkredit.at, phone: +43 (0)1 31631 ext. 165

- Mag. Helmut Schramek (Deputy Compliance and AML Officer), E-Mail: h.schramek@kommunalkredit.at, phone: +43 (0)1 31631 ext. 581

13. Legislation which requires shareholders to obtain regulatory approval before becoming significant shareholder in the bank:

§§ 20, 20a und 20b Austrian Banking Act (Bankwesengesetz)

14. Ownership: Major shareholders and their control percentage (direct and indirect):

1. Gesona Beteiligungsverwaltung GmbH, registered under Companies Register Number 428969 m, Commercial Court of Vienna; Address of Incorporation: Sterngasse 13, 1010 Vienna, Austria; 99,78% direct;

2. Satere Beteiligungsverwaltungs GmbH, registered under Companies Register Number 428981 f, Commercial Court of Vienna; Address of Incorporation: Sterngasse 13, 1010 Vienna, Austria; 99,78% indirect;

3. lnterritus Ltd., registered under Company Number 9132297, Register of Companies for England and Wales; Address of Incorporation: 7-8 Blithfield Street, London, W8 6RH, United Kingdom; 54,879% indirect:

4. Trinity Investments Limited, registered under Registration Number 535698, Companies Registration Office; Address of Incorporation: Fourth Floor, 3 George's Dock, IFSC, Dublin 1, Ireland; 44,901% indirect.

Kommtnekrecit Austria AG

Ge5.0tle Bebiligungsveneeeltung

GmbH

ge,78%

Salere Beedigungsven‘allungs

GmbH

.99,78%

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the Wolfsberg

Group

The Wolfsberg Group Anti-Money Laundering Questionnaire 2014

Financial Institution Name: Kommunalkredit Austria AG

Location: Tuerkenstraße 9, 1092 Vienna, Austria

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 dient due diligence in a manner consistent with the risk profile presented by the client. The responsibility for ensuring ade quate due diligence, which may include independent verification or follow up of the answers and documents provided, remains the responsibilhy c?f* 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: y_gl

YES

14,12

NO 1. Is the AML compliance program approved by the FI's board or a

senior committee?

2. Does the FI have a legal and regulatory compliance program that includes a designated officer that is responsible for coordinating and overseeing the AML framework?

NO

3. Has the FI developed written policies documenting the processes that they have in place to prevent, detect and report suspicious transactions?

YES NO

4. In addition to inspections by the government supervisors/regulators, does the FI client have an internal audit function or other independent third party that assesses AML policies and practices on a reqular basis?

YES NO

NO YES

5. Does the FI have a policy prohibiting accounts/relationships with shell banks? (A shell bank is defined as a bank incorporated in a jurisdiction in which lt has no physical presence and which is unaffiliated with a regulated financial group.)

6. Does the EI have policies to reasonably ensure that they will not conduct transactions with or on behalf of shell banks through any of its accounts or 'products?

YES NO

7. Does the Exposed Persons

FI have policies covering relationships with Politically (PEP's), their family and close associates?

FI have record retention procedures that comply with law?

YES NO

NO YES 8. Does the

applicable 9. Are the Frs AML policies and practices being applied to all branches

and subsidiaries of the FI both in the home country and in locations outside of that 'urisdiction?

YES NO

The Wolfsberg Group consists of the following leading international financial institutions: Banco Santander, Bank of Tokyo-Mitsubishi UFJ, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JID Morgan Chase, Societe Generale and UBS which aim to develop financial services industry standards, and related products, for Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies.

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the The Wolfsberg Group Anti-Money Laundering Questionnaire 2014

Wolfsberg Group

II. Risk Assessment Yes LAQ 10. Does the FI have a risk-based assessment of its customer base and

their transactions? YES NO

11. Does the FI determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that the FI has reason to believe pose a heightened risk of illicit activities at or through the FI?

YES NO

III. Know Your Customer, Due Diligence and Enhanced Due Diligence

i n _N2

12. Hes the FI innplemented processes for the identification of those customers on whose behalf lt maintains or operates accounts or conducts transactions?

YES, NO

13. Does the FI have a requirement to collect information regarding its customers' business activities?

YES NO

14. Does the FI assess its FI customers' AML policies or practices? YES NO 15. Does the FI have a process to review and, where appropriate,

update customer information relating to high risk client information?

YES NO

16. Does the FI have procedures to establish a record for each new customer noting their respective identification documents and „Know Your Customer' information?

icl NO

17. Does the FI complete a risk-based assessment to understand the normal and expected transactions of its customers?

nä, NO

IV. Reportable Transactions and Prevention and Detection of Transactions with Illegally Obtained Funds

Yes N o ,

18. Does the FI have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities?

YES NO

19. Where cash transaction reporting is mandatory, does the FI have procedures to identify transactions structured to avoid such obligations?

YES NO

20. Does the FI screen customers and transactions against lists of persons, entities or countries issued by government/competent authorities?

YES NO

21. Does the EI have policies to reasonably ensure that lt only operates with correspondent banks that possess licenses to operate in their countries of origin?

YES NO

22. Does the EI adhere to the Wolfsberg Transparency Principles and the appropriate usage of the SWIFT MT 202/202C0V and MT 205/205C0V message formatsl?

YES NO

The four payment message standards to be observed are: i) FIs should not omit, delete, or alter Information in payment messages or orders for the purpose of avoiding detection of that information by any other FI in the payment process; ii) FIs should not use any particular payment message for the purpose of avoiding detection of information by any other FI in the payment process; iii) Subject to applicable laws, FIs should cooperate as fully as practicable with other FIs in the payment process when requesting to provide information about the parties involved; and (iv) FIs should strongly encourage their correspondent banks to observe these principles.

SOurCe: litto://www.wolfsbera-orincioles.com/adf/standards/Wolfsbera NYCH Statement on Pavment Messaae Standards (2007).odf

The Wolfsberg Group consists of the following leading international financial institutions: Banco Santander, Bank of Tokyo-Mitsubishi UFJ, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sechs, HSBC, JP Morgan Chase, Societe Generale and UBS which aim to develop financial services industry standards, and related products, for Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies.

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the Woffsberg

Group

The Wolfsberg Group Anti-Money Laundering Questionnaire 2014

V. Transaction lifonitoring Yes No 23. Does the FI have a monitoring program for unusual and potentially

suspicious activity that covers funds transfers and monetary Instruments such as travelers checks, money orders, etc.?

il.ä. NO

VI. AML Training Yes No 24. Does the FI provide AML training to relevant employees that

includes: • Identification and reporting of transactions that must be reported to

government authorities. • Examples of different forms of money laundering involving the FI's

products and services. • Internal policies to prevent money laundering.

YES NO

NO

NO

YES 25. Does the FI retain records of its training sessions including

attendance records and relevant training materials used?

YES 26. Does the FI communicate new AML related laws or changes to

existing AML related policies or practices to relevant employees? 27. Does the FI employ third parties to carry out some of the functions

of the FI? YES NO

28. If the answer to question 27 is yes, does the FI provide AML training to relevant third parties that includes:

• Identification and reporting of transactions that must be reported to governrnent authorities.

• Examples of different forms of money laundering involving the FI's products and services.

• Internel policies to prevent money laundering.

YES NO

The Wolfsberg Group consists of the following leading international financial institutions: Banco Santander, Bank of Tokyo-Mitsubishi UFJ, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Societe Generale and UBS which aim to develop financial services industry standards, and related products, for Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies.

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the Woffsberg The Wolfsberg Group Anti-Money Laundering Questionnaire 2014

Group Space for additional Information: (Please indicate which question the Information is referring to.)

Name: Mag. Wolfgang Sorger, Mag. Helmut Schramek (7---- Title: AML and Compliance Officer, Deputy AML and Co plianceefficz Signature: Kommunalkredit Austria AG

Date: 01/02/2016

The Wolfsberg Group consists of the following leading international financial institutions: Banco Santander, Bank of Tokyo-Mitsubishi UFJ, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Societe Generale and UBS which aim to develop financial services industry standards, and related products, for Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies.

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