Geneva, January 2023

The Management and all other staff of Credit Europe Bank (Suisse) SA (CEB SA) endeavors to maintain a company culture and business strategy whereby CEB SA’s core and base values and standards of professional conduct are maintained at every business level and within all its activities. These standards include national, international and European legislation, regulations issued by the relevant local (supervisory) authorities, generally accepted business standards and CEB Group’s  own internal standards (including ethical standards).

CEB SA endeavors to contribute to the global fight against financial-economic crime, such as money laundering, tax evasion, fraud and corruption. CEB SA also undertakes to make business decisions mindful of their potential impact on the environment and society. For this, it has adopted a sustainability strategy to implement effectively the environmental, social and governance (ESG) aspects into its business operations and to pursue a “people, planet and profit” oriented way of doing business across its value chain. By setting sector-specific ESG criteria and maintaining a prohibited activities list, CEB SA aims to address related risks adequately.

CEB SA does not tolerate tax evasion, being a violation of (inter)national law. At the same time, it recognizes that the legal establishment, business structures and transactions of some (legal) entities can be motivated by tax incentives, exemptions, or other tax benefits legally offered by specific (offshore) jurisdictions or specialized tax companies. It is a well-known fact that tax considerations (regular tax planning) play a part in companies and private individuals setting up a legal structure. CEB SA therefore specifically assesses whether a customer’s tax integrity risk falls within CEB Group’s tax integrity risk appetite. Under no circumstances, CEB SA will accept or condone activities or behavior that will or might in any way conflict with any of its core and base values and standards.

CEB SA is committed to create value for its customers whilst meeting its statutory and regulatory obligations. This includes maintaining a financial-economic crime prevention culture. The Bank’s core and base values and standards, and governance and risk management frameworks work together to prevent, detect and respond to potential or actual financial-economic crime conduct. To ensure the Bank understand at all times the integrity risks ￚ also referred to as compliance risks ￚ it is facing, integrity risk assessments are undertaken periodically to determine how these risks are mitigated by the controls that have been implemented and to establish whether the residual risk level is within CEB Group’s integrity risk appetite. CEB SA staff are provided with training and communication in ethics and compliance, including financial-economic crime prevention, to understand their responsibilities and obligations in observing and maintaining high standards of integrity in all CEB SA’s business dealings.

The Management has adopted a Compliance Charter and validated compliance policies on specific topics with the sole purpose of embedding the integrity principles of CEB SA and CEB Group in all levels and structures of its organization. The integrity principles identified by CEB SA are grouped in four (4) categories: staff integrity, customer integrity, organization integrity and services integrity. By implementing these principles in all levels and structures of the organization, CEB SA intends (i) to protect its assets from any form of loss or damage and (ii) to avoid further any kind of negative publicity for its organization.

Although the Management has the overall responsibility for ensuring compliance, it is important to stress that all staff of CEB SA have a duty in respect of compliance. Therefore, the mitigation of any compliance risks is a shared responsibility. For this, the Bank applies three lines of defense model:

• The first line of defense is formed by the Management and business which are ￚas stated hereinabove- primarily responsible for the implementation and maintenance of proper control measures with respect to compliance.
• The second line of defense is formed by the risk management functions ￚincluding the compliance function ￚ that support the first line of defense functions and provide advice on the implementation and maintenance of compliance.

• The third line of defense is formed by the internal audit function, which assesses the functioning and effectiveness of the business units and the risk management and compliance activities.

As compliance is strongly related to socially accepted standards and society is constantly changing, the Bank’s method of mitigating any compliance risks is subject to constant evaluation and upgrade.