SFC POLICIES SAGICOR FATCA POLICY. VERSION 2.0 Date: May Name of Policy Page 1 of 18

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1 SFC POLICIES SAGICOR FATCA POLICY VERSION 2.0 Date: May 2015 Name f Plicy Page 1 f 18

2 Sagicr FATCA Plicy TABLE OF CONTENTS 1.0 REVISIONS POLICY PURPOSE: OVERVIEW: SCOPE: ROLES AND RESPONSIBILITIES: DEFINITIONS: INTER-GOVERNMENTAL AGREEMENTS (IGAs) DUE DILIGENCE REPORTING ENFORCEMENT AND SANCTIONS GOVERNANCE STRUCTURE OTHER RELEVANT POLICIES EXCEPTIONS APPENDIX A - FFI s within SGJ with reprting bligatins under FATCA FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 2 f 18

3 Plicy ID FAT001 Revisin 2.0 Effective Date: Immediately Title Sagicr FATCA Plicy Prepared By: Lesa Wilkinsn Reviewed By: Hpe Wint VP, ERM & Grup Cmpliance Bard Apprval: Crprate Gvernance Cmmittee Print Date mm/dd/yyyy Date Prepared mm/dd/yyyy Date Reviewed mm/dd/yyyy Date Apprved/Ratified 07/03/ REVISIONS There are minr drafting edits thrughut the dcument. The substantive changes are the inclusin f a definitin fr Specified U.S. Persns and the additin f the fllwing In Scpe Entities in the Appendix: X Funds Prperties Ltd Sagicr Pled Investment Funds Ltd 2.0 POLICY PURPOSE: This Plicy is prepared in fulfilment f Sagicr Grup Jamaica Limited s (SGJ) bligatins under the Freign Accunt Tax Cmpliance Act (FATCA) t establish due diligence and client n barding plicies and prcedures in rder t: identify and dcument relatinships with U.S. Persns; btain apprpriate due diligence infrmatin and; ensure disclsure and reprting bligatins are met. 3.0 OVERVIEW: FATCA was enacted in the United States n March 18, 2010 and the final Regulatins were published n January 17, The gal f FATCA is t cmbat tax evasin by ensuring that U.S. Persns with financial assets utside the U.S. pay U.S. taxes. The U.S. Gvernment aims t achieve this thrugh infrmatin gathering frm freign financial institutins. Accrdingly FATCA requires that FFIs reprt and disclse certain freign financial accunts wned by: a) U.S. Persns (individuals and entities) and b) Nn U.S. Entities which have U.S. Cntrlling Persns. 4.0 SCOPE: This dcument is intended t guide staff f entities within SGJ which fall within the purview f the FATCA framewrk ( In Scpe Entities ) in carrying ut their due diligence and reprting bligatins as required by FATCA. Appendix A identifies the entities within SGJ which fall within the purview f the FATCA regime. As such these entities are mandated t cmply with specific due diligence prcedures and reprting bligatins based n FATCA s requirements. FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 3 f 18

4 5.0 ROLES AND RESPONSIBILITIES: I. The Bard The Bard f SGJ must be apprised f the Grup s bligatins under the Freign Accunts Tax Cmpliance Act (FATCA) t establish due diligence and client n barding plicies and prcedures. It will be respnsible fr reviewing and apprving this Plicy and ensuring the Bards f the respective entities within the SGJ are s apprised. II. The Respnsible Officer The appinted Respnsible Officer is the Vice President, Enterprise Risk Management (ERM) & Grup Cmpliance f SGJ wh wns and administers this Plicy and is: a) Respnsible fr versight and sufficiency f SGJ s FATCA cmpliance prgram; b) Required t prvide requisite certificatins (if any) n behalf f SGJ regarding cmpliance; and c) Respnsible fr ensuring the Plicy s currency, annual review and re-apprval by the SGJ Bard (if required). III. IV. The Pint f Cntact The Respnsible Officer may appint Pints f Cntact (POC) t assist with managing issues fr SGJ bth internally prviding guidance t team members where required and externally where infrmatin is t be prvided t the lcal tax authrity and the IRS. The Manager, Grup Regulatry Cmpliance has been appinted the POC fr SGJ and its In Scpe Entities. Grup ERM and Cmpliance This Plicy shall be maintained by the ERM & Grup Cmpliance Department and members f the Department will prvide guidance t staff n their bligatins under FATCA. V. Relatinship Manager The Relatinship Managers within SGJ s In Scpe Entities have a key rle in the due diligence prcesses and prcedures as reliance will be placed n their actual knwledge f the custmer. As such where the required due diligence prcedures are applied t High Value Accunts and there is n U.S. indicia present, the Relatinship Managers assigned t the accunts will be cnsulted t advise n their actual knwledge f whether the custmer is a U.S. Persn. Additinally, the Relatinship Managers shall bring t the attentin f the Head f Department r the Pint f Cntact any change in circumstance f which they have becme aware which culd give rise t U.S. indicia being present r assciated with the accunt. This applies fr example in the case where the accunthlder has a new mailing address in the U.S. r there are standing instructins t FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 4 f 18

5 transfer funds t the U.S. as the SGJ In Scpe Entity which maintains the accunt will be bligated t apply the apprpriate due diligence prcedures theret. VI. Team Members All Team Members are required t read and familiarize themselves with this Plicy. Unit Heads must ensure that new staff members are given an pprtunity t read the Plicy during the rientatin prcess and are apprpriately trained n FATCA nbarding and due diligence requirements. Where a Team Member has actual knwledge that infrmatin prvided by a custmer is incrrect r misleading as it relates t his U.S. status, the team member shuld advise the Head f Department r Pint f Cntact accrdingly, indicating the basis f knwledge. 6.0 DEFINITIONS: a) Bard means the Bard f Directrs f Sagicr Grup Jamaica Ltd. b) Sagicr Grup Jamaica Ltd r SGJ means Sagicr Grup Jamaica Ltd and the entities within this Grup. c) Chief Financial Officer r CFO means the Executive respnsible fr preparing and submitting all financial statements in respect f SGJ as required by law and Cmpany Plicy. d) $ - All dllar amunts are in U.S. dllars r the equivalent in any ther currency. e) IRS means United States Internal Revenue Service. f) Entity means any legal persn r legal arrangement (such as a Trust), but excludes an individual acting in a persnal capacity. g) Freign Financial Institutin r FFI means any financial institutin that is a freign entity nt frmed under U.S. laws which are classified as fllws: i. Custdial Institutin which is an Entity that hlds as a substantial part f its business, financial assets fr the accunt f thers; ii. Depsitry Institutin which is an Entity that accepts depsits in the rdinary curse f banking r similar business; iii. Investment Entity; r iv. A Specified insurance Cmpany FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 5 f 18

6 h) An Investment Entity means any Entity that cnducts as a business (r is managed by an entity that cnducts as a business) ne r mre f the fllwing activities r peratins n behalf f a custmer: i. trading in mney market instruments (cheques, bill, certificates f depsit, derivatives, etc.); freign exchange, interest rate and index instruments; transferable securities r cmmdity futures trading; ii. individual and cllective prtfli management; r iii. therwise investing, administering r managing funds r mney n behalf f thers. i) Specified insurance Cmpany means any Entity that is an insurance cmpany (r hlding cmpany f an insurance cmpany) that issues r is bligated t make payments with respect t a Cash Value Insurance cntract r an Annuity Cntract. j) Specified U.S. Persn means a U.S. Persn ther than: i. a crpratin the stck f which is regularly traded n ne r mre established securities markets; ii. any crpratin that is a member f the same expanded affiliated grup as a crpratin described in clause (i); iii. the United States r any whlly wned agency r instrumentality theref; iv. any State f the United States, any U.S. territry, any plitical subdivisin f any f the freging, r any whlly wned agency r instrumentality f any ne r mre f the freging; v. any rganizatin exempt frm taxatin under sectin 501(a) r an individual retirement plan as defined in sectin 7701(a)(37) f the U.S. Internal Revenue Cde; vi. any bank as defined in sectin 581 f the U.S Internal Revenue Cde; vii. any real estate investment trust as defined in sectin 856 f the U.S. Internal Revenue Cde; viii. any regulated investment cmpany as defined in sectin 851 f the U.S. Internal Revenue Cde r any entity registered FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 6 f 18

7 with the Securities Exchange Cmmissin under the Investment Cmpany Act f 1940 (15 U.S.C. 80a-64); ix. any cmmn trust fund as defined in sectin 584(a) f the U.S. Internal Revenue Cde; x. any trust that is exempt frm tax under sectin 664(c) f the U.S. Internal Revenue Cde r that is described in sectin 4947(a)(1) f the U.S. Internal Revenue Cde; xi. a dealer in securities, cmmdities, r derivative financial instruments (including ntinal principal cntracts, futures, frwards, and ptins) that is registered as such under the laws f the United States r any State; r xii. a brker as defined in sectin 6045(c) f the U.S. Internal Revenue Cde. k) Cash Value Insurance Cntract means an insurance cntract (ther than an indemnity reinsurance cntract between tw insurance cmpanies) that has a cash value greater than US$50, l) Cash Value means the greater f: i) the amunt the plicyhlder is entitled t receive upn surrender r terminatin f the cntract (determined withut reductin fr any surrender charge r plicy lan) and, ii) the amunt the plicyhlder can brrw under r with regard t the cntract. Ntwithstanding the freging the Cash Value des nt include an amunt payable under an insurance cntract as: i. A persnal injury r sickness benefit r ther benefit prviding indemnificatin r ecnmic lss incurred upn the ccurrence f the event insured against; ii. A refund f the plicyhlder f a previusly paid premium under an insurance cntract (ther than under a life insurance cntract) due t plicy cancellatin r terminatin, decrease in risk expsure during the effective perid f the insurance cntract r arising frm a redeterminatin f the premium due t crrectin f psting r ther similar errr; r iii. A plicyhlder dividend based upn the underwriting experience f the cntract r grup invlved. FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 7 f 18

8 m) U.S. Persn means a U.S. citizen r U.S. resident, a partnership r crpratin rganized in the U.S. r under the laws f the U.S. and sme trusts, r an estate f a deceased persn that is a citizen r resident f the U.S. Nte that a U.S. Persn des nt include: i. a publicly traded crpratin; ii. the U.S. gvernment r any whlly wned agency theref; iii. individual retirement plans; iv. any bank; v. regulated investment cmpany; vi. real estate investment trust; vii. dealers in securities, cmmdities, r derivative financial instruments. n) Nn-U.S Entity means an Entity which is nt a U.S. Persn. ) Cntrlling Persns are the natural persns wh exercise ultimate effective cntrl ver an Entity. In the case f a trust such persns wuld be the settlr (i.e., the ne establishing the trust), the trustees, the beneficiaries, r class f beneficiaries and any natural persn wh exercises ultimate cntrl ver the trust r in ther legal arrangements. p) Recalcitrant means any custmer wh fails t cmply with reasnable requests fr infrmatin t determine whether the accunt is a U.S. accunt r fails t prvide the infrmatin fr reprting. q) Brad Participatin Retirement Fund means a fund established in Jamaica / Cayman / Csta Rica t prvide retirement, disability, r death benefits, r any cmbinatin theref, t beneficiaries that are current r frmer emplyees f ne r mre emplyers in cnsideratin fr services rendered, prvided that the fund: i. Des nt have a single beneficiary with the right t mre than 5% f the fund s assets; ii. Is subject t gvernment regulatin and prvides annual FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 8 f 18

9 iii. infrmatin reprting abut beneficiaries t the relevant tax authrities in Jamaica / Cayman / Csta Rica; AND Satisfies at least ne f the fllwing requirements: a) The fund is generally exempt frm incme tax in Jamaica / Cayman / Csta Rica n incme under law due t its status as a retirement r pensin plan; b) The fund receives at least 50% f its ttal cntributins frm the spnsring emplyers (excluding transfers frm ther plans); c) Distributins r withdrawals frm the fund are allwed nly upn the ccurrence f specified events related t retirement, disability, r death (except rllver distributins t ther retirement funds), r penalties apply t distributins r withdrawals made befre such specified events; OR d) Cntributins (ther than certain permitted makeup cntributins) by emplyees t the fund are limited by reference t earned incme f the emplyee r may nt exceed $50,000 annually. r) Narrw Participatin Retirement Fund means a fund established in Jamaica / Cayman / Csta Rica t prvide retirement, disability, r death benefits t beneficiaries that are current r frmer emplyees f ne r mre emplyers in cnsideratin fr services rendered, prvided that: i. The fund has fewer than 50 participants; ii. The fund is spnsred by ne r mre emplyers that are nt Investment Entities r Passive NFFEs; iii. The emplyee and emplyer cntributins t the fund (ther than transfers f assets frm treaty-qualified retirement funds r retirement and pensin accunts classified as certain savings accunts ) are limited t earned incme and cmpensatin f the emplyee; iv. Participants that are nt residents f Jamaica / Cayman / Csta Rica are nt entitled t mre than 20% f the fund s assets; AND FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 9 f 18

10 v. The fund is subject t gvernment regulatin and prvides annual infrmatin reprting abut its beneficiaries t the tax authrities in Jamaica / Cayman / Csta Rica. s) Passive NFFE refers t a Nn-Financial Freign Entity that is nt: i. An Entity rganized under the laws f the U.S. and whlly wned by ne r mre U.S. Persn; ii. A freign gvernment, plitical subdivisin f a freign gvernment, r any whlly wned agency r instrumentality f any ne r mre f them; iii. An Internatinal Organizatin r whlly wned agency r instrumentality f an internatinal rganizatin; iv. A freign central bank (unless acting as intermediary fr clients); v. Any ther class f persns identified by the IRS r US Department f the Treasury as psing a lw risk f tax evasin. t) In this Plicy, the singular includes the plural and the plural includes the singular; and the masculine gender includes the feminine and neuter genders. 7.0 INTER-GOVERNMENTAL AGREEMENTS (IGAs) The United States has entered int an Inter-Gvernmental Agreements with the gvernments f a number f jurisdictins in rder t enable lcal financial institutins t meet FATCA reprting requirements withut breaching lcal privacy laws which prevent sharing f custmer infrmatin with the IRS, withut custmer cnsent. Additinally there is legislatin in many f these cuntries which d nt permit financial institutins t unilaterally terminate custmer relatinships. FATCA laws require that in sme instances custmer relatinships be terminated where custmers fail t prvide requisite infrmatin t establish whether they are U.S. persns fr the purpses f FATCA. There are tw versins f the IGA namely a Mdel 1 and Mdel 2 IGA. Under bth versins all FFIs are required t register with the IRS. Once registered, a Glbal Intermediary Identificatin Number (GIIN) is issued t the FFI. These GIINs are available fr viewing by FFIs n the IRS website and will be updated by the IRS mnthly. 7.1 Mdel 1 IGA The main features f the Mdel 1 IGA are as fllws: FFIs in these cuntries will submit reprts directly t their lcal tax authrities and these authrities in turn will share the infrmatin received with the IRS; FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 10 f 18

11 The IGA eliminates the requirement that U.S. financial institutins withhld taxes (30%) n certain payments made t FFIs in a jurisdictin with an IGA unless in the extreme case where there is significant nn-cmpliance by the FFI in an IGA cuntry which results in the IRS classifying the FFI as Nn-Participating; Under the IGA the requirement fr the FFI t clse the accunt f, r withhld n payments made t the Recalcitrant des nt apply, prvided the FFI submits certain reprtable infrmatin t the lcal tax authrity. This wuld nt be the case in the absence f an IGA; FFI s in jurisdictins with a Mdel 1 IGA need nt enter int separate FFI Agreements with the IRS prvided each FFI is registered with the IRS. There are tw versins f the Mdel 1 IGA namely a Mdel 1A and Mdel 1B. Mdel 1A Under the Mdel 1A IGA, the U.S. is als required t exchange infrmatin held in U.S. financial institutins n residents f the Mdel 1A IGA Partner Cuntry. Mdel 1B Under the Mdel 1B IGA, there is n bligatin f reciprcity n the part f the U.S. Jamaica and Csta Rica have adpted the Mdel 1A IGA hwever the Cayman Islands have adpted the Mdel 1B versin. 7.2 Mdel 2 IGA The main differences between the Mdel 1 and Mdel 2 IGA are: Under the Mdel 2 IGA, FFIs will reprt infrmatin directly t the IRS as ppsed t the Mdel 1 IGA which requires reprting t the lcal tax authrities; The U.S. will nt need t reciprcate r exchange infrmatin held in U.S. financial institutins n residents f the Mdel 2 IGA Partner Cuntry; FFIs are still required t sign an FFI Agreement with the IRS ntwithstanding the existence f the IGA. 7.3 Nn Reprting Entities under the Mdel 1 IGA The Mdel 1 IGA utlines the Reprting Institutins (FFIs) which have specific due diligence and reprting bligatins under FATCA hwever there are sme institutins, funds and financial accunts which are classified as Nn-Reprting Institutins. They are designated Deemed Cmpliant r Exempt Beneficial Owners r Excluded Financial Accunts mainly because they are deemed t present a lw risk f being used by U.S. persns fr tax evasin. The entities include: Exempt Beneficial Owners Gvernment entities and its agencies; The Central Banks f the Mdel 1 jurisdictin; FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 11 f 18

12 Internatinal Organizatins including intergvernmental rganizatins cmprising primarily nn-u.s. gvernments and whse incme des nt inure t the benefit f private persns; Certain Retirement Funds, including Treaty qualified funds - a fund established in Jamaica / Cayman / Csta Rica which is entitled t benefits under an incme tax treaty between Jamaica / Cayman / Csta Rica and the U.S. n incme derived frm surces within the U.S. as a resident f Jamaica / Cayman / Csta Rica that satisfies any applicable limitatin n benefits requirement, and is perated primarily t administer r prvide pensin r retirement benefits; Brad participatin retirement funds; Narrw participatin retirement funds; Pensin fund f an exempt beneficial wner; Investment entity whlly wned by exempt beneficial wners Deemed Cmpliant FFIs Nn-prfit rganizatins; Financial Institutins with a lcal client base satisfying certain requirements; Lcal Bank satisfying certain requirements; Financial Institutins with nly lw-value accunts; Qualified Credit Card Issuer wh nly accepts depsits when a custmer makes a payment in excess f a balance due; Certain Cllective Investment Vehicles; Certain Investment Advisrs and Investment Managers. Excluded Financial Accunts Certain Savings Accunts such as: Retirement and Pensin Accunts that satisfy the fllwing requirements under the laws f Jamaica / Cayman / Csta Rica: The accunt is regulated as a persnal retirement accunt r is part f a registered r regulated retirement r pensin plan fr the prvisin f retirement r pensin benefits (including death r disability benefits); The accunt is tax favured; FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 12 f 18

13 Annual infrmatin reprting is required by the tax authrities in Jamaica / Cayman / Csta Rica with respect t the accunt; Withdrawals are cnditined n reaching a specified retirement age, disability, r death, r penalties apply t withdrawals made befre such specified events; AND Either cntributins are limited t $50,000 r less, r there is a maximum lifetime cntributin limit t the accunt f $1,000,000 r less. Nn-Retirement Savings Accunts that satisfy the fllwing requirements under the laws f Jamaica / Cayman / Csta Rica: The accunt is regulated as a savings vehicle fr purpses ther than fr retirement; The accunt is tax favured; Withdrawals are cnditined n meeting specified criteria related t the purpse f the savings accunt (e.g.) prvisin f educatinal r medical expenses), r penalties apply t withdrawals made befre such criteria are met; AND Annual cntributins are limited t $50,000 r less. Certain Term Life Insurance Cntracts; Accunts held by an estate, if the dcumentatin fr such accunt includes a cpy f the deceased s will r death certificate; Escrw Accunts meeting certain cnditins. 8.0 DUE DILIGENCE 8.1 New Accunt Onbarding All SGJ In-Scpe Entities must take steps t cmply with due diligence prcedures t identify if there are any U.S. indicia with respect t a new custmer s that the new custmers may be classified as fllws: Fr new individual custmers - U.S. persn, a Nn U.S. Persn r Recalcitrant Fr new Entity accunthlders - U.S. persn, FFI r a Nn- Financial Freign entity with U.S Cntrlling Persns r Recalcitrant. The fllwing New Individual Accunts are nt required t be reviewed, identified, r reprted as U.S. Reprtable Accunts: 1. A Depsitry Accunt unless the accunt balance exceeds US$50, at the end f any calendar year r ther apprpriate reprting perid. FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 13 f 18

14 2. A Cash Value Insurance Cntract unless the Cash Value exceeds US$50, at the end f any calendar year r ther apprpriate reprting perid. The due diligence prcess t be applied are utlined in the Due Diligence Plicy. The U.S indicia as utlined by FATCA are as fllws: U.S citizenship r lawful permanent resident; U.S. birthplace; A current U.S. residence address r US mailing address (including a U.S. pst ffice Bx); A current U.S. telephne number ; Standing instructins t transfer funds t an accunt maintained in the U.S; An in care f r hld mail address that is the sle address fr the accunthlder; A current pwer f attrney r signatry authrity granted t a persn with a U.S. address; 8.2 Pre-existing Accunt Analysis In Scpe Entities within SGJ are required t cnduct analysis f pre-existing individual and entity accunts as at June 30, 2014 based n U.S. indicia utlined abve and certain threshlds. Banking & Investments A review is required fr: Lwer Value Individual Accunt with an aggregate value which exceeds US$50,000 but is less than US$1,000,000.00; High Value Accunts with an aggregate balance which exceeds US$1,000,000; Entity Accunts with an aggregate balance in excess f US$250,000. Insurance - Cash Value Insurance and Annuity Cntracts A review is required fr: Lwer Value Individual Accunt with an aggregate value which exceeds US$250,000 but is less than US$1,000,000.00; High Value Individual Accunt with an aggregate balance which exceeds US$1,000,000; Entity Accunts with an aggregate balance in excess f US$250, REPORTING 9.1 Aggregatin I. Aggregatin f Individual Accunts Fr the purpses f reprting t the lcal tax authrities, In Scpe Entities in SGJ must, as far as pssible, aggregate the balance r value f a financial accunt held by an individual custmer f mre than ne In Scpe Entities, within the same jurisdictin t the extent the cmputerized FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 14 f 18

15 systems f these Entities link the accunt by a cmmn data element such as a Taxpayer Registratin Number r client number. Based n the freging aggregatin must ccur where fr example a custmer is cmmn t Sagicr Bank Jamaica Ltd and Sagicr Investments Jamaica Ltd prvided the cmputer systems can aggregate the balance r value f in scpe accunts acrss these entities. NOTE that a jint hlder f an accunt is attributed the entire balance r value f the jintly held financial accunt fr the purpses f applying the aggregatin requirements. II. Aggregatin f Entity Accunts Accunts held by entities acrss In Scpe Entities r acrss business lines in an In Scpe Entity within the same jurisdictin are required t be aggregated in determining the value r value f the Financial Accunt t the extent the cmputerized systems link the accunt by a cmmn data element such as a Taxpayer Registratin Number r client number. 9.2 Infrmatin t be reprted fr U.S. Reprtable Accunts The infrmatin t be shared with the Jamaica and Caymanian lcal tax authrities in respect f a U.S. Reprtable Accunt in the respective jurisdictins is as fllws: i. Name, address, U.S. taxpayer identificatin number (U.S. Tin) f each Specified U.S. persn that is listed as an Accunthlder r in the case f an accunt held by a Nn US entity a Cntrlling Persn wh is a Specified U.S. Persn, the name address and U.S. Tin f any such entity and f each Specified U.S. persn; ii. The accunt number r equivalent (if there is n accunt number); iii. The name and identifying number f the SGJ Reprting Entity; iv. The accunt balance r value (including in the case f a cash value Insurance r Annuity Cntract, the Cash Value r surrender value) as at the end f the calendar year r ther reprting perid, r if the accunt was clsed during the calendar year, immediately befre such clsure. In the Case f a Custdial Accunt The ttal grss amunt f interest, the ttal grss amunt f dividends and the ttal grss amunt f ther incme generated with respect t the assets held in the accunting in each case paid r credited t the accunt (r with respect t the accunt) during the calendar year r ther apprpriate reprting perid; The ttal grss prceeds frm the sale r redemptin f prperty paid r credited t the accunt during the calendar year r ther apprpriate reprting perid the financial institutin acted as custdian, brker nminee r therwise as an agent fr the Accunthlder; The ttal grss prceeds frm the sale r redemptin. In the Case f Depsitry Accunts FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 15 f 18

16 The ttal grss amunt f interest paid r credited t the accunt during the calendar year r ther apprpriate reprting perid. In the Case f Other Accunts The ttal grss amunt paid t the accunthlder by the financial institutin under a legal bligatin and any redemptin payments made during the calendar year r ther apprpriate reprting perid. 9.3 Timelines fr Reprting The infrmatin t be reprted t the IRS thrugh the lcal tax authrities: With respect t 2014: Name, address, U.S. taxpayer identificatin number (U.S. Tin) f each Specified U.S. persn that is listed as an Accunthlder r in the case f an accunt held by an Nn US entity a Cntrlling Persn wh is a Specified US Persn, the name address and U.S Tin f any such entity and f each Specified US persn; The accunt number r equivalent (if there is n accunt number); The name and identifying number f the SGJ Reprting Entity; The accunt balance r value (including in the case f a cash value Insurance r Annuity Cntract, the Cash Value r surrender value) as at the end f the calendar year r ther reprting perid, r if the accunt was clsed during the calendar year, immediately befre such clsure; With respect t 2015: In additin t the freging 2014 items the fllwing: Fr Custdial Accunts - the ttal grss amunt f interest, the ttal grss amunt f dividends and the ttal grss amunt f ther incme generated with respect t the assets held in the accunting each case paid r credited t the accunt (r with respect t the accunt) during the calendar year r ther apprpriate reprting perid; Fr Depsitry Accunts - the ttal grss amunt f interest paid r credited t the accunt during the calendar year r ther apprpriate reprting perid; Fr Other Accunts nt described abve - the ttal grss amunt paid t the accunthlder by the financial institutin under a legal bligatin and any redemptin payments made during the calendar year r ther apprpriate reprting perid. With respect t 2016: All the freging items as utlined abve in additin t the ttal grss prceeds frm the sale r redemptin f prperty paid r credited t the accunt. FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 16 f 18

17 Reprting Exchange Rate Fr the purpse f determining the accunt balance r value f a Financial Accunt which is denminated in a currency ther than U.S. dllars, SGJ and its In Scpe Entities must cnvert the U.S dllar int the currency using the published rate f exchange as at the last day f the calendar year in which the Entity determines the value r balance ENFORCEMENT AND SANCTIONS 10.1 Minr and Administrative Errrs In the case f minr r administrative errrs which may have led t incrrect r incmplete infrmatin being filed, the Cmpetent Authrity i.e., the Ministry f Finance r its delegate, i.e. the lcal tax authrity shall apply dmestic laws t btain crrected r cmplete infrmatin r reslve any ther infringements f the IGA Significant Nn-Cmpliance If a Reprting Financial Institutin under the IGA fails t reslve significant cmpliance failures within 18 mnths f being ntified the FFI will be treated as a Nn-Participating Financial Institutin by the IRS GOVERNANCE STRUCTURE 11.1 Maintenance and Apprval f Plicy The appinted FATCA Respnsible Officer (r designate) will be respnsible fr the maintenance f this Plicy, which includes an annual review and update t ensure its currency. Apprval f this Plicy is the respnsibility f the Bard f SGJ, and hence the initial and subsequent amendments must be s ratified. The Enterprise Risk Management (ERM) & Grup Cmpliance Unit will mnitr and evaluate cmpliance with the plicy n a regular and nging basis OTHER RELEVANT POLICIES The FATCA Due Diligence Prcedures shuld be read in cnjunctin with this Plicy EXCEPTIONS In general, requests fr exceptins, exemptins r deferrals in respect f, this plicy will nt be granted. In rare instances an exceptin, exemptin r deferral may be permitted. Requests fr exceptins, exemptins r deferrals in respect f this plicy must be sent t Enterprise Risk Management & Grup Cmpliance. FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 17 f 18

18 14.0 APPENDIX A - FFI s within SGJ with reprting bligatins under FATCA a) Sagicr Grup Jamaica Limited b) Sagicr Investments Jamaica Ltd c) Sagicr Life Jamaica Ltd d) Sagicr Bank Ltd e) Sagicr Re insurance Ltd f) Sagicr St. Lucia Ltd g) Sagicr Life f the Cayman Islands Ltd h) X Funds Prperties Ltd i) Sagicr Pled Investment Funds Ltd FAT001-Sagicr FATCA Plicy-Revisin 2.0 Page 18 f 18