This statement is provided as per the provisions of art. 21 of Legislative Decree 21 November 2007, no. 231 and its subsequent amendments, and its purpose is to provide information required to verify the clients as foreseen by Title II, Chapter I, Section I of the above mentioned decree and the related implementation provisions of Banca d Italia. QUESTIONNAIRE FOR THE APPROPRIATE VERIFICATION OF CLIENTS: LEGAL PERSONS CLIENT (LEGAL ENTITY / FOUNDATION)( 1 )( 2 ) HOLDER CO-HOLDER Company name: Registered Office: Type of legal status: VAT registration number: Tax Code: Field of activity: (cf. note 1 below) S.p.A. Legal Person (other than an S.p.A.) Ecclesiastical organizations Organizations lacking a legal person Non-profit organization (beneficiaries: ) (e.g.: the homeless, disabled persons, victims of a natural disaster or war, etc.) Trust (Purpose: ; Location/Country of establishment: ) Other (Please Specify) o Field of economic activity (SAE) o ATECO Code Place and date of establishment: Purpose of establishment: Nationality: Administrative Office: Registered head office: Registration Number in the Companies Register of: Enrollment in the Registry: Mailing address (if different from the registered office): No. ( 1 ) In the event of more individuals (holder/co-holder) the questionnaire must be filled out by each party. ( 2 ) Attach documentation that attests to the information provided (deed of incorporation, statutes, last approved balance sheet, title searches, copy of the deeds of allocation of powers; control structures; group of affiliation and/or participation chain).
Main area of activity: (cf. note 2 below) Secondary offices both national and foreign: - Commercial, operational, financial relations with other Countries: - Shares in foreign companies: o Northern Italy o Southern Italy and Islands o Central Italy Foreign country o Northern Italy o Southern Italy and Islands o Central Italy Foreign country No Yes (Please Specify) No Yes ( 3 ) Phone Number: E-mail: Fax: Operation Type of relation To be completed by: - Bank wire from checking account no., IBAN, in the name of ( 4 ) ; - Cashier s check on checking account no., IBAN, in the name of ( 5 ) Origin of the funds used: real estate income returns on capital company returns inheritance Shareholders contributions sale of real estate/goods disinvestment/disposal of financial instruments and other investments loan/financing other (please specify: ) undeclared Signing common investment shares Transferring common investment shares Real estate consultancy (3) Attach documentation that attests to the nature of the participation and with regards to the company participated in: name, registered office and administrative offices, company officials. ( 4 ) Specify all account holders on the checking account. ( 5 ) Specify all account holders on the checking account.
Nature and purpose of the relation/operation Turnover, in euro (on an annual basis) (please specify) up to 1 million 1 to 5 million 5 to 10 million above 10 million Legal Representative( 8 ) Name Surname Place and date of birth Province Address of Residence Domicile/mailing address (if different from the address of residence) Phone number: Fax: Tax Code Politically exposed persons (PEP) (cf. note 3 below) Company Structure ( 6 )( 7 ) Yes No Sex M F Nationality: Email: **** Subject authorized to work on the relation (Proxy/Delegate/Agents/Curators/Official Receiver/Trustee) Settlor and Protector (*) (include data for all subjects who have authority to act in the name of and on behalf of the holder of the relation, in other words of the person who has the trust available (Settlor), or the subject with the power to control and act (Protector) Name Surname/Title Place and date of birth Sex M F Province Nationality: Address of residence/registered office Domicile/mailing address (if different from the address of residence) Phone number: Email: Fax: Tax Code/VAT Number (*) Acting in the capacity of (Please specify) Politically exposed persons (PEP) (cf. note 3 below) Yes No ( 6 ) If one or more sections apply to several subjects, said section/s must be filled out by each person. The actual existence of the power to represent must be verified and information necessary to verify the identity of all pertinent delegate representatives of the company must be collected for all related operations. ( 7 ) Attach a copy of a valid and current identification document and of the tax code. ( 8 ) Even in the event of a legal person type trustee.
Relation between Client and Executor (when applicable):
TRUSTOR / BENEFICIARY INFORMATION ( 9 ) Physical person Trustor / Trustee ( 10 ) Name Surname Place and date of birth Sex M F Province Nationality: Address of residence Domicile/mailing address (if different from the address of residence) Phone number: Email: Fax: Tax code Politically exposed persons (PEP) Yes No (cf. note 3 below) Legal person Trustor / Trustee ( 11 ) Title/Company name: Registered office: Administrative offices: Type of legal status: VAT number (enrollment in the company registry): Tax Code: Main area of activity (geographic area): (cf. note 2 below) S.p.A. Legal person (other than an S.p.A.) Ecclesiastical organizations Organizations lacking a legal person Non-profit organization (beneficiaries: ) (e.g.: the homeless, disabled persons, victims of a natural disaster or war, etc.) Other (please specify) o Northern Italy o Southern Italy and Islands o Central Italy o Foreign Country ( 9 ) Fill out only in the event of Trustor/Trustee client. In the event of multiple subjects the section must be filled out by each party. ( 10 ) Attach a copy of a valid and current identification document and of the tax code. ( 11 ) The section related to the actual holder must also be filled out.
Actual Holder( 12 )( 13 ) Noting that actual holder refers to the physical person or persons that, ultimately, own or control the client, meaning they are its beneficiaries as described below; I declare, on my own responsibility, that There is/are no Actual Holder/s (Reason: There is/are Actual Holder/s (fill out the following section) Name Surname Place and date of birth Sex M F Province Nationality: Address of residence Tax code Politically exposed persons (PEP) (cf. note 3 below) Yes No Subjects identified that belong to the Politically exposed persons (Pep) category ( 12 ) In the event of more than one actual holder, this section must be filled out by each party. ( 13 ) Attach a copy of the identification document and of the tax code.
(to be filled out in the presence of the PEP physical persons residing in other states of the community or outside the community or in Italy who are or were appointed to important public positions and their direct family members or persons with whom they hold well known close ties) Type of Pep National Foreigner Name 14 - Head of State, Head of Government, Minister and Vice Minister or Undersecretary - Member of Parliament - Member of the Supreme Court, of the Constitutional Court and other high level Judicial Bodies; - Member of the Court of Audits and of the Administration Councils of the Central Banks; - Ambassador, Business Manager and high level official of the Armed Forces - Member of the Administrative, Management or Auditing bodies of State owned Companies. - Regional, provincial and municipal manager, mayor member of regional councils - Direct family members of Pep [a) spouse, b) children and their spouses, c) cohabitees of a) and b) within the last five years, d) parents] Please provide Details - Subject with whom politically exposed persons hold well-known close ties 14 Specify whether it refers to the client (holder of the relation), the actual holder, meaning the subject/s that has/have the authority to act in the name of and on behalf of the client or the Settlor or the subject with power to control and act (Protector)
The undersigned, aware of the criminal consequences of false statements, declare/s that the above information, including all information identifying the holder of the relations/operation described in the pertinent fields of this Form, is correct, complete and up to date, and declare/s having provided all information known to him/her/them, including information about the actual holder. The undersigned commit/s to promptly report to InvestiRE SGR S.p.A. any change to the information presented in this Form. Place and Date Legal Representative s Signature ea Authorized person s Signature (proxy/delegate/executor/other) The undersigned (15) declares: having fulfilled the obligations of appropriate verification, in compliance with current regulations on recycling and on the prevention of financing of terrorism (Leg. Dec. 231/2007 and implementation provisions) having verified the power to represent. Place and date, Signature of SGR s representative We authorize continuing relations with Politically Exposed Persons. Place and date, Managing Director (15) Name of SGR s representative who performed appropriate verification.
(a) Documents to be attached: Photocopy of a current and valid identification document (cf. note 5 below) and of the tax code (legal representative/delegate/proxy/executor/actual holder/trustor); Copy of the deed of incorporation; Copy of the Company Statutes; Currently valid title searches; last approved balance sheet; Last VAT statement; Copy of the deeds of allocation of powers; Control structure: affiliation group and/or chain of participation; Documentation about the trust (e.g. deed of establishment); Business relations with the other owners (if applicable); Commercial, operational, financial relations with other Countries (if applicable); Participation in foreign companies (amount of participation; company participated in; registered and administrative head office; company officials) (if applicable).
Notes for completion 1. Economic Activity Sector (SAE): the clients economic activity sector must be specified. Information is compulsory in registrations related to ongoing relations and operations on the account. ATECO: the client s 2007 (or later) ATECO Code must be specified. Information is compulsory in registrations related to ongoing relations and operations on the account. Codes may be verified through a title search. 2. Main area of activity: e.g. region, city. 3. Politically exposed persons (PEP): Subjects living in another State in the community or outside the community or a direct relative or individuals with whom they hold well known close ties must provide the information requested (see list); Italian politically exposed persons physical persons living on national soil who hold or have held important positions. 4. Actual Holder: a) In the event of a company: (i) The physical person or persons that own/s or control/s a legal person through direct or indirect ownership or control of a sufficient percentage share of the share capital or of the rights to vote within the aforementioned legal person, even through bearer shares, provided it is not a company traded on a regulated market that is subject to communication obligations as per the provisions of community regulations or equivalent international standards; this criteria is considered fulfilled when participating in 25% plus one of the share capital; (ii) The physical person or persons who in some other manner exercise control of the management of a legal person; b) In the event of legal persons such as judicial foundations and institutions such as trusts, which manage and distribute funds: (i) If future beneficiaries have already been determined, the physical person or persons who is/are beneficiary/ies of 25% or more of a legal person; (ii) If the beneficiaries of the legal person have yet to be defined, the category of persons in whose main interest the legal person has been established or acts; (iii) The physical person or persons who exercise control over 25% or more of a legal person; (iv) If different, each trustee of the trust, if yet to be identified; c) in the event of a non-profit organization, points (i) and (ii) of the above letter b) will apply; d) in the event of scenarios other than the ones described above ( 16 ), the actual holder must be identified: (i) in subjects that hold a share greater than 25% of the organization s fund or capital; (ii) and if different in subjects that, as a result of the incorporation agreement (and subsequent amendments and additions) or of other deeds or circumstances, are holders of a percentage of votes within the organization s decision-making body that is greater than 25%, or of the right to express majority of the members of the administration. In all of the above scenarios, if one or more subjects identified according to the preceding criteria is not a physical person, the actual holder will be the physical person or persons that, ultimately, directly or indirectly owns or controls the aforementioned subject. The actual holder can be one or more persons in charge of administration, due to the influence they may exercise on the decisions reserved for participants of the organization, with regards, in particular, to decisions related to the appointment of those in charge of administration. This appraisal is of particular relevance when the client does not meet the conditions specified in points 1) and 2) of letter d) above. ( 16 ) For example when the client is a consortium or other organization defined by an equivalent ownership structure (network of companies, parenthetical cooperative group, economic group of European interest, etc.) or another organization or association of any type.
5. Identification document refers to the I.D. card and any equivalent identification documents (passport, driver s license, boating license, retirement booklet, license to run heating plants, gun permit, I.D. cards, as long as the document bears a photograph and a stamp or other equivalent mark, and is issued by a State authority) that are still current and up to date.