the The Wolfsberg Group Anti- 2014 lf;berg euBstionnaire 6ro ryt3;

Financial llnstitution Name: Jointstock company

Location: 11, Z. Byadulistr., 220034 Minsk, Belarus

This questionnaire acfs as an aid to firms conducting due diligence and should not be relied on exclusivelr, or excessively" Firms may use this qu'estionnaire p alongside their own policies and procedures t,n t>rder to conc a manner consistent with the risk profile presented b resp( te due diligertce, which may includ'e indepentlent v w up ts provided, remains the responsibitit,;y of Ehet firm usi ng th is q u estion na i ret. tmrEvoir=[t|Elril.l=nfiTfol If you answer "non'to any question, additionar inforrnation can be supplied at the end of the querstionnaire.

1. Is the AIVL compliance program approved by the FI,s board or a YV No senior committee? 2. Does the FI have a legal and regulatory compliance program YV J\JO that include:; a designated officer that is responsible for coordinerting and overseeinq the AML framework? 3. Has the FI developed written policies documenting the Yg No processes that they have in place to prevent, deter:t and report suspicious transactions? 4. In addition to inspections by the government Yg No supervisors/regulators, does the FI client have an internal audit function or other independent third party that assersses AML policies and practices on a reqular basis? 5, Does thel FI lhave a policy prohibiting accounts/relartionships Yg No with shell banks? (A shell bank is defined as a bank incorporated in a jurisdiction in which it has no physical presence and which is unaffiliated with a regulateot financial qroup.) 6. Does the FI [rave policies to reasonably ensure that they will Yg No not concluct transactions with or on behalf of shell banks throuqh any of its accounts or products? 7. Does ther FI have policies covering relationships wirth Politically YEI No Exposed Persons (PEP's), their familv and close ass;ociates? 8, Does ther FI have record retention procedures that comply with Yg No applicable law? 9. Are the FI's AML policiers and practices being applied to all YEI No branche:s and subsidiaries of the FI both in the honre country and in lo,cations outside of that jurisdiction?

The Wolfsberg Group consists of the following leading international financial institutions: , Bank of Toklyo-Mitsubisfri UFJ, , , , , , HSBC, JP Morgan Chase, Soci6te G6nerale ancl UBS which aim to develop financial servic;es industry standerrds, and related products, for Kno',v Your Customer, Anti-Money L.aundering and Counter Terrorist Financing policies. The Wolfsberg Group Anti-Money Laundering Questionnaire 2:Cr14

F

10, Does the FI have a risk-based YET l\o and their transactions? 11. Does the FI determine the a YET Itl o diligence necessary for those categories of customers and transactions that the FI has reason to believe pose a es at or throuqh the FI?

12. Has the FI implemented processes for the identification of those Y@ [,i o customers on whose behalf it maintains or operat,es accounts or cond ucts tra nsactions? 13. Does the FI have a requirement to coll Yg IG its customers' business activities?

or practrces? Yg I'l,l o 15. Does the FI have a process to review and, where appropriate, YEI |.|lo update customer information relating to high risk client information? 16. Does the FI have procedures to establish a record for each new YEI t\t o customer noting their respective identification documents and 'Know You r Customer' information? 17. Does the FI complete a risk-based assessment to understand Yg r\l o the normal and expected transactions of its customers?

18' Does the FI have policies or practices for the identification and YV No reporting of transactions that are required to be reported to the authorities? 19.Where cash transaction reporting is mandatory, does the FI Yg Nl o have procedures to identify transactions,structured to avoid such obliqations? 20, Does the FI screen customers and transactions against lists of Yg No persons, entities or countries issued by government/competent authorities? 21.Does the FI have policies to reasonably ensure that it only Yg r\r o operates with correspondent banks that possess licenses to operate in their countries of oriqirr? 22. Does the FI adhere to the Wolfsberg Transparency Principles YV No and the appropriate usage of the SWIFT MT 2O2/202COV and Mf 205/205COV messaqe formats?l

23, Does the FI have a monitoring program for unusual and Yg No potentially suspicious activity that covers funds transfers and monetary instruments such as travelers checks, money orders, etc?

payment I The four message standards to be observed are: i) FIs should not omit, dele-te, or alter inrormation in payment messages or orders for l,he purpose of avoiding detection of that information by any other FI in the paymen! process; ii) FIs should not use any particular payment message tor the purppse of avoiding detection ot 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: 7\,pdf

The Wolfsberg Group consists of the following leading international financial institutions: Banco Santander, Bank of Tof,lyo-Mitsubishi UFJ, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Soci6t6 G6n6rale ancl UBS which aim to develop financial services industry standards, and related products, for , Anti-Money Laun4ering and Counter Terrorist Financing policies. the The Wolfsberg Group Anti-Money Laundering questionnaire 2tC)14 tUtnlf:shorg Sro ilIF;

24. Does the FI provide AML training to relevJ.'t"r..p YEI tt,l o includels: Identification and reporting of transactions that mrust be reported to govern ment authorities, Examples of different forms of money laundering involving the FI's products and seryices, Interna lao[icies; to prevent mon ey lau nderi n g, 25. Does the FI retain records of its training sessions Yg l\n o attendancer recoJds and relevant traininq materials'ncluding used? 26. Does the FI communicate new AML related laws or changes to [\o existing AML rellated policies or practices to relevilnt emplovees'7 27. Does the Ftr employ third parties to carry out some of tfre YET No functions of the FI? 28,If the answer to question 27 isyes, does the fI provide nlvtt Yg Nl o training to relevant third parties that includes: . Identification and reporting of transactions that must be reported to govr-.rn ment a uthorities. . Examples ol=diff'erent forms of money laundering involving the FI's products and services. Internal policies to prevent money launderinq.

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

aaaa ar r ! t a r r aa aa r r a t r rr r r t r ra a a ta r r !a a t rr r r r a r tr r r

a a rr a t r r ra I I r r t a ta r r r r a r a r r r ra r r ar r a t rr r r n a r rr rr aa r r

lr ra a a r r a t I a r a r a a! I i a r a a a r rt a t a r r rra t a r at t a l I ra r r r r ! l I t

a r r a r aa at ar !t I r r a r aa a r r r aa aa r r r a t a t r r r a I r tr rr t a

a l r r r a r a a t r r r r a t I tt a r a t at r arr a r r r r ]a a r ra r r a !

rra!aarratNrraaa aaarrarraarrrarra aarrr

rrrrat ataraataaarrtra aa!!rrrrrarr

rrrtrr rrraa aarrra

rr r! ar a ! t ! tr r !a a t a r rr a ! a r r ar r ! ! ! af, r r a t t r r r t a ! aa r r ! t r r r r r a a t r r aa

r ! a r r r t r aa I r a t a r r a a t r r a ar r t t t ar r t a ! t r ir a r aaa r r a ! aa rr rr aa ta ar r r

rrrara !ataa

Name: Alena Papushava Title: Chairperson of

Date:ZOLAlO:L E,E{9

The Wollsberg Group consists of the following leading international financial institutions: Ba nco Santander, Bank of Tolrlyo - M itsubishi UFl, Barclays, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, HSBC, JP Morgan Chase, Soci6t6 G6ndrale ancl UUS which aim to develop financial seryices industry standards, and related products, tor Know Your Customer, Anti-Money Launderirrg and Counter Terrorist Financing policies;.