MiFID II Data Collation This document provides a summary of MiFID II Transaction Reporting information needed from shareholders/employees (person) in order to provide their national identifiers and codes. The information and tables below are subject to change, though reflect requirements as at April 2017.

IDENTIFICATION OF PRIMARY NATIONALITY MiFID II CUSTOMER DATA INTERNATIONALLY MOBILE EMPLOYEES 1. A person shall be identified in a Transaction All channels including web portals and paper The same principles as above will apply to internationally Report using the two letter country code forms will be modified to capture reportable mobile employees. Even though an employee of their primary nationality, followed by the customer data and data fields include: may work in a number of different countries, their national client identifier and its code (details of First name(s) national identifier remains the same and continues the codes are shown in the tables below). Surname to be recorded as per their primary nationality. 2. The national client identifier referred to above Date of birth STOCK PURCHASE PLANS shall be assigned in accordance with the Nationality (or nationalities if relevant) priority levels (shown in table 2) using the National identifier (and if needed its classification There are certain dealing transactions that do highest priority identifier that a person has. so that the relevant code can be determined) not need to be reported and this includes an acquisition or disposal under an employee share 3. Where a person is a national of more than one As an example of how this information will be plan where all the following criteria are met: European Economic Area (EEA) country, the country reported, David Stefan decides to sell his shares. code of the first nationality when sorted alphabetically He has Australian and Romanian nationalities (i) the dates of acquisition or disposal are pre- shall be used. Where a person has a non-EEA and his date of birth is 8 May 1952. determined and published in advance; nationality, the highest priority identifier in accordance • For Transaction Reporting purposes EEA (ii) the investment decision concerning the with the field referring to ‘all other countries’ shall be nationality takes priority and therefore the acquisition or disposal that is taken by the used. Where a person has EEA and non-EEA nationality, Romanian National Identification Number investor amounts to a choice by the investor the country code of the EEA nationality and the highest (Cod Numeric Personal) should be used. to enter into the transaction with no ability to priority identifier of that nationality shall be used. unilaterally vary the terms of the transaction; • The Romanian National Identification Number 4. Where the identifier refers to CONCAT, the person for David Stefan is 1234567890123. (iii) there is a delay of at least ten business days between shall be identified using the concatenation of the the investment decision and the moment of execution; • Transaction Reporting will include following elements in the following order: the following information: (iv) the value of the transaction is capped at the (i) the date of birth of the person; equivalent of a thousand euros for a one off o First name = David (ii) the first five characters of the first name; transaction for the particular investor in the o Surname = Stefan particular instrument or, where the arrangement (iii) the first five characters of the surname. o Date of birth = 1952-05-08 results in transactions, the cumulative value of the The priority of the codes must be strictly followed o Country code and identifier = RO1234567890123 transaction shall be capped at the equivalent of for each jurisdiction. A combination of the name and five hundred euros for the particular investor in o National identifier code = NIDN date of birth i.e. CONCAT code, should not be used the particular instrument per calendar month. as a default identifier and should never be used for Current stock purchase plans will need to be reviewed those countries that according to the table have not to determine whether or not reportable data will chosen the CONCAT code as an identifier in any of need to be collected prior to 2018 purchases. the three priority possibilities. Where reporting is required, this information must be provided from 3 January 2018 (there is no phased approach). TABLE 1 - NATIONAL IDENTIFIER CODES MiFID II Data The following table represents some of the national identifier codes that are relevant to shareholders and employees.

Collation Code Name Definition CCPT Passport Number Number assigned by an authority to identify the passport number of a person CUST Customer Identification Number Number assigned by an issuer to identify a customer NIDN National Identity Number Number assigned by an authority to identify the national identity number of a person SOSE Social Security Number Number assigned by an authority to identify the social security number of a person TXID Tax Identification Number Number assigned by a tax authority to identify a person

TABLE 2 - NATIONAL IDENTIFIER AND PRIORITY The following table shows country codes and priority of national identifiers.

National National National National National National Country Country identifier identifier identifier Country Country identifier identifier identifier code name 1st priority Code 2nd priority Code 3rd priority Code code name 1st priority Code 2nd priority Code 3rd priority Code

AT Austria CONCAT CUST IT Italy Fiscal code (Codice fiscale) TXID

Belgian National Number National Identity LI Liechtenstein National Passport Number CCPT NIDN CONCAT CUST BE Belgium (Numéro de registre national NIDN CONCAT CUST Card Number – Rijksregisternummer) National Passport LT Personal code (Asmens kodas) NIDN CCPT CONCAT CUST Lithuania Number BG Bulgaria Bulgarian Personal Number NIDN CONCAT CUST LU CONCAT CUST CY Cyprus National Passport Number CCPT CONCAT CUST Luxembourg

National identification LV Latvia Personal code (Personas kods) NIDN CONCAT CUST CZ NIDN Passport Number CCPT CONCAT CUST Czech Republic number (Rodné číslo) National Passport MT Malta National Identification Number NIDN CCPT DE Germany CONCAT CUST Number National identity Personal identity code NL National Passport Number CCPT NIDN CONCAT CUST Netherlands card number DK Denmark 10 digits alphanumerical: NIDN CONCAT CUST DDMMYYXXXX 11 digit personal id NO NIDN CONCAT CUST Norway (Foedselsnummer) Estonian Personal Identification EE Estonia NIDN Code (Isikukood) Tax Number National Identification (Numer Tax identification number PL Poland NIDN TXID ES TXID Number (PESEL) identyfikacji Spain (Código de identificación fiscal) podatkowej) FI Personal identity code NIDN CONCAT CUST Finland Tax number (Número de National Passport PT TXID CCPT CONCAT CUST Portugal Identificação Fiscal) Number FR France CONCAT CUST National Identification Number National Passport GB United Kingdom UK National Insurance number SOSE CONCAT CUST RO NIDN CCPT CONCAT CUST Romania (Cod Numeric Personal) Number GR Greece 10 DSS digit investor share NIDN CONCAT CUST SE Sweden Personal identity number NIDN CONCAT CUST Personal Identification Number HR Croatia NIDN CONCAT CUST Personal Identification (OIB – Osobni identifikacijski broj) SI Slovenia Number (EMŠO: Enotna NIDN CONCAT CUST Matična Številka Občana) HU Hungary CONCAT CUST National Passport SK Personal number (Rodné číslo) NIDN CCPT CONCAT CUST Slovakia Number IE Ireland CONCAT CUST All other IS Iceland Personal Identity Code NIDN National Passport Number CCPT CONCAT CUST countries