Privacy policy.

Definition 1 - Politically Exposed Person (PEP)

PEPs shall mean natural persons holding significant positions or fulfilling significant public functions, including:

a) heads of state, heads of government, ministers, deputy ministers and state secretaries;

b) members of parliament or similar legislative bodies;

c) members of governing bodies of political parties;

d) members of the supreme courts, constitutional courts and other high-level judicial authorities whose decisions are not subject to appeal, except extraordinary procedures;

e) members of the courts of auditors or the management boards of central banks;

f) ambassadors, chargés d'affaires and senior officers of armed forces;

g) members of administrative, management or supervisory bodies of state-owned enterprises, including companies with the State Treasury shareholding, where over a half of stocks or shares belongs to the State Treasury or other state legal persons;

h) directors, deputy directors and members of governing bodies of international organisations, or persons exercising corresponding functions in such organisations;

i) directors-general in the head offices and central government offices and directors-general of the voivodship offices;

j) other persons holding public offices or functions in state authorities or central government bodies.

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Definition 2 - A family member of a person in an exposed political position

Family members of a politically exposed person shall mean:

a) a spouse or a cohabitant of a PEP;
b) PEP’s child and his/her spouse or cohabitant;
c) PEP’s parents.

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Definition 3 - A close associate of a politically exposed person

Persons known as close associates of a politically exposed person shall mean:

a) natural persons being Beneficial Owners of legal persons, organisational units without legal personality or trusts, jointly with a politically exposed person, or maintaining other close relationship with such a person, related to the conducted economic activity;
b) natural persons being the only Beneficial Owner of legal persons, organisational units without legal personality or a trust, which are known to have been established in order to enable a politically exposed person gaining actual benefits.

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Definition 4 - Categories of persons considered to be Beneficial Owners

A natural person or natural persons exercising direct or indirect control over the Investor through the powers that arise from legal or factual circumstances, which make it possible to exercise decisive influence over the acts or actions of the Investor, or a natural person or natural persons, on whose behalf economic relationships are established or an occasional transaction is performed, including:

1. in the case of the Investor who is a legal person other than a company whose securities are admitted to trading on a regulated market subject to disclosure requirements under European Union law or corresponding third country law:

a) a natural person who is a shareholder or stockholder of the Investor, and who is entitled to the ownership of more than 25% of the total number of shares or stocks of that legal person;
b) natural person holding more than 25% of the total number of votes in the Investor's decision-making body, including as a pledgee or as a usufructuary, or under agreements with other entities holding voting rights;
c) a natural person exercising control over a legal person or legal persons who, in aggregate, holds more than 25% of the total number of the Investor's shares or stocks, or who in aggregate holds more than 25% of the total number of votes in the Investor's corporate body, including as a pledgee or as a usufructuary, or under agreements with other entities holding voting rights;
d) a natural person exercising control over the Investor by holding in respect to that legal person the rights referred to in Article 3 section 1 item 37 of the Accounting Act (Ustawa o rachunkowości) of 29 September 1994 (consolidated text: Journal of Laws of 2018, as amended), or
e) a natural person in a senior management position in the event of a documented impossibility of identifying or doubt as to the identity of the natural persons referred to in points a) to d) and in the event there are no suspicions concerning money laundering or terrorist financing.

2. in the case of the Investor being a trust, understood as a regulated by foreign law legal relationship arising from a legal event, contract or arrangement, including a set of such events or legal acts, under which ownership or possession of assets is transferred to a custodian for the purpose of exercising fiduciary management and making those assets available to beneficiaries of that relationship:

a) the settlor;

b) the trustee;

c) the trust manager, if any;

d) the beneficiary;

e) another person in control of the trust.

3. in the case of the Investor who is a natural person carrying out an economic activity and for which there are no reasons or circumstances that could indicate that another natural person or natural person has control over him/her, such an Investor shall be deemed to be at the same time a beneficial owner.

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