FATCA and
Tax Reporting

1.2The Policy supports the Client Agreement, which requires the Client to provide complete, accurate and current information, to notify material changes including changes to tax residence, and to cooperate with lawful tax and information requests.

1.3This Policy does not create, extend or limit any contractual right. Where this Policy and the Client Agreement address the same matter, the Client Agreement prevails in accordance with the order of precedence stated in it.

1.4Nothing in this Policy removes or reduces a protection conferred on the Client by Applicable Law that cannot lawfully be excluded.

1.5Terms defined in the Client Agreement have the same meaning in this Policy.

2.2Each entity is a financial institution for the purposes of the international tax-information regimes implemented in its own jurisdiction, and reports to the competent authority of that jurisdiction. It does not report to a foreign tax authority directly.

2.3The obligations described in this Policy arise from law, not from the Company's commercial preference. The Company has no discretion to disapply them, to waive a requirement for a particular Client, or to accept an Account that cannot be documented.

2.4The Company's registration details for these purposes, including its Global Intermediary Identification Number, are provided on request and are published where required.

3.2The Common Reporting Standard, developed by the Organisation for Economic Co-operation and Development, requires financial institutions to identify accounts held by persons who are tax resident in a participating jurisdiction and to report information about those accounts.

3.3Both regimes operate in the same way: the Company identifies the tax residence and, for the United States, the citizenship status of account holders and certain controlling persons; documents that status; and reports the required information annually to its competent authority, which exchanges it with the relevant foreign authority.

3.4The Company applies both regimes together, because the information required overlaps and a single account may be reportable under either or both.

3.5These regimes concern the reporting of information. They do not determine whether tax is payable, and they do not relieve the Client of any obligation to declare income or to file a return.

4.2For an Account held by an entity, this Policy also applies to the controlling persons of that entity, including beneficial owners, senior managing officials, settlors, trustees, protectors and beneficiaries as the applicable law requires.

4.3This Policy applies at onboarding, on any change in circumstances, and on periodic review for as long as the Account is maintained, and it continues to apply to information relating to a period during which the Account was maintained after the Account is closed.

5.2A reportable person is a person who is tax resident in a jurisdiction to which the Company is required to report information, other than a person excluded by the applicable law.

5.3A self-certification is a written declaration by the Client, in the form the Company requires, stating the Client's jurisdictions of tax residence, taxpayer identification numbers, citizenship where required, and other information the applicable law prescribes.

5.4A change in circumstances is any change that affects, or may affect, a person's status under this Policy, including a change of citizenship, tax residence, address, telephone number, standing payment instruction, power of attorney, controlling person or entity classification.

5.5Indicia are facts held by the Company that suggest a person may be a US person or a reportable person, and that require documentation or investigation before the Account status can be treated as settled.

6.2A self-certification must be complete, must be signed or electronically affirmed by the Client or by a duly authorised person, and must state every jurisdiction in which the Client is tax resident, together with the taxpayer identification number issued by each such jurisdiction or an explanation permitted by the applicable law where no number has been issued.

6.3Where the Client is a citizen of the United States, or holds United States citizenship in addition to any other citizenship, the self-certification must state that fact and must include the Client's United States taxpayer identification number.

6.4A self-certification is not a formality. The Company relies on it, and the Client is responsible for its accuracy.

6.5Where a self-certification is incomplete, internally inconsistent, or inconsistent with other information held by the Company, the Company will require it to be corrected or supported before the Account proceeds.

6.6The Company may require a self-certification to be renewed periodically, and will require a new self-certification following a change in circumstances.

7.2Documentary evidence may include a passport or national identity document, evidence of residence, a certificate of tax residence, a taxpayer identification document, and, where relevant to United States status, a certificate of loss of nationality or other evidence recognised by the applicable law.

7.3The Company may request further information at any time and may hold an application or restrict an Account until the information is provided.

7.4The Company may verify information against public registers, sanctions and screening services, and other lawful sources, and may take account of information obtained in the course of its financial-crime checks.

8.2Indicia include identification of the Client as a citizen or resident of the United States; a place of birth in the United States; a current mailing or residence address in the United States, including a post office box; a current United States telephone number; a standing instruction to transfer funds to an account maintained in the United States; a power of attorney or signatory authority granted to a person with a United States address; and a hold-mail instruction or an "in care of" address that is the only address held for the Client.

8.3A United States place of birth is treated as a strong indication of United States citizenship, because United States citizenship is generally acquired by birth in the United States and is not lost by living elsewhere, by acquiring another nationality, or by the passage of time.

8.4Equivalent indicia are applied in respect of every other jurisdiction to which the Company is required to report.

8.5Where an indicium is identified, the Account is treated as requiring documentation until the position is resolved under section 11.

9.2A self-certification is required from the entity and, where the applicable law requires, from each controlling person.

9.3An entity Account may be reportable because of the status of a controlling person even where the entity itself is not a reportable person and is not established in a reportable jurisdiction.

9.4A change in the controlling persons of an entity is a change in circumstances and must be notified to the Company.

10.2Every citizenship held by the Client must be declared, including a citizenship the Client regards as inactive, historic, inherited, unused, or held only through a passport the Client does not travel on.

10.3United States citizenship in particular is not affected by residence elsewhere, by holding another passport, by having left the United States as a child, by never having lived or worked in the United States, or by never having filed a United States tax return. A person born in the United States is generally a United States citizen unless that citizenship has been formally relinquished and evidenced.

10.4A person may also be a United States citizen by descent, where one or both parents were United States citizens, even if that person was born elsewhere and has never held a United States passport.

10.5Disclosing a second citizenship does not by itself create a tax liability, does not by itself trigger reporting, and does not affect the Client's ability to hold an Account. What creates difficulty is the failure to disclose it.

10.6Where a Client declares United States citizenship, the Company documents the Account accordingly, obtains the required taxpayer identification number, and reports the Account as the applicable law requires. The Account continues to operate normally.

10.7Where a Client has formally relinquished a citizenship, the Company requires evidence of that relinquishment. A statement that a citizenship is no longer used, or is not recognised by the Client, is not evidence of relinquishment and will not be accepted.

10.8Where the Client is uncertain whether they hold a citizenship or a tax residence, the Client should disclose the uncertainty and obtain independent tax advice. The Company will document the Account on a conservative basis until the position is clarified.

11.2Where the Company identifies an indicium that is inconsistent with the Client's self-certification, it will notify the Client, explain what has been identified, and request a corrected self-certification together with supporting documentary evidence within the period stated in the request.

11.3Pending resolution, the Company may restrict the Account. Restrictions may include placing the Account in close-only mode, declining new Orders, suspending withdrawals to the extent lawful, and declining further deposits.

11.4Where the Client does not respond within the period stated, does not provide the documentation required, or provides documentation that does not resolve the inconsistency, the Company will treat the Account as undocumented and will apply section 12.

11.5Where the indicium is a United States indicium and it is not cured, the Company will treat the Client as a United States person and will document and report the Account on that basis, whether or not the Client accepts that classification.

11.6Where the Company concludes that a self-certification was false or misleading, it may close the Account and terminate the Agreement, and may report the matter to its competent authority. Providing a false self-certification may constitute an offence under the legislation implementing these regimes in the relevant jurisdiction, and may carry penalties for the Client independently of any action by the Company.

11.7A failure to disclose does not remain private between the Client and the Company. Where an Account is reportable, information is reported to the competent authority and exchanged with the foreign authority regardless of whether the Client subsequently corrects the position, and a corrected disclosure may itself prompt reporting for earlier periods.

11.8Where a failure to disclose results in the Company being subject to withholding, a penalty, an interest charge, an assessment or a cost, the Company may recover that amount from the Client under section 16.

11.9Correcting an omission voluntarily and promptly is treated as a change in circumstances rather than as a false certification, provided the correction is made before the Company identifies the discrepancy and is supported by evidence.

12.2An undocumented Account is reported to the competent authority as the applicable law requires, on the basis of the information the Company holds.

12.3The Company may decline to open, may restrict, may place in close-only mode, or may close an undocumented Account, and may terminate the Agreement on notice.

12.4Closing an undocumented Account does not remove the Company's obligation to report information relating to the period during which the Account was maintained.

12.5Funds in an undocumented Account are returned to the Client through a verified payment method in the Client's name, subject to any withholding, retention or legal restriction that applies.

13.2A change in circumstances includes acquiring a citizenship; relinquishing a citizenship; becoming or ceasing to be tax resident in a jurisdiction; obtaining a taxpayer identification number; changing address, telephone number or standing payment instructions; granting or revoking a power of attorney; and, for an entity, a change in classification or in controlling persons.

13.3Following a change in circumstances, the Company will require a new self-certification and, where relevant, supporting documentation.

13.4Where a change in circumstances is not notified, and the Company later identifies it, section 11 applies.

14.2Where a payment is a withholdable payment for the purposes of the Foreign Account Tax Compliance Act and the recipient is not properly documented, withholding is applied at the rate required by United States law.

14.3An amount withheld is not recoverable from the Company. A Client who considers that an amount has been withheld in excess of what was due must pursue the matter with the relevant tax authority.

14.4The Company does not gross up a payment to compensate for an amount withheld.

15.2For an entity Account, the information reported may include equivalent details for each reportable controlling person.

15.3Reporting is made annually within the period the applicable law prescribes. The competent authority exchanges the information with the tax authority of the relevant jurisdiction.

15.4The Company reports on the basis of the information it holds. It does not calculate the Client's tax liability and does not report an opinion about the Client's tax affairs.

15.5The Company will inform the Client, on request, of the categories of information reported in respect of that Client's Account, except where the applicable law prevents it.

15.6Reporting is a legal obligation. It is not a breach of the confidentiality provisions of the Client Agreement, and consent to it is given by the Client on accepting the Agreement.

16.2The Client undertakes to disclose every citizenship held and every jurisdiction of tax residence, to notify a change in circumstances within the period stated in section 13, and to provide documentation reasonably requested within the period stated in the request.

16.3The Client acknowledges that the Company relies on the information provided, and that the Company is entitled to act on it without independent enquiry, save where an indicium or an inconsistency requires investigation.

16.4The Client indemnifies the Company against any tax, withholding, penalty, interest, assessment, cost or reasonable expense that the Company incurs as a result of the Client's failure to disclose a citizenship or tax residence, the provision of a false or misleading self-certification, or the failure to notify a change in circumstances, except to the extent caused by the Company's own breach, negligence or misconduct.

16.5The Client remains responsible for determining, reporting and paying tax due in every jurisdiction in which the Client is liable, and for making any required filing. Reporting by the Company does not discharge that responsibility.

17.2Information reported under this Policy is disclosed to the competent authority of the Company's jurisdiction and, through that authority, to the tax authority of the relevant jurisdiction. It may also be disclosed to the Company's auditors, professional advisers and service providers where lawful and necessary.

17.3The Client cannot object to processing carried out to meet a legal obligation, and withdrawal of consent does not affect it.

17.4The Company does not disclose information under this Policy to any recipient other than as this Policy and the applicable law provide.

18.2Records are made available to the competent authority on request.

18.3The Client should retain a copy of each self-certification provided.

19.2Nothing in this Policy, and nothing said by a Relevant Person, constitutes advice as to whether a Client is a citizen of any jurisdiction, is tax resident in any jurisdiction, or is required to file a return anywhere.

19.3A Client who is uncertain about their status must obtain independent professional advice. The Company cannot determine the Client's status for them and will not do so.

19.4The Company will not assist a Client to structure an Account, a holding or an arrangement so as to avoid reporting, and will treat a request to do so as a matter requiring escalation.

20.2Indicia review, self-certification validation and reporting are subject to internal controls and to periodic testing.

20.3This Policy is reviewed at least annually, and in addition whenever a material change occurs in the applicable law, in the Company's business, or in the jurisdictions to which it reports.

20.4Relevant Persons involved in onboarding, account maintenance and payments receive training on this Policy.

21.2The current version of this Policy is made available through an Approved Medium. The Company maintains version control and records the effective date of each version.

21.3The governing language of this Policy is English. A translation is provided for convenience only and, in the event of conflict, the English version prevails to the extent permitted by Applicable Law.