Compliance

1.

Hypo Vorarlberg Bank AG is a universal bank registered in Austria, a member country of FATF. Access to banking activities in Austria is regulated by the Austrian Banking Act (Bankwesengesetz). Hypo Vorarlberg Bank AG operates under the supervision of the Austrian Financial Market Authority (Finanzmarktaufsicht).

With regard to the legal requirements Hypo Vorarlberg Bank AG has always followed a policy of strict compliance.

2.

All the institutional, economic and financial information on Hypo Vorarlberg Bank AG is available to the public on our homepage. The latter contains information on the group’s identification details, branch offices, main lines of business, members on the Board of Directors, main shareholders, etc.

3.

In regard to the banks activities, internal structure and actions in the field of money laundering prevention, please note the following:

The policy of Hypo Vorarlberg Bank AG is and has always been in compliance with all legal requirements of every country it operates in. We pay special attention to any regulations concerning the prevention of Money Laundering.

The main elements of the money laundering prevention policy are:

Identification of customers and their activities according to §6 of the Austrian Financial Markets Anti Money Laundering Act ( Finanzmarkt-Geldwäschegesetz FM-GwG) Specific training of all employees with emphasis on the prevention of money launderingControlling and monitoring of all transactionsReview of the above elements by the Bank’s internal auditors and the compliance office

The compliance-office is also responsible for putting in place prevention policies and internal control procedures. The compliance-officers directly report to the Board of Directors accordingly and at least four times a year.

At Hypo Vorarlberg Bank AG no anonymous accounts can be opened. Hypo Vorarlberg Bank AG has no business relations with shell banks. Hypo Vorarlberg Bank AG always controls whether its clients are people or organizations suspected of criminal activity.