Settlement with the Central Bank - Q&A from shareholders

Questions from shareholders and other stakeholders. The Bank will make all questions and answers available to shareholders on its website, prior to the Shareholder Meeting to be held on 28 July 2023.

Section 3 of the settlement states that the Bank has not satisfactorily met the requirements of the law, on measures for conflicts of interest.

Section 4 of the settlement discusses the Bank's monitoring system with risk factors in its operations and how they are applied in practice. It is the conclusion of the FSA that the Bank did not comply with the provisions of the law when operating the system.

Section 5 of the settlement deals with the lack of recording and retention of phone calls and other electronic communications. The statistics in the chapter are notable, as is the assumed paucity of follow-up by management in light of the comments of the internal auditor and the compliance officer and certain disciplinary problems amongst some employees.

Section 6 of the settlement deals with customer categorisation. From the review, it can be concluded that the Bank´s employees handled consumer protection rules in a somewhat careless fashion.

Section 7 of the settlement deals with the provision of information to customers. From the review it could be assumed that the Bank´s employees intentionally misled the Bank´s customers, namely the buyers and sellers in the offering.

Section 8 of the settlement deals with the Bank's breach of its obligations to act honestly, fairly and professionally in accordance with normal and sound business practices and customs. Section 9 also deals with the corporate governance of the Bank. The conclusions of these sections bore witness to deficiencies in the Bank's Board of Directors and its senior management. In light of this, the former CEO and some of her subordinates are no longer in their roles and it is foreseeable that the Board of Directors may not continue without a renewed mandate.

Having read the settlement, one could conclude that the position of the Compliance Officer was weak and that the Officer's comments and warnings were not given the weight they should have.