Banco Pine S A : 09/12/2023 - Wolfsberg Questionnaire

Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) V1.3

Financial Institution Name:

Location (Country) :

Banco Pine S.A

Brazil

The questionnaire is required to be answered on a Legal Entity (LE) Level. The Financial Institution should answer the questionnaire at the legal entity level including any branches for which the client base, products and control model are materially similar to the LE Head Office. This questionnaire should not cover more than one LE. Each question in the CBDDQ will need to be addressed from the perspective of the LE and on behalf of all of its branches. If a response for the LE differs for one of its branches, this needs to be highlighted and details regarding this difference captured at the end of each sub-section. If a branch's business activity (products offered, client base etc.) is materially different than its Entity Head Office, a separate questionnaire can be completed for that branch.

No #

Question

1. ENTITY & OWNERSHIP

Answer

1	Full Legal Name	Banco Pine S.A
2	Append a list of foreign branches which are	Banco Pine - Cayman Islands Branch
	covered by this questionnaire
3	Full Legal (Registered) Address	Av. Pres. Juscelino Kubitschek, 1830, Tower 5 - 6th Floor
		Zip Code: 04543-900
		São Paulo, SP, Brazil
4	Full Primary Business Address (if different from	N/A
	above)
5	Date of Entity incorporation/ establishment	1997

6 Select type of ownership and append an ownership chart if available

6 a	Publicly Traded (25% of shares publicly traded)	Yes
6 a1	If Y, indicate the exchange traded on and ticker	B3 - PINE4
	symbol
6 b	Member Owned/ Mutual	No
6 c	Government or State Owned by 25% or more	No
6 d	Privately Owned	Yes
6 d1	If Y, provide details of shareholders or ultimate	Mr. Noberto Pinheiro (UBO) - has 63,44% of total shares
	beneficial owners with a holding of 10% or more
7	% of the Entity's total shares composed of	The Bank does not have bearer shares
	bearer shares

8 Does the Entity, or any of its branches, operate

	under an Offshore Banking License (OBL) ?	Yes
8 a	If Y, provide the name of the relevant branch/es	Banco Pine Cayman Islands Branch
	which operate under an OBL
9	Name of primary financial regulator / supervisory	Banco Central do Central
	authority

© The Wolfsberg Group 2020

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CBDDQ V1.3

Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) V1.3

10	Provide Legal Entity Identifier (LEI) if available	549300B3S9ENN2P5WM84
11	Provide the full legal name of the ultimate parent	NA
	(if different from the Entity completing the DDQ)
12	Jurisdiction of licensing authority and regulator	NA
	of ultimate parent

13 Select the business areas applicable to the Entity

13 a	Retail Banking	No
13 b	Private Banking / Wealth Management	No
13 c	Commercial Banking	Yes
13 d	Transactional Banking	Yes
13 e	Investment Banking	No
13 f	Financial Markets Trading	Yes
13 g	Securities Services / Custody	No
13 h	Broker / Dealer	No
13 i	Multilateral Development Bank	No
13 j	Other	NA

14 Does the Entity have a significant (10% or more) portfolio of non-resident customers or does it derive more than 10% of its revenue from non-

	resident customers? (Non-resident means	No
	customers primarily resident in a different
	jurisdiction to the location where bank services
	are provided.)
14 a	If Y, provide the top five countries where the non-	NA
	resident customers are located.

15 Select the closest value:

15 a	Number of employees
	201-500
15 b	Total Assets
	Greater than $500 million

16 Confirm that all responses provided in the above

	Section ENTITY & OWNERSHIP are	Yes
	representative of all the LE's branches
16 a	If N, clarify which questions the difference/s	NA
	relate to and the branch/es that this applies to.
16 b	If appropriate, provide any additional information	NA
	/ context to the answers in this section.

© The Wolfsberg Group 2020

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CBDDQ V1.3

Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) V1.3

2. PRODUCTS & SERVICES

17 Does the Entity offer the following products and services:

17 a	Correspondent Banking	No
17 a1	If Y
17 a2	Does the Entity offer Correspondent Banking
	services to domestic banks?
17 a3	Does the Entity allow domestic bank clients to
	provide downstream relationships?
17 a4	Does the Entity have processes and procedures
	in place to identify downstream relationships
	with domestic banks?
17 a5	Does the Entity offer correspondent banking
	services to Foreign Banks?
17 a6	Does the Entity allow downstream relationships
	with Foreign Banks?
17 a7	Does the Entity have processes and procedures
	in place to identify downstream relationships
	with Foreign Banks?
17 a8	Does the Entity offer correspondent banking
	services to regulated MSBs/MVTS?
17 a9	Does the Entity allow downstream relationships
	with MSBs/MVTS?
17 a10	Does the Entity have processes and procedures
	in place to identify downstream relationships
	with MSB /MVTS?
17 b	Private Banking (domestic & international)	Yes
17 c	Trade Finance	Yes
17 d	Payable Through Accounts	No
17 e	Stored Value Instruments	No
17 f	Cross Border Bulk Cash Delivery	No
17 g	Domestic Bulk Cash Delivery	No
17 h	International Cash Letter	No
17 i	Remote Deposit Capture	No
17 j	Virtual /Digital Currencies	No
17 k	Low Price Securities	No
17 l	Hold Mail	No
17 m	Cross Border Remittances	No
17 n	Service to walk-in customers (non-account	No
	holders)
17 o	Sponsoring Private ATMs	No
17 p	Other high risk products and services identified	NA
	by the Entity

18 Confirm that all responses provided in the above

	Section PRODUCTS & SERVICES are	Yes
	representative of all the LE's branches
18 a	If N, clarify which questions the difference/s
	relate to and the branch/es that this applies to.
18 b	If appropriate, provide any additional information	NA
	/ context to the answers in this section.

© The Wolfsberg Group 2020

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CBDDQ V1.3

Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) V1.3

3. AML, CTF & SANCTIONS PROGRAMME

19 Does the Entity have a programme that sets minimum AML, CTF and Sanctions standards regarding the following components:

19 a	Appointed Officer with sufficient	Yes
	experience/expertise
19 b	Cash Reporting	Yes
19 c	CDD	Yes
19 d	EDD	Yes
19 e	Beneficial Ownership	Yes
19 f	Independent Testing	Yes
19 g	Periodic Review	Yes
19 h	Policies and Procedures	Yes
19 i	Risk Assessment	Yes
19 j	Sanctions	Yes
19 k	PEP Screening	Yes
19 l	Adverse Information Screening	Yes
19 m	Suspicious Activity Reporting	Yes
19 n	Training and Education	Yes
19 o	Transaction Monitoring	Yes

20 How many full time employees are in the Entity's

AML, CTF & Sanctions Compliance	Less than 10
Department?

21 Is the Entity's AML, CTF & Sanctions policy

	approved at least annually by the Board or	Yes
	equivalent Senior Management Committee?
22	Does the Board or equivalent Senior
	Management Committee receive regular	Quarterly/Every three months
	reporting on the status of the AML, CTF &
	Sanctions programme?

23 Does the Entity use third parties to carry out any

	components of its AML, CTF & Sanctions	No
	programme?
23 a	If Y, provide further details	NA
24	Confirm that all responses provided in the above
	Section AML, CTF & SANCTIONS Programme	Yes
	are representative of all the LE's branches
24 a	If N, clarify which questions the difference/s	NA
	relate to and the branch/es that this applies to.
24 b	If appropriate, provide any additional information	NA
	/ context to the answers in this section.

© The Wolfsberg Group 2020

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CBDDQ V1.3

Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ) V1.3

4. ANTI BRIBERY & CORRUPTION

25	Has the Entity documented policies and
	procedures consistent with applicable ABC
	regulations and requirements to [reasonably]	Yes
	prevent, detect and report bribery and
	corruption?

1. Does the Entity have an enterprise wide
   programme that sets minimum ABC standards? Yes
2. Has the Entity appointed a designated officer or officers with sufficient experience/expertise
   responsible for coordinating the ABCYes

programme?

28 Does the Entity have adequate staff with

	appropriate levels of experience/expertise to	Yes
	implement the ABC programme?
29	Is the Entity's ABC programme applicable to:	Not Applicable

30 Does the Entity have a global ABC policy that:

30 a	Prohibits the giving and receiving of bribes?
	This includes promising, offering, giving,
	solicitation or receiving of anything of value,	Yes
	directly or indirectly, if improperly intended to
	influence action or obtain an advantage
30 b	Includes enhanced requirements regarding	Yes
	interaction with public officials?
30 c	Includes a prohibition against the falsification of
	books and records (this may be within the ABC	Yes
	policy or any other policy applicable to the Legal
	Entity)?

31 Does the Entity have controls in place to monitor

the effectiveness of their ABC programme?	Yes

32 Does the Entity's Board or Senior Management

	Committee receive regular Management	Yes
	Information on ABC matters?
33	Does the Entity perform an Enterprise Wide	Yes
	ABC risk assessment?
33 a	If Y select the frequency	12 Months

1. Does the Entity have an ABC residual risk rating
   that is the net result of the controls effectiveness Yes and the inherent risk assessment?
2. Does the Entity's ABC EWRA cover the inherent risk components detailed below:

35 a	Potential liability created by intermediaries and	Yes
	other third-party providers as appropriate
35 b	Corruption risks associated with the countries
	and industries in which the Entity does business,	Yes
	directly or through intermediaries
35 c	Transactions, products or services, including
	those that involve state-owned or state-	Yes
	controlled entities or public officials
35 d	Corruption risks associated with gifts and
	hospitality, hiring/internships, charitable	Yes
	donations and political contributions
35 e	Changes in business activities that may	Yes
	materially increase the Entity's corruption risk
36	Does the Entity's internal audit function or other
	independent third party cover ABC Policies and	Yes
	Procedures?

© The Wolfsberg Group 2020

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CBDDQ V1.3