Effective: 4 June 2024

The purpose of this document ("Data Protection Policy") is to inform you of how Oversea-Chinese Banking Corporation Limited and its related corporations (collectively, the "Companies"), and their respective representatives and agents ("Representatives") (the Companies and Representatives collectively referred to as "OCBC", "us", "we" or "our") collect, use and disclose Personal Data.

We may update or change this Data Protection Policy by publishing the latest version of our Data Protection Policy on our website (www.ocbc.com). This ensures that our Data Protection Policy conforms with future developments, industry trends, and legal or regulatory changes. We may inform you of changes in how we process your Personal Data through appropriate means, such as by posting a notice or sending you a notification.

1. Personal Data

In this Data Protection Policy, "Personal Data" refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

The Personal Data you provide us depends on the nature of your interaction with us and the OCBC products and services you use. Some examples of Personal Data include:

1.1. your full name;

1.2. NRIC, passport or other identification number;
1.3. contact details such as telephone number(s), mailing address, email address;
1.4. your location;
1.5. customer information (e.g. deposit information);
1.6. account numbers and transactional data; and
1.7. information relating to any individuals which you provide to us.

2. Collection of Personal Data

We will only collect your Personal Data in a lawful manner and when we have a valid reason to do so. The provision of your personal data is voluntary. However, if you do not provide your personal data to us, we may not be able to provide you with requested products and services. We collect your Personal Data in the following ways:

2.1when you submit any form, including application, declaration, proposal or referral forms;

2.2. when you enter into any agreement, provide other documentation or information relating to your interactions and transactions with us, or when you use our services;

2.3. when you interact with us (including customer service officers, relationship managers, and our automated systems for example, via telephone calls (which may be recorded), letters, online chat, fax, face-to-face meetings and e-mail);

2.4. when you are within our premises, or attend events hosted by us;

2.5. when you use services provided through our online and other technology platforms, such as websites and apps, including when you set up any online accounts with us;

2.6. when you ask us to contact you, include you in an e-mail or other mailing list, or participate in our promotions and other marketing initiatives;

2.7. when you respond to our marketing representatives and agents and other service providers;

2.8. when you send an employment application, provide documents or information (such as your resume) in connection with any appointment as an officer, director, representative or to any other position, or when you attend interviews with us;

2.9. when you interact with us via our websites and platforms, or use services on our websites and platforms;

2.10. where allowed under applicable law, when we seek information about you regarding your relationship with us (including for banking products, insurance policies or job applications) and receive your Personal Data (for example, from business partners, public agencies, your ex-employers and the relevant third parties);

2.11. when you respond to a request from us for additional Personal Data;

2.12. from third party sources to which you have given your consent (such as our ecosystem partners) or if the collection of your Personal Data is necessary to comply with applicable data protection laws;

2.13. when you use our Electronic Banking Services, such as OCBC Phone Banking Service, OCBC ATM Service or OCBC Internet Banking Service. For more information, refer to the Terms and conditions governing the Business Account;

2.14 when you use our mobile and digital applications (“Digital Services

2.15 when you give us consent to collect your Personal Data from your mobile device (e.g. location information); and
2.16. when you send your Personal Data to us for any other reason.

We may collect your information when you browse or use our website and platforms. Please see the section below on "Use of Cookies and Related Technologies" for more information.

If you provide us with any Personal Data of a third party (e.g. information on your customers, spouse, children, parents, and/or employees), you represent that, by sending such information to us, you have obtained the consent of such third party for you to provide us with their Personal Data for the respective purposes.

You should ensure that all Personal Data sent to us is complete, accurate, true and correct. Failure on your part to do so may prevent us from providing you with the products and services you have asked for.
 

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

We must be transparent in how your Personal Data is used so that you can trust us. OCBC collects, uses and discloses your Personal Data for the following purposes:

3.1. managing and responding to your complaints, queries, requests, feedback and suggestions;
3.2. establishing and verifying your identity;
3.3. managing our administrative and business operations;
3.4. facilitating corporate restructuring processes and business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
3.5. matching any Personal Data which relates to you for any of the purposes listed in this policy;
3.6. requesting feedback or participation in surveys, conducting market research or analysis for statistical, profiling, or other similar purposes. These other purposes include the development, design and improvement of our products and services, and understanding customer behaviour, preferences, and market trends;
3.7. preventing, detecting, and investigating crime (including fraud, money-laundering and terrorist financing);
3.8. analysing and managing commercial risks;
3.9. managing the safety and security of our premises and services (including CCTV surveillance and conducting security clearances);
3.10. project management;
3.11. providing media announcements and responses;
3.12. marketing offers and promotions in relation to products and services (including co-branded products and services and organising promotional events);
3.13. in connection with any claims, actions or proceedings (including drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and in protecting and enforcing our contractual and legal rights and obligations;
3.14. managing and preparing internal and external reporting;
3.15. training our employees to provide better products and services to you;
3.16. to determine service levels;
3.17. meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us, or which we have been advised, recommended or informed that we are expected to comply with (including disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, and due diligence), internal policies, assisting law enforcement or investigations by relevant authorities, and complying with listing and other requirements or directions of the Singapore Exchange Limited and/or any other relevant securities exchange;
3.18. responding to an emergency; and
3.19. any other reasonable purpose relating to the above.

Relationship with OCBC

In addition, OCBC collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:

4. Prospective Customers

4.1. evaluating your financial and banking needs and providing recommendations to you;
4.2. assessing and processing any applications or requests made by you for products and services offered by OCBC; and
4.3. any other reasonable purpose relating to the above.

5.Retail Banking Customers, Private Investors, Beneficial Owners, Guarantors, Security Providers, or Appointed Representatives (including a Mandate Holder or a Power of Attorney)

5.1. opening, maintaining or closing your accounts, and establishing or providing banking services to you;

5.2. if an account or relationship manager, or agent has been assigned to service your account or portfolio, using your telephone number to contact you to take your instructions, and provide you with information, updates, or recommendations per the terms and conditions of our agreement with you;

5.3. facilitating the continuation or termination of the banking relationship, the daily operations of services and credit and trading facilities, and providing client servicing (including responding to requests by customers, providing mailing, conveyancing, reporting, clearing and reconciliation services, investigating discrepancies, errors or claims, and providing customer satisfaction);

5.4. conducting client reviews (for example, annual reviews of your portfolio);

5.5. to establish your financial situation, risk profile, investment experience and investment goals, and help you consider the suitability of the products you have invested or intend to invest;

5.6. providing Electronic Banking Services;

5.7. facilitating the transfer of funds within OCBC banking accounts or from OCBC accounts to external banking accounts and vice versa;

5.8. ensuring the ongoing creditworthiness of customers;

5.9. administering exceptional approvals, fee adjustments or waivers;

5.10. managing investment products (including unit trusts, treasury products, shares, commodities, foreign exchange, Supplementary Retirement Scheme, initial public offerings or CPF investment accounts, and other investment products which OCBC may make available from time to time) and providing custody services;

5.11. customer outreach and relationship management;

5.12. meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us, or which we have been advised, recommended or informed that we are expected to comply with (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, and customer due diligence);

5.13. archival management (including warehouse storage and retrievals);

5.14. administering credit, debit, charge, ATM and other cards (including processing card applications, transactions, credit limit approvals and enquiries);

5.15. providing cheque deposit and issuance services;

5.16. providing loans and overdraft facilities (including the evaluation of credit risks and enforcement of repayment obligations);

5.17. administering bancassurance products (including the maintenance, management and operation of the products and services, communication with policyholders, and processing of any claims and payments arising under the respective policies);

5.18. administering fund services (including maintaining, managing and operating the services, and communicating with investors);

5.19. administering and facilitating any offer of or other transactions dealing with securities, derivatives or other instruments or investments, and the execution of such transactions on a trading system or platform; and

5.20. any other reasonable purpose relating to the above.

6. Bancassurance Customers

6.1  processing your insurance application;
6.2. administering, maintaining, managing and operating the products and services offered to you, including reinsured products by other companies and government-driven schemes;

6.3. sending updates and administrative notices to you regarding the products and services used by you, including notification of maturity of payments and maturity of policies;

6.4. underwriting of policy risks;

6.5. assessing and processing any claims arising under your policy;

6.6. collecting premiums and debt collection; and

6.7. any other reasonable purpose relating to the above.

7. Employees, Business Partners, Sole Proprietors, Investors, Proxy Voters, Corporate Shareholders, Guardians, Directors, Nominee Directors, Chargors, Sureties or Guarantors, Agents or Representatives of an Organization that is a Business Banking Customer or has a corporate relationship with OCBC

7.1. opening or continuation of accounts, and establishing or providing banking services;

7.2. facilitating the daily operation of services, and credit and trading facilities (including providing loans, gathering deposits, transferring funds, processing trades, reporting and clearing of trades, updating contact details of investors and investees, corporate action processing and entering into related ancillary arrangements);

7.3. facilitating the continuation or termination of the banking relationship (including the closing of accounts);

7.4. managing investment banking (including capital markets, corporate finance services and financing by mezzanine capital services);

7.5. managing investment products (including unit trusts, treasury products, shares, commodities, foreign exchange, and other investment products which OCBC may make available) and providing custody services;

7.6. networking to maintain customer relationships;

7.7. providing client servicing (including providing customer satisfaction, proxy voting and merchant servicing);

7.8. facilitating and conducting due diligence checks;

7.9. administering fund services (including the maintenance, management and operation of the services, and communication with investors);

7.10. processing commissions and remuneration for sales representatives;

7.11. administering corporate or business credit, debit, and other cards (including processing card applications, transactions and credit limit approvals);

7.12. providing loans and overdraft facilities (including evaluating credit risks and enforcement of repayment obligations);

7.13. administering and facilitating any offer or other transaction dealing with securities, derivatives or other instruments or investments, and the execution of such transactions on a trading system or platform; and7.14. any other reasonable purpose relating the above.

8. Employees, Agents or Owners of a Referrer or other similar intermediaries

8.1. marketing and leads management;

8.2. processing commissions and remuneration; and

 8.3. any other reasonable purpose relating to the above.

9. Employees, officers or owners of an external service provider or vendor outsourced or prospected by OCBC, or an independent contractor

9.1. managing project tenders or the supply of goods and services;

9.2. processing and payment of vendor invoices; and

9.3. any other reasonable purpose relating to the above.

10. OCBC shareholders

10.1. maintaining statutory registers and managing the publication of shareholder statistics on annual reports and circulars;

10.2. providing shareholding listings for preference shares, subordinated debt and senior term issuances;

10.3. facilitating the implementation of projects (including seeking approvals for new investments, additional fundraising exercises or bonuses);

10.4. processing claims (including processing claims for unclaimed cash distribution); and

10.5. any other reasonable purpose relating to the above.


11. Parties or counterparties to a transaction (for example, a beneficiary of a fund transfer or payment)

11.1. providing cash, payment and transactional services (including the execution, settlement, reporting and/or clearing of the relevant transaction); and

11.2. any other reasonable purpose relating to the above.

12. Persons who apply for positions with us

This paragraph applies to candidates who send in applications for employment or representative positions, and independent contractors, interns and trainees who apply for (or are put forward for) positions with us.

12.1 conducting interviews;

12.2. processing your application which includes pre-recruitment or pre-engagement checks involving your qualifications and facilitating interviews;

12.3. providing or obtaining employee references and for background screening;

12.4. assessing and evaluating your suitability for employment or engagement in any current or prospective position;

12.5. processing staff referrals;

12.6. verifying your identity and the accuracy of your personal details and other information provided; and

12.7. any other reasonable purpose relating to the above.

13. Employees, temporary staff, interns, trainees, and direct contractors of OCBC

This paragraph applies to all persons engaged in a contract of service or contract for service (including employees, interns and trainees) or contract for service with us (including direct contractors) and their dependants.

The purposes listed below apply to you during your relationship with us. They may continue to apply even when your relationship with us has been terminated or altered in any way.

13.1. performing obligations under or in connection with your contract of employment or relationship with us, such as payment of remuneration and tax;

13.2. reviewing salaries, remuneration and bonuses, conducting salary benchmarking reviews, staff appraisals and evaluations, as well as recognising individuals for their services and conferring awards;

13.3. assessing and evaluating your suitability for employment or appointment, or continued employment or employment in any position in OCBC, and conducting appraisals and evaluations;

13.4. administrative, human resources related and support processes relating to your employment or relationship with us, including managing and terminating your employment or appointment, staff benefits (including medical, travel, workforce, business continuity and logistical management or support), processing expense claims, administering insurance applications, leave administration, training, learning and talent development, resolving grievances, and planning and organising corporate events;

13.5. investigating any acts or defaults or infringements of our internal or external compliance obligations (including fraud and managing insider trading risks);

13.6. providing you with tools and facilities to enable or facilitate the performance of your duties, and monitoring your use of such tools and facilities;

13.7. ensuring business continuity, including compiling and publishing internal directories and emergency contact lists;
13.8. to understand risks in our workplaces, and ensure the safety, health and welfare of persons in our workplaces;

13.9. managing corporate social responsibility projects;

13.10. conducting analytics and research for human resource planning and management, and reviewing and developing work-related practices, environment and productivity;

13.11. ensuring that OCBC’s operations function in a secure, efficient and effective manner (including examining or monitoring any computer software and hardware installed within OCBC, your activities on such computer software and hardware, your internet access, your work e-mails and personal digital and storage devices);

13.12. performing obligations in connection with the provision of our goods or services to our clients;

13.13. responding to an emergency;

13.14. administering cessation processes; and

13.15. any other reasonable purpose relating to the above.

14. OCBC Board of Directors

14.1. facilitating appointments to the Board (including managing the publication of directors' statistics on annual reports and circulars);

14.2. administrative matters (including the maintenance of statutory registers and lodgement of directors' fees);

14.3. managing insurance programmes; and

14.4 any other reasonable purpose relating to the above.

15.Users with multiple relationships with OCBC

This paragraph applies if you have multiple relationships with us (for example, if you use our Digital Services and Electronic Banking Services).

15.1. Combining your Personal Data with other personal data in our possession; and

15.2. Linking the Personal Data collected across your various relationships with OCBC to facilitate your use of our various products and services.
15.3. Depending on your relationship with OCBC, the following data protection policies may also apply:

• Business Banking Data Protection Policy
• China – Privacy Policy (Retail Banking)
• China – Privacy Policy (Corporate Banking)
• Hong Kong – Privacy Policy and Personal Information Collection Statement
• Malaysia – Security and Privacy
• Thailand – Personal Data Protection Notification
• US Agencies – CCPA/CPRA Compliance Privacy Policies
• Vietnam - Data Protection Annex

16. Additional Purposes

Where allowed under applicable law, we may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data).

16.1. providing or marketing services, products and benefits to you (including promotions, loyalty and reward programmes) through various channels including direct marketing, e-mails, voice calls and phone number-based text messaging;

16.2. matching Personal Data with other data collected for other purposes and from other sources (including from our related corporations, business partners and third parties) in connection with the customisation, provision, improvement or offering of products, services, marketing or promotions, whether by OCBC or other third parties;

16.3. administering contests and competitions,

16.4. personalising your experience at our various touchpoints, including our branches;

16.5. sending you information about products, services, offers and rewards; and

16.6. developing and enhancing existing and future products and services through testing, research, and analysis (including analysing behaviour, needs, preferences, location and demographics), and marketing, offering and providing those products and services to you.

We may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data in relation to specific products or services or in your interactions with us. If so, we will also collect, use and disclose your Personal Data for these purposes.

17. Disclosure of Personal Data

We take the confidentiality and disclosure of your Personal Data seriously. We will only share your Personal Data with selected third parties. When we disclose your personal data to such third parties, we require them to ensure that your personal data is kept confidential and secure. Your Personal Data may be disclosed for the purposes listed above (where applicable) to the following entities or parties, whether they are located overseas or in Singapore:

17.1. OCBC’s related corporations, their respective employees, and our Representatives;

17.2. any person or Organisation providing electronic or other services to us;

17.3. counterparties and their respective banks concerning fund transfers, payments, drawing of cheques, and other transactions;

17.4. third-party recipients of bank reference letters;

17.5. companies providing services relating to insurance and reinsurance to OCBC;

17.6. any person or Organisation (including agents, contractors, and third-party service providers) to whom we outsource certain operational functions or activities, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to OCBC;

17.7. vendors or other third-party service providers in connection with marketing promotions and services offered by OCBC;

17.8. analytics, search engine providers or other third-party service providers that help us deliver, improve and optimise our products, services, websites and platforms.

17.9. credit reporting agencies;

17.10. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;

17.11. other banks, financial institutions, credit agencies, credit card companies and their respective service providers;

17.12. third party referrers;

17.13. our co-brand, ecosystem partners and other business partners;

17.14. our professional advisers such as our auditors and lawyers;

17.15. relevant government regulators, ministries, statutory boards or authorities, law enforcement agencies and public officers, whether local or overseas, including the Monetary Authority of Singapore, the Accounting and Corporate Regulatory Authority, the Singapore Police Force, and the Insolvency and Public Trustee Office;

17.16. surveyors, auctioneers, valuers or other third parties concerning loans and other credit facilities such as mortgages;

17.17. universities for tuition fee loan reporting;

17.18. hotels, travel agents and foreign embassies for overseas travel arrangements for staff;

17.19. the Central Provident Fund Board (“CPF”) and its agent banks for CPF investment products, payment schemes and processing excess payment refunds;

17.20. brokerage houses, Central Depository (Pte) Limited, fund houses, registrars, custodians, nominee banks, external banks and investment vehicles for asset management and investment product settlement processing;

17.21. Credit Counselling Singapore and collection and repossession agencies – to enforce repayment obligations for loans and other credit facilities;

17.22. foreign embassies and foreign credit reporting agencies – for credit reviews and the enforcement of repayment obligations for loans and other credit facilities;

17.23. external business and charity partners for corporate promotional events;

17.24. payee corporations, including telecommunications companies, the National Trades Union Congress, Singapore Press Holdings, local town councils and any other entities for processing the payment of bills;

17.25. commercial shops and retailers – to provide staff welfare benefits;

17.26. any swap repository, trade data repository, reporting agent, clearing house, centralised clearing party (including any clearing member of such clearing house or centralised clearing party), clearing broker, multilateral or other trading facility, system or platform or such other communication network or auction facility;

17.27. any other party to whom you authorise us to disclose your information or Personal Data; and

17.28. where necessary, to any person, Organisation, corporation, firm, partnership, limited partnership, limited liability partnership, society, association, trade union, institution or other business concern, whether local or foreign.

18. Retention of Personal Data

Your Personal Data will be retained if a purpose for which it was collected remains reasonable and for other legal or business purposes for which retention of your Personal Data may be necessary.


19. Other Bases for Handling or Processing your Personal Data

In addition to the consent you have provided to our collection, use and disclosure of your Personal Data, where permitted by applicable law, OCBC may also collect, use and disclose your Personal Data without consent:

19.1. for our or a third-party’s legitimate interests, such as:
19.1(a) improving anti-money laundering and financial crime risk management;
19.1(b) detection and prevention of fraud, financial crime, and other illegal activities;
19.1(c) detection of threats to safety and security (including IT and network security);
19.1(d) prevention of misuse of products and services;

19.2. performing credit analysis and other necessary due diligence checks;
19.3. to improve the Companies’ products, services, processes or business, understand your preferences, and personalise experiences and recommendations (regardless of whether you are an existing or prospective customer of any of the Companies) ; and.

19.4 pursuant to exceptions, or when required or authorised to under applicable laws.

20. Use of Cookies and Related Technologies

Our websites and platforms use cookies, web beacons and related technologies. Cookies are files stored on your web browser or electronic device. They are used to enable certain functions on our website, such as remembering your preference and other information. The next time you visit our website or platform, your browser will read the cookie and relay the information back to the website or platform that set the cookie.

Web beacons are unobtrusive graphics that monitors your interactions with our websites and platforms. Our websites or platforms may also use tracking links to help us understand your preferences. –

These technologies can be used to track traffic patterns on websites and platforms, find out if an e-mail has been received or opened, and see if there has been any response.

We may employ cookies, web beacons and related technologies for the following purposes:

20.1. to run our websites and platforms, such as enabling you to log in and navigate our websites and platforms;

20.2. understanding and remembering your preferences;

20.3. enhancing the use, effectiveness and performance of our website and platforms;

20.4. displaying advertising that is relevant to you and understanding the effectiveness of our advertisements; and

20.5. collating information on a user’s browsing history on OCBC’s websites and platforms.

Some cookies we use are from third-party web analytics and intelligence providers. We use such information to compile statistics about visitors who interact with our websites, platforms and online content, to gauge the effectiveness of our communications, and to provide more better information to our visitors. For more information, please refer to the following links:

• Facebook Pixel
• Adobe Analytics

If you do not agree to such use of cookies, you may delete the cookies - or change the settings on your browser accordingly. For information on configuring your web browser, please refer to:

• Chrome
• Safari
• Edge

Please note that, this may affect your user experience and you may be unable to enter certain parts of our websites or platforms.  Our system will issue cookies when you visit our websites or platforms or click on a link in a targeted e-mail we send, even if you have previously deleted our cookies.

21. Artificial Intelligence

We’re constantly innovating to enhance your banking experience, ensuring that it is seamless and secure. Our use of various technologies, like artificial intelligence, actively guards against fraud, streamlines our communications with you, tailors our offerings to fit your needs and ensures that we offer you suitable products and services.

For in-depth insights into our use of artificial intelligence, please refer to our Artificial Intelligence Policy.

22. Security

OCBC has put in place safeguards to protect your Personal Data. This includes an organisation-wide data protection management programme to ensure data protection compliance and risk management. As part of this programme, we have ensured that all our staff have been trained to protect Personal Data. Regular internal and external audits of our data protection compliance are also conducted. A breach of our data protection policies could result in disciplinary action.

While we strive to protect your Personal Data, there are risks when electronic services are used. For tips on securing your Personal Data, please refer to the Online Banking Securityand Malware Notificationsections.

23. Third-Party Sites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of such websites. If you visit these third-party websites, you should review their privacy policies. Some of these third-party websites may be branded with the OCBC logo, even if we do not operate or maintain them.

24. Contacting Us

To contact our Data Protection Office regarding your Personal Data, our Data Protection Policy (including our reliance on legitimate interests), withdrawal of your consent, or obtaining access and making corrections to your Personal Data records, please get in touch with us:

• email: dpo@ocbc.com;
• phone: 1800 363 3333; or
• talk to our staff at any of our branches.

You may withdraw your consent for collecting, using and disclosing your Personal Data. If you withdraw your consent, OCBC may not be able to continue to provide its products or services to you, administer any contractual relationship already in place, or perform or conclude an existing or prospective agreement. This may result in the termination of any agreements you have with OCBC and your breach of contractual obligations or undertakings. In such an event, we reserve our legal rights and remedies.

Please note that if a third party provided your Personal Data to us (e.g. The Central Depository (Pte) Limited), you should contact such third party directly to make any queries, feedback, and access and correction requests to us on your behalf.

25. Governing Law

This Data Protection Policy and your use of this website shall be governed by the laws of Singapore.

Foreign Exchange Terms of Dealing

This communication sets forth our standard terms of foreign exchange (FX) dealing generally with our clients (together with other market participants, "counterparties" or "you") in principal-to-principal transactions in wholesale FX markets (as well as when you act as agent for another principal).

Principal Trading and Conflicts of Interest

Oversea-Chinese Banking Corporation Limited (“OCBC Bank”, “we” or “us”) transacts and makes markets in the wholesale FX market. As such, OCBC Bank engages in price quoting, order taking, trade execution and other related activities. Unless explicitly agreed, OCBC Bank engages in these transactions strictly as principal on an arm’s length basis for the benefit of OCBC Bank and does not act as agent or fiduciary or in any similar capacity on behalf of its counterparties.

Any statements made by or through OCBC Bank’s personnel, our electronic systems or otherwise in the processing or execution of FX transactions should not be construed or relied upon as recommendations or advice. You (or your agent) should independently evaluate the appropriateness of any FX transaction based on the facts, trading objectives and circumstances relevant to you and your assessment of such transaction’s merits.

In all of its communications and transactions with you, including in the handling of requests for firm or indicative quotes, trade requests, placement and execution of orders and all other expressions of interest that may lead to the execution of transactions, there exists the potential that OCBC Bank’s interests may conflict with, diverge from or adversely impact your interests.

OCBC Bank, its related companies, their respective directors and/or employees (collectively “Related Persons”) may or might have in the future interests in the FX transactions or the investment products relating to or in connection with the FX transactions. Such interests include effecting transactions in such investment products, and providing broking, investment banking and other financial services to issuers of such investment products. OCBC Bank and its Related Persons may also be related to, and receive fees from, providers of such investment products.

Market Making

As a market maker that manages a portfolio of positions for multiple counterparties’ competing interests, OCBC Bank acts as principal and may trade prior to or alongside a counterparty’s transaction to execute transactions for OCBC Bank or to facilitate executions with other counterparties, to manage risk, to source liquidity or for other reasons. These activities can have an impact on (i) the prices we offer a counterparty on a transaction and (ii) the availability of liquidity at levels necessary to execute counterparty orders. Such activities potentially can trigger stop loss orders, barriers, knock-outs, knock-ins and similar conditions.

In addition, as a market maker, OCBC Bank may receive requests for quotations and multiple orders for the same or related currency pairs. OCBC Bank acts as principal and may seek to satisfy the requests of all of its counterparties and its independent risk management objectives, nevertheless, it retains discretion with respect to how to satisfy its counterparties, including with respect to order execution, aggregation, priority and pricing. OCBC Bank is not required to disclose to a counterparty when the counterparty attempts to leave an order that OCBC Bank is handling other counterparties’ orders or OCBC Bank orders ahead of, or at the same time as, or on an aggregated basis with, the counterparty’s order. OCBC Bank is under no obligation to disclose to a counterparty why OCBC Bank is unable to execute the counterparty’s order in whole or in part.

Order Handling

When OCBC Bank accepts a counterparty’s order that includes a price (such as a limit order), OCBC Bank is indicating a willingness to attempt to complete the trade at the price requested by the counterparty. Unless otherwise specifically agreed, OCBC Bank will exercise its reasonable discretion in deciding, which orders to execute, when to execute them, and how to execute them, including whether to execute all or part of the order.

OCBC Bank’s acceptance of an order from a counterparty commits OCBC Bank to execute the order, in part or in full and at a price, as may be reasonably expected given market circumstance, as determined by OCBC Bank in its sole and absolute discretion. OCBC Bank’s determination that an order has been filled will create a contract for the exchange of currency under the determined terms, consistent with the order received. The order may be cancelled by either party before the execution of such order commences.

OCBC Bank will exercise its reasonable discretion in deciding if an order should be rejected due to an application of pre-trade execution controls. Such pre-trade execution controls include, but are not limited to, credit and settlement risk limits, market risk limits, and erroneous price checks.

As it relates to timing, OCBC Bank may look for market opportunities that satisfy both a price where we can execute a counterparty’s order at the counterparty’s price and earn a reasonable return for that activity, including while managing and prioritising other interests, positions and executions for OCBC Bank and other counterparties. When OCBC Bank is willing to execute an order with a counterparty, the price at which OCBC Bank would do so may include a mark-up over the price at which OCBC Bank transacted, or may have been able to transact, with other counterparties.

Pricing Factors

OCBC Bank adheres to the principle that prices offered should be fair and reasonable taking into consideration applicable market conditions, best execution practices and internal risk management practices and policies.

Unless otherwise agreed, any firm or indicative price quoted by OCBC Bank to a counterparty is an “all-in” price, inclusive of any mark-up above the price at which OCBC Bank may be able to transact, or has transacted, with other counterparties, regardless of the circumstances under which a counterparty receives or overhears a price. OCBC Bank has the sole and absolute discretion to offer different prices to different counterparties for the same or substantially similar transactions.

Any firm or indicative price or mark-up or other terms of a transaction may vary according to our discretion depending on a broad range of factors. These include transaction or counterparty specific factors, including the overall size of the transaction, OCBC Bank’s expenses associated with effecting the transaction, the credit and settlement risks associated with the transaction, operational risks, a return for OCBC Bank and the nature of our relationship with you including the level of service that we provide to you. In addition, OCBC Bank considers other factors, including prevailing market conditions, OCBC Bank’s risk profile, inventory and risk appetite. OCBC Bank’s provision of principal liquidity is therefore not independent from the interests of OCBC Bank, which may conflict with, diverge from or adversely impact your interests.

OCBC Bank may also differentiate pricing by platform or trading venue, which may result in you receiving different prices on different platforms or venues. Factors that may contribute to this differentiation by platform or venue include but are not limited to the conventions of the platform or venue, which may include minimum price increment, on-the-wire time, parameters for accepting or rejecting orders or trade requests, available order or trade types, underlying technology or latency, fees and other economic considerations, such as historic experience with the platform or venue.

OCBC Bank is under no obligation to disclose the amount of revenue that we expect to earn from a transaction, nor are we required to disclose the components of OCBC Bank’s all-in price.

Pre-hedging Activities

When a counterparty indicates its interest in a potential transaction or provides OCBC Bank with a request to enter into a transaction, OCBC Bank may use that information to engage in pre-hedging activities, which may include entering into transactions prior to executing such potential transaction or request with a view to facilitating such potential transaction or request. Any transactions entered into by OCBC Bank with a view to facilitating such potential transaction or request will be entered into by OCBC Bank as principal, not as agent for the counterparty could be at different prices from the price at which OCBC Bank executes the transaction and may result in profit, or loss, to OCBC Bank.

Such pre-hedging activities will be undertaken for risk management purposes associated with one or more counterparty orders. OCBC Bank will consider prevailing market conditions (such as liquidity) and the size and nature of the potential transaction(s) when undertaking pre-hedging activities.

Handling of Electronic Trade Requests - “Last Look”

Unless expressly stated otherwise, prices communicated electronically by OCBC Bank on electronic platforms do not constitute offers to trade but rather are indications of interest subject to further review by us, and such indicative prices may be withdrawn at any time. Your electronic trade request constitutes an electronic offer to execute a transaction.

Upon receipt of your electronic offer to execute a transaction at a price and quantity, whether in response to an indication of interest or otherwise, OCBC Bank reserves the right to either accept or reject any trade request received from you based on an assessment of whether such trade request meets defined deal acceptance criteria.

The deal acceptance process, also referred to as “the last look window”, may involve one or more checks, including, but not limited to, credit, available liquidity and malformed order checks as well as latency arbitrage protection. The latency arbitrage protection is introduced to prevent the acceptance of requests to trade that appear “on market” when initiated but are later found to have been “stale” or “off market” by the time the primary venues have updated their prices. The expected or typical period of time for making the deal acceptance decision is between 50 milliseconds and 300 milliseconds. Where trading is conducted via a third party venue, OCBC Bank complies with the maximum permitted last look window prescribed by such third party venue.

OCBC Bank does not pre-hedge or otherwise utilize the “offer to deal” information for anything other than deciding trade acceptance during the last look window when market making and applies last look symmetrically, which means trades are rejected if the prevailing market has moved materially either in the counterparties’ favour or against them.

Information Handling

OCBC Bank has policies and controls that are designed to protect a counterparty’s confidential information. However, a counterparty should understand that OCBC Bank makes use of information provided to it as principal in order to effectuate and risk manage transactions.  Specifically, unless otherwise agreed, OCBC Bank may use the economic terms of a transaction (but not the counterparty identity) in order to source liquidity and/or execute risk-mitigating transactions. Please be notified that OCBC Bank, as a regulated entity, has regulatory and other duties to supervise and control its business. OCBC Bank shares information as necessary to fulfil these responsibilities and will respond to general and specific regulatory and other requests with which it is required to comply.

With regard to executed transactions, OCBC Bank analyses this information on an individual and aggregate basis for a variety of purposes, including counterparty risk management, sales coverage, and counterparty relationship management. OCBC Bank may also analyse, comment on, and disclose anonymised and aggregated information regarding executed transactions, together with other relevant market information, internally and to third parties, as market colour.

1. INTRODUCTION

   The purpose of this document is to detail the Best Execution policy (“BE Policy”) of Oversea-Chinese Banking Corporation Limited (“OCBC Bank”) when executing orders in respect of certain financial instruments within the scope of requirements imposed by applicable laws and regulations in the locations we operate in.

2. SCOPE

   The BE Policy applies to all OCBC Bank offices where they conduct regulated activities under the Securities and Futures Act (“SFA”) or their staff are appointed representatives under the SFA, and excludes subsidiaries of OCBC Bank.

   The BE Policy will set the guiding principles for OCBC Bank’s best execution processes. In case of conflicts or inconsistencies, local regulatory requirements would prevail.

3. GOVERNANCE & MANAGEMENT SUPERVISION

   We will monitor best execution arrangements on an on-going basis (at least annually) to identify and implement any appropriate enhancements.

   OCBC Bank reserves the right to amend this document from time to time as it deems necessary. Any material changes to the BE Policy shall be updated here.

4. APPLICABILITY OF BEST EXECUTION

   This document applies with respect to all financial instruments within the scope of “best execution” as prescribed by the regulators in the locations we operate.

   We have in place a policy and framework which are designed for OCBC Bank to try deliver the best possible execution for our clients, subject to the financial instrument and taking into account the nature of the client’s orders, the execution venues available for such financial instruments and the priorities the client places upon us to execute those orders. While OCBC Bank will take all reasonable steps to achieve best execution, OCBC Bank does not guarantee that it will be able to achieve best execution for every transaction or confirm that every transaction will be executed in full.

5. POLICY REQUIREMENTS

   OCBC Bank shall take into account the following factors when executing your order:

   1. Price;
   2. Costs;
   3. Speed;
   4. Likelihood of execution;
   5. Likelihood of settlement;
   6. Size of the order(s);
   7. Nature of the order(s);
   8. Other aspects of the order(s).

   Notwithstanding this, there are certain situations in which these factors will change. These may include, but are not limited to, the following:

   1. Type of order;
   2. Type of product;
   3. Specific instructions that the customer provides;
   4. General prevailing conditions in the market at the time of the order.

6. Specific Instructions

   Where specific instructions are given by you regarding the execution of an order or a part of the order, OCBC Bank will ensure to execute your order in accordance with those instructions. In this circumstance, OCBC Bank will consider itself as having satisfied its best execution obligations with respect to the part of your order to which the instruction relates, when those instructions have been carried out as specifically requested.

   In circumstances where specific instructions are given, these instructions may result in an execution that is less satisfactory than what may have been achieved in the absence of the instruction.

   Where you provide specific instructions covering only part of an order, OCBC Bank will not consider itself released from its best execution obligations for the parts of the order which are not covered by the instructions. In this case, OCBC Bank will comply with our BE policy in respect of that part of the trade not covered by the instructions.

   Where specific instructions given by you cannot be followed, OCBC Bank will inform you of the reasons before executing your order(s).

7. Order Handling

   We have further procedures in place to ensure we execute and allocate your orders promptly and fairly, taking into account the need to manage any potential conflicts of interest that may exist between you, ourselves and our other clients.

   We will execute your order in line with other comparable client orders sequentially and promptly, unless (i) the characteristics of your order or prevailing market conditions make this impracticable; or (ii) your interests require otherwise.

   Where you do not provide specific instructions, we will execute and allocate the order as soon as reasonably practicable.

   When executing your order, we may decide to aggregate the order with a transaction for our own account or that of another client. Such aggregation will be taken, for example, to provide a better price to you or to reduce transaction costs by allowing us to execute in a larger size. We will only aggregate your order if it is unlikely that the aggregation will work overall to your disadvantage. Where we are unable to fill an aggregated order in full, we will allocate the executed notional on a fair and equitable basis.

   We will endeavour to communicate the order execution and allocation status of the order to you as soon as reasonably practicable.

8. Matters outside of the Bank’s Control

   In some cases, whether as a result of system failures, disrupted markets or otherwise, it may be necessary to execute client orders in a different manner as documented for the financial instrument in question. In such circumstances, the transacting unit will still seek to achieve the best possible result available in the prevailing circumstances.

9. CONTACT DETAILS FOR YOUR QUESTIONS

   For queries, please contact your Relationship Manager.

How do we use Artificial Intelligence?

OCBC is committed to harnessing advanced technology to deliver efficient and innovative services to our customers and to enhance our processes. As part of this commitment, OCBC uses Artificial Intelligence (“AI”) across our business.

AI represents a significant advancement in computer systems, enabling them to perform tasks that traditionally required human intelligence. By leveraging AI, we aim to enhance our customers’ experience and make work more meaningful for our employees.

Here are some key ways in which we use AI to serve you better:

1. Protecting our customers
   Our AI algorithms are constantly monitoring your account activities to detect any suspicious transactions or patterns that may indicate scams or fraudulent activity. By taking this proactive approach, we aim to ensure the safety of your financial well-being and protect your accounts from unauthorized access.
2. Protecting the bank and society
   We apply AI algorithms to proactively monitor for financial crime, such as money laundering. By proactively identifying financial crime, we aim to protect OCBC and society, and the wellbeing of our financial system.
3. Personalisation & marketing
   Our AI algorithms analyse banking transactions, interactions and customer profiles to provide you with tailored insights and recommendations. This empowers our customers to make better financial decisions and receive more relevant marketing communications from OCBC.
4. Enhance customer service
   Our AI-powered chatbots are available 24/7 to assist you with basic servicing enquiries such as managing your accounts and providing general banking information. These chatbots deliver prompt and accurate responses, ensuring seamless assistance whenever you need it.
5. Efficient loan approvals
   We apply AI algorithms as part of our loan application assessment process to facilitate more precise and faster decision-making. This improves the efficiency of our loan processing, ensuring you receive a timely decision for your loan application
6. Improving quality of work for our employees
   We also use AI to improve our productivity. This streamlines our internal processes, allowing us to serve you efficiently.
7. Improving our employee engagement
   As our employees are a critical part of our organisation, we use AI to improve our employee engagement by providing our employees with recommendations for their careers, learning and development needs based on their skills. We also use AI to take proactive measures to retain talent. This helps our employee to realise their aspirations and provides us with a stable workforce to better serve our customers.

We understand that data privacy and security and unintentional biases of AI-driven decisions are important concerns for you. Please be assured that we strictly adhere to data protection regulations and employ robust security measures to safeguard your personal data. Our Data Protection Policy sets out how we collect, use and disclose your personal data. We also regularly review and test the AI deployed by us for errors or unintentional biases.

As technology continues to evolve, we remain committed to remaining at the forefront of innovation to serve you better. Our dedicated team of experts continuously explores new ways to leverage AI and other emerging technologies to meet your evolving banking needs.

Please Contact Us if you have questions about our usage of AI.

1. What is FATCA?

   The Foreign Account Tax Compliance Act (FATCA) was enacted by the United States (US) Congress in March 2010 and become effective on 1 July 2014, with a phased implementation timeline where some obligations will be implemented over a period of 2.5 years. FATCA targets non-compliance with US tax laws by US Persons holding accounts and investments outside of US.

   FATCA affects financial institutions (FIs) worldwide. The US has developed Intergovernmental Agreement (IGA) models and reached out to partner jurisdictions, including Singapore, using these bilateral IGAs as tools to facilitate FIs' compliance with FATCA.

2. What is the impact of FATCA?

   FATCA requires all financial institutions (FIs) outside the US to report on a regular basis information about financial accounts held directly or indirectly by US Persons (both personal and business) to IRS or the local tax authorities. FATCA legislation also affects certain types of non-US businesses with US owners.

   For Singapore-based FIs, we are required to undertake annual reporting to the Inland Revenue Authority of Singapore (IRAS) under the Singapore Income Tax (International Tax Compliance Agreements) (United States of America) Regulations 2014 arising from FATCA requirements.

   OCBC is committed to being fully FATCA compliant. With effect from 1 January 2015, we will require customer establishing financial accounts with our Bank to provide us information on their FATCA statuses. We will also be reviewing our existing customer base to confirm the FATCA statuses of our customers and where necessary, we may have to contact our customers for further information and documentation.

3. Is FATCA applicable to personal or business customers?

   FATCA impacts both personal and business customers.

   It affects personal and business customers who are treated as a US Person for US Tax purposes.

   The FATCA legislation also affects certain types of non-US businesses that have a FATCA status as Passive non-financial foreign entities with US owners.

   Please note that OCBC is unable to provide any tax advice. In case of uncertainty, please consult professional tax advice, or refer to the IRS website and IRAS website for more information.

4. Is FATCA only applicable to US businesses?

   No. FATCA impacts not only US businesses, it also imposes extra disclosure requirements on many non-US businesses. Financial Institutions (FIs) are required under the Act to reach out to many business customers globally to determine their status under FATCA. The aim of this exercise is to identify customers which are reportable under FATCA.

5. What is required from a business customer?

   In order to establish your tax status under FATCA, we may need you to provide a Certification on your FATCA status and additional information or documentation to substantiate the status. Please refer to www.ocbc.com/business-banking/Forms.html on the FATCA documents required by OCBC.

   Please note that you may receive more than one request for documentation if you have multiple relationships with different members of OCBC Group. It is important that you respond to all requests, even if you believe you have already supplied the requested information.

   In addition, the way in which financial institutions (FIs) collect information from their customers in order to confirm their tax status under FATCA may vary. This may mean that in some instances you are asked for different documentation from OCBC than from another bank.

   Please note that OCBC is unable to provide any tax advice. In case of uncertainty, please consult professional tax advice, or refer to the IRS website and IRAS website for more information.

6. How will incoming funds from US into a business account affect FATCA reporting?

   FATCA entity classification of a customer will be based on the customer's declaration of its FATCA status to the Bank, as well as any additional information or documentation required to substantiate the status. In case of uncertainty of your FATCA status, please consult professional tax advice.

7. How frequent is FATCA information required?

   FATCA is an ongoing process. If there is any change in your FATCA status, you have to notify us within 30 calendar days from the date of change.

   If your account information changes, we may also contact you to obtain additional information or documentation to update your FATCA status with the Bank.

8. Under what circumstances would OCBC report account information to the IRS or local tax authority?

   The purpose of FATCA is to prevent US Persons from using banks and other financial organisations to avoid US taxation on their global income and assets. OCBC will therefore report information to the Inland Revenue Authority of Singapore (IRAS) on all accounts (including personal and business) held directly or indirectly by US Persons, as well as certain types of non-US businesses that have FATCA status as Passive non-financial foreign entities with US owners. In addition, we may also need to report information about customers who do not provide the required documentation to us.

9. What will OCBC do if customer does not provide the information required under FATCA?

   OCBC is committed to being fully FATCA compliant. Thus, OCBC may not open new accounts or offer additional products and services to customers who choose not to comply with OCBC's requests for documentation to establish their status under FATCA.

   OCBC may need to report information about customers who do not provide the required documentation to us to the Inland Revenue Authority of Singapore (IRAS).

   For more information regarding FATCA, please refer to the IRS website and IRAS website or contact your professional tax advisor for advice.

10. What do I do if I am unsure of my business FATCA status?

    Please do consult professional tax advice.

    Download FATCA Certification Forms to establish your foreign tax status.

Effective 1 January 2015

1. Definitions and Interpretation

   In this FATCA Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation the account number, account balance or value, and gross receipts, withdrawals and payments to or from the account.

   "Applicable Laws and Regulations" means obligations of OCBC Bank to comply with: (i) applicable local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules, codes of practice, whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including but not limited to FATCA.

   "Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Singapore.

   "Consenting Person" means any Person or entity whose information (including Tax Information) is received by OCBC Bank in connection with the provision of Services. For the avoidance of doubt, "Consenting Person" may include Customers, substantial owners and controlling persons of Customers, any Person who is beneficially interested or financially interested in the payments made or to be made by OCBC Bank.

   "Controlling Person" means any individual who exercises ultimate effective control over an entity or trust.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "FATCA" means Section 1471 to 1474 of the United States Internal Revenue Code of 1986, as amended and any associated similar or analogous legislation, treaty, intergovernmental agreement, foreign financial institution agreement, regulation, instruction, or other official guidance of any Authority in any jurisdiction whether within or outside of Singapore.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited and shall include its successors and assigns.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Consenting Person, means: (i) where the Customer and any Consenting Person is an individual, his/her full name, date and place of birth, residential address, mailing address, contact information (including telephone number), and any taxpayer identification number, social security number, citizenship(s), residency(ies) and tax residency(ies) or (if applicable) such information as OCBC Bank may reasonably require regarding Customer and any Consenting Person; (ii) where the Customer and any Consenting Person is a corporate/entity, its date and place of incorporation or formation, registered address, address of place of business, tax identification number, tax status, tax residency, registered address, address of place of business or (if applicable) such information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

   "Services", in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Substantial owner" includes (1) with respect to a corporate or entity, certain persons that directly or indirectly own 25% or more of the corporation's stock (by vote or value), (2) with respect to a partnership, certain persons that directly or indirectly own 25% or more of the profits or capital interests in the partnership, and (3) with respect to a trust, certain persons treated as the owner of the trust or treated as holding directly or indirectly 25% or more of the beneficial interests of the trust.

   "Tax Information" in respect of a Customer and any Consenting Person, means: (i) any documentation or information (and accompanying statements, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Consenting Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Consenting Person; (ii) Personal Information of the Customer and any Consenting Person; and (iii) Account Information.

2. Tax Withholding and Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Consenting Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Consenting Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition.
      3. The Customer must, and, where applicable, procure such other Consenting Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Consenting Person to provide or confirm accuracy of their Personal Information without involving Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any other Consenting Person to any Authority in any jurisdiction for ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any other Consenting Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any other Consenting Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with its obligations under 2.1 above; or
      2. where any of the other Consenting Persons fails to comply with OCBC Bank's requirements in 2.1 or 2.2; or
      3. where the Personal Information (regardless of whether such Personal Information is in relation to Customer or any other Consenting Person) is inaccurate, incomplete, or not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under Singapore law or otherwise) from making disclosure of the Tax Information of Customer and/or any other Consenting Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. deduct from or withhold part of any amounts payable by OCBC Bank to the Customer and/or any other Consenting Person;
      2. refuse to provide new Services to the Customer;
      3. terminate the Customer's account(s) with OCBC Bank;
      4. discontinue entirely or in part OCBC Bank's relationship with Customer;
      5. provide (whether before or after taking actions as described in items 3 and 4 of this section) the Tax Information relating to Customer and/or any of the Consenting Persons to such Authority in any jurisdiction.

3. Customer Confirmations

   By using or accepting the Services, the Customer confirms and agrees that:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this FATCA Policy, has received adequate explanation, and understands the implications of this FATCA Policy by which Customer irrevocably agrees to be bound;
   2. any agreement, waiver, confirmations given in, or to be given pursuant to, this FATCA Policy is irrevocable;
   3. OCBC Bank is not liable for any costs or loss that the Customer (or any other Consenting Persons) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this FATCA Policy;
   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this FATCA Policy;
   5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Consenting Person for the provision of his/her/its Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this FATCA Policy; the Customer must inform each Consenting Person of OCBC Bank's powers under this FATCA Policy;
   6. this FATCA Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between Customer and OCBC Bank.

4. General

   1. In the event of any conflict or inconsistency between any of the contents of this FATCA Policy and other terms and conditions that govern the Customer’s relationship with OCBC Bank, this FATCA Policy shall prevail.
   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this FATCA Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
   3. If all or any part of this FATCA Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this FATCA Policy in that jurisdiction.
   4. It is the Customer's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this FATCA Policy. OCBC Bank do not provide tax or legal advice and are unable to advise Customers regarding the US federal income tax or other tax consequences to them under the Customer's particular circumstances.

Effective 1 January 2015

1. Definitions and Interpretation

   In this FATCA Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation the account number, account balance or value, and gross receipts, withdrawals and payments to or from the account.

   "Applicable Laws and Regulations" means obligations of OCBC Bank to comply with: (i) applicable local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules, codes of practice, whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including but not limited to FATCA.

   "Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Singapore.

   "Consenting Person" means any Person or entity whose information (including Tax Information) is received by OCBC Bank in connection with the provision of Services. For the avoidance of doubt, "Consenting Person" may include Customers, substantial owners and controlling persons of Customers, any Person who is beneficially interested or financially interested in the payments made or to be made by OCBC Bank.

   "Controlling Person" means any individual who exercises ultimate effective control over an entity or trust.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "FATCA" means Section 1471 to 1474 of the United States Internal Revenue Code of 1986, as amended and any associated similar or analogous legislation, treaty, intergovernmental agreement, foreign financial institution agreement, regulation, instruction, or other official guidance of any Authority in any jurisdiction whether within or outside of Singapore.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited and shall include its successors and assigns.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Consenting Person, means: (i) where the Customer and any Consenting Person is an individual, his/her full name, date and place of birth, residential address, mailing address, contact information (including telephone number), and any taxpayer identification number, social security number, citizenship(s), residency(ies) and tax residency(ies) or (if applicable) such information as OCBC Bank may reasonably require regarding Customer and any Consenting Person; (ii) where the Customer and any Consenting Person is a corporate/entity, its date and place of incorporation or formation, registered address, address of place of business, tax identification number, tax status, tax residency, registered address, address of place of business or (if applicable) such information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

   "Services", in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Substantial owner" includes (1) with respect to a corporate or entity, certain persons that directly or indirectly own 25% or more of the corporation's stock (by vote or value), (2) with respect to a partnership, certain persons that directly or indirectly own 25% or more of the profits or capital interests in the partnership, and (3) with respect to a trust, certain persons treated as the owner of the trust or treated as holding directly or indirectly 25% or more of the beneficial interests of the trust.

   "Tax Information" in respect of a Customer and any Consenting Person, means: (i) any documentation or information (and accompanying statements, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Consenting Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Consenting Person; (ii) Personal Information of the Customer and any Consenting Person; and (iii) Account Information.

2. Tax Withholding and Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Consenting Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Consenting Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition.
      3. The Customer must, and, where applicable, procure such other Consenting Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Consenting Person to provide or confirm accuracy of their Personal Information without involving Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any other Consenting Person to any Authority in any jurisdiction for ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any other Consenting Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any other Consenting Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with its obligations under 2.1 above; or
      2. where any of the other Consenting Persons fails to comply with OCBC Bank's requirements in 2.1 or 2.2; or
      3. where the Personal Information (regardless of whether such Personal Information is in relation to Customer or any other Consenting Person) is inaccurate, incomplete, or not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under Singapore law or otherwise) from making disclosure of the Tax Information of Customer and/or any other Consenting Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. deduct from or withhold part of any amounts payable by OCBC Bank to the Customer and/or any other Consenting Person;
      2. refuse to provide new Services to the Customer;
      3. terminate the Customer's account(s) with OCBC Bank;
      4. discontinue entirely or in part OCBC Bank's relationship with Customer;
      5. provide (whether before or after taking actions as described in items 3 and 4 of this section) the Tax Information relating to Customer and/or any of the Consenting Persons to such Authority in any jurisdiction.

   4. Customer Confirmations

      By using or accepting the Services, the Customer confirms and agrees that:

      1. without prejudice to the terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this FATCA Policy, has received adequate explanation, and understands the implications of this FATCA Policy by which Customer irrevocably agrees to be bound;
      2. any agreement, waiver, confirmations given in, or to be given pursuant to, this FATCA Policy is irrevocable;
      3. OCBC Bank is not liable for any costs or loss that the Customer (or any other Consenting Persons) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this FATCA Policy;
      4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this FATCA Policy;
      5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Consenting Person for the provision of his/her/its Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this FATCA Policy;
      6. the Customer must inform each Consenting Person of OCBC Bank's powers under this FATCA Policy;
      7. this FATCA Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between Customer and OCBC Bank.

   5. General

      1. In the event of any conflict or inconsistency between any of the contents of this FATCA Policy and other terms and conditions that govern the Customer’s relationship with OCBC Bank, this FATCA Policy shall prevail.
      2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this FATCA Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
      3. If all or any part of this FATCA Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this FATCA Policy in that jurisdiction.
      4. It is the Customer's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this FATCA Policy. OCBC Bank do not provide tax or legal advice and are unable to advise Customers regarding the US federal income tax or other tax consequences to them under the Customer's particular circumstances.

Effective 1 January 2015

1. Definitions and Interpretation

   In this FATCA Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation the account number, account balance or value, and gross receipts, withdrawals and payments to or from the account.

   "Applicable Laws and Regulations" means obligations of OCBC Bank to comply with: (i) applicable local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules, codes of practice, whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including but not limited to FATCA.

   "Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Singapore or Japan.

   "Consenting Person" means any Person or entity whose information (including Tax Information) is received by OCBC Bank in connection with the provision of Services. For the avoidance of doubt, "Consenting Person" may include Customers, substantial owners and controlling persons of Customers, any Person who is beneficially interested or financially interested in the payments made or to be made by OCBC Bank.

   "Controlling Person" means any individual who exercises ultimate effective control over an entity or trust.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "FATCA" means Section 1471 to 1474 of the United States Internal Revenue Code of 1986, as amended and any associated similar or analogous legislation, treaty, intergovernmental agreement, foreign financial institution agreement, regulation, instruction, or other official guidance of any Authority in any jurisdiction whether within or outside of Singapore or Japan.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited and shall include its successors and assigns.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Consenting Person, means: (i) where the Customer and any Consenting Person is an individual, his/her full name, date and place of birth, residential address, mailing address, contact information (including telephone number), and any taxpayer identification number, social security number, citizenship(s), residency(ies) and tax residency(ies) or (if applicable) such information as OCBC Bank may reasonably require regarding Customer and any Consenting Person; (ii) where the Customer and any Consenting Person is a corporate/entity, its date and place of incorporation or formation, registered address, address of place of business, tax identification number, tax status, tax residency, registered address, address of place of business or (if applicable) such information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

   "Services", in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Substantial owner" includes (1) with respect to a corporate or entity, certain persons that directly or indirectly own 25% or more of the corporation's stock (by vote or value), (2) with respect to a partnership, certain persons that directly or indirectly own 25% or more of the profits or capital interests in the partnership, and (3) with respect to a trust, certain persons treated as the owner of the trust or treated as holding directly or indirectly 25% or more of the beneficial interests of the trust.

   "Tax Information" in respect of a Customer and any Consenting Person, means: (i) any documentation or information (and accompanying statements, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Consenting Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Consenting Person; (ii) Personal Information of the Customer and any Consenting Person; and (iii) Account Information.

2. Tax Withholding and Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Consenting Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Consenting Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition.
      3. The Customer must, and, where applicable, procure such other Consenting Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Consenting Person to provide or confirm accuracy of their Personal Information without involving Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any other Consenting Person to any Authority in any jurisdiction for ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any other Consenting Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any other Consenting Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with its obligations under 2.1 above; or
      2. where any of the other Consenting Persons fails to comply with OCBC Bank's requirements in 2.1 or 2.2; or
      3. where the Personal Information (regardless of whether such Personal Information is in relation to Customer or any other Consenting Person) is inaccurate, incomplete, or not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under Singapore law or Japanese law or otherwise) from making disclosure of the Tax Information of Customer and/or any other Consenting Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. deduct from or withhold part of any amounts payable by OCBC Bank to the Customer and/or any other Consenting Person;
      2. refuse to provide new Services to the Customer;
      3. terminate the Customer's account(s) with OCBC Bank;
      4. discontinue entirely or in part OCBC Bank's relationship with Customer;
      5. provide (whether before or after taking actions as described in items 3 and 4 of this section) the Tax Information relating to Customer and/or any of the Consenting Persons to such Authority in any jurisdiction.

3. Customer Confirmations

   By using or accepting the Services, the Customer confirms and agrees that:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this FATCA Policy, has received adequate explanation, and understands the implications of this FATCA Policy by which Customer irrevocably agrees to be bound;
   2. any agreement, waiver, confirmations given in, or to be given pursuant to, this FATCA Policy is irrevocable;
   3. OCBC Bank is not liable for any costs or loss that the Customer (or any other Consenting Persons) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this FATCA Policy;
   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this FATCA Policy;
   5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Consenting Person for the provision of his/her/its Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this FATCA Policy; the Customer must inform each Consenting Person of OCBC Bank's powers under this FATCA Policy;
   6. this FATCA Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between Customer and OCBC Bank.

4. General

   1. In the event of any conflict or inconsistency between any of the contents of this FATCA Policy and other terms and conditions that govern the Customer’s relationship with OCBC Bank, this FATCA Policy shall prevail.
   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this FATCA Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
   3. If all or any part of this FATCA Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this FATCA Policy in that jurisdiction.
   4. It is the Customer's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this FATCA Policy. OCBC Bank do not provide tax or legal advice and are unable to advise Customers regarding the US federal income tax or other tax consequences to them under the Customer's particular circumstances.

Effective 1 January 2015

1. Definitions and Interpretation

   In this FATCA Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation the account number, account balance or value, and gross receipts, withdrawals and payments to or from the account.

   "Applicable Laws and Regulations" means obligations of OCBC Bank to comply with: (i) applicable local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules, codes of practice, whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including but not limited to FATCA.

   "Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Singapore.

   "Consenting Person" means any Person or entity whose information (including Tax Information) is received by OCBC Bank in connection with the provision of Services. For the avoidance of doubt, "Consenting Person" may include Customers, substantial owners and controlling persons of Customers, any Person who is beneficially interested or financially interested in the payments made or to be made by OCBC Bank.

   "Controlling Person" means any individual who exercises ultimate effective control over an entity or trust.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "FATCA" means Section 1471 to 1474 of the United States Internal Revenue Code of 1986, as amended and any associated similar or analogous legislation, treaty, intergovernmental agreement, foreign financial institution agreement, regulation, instruction, or other official guidance of any Authority in any jurisdiction whether within or outside of Singapore.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Consenting Person, means: (i) where the Customer and any Consenting Person is an individual, his/her full name, date and place of birth, residential address, mailing address, contact information (including telephone number), and any taxpayer identification number, social security number, citizenship(s), residency(ies) and tax residency(ies) or (if applicable) such information as OCBC Bank may reasonably require regarding Customer and any Consenting Person; (ii) where the Customer and any Consenting Person is a corporate/entity, its date and place of incorporation or formation, registered address, address of place of business, tax identification number, tax status, tax residency, registered address, address of place of business or (if applicable) such information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

   "Services", in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Substantial owner"
   A person shall be deemed to be a controlling shareholder if he Controls more than 50% of the voting rights

   "Substantial owner" includes (1) with respect to a corporate or entity, certain persons that directly or indirectly own 25% or more of the corporation's stock (by vote or value), (2) with respect to a partnership, certain persons that directly or indirectly own 25% or more of the profits or capital interests in the partnership, and (3) with respect to a trust, certain persons treated as the owner of the trust or treated as holding directly or indirectly 25% or more of the beneficial interests of the trust.

   "Tax Information" in respect of a Customer and any Consenting Person, means: (i) any documentation or information (and accompanying statements, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Consenting Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Consenting Person; (ii) Personal Information of the Customer and any Consenting Person; and (iii) Account Information.

2. Tax Withholding and Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Consenting Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Consenting Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition.
      3. The Customer must, and, where applicable, procure such other Consenting Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Consenting Person to provide or confirm accuracy of their Personal Information without involving Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any other Consenting Person to any Authority in any jurisdiction for ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any other Consenting Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any other Consenting Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with its obligations under 2.1 above; or
      2. where any of the other Consenting Persons fails to comply with OCBC Bank's requirements in 2.1 or 2.2; or
      3. where the Personal Information (regardless of whether such Personal Information is in relation to Customer or any other Consenting Person) is inaccurate, incomplete, or not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under Singapore law or otherwise) from making disclosure of the Tax Information of Customer and/or any other Consenting Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. deduct from or withhold part of any amounts payable by OCBC Bank to the Customer and/or any other Consenting Person;
      2. refuse to provide new Services to the Customer;
      3. terminate the Customer's account(s) with OCBC Bank;
      4. discontinue entirely or in part OCBC Bank's relationship with Customer;
      5. provide (whether before or after taking actions as described in items 3 and 4 of this section) the Tax Information relating to Customer and/or any of the Consenting Persons to such Authority in any jurisdiction.

3. Customer Confirmations

   By using or accepting the Services, the Customer confirms and agrees that:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this FATCA Policy, has received adequate explanation, and understands the implications of this FATCA Policy by which Customer irrevocably agrees to be bound;
   2. any agreement, waiver, confirmations given in, or to be given pursuant to, this FATCA Policy is irrevocable;
   3. OCBC Bank is not liable for any costs or loss that the Customer (or any other Consenting Persons) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this FATCA Policy;
   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this FATCA Policy;
   5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Consenting Person for the provision of his/her/its Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this FATCA Policy; the Customer must inform each Consenting Person of OCBC Bank's powers under this FATCA Policy;
   6. this FATCA Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between Customer and OCBC Bank.

4. General

   1. In the event of any conflict or inconsistency between any of the contents of this FATCA Policy and other terms and conditions that govern the Customer’s relationship with OCBC Bank, this FATCA Policy shall prevail.
   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this FATCA Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
   3. If all or any part of this FATCA Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this FATCA Policy in that jurisdiction.
   4. It is the Customer's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this FATCA Policy. OCBC Bank do not provide tax or legal advice and are unable to advise Customers regarding the US federal income tax or other tax consequences to them under the Customer's particular circumstances.

Effective 23 April 2015

1. Definitions and Interpretation

   In this FATCA Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation the account number, account balance or value, and gross receipts, withdrawals and payments to or from the account.

   "Applicable Laws and Regulations" means obligations of OCBC Bank to comply with: (i) applicable local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules, codes of practice, whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including but not limited to FATCA.

   "Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Myanmar.

   "Consenting Person" means any Person or entity whose information (including Tax Information) is received by OCBC Bank in connection with the provision of Services. For the avoidance of doubt, "Consenting Person" may include Customers, Substantial Owners and Controlling Persons of Customers, any Person who is beneficially interested or financially interested in the payments made or to be made by OCBC Bank.

   "Controlling Person" means any individual who exercises ultimate effective control over an entity or trust.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "FATCA" means Section 1471 to 1474 of the United States Internal Revenue Code of 1986, as amended and any associated similar or analogous legislation, treaty, intergovernmental agreement, foreign financial institution agreement, regulation, instruction, or other official guidance of any Authority in any jurisdiction whether within or outside of Myanmar.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited, Yangon Branch and shall include its successors and assigns.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Consenting Person, means: (i) where the Customer and any Consenting Person is an individual, his/her full name, date and place of birth, residential address, mailing address, contact information (including telephone number), and any taxpayer identification number, social security number, citizenship(s), residency(ies) and tax residency(ies) or (if applicable) such information as OCBC Bank may reasonably require regarding Customer and any Consenting Person; (ii) where the Customer and any Consenting Person is a corporate/entity, its date and place of incorporation or formation, registered address, address of place of business, tax identification number, tax status, tax residency, registered address, address of place of business or (if applicable) such information as OCBC Bank may reasonably require regarding each of its Substantial Owners and Controlling Persons.

   "Services", in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Substantial Owner" includes (1) with respect to a corporate or entity, certain persons that directly or indirectly own 10% or more of the corporation's stock (by vote or value), (2) with respect to a partnership, certain persons that directly or indirectly own 10% or more of the profits or capital interests in the partnership, and (3) with respect to a trust, certain persons treated as the owner of the trust or treated as holding directly or indirectly 10% or more of the beneficial interests of the trust.

   "Tax Information" in respect of a Customer and any Consenting Person, means: (i) any documentation or information (and accompanying statements, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Consenting Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Consenting Person; (ii) Personal Information of the Customer and any Consenting Person; and (iii) Account Information.

2. Tax Withholding and Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Consenting Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Consenting Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition.
      3. The Customer must, and, where applicable, procure such other Consenting Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Consenting Person to provide or confirm accuracy of their Personal Information without involving Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any other Consenting Person to any Authority in any jurisdiction for ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any other Consenting Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any other Consenting Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with its obligations under 2.1 above; or
      2. where any of the other Consenting Persons fails to comply with OCBC Bank's requirements in 2.1 or 2.2; or
      3. where the Personal Information (regardless of whether such Personal Information is in relation to Customer or any other Consenting Person) is inaccurate, incomplete, or not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under Myanmar law or otherwise) from making disclosure of the Tax Information of Customer and/or any other Consenting Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. deduct from or withhold part of any amounts payable by OCBC Bank to the Customer and/or any other Consenting Person;
      2. refuse to provide new Services to the Customer;
      3. terminate the Customer's account(s) with OCBC Bank;
      4. discontinue entirely or in part OCBC Bank's relationship with Customer;
      5. provide (whether before or after taking actions as described in items 3 and 4 of this section) the Tax Information relating to Customer and/or any of the Consenting Persons to such Authority in any jurisdiction.

3. Customer Confirmations

   By using or accepting the Services, the Customer confirms and agrees that:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this FATCA Policy, has received adequate explanation, and understands the implications of this FATCA Policy by which Customer irrevocably agrees to be bound;
   2. any agreement, waiver, confirmations given in, or to be given pursuant to, this FATCA Policy is irrevocable;
   3. OCBC Bank is not liable for any costs or loss that the Customer (or any other Consenting Persons) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this FATCA Policy;
   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this FATCA Policy;
   5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Consenting Person for the provision of his/her/its Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this FATCA Policy;
   6. the Customer must inform each Consenting Person of OCBC Bank's powers under this FATCA Policy;
   7. this FATCA Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between Customer and OCBC Bank.

4. General

   1. In the event of any conflict or inconsistency between any of the contents of this FATCA Policy and other terms and conditions that govern the Customer’s relationship with OCBC Bank, this FATCA Policy shall prevail.
   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this FATCA Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
   3. If all or any part of this FATCA Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this FATCA Policy in that jurisdiction.
   4. It is the Customer's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this FATCA Policy. OCBC Bank do not provide tax or legal advice and are unable to advise Customers regarding the US federal income tax or other tax consequences to them under the Customer's particular circumstances.

Effective 1 January 2015

1. Definitions and Interpretation

   In this FATCA Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation the account number, account balance or value, and gross receipts, withdrawals and payments to or from the account.

   "Applicable Laws and Regulations" means obligations of OCBC Bank to comply with: (i) applicable local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules, codes of practice, whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including but not limited to FATCA.

   "Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Singapore.

   "Consenting Person" means any Person or entity whose information (including Tax Information) is received by OCBC Bank in connection with the provision of Services. For the avoidance of doubt, "Consenting Person" may include Customers, substantial owners and controlling persons of Customers, any Person who is beneficially interested or financially interested in the payments made or to be made by OCBC Bank.

   "Controlling Person" means any individual who exercises ultimate effective control over an entity or trust.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "FATCA" means Section 1471 to 1474 of the United States Internal Revenue Code of 1986, as amended and any associated similar or analogous legislation, treaty, intergovernmental agreement, foreign financial institution agreement, regulation, instruction, or other official guidance of any Authority in any jurisdiction whether within or outside of Singapore.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited and shall include its successors and assigns.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Consenting Person, means: (i) where the Customer and any Consenting Person is an individual, his/her full name, date and place of birth, residential address, mailing address, contact information (including telephone number), and any taxpayer identification number, social security number, citizenship(s), residency(ies) and tax residency(ies) or (if applicable) such information as OCBC Bank may reasonably require regarding Customer and any Consenting Person; (ii) where the Customer and any Consenting Person is a corporate/entity, its date and place of incorporation or formation, registered address, address of place of business, tax identification number, tax status, tax residency, registered address, address of place of business or (if applicable) such information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

   "Services", in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Substantial owner" includes (1) with respect to a corporate or entity, certain persons that directly or indirectly own 25% or more of the corporation's stock (by vote or value), (2) with respect to a partnership, certain persons that directly or indirectly own 25% or more of the profits or capital interests in the partnership, and (3) with respect to a trust, certain persons treated as the owner of the trust or treated as holding directly or indirectly 25% or more of the beneficial interests of the trust.

   "Tax Information" in respect of a Customer and any Consenting Person, means: (i) any documentation or information (and accompanying statements, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Consenting Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Consenting Person; (ii) Personal Information of the Customer and any Consenting Person; and (iii) Account Information.

2. Tax Withholding and Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Consenting Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Consenting Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition.
      3. The Customer must, and, where applicable, procure such other Consenting Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Consenting Person to provide or confirm accuracy of their Personal Information without involving Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any other Consenting Person to any Authority in any jurisdiction for ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any other Consenting Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any other Consenting Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with its obligations under 2.1 above; or
      2. where any of the other Consenting Persons fails to comply with OCBC Bank's requirements in 2.1 or 2.2; or
      3. where the Personal Information (regardless of whether such Personal Information is in relation to Customer or any other Consenting Person) is inaccurate, incomplete, or not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under Singapore law or otherwise) from making disclosure of the Tax Information of Customer and/or any other Consenting Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. deduct from or withhold part of any amounts payable by OCBC Bank to the Customer and/or any other Consenting Person;
      2. refuse to provide new Services to the Customer;
      3. terminate the Customer's account(s) with OCBC Bank;
      4. discontinue entirely or in part OCBC Bank's relationship with Customer;
      5. provide (whether before or after taking actions as described in items 3 and 4 of this section) the Tax Information relating to Customer and/or any of the Consenting Persons to such Authority in any jurisdiction.

3. Customer Confirmations

   By using or accepting the Services, the Customer confirms and agrees that:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this FATCA Policy, has received adequate explanation, and understands the implications of this FATCA Policy by which Customer irrevocably agrees to be bound;
   2. any agreement, waiver, confirmations given in, or to be given pursuant to, this FATCA Policy is irrevocable;
   3. OCBC Bank is not liable for any costs or loss that the Customer (or any other Consenting Persons) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this FATCA Policy;
   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this FATCA Policy;
   5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Consenting Person for the provision of his/her/its Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this FATCA Policy; the Customer must inform each Consenting Person of OCBC Bank's powers under this FATCA Policy;
   6. this FATCA Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between Customer and OCBC Bank.

4. General

   1. In the event of any conflict or inconsistency between any of the contents of this FATCA Policy and other terms and conditions that govern the Customer’s relationship with OCBC Bank, this FATCA Policy shall prevail.
   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this FATCA Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
   3. If all or any part of this FATCA Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this FATCA Policy in that jurisdiction.
   4. It is the Customer's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this FATCA Policy. OCBC Bank do not provide tax or legal advice and are unable to advise Customers regarding the US federal income tax or other tax consequences to them under the Customer's particular circumstances.

Effective 1 January 2015

1. Definitions and Interpretation

   In this FATCA Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation the account number, account balance or value, and gross receipts, withdrawals and payments to or from the account.

   "Applicable Laws and Regulations" means obligations of OCBC Bank to comply with: (i) applicable local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules, codes of practice, whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including but not limited to FATCA.

   "Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Singapore.

   "Consenting Person" means any Person or entity whose information (including Tax Information) is received by OCBC Bank in connection with the provision of Services. For the avoidance of doubt, "Consenting Person" may include Customers, Substantial Owners and controlling persons of Customers, any Person who is beneficially interested or financially interested in the payments made or to be made by OCBC Bank.

   "Controlling Person" means any individual who exercises ultimate effective control over an entity or trust.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "FATCA" means Section 1471 to 1474 of the United States Internal Revenue Code of 1986, as amended and any associated similar or analogous legislation, treaty, intergovernmental agreement, foreign financial institution agreement, regulation, instruction, or other official guidance of any Authority in any jurisdiction whether within or outside of Singapore.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited, including any of its branches in any jurisdiction and shall include its successors and assigns.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Consenting Person, means: (i) where the Customer and any Consenting Person is an individual, his/her full name, date and place of birth, residential address, mailing address, contact information (including telephone number), and any taxpayer identification number, social security number, citizenship(s), residency(ies) and tax residency(ies) or (if applicable) such information as OCBC Bank may reasonably require regarding Customer and any Consenting Person; (ii) where the Customer and any Consenting Person is a corporate/entity, its date and place of incorporation or formation, registered address, address of place of business, tax identification number, tax status, tax residency, registered address, address of place of business or (if applicable) such information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

   "Services", in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Substantial Owner" includes (1) with respect to a corporate or entity, certain persons that directly or indirectly own 25% or more of the corporation's stock (by vote or value), (2) with respect to a partnership, certain persons that directly or indirectly own 25% or more of the profits or capital interests in the partnership, and (3) with respect to a trust, certain persons treated as the owner of the trust or treated as holding directly or indirectly 25% or more of the beneficial interests of the trust.

   "Tax Information" in respect of a Customer and any Consenting Person, means: (i) any documentation or information (and accompanying statements, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Consenting Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Consenting Person; (ii) Personal Information of the Customer and any Consenting Person; and (iii) Account Information.

2. Tax Withholding and Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Consenting Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Consenting Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition.
      3. The Customer must, and, where applicable, procure such other Consenting Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Consenting Person to provide or confirm accuracy of their Personal Information without involving Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any other Consenting Person to any Authority in any jurisdiction for ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any other Consenting Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any other Consenting Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with its obligations under 2.1 above; or
      2. where any of the other Consenting Persons fails to comply with OCBC Bank's requirements in 2.1 or 2.2; or
      3. where the Personal Information (regardless of whether such Personal Information is in relation to Customer or any other Consenting Person) is inaccurate, incomplete, or not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under Singapore law or otherwise) from making disclosure of the Tax Information of Customer and/or any other Consenting Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. deduct from or withhold part of any amounts payable by OCBC Bank to the Customer and/or any other Consenting Person;
      2. refuse to provide new Services to the Customer;
      3. terminate the Customer's account(s) with OCBC Bank;
      4. discontinue entirely or in part OCBC Bank's relationship with Customer;
      5. provide (whether before or after taking actions as described in items 3 and 4 of this section) the Tax Information relating to Customer and/or any of the Consenting Persons to such Authority in any jurisdiction.

3. Customer Confirmations

   By using or accepting the Services, the Customer confirms and agrees that:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this FATCA Policy, has received adequate explanation, and understands the implications of this FATCA Policy by which Customer irrevocably agrees to be bound;
   2. any agreement, waiver, confirmations given in, or to be given pursuant to, this FATCA Policy is irrevocable;
   3. OCBC Bank is not liable for any costs or loss that the Customer (or any other Consenting Persons) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this FATCA Policy;
   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this FATCA Policy;
   5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Consenting Person for the provision of his/her/its Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this FATCA Policy; the Customer must inform each Consenting Person of OCBC Bank's powers under this FATCA Policy;
   6. this FATCA Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between Customer and OCBC Bank.
   7. The Customer shall fully indemnify and hold OCBC Bank harmless in respect of any liabilities, losses, damages, claims, costs and/or expenses (other than loss of profit, loss of revenue or loss of business) which may be suffered or reasonably incurred by OCBC Bank directly or indirectly arising out of or in connection with:
   8. (x) any material misrepresentation, or incomplete or inaccurate or false information you provided to us; (y) any withdrawal of consent, agreement or waiver referred to in this FATCA Policy; or (z) any breach of any terms of this FATCA Policy on the part of the Customer or the Consenting Person.
   9. any claims, proceedings or actions against OCBC Bank by the Consenting Person.

4. General

   1. In the event of any conflict or inconsistency between any of the contents of this FATCA Policy and other terms and conditions that govern the Customer’s relationship with OCBC Bank, this FATCA Policy shall prevail.
   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this FATCA Policy unilaterally at any time as may be required by OCBC Bank to ensure compliance with Applicable Laws and Regulations.
   3. If all or any part of this FATCA Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this FATCA Policy in that jurisdiction.
   4. It is the Customer's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this FATCA Policy. OCBC Bank do not provide tax or legal advice and are unable to advise Customers regarding the US federal income tax or other tax consequences to them under the Customer's particular circumstances.
   5. Where the Customer is opening and/or maintaining account(s) with OCBC Bank and/or obtaining Services from us as an agent or a nominee for any Consenting Person, the consents, agreements and waivers in this FATCA Policy shall be deemed to be given by the Customer in its own capacity and on behalf of each such Consenting Person.

Effective 1 January 2015

1. Definitions and Interpretation

   In this FATCA Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation the account number, account balance or value, and gross receipts, withdrawals and payments to or from the account.

   "Applicable Laws and Regulations" means obligations of OCBC Bank to comply with: (i) applicable local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules, codes of practice, whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including but not limited to FATCA.

   "Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Singapore.

   "Consenting Person" means any Person or entity whose information (including Tax Information) is received by OCBC Bank in connection with the provision of Services. For the avoidance of doubt, "Consenting Person" may include Customers, substantial owners and controlling persons of Customers, any Person who is beneficially interested or financially interested in the payments made or to be made by OCBC Bank.

   "Controlling Person" means any individual who exercises ultimate effective control over an entity or trust.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "FATCA" means Section 1471 to 1474 of the United States Internal Revenue Code of 1986, as amended and any associated similar or analogous legislation, treaty, intergovernmental agreement, foreign financial institution agreement, regulation, instruction, or other official guidance of any Authority in any jurisdiction whether within or outside of Singapore.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited and shall include its successors and assigns.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Consenting Person, means: (i) where the Customer and any Consenting Person is an individual, his/her full name, date and place of birth, residential address, mailing address, contact information (including telephone number), and any taxpayer identification number, social security number, citizenship(s), residency(ies) and tax residency(ies) or (if applicable) such information as OCBC Bank may reasonably require regarding Customer and any Consenting Person; (ii) where the Customer and any Consenting Person is a corporate/entity, its date and place of incorporation or formation, registered address, address of place of business, tax identification number, tax status, tax residency, registered address, address of place of business or (if applicable) such information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

   "Services", in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Substantial owner" includes (1) with respect to a corporate or entity, certain persons that directly or indirectly own 10% or more of the corporation's stock (by vote or value), (2) with respect to a partnership, certain persons that directly or indirectly own 10% or more of the profits or capital interests in the partnership, and (3) with respect to a trust, certain persons treated as the owner of the trust or treated as holding directly or indirectly 10% or more of the beneficial interests of the trust.

   "Tax Information" in respect of a Customer and any Consenting Person, means: (i) any documentation or information (and accompanying statements, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Consenting Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Consenting Person; (ii) Personal Information of the Customer and any Consenting Person; and (iii) Account Information.

2. Tax Withholding and Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Consenting Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Consenting Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition.
      3. The Customer must, and, where applicable, procure such other Consenting Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Consenting Person to provide or confirm accuracy of their Personal Information without involving Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any other Consenting Person to any Authority in any jurisdiction for ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any other Consenting Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any other Consenting Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with its obligations under 2.1 above; or
      2. where any of the other Consenting Persons fails to comply with OCBC Bank's requirements in 2.1 or 2.2; or
      3. where the Personal Information (regardless of whether such Personal Information is in relation to Customer or any other Consenting Person) is inaccurate, incomplete, or not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under Singapore law or otherwise) from making disclosure of the Tax Information of Customer and/or any other Consenting Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. deduct from or withhold part of any amounts payable by OCBC Bank to the Customer and/or any other Consenting Person;
      2. refuse to provide new Services to the Customer;
      3. terminate the Customer's account(s) with OCBC Bank;
      4. discontinue entirely or in part OCBC Bank's relationship with Customer;
      5. provide (whether before or after taking actions as described in items 3 and 4 of this section) the Tax Information relating to Customer and/or any of the Consenting Persons to such Authority in any jurisdiction.

3. Customer Confirmations

   By using or accepting the Services, the Customer confirms and agrees that:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this FATCA Policy, has received adequate explanation, and understands the implications of this FATCA Policy by which Customer irrevocably agrees to be bound;
   2. any agreement, waiver, confirmations given in, or to be given pursuant to, this FATCA Policy is irrevocable;
   3. OCBC Bank is not liable for any costs or loss that the Customer (or any other Consenting Persons) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this FATCA Policy;
   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this FATCA Policy;
   5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Consenting Person for the provision of his/her/its Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this FATCA Policy; the Customer must inform each Consenting Person of OCBC Bank's powers under this FATCA Policy;
   6. this FATCA Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between Customer and OCBC Bank.

4. General

   1. In the event of any conflict or inconsistency between any of the contents of this FATCA Policy and other terms and conditions that govern the Customer’s relationship with OCBC Bank, this FATCA Policy shall prevail.
   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this FATCA Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
   3. If all or any part of this FATCA Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this FATCA Policy in that jurisdiction.
   4. It is the Customer's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this FATCA Policy. OCBC Bank do not provide tax or legal advice and are unable to advise Customers regarding the US federal income tax or other tax consequences to them under the Customer's particular circumstances.

Effective 1 January 2015

1. Definitions and Interpretation
   Định nghĩa và diễn giải

   In this FATCA Policy, the following capitalised terms have the following meaning:
   Trong Chính sách FATCA này, những thuật ngữ in đậm dưới đây có ý nghĩa như sau:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation the account number, account balance or value, and gross receipts, withdrawals and payments to or from the account.
   "Thông tin Tài khoản" có nghĩa là bất cứ thông tin nào liên quan đến bất kỳ tài khoản nào của Khách hàng mở tại Ngân hàng OCBC bao gồm nhưng không chỉ giới hạn đến số tài khoản, số dư tài khoản hoặc giá trị tài khoản, và những khoản tiền ghi có, rút và thanh toán đến hoặc từ tài khoản.

   "Applicable Laws and Regulations" means obligations of OCBC Bank to comply with: (i) applicable local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules, codes of practice, whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including but not limited to FATCA.
   "Luật và Quy định pháp luật áp dụng" có nghĩa là nghĩa vụ của Ngân hàng OCBC phải tuân thủ với (i) luật, pháp lệnh, quy định, yêu cầu, thông báo, hướng dẫn, luật lệ, quy tắc thực hành trong nước và nước ngoài, dù là có hay không có liên quan đến Hiệp định liên chính phủ giữa các chính phủ hoặc các cơ quan có thẩm quyền của hai hay nhiều thẩm quyền tài phán khác nhau và (ii) bất cứ thỏa thuận nào giữa Ngân hàng OCBC và bất kỳ chính phủ hoặc cơ quan thuế ở bất kỳ thẩm quyền tài phán nào, và bao gồm nhưng không giới hạn FATCA.

   "Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Vietnam.
   "Cơ quan Thẩm quyền" có nghĩa là bất kỳ quốc gia, tiểu bang hoặc chính quyền địa phương, phân khu hay cơ quan chính trị nào trực thuộc chính quyền đó, bất kỳ nhiệm sở, cơ quan thẩm quyền, công cụ quyền lực nào, cho dù là về mặt tổ chức tư pháp hoặc hành chính, tổ chức chính quy hoặc tự điều tiết, cơ quan thi hành pháp luật, tòa án, ngân hàng trung ương hoặc cơ quan thuế vụ ở bất kỳ thẩm quyền tài phán nào, dù trong hay ngoài quốc gia Việt Nam".

   "Consenting Person" means any Person or entity whose information (including Tax Information) is received by OCBC Bank in connection with the provision of Services. For the avoidance of doubt, "Consenting Person" may include Customers, substantial owners and controlling persons of Customers, any Person who is beneficially interested or financially interested in the payments made or to be made by OCBC Bank.
   "Bên Chấp thuận" có nghĩa là bất kỳ cá nhân hay tổ chức nào có thông tin (bao gồm Thông tin Thuế) nhận được bởi Ngân hàng OCBC trong quá trình cung cấp Dịch vụ. Để tránh nghi ngờ, "Bên Chấp thuận" có thể bao gồm Khách hàng, Chủ sở hữu lớn và Người kiểm soát Khách hàng, bất cứ đối tượng nào được hưởng lợi về mặt lợi ích hoặc về mặt tài chính trong các giao dịch đã hoặc sẽ thanh toán bởi Ngân hàng OCBC.

   "Controlling Person" means any individual who exercises ultimate effective control over an entity or trust.
   "Người Kiểm soát" có nghĩa là bất kỳ cá nhân nào thực hiện quyền kiểm soát cuối cùng đối với một tổ chức hoặc quỹ tín thác.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.
   "Khách hàng" có nghĩa là bất kỳ Đối tượng nào có quan hệ với Ngân hàng OCBC liên quan đến Dịch vụ, cho dù là riêng hoặc chung với Đối tượng khác và, đối với công ty sẽ bao gồm người kế thừa của nó, đối với công ty hợp danh hoặc các tổ chức chưa hợp nhất khác gồm hai hay nhiều thành viên sẽ bao gồm người kế thừa, người chấp hành và người đại diện cá nhân của nó.

   "FATCA" means Section 1471 to 1474 of the United States Internal Revenue Code of 1986, as amended and any associated similar or analogous legislation, treaty, intergovernmental agreement, foreign financial institution agreement, regulation, instruction, or other official guidance of any Authority in any jurisdiction whether within or outside of Vietnam.
   "FATCA" có nghĩa là mục 1471 đến mục 1474 của Đạo Luật Thuế Vụ năm 1986 của Hoa Kỳ, các sửa đổi của nó và bất kỳ quy định liên quan hoặc tương tự pháp luật, điều ước quốc tế, thỏa thuận liên chính phủ, thỏa thuận tổ chức tài chính nước ngoài, quy định, hướng dẫn hoặc văn bản chính thức của bất kỳ Cơ quan Thẩm quyền nào ở bất kỳ thẩm quyền tài phán nào trong hoặc ngoài quốc gia Việt Nam.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited and shall include its successors and assigns.
   "Ngân hàng OCBC" nghĩa là Oversea-Chinese Banking Corporation Limited, bao gồm cả những người kế nhiệm và người nhận chuyển nhượng.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.
   "Đối tượng" có nghĩa là bất  kỳ cá nhân, tổ chức, công ty, công ty hợp danh, công ty liên doanh, quỹ tín thác, đầu tư bất động sản, công ty trách nhiệm hữu hạn, tổ chức chưa hợp nhất hoặc là những tổ chức khác.

   "Personal Information" in respect of a Customer and any Consenting Person, means: (i) where the Customer and any Consenting Person is an individual, his/her full name, date and place of birth, residential address, mailing address, contact information (including telephone number), and any taxpayer identification number, social security number, citizenship(s), residency(ies) and tax residency(ies) or (if applicable) such information as OCBC Bank may reasonably require regarding Customer and any Consenting Person; (ii) where the Customer and any Consenting Person is a corporate/entity, its date and place of incorporation or formation, registered address, address of place of business, tax identification number, tax status, tax residency, or (if applicable) such information as OCBC Bank may reasonably require regarding each of its Substantial owners and Controlling persons.
   "Thông tin Cá nhân" liên quan đến Khách hàng và bất kỳ Bên Chấp thuận nào có nghĩa là (i) đối với Khách hàng và Bên Chấp thuận là cá nhân, đó là tên đầy đủ, ngày sinh, nơi sinh, địa chỉ cư trú, địa chỉ gởi thư, thông tin liên hệ (bao gồm số điện thoại liên lạc), và bất kỳ mã số nhận diện thuế, số an sinh xã hội, quyền công dân, nơi cư trú và nơi chịu thuế hoặc (nếu có) những thông tin cần thiết khác mà Ngân hàng có lý do hợp lý để yêu cầu Khách hàng và Bên Chấp thuận; (ii) đối với với Khách hàng và Bên Chấp thuận là tổ chức, đó là ngày và nơi đăng ký kinh doanh hoặc thành lập, địa chỉ đăng ký, địa chỉ hoạt động và nơi hoạt động, mã số nhận diện thuế, tình trạng thuế, nơi chịu thuế hoặc (nếu có) những thông tin cần thiết khác mà Ngân hàng có lý do hợp lý để yêu cầu liên quan đến Chủ sở hữu lớn và Người Kiểm soát của Khách hàng.

   "Services", in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).
   "Dịch vụ", trong mối quan hệ với Khách hàng có nghĩa là, nhưng không chỉ giới hạn đến (i) việc mở, duy trì và đóng tài khoản ngân hàng; (ii) việc phát hành, duy trì, quản lý, và chấm dứt hợp đồng bảo hiểm; (iii) việc cung cấp bất kỳ dịch vụ ngân hàng hoặc dịch vụ tài chính và sản phẩm (bao gồm nhưng không chỉ giới hạn đến, dịch vụ ngân hàng bán lẽ, hạn mức tín dụng, dịch vụ thẻ tín dụng, cho vay, môi giới, dịch vụ ngân hàng đầu tư, dịch vụ tài chính doanh nghiệp, cung cấp vốn thứ cấp, dịch vụ thị trường vốn, dịch vụ sản phẩm ngân quỹ và giao dịch tài chính phái sinh); duy trì mối quan hệ giữa Ngân hàng OCBC và Khách hàng (bao gồm nhưng không chỉ giới hạn đến, các họat động tiếp thị và khuyến mãi các sản phẩm và dịch vụ tài chính và ngân hàng); và (v) bất kỳ hành động hay tài liệu nào mà Ngân hàng OCBC hổ trợ, triển khai bất kỳ khoản (i) đến (iv) nêu trên (bao gồm nhưng không chỉ giới hạn đến họat động nghiên cứu và phân tích).

   "Substantial owner" includes (1) with respect to a corporate or entity, certain persons that directly or indirectly own at least 10% of charter capital of the corporate; certain persons that directly or indirectly own more than 20% of charter capital of the corporate or entity contributing over 10% of charter capital of the corporate or entity, (2) with respect to a private company, the owners of the private company and (3) other certain persons who actually govern the corporate or entity.
   "Chủ sở hữu lớn" bao gồm (1) đối với công ty hoặc tổ chức, đó là những cá nhân trực tiếp hoặc gián tiếp sở hữu từ 10% trở lên vốn điều lệ của công ty hoặc tổ chức đó; những cá nhân trực tiếp hoặc gián tiếp sở hữu từ 20% trở lên vốn điều lệ của tổ chức góp trên 10% vốn điều lệ của công ty hoặc tổ chức đó, (2) đối với công ty tư nhân, đó chủ doanh nghiệp tư nhân và (3) cá nhân khác thực tế chi phối công ty hoặc tổ chức đó.

   "Tax Information" in respect of a Customer and any Consenting Person, means: (i) any documentation or information (and accompanying statements, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Consenting Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Consenting Person; (ii) Personal Information of the Customer and any Consenting Person; and (iii) Account Information.
   "Thông tin Thuế" liên quan đến Khách hàng và bất kỳ Bên Chấp thuận nào, có nghĩa là (i) bất kỳ chứng từ hoặc thông tin (và kèm theo bản sao kê, miễn trừ và chấp thuận theo yêu cầu của Ngân hàng OCBC vào từng thời điểm cụ thể) liên quan trực tiếp hoặc gián tiếp đến tình trạng thuế của Khách hàng và bất kỳ Bên Chấp thuận nào; (ii) Thông tin Cá nhân của Khách hàng và bất kỳ Bên Chấp thuận nào; và (iii) Thông tin Tài khoản.

2. Tax Withholding and Compliance Provisions
   Khấu trừ thuế và Những quy định Tuân thủ

   1. Provision of Information
      Cung cấp thông tin

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Consenting Person, in such form and within such time, as OCBC Bank may from time to time require.

         Khách hàng phải cung cấp cho Ngân hàng OCBC Thông tin Cá nhân của Khách hàng, và theo yêu cầu hợp lý của Ngân hàng OCBC, Thông tin Cá nhân của bất kỳ Bên Chấp thuận nào theo hình thức và vào thời gian mà Ngân hàng OCBC yêu cầu ở từng thời điểm cụ thể.

      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Consenting Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition.

         Khi có sự thay đổi hoặc bổ sung Thông tin Cá nhân của Khách hàng và (nếu có) bất kỳ Bên Chấp thuận nào, Khách hàng phải nhanh chóng thông báo cho Ngân hàng OCBC về sự thay đổi hoặc bổ sung đó (và trong bất cứ trường hợp nào cũng không trễ hơn 30 ngày kể từ ngày thay đổi hoặc bổ sung).

      3. The Customer must, and, where applicable, procure such other Consenting Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.

         Khách hàng phải, và, nếu có, thúc đẩy Bên Chấp thuận khác hoàn thành và ký những chứng từ và tiến hành các hành động theo yêu cầu hợp lý của Ngân hàng OCBC từng thời điểm cụ thể nhằm mục đích tuân thủ Luật và Quy định pháp luật áp dụng của Ngân hàng OCBC.

      4. The Customer agrees that OCBC Bank may directly require any Consenting Person to provide or confirm accuracy of their Personal Information without involving Customer if OCBC Bank reasonably considers it appropriate.

         Khách hàng đồng ý rằng Ngân hàng OCBC có thể trực tiếp yêu cầu bất kỳ Bên Chấp thuận cung cấp hoặc xác nhận tính chính xác về Thông tin Cá nhân của họ mà không cần thông qua Khách hàng nếu Ngân hàng OCBC có cơ sở hợp lý cho rằng việc này là đúng đắn.

   2. Disclosure of Information
      Công bố Thông tin

      1. he Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any other Consenting Person to any Authority in any jurisdiction for ensuring OCBC Bank's compliance with Applicable Laws and Regulations.

         Khách hàng đồng ý rằng Ngân hàng OCBC có thể công bố Thông tin Thuế của Khách hàng và Thông tin Thuế của bất kỳ Bên Chấp thuận nào cho bất kỳ Cơ quan Thẩm quyền nào trong bất kỳ thẩm quyền tài phán nào nhằm bảo đảm việc tuân thủ của Ngân hàng OCBC theo Luật và Quy định pháp luật áp dụng.

      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any other Consenting Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.

         Khách hàng từ bỏ, và, theo yêu cầu hợp lý của Ngân hàng OCBC, đồng ý thúc đẩy bất kỳ Bên Chấp thuận nào khác từ bỏ bất kỳ hạn chế nào, nếu không, sẽ cản trở khả năng của Ngân hàng OCBC khi công bố Thông tin Thuế nhằm mục đích tuân thủ Luật và Quy định pháp luật áp dụng, và cụ thể là, sẽ công bố Thông tin Thuế theo cách thức quy định tại khoản 2.2a.

      3. The Customer agrees that OCBC Bank may directly require any other Consenting Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

         Khách hàng đồng ý rằng Ngân hàng OCBC có thể trực tiếp yêu cầu bất kỳ Bên Chấp thuận nào đồng ý việc công bố thông tin theo quy định tại khoản 2.2a.và/ hoặc từ bỏ bất kỳ hạn chế nào về công bố thông tin, nếu Ngân hàng OCBC có cơ sở hợp lý cho rằng việc này là đúng đắn.

   3. Failure to Provide Information
      Không thể cung cấp thông tin

      The Customer agrees that:
      Khách hàng đồng ý rằng:

      1. where the Customer fails to comply with its obligations under 2.1 above; or

         khi Khách hàng không tuân thủ trách nhiệm của mình theo khoản 2.1 ở trên; hoặc

      2. where any of the other Consenting Persons fails to comply with OCBC Bank's requirements in 2.1 or 2.2; or

         khi bất kỳ Bên Chấp thuận nào không tuân thủ những yêu cầu của Ngân hàng OCBC nêu tại khoản 2.1 hoặc 2.2, hoặc

      3. where the Personal Information (regardless of whether such Personal Information is in relation to Customer or any other Consenting Person) is inaccurate, incomplete, or not promptly updated; or

         khi Thông tin Cá nhân (cho dù Thông tin Cá nhân này liên quan đến Khách hàng hoặc bất kỳ Bên Chấp thuận nào hay không) không chính xác, không hoàn chỉnh, không được cập nhật; hoặc

      4. for whatever reason OCBC Bank is prevented (under Vietnamese law or otherwise) from making disclosure of the Tax Information of Customer and/or any other Consenting Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

         vì bất cứ lý do gì Ngân hàng OCBC bị trở ngại (theo luật Việt Nam hoặc quy định khác) không thể công bố Thông tin Thuế của Khách hàng và/ hoặc (những) Bên Chấp thuận cho Cơ quan Thẩm quyền theo yêu cầu của Luật và Quy định pháp luật áp dụng,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:
      Ngân hàng OCBC có thể tiến hành một hoặc nhiều hành động sau đây vào bất cứ thời điểm nào mà Ngân hàng yêu cầu nhằm đảm bảo việc tuân thủ Luật và Quy định pháp luật áp dụng:

      1. deduct from or withhold part of any amounts payable by OCBC Bank to the Customer and/or any other Consenting Person;

         Khấu trừ hoặc giữ lại một phần từ bất kỳ khoản tiền nào mà Khách hàng và/ hoặc (những) Bên Chấp thuận phải trả tại Ngân hàng OCBC;

      2. refuse to provide new Services to the Customer;

         từ chối cung cấp Dịch vụ mới cho Khách hàng;

      3. terminate the Customer's account(s) with OCBC Bank;

         chấm dứt (những) tài khoản của Khách hàng với Ngân hàng OCBC;

      4. discontinue entirely or in part OCBC Bank's relationship with Customer; and

         ngừng toàn bộ hoặc một phần quan hệ của Ngân hàng OCBC với Khách hàng; và

      5. provide (whether before or after taking actions as described in items 3 and 4 of this section) the Tax Information relating to Customer and/or any of the Consenting Persons to such Authority in any jurisdiction.

         cung cấp (dù là trước hoặc sau khi tiến hành các hành động tại mục 3 và 4 của khoản này) Thông tin Thuế liên quan đến Khách hàng và/hoặc bất kỳ những Bên Chấp thuận nào cho Cơ quan Thầm quyền của bất kỳ thẩm quyền tài phán nào.

3. Customer Confirmations
   Xác nhận Khách hàng

   By using or accepting the Services, the Customer confirms and agrees that:
   Bằng việc sử dụng hoặc chấp nhận những Dịch vụ, Khách hàng xác nhận và đồng ý rằng:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this FATCA Policy, has received adequate explanation, and understands the implications of this FATCA Policy by which Customer irrevocably agrees to be bound;

      không ảnh hưởng đến các điều khoản và điều kiện áp dụng điều chỉnh mối quan hệ giữa Ngân hàng OCBC và Khách hàng, Khách hàng xác nhận rằng Khách hàng đã đọc Chính sách FATCA này, đã nhận được lời giải thích thỏa đáng, và hiểu được ý nghĩa của Chính sách FATCA này mà Khách hàng đồng ý một cách không thể hủy ngang về việc chịu sự ràng buộc theo đó;

   2. any agreement, waiver, confirmations given in, or to be given pursuant to, this FATCA Policy is irrevocable;

      bất kỳ thỏa thuận, miễn trừ, xác nhận được đưa ra, hoặc sẽ được đưa ra theo chính sách FATCA này là không thể hủy ngang;

   3. OCBC Bank is not liable for any costs or loss that the Customer (or any other Consenting Persons) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this FATCA Policy;

      Ngân hàng OCBC không chịu bất kỳ chi phí hoặc tổn thất nào mà Khách hàng (hoặc những Bên Chấp thuận) có thể xảy ra do Ngân hàng OCBC tiến hàng bất kỳ những hành động được phép hoặc thực thi bất kỳ quyền nào theo Chính sách FATCA;

   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this FATCA Policy;

      bất kỳ khoản rút tiền hoặc thanh toán nào được thực hiện bởi Ngân hàng OCBC theo bất kỳ Dịch vụ nào sẽ chịu sự điều chỉnh của Chính sách FATCA này;

   5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Consenting Person for the provision of his/her/its Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this FATCA Policy; the Customer must inform each Consenting Person of OCBC Bank's powers under this FATCA Policy;

      Khách hàng phải nhận được hoặc, tùy từng trường hợp, đã nhận được sự chấp thuận cần thiết từ mỗi Bên Chấp thuận về việc cung cấp Thông tin Thuế của họ cho Ngân hàng OCBC và Thông tin Thuế đó sẽ được công bố bởi Ngân hàng OCBC theo Chính sách FATCA này; Khách hàng phải thông báo cho mỗi Bên Chấp thuận về quyền của Ngân hàng OCBC theo Chính sách FATCA này;

   6. this FATCA Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between Customer and OCBC Bank.

      Chính sách FATCA này không ảnh hưởng, và bổ sung thêm cho, các quyền và quyền hạn của Ngân hàng OCBC theo các điều khoản và điều kiện điều chỉnh mối quan hệ giữa Khách hàng và Ngân hàng OCBC.

4. General
   Điều khoản chung

   1. In the event of any conflict or inconsistency between any of the contents of this FATCA Policy and other terms and conditions that govern the Customer’s relationship with OCBC Bank, this FATCA Policy shall prevail.
      Nếu có bất kỳ mâu thuẫn hoặc không thống nhất giữa những nội dung của Chính sách FATCA và những điều khoản và điều kiện điều chỉnh mối quan hệ giữa Khách hàng và Ngân hàng OCBC, Chính sách FATCA sẽ ưu tiên áp dụng.

   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this FATCA Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.

      Không phụ thuộc vào bất kỳ các điều khoản và điều kiện nào khác điều chỉnh mối quan hệ giữa Khách hàng và Ngân hàng OCBC (bao gồm nhưng không chỉ giới hạn đến những điều chỉnh hoặc sửa đổi đến các điều khoản và điều kiện đó), Ngân hàng OCBC có thể điều chỉnh, cập nhật, và sửa đổi Chính sách FATCA này đơn phương vào bất kỳ lúc nào theo yêu cầu của Ngân hàng để đảm bảo sự tuân thủ với Luật và Quy định pháp luật áp dụng.

   3. If all or any part of this FATCA Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this FATCA Policy in that jurisdiction.

      Nếu toàn bộ hoặc một phần của Chính sách FATCA này bất hợp pháp, vô hiệu, hoặc không thề thực thi được theo luật của bất kỳ một thẩm quyền tài phán nào, thì điều đó sẽ không ảnh hưởng đến tính hợp pháp, hiệu lực hoặc thực thi các điều khoản đó ở bất kỳ một thẩm quyền tài phán khác hoặc phần còn lại của Chính sách FATCA này tại thẩm quyền tài phán đó.

   4. It is the Customer's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this FATCA Policy. OCBC Bank do not provide tax or legal advice and are unable to advise Customers regarding the US federal income tax or other tax consequences to them under the Customer's particular circumstances.

      Việc yêu cầu các tư vấn độc lập về nghĩa vụ của mình theo Chính sách FATCA này cũng như những hệ quả theo đó từ các chuyên gia có đủ năng lực về thuế hoặc luật pháp là trách nhiệm của Khách hàng. Ngân hàng OCBC không cung cấp các tư vấn thuế hoặc luật pháp và cũng không tư vấn Khách hàng liên quan đến thuế thu nhập Liên bang Hoa Kỳ hoặc những nghĩa vụ thuế khác là hệ quả theo đó theo từng hoàn cảnh cụ thể của Khách hàng.

1. What is CRS?

   The Common Reporting Standard ("CRS") is a global standard for automatic exchange of financial account information. It was developed by the Organisation for Economic Cooperation and Development ("OECD"). It is also commonly known as Automatic Exchange of Information ("AEOI") or sometimes as global Foreign Account Tax Compliance Act ("FATCA").

   CRS is designed to mitigate offshore tax evasion. It is intended to provide participating jurisdictions transparency on the financial assets held offshore by their tax residents. CRS is a reporting regime and it does not impose a new taxation regime.

2. What is the impact of CRS?

   CRS requires financial institutions based in CRS participating jurisdictions to identify customers' tax residencies and report financial accounts held directly or indirectly by foreign tax residents to the local tax authorities in the jurisdiction where the financial institutions are based. The local tax authorities are expected to exchange this information with the relevant tax authorities in other participating jurisdictions.

   To facilitate the exchange of information, participating jurisdictions must enter into Competent Authority Agreements ("CAA") which may be bilateral or multilateral. The Singapore Government has enacted legislation to allow the implementation of CRS in Singapore and has entered into bilateral CAAs with jurisdictions to facilitate the exchange of information. The complete list of CAA can be found here. The first exchange of information shall take place by September 2018.

   OCBC is committed to being fully CRS compliant. With effect from 1 January 2017, we will require customers establishing financial accounts with our Bank to provide us information on their CRS statuses. We will also review our existing customer base to confirm CRS statuses of our customers and where necessary, we may have to contact our customers for further information and documentation.

3. Is CRS applicable to personal or business customers?

   CRS impacts both personal and business customers. Under Singapore CRS law, OCBC is required to:

   • Seek customers' cooperation to identify their tax residencies; and
   • Report financial accounts held directly or indirectly by customers who are foreign tax residents to the Singapore tax authority.

   Customers should be aware that details of their financial assets may be made available to the tax authorities of the jurisdiction they are tax residents of.

4. What is required from a customer?

   In order to establish your status under CRS, we will require you to complete a Self-Certification form to declare your CRS status and tax residency and provide additional information or documentation to substantiate the declaration. The self-certification form will be available for download at www.ocbc.com/business-banking/forms.html from 1 January 2017 onwards.

   Please note that you may receive more than one request for documentation if you have multiple relationships with different members of OCBC Group. It is important that you respond to all requests, even if you believe you have already supplied the requested information.

   In addition, the way in which financial institutions ("FIs") collect information from their customers in order to confirm their tax status under CRS may vary. This means that, in some instances, you may be asked for documentation from OCBC that differs from other banks.

5. How frequent is CRS information required?

   OCBC is required to monitor, on an ongoing basis, changes to customers' CRS information.

   If there is any change to the following types of account information that will impact your CRS status, you have to notify us within 30 calendar days from the date of change:

   1. Change in the entity's nature of business
   2. Change of business's country of domicile
   3. Change of business's country of incorporation
   4. Change of business's country of tax residency
   5. Change of business' Taxpayer Identification Number (TIN)
   6. Change of registered business address
   7. Change of registered mailing address
   8. Change of shareholding structure
   9. Change of controlling person/s
   10. Change of residential address/es of declared controlling person/s
   11. Change in tax residency of controlling person/s
   12. Change in TIN of controlling person/s

   Where we detect changes and/or updates to account information that may potentially impact your CRS status and/or tax residency, we may also contact you to obtain additional information or documentation to verify your CRS status with the Bank.

6. What will OCBC do if a customer does not provide the information required under CRS?

   OCBC is committed to being fully CRS compliant. Thus, OCBC will not open new accounts or offer additional products and services to customers who choose not to comply with OCBC's requests for documentation to establish status under CRS.

   OCBC may need to report information about customers who do not provide the required documentation to us to the Inland Revenue Authority of Singapore (IRAS).

7. What do I do if I am unsure of my business CRS status?

   Please consult your professional tax and/or legal advisors.

8. Will there be withholding of taxes under CRS?

   There will be no requirement for withholding of taxes under CRS.

9. What if I have multiple tax residencies?

   Information will be reported via IRAS to tax authorities in each jurisdiction which Singapore has signed CAA with.

10. What is my tax residency?

    Tax residency is defined by each jurisdiction's local tax laws and therefore the determination of tax residency for one jurisdiction may vary from that of another jurisdiction. It is possible that a person could be considered a tax resident in more than one jurisdiction.

    If this may be the case for you, please check whether both jurisdictions have in place an avoidance of double taxation treaty which may attribute your tax residency exclusively to one jurisdiction.

11. What are the consequences for incorrect self-certification?

    Each participating jurisdiction will put in place penalties for wilful false certifications.

12. Will other banks ask me to certify my tax residency?

    Yes, all financial institutions in CRS participating jurisdictions are required to identify the tax residency/ies of their customers or to-be customers.

13. I am a Singapore tax resident, which tax authority will my information be provided to?

    For accounts opened with OCBC by Singapore tax residents, OCBC is not required to report their information under CRS. In certain circumstances, OCBC is required to collect and report information pertaining to the controlling person/s of a Singapore tax resident company.

14. Will my account information in OCBC's possession be publicly available?

    No, your account information held by OCBC will not be made publicly available by us. If you are a tax resident of a jurisdiction other than Singapore, OCBC may be required to report your information to the IRAS. The IRAS will then disseminate your information to the tax authorities in the jurisdiction of which you are a resident. The participating jurisdictions with which the information is exchanged are expected to have a strong rule of law to ensure the confidentiality of information exchanged and to prevent any unauthorised use.

15. Will information of my trust be reportable, to whom and how?

    Information reporting under CRS in the context of a trust may vary, depending on whether the status of the trust is determined to be a financial institution or a passive non-financial entity under CRS. The settlor, trustee, protector, beneficiaries and/or any other natural person having control over the trust may be reported. Please refer to table 7 and table 8 of the OECD handbook for a snapshot of the financial activity to be reported in case of a trust.

16. If I am a resident of a non-CRS participating jurisdiction, will my information still be collected and report to the IRAS?

    Singapore has adopted the wider approach to CRS compliance and this wider approach requires Financial Institutions to collect information from all customers who are non-Singapore tax residents. However, OCBC will only report information of customers who are tax residents of a jurisdiction which has signed a bilateral CAA with Singapore.

17. What happens if I don't have a taxpayer identification number ("TIN")?

    There are only two exceptions in which TIN is not required to be collected or reported:

    1. TIN is not issued by the jurisdiction where you are tax resident in*; and
    2. Domestic law of the jurisdiction where you are resident in does not require the collection of such TIN.

    * TIN is considered not to be issued by a jurisdiction where (a) the jurisdiction does not issue a TIN to its residents, or (b) the jurisdiction has not issued a TIN to a particular individual or entity.

18. Will real estate property be reportable?

    Generally, only information pertaining to Financial Accounts is reportable. Under CRS, Financial Accounts do not include a non-debt, direct interest in real estate property. However, shares or units in a real estate investment trust would generally be considered Financial Accounts.

19. If I have a joint account, what is the amount to be reported for me?

    Each holder of the joint account is attributed the entire balance or value of the account as well as the entire amounts paid or credited to the joint account. Accordingly, the entire amount in the joint account will be reported for you.

20. What will be reported - the gross account balance or the net balance after deducting loans granted by OCBC?

    Gross account balance will be reported.

    You may download the Self-Certification forms to declare your tax status from 1 January 2017 onwards.

Disclaimer

Please note that OCBC is unable to provide any tax advice. In case of uncertainty with respect to your tax residency or CRS classification, please consult professional tax and/or legal advisor/s or refer to the OECD website and the Inland Revenue Authority of Singapore ("IRAS") website for more information.

Effective 1 July 2017

1. Definitions and Interpretation

   In this CRS Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation (and if applicable):

   1. the account number;
   2. account balance or value;
   3. currency denomination;
   4. gross receipts;
   5. ithdrawals and payments to or from the account;
   6. the total gross amount of interest paid or credited to the account;
   7. the total gross amount of interest, dividends and other income generated with respect to the assets held in the account, in each case paid or credited to the account or with respect to the account;
   8. ) the total gross proceeds from the sale or redemption of property paid or credited to the account; and
   9. the total gross amount paid or credited to the Customer with respect to the account, including the aggregate amount of any redemption payments made to the Customer.

   "Applicable Laws and Regulations" mean any of the following that currently or in the future apply to OCBC Bank: (i) local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules and codes of practice, including whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including, but not limited to, the CRS.

   ”Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Singapore.

   "Controlling Person" means any natural person who exercises control over a legal person or a legal arrangement, such as a corporation, partnership, trust or foundation. In the case of a trust, such term means the settlor, the trustees, the protector (if any), the beneficiaries or class of beneficiaries, and any other natural person exercising ultimate effective control over the trust, and in the case of a legal arrangement other than a trust, such term means persons in equivalent or similar positions. The term "Controlling Person" must be interpreted in a manner consistent with the Financial Action Task Force Recommendations. Where no natural person or persons is or are identified as exercising control of the entity through ownership interests, the controlling person of the entity is deemed to be the natural person who holds the position of senior managing official.

   "CRS" means the Standard for Automatic Exchange of Financial Account Information in Tax Matters, developed by the Organisation for Economic Co-operation and Development and any associated similar or analogous legislation, treaty, regulation, instruction or other official guidance of any Authority in any jurisdiction.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited and shall include its successors and assigns.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Controlling Person, means: (i) where the Customer and any Controlling Person is an individual, his/her full name, date and place of birth, residential address, mailing address, hold mail instruction or in-care-of address, contact information (including telephone number), and any taxpayer identification number (or functional equivalent), (if applicable) social security number, citizenship(s), standing instructions to transfer funds to an account, power of attorney or signatory authority granted to any person, residency(ies) and tax residency(ies) or (if applicable) such other information as OCBC Bank may reasonably require regarding such Customer and any Controlling Person; (ii) where the Customer and any Controlling Person is a corporate/entity, its full name, date and place of incorporation or formation, address, registered address, address of place of business, tax identification number (or functional equivalent), tax status, tax residency, financial statements, certification of its CRS status/classification, whether it is a passive NFE (as that term is defined by Applicable Laws and Regulations) with one or more Controlling Persons, or (if applicable) such other information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

   "Services", in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Tax Information" in respect of a Customer and any Controlling Person, means: (i) any documentation or information (and accompanying statements, forms, representations, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Controlling Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Controlling Person; (ii) Personal Information of the Customer and any Controlling Person; (iii) Account Information; and (iv) any other information received by OCBC Bank in relation to the Customer, including (but not limited to) information collected and maintained pursuant to AML/KYC procedures.

2. Tax Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Controlling Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Controlling Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition if the Customer has not done so already.
      3. The Customer must, and, where applicable, procure such Controlling Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Controlling Person to provide or confirm the accuracy of their Personal Information without involving the Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any Controlling Person to any Authority in any jurisdiction for the purpose of ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any Controlling Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any Controlling Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with its obligations under 2.1 or 2.2 above; or
      2. where any Controlling Person fails to comply with OCBC Bank's requirements set out in 2.1 or 2.2 above; or
      3. where the Personal Information (regardless of whether such Personal Information is in relation to the Customer or any Controlling Person) is inaccurate, incomplete, misleading or is not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under Singapore law or otherwise) from disclosing the Tax Information of the Customer and/or any Controlling Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. refuse to provide new Services to the Customer;
      2. terminate the Customer's account(s) with OCBC Bank;
      3. discontinue entirely or in part OCBC Bank's relationship with Customer;
      4. provide (whether before or after taking actions as described in items 2 and 3 of this section) the Tax Information relating to the Customer and/or any Controlling Person to an Authority in any jurisdiction.

3. Customer Confirmations

   By using or accepting the Services, the Customer confirms and agrees that:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this CRS Policy, has received adequate explanation, and understands the implications of this CRS Policy by which the Customer irrevocably agrees to be bound;
   2. any agreement, waiver, representation and/or confirmation given in, or to be given pursuant to, this CRS Policy is irrevocable;
   3. OCBC Bank is not liable for any costs or loss that the Customer (or any Controlling Person) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this CRS Policy;
   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this CRS Policy;
   5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Controlling Person for the provision of his or her Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this CRS Policy and the Customer must inform each Controlling Person of OCBC Bank's powers under this CRS Policy;
   6. this CRS Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between the Customer and OCBC Bank.

4. General

   1. In the event of any conflict or inconsistency between any of the contents of this CRS Policy and other terms and conditions that govern the Customer's relationship with OCBC Bank, this CRS Policy shall prevail.
   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this CRS Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
   3. If all or any part of this CRS Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this CRS Policy in that jurisdiction.
   4. It is the Customer's and each Controlling Person's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this CRS Policy. OCBC Bank do not provide tax or legal advice and are unable to advise Customers and/or Controlling Persons regarding the US federal income tax or other tax consequences that may be applicable to them in the Customer's (or the relevant Controlling Person's) particular circumstances.

Effective 1 January 2017

1. Definitions and Interpretation

   In this CRS Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation (and if applicable):

   1. the account number;
   2. account balance or value;
   3. currency denomination;
   4. gross receipts;
   5. withdrawals and payments to or from the account;
   6. the total gross amount of interest paid or credited to the account;
   7. the total gross amount of dividends paid or credited to the account;
   8. the total gross amount of other income generated with respect of the financial assets held in the account, in each case paid or credited to the account or with respect to the account;
   9. the total gross proceeds from the sale or redemption of financial assets paid or credited to the account; and
   10. the total gross amount paid or credited to the Customer with respect to the account, including the aggregate amount of any redemption payments made to the Customer.

   "Applicable Laws and Regulations" mean any of the following that currently or in the future apply to OCBC Bank: (i) local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules and codes of practice, whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including, but not limited to, the CRS.

   "Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Singapore.

   "Controlling Person" includes any natural person who exercises control over a legal person or a legal arrangement, such as a corporation, partnership, trust or foundation. In the case of a trust, such term includes the settlor, the trustees, the protector (if any), the beneficiaries or class of beneficiaries, and any other natural person exercising ultimate effective control over the trust, and in the case of a legal arrangement other than a trust, such term includes persons in equivalent or similar positions. The term "Controlling Person" may be interpreted in a manner consistent with the Financial Action Task Force Recommendations. Where no natural person or persons is or are identified as exercising control of the entity through ownership interests, the controlling person of the entity may be deemed to be the natural person who holds the position of senior managing official.

   "CRS" means the Standard for Automatic Exchange of Financial Account Information in Tax Matters, developed by the Organisation for Economic Co-operation and Development and any associated similar or analogous legislation, treaty, regulation, instruction or other official guidance of any Authority in any jurisdiction.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited and shall include its successors and assigns.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Controlling Person, means: (i) where the Customer and any Controlling Person is an individual, his/her full name, date and place of birth, residential address, mailing address, hold mail instruction or in-care-of address, contact information (including telephone number), and any taxpayer identification number (or functional equivalent), (if applicable) social security number, citizenship(s), standing instructions to transfer funds to an account, power of attorney or signatory authority granted to any person, residency(ies) and tax residency(ies) or (if applicable) such other information as OCBC Bank may reasonably require regarding such Customer and any Controlling Person; (ii) where the Customer and any Controlling Person is a corporate/entity, its full name, date and place of incorporation or formation, address, registered address, address of place of business, tax identification number (or functional equivalent), tax status, tax residency, financial statements, certification of its CRS status/classification, whether it is a passive NFE (as that term is defined by Applicable Laws and Regulations) with one or more Controlling Persons or (if applicable) such other information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

   "Services" in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Tax Information" in respect of a Customer and any Controlling Person, means: (i) any documentation or information (and accompanying statements, forms, representations, self-certification, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Controlling Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Controlling Person; (ii) Personal Information of the Customer and any Controlling Person; (iii) Account Information; and (iv) any other information received by OCBC Bank in relation to the Customer, including (but not limited to) information collected and maintained pursuant to AML/KYC procedures.

2. Tax Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, whether it is controlled by any Controlling Person, and where reasonably required by OCBC Bank, the Personal Information of any Controlling Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Controlling Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition if the Customer has not done so already.
      3. The Customer must, and, where applicable, procure any Controlling Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Controlling Person to provide or confirm the accuracy of their Personal Information without involving the Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any Controlling Person to any Authority in any jurisdiction for the purpose of ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any Controlling Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any Controlling Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with any of its obligations under 2.1 or 2.2 above; or
      2. where any Controlling Person fails to comply with any of OCBC Bank's requirements set out in 2.1 or 2.2 above; or
      3. where any Personal Information (regardless of whether such Personal Information is in relation to the Customer or any Controlling Person) is inaccurate, incomplete, misleading or is not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under Singapore law or otherwise) from disclosing the Tax Information of the Customer and/or any Controlling Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. refuse to provide or to continue to provide Services to the Customer;
      2. terminate the Customer's account(s) with OCBC Bank;
      3. discontinue entirely or in part OCBC Bank's relationship with the Customer;
      4. without notice to the Customer and/or any Controlling Person, provide (whether before or after taking actions as described in items 2 and 3 of this section) the Tax Information relating to the Customer and/or any Controlling Person to an Authority in any jurisdiction.

3. Customer Confirmations

   By using or accepting the Services, the Customer confirms and agrees that:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this CRS Policy, has received adequate explanation, and understands the implications of this CRS Policy by which the Customer irrevocably agrees to be bound;
   2. any agreement, waiver, representation and/or confirmation given in, or to be given pursuant to, this CRS Policy is irrevocable;
   3. OCBC Bank is not liable for any costs or loss that the Customer (or any Controlling Person) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this CRS Policy, unless such costs or loss is caused by the negligence of OCBC Bank;
   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this CRS Policy;
   5. the Customer must obtain or, as the case may be, has obtained the requisite consent from each Controlling Person for the provision of his or her Tax Information to OCBC Bank and the disclosure of such Tax Information by OCBC Bank under this CRS Policy and the Customer must inform each Controlling Person of OCBC Bank's powers under this CRS Policy;
   6. this CRS Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between the Customer and OCBC Bank from time to time.

4. General

   1. In the event of any conflict or inconsistency between any of the contents of this CRS Policy and other terms and conditions that govern the Customer's relationship with OCBC Bank, this CRS Policy shall prevail.
   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modifications of such terms and conditions), OCBC Bank may amend, update, and revise this CRS Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
   3. If all or any part of this CRS Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this CRS Policy in that jurisdiction.
   4. It is the Customer's and each Controlling Person's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this CRS Policy. OCBC Bank do not provide and are unable to advise Customers and/or Controlling Persons regarding any tax or legal matters, including without limitation the US federal income tax, or other tax consequences that may be applicable to them in the Customer's (or the relevant Controlling Person's) particular circumstances.

Effective 1 January 2017

1. Definitions and Interpretation

   In this CRS Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation (and if applicable):

   1. the account number;
   2. account balance or value;
   3. currency denomination;
   4. gross receipts;
   5. withdrawals and payments to or from the account;
   6. the total gross amount of interest paid or credited to the account;
   7. the total gross amount of interest, dividends and other income generated with respect to the assets held in the account, in each case paid or credited to the account or with respect to the account;
   8. the total gross proceeds from the sale or redemption of property paid or credited to the account; and
   9. the total gross amount paid or credited to the Customer with respect to the account, including the aggregate amount of any redemption payments made to the Customer.

   "Applicable Laws and Regulations" mean any of the following that currently or in the future apply to OCBC Bank: (i) local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules and codes of practice, including whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including, but not limited to, the CRS.

   "Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Singapore or Japan.

   "Controlling Person" means any natural person who exercises control over a legal person or a legal arrangement, such as a corporation, partnership, trust or foundation. In the case of a trust, such term means the settlor, the trustees, the protector (if any), the beneficiaries or class of beneficiaries, and any other natural person exercising ultimate effective control over the trust, and in the case of a legal arrangement other than a trust, such term means persons in equivalent or similar positions. The term "Controlling Person" must be interpreted in a manner consistent with the Financial Action Task Force Recommendations. Where no natural person or persons is or are identified as exercising control of the entity through ownership interests, the controlling person of the entity is deemed to be the natural person who holds the position of senior managing official.

   "CRS" means the Standard for Automatic Exchange of Financial Account Information in Tax Matters, developed by the Organisation for Economic Co-operation and Development and any associated similar or analogous legislation, treaty, regulation, instruction or other official guidance of any Authority in any jurisdiction.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited and shall include its successors and assigns.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Controlling Person, means: (i) where the Customer and any Controlling Person is an individual, his/her full name, date and place of birth, residential address, mailing address, hold mail instruction or in-care-of address, contact information (including telephone number), and any taxpayer identification number (or functional equivalent), (if applicable) social security number, citizenship(s), standing instructions to transfer funds to an account, power of attorney or signatory authority granted to any person, residency(ies) and tax residency(ies) or (if applicable) such other information as OCBC Bank may reasonably require regarding such Customer and any Controlling Person; (ii) where the Customer and any Controlling Person is a corporate/entity, its full name, date and place of incorporation or formation, address, registered address, address of place of business, tax identification number (or functional equivalent), tax status, tax residency, financial statements, certification of its CRS status/classification, whether it is a passive NFE (as that term is defined by Applicable Laws and Regulations) with one or more Controlling Persons, or (if applicable) such other information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

   "Services" in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Tax Information" in respect of a Customer and any Controlling Person, means: (i) any documentation or information (and accompanying statements, forms, representations, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Controlling Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Controlling Person; (ii) Personal Information of the Customer and any Controlling Person; (iii) Account Information; and (iv) any other information received by OCBC Bank in relation to the Customer, including (but not limited to) information collected and maintained pursuant to AML/KYC procedures.

2. Tax Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Controlling Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Controlling Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition if the Customer has not done so already.
      3. The Customer must, and, where applicable, procure such Controlling Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Controlling Person to provide or confirm the accuracy of their Personal Information without involving the Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any Controlling Person to any Authority in any jurisdiction for the purpose of ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any Controlling Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any Controlling Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with any of its obligations under 2.1 or 2.2 above; or
      2. where any Controlling Person fails to comply with any of OCBC Bank's requirements set out in 2.1 or 2.2 above; or
      3. where any Personal Information (regardless of whether such Personal Information is in relation to the Customer or any Controlling Person) is inaccurate, incomplete, misleading or is not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under Singapore law or Japanese law or otherwise) from disclosing the Tax Information of the Customer and/or any Controlling Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. refuse to provide new Services to the Customer;
      2. terminate the Customer's account(s) with OCBC Bank;
      3. discontinue entirely or in part OCBC Bank's relationship with the Customer;
      4. provide (whether before or after taking actions as described in items 2 and 3 of this section) the Tax Information relating to the Customer and/or any Controlling Person to an Authority in any jurisdiction.

3. Customer Confirmations

   By using or accepting the Services, the Customer confirms and agrees that:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this CRS Policy, has received adequate explanation, and understands the implications of this CRS Policy by which the Customer irrevocably agrees to be bound;
   2. any agreement, waiver, representation and/or confirmation given in, or to be given pursuant to, this CRS Policy is irrevocable;
   3. OCBC Bank is not liable for any costs or loss that the Customer (or any Controlling Person) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this CRS Policy;
   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this CRS Policy;
   5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Controlling Person for the provision of his or her Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this CRS Policy and the Customer must inform each Controlling Person of OCBC Bank's powers under this CRS Policy;
   6. this CRS Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between the Customer and OCBC Bank.

4. General

   1. In the event of any conflict or inconsistency between any of the contents of this CRS Policy and other terms and conditions that govern the Customer's relationship with OCBC Bank, this CRS Policy shall prevail.
   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this CRS Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
   3. If all or any part of this CRS Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this CRS Policy in that jurisdiction.
   4. It is the Customer's and each Controlling Person's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this CRS Policy. OCBC Bank do not provide tax or legal advice and are unable to advise Customers and/or Controlling Persons regarding the US federal income tax or other tax consequences that may be applicable to them in the Customer's (or the relevant Controlling Person's) particular circumstances.

Effective 1 January 2019

1. Definitions and Interpretation

   In this CRS Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation (and if applicable):

   1. the account number;
   2. account balance or value;
   3. currency denomination;
   4. gross receipts;
   5. withdrawals and payments to or from the account;
   6. the total gross amount of interest paid or credited to the account;
   7. the total gross amount of dividends paid or credited to the account;
   8. the total gross amount of other income generated with respect of the financial assets held in the account, in each case paid or credited to the account or with respect to the account;
   9. the total gross proceeds from the sale or redemption of financial assets paid or credited to the account; and
   10. the total gross amount paid or credited to the Customer with respect to the account, including the aggregate amount of any redemption payments made to the Customer.

   "Applicable Laws and Regulations" mean any of the following that currently or in the future apply to OCBC Bank: (i) local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules and codes of practice, whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including, but not limited to, the CRS.

   "Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Taiwan.

   "Controlling Person" includes any natural person who exercises control over a legal person or a legal arrangement, such as a corporation, partnership, trust or foundation. In the case of a trust, such term includes the settlor, the trustees, the protector (if any), the beneficiaries or class of beneficiaries, and any other natural person exercising ultimate effective control over the trust, and in the case of a legal arrangement other than a trust, such term includes persons in equivalent or similar positions. The term "Controlling Person" may be interpreted in a manner consistent with the Financial Action Task Force Recommendations. Where no natural person or persons is or are identified as exercising control of the entity through ownership interests, the controlling person of the entity may be deemed to be the natural person who holds the position of senior managing official.

   "CRS" means the Standard for Automatic Exchange of Financial Account Information in Tax Matters, developed by the Organisation for Economic Co-operation and Development and any associated similar or analogous legislation, treaty, regulation, instruction or other official guidance of any Authority in any jurisdiction.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited and shall include its successors and assigns.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Controlling Person, means: (i) where the Customer and any Controlling Person is an individual, his/her full name, date and place of birth, residential address, mailing address, hold mail instruction or in-care-of address, contact information (including telephone number), and any taxpayer identification number (or functional equivalent), (if applicable) social security number, citizenship(s), standing instructions to transfer funds to an account, power of attorney or signatory authority granted to any person, residency(ies) and tax residency(ies) or (if applicable) such other information as OCBC Bank may reasonably require regarding such Customer and any Controlling Person; (ii) where the Customer and any Controlling Person is a corporate/entity, its full name, date and place of incorporation or formation, address, registered address, address of place of business, tax identification number (or functional equivalent), tax status, tax residency, financial statements, certification of its CRS status/classification, whether it is a passive NFE (as that term is defined by Applicable Laws and Regulations) with one or more Controlling Persons or (if applicable) such other information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

   "Services" in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Tax Information" in respect of a Customer and any Controlling Person, means: (i) any documentation or information (and accompanying statements, forms, representations, self-certification, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Controlling Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Controlling Person; (ii) Personal Information of the Customer and any Controlling Person; (iii) Account Information; and (iv) any other information received by OCBC Bank in relation to the Customer, including (but not limited to) information collected and maintained pursuant to AML/KYC procedures.

2. Tax Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, whether it is controlled by any Controlling Person, and where reasonably required by OCBC Bank, the Personal Information of any Controlling Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Controlling Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition if the Customer has not done so already.
      3. The Customer must, and, where applicable, procure any Controlling Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Controlling Person to provide or confirm the accuracy of their Personal Information without involving the Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any Controlling Person to any Authority in any jurisdiction for the purpose of ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any Controlling Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any Controlling Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with any of its obligations under 2.1 or 2.2 above; or
      2. where any Controlling Person fails to comply with any of OCBC Bank's requirements set out in 2.1 or 2.2 above; or
      3. where any Personal Information (regardless of whether such Personal Information is in relation to the Customer or any Controlling Person) is inaccurate, incomplete, misleading or is not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under Taiwan law or otherwise) from disclosing the Tax Information of the Customer and/or any Controlling Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. refuse to provide or to continue to provide Services to the Customer;
      2. terminate the Customer's account(s) with OCBC Bank;
      3. discontinue entirely or in part OCBC Bank's relationship with the Customer;
      4. without notice to the Customer and/or any Controlling Person, provide (whether before or after taking actions as described in items 2 and 3 of this section) the Tax Information relating to the Customer and/or any Controlling Person to an Authority in any jurisdiction.

3. Customer Confirmations

   By using or accepting the Services, the Customer confirms and agrees that:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this CRS Policy, has received adequate explanation, and understands the implications of this CRS Policy by which the Customer irrevocably agrees to be bound;
   2. any agreement, waiver, representation and/or confirmation given in, or to be given pursuant to, this CRS Policy is irrevocable;
   3. OCBC Bank is not liable for any costs or loss that the Customer (or any Controlling Person) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this CRS Policy, unless such costs or loss is caused by the negligence of OCBC Bank;
   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this CRS Policy;
   5. the Customer must obtain or, as the case may be, has obtained the requisite consent from each Controlling Person for the provision of his or her Tax Information to OCBC Bank and the disclosure of such Tax Information by OCBC Bank under this CRS Policy and the Customer must inform each Controlling Person of OCBC Bank's powers under this CRS Policy;
   6. this CRS Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between the Customer and OCBC Bank from time to time.

4. General

   1. In the event of any conflict or inconsistency between any of the contents of this CRS Policy and other terms and conditions that govern the Customer's relationship with OCBC Bank, this CRS Policy shall prevail.
   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modifications of such terms and conditions), OCBC Bank may amend, update, and revise this CRS Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
   3. If all or any part of this CRS Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this CRS Policy in that jurisdiction.
   4. It is the Customer's and each Controlling Person's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this CRS Policy. OCBC Bank do not provide and are unable to advise Customers and/or Controlling Persons regarding any tax or legal matters, including without limitation the US federal income tax, or other tax consequences that may be applicable to them in the Customer's (or the relevant Controlling Person's) particular circumstances.

Effective 31 March 2023

1. Definitions and Interpretation

   In this CRS Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation (and if applicable):

   1. the account number;
   2. account balance or value;
   3. currency denomination;
   4. gross receipts;
   5. withdrawals and payments to or from the account;
   6. the total gross amount of interest paid or credited to the account;
   7. the total gross amount of interest, dividends and other income generated with respect to the assets held in the account, in each case paid or credited to the account or with respect to the account;
   8. the total gross proceeds from the sale or redemption of property paid or credited to the account; and
   9. the total gross amount paid or credited to the Customer with respect to the account, including the aggregate amount of any redemption payments made to the Customer.

   "Applicable Laws and Regulations" means any of the following that currently or in the future apply to OCBC Bank: (i) local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules and codes of practice, including whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including, but not limited to, the CRS.

   ”Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Thailand.

   "Controlling Person" means any natural person who exercises control over a legal person or a legal arrangement, such as a corporation, partnership, trust or foundation. In the case of a trust, such term means the settlor, the trustees, the protector (if any), the beneficiaries or class of beneficiaries, and any other natural person exercising ultimate effective control over the trust, and in the case of a legal arrangement other than a trust, such term means persons in equivalent or similar positions. The term "Controlling Person" must be interpreted in a manner consistent with the Financial Action Task Force Recommendations. Where no natural person or persons is or are identified as exercising control of the entity through ownership interests, the controlling person of the entity is deemed to be the natural person who holds the position of senior managing official.

   "CRS" means the Common Reporting Standard or the Standard for Automatic Exchange of Financial Account Information in Tax Matters, developed by the Organisation for Economic Co-operation and Development and any associated similar or analogous legislation, treaty, regulation, instruction or other official guidance of any Authority in any jurisdiction.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited and shall include its branches, successors and assigns.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Controlling Person, means: (i) where the Customer and any Controlling Person is an individual, his/her full name, date and place of birth, residential address, mailing address, hold mail instruction or in-care-of address, contact information (including telephone number), and any taxpayer identification number (or functional equivalent), (if applicable) social security number, citizenship(s), standing instructions to transfer funds to an account, power of attorney or signatory authority granted to any person, residency(ies) and tax residency(ies) or (if applicable) such other information as OCBC Bank may reasonably require regarding such Customer and any Controlling Person; (ii) where the Customer and any Controlling Person is a corporate/entity, its full name, date and place of incorporation or formation, address, registered address, address of place of business, tax identification number (or functional equivalent), tax status, tax residency, financial statements, certification of its CRS status/classification, whether it is a passive NFE (as that term is defined by Applicable Laws and Regulations) with one or more Controlling Persons, or (if applicable) such other information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

   "Services", in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Tax Information" in respect of a Customer and any Controlling Person, means: (i) any documentation or information (and accompanying statements, forms, representations, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Controlling Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Controlling Person; (ii) Personal Information of the Customer and any Controlling Person; (iii) Account Information; and (iv) any other information received by OCBC Bank in relation to the Customer, including (but not limited to) information collected and maintained pursuant to AML/KYC procedures.

2. Tax Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Controlling Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Controlling Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition if the Customer has not done so already.
      3. The Customer must, and, where applicable, procure such Controlling Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Controlling Person to provide or confirm the accuracy of their Personal Information without involving the Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any Controlling Person to any Authority in any jurisdiction for the purpose of ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any Controlling Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any Controlling Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with its obligations under 2.1 or 2.2 above; or
      2. where any Controlling Person fails to comply with OCBC Bank's requirements set out in 2.1 or 2.2 above; or
      3. where the Personal Information (regardless of whether such Personal Information is in relation to the Customer or any Controlling Person) is inaccurate, incomplete, misleading or is not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under Thai law or otherwise) from disclosing the Tax Information of the Customer and/or any Controlling Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. refuse to provide new Services to the Customer;
      2. terminate the Customer's account(s) with OCBC Bank;
      3. discontinue entirely or in part OCBC Bank's relationship with Customer;
      4. provide (whether before or after taking actions as described in items 2 and 3 of this section) the Tax Information relating to the Customer and/or any Controlling Person to an Authority in any jurisdiction.

3. Customer Confirmations

   By using or accepting the Services, the Customer confirms and agrees that:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this CRS Policy, has received adequate explanation, and understands the implications of this CRS Policy by which the Customer irrevocably agrees to be bound;
   2. any agreement, waiver, representation and/or confirmation given in, or to be given pursuant to, this CRS Policy is irrevocable;
   3. OCBC Bank is not liable for any costs or loss that the Customer (or any Controlling Person) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this CRS Policy;
   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this CRS Policy;
   5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Controlling Person for the provision of his or her Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this CRS Policy and the Customer must inform each Controlling Person of OCBC Bank's powers under this CRS Policy;
   6. this CRS Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between the Customer and OCBC Bank.

4. General

   1. In the event of any conflict or inconsistency between any of the contents of this CRS Policy and other terms and conditions that govern the Customer's relationship with OCBC Bank, this CRS Policy shall prevail.
   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this CRS Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
   3. If all or any part of this CRS Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this CRS Policy in that jurisdiction.
   4. It is the Customer's and each Controlling Person's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this CRS Policy. OCBC Bank do not provide tax or legal advice and are unable to advise Customers and/or Controlling Persons regarding the income tax or other tax consequences that may be applicable to them in the Customer's (or the relevant Controlling Person's) particular circumstances.

Disclosure of Financial Account Information Policy

1. Definitions and Interpretation

   In this DOFAI Policy, the following capitalised terms have the following meaning:

   "Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation the account number, account balance or value, and gross receipts, withdrawals and payments to or from the account.

   "Applicable Laws and Regulations" means obligations of OCBC Bank to comply with: (i) applicable local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules, codes of practice, whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including but not limited to CDOT, CRS, DAC and FATCA.

   "Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside the United Kingdom.

   "CDOT" means the International Tax Compliance (Crown Dependencies and Gibraltar Regulations 2014 (S1 2014/520) as amended from time to time and any related official instruction or guidance of any Authority.

   "CRS" means the Multilateral Competent Authority Agreement on the Automatic Exchange of Financial Account Information signed by the Government of the United Kingdom of Great Britain and Northern Ireland on 29th October 2014 in relation to agreements with the participating jurisdictions from time to time to improve international tax compliance based on the standard for automatic exchange of financial account information developed by the Organisation for Economic Co-Operation and Development and any implementing regulations and any official instruction or guidance of any Authority whether within or outside the United Kingdom.

   "Consenting Person" means any Person or entity whose information (including Tax Information) is received by OCBC Bank in connection with the provision of Services. For the avoidance of doubt, "Consenting Person" may include Customers, substantial owners and controlling persons of Customers, any Person who is beneficially interested or financially interested in the payments made or to be made by OCBC Bank.

   "Controlling Person" means any individual who exercises ultimate effective control over an entity or trust.

   "Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

   "DAC" means the Directive on Administration Cooperation in Tax Matters (Council Directive 2011/16/EU (as amended from time to time)) and any implementing regulations and any official instruction or guidance of any Authority of the United Kingdom or any other EU jurisdiction.

   "DOFAI" means disclosure of financial account information pursuant to, but not limited to, CDOT, CRS, DAC and FATCA.

   "FATCA" means Section 1471 to 1474 of the United States Internal Revenue Code of 1986, as amended from time to time and any associated similar or analogous legislation, treaty, intergovernmental agreement, foreign financial institution agreement, regulation, instruction, or other official guidance of any Authority in any jurisdiction whether within or outside the United Kingdom.

   "OCBC Bank" means Oversea-Chinese Banking Corporation Limited acting through its London branch and shall include its successors and assigns.

   "Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

   "Personal Information" in respect of a Customer and any Consenting Person, means: (i) where the Customer and any Consenting Person is an individual, his/her full name, date and place of birth, residential address, mailing address, contact information (including telephone number), and any taxpayer identification number, social security number, citizenship(s), residency(ies) and tax residency(ies) or (if applicable) such information as OCBC Bank may reasonably require regarding Customer and any Consenting Person; (ii) where the Customer and any Consenting Person is a corporate/entity, its date and place of incorporation or formation, registered address, address of place of business, tax identification number, tax status, tax residency or (if applicable) such information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

   "Services", in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

   "Substantial Owner" includes (1) with respect to a corporate or entity, certain persons that directly or indirectly own 25% or more of the corporation's stock (by vote or value), (2) with respect to a partnership, certain persons that directly or indirectly own 25% or more of the profits or capital interests in the partnership, and (3) with respect to a trust, certain persons treated as the owner of the trust or treated as holding directly or indirectly 25% or more of the beneficial interests of the trust.

   "Tax Information" in respect of a Customer and any Consenting Person, means: (i) any documentation or information (and accompanying statements, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Consenting Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Consenting Person; (ii) Personal Information of the Customer and any Consenting Person; and (iii) Account Information.

2. Tax Withholding and Compliance Provisions

   1. Provision of Information

      1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Consenting Person, in such form and within such time, as OCBC Bank may from time to time require.
      2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Consenting Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition.
      3. The Customer must, and, where applicable, procure such other Consenting Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
      4. The Customer agrees that OCBC Bank may directly require any Consenting Person to provide or confirm accuracy of their Personal Information without involving Customer if OCBC Bank reasonably considers it appropriate.

   2. Disclosure of Information

      1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any other Consenting Person to any Authority in any jurisdiction for ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
      2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any other Consenting Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
      3. The Customer agrees that OCBC Bank may directly require any other Consenting Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

   3. Failure to Provide Information

      The Customer agrees that:

      1. where the Customer fails to comply with its obligations under 2.1 above; or
      2. where any of the other Consenting Persons fails to comply with OCBC Bank's requirements in 2.1 or 2.2; or
      3. where the Personal Information (regardless of whether such Personal Information is in relation to Customer or any other Consenting Person) is inaccurate, incomplete, or not promptly updated; or
      4. for whatever reason OCBC Bank is prevented (under United Kingdom law or otherwise) from making disclosure of the Tax Information of Customer and/or any other Consenting Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

      OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

      1. deduct from or withhold part of any amounts payable by OCBC Bank to the Customer and/or any other Consenting Person;
      2. refuse to provide new Services to the Customer;
      3. terminate the Customer's account(s) with OCBC Bank;
      4. discontinue entirely or in part OCBC Bank's relationship with Customer;
      5. provide (whether before or after taking actions as described in items 3 and 4 of this section) the Tax Information relating to Customer and/or any of the Consenting Persons to such Authority in any jurisdiction.

3. Customer Confirmations

   By using or accepting the Services, the Customer confirms and agrees that:

   1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this DOFAI Policy, has received adequate explanation, and understands the implications of this DOFAI Policy by which Customer irrevocably agrees to be bound;
   2. any agreement, waiver, confirmations given in, or to be given pursuant to, this DOFAI Policy is irrevocable;
   3. OCBC Bank is not liable for any costs or loss that the Customer (or any other Consenting Persons) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this DOFAI Policy;
   4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this DOFIA Policy;
   5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Consenting Person for the provision of his/her/its Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this DOFAI Policy; the Customer must inform each Consenting Person of OCBC Bank's powers under this DOFAI Policy;
   6. this DOFAI Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between Customer and OCBC Bank.

4. General

   1. In the event of any conflict or inconsistency between any of the contents of this DOFAI Policy and other terms and conditions that govern the Customer's relationship with OCBC Bank, this DOFAI Policy shall prevail.
   2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this DOFAI Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
   3. If all or any part of this DOFAI Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this DOFAI Policy in that jurisdiction.
   4. It is the Customer's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this DOFAI Policy. OCBC Bank does not provide tax or legal advice and is unable to advise Customers regarding the US federal income tax or other tax consequences to them under the Customer's particular circumstances.