Appendix no. 1 to the Regulation of the Member of the Bank s Management Board no. 181/2015 of 27 March 2015

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1 Appendix no. 1 to the Regulation of the Member of the Bank s Management Board no. 181/2015 of 27 March 2015 CAPITAL GROUP Dom Maklerski BZ WBK (DM BZ WBK) is a separate organisational unit of Bank Zachodni WBK S.A. (the Bank ) conducting brokerage activities. Registered office: Rynek 9/11, Wrocław Mailing address: pl. Wolności 15, Poznań tel. (+48 61) fax (+48 61) Registered by the District Court in Wrocław - Fabryczna, 6th Business Section of the National Court Register under number KRS ; Management Board composition: Mateusz Morawiecki, Andrzej Burliga, Michael McCarthy, Piotr Partyga, Marcin Prell, Mirosław Skiba, Feliks Szyszkowiak, Juan de Porras Aguirre, Eamonn Crowley and Marco Antonio Silva Rojas; share capital of PLN 992,345,340 fully paid-up; Taxpayer Identification Number (NIP) COMMUNICATION METHODS The Client can communicate with DM BZ WBK in person (e.g. by visiting a Customer Service Point) or via electronic channels (telephone, Internet). The Client can place orders in person at a Customer Service Point or via electronic channels (telephone, Internet). LANGUAGES IN WHICH DM BZ WBK PROVIDES SERVICES 1. DM BZ WBK delivers services and provides information and materials to Customers in the Polish language, subject to point Selected services, information and documents are delivered to Customers in the English language, in the following cases: a) a relevant provision is included in the agreement with DM BZ WBK, b) DM BZ WBK considers positively the Customer s relevant request, c) no Polish language version of information or documents not authored by DM BZ WBK, d) English terms commonly used in financial instrument trading, e) information concerning orders executed for OTC instruments (Forex) provided to Customers via the OTC application, f) selected investment analyses, financial analyses and other general recommendations concerning transactions on financial instruments. In each case, DM BZ WBK reserves the right to deliver to the Customer (concurrently or at a later date) a Polish translation of entire or part of the above-mentioned information or documents, also as explanation of meaning of certain English terms. DM BZ WBK is not required to prepare or provide such translations. Unless otherwise specified, the English language version of the information provided shall be binding. LICENSE DM BZ WBK operates pursuant to a license issued by the Polish Financial Supervision Authority (PFSA). DM BZ WBK is subject to the supervision of PFSA. Polish Financial Supervision Authority Registered office: 1 Plac Powstańców Warszawy, Warsaw tel. (+48 22) , (+48 22) fax (+48 22) (95) knf@knf.gov.pl

2 SCOPE OF PROVIDED SERVICES DM BZ WBK provides the following services: 1) accepting and transferring orders to purchase or sell financial instruments for execution on the Polish market and other foreign markets, 2) executing orders to purchase or sell financial instruments for the account of a person placing an order, 3) acquiring and disposing of financial instruments for its own account, 4) offering financial instruments, 5) providing services under the executed firm-commitment underwriting and stand-by underwriting agreements and other similar agreements regarding financial instruments, 6) providing additional services concerning firm-commitment underwriting and stand-by underwriting agreements, 7) maintaining securities accounts to register financial instruments and cash accounts to serve securities accounts, 8) safekeeping and recording financial instruments and changes in their balances, 9) preparing investment analyses, financial analyses and other generic recommendations concerning transactions in financial instruments, 10) advising companies on the structure of equity assets, business strategy or other aspects related to the equity structure or business strategy, 11) providing advisory and other services related to mergers, demergers and acquisition of businesses; 12) providing investment advisory; 13) providing foreign-exchange services where these are connected with investment services, as provided for in sec. 1)- 5) and 12). CLIENT CATEGORIES DM BZ WBK introduces Client categorisation in order to ensure an adequate degree of protection to all Clients. The protection involves provision of specific information for the Clients, assessment of suitability and appropriateness of services for the Clients, applying specific policies with regard to the Clients assigned to each category and fulfilling other obligations, in accordance with Directive 2004/39/EC of the European Parliament and of the Council of 21 April 2004 on Markets in Financial Instruments amending Council Directives 85/611/EEC and 93/6/EEC and Directive 2000/12/EC of the European Parliament and of the Council and repealing Council Directive 93/22/EEC (hereinafter jointly referred to as MiFID ) and the Decree of the Minister of Finance of 20 November, 2009 on the procedures and conditions to be followed by investment firms, banks referred to in Art. 70 section 2 of the Trading in Financial Instruments Act, and custodian banks (hereinafter the Decree ).DM BZ WBK classifies its Clients into Retail and Professional, with a subcategory of Eligible Counterparties distinguished in the latter case. According to MiFID and the Decree, the highest degree of protection should be offered to Retail Clients and the lowest to Eligible Counterparties. In accordance with MiFID and the Decree, in the case of Professional Clients DM BZ WBK: - is not obliged to assess the adequacy and suitability of the services and products offered to Professional Clients, - is not obliged to draw up terms and conditions of brokerage services; the rights and responsibilities of both DM BZ WBK and the Client are set forth in the brokerage service agreement, - while executing orders placed by Professional Clients, DM BZ WBK is required to provide the Professional Client immediately after the order is executed only with the most significant information concerning the order, without informing the Client about all the details. Scope of protection and information Retail Clients Professional Eligible Clients Counterparties Suitability and appropriateness assessment - - Terms and conditions of brokerage services - - Detailed information on DM BZ WBK and services - - Information on existing conflicts of interest entailing a risk of damage to the Client s interest Information on financial instruments and risks inherent in investing in such instruments - Information on incentives - Information on where the issue prospectus is available during the public offering - - DM BZ WBK policy on order execution and acting in the Client s best interest - Confirmation of transaction execution provided after the transaction is executed - Each Client can at any time request in writing that it is treated as a client of a different category than originally assigned to it by DM BZ WBK. In particular, a Professional Client can request in writing to be treated as a Retail Client in the scope defined in its written request. DM BZ WBK will respond to such requests in accordance with the rules set out below. If a Page 2 of 19

3 Client opts for a category with a lower degree of protection, DM BZ WBK will accept the request, provided the Client meets the criteria set out in MiFID or in the Decree, concerning the number and value of executed transactions and the value of the Client s assets. Even when the Client meets the requirements, DM BZ WBK may refuse to downgrade the Client s categorisation. Such decision may be made by DM BZ WBK particularly to ensure optimum protection to the Client. DM BZ WBK shall accept each request of a Client opting for a category with a higher degree of protection versus the original category. INFORMATION ABOUT FINANCIAL INSTRUMENTS AND RISK RISK DM BZ WBK informs that risk is inherent in each investment decision. The degree of risk varies and depends on the kind of a financial instrument being the subject of investment. Taking any investment decision requires assessment of the future income as well as the related risk. DM BZ WBK informs that investing in financial instruments is associated with the risk of losing some or all invested funds, or even bearing additional costs. DM BZ WBK emphasizes that the value of financial instruments can be affected by many factors that are or may be independent from issuers and results of their performance. These include changing economic, legal, political and tax environment. The use of credit products or receivables limits is associated with financial leverage which, on the one hand may boost the investment profitability but, on the other hand, can also render bigger losses. Information on high rates of return on a particular investment or services provided in the past should not be deemed as guarantee of similar performance at present or in the future and should not be construed as anticipated or achievable results. Below you will find detailed information about particular types of financial instruments and the associated risks. You can also learn more about particular securities from the issue prospectuses, information memorandums and the issue and trading terms and conditions published by issuers. Information is also available from specialist info services and the websites of the Polish Financial Supervision Authority and the Warsaw Stock Exchange ( where you can find educational materials and guidelines for investors. When investing in financial instruments traded on foreign execution venues, the Client should additionally take into account the risks outlined below in the section on investments on foreign execution venues. The list of risks described herein is by no means exhaustive. DM BZ WBK emphasizes that prior to making any investment decision, the Client should thoroughly review the information about particular financial instruments and the associated risk types. EQUITIES Equities are equity financial instruments which represent a share of ownership in a company and its assets. Ownership share entitles the holder to a membership in a joint stock company and, at the same time, defines the scope of the shareholders rights and responsibilities. The rights of shareholders include property and corporate rights. The property rights include the right to a dividend and to a proportional stake of the corporate assets upon liquidation of the company. The corporate rights also encompass the right to attend the general meetings of shareholders, the right to receive information about the company s performance and the voting rights. Ownership of equity shares is not only associated with rights but also with particular risks. One of the key risks inherent in investments in equities is fluctuation of their value dictated by the market. When a company performs well, both its value and the stock price rise as well as investors may count on a dividend. However, in a free market economy based on the principle of unrestricted competition, other scenarios are also possible, such as difficulties with selling the products, no profits or even bankruptcy. While being aware of the opportunities of a successful business for unlimited stock value growth, investors should not forget about a possibility of a market price drop or, in extreme cases, a total loss of value of a company going bankrupt. The organized trading involves dematerialized shares. The key risk factors of investments in equities are associated with the financial standing of the issuers. The main categories of risk include: macroeconomic risk related to the capital market sensitivity to domestic and global macroeconomic factors, in particular including the economic growth rate, degree of economic imbalance (budget, trading and current turnover deficit), volume of consumer demand, size of investments, interest rates, the inflation rate and inflation trends, raw material prices and price trends and the geopolitical situation; industry risk shares of companies operating in particular industry sectors are exposed to specific types of risk, in particular including increased competition, drop in demand for products offered by the industry and technology changes; diversification of investments across various sectors may help to limit the industry risk; company specific risk all shares are exposed to risks related to the performance of particular companies, such as the quality of management, change of the business strategy or business model, changes in the corporate governance arrangements or the dividend policy; force majeure circumstances affecting the operations of the company, conflicts between the shareholders, and agency costs; diversification of investments may effectively reduce company specific risk. 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4 In addition to the risks described above, owning shares is subject to a number of general risks associated with investments in regulated instruments, such as liquidity risk or a risk of suspending or withdrawing an instrument from organised trading. Shares are characterized by a high-degree of price volatility, particularly in a short-term perspective. Assuming a longer term investment horizon effectively mitigates the risk related to share price fluctuation. ALLOTMENT CERTIFICATES (PDA) Allotment certificates are financial instruments of a nature similar to equities which entitle the holders to take up new share issues of public companies. The rights attached to shares are established at the time of allocation of shares and expire upon registration of shares with a depository for securities or as of an effective date of the Registry Court decision refusing to record a share capital increase in the register of entrepreneurs. The purpose of allotment certificates is to reduce the time between the allotment of newly issued shares and their first listing on a regulated market. Allotment certificates, however, do not offer their holders the same benefits as the actual shares in a company. Share issuers are not obliged to each time offer newly issued shares in the form of allotment certificates prior to their registration. Investments in allotment certificates are associated with the same risks as those described for equities. Additionally, Clients should be aware of the fact that if the court refuses to register a share issue, the issuer will be obliged to repay the holder of the allotment certificates the funds paid during the subscription according to the share issue price, regardless of the actual price paid for allotment certificates. Allotment certificates are characterised by considerable price volatility, often higher than in the case of shares themselves. Assuming that the court agrees to register a new share issue, extension of the investment horizon will reduce the degree of price fluctuation risk inherent in the allotment certificates to the level typical of shares of the issuer. SUBSCRIPTION RIGHTS Subscription rights apply to planned issues of new shares by a company. They constitute pre-emptive rights to the purchase of new shares by existing shareholders. Such rights are important due to the fact that if a new group of shareholders were to take up new stock, it would result in a so called capital dilution i.e. reduction of percentage holdings of the current shareholders versus the total value of the share capital. By exercising their subscription rights, the shareholders can retain their current level of holding in a joint stock company. In the case of shares admitted to trading on a regulated market, an important characteristic of the subscription rights is a possibility of being traded independently as an autonomous type of securities. This means that the current holders of the existing shares may resign from their right to take up new shares by selling such right on a regulated market. Furthermore, new shareholders who did not have interests in the company prior to the new share issue but wish to acquire newly issued shares may do it by purchasing the subscription rights. The General Shareholders Meeting, while adopting resolutions regarding a new share issue, may decide to exclude the subscription rights of existing shareholders. Investments in subscription rights are subject to the same risk factors as those characteristic of investments in equities. Additionally, the period of time when subscription rights are listed is usually very short (from a few days to a few weeks). If the subscription rights are not sold on the last trading day, the Client should thoroughly analyze the need to subscribe to a new issue of shares by exercising their rights. Thus, the Client should always remember that the subscription right is a financial instrument with a specified expiry date. If a holder of subscription rights fails to subscribe to a new share issue or sell the rights during the period of their listing on a regulated market, the holder will not receive any compensation upon the expiry of the rights. Subscription rights exhibit considerable price volatility, often much higher than in the case of shares of the same company. FUTURES CONTRACTS Futures are financial instruments which represent a kind of contract between two parties, a buyer who undertakes to purchase and the seller who undertakes to sell an underlying instrument at a predetermined future price and date (i.e. expiry date) or to make an equivalent cash settlement. The underlying instruments for futures contracts may include stock indexes, currencies, company shares, interest rates or bonds. Although the purchase or sale of a futures contract is equivalent to a commitment to accept or deliver a particular underlying instrument in the future, in the case of majority of futures contracts traded on the Warsaw Stock Exchange (WSE) the settlement is actually effected in cash. Futures contracts are traded in series. One series encompasses all contracts with the same delivery date. A buyer or seller of a futures contract is said to have an open position (a long or short position, respectively). The holder of a futures contract may keep it until the delivery date or withdraw from the market at any time (close the position). The buyer of a futures contract (holder of a long position) who wants to close the position must sell the contract with the same Page 4 of 19

5 delivery date. On the other hand, the seller of a futures contract (holder of a short position) who wants to close the position must buy the contract. The client buying/ selling a futures contract is required to place a margin as collateral for the settlement of the obligation towards the counterparty. The minimum margin value placed with an investment firm is determined by the competent clearing house (e.g. National Depository for Securities) responsible for clearing and guaranteeing all transactions executed on the market. In the majority of cases, margins are revaluated daily and daily settlements are made, resulting either in a margin call or a margin refund. Since the margin value accounts only for a part of the transaction value, futures contracts are said to have high financial leverage. In this way, high return can be obtained by engaging a relatively low amount of capital i.e. margin. Both profits and losses on futures market investments (in percentage terms) are a multiple of the equivalent profits and losses made on the spot market. The price of a contract is denominated, among others, in index points or polish zloty, and its value can be determined by multiplying the price by a relevant multiplier. Multiplier values differ depending on contract classes (underlying instruments of the futures contracts). Detailed information about different types of futures traded on the WSE can be found on the WSE website at Investments in the futures contracts are subject to all types of risk factors typical of the underlying instrument. Additionally, an inherent characteristic of investments in the futures contracts (listed on WSE) is the base risk i.e. a risk that the price of the derivative instrument may be different from the theoretical price of the underlying instrument. Because of a limited capital exposure at the time of opening a futures position (placing a margin instead of paying the entire value of the contract; use of financial leverage), investments in futures contracts are subject to a very high degree of risk. The Client should take into account not only the possibility of losing all the capital invested but also with a possibility of suffering a potential loss exceeding the value of the initial margin. Liquidity risk the liquidity of some of the futures contracts is significantly lower than the liquidity of the relevant underlying instruments (e.g. futures contracts on shares). The fluctuation in the price of contracts approximates the volatility of underlying instruments, subject to the differences resulting from the base risk. OPTIONS An option is a financial instrument in the form of a contract, under which the holder has a right to buy (call option) or sell (put option) an underlying instrument at a strike price fixed on the expiry date i.e. a right to exercise the option. The underlying instruments of options listed on the WSE are shares or WIG20 indexes. Obligations resulting from the options are cleared exclusively in the cash settlement form. Similarly to contracts, options are traded in series. One series encompasses all options of a given type with the same expiry date. In the case of options listed on the WSE, the last trading day for each series is the third Friday of the delivery month. There are two types of options: call options and put options. Both call options and put options can be purchased or sold by the Clients. A buyer or seller of an option is said to have an open position. The holder of an option may keep it until the option expiry date or withdraw from the market at any point in time (close the position). The buyer of an option who wants to close the position must sell the option with the same expiry date and the same strike price. On the other hand, the seller of an option who wants to close the position must buy it. Depending on the type of position held (purchase long position, sale short position), the profitability of particular positions differs significantly. The purchase of a call option and sale of a put option offer a possibility of making profit when the value of the underlying instrument goes up. The purchase of a call option and the sale of a put option offer a possibility of benefiting from a drop in the value of the underlying instrument. The maximum profit of a Client with a long position on options is unlimited, while the maximum profit of a Client investing in a short position is equivalent to a premium gained upon opening of the position. In the case of options listed on the WSE, the premium is equal to a transaction value multiplied by the applicable multiplier. The multiplier value depends on the type of the underlying instrument. Detailed information about different types of options traded on the WSE can be found on the WSE website at The Client opening a long position on options has to pay a premium. The Client opening a short position on options contributes a margin. The minimum margin value placed with an investment firm is determined by the competent clearing house (e.g. National Depository for Securities) responsible for the clearing and guaranteeing all transactions executed on the market. The major factors of significance in the case of options include volatility and time. The higher the volatility of an underlying instrument, the higher the options prices. In general, the shorter the time until option expiry, the lower the value of the option. Investments in options are associated with all risk factors typical of the underlying instrument of an option contract. Additionally, there is no universal method to determine the value of an option prior to its expiry date, therefore the Client should be aware of the fact that the market price is a function of the market expectations as to the future performance of the underlying instrument and that there are no hard factors involved. Page 5 of 19

6 The maximum loss of a Client taking up a long position on options (purchase of a call or put option) is equal to the invested capital, while in the case of a Client taking up a short position on options (sale of a call or put option), the loss may be higher than the value of the initial margin. The market risk resulting from the dependence on the underlying instrument is augmented by the financial leverage effect. The value of the initial investment which, in the case of an option purchase is the option price multiplied by a multiplier, and in the case of an option sale - the margin, is relatively low compared to the value of the underlying instrument. Thus, even minor fluctuations in the price of the underlying instrument have a proportionally bigger effect on the value of the option position. The risk of time lapse the price of an option is conditional on time to its expiry. The approaching expiry date may trigger a drop in the option value, even when the price of the underlying instrument remains unchanged. Hence, the impact of time is detrimental to the buyers of call options and put options. The risk of underlying instrument volatility trends in the volatility of the underlying instrument affect the value of the option. The higher the volatility of the underlying instrument, the higher the option value and vice versa. Liquidity risk the liquidity of options, in particular including the options on shares is very low. Quotations of options tend to vary considerably. SUBSCRIPTION WARRANTS Subscription warrants are very similar to options; however, the writer (holder of a short position) of subscription warrants may only be the issuer of the underlying instrument (company). Therefore, subscription warrants are actually a combination of an option with subscription rights. From the point of view of the warrant exercise time, two types of warrants are distinguished: European warrants (call or put) and American warrants (call or put). A European warrant may be exercised only on a date predefined by the issuer (referred to as the expiry date). An American warrant, on the other hand, may be exercised at any time selected by the Client prior to or on the expiry date. The risk factors associated with investments in subscription warrants are identical with the risk factors applicable to option contracts from the perspective of the holders of long positions. Liquidity risk the liquidity of subscription warrants is very low. Quotations of warrants tend to vary considerably. OPTION WARRANTS Option warrants are identical to subscription warrants in terms of the formula, with the only difference concerning the warrant writer. Unlike in the case of subscription warrants written exclusively by issuers of the underlying instruments, option warrants can be written by banks and other financial institutions e.g. brokerage houses for shares of other companies traded on an organized exchange market. BONDS Bonds are debt securities, i.e. the sale of bonds is equivalent to a owing a debt by the bond issuers to the bond holders. The debt is repaid as cash obligations at a strictly predefined time with interest, the calculation of which is defined in the bond issue terms. The value of the loan is the nominal value of bonds and the repayment date is the bonds redemption date. From the point of view of the interest on bonds, fixed and floating rate bonds are distinguished (coupon bonds), as well as zero coupon bonds. Credit risk the risk of insolvency of the issuer, guarantor, or underwriter of the security or the financial instrument means that the debtor may be unable to fulfil the repayment obligation. Interest rate risk change in the price of fixed interest rate debt securities in the event of a change in the market interest rate. When the interest rates go up, the price of the securities decreases, while when the interest rates go down it increases. In the case of T-bills and securities with a floating interest rate, the risk is low. The longer the time to maturity of fixed-rate instruments, the higher the risk. Risk of reinvestment a risk that the return rate on debt securities assumed by the Client will not be achieved due to reinvestment of coupon funds in lower interest-rate instruments. Bonds are characterized by limited price fluctuation. PARTICIPATION UNITS Participation units are sold by open-end investment funds. An open-end fund is obliged to sell participation units to anyone who makes a contribution to the fund. An open-end fund is also obliged to buy back participation units from any fund member who requests a repurchase. Such participation units are redeemed and cannot be sold again. Open-end fund participants are not allowed to transfer their participation units to any third parties. Page 6 of 19

7 Participation units are not subject to organised trade. The risk of selecting financial instruments fund managers may make wrong decisions when selecting the securities for the fund s investment portfolio; this risk is mitigated by diversification of the investment portfolio. The risk related to inability to precisely define the current investment parameters, including the risk associated with a particular fund. The risk of lack of access to the current investment portfolio composition of a particular fund. The risk associated with the concentration of assets or markets when investing in participation units. The risk related to special terms of transactions executed by the Fund (e.g. purchasing participation units of foreign funds). The fluctuation of the valuation of participation units differs depending on the fund type, however, usually is not higher than the volatility of individual shares. INVESTMENT CERTIFICATES Investment certificates are securities issued by closed-end investment funds. The value of investment certificates depends on the value of the fund s investment portfolio. Compared to open-end funds, closed-end investment funds have much broader investment opportunities and, consequently, much more flexibility in selecting a strategy and investments by the managers. A closed-end investment fund may be established for a specific period of time. The existence of a fund ends with liquidation proceedings involving redemption of the investment certificates and payment to the fund members of amounts of money equivalent to the number of investment certificates held by each member multiplied by the final settlement value of the certificates. Investment certificates are characterized by all risk factors associated with the participation units. Bearing in mind the wider investment opportunities, closed-end funds and their investment certificates may be subject to a higher risk compared to the open-end fund units. Closed-end investment funds are not required to revalue their assets as frequently as open-end investment funds. The market price of investment certificates may not reflect their actual value. Liquidity risk in the majority of cases the liquidity of investment certificates is low. The fluctuation of the valuation of investment certificates differs depending on the fund type, however, usually is not higher than the volatility of individual shares. STRUCTURED PRODUCTS Structured products are financial instruments, the price of which depends on the value of particular market indicators (e.g. prices of stocks or stock baskets, value of stock market indexes or currency exchange rates). Structured products are issued by financial institutions, most often by banks or brokerage houses. The issuer of a structured product makes a commitment towards the buyer (Client) to pay the buyer, on the maturity date, a final settlement amount calculated according to a specific formula. The formula defining the settlement terms facilitates tracking the current value of the instrument by the holders. Depending on the instrument architecture, two basic types of structured products can be distinguished: products with capital protection (very safe) offer the Client a possibility of participating in the profits generated by the underlying market index and, at the same time, give a 100 % guarantee of invested capital repayment (the Client will not suffer any loss), products without full capital protection more risky instruments; the Client participates to a higher extent both in the profits and losses generated by the underlying product (so the Client s return prospects are much better). Due to an almost unlimited spectrum of the possible investment strategies underlying structured products, the general risk profile cannot be determined. A common feature of structured products is the issuer s credit risk. Structured products based on a dealer quoting system are characterized by relatively low price volatility. On the other hand, structured products based on the broker quoting system have limited liquidity and, as such, may be subject to considerable price fluctuations in a short-term perspective. Extension of the investment horizon should effectively restrict the volatility level. ETFs (Exchange Traded Funds) ETFs are open-end investment funds traded on the stock exchange, which track the performance of an exchange index. Like other investment funds, ETFs are regulated by EU Directives and national regulations. An ETF may create and redeem units/shares called creation units on on-going (daily) basis. ETF creation units are traded on the stock exchange on the same terms as shares. WIG20 ETF creation units are securities Page 7 of 19

8 Investments in ETFs are subject to all risk factors applicable to an underlying instrument, whose rate of return is represented by a given investment fund. In the case of ETFs issued on the basis of equity markets indices, their capital risk (price volatility) is higher than the risk associated with bonds or other securities generating fixed income. Investments in ETFs are associated with counterparty risk resulting from the use of financial instruments concluded with a credit institution and its potential failure to perform its obligations resulting from such instruments. Furthermore, investors investing in ETFs run the risk of inaccurate representation of an underlying instrument s rate of return. INVESTMENTS IN FINANCIAL INSTRUMENTS TRADED ON FOREIGN MARKETS DM BZ WBK offers its Clients a broad range of investment opportunities on foreign execution venues. Foreign investments in particular financial instruments are subject to all risk factors applicable to the same financial instruments traded on the domestic markets. Additionally, a number of other risk factors should be taken into account: risk of the Polish zloty exchange rate fluctuation versus other currencies, risk of limited (delayed) access to information. The volatility of investments in foreign assets may be higher due to exposure not only to fluctuation of the financial instrument prices, but also to FX rates fluctuation. FX FUTURES The Forex market (foreign exchange market also known as the FX market or currency market), being decentralized (no physical location), leveraged and unregulated (OTC), is one of the biggest and most liquid ones in the world. FX futures involve the purchase of one currency against the sale of the other, yet the investor is not obliged to hold the traded currencies. The Client investing in FX futures trades at prices presented in the quotes provided by DM BZ WBK, determined on basis on the data from the interbank foreign exchange market. Transactions in FX futures are settled in real time by transferring the difference between the opening price and closing price. In addition, such transactions do not oblige any of the parties to deliver an underlying instrument, due to which such transactions are of unreal nature and are characterized by the use of financial leverage. Where the Client does not close the currency position on the same day when it is opened, such position will remain open overnight, which will result in charging SWAP rates related to the difference between the interest rate of the two currencies. Financial leverage mechanism allows the investor to open a position of a much greater nominal value than initial margin. Thus even a small price movement may lead to either above-average gains or above-average losses exceeding the value of initial margin. Risk of adverse changes in the market value of an underlying instrument a change in the price of one currency against the other may have an adverse effect on the investor, i.e. when closing the position, the investor may incur losses that may be additionally magnified by the use of financial leverage. Currency risk a change in the price of one currency against the other may have an adverse effect on the transaction value and the investor s financial situation. Where a transaction is settled in a currency other than the one needed to buy a given financial instrument, the investor is exposed to an additional risk associated with foreign exchange rates (e.g. in the pair of EUR/USD settled in PLN, in addition to the risk related to EUR/USD, the risk related to USD/PLN should also be taken into account). Liquidity risk related to limited trading in a given instrument, which - in turn results in a significant deviation of the closing price from a potential price under a full liquidity scenario. Liquidity risk is low in the case of major currency pairs, i.e. EUR/USD, GBP/USD, USD/JPY, USD/CHF etc., while it is much higher in the case of less popular currencies, e.g. PLN. Risk associated with the requirement to bring the margin level back up to the required level transactions secured by margin deposits involve great risk. The use of leverage allows the investor to open a position of a much greater value than the investor s assets, yet even a small change in the price of an underlying instrument may lead to sever losses, including the initial margin deposit. When the value of the inventor s margin drops below the required level, an investment firm may close all or selected positions to prevent further losses. CFDs (Contracts for Difference) CFDs are non-standardized, OTC, complex financial instruments (different CFDs providers are bound by different legal regulations concerning such instruments) that are used mainly to speculate on changes in foreign exchange rates, stock indices, prices of commodities, raw materials, equities, bonds and other assets. They traded on the OTC market. A CFD is a contract between two parties (seller and buyer), where one party is obliged to pay the other party the difference Page 8 of 19

9 between the opening price of the contract and its closing price. CFDs are leveraged derivative instruments, the price of which depends on the value of an underlying instrument. The Client should keep in mind that the main cost related to investing in CFDs is spread, i.e. the difference between the opening price of a position and its closing price, which, depending on market conditions, may widen. Financial leverage mechanism allows the investor to open a position of a much greater nominal value than initial margin. Thus even a small price movement may lead to either above-average gains or above-average losses exceeding the value of initial margin. Risk of adverse changes in the market value of an underlying instrument a change in the price of an underlying instrument may have an adverse effect on the investor, i.e. when closing the position, the investor may incur losses that may be additionally magnified by the use of financial leverage. Currency risk a change in the price of one currency against the other may have an adverse effect on the transaction value and the investor s financial situation. Where a transaction is settled in a currency other than the one needed to buy a given financial instrument, the investor is exposed to an additional risk associated with foreign exchange rates (e.g. in the pair of EUR/USD settled in PLN, in addition to the risk related to EUR/USD, the risk related to USD/PLN should also be taken into account). Liquidity risk related to the lack of liquidity in the market for a particular underlying instrument or trading halt of a particular underlying instrument. As a result, the position is closed at a much lower price than a potentially profitable deal under a full liquidity scenario, or it is not possible to execute the deal, which finally leads to losses or loss of potential profits. Risk associated with the requirement to bring the margin level back up to the required level transactions secured by margin deposits involve great risk. The use of leverage allows the investor to open a position of a much greater value than the investor s assets, yet even a small change in the price of an underlying instrument may lead to sever losses, including the initial margin deposit. When the value of the inventor s margin drops below the required level, an investment firm may close all or selected positions to prevent further losses. Due to the existing concentration on the forex market among entities in respect of instruments offered through trading platforms, the Clients are advised to consider greater diversification of their portfolios of financial instruments in which they invest. The Clients should pay special attention to the fact that the diversity of derivative instruments offered through trading platforms implies that even seemingly similar derivative instruments may differ significantly in terms of their specifications applicable on a given trading platform. Derivatives offered by certain investment firms through trading platforms on the over-the-counter market, in particular CFDs, may differ in the following parameters: margin level, lot size (nominal value), pip value, standard spread, maximum order value, quotes source, institutions acting as liquidity providers, fees paid by the Client. Investing in non-standardized derivative instruments on the OTC market, the Clients should refer to the detailed terms and conditions of investing in particular financial instruments offered through a given trading platform and apply them to their planned investment activities and strategies. DM BZ WBK carries out the Client s orders for Forex instruments by concluding transactions with the Client for its own account. ADVANCED ORDERS Advanced orders are special types of orders for futures contracts. All entered orders are fully automated and allow the Client to set investment strategies based on the combinations of new-type orders and ensure freedom of action without tracking the market continually. Take or Cut Orders - ToC Orders The main objective of this order is to secure the Client s position realization of profits from the investment, but also protection of the invested capital. A ToC order is a set of two related orders. The first one Take Order is an order with a price limit, by definition realizing profits from the investment. The second one - Cut Order - is a stop order, limiting losses in case of an unfortunate transaction. The orders are related to each other, so if one of them is executed or activated in the order book, Page 9 of 19

10 the other one will be automatically cancelled by a brokerage house. Moreover, if one of the orders is executed in part, the volume of other one will be automatically adjusted accordingly. Step Stop Limit / Loss Orders - SSL Orders This is a dynamic stop order, maximizing profits from the investment and limiting losses. The SSL order adapts itself to changes in the market prices in accordance with the parameters set by the investor. The buy order in the order book will move downwards (activation limit will be decreasing) and follow the falling stock price to maximize the investor s profits from the held short position. If the stock price rises unexpectedly, profit will be realized at the maximum possible level. The order works in a similar way to minimize losses. The SSL order works in a similar way for the sell order. Due to the SSL order of a Stop Loss type, the client s profits may increase while losses may be only smaller than envisaged by the client himself/herself. Speed Take or Cut Orders - SToC Orders This order, dedicated to day-traders, is a set of three different orders. Due to its structure, the SToC order allows the investor to open a position at any time during the trading session, realize profits and limit losses without turning on a computer again. The Speed order, being an integral part of the SToC order, combined with the Take and Cut orders, allows a brokerage house to create unique opportunities for investors. The Take and Cut orders work in the same way as the ToC order. The order is a tool helpful in planning investment strategies based on the technical analyses and allows the investor to successfully participate in dramatic price movements occurring often after publication of cyclical macroeconomic data, etc. The investor determines the price at which to open the position, the level of profit to be realized, and the maximum acceptable loss. All other matters are taken care of by a brokerage house which enters orders at an appropriate time. The client does not have to track the stock quotes. Quotations of financial instruments distributed by the WSE and monitored online by a brokerage house provide a basis for automatic modification of advanced orders. The factor that distinguishes advanced orders from basic ones is an inability to modify placed orders (the Client can cancel an order and place a new one with new parameters). Detailed information about advanced orders can be found on Advanced orders are subject to the same risk factors as those characteristic of investments in futures contracts. SHORT SELLING Short sale is a service allowing the investor to sell financial instruments without holding them in the account at the moment of placing a sale order. DM BZ WBK provides the short sale service pursuant the investment account agreement and the Client s oral instruction. Financial instruments available for short sale are specified by the WSE and additionally by DM BZ WBK. In order to place a short sale order, the client is obliged to deposit and maintain initial margin required by DM BZ WBK. The Client is obliged to cover the short position no later than the settlement date. If the Client fails to deliver the financial instruments sold short, DM BZ WBK will use the loan until the repurchase transaction is settled. Investments in short sale transactions are associated with all risk factors applicable to investments in equity shares and bonds. Extra costs resulting from securities lending incurred during the term of the loan also generate risk. REPORTING DM BZ WBK reports to its Clients on the performance of the provided services in accordance with the provisions of the brokerage agreement, in particular including notification of executed transactions. DM BZ WBK generates account statements showing the balance as at the end of each calendar year and delivers them free of charge to the Clients for whom it keeps investment accounts, using the agreed correspondence channel. GENERAL RULES OF ASSET PROTECTION DM BZ WBK is a member of the Investor Compensation Scheme operated by Krajowy Depozyt Papierów Wartościowych S.A. (National Depository for Securities). The Scheme guarantees protection of the assets registered on the investment accounts or deposited with DM BZ WBK and the repayment of funds up to the limit defined in the Act on Trading in Financial Instruments of 29 July, 2005 (Journal of Laws 2014, item 94 as amended thereafter) in the event of: 1) announcement of bankruptcy by DM BZ WBK, Page 10 of 19

11 2) legally binding dismissal of a motion for bankruptcy due to insufficiency of DM BZ WBK assets to cover the costs of the bankruptcy proceedings, 3) a decision of the Polish Financial Supervision Authority stating that due to poor financial condition, DM BZ WBK is unable to fulfil its obligations towards the investors at present and in the near future. Discontinuance of bankruptcy proceedings against a brokerage house does not preclude payment of compensation to investors. The Compensation Scheme guarantees repayment of the Client s funds after deducting the amounts due to DM BZ WBK from the Client in consideration of the services provided until the time when one of the circumstances described above has occurred, in the maximum amount of up to EUR 3,000 guaranteed in 100% under the compensation scheme plus 90% of the surplus amount of funds, however, not more than the total maximum limit of the guaranteed funds i.e. the PLN equivalent of EUR 22,000. PROTECTION OF THE CLIENT S FINANCIAL INSTRUMENTS AND FUNDS DM BZ WBK cooperates with other investment firms conducting investment activities and providing investment services abroad ( Foreign Brokers ) and with foreign custodian banks ( Foreign Custodian Banks ), who provide DM BZ WBK with services involving, respectively, execution of orders concerning financial instruments listed on foreign markets and safekeeping of such financial instruments. Such cooperation gives rise to a risk associated with the maintenance of business continuity by the aforementioned institutions (risk of bankruptcy or liquidation of the counterparties). DM BZ WBK shall be liable for the choice of a Foreign Broker and Foreign Custodian Bank, unless the broker or the custodian have been selected by the Client. DM BZ WBK informs that when selecting a Foreign Broker and Foreign Custodian Bank it acted with all due diligence to protect clients interests. DM BZ WBK may keep financial instruments of Retail Clients on an omnibus account maintained by DM BZ WBK or another investment firm. Such an arrangement does not give rise to a risk of inability to separate Clients financial instruments from the instruments of an investment firm or DM BZ WBK held on their own account, thanks to the register of rights to foreign financial instruments and a register of foreign financial instruments kept by DM BZ WBK. The omnibus account kept by a Foreign Broker is used exclusively to record financial instruments of DM BZ WBK Clients. In the event of a need to deposit the financial instruments of DM BZ WBK on an account maintained by a Foreign Broker, DM BZ WBK will open a separate account for such instruments. When binding regulations of a given country, in the territory of which the Client s financial instruments or cash are to be kept in custody, does not provide for safekeeping or registration of the Client s assets separately from the assets of DM BZ WBK, the Foreign Broker or Foreign Custodian Bank, DM BZ WBK will notify the Clients of this. Safekeeping of the Client s financial instruments or cash by such entity requires the Client s prior consent in writing. When special operations are performed on the Client s foreign financial instruments (e.g. split or reverse-split, etc.) and the identification of such operations on the day when they are performed is not possible, there is a potential risk of executing wrong transactions on the Client s financial instruments. In order to eliminate such a risk, DM BZ WBK shall immediately contact the Foreign Broker/ Foreign Custodian Bank. Any benefits and/or other rights vested in the financial instruments acquired by the Client are recorded on the Client s account immediately after clarifying the case with the Foreign Broker/ Foreign Custodian Bank. In the event of executing wrong transactions on the Client s financial instruments, referred to above, resulting in improper settlement of such transactions on the Client s account, DM BZ WBK, to the extent permitted by law, may introduce proper changes to the transaction accounting (cancel accounting records) in order to assure compliance with the actual condition. The terms of services provided by a Foreign Broker or a Foreign Custodian Bank, including keeping the accounts on which Clients financial instruments are recorded are subject or may be subject to the legal regulations of the country where the Foreign Broker or the Foreign Custodian Bank are based. This means that the rights of DM BZ WBK Clients may differ from the rights envisaged in the regulations in force in Poland. DM BZ WBK may establish a security on the Clients financial instruments in relation to the pursuit of claims or debt recovery proceedings instituted by third parties, in accordance with the provisions of the brokerage agreement and the applicable legal regulations in force. DM BZ WBK shall not use for this purpose financial instruments owned by retail Clients. If, however, such a situation were to occur, DM BZ WBK shall inform the Client, with a due notice period and in a hardcopy form, about the Client s obligations and scope of liability, the procedure to regain ownership of the financial instruments and the related risks. GENERAL PROCEDURE OF MANAGING CONFLICTS OF INTEREST Dom Maklerski BZ WBK, a separate organisational unit of Bank Zachodni WBK S.A. (the Bank ) conducting brokerage activities (DM BZ WBK),seeks to prevent conflicts of interest with their Clients by implementing appropriate organisational arrangements and internal regulations. DM BZ WBK acts with due care in order to ensure that if a conflict of interest arises, the Clients interests are not infringed. Page 11 of 19

12 DM BZ WBK and other members of the Group to which Bank belongs provide a broad range of services on the financial market to a highly diverse group of customers. In particular, with regard to the financial instruments which are the object of orders placed by the Clients, such entities could or can execute conflicting orders, act as market maker, offer financial instruments, purchase or sell such instruments for its own account or for the account of a third party or make transactions involving such instruments. BZWBK Group members can also provide services of managing financial instruments, as well as brokerage services or investment banking services to the issuers of financial instruments which are or might be in the future the object of the Clients investments. DM BZ WBK and its related parties can also act as firm-commitment or standby underwriters of financial instruments offered and participate in the merger or acquisition transactions and other transactions affecting issuers of the financial instruments which are of interest to the Clients, be the issuers of financial instruments or be associated with such issuers and, as a result, receive remuneration or fees or generate profits. 1. Underlying regulations 1) Introduction The rules of managing conflicts of interest apply to the potential conflicts of interest between the Client and DM BZ WBK, the Client and another Client, the Client and a Member of Bank Capital Group, as well as between the Client and an Employee of DM BZ WBK. 2) The following terms are defined below for the purpose of these rules: a) DM BZ WBK Client The Client of DM BZ WBK is a natural person, legal entity or an organisation without a legal status for which DM BZ WBK provides its services. b) The legal regulations which impose an obligation to manage conflicts of interest on DM BZ WBK: Trading in Financial Instruments Act; Regulation of the Minister of Finance of 20 November, 2009 regarding the procedure and terms of operations of the investment firms and banks referred to in Art. 70 section 2 of the Trading in Financial Instruments Act and custodian banks (hereinafter the Regulation ); Regulation of the Minister of Finance on defining the detailed technical and organisational terms for the investment firms and banks referred to in Art. 70 section 2 of the Trading in Financial Instruments Act and custodian banks and the terms of capital adequacy assessment by brokerage houses. c) Conflict of Interest Conflicts of interest are understood as circumstances known to DM BZ WBK which can lead to a conflict between the interest of DM BZ WBK, other entities from its Group and the obligation of DM BZ WBK to act in a reliable and professional way to the best interest of the DM BZ WBK Client, as well as all and any circumstances known to DM BZ WBK which can give rise to a conflict between the interests of a number of DM BZ WBK Clients. 3) Managing conflicts of interest The management of conflicts of interest by DM BZ WBK generally consists of three stages. The first stage assumes avoidance of situations in which a conflict of interest could potentially arise. The second stage involves organisational arrangements implemented by DM BZ WBK which prevent the occurrence of conflicts of interest in the institutionalised. If the actions undertaken under those two stages are not sufficient to eliminate the risk of a conflict of interest, the third stage involves disclosure of a specific risk of a conflict of interest to the Client and making the further steps conditional on the Client s decision. 2. General organisational arrangements and internal regulations used to prevent conflict of interest DM BZ WBK has implemented a number of regulations which underlie proactive management of conflicts of interest, in particular including: organisation regulations defining the scope and breakdown of rights and responsibilities between the particular departments and teams; regulations on the protection of confidential information and professional secrets; regulations of trading in financial instruments by persons associated with Bank or for their account. Special restrictions apply to transactions executed for the account of the persons taking part in the preparation of recommendations, financial analysis and the public offering. 1) Internal regulations rules which prevent manipulation or abuse of confidential information at the organisational level have been implemented. One of the specific organisational solutions applied is the creation of the so called Chinese walls i.e. information barriers which prevent uncontrolled flow of information between particular organisational units or employees of DM BZ WBK, as well as keeping the Watch List and the Restricted List. Page 12 of 19

13 Chinese walls separate selected organisational units of the Brokerage House, in accordance with the organisation regulations. In the case of a justified risk of emergence of a conflict of interest, Chinese walls are also established during the implementation of a specific project for the Client. 2) Recommendations and analyses DM BZ WBK has undertaken appropriate actions and implemented organisational measures in order to counteract, detect and manage conflicts of interest during the preparation of recommendations and analyses. The potential conflicts of interest concerning a specific recommendation or analysis which is made available publically or known to a wide range of people are disclosed in the recommendation or analysis or in an attached document. 3) Commissions (inducements) In consideration of the provided brokerage services, DM BZ WBK cannot accept or offer any inducements other than the standard fee or commission for a given service, unless such additional inducements are intended to ensure a higher quality of the service provided for the Client. Acceptance or offering of an inducement cannot preclude due and proper delivery of the service to the Client and the very fact of its acceptance or offering, as well as the type and value of the inducement must be disclosed to the Client prior to commencement of providing the service in an exhaustive, clear and understandable way. 4) Order execution policy (best execution principle) DM BZ WBK has implemented the Policy of Best Execution of the Clients Orders and Acting to the Best Interest of the Client which regulates the acceptance, transmission and execution of the orders placed by the Clients. 3. Special organisational arrangements 1) Other roles DM BZ WBK has adopted and implemented measures aimed at counteracting conflicts of interest and in the event of their emergence managing such conflicts, in relation to the fact that some employees of DM BZ WBK have other functions and roles outside DM BZ WBK. In particular, the employees of DM BZ WBK are obliged to disclose information about membership in the governing bodies of any public companies and to obtain consent for fulfilling such a role during their employment with DM BZ WBK. 2) Execution of the Clients orders When executing the orders placed by the Clients, a potential conflict of interest can arise in relation to the execution of DM BZ WBK s own transactions. DM BZ WBK has adopted and followed the rules which prevent execution of own transactions on privileged terms with regard to the Clients orders. Furthermore, DM BZ WBK has implemented procedures which preclude the use of information about the balances and turnovers in the Clients accounts and other information about the Clients when making decisions about the transactions executed by DM BZ WBK for its own account. The processes of executing the Clients orders and DM BZ WBK own orders are separated by means of Chinese walls. 4. Managing existing conflicts of interest If, despite conformance with all the above mentioned procedures during the provision of services for the Clients, a conflict of interest has occurred and, to the best knowledge of DM BZ WBK, the undertaken preventive measures are not sufficient to manage the conflict of interest, DM BZ WBK shall notify the Client about it and refrain from providing brokerage services for the Client until receipt of an express statement of the Client with a decision to either continue or terminate the agreement. 5. Additional information The general rules of managing conflicts of interest are reviewed at regular time intervals, at least once a year, and the significant changes are communicated to the Clients by publication on DM BZ WBK website or in any other way agreed with the Client, provided the binding legal regulations are met. At the request of the Client, detailed information about the rules currently in force can be delivered to the Client in a hardcopy format or made available via electronic channels. The information presented above shall be deemed to be the information referred to in 10 section 2 item 10 of the Regulation. INFORMATION ABOUT THE FEES, COMMISSIONS AND NON-MONETARY BENEFITS DM BZ WBK collects fees and charges in conformance with the brokerage agreement. In addition to the costs specified in the agreement, the Client may have to bear additional costs in consideration of using services outside the scope of the brokerage agreement. Page 13 of 19

14 Detailed information about the fees and charges associated with investments in participation units of open-ended investment funds is included in the prospectus, key information for investors of respective funds and the schedules of fees and charges currently in force. DM BZ WBK keeps securities accounts in the following currencies: Euro (EUR), U.S. dollar (USD), Swiss franc (CHF), Pound sterling (GBP). The employees of DM BZ WBK can participate in training organised and financed or co-financed by third parties (e.g. TFI, Asset Management, issuer). The employees of DM BZ WBK may take part in a competition for accepting and transferring orders in respect of participation units of investment funds and sub-funds managed by TFIs and a competition for execution of orders for particular financial instruments offered by DM BZ WBK. In consideration of the provided service of offering financial instruments and accepting subscriptions for financial instruments offered in a public and non-public offering, DM BZ WBK receives or may receive remuneration from third parties. When DM BZ WBK acts as the issue agent, the remuneration is paid by the issuer or the seller of financial instruments. When a prospectus is drawn up and published for the purpose of an issue, the information about costs associated with the offering, including the amount of remuneration payable to the issuer s/seller s advisors, is included in the prospectus. When DM BZ WBK participates in a consortium of distributors of financial instruments under a public offering procedure, the remuneration is received from an investment firm acting as the issue agent or takes a form of a brokerage commission on orders executed on the basis of subscriptions placed in relation to the offering. At the Client s request, DM BZ WBK provides the Client with information about charges, fees and non-financial benefits other than: 1. charges, fees and non-financial benefits received from the Client or a person acting on behalf of the Client or paid to the Client or a person acting on the Client s behalf, 2. charges and fees required for the purpose of providing a given brokerage service to the Client. DM BZ WBK is obliged to withhold and pay a flat-rate tax on the dividend and interest income due to the Client in consideration of the financial instruments held. DM BZ WBK is obliged to withhold and pay tax in the case of early termination of an account exempt from tax by the Client, prior to the expiry of the statutory deadline. THE POLICY OF BEST EXECUTION OF ORDERS PLACED BY THE CLIENTS OF DM BZ WBK DM BZ WBK shall accept and execute or transmit Clients orders in accordance with the brokerage agreement and this Best Execution of Orders Policy of DM BZ WBK (hereinafter referred to as the Policy ). The terms used in this Policy shall have a meaning assigned to them in Directive 2004/39/EC of the European Parliament and of the Council of 21 April, 2004 on markets in financial instruments amending Council Directives 85/611/EEC and 93/6/EEC and Directive 2000/12/EC of the European Parliament and of the Council and repealing Council Directive 93/22/EEC and the associated legal acts (hereinafter MiFID ) and in the brokerage agreement. 1. DM BZ WBK accepts and executes or transmits orders in accordance with the order execution terms specified by the Client. 2. DM BZ WBK accepts orders for execution in different systems. 3. DM BZ WBK executes orders immediately after their acceptance, in the sequence in which they are placed, unless the terms of the order execution, the nature of the order or the current market situation indicates otherwise or unless such a sequence would be contradictory to the Client s best interest. 4. DM BZ WBK executes orders in the execution venues (market) defined in the appendix hereto, in accordance with the brokerage agreement. 5. DM BZ WBK executes Clients orders by carrying out transactions for the Clients account, on a market where DM BZ WBK operates directly. 6. DM BZ WBK executes Clients orders on a market where DM BZ WBK does not operate directly by transmitting the order to a relevant investment firm, if the brokerage agreement so provides. DM BZ WBK informs its Clients about third-party investment firms whose services it uses. The investment firm to which the Client order is transmitted is selected by DM BZ WBK in accordance with the provisions of paragraphs accordingly, subject to a reservation that the best price criterion referred to in 11.2 applies only to orders with unspecified price. The lowest cost factor is taken into account by DM BZ WBK if the total cost incurred by the Client differs depending on the selected investment firm. 7. If detailed terms of the Client s order execution are not specified, DM BZ WBK shall execute the order according to the following procedure: 1) when the details required to execute an order are missing, DM BZ WBK shall reject the order, unless the missing data can be instantly supplemented by DM BZ WBK in an indisputable way, 2) when the number of financial instruments being the subject of the Client order has not been specified, DM BZ WBK shall reject the order; the number of financial instruments can be specified indirectly, Page 14 of 19

15 3) when the price has not been specified by a Retail Client, DM BZ WBK shall execute the order at the best current price quoted in an offer matching the Client order, unless due to its size or nature the order should be executed in accordance with item 4 below; 4) when the price has not been specified by a Professional Client, DM BZ WBK shall execute the order at a price as close as possible to the average volume-weighted market price available from the moment the Client order has been accepted, unless due to its size or nature the order should be executed in accordance with item 3 above; 5) when the market has not been specified, DM BZ WBK shall execute the order on a market on which the financial instrument is traded, subject to the provisions of below, unless the brokerage agreement provides otherwise or the circumstances of the order placement indicate otherwise. The Brokerage House may restrict the possibility of placing orders with incomplete execution terms to particular systems. 8. The Client may define additional terms which will affect the execution of the order. Acceptability of additional order execution terms defined by the Client may depend on the Client s fulfilment of specific requirements set by DM BZ WBK, in particular associated with the trading volume, order size or the value of assets held by the Client. Any specific instructions issued by the Client (additional terms exceeding the minimum information required to execute the order) may prevent DM BZ WBK from undertaking the measures which have been designed and implemented under this Policy to ensure best possible order execution terms, with regard to the aspects affected by such instructions. 9. DM BZ WBK can execute the Client s order by carrying out a transaction outside the regulated market or a Multilateral Trading Platform (MTF) if the Client has agreed to it and the terms of such order execution will be at least equal to those of other execution venues, subject to a reservation that the requirement shall not apply in a situation when the Client has specifically demanded execution of the order outside the regulated market or MTF. DM BZ WBK may refuse to execute such an order and the provisions of paragraphs shall apply accordingly. 10. DM BZ WBK can execute the Client s order by carrying out a transaction for its own account, provided that the terms of the order execution are at least equal to those of other execution venues, subject to a reservation that the requirement shall not apply in a situation when the Client has specifically demanded execution of the order on the account of DM BZ WBK. DM BZ WBK may refuse to execute such an order, and the provisions of paragraphs shall apply accordingly. 11. When the financial instrument which is the subject of the Client s order is traded on more than one market, DM BZ WBK executes orders on at least two of those markets and the Client has not specified expressly on which market the order should be executed, DM BZ WBK shall: 1) transmit the order for execution by an investment firm referred to in 6 above, where DM BZ WBK does not operate directly on any of those markets or where DM BZ WBK operates directly on at least one of such markets: 2) identify the market with the lowest price for purchase orders or the highest price for sales orders, 3) identify the market with the lowest order execution costs, 4) identify the market on which the order will be executed and settled in the shortest period of time, 5) identify the market with the highest likelihood of order execution, taking into account the trading volume of the market, the number of financial instruments covered by the order and the specific characteristics of the order, 6) identify the market with the highest likelihood of settlement of the transaction executed on the basis of the order, and subsequently, having conducted an analysis in accordance with the provisions of 12-14, DM BZ WBK shall issue a broker order for the specific market or transmit the Client order for execution by an investment firm, indicating the market on which the order is to be executed, where DM BZ WBK does not operate directly on such a market. 12. When deciding about the further course of action as described in 11 above, DM BZ WBK takes into account the need to transfer financial instruments between clearing houses in the case of financial instruments quoted on markets settled and cleared by different organisations and/or in different currencies, as well as the associated time and costs. 13. DM BZ WBK considers the aspects set out in items (criteria) one by one, in the above stated sequence, and selects the market offering the best price for the Client, with the lowest costs and the highest likelihood of the transaction execution and settlement in the shortest possible time (execution factors). If no single market meets all of the criteria, DM BZ WBK shall apply relative weights to the factors determining the choice of the market on which the order will be executed, as described in the appendix hereto. 14. The analysis of the factors is carried out once, directly prior to the Client order execution. It is based on all market information available to DM BZ WBK at the time of the analysis or on historical information depending on the factor type, the nature of the order and the circumstances of its placement and the results of the analysis are not subject to verification or modification at the time of the order execution. In particular, the analysis will not be repeated after the Client s subsequent modification of the order, unless execution of the order has not commenced yet. 15. DM BZ WBK may define new weights of the factors determining the choice of the market on which the order will be executed by assigning specific numeric values to the factors, differentiating them depending on the characteristics of the Client and the order, the properties of the financial instruments being the subject of the order and the markets to which the order can be transmitted. DM BZ WBK presents the current relative weights of particular factors on its website for the Clients who use the service. Other Clients are offered access to the information in the form envisaged in the brokerage agreement. 16. The provisions of paragraphs 5-7 and shall apply as appropriate to the transmission of orders for execution to the markets, when the orders are not executed by DM BZ WBK. 17. DM BZ WBK can merge Client s orders with the orders of other Clients or DM BZ WBK, unless such an operation is detrimental to the interest of any of the Clients. If the merger of orders could potentially damage the interest of one of the Clients but the likelihood of such an event is low, DM BZ WBK shall inform the Client about it. In other cases DM Page 15 of 19

16 BZ WBK shall not merge orders. The merged orders will be executed in the sequence in which they were placed, in particular including partial execution of an order consisting of a number of merged orders. The size or price has no impact on the order execution sequence. 18. This Policy cannot guarantee that in each case the Client order will be executed with the best effect for the Client measured in terms of the Client s individual expectations at the time of placing the order. 19. The purpose of this Policy is to inform the Clients how DM BZ WBK will be executing or transmitting their orders for execution. 20. DM BZ WBK will execute the Client s orders or transmit them for execution provided the Client has accepted the provisions of this Policy. The Client may confirm acceptance of the Policy in the same way as in the case of changes to the brokerage agreement or in another, explicit or implicit form, as long as the Client s will is expressed in an undisputable way. DM BZ WBK may request confirmation of the Client s consent on a durable medium or prepare such a confirmation, in particular, on the basis of the records stored in its systems. 21. At each request of the Client, DM BZ WBK shall provide information in a scope sufficient to assess whether the order has been executed or transmitted in conformance with the provisions of this Policy. 22. This Policy shall be reviewed by DM BZ WBK at least once a year in terms of its conformance with the applicable laws, in particular including the requirements of ensuring the best execution of Clients orders. 23. This Policy shall not apply to Clients who in their relations with DM BZ WBK act as eligible counterparties, unless they require to be treated by DM BZ WBK as professional or retail clients. 24. This Policy entered into force on 1 November, 2007 and, following the recent amendments, has been effective since 31 October APPENDIX TO THE ORDER EXECUTION POLICY OF DM BZ WBK DESCRIPTION OF RELATIVE WEIGHTS ASSIGNED TO PARTICULAR FACTORS HAVING IMPACT ON THE SELECTION OF THE EXECUTION VENUE WHERE AN ORDER WILL BE EXECUTED 1. When choosing an execution venue where a Client order will be executed, DM BZ WBK shall take into account the best price and the lowest costs to the Client, provided that the market offers a possibility of executing the whole order or a significant portion of the order. 2. If, despite the best price and the lowest cost, it is not possible to execute the whole order or its significant portion, DM BZ WBK shall transmit the order to a market on which such execution is possible, provided the cost and the price offered by that market do not differ significantly from those identified as the most beneficial to the Client. If this condition cannot be met either, DM BZ WBK transmits the order to a market with the best price and the lowest costs available in the case of retail client orders and in the case of professional clients, to a market with the highest likelihood of order execution. 3. If the highest price and the lowest costs are available on different markets, the deciding factor for DM BZ WBK will be the costs in the case of retail clients and the likelihood of order execution in the case of professional clients. 4. If the costs on different markets identified for retail clients and the likelihood of order execution identified for professional clients as market selection criteria do not differ significantly, the market is selected on the basis of the price, followed by the order execution likelihood or the costs, respectively and, then the order execution time and settlement likelihood. APPENDIX TO THE ORDER EXECUTION POLICY OF DM BZ WBK IDENTIFICATION OF THE MARKETS (EXECUTION VENUES) FOR PARTICULAR TYPES OF FINANCIAL INSTRUMENTS AND MARKETS ON WHICH DM BZ WBK OPERATES IN ORDER TO ENSURE THE BEST EXECUTION OF THE CLIENT ORDERS ON AN ONGOING BASIS DM BZ WBK executes orders of the Clients, for whom it keeps investment accounts, on the following markets: 1) WSE financial instruments quoted on this market; 2) BondSpot, Catalyst, Wiener Borse, NYSE, NYSE Euronext, Nasdaq, NasdaqOMX, Xetra, Borsa Italiana, SIX Swiss Exchange, London SE, CME Group, Intercontinental Exchange, Madrid Stock Exchange financial instruments quoted on those markets; 3) NewConnect alternative trading system financial instruments quoted on those markets, if the brokerage agreement so provides and if the order can be executed on this market. 4) DM BZ WBK financial instruments quoted on the OTC market and the markets referred to points 1-3 if the brokerage agreement so provides and the order can be executed on this market. DM BZ WBK executes orders of the Clients, for whom it keeps investment accounts, in given execution venues through the agency of the following institutions authorised to accept and transmit or execute orders related to foreign financial instruments: Page 16 of 19

17 Wiener Borse, NYSE, NYSE Euronext, Nasdaq, NasdaqOMX, Xetra, Borsa Italiana, SIX Swiss Exchange, London SE, Madrid Stock Exchange Bank of New York Mellon Capital Markets EMEA Limited, CME Group, Intercontinental Exchange- BANCO SANTANDER S.A. DM BZ WBK executes orders of the Clients, for whom it does not keep investment accounts, in the following execution venues (for financial instruments listed on a given market): NYSE, NASDAQ, Prague Stock Exchange, Bucharest Stock Exchange, Ljubljana Stock Exchange, Bulgaria Stock Exchange, NASDAQ OMX, Istanbul Stock Exchange, London Stock Exchange International, Vienna Stock Exchange, XETRA, Deutsche Boerse, SIX Swiss Exchange, Budapest Stock Exchange, RTS Stock Exchange, Zagreb Stock Exchange, Bratislava Stock Exchange, Athens Stock Exchange, London Stock Exchange, NYSE Euronext, Borsa Italiana, Oslo Stock Exchange, Madrid Stock Exchange, Tokyo Stock Exchange, Hong Kong Stock Exchange, Australian Securities Exchange, Canadian National Stock Exchange, if the brokerage agreement so provides and the order can be executed on this market. DM BZ WBK executes orders of the Clients, for whom it does not keep investment accounts, in given execution venues through the agency of the following institutions authorised to accept and transmit or execute orders related to foreign financial instruments: 1) NYSE, NASDAQ, Vienna Stock Exchange, XETRA, Deutsche Boerse, SIX Swiss Exchange, RTS Stock Exchange, Athens Stock Exchange, London Stock Exchange, London Stock Exchange International, NYSE Euronext, Borsa Italiana, Oslo Stock Exchange, Madrid Stock Exchange, Tokyo Stock Exchange, Australian Securities Exchange - Raiffeisen Centrobank AG, SANTANDER Investment Bolsa, S.V.,S.A., 2) Ljubljana Stock Exchange, Zagreb Stock Exchange, Bratislava Stock Exchange, Hong Kong Stock Exchange - Raiffeisen Centrobank AG, 3) Canadian National Stock Exchange, BM&F BOVESPA, BMV Bolsa Mexicana de Valores, Irish Stock Exchange - SANTANDER Investment Bolsa, S.V.,S.A., 4) Prague Stock Exchange - Raiffeisen Centrobank AG, J&T Banka, a.s. 5) Bucharest Stock Exchange - KBC Securities Romania 6) NASDAQ OMX - Raiffeisen Centrobank AG, AS SEB PANK, INSTINET Europe Limited, AS LHV Pank, SANTANDER Investment Bolsa, S.V.,S.A., 7) Istanbul Stock Exchange - Raiffeisen Centrobank AG, ECZACIBASI Securities, Ata Invest, IS Investment Securities, SANTANDER Investment Bolsa, S.V.,S.A., 8) Budapest Stock Exchange - Raiffeisen Centrobank AG, IPOPEMA SECURITIES S.A. DM BZ WBK transmits orders for execution to the following execution venues: 1) BZ WBK Towarzystwo Funduszy Inwestycyjnych S.A., 2) Legg Mason Towarzystwo Funduszy Inwestycyjnych S.A., 3) BPH Towarzystwo Funduszy Inwestycyjnych S.A., 4) ING Towarzystwo Funduszy Inwestycyjnych S.A., 5) Skarbiec Towarzystwo Funduszy Inwestycyjnych S.A., 6) MetLife Towarzystwo Funduszy Inwestycyjnych S.A., 7) Noble Funds Towarzystwo Funduszy Inwestycyjnych S.A., 8) Opera Towarzystwo Funduszy Inwestycyjnych S.A., 9) Investors Towarzystwo Funduszy Inwestycyjnych S.A., 10) Towarzystwo Funduszy Inwestycyjnych Allianz Polska S.A. 11) Aviva Investors Poland Towarzystwo Funduszy Inwestycyjnych S.A., 12) Franklin Templeton Investment Funds, 13) Union Investment Towarzystwo Funduszy Inwestycyjnych S.A. 14) Quercus Towarzystwo Funduszy Inwestycyjnych S.A with regard to participation units of mutual funds managed by the aforementioned Investment Fund Companies offered by DM BZ WBK, 15) issuers of financial instruments or entities appointed to execute orders involving the issuers instruments which are offered by DM BZ WBK. INFORMATION ABOUT TAX OBLIGATIONS OF THE CLIENTS Below find general information about the tax obligations of DM BZ WBK and its Clients. Due to the fact, that tax obligations depend on the individual situation of the Client and the domiciliation of the investment activities, we recommend consulting a tax advisor in order to find out detailed and Client specific information about the binding tax obligations. Page 17 of 19

18 The detailed rules of taxation of natural persons who are not permanent residents of the Republic of Poland and of corporate entities which are neither seated nor managed on the territory of the Republic of Poland are regulated by the applicable international agreements. This information, true and accurate as at the date of its preparation, is subject to changes at any time; hence the Client should always check the most recent regulations in force or consult a tax advisor. DM BZ WBK provides this information to the Clients in order to facilitate assessment of the tax implications of undertaken investment activities and shall not be held liable for the consequences of conformance or non-conformance herewith. DM BZ WBK shall periodically update the information and publish the updated version on its website at as well as make it available in a hardcopy format at Customer Service Points. The updated information about tax obligations is not delivered automatically to all the Clients who received the earlier versions of the information. The income tax payable by natural persons is regulated by the provisions of the Personal Income Tax Act of 26 July 1991 (Journal of Laws 2012, items 361 as amended later), hereinafter referred to as the Act. Income tax is charged on all types of income excluding special income categories listed in the Act, as well as income exempted from income tax pursuant to the Tax Ordinance (Art. 9 section 1 of the Act). Unless the Act stipulates otherwise, income from a particular source of revenues is defined as the surplus of revenues from this source over deductible costs of income generation during the fiscal year. If the costs are higher than the total revenues, the difference is defined as a loss from a revenue source (Art. 9 section 2 of the Act). Pursuant to Article 30b section 1 of the Act, the income tax rate on income earned from the sale of securities or financial derivatives, including gains on the exercise of rights attached to any of the above instruments, gains on sale of shares (stocks) or acquisition of shares (stocks) against non-cash contribution other than contributions of an enterprise or an organised part thereof, is 19% of the income earned. The provisions of Art. 30b section 1 of the Act do not apply if the sale of securities or derivative financial instruments and the exercise of the rights vested therein is done as part of the conducted business activity (Art. 30b section 4 of the Act). The income referred to in Art. 30b section 1 of the Act shall not be totalled with other income subject to taxation pursuant to the generally applicable rules (for instance, with income from the employment relationship) or income from the conducted business operations (Art. 30b section 5 in relation to Art. 27 and Art. 30c of the Act). Pursuant to Art. 39 section 3 of the Act, DM BZ WBK shall send to the Client (taxpayer) and the Tax Office managed by the Head of the tax Office in charge of taxation of foreigners individual information about the amount of the Client s income referred to in Art. 30b section 2 of the Act, according to a predefined format (PIT-8C form). The individual information about the amount of the Client s income (PIT-8C), DM BZ WBK shall include the following costs: 1. costs directly assigned to a specific transaction cost of buying securities intended for disposal; in the case of inherited securities sold after 1 January 2014, DM BZ WBK considers the cost incurred by the testator in order to buy the securities as a cost. 2. costs incurred by the Client (taxpayer) during the tax year in relation to the maintenance of the securities accounts kept by DM BZ WBK and necessary in order to generate the income, such as the fees and commissions, e.g. on the sales and purchase transactions, paid during the year and the costs of account opening or maintenance, costs of management fee in relation to accounts entrusted to management. DM BZ WBK is not a payer of personal income tax. At the end of the tax year, the taxpayer is obliged to disclose in a separate tax statement (Art. 45 section 1a item 1 of the Act) the income gained during the tax year from the sale of securities, including the income referred to in Art. 24 section 14 of the Act (income from the sale of borrowed securities), income from the sale of financial instruments and the exercise of rights vested therein as well as income from the sale of interests in companies or from taking up shares (stocks) in companies or interests (stocks) in cooperatives in return for non-cash contribution other than a business or its organised part and calculate the amount of income tax payable (Art.30b section 6 of the Act). Pursuant to the provisions of Art. 30a section 1 of the Act, income from: 1. interest and discount on securities; 2. dividend and other proceeds from the shares in the income of legal entities; 3. income from participation in capital funds; 4. interest or other proceeds from cash funds deposited on the taxpayer s account or other forms of savings, safekeeping or investing schemes offered by entities licensed pursuant to separate regulations excluding funds associated with the business activities; 5. income from a return or partial return on the individual pension account, in the meaning of regulations on the individual pension accounts and funds deposited on those accounts is subject to a 19% flat-rate tax, subject to the provisions of Art. 52a of the Act where exemptions from the income tax are specified. The flat-rate tax on the income from interest and discount on securities, dividend and other proceeds from the shares in the income of legal entities, income from participation in capital funds and interest or other proceeds from cash funds deposited on the taxpayer s account or other forms of savings, safekeeping or investing schemes offered by entities Page 18 of 19

19 licensed pursuant to separate regulations excluding funds associated with the business activities is charged from the total income, without deducting the costs of income generation (Art. 30a section 6 of the Act). The flat 19% tax is calculated, withheld and paid to the account of the appropriate tax office by the payer. The payer is the person/ entity who pays out the income from the sources mentioned in Art. 30a section 1 of the Act (sole traders, legal entities and organisations without a legal status responsible for paying out the income generated from the sources referred to in Art. 30a section 1 of the Act). The income from participation in capital funds is not adjusted by deducting the losses suffered as a result of participation in such funds or other losses on cash funds or property rights incurred during the tax year or in the previous years (Art. 30a section 5 of the Act). The loss incurred on a particular source of income during the tax year can be deducted from the income derived from the same source for a period of the next 5 tax years, subject to the reservation that the deducted amount cannot exceed 50% of the loss value in any of the years (Art. 9 section 3 of the Act). The provisions stipulating the flat-rate tax income tax payment, Art. 30a section 1 items 1 5 and of Art. 30b section 1 of the Act are applied taking into account the agreements on the avoidance of double taxation to which the Republic of Poland is a party. However, application of a tax rate resulting from the relevant agreement on the avoidance of double taxation or failure to withhold (or pay) tax pursuant to the provisions of such an agreement is possible, when the tax residence of the taxpayer can be documented by the original residence certificate and the sworn translation of such certificate provided by the taxpayer (Art. 30a section 2 and Art. 30b section 3 of the Act and Art. 26 sec. 1, sec. 1d and sec. 1g of the Corporate Income Tax Act). COMPLAINT HANDLING As a result of non-performance or improper or ineffective performance of obligations towards the Client, or other negligence of DM BZ WBK or any third party concerning provision of the brokerage services, the Client shall be entitled to file a complaint. The Client s complaint should be filed immediately after occurrence of an event giving rise to the complaint or immediately on learning of such event in order to ensure that the complain receives careful consideration. Complaints may be filed: in writing, addressed to DM BZ WBK (pl. Wolności 15, Poznań) or any of the Bank s organisational units in charge of customer service (addresses available on the website of DM BZ WBK at by mail, courier or in person; electronically, by to : reklamacje.dm@bzwbk.pl; by telephone, contacting one of DM BZ WBK employees at: , , or the infoline at: ; by fax to: ; in person, in the office of DM BZ WBK (pl. Wolności 15, Poznań) or any of the Bank s organisational units in charge of customer service (addresses available on the website of DM BZ WBK at by mail, courier or in person; If a complaint is submitted in a manner other than by mail or courier, DM BZ WBK will issue, at the Client s request, confirmation of the complaint receipt under the procedure agreed with the Client. The Client can submit a complaint through a proxy holder. Complaints are evaluated as soon as possible, no later than within 30 days from the complaint filing date. In the case of justified circumstances preventing issue of a response to the complaint within 30 days, the response time can be prolonged to maximum 90 days, after prior explanation of the delay reasons to the Client and specification of the facts and circumstances which need to be additionally investigated. The Client may seek assistance of Municipal or District Consumer Spokesperson. In the event of any dispute arising in connection with the complaint, the Client can apply to ordinary courts for resolution of the dispute, while submission of the dispute to arbitration requires a separate agreement between DM BZ WBK and the Client. DM BZ WBK may refuse to enter in such agreement. Information valid as at 27 March The information presented in this document is periodically updated and made publically available by DM BZ WBK on its website at and in the Customer Service Points. Unless required by the applicable legal regulations, DM BZ WBK shall not deliver the new version of the information to all Clients who received the previous version of the document earlier. Page 19 of 19