The present policy is based on the current legislation and the Inducements Handling Policy of National Bank of Greece S.A.

While providing investment and ancillary services and activities for the account of its clients UBB AD - member of the NBG Group of Companies (hereinafter “The Bank”) acts in a fair, honest, transparent and professional manner, in accordance with the best interest of its clients. For this purpose the Bank:

 

The Bank defines as inducement the direct or indirect fee, commission, discount or non-monetary benefit, paid or provided to or by the client or a person acting on behalf of the client in relation to the provision of investment and / or ancillary services over the predefined pricing levels of its fees and commissions.

 

 This policy applies to all cases of provision of investment and / or ancillary services to clients, including financial analysis and investment research, in line with the Bank’s commitment to professional conduct while providing these services to clients.

This policy may be applied along with the other internal Bank’s acts, handling the same or similar subject matter, such as the Code of Conduct, other rules and procedures concerning the conflict of interest and trust ensuring. In case of discrepancy between current internal acts, the one stipulating stronger restrictions will apply. 

 

The Senior Management of the Bank is responsible for setting written rules and for the existence of adequate controls and appropriate procedures for the provision of investment and / or ancillary services, as well as for the supervision of the policy implementation.

Authorized Divisions are responsible for the development of this policy, whilst its approval is the responsibility of the Bank’s competent bodies, following approval by NBG Group Compliance Division.

 The present policy, as well as the costs and commissions of the Bank’s services are revised on an annual basis or more often when appropriate, in order to include the changes into the current regulatory and statutory requirements, as well as the changes on Bank’s strategic objectives or on the internal (operational – business) and external (market) environment.

The directors, executive staff members and the Personnel of the Bank are responsible for the sound implementation of this policy. They should immediately report to the competent bodies of the Bank any case of non-implementation, brought to their attention or reported to them by clients, and they should act jointly with the authorized divisions in accordance with the preset remedial actions stated in this policy.

The Bank establishes Compliance mechanisms and integrated Internal Audit systems.

 

The Bank does not pay, provide or receive fees, commissions or non-monetary benefits, including inducements within the meaning of the present policy, except:

 

- the existence, nature and amount of the fee, commission or non-monetary benefit, or, where the amount cannot be ascertained, the method of calculating that amount, are clearly disclosed to the client, in a manner that is comprehensive, accurate and understandable, prior to the provision of the relevant investment or ancillary service. This condition is satisfied when the Bank provides the substantial contract conditions concerning the fee, commission or non-monetary benefit, when the Bank provides detailed information concerning the fee, commission or non-monetary benefit upon client’s request and when providing of the information is honestly and fairly and in accordance with the client’s interest.   

- the payment of the fee, commission, or the provision of the non-monetary benefit is designed to enhance the quality of the relevant service to the client and does not impair compliance with the Bank’s duty to act in the best interests of the client.

 

The above restrictions are imposed with a view to identifying areas and types of conflict of interest between clients, or between clients and third parties, including the Bank’s personnel which arise or may arise upon payment of unregulated benefits for provision of investment and / or ancillary services, as well as for the purposes of prevention of such actions to or by its clients.  

The members of management / Bank, executive staff members, Bank’s personnel or other persons working under contract for the Bank may not negotiate, receive or pay fees on its behalf or by other way in breach of the above rules.  

The Bank maintains mechanisms and relevant procedures of monitoring and reconciling the inducements in accordance with provided investment and / or ancillary services.

The Bank provides its clients with additional detailed information on implementation of this policy upon receipt of a written request by the client.