

1) HELLENIC AMERICAN SECURITIES S.A. , in compliance to the decisions of the Hellenic Capital Market Commission (articles 16 & 18 of decision 2/452/1.11.2007), separates client credit balances from the Company’s own funds in both Euros and foreign currencies. Client credit balances are maintained daily in special client accounts at the following bank institutions: ALPHA BANK, PIRAEUS BANK, EUROBANK ERGASIAS, NATIONAL BANK OF GREECE and CHANIA BANK.
2) In the field of application of Law 4370/2016, “Deposit Guarantee Schemes (implementation of Directive 2014/49/EU), Deposit and Investment Guarantee Fund and other provisions” credit institutions are required to implement the necessary systems in line with the operational and technical specifications set by the Deposit Guarantee Fund (TEKE), including the Electronic Centralized Customer Information System (ECCIS), which ensures the identification and monitoring of accounts per depositor. The Electronic Centralized Customer Information System (ECCIS) has the technical specifications, rules and procedures for timely and secure submission of information by credit institutions to ensure deposits are covered under the Deposit Guarantee Fund.
To meet this obligation and therefore enable proper management and production of files of the ECCIS II with the specifications set by TEKE, we inform you that our Company provides credit constitutions with files containing all necessary information (detailed customer data, exact credit balances per beneficiary) and according to ECCIS II specifications so these institutions to consolidate the data to accurately determine the actual beneficiaries and their precise balances held at each bank.
3) The Company informs the client that under Article 10 paragraph 2 of Law 4370/2016, the guarantee covers the actual beneficiary of the credit balance, provided that this person is designated or can be designated before the date on which a deposit becomes unavailable. In the case of multiple actual beneficiaries, for the application of the limit set in Article 9, paragraph 1 of Law 4370/2016-i.e, one hundred thousand (100,000) euros as the maximum compensation limit for covered deposits of the same depositor in a credit institution covered by the Hellenic Deposit and Investment Guarantee Fund (TEKE) – the share corresponding to each beneficiary is taken into account based on the legal or contractual arrangements governing the management of the deposited amounts.
4) The Company allocates client’s credit balances in client accounts with Greek credit institutions on a pro rata basis so that the clients daily credit balance is distributed in the same proportion as it relates to the total client credit balances across all client accounts of the investment firm (pro rata method), meaning that it is indifferent at which bank the client deposits their funds
5) The computerized system used by our Company to separate client assets from the Company’s own assets provides all the necessary support and information and has been fully adapted to meet the specifications required for the analysis of clients credit balances and their verification with the corresponding client accounts maintained at credit institutions, in accordance with the specifications announced by the Hellenic Deposit and Investment Guarantee Fund (TEKE).