Competent Persons

The Board of Directors (the “BOD”) is required to take all necessary measures for the implementation and pursuance of this Code in the respective branch as soon as practically possible. That means in particular through schooling and providing guidance to the local team. Furthermore, the BOD is required to exercise effective control in regards to ethics and compliance in all areas of the branch operations.

On the level of the whole Firm the following persons are competent to deal with ethical issues:

The Firm Global Legal Counsel is responsible for regular updates of this Code as well as for its implementation. BOD may at any time seek the advice of the FIRM Global Legal Counsel and, at the same time, are required to report to him or her on a regular basis. The Firm Anti-bribery and Corruption Officer (the “ABC Officer”) is competent to deal with all issues concerning bribery, corruption and insider trading. The Firm Ethics and Compliance Officer (the “EC Officer”) is responsible for dealing with any other issues.