Definition of Politically Exposed Person:

Legislative Decree No. 231/2007 (as amended by Legislative Decree No. 90/2017) provides that "Politically Exposed Person" means: "the natural person who occupies or has ceased to occupy for less than one year important public offices, as well as his or her family members and those known to have close ties with the aforementioned person," and means:

1. Individuals who occupy or have occupied important public offices are defined as: a) heads of state, heads of government, ministers and deputy ministers or undersecretaries, regional presidents, regional aldermen, mayors of provincial capitals or metropolitan cities, mayors of municipalities with a population of not less than 15000 inhabitants; b) Members of Parliament and regional councillors; c) members of the central governing bodies of political parties; d) judges of the Constitutional Court, magistrates of the Court of Cassation or the Court of Auditors, councillors of State and other members of the Council of Administrative Justice for the Sicilian Region; e) members of the governing bodies of central banks and independent authorities; (f) ambassadors, chargés d'affaires and high-ranking officers of the armed forces; (g) members of the administrative, management or control bodies of enterprises controlled, even indirectly, by the Italian State or a foreign state or in which the Regions, provincial capitals and metropolitan cities and municipalities with a total population of not less than 15.000 inhabitants; h) general managers of ASLs and hospital companies, university hospital companies and other entities of the national health service; i) directors, deputy directors and members of the management body or person performing equivalent functions in international organizations.None of the above specified categories includes middle or lower level officials. Categories (a) to (i) include, where applicable, positions at the European and international level
2. Family members are defined as (a) spouse; (b) children and their spouses; (c) persons bound in civil union or cohabitation or similar institutions to the person referred to in No. 1. or his or her children; (d) parents.
3. For the purpose of identifying persons with whom the persons referred to in No. 1 are known to have close ties, reference shall be made to: a) natural persons related to the person referred to in No. 1. by joint beneficial ownership of legal entities or other close business relationship; b) natural persons who only formally hold total control of an entity known to be established, in fact, in the interest and for the benefit of a person referred to in No.
4. Without prejudice to the risk-dependent application of enhanced customer due diligence requirements, when a person has ceased to hold important public office for a period of at least one year, the addressees of this decree are not required to consider that person as politically exposed.

For the identification of the Effective Owner.:

Definition under Legislative Decree No. 231/2007 (as amended by Legislative Decree No. 90/2017) : the natural person or persons, other than the client, in whose interest or interests the continuing relationship is ultimately established, the professional service is rendered or the transaction is performed. Specifically, in the case of corporations:

1. a) An indication of direct ownership is the ownership of an interest of more than 25 percent of the client's capital held by a natural person.b) An indication of indirect ownership is the ownership of an interest of more than 25 percent of the client's capital held through subsidiaries, trusts or intermediaries.
2. In cases where the examination of the ownership structure does not allow for the unambiguous identification of the natural person or persons to whom direct or indirect ownership of the entity is attributable, the beneficial owner coincides with the natural person or persons who have:a) control of a majority of the votes that can be exercised in the ordinary meeting. b) control of sufficient votes to exercise a dominant influence in the ordinary meeting, c) special contractual ties that allow for the exercise of a dominant influence.
3.  Where the application of the criteria set forth in the preceding paragraphs does not enable the unambiguous identification of one or more beneficial owners, the beneficial owner shall coincide with the natural person or persons holding powers of administration or management of the company. Trustees of express trusts, regulated pursuant to Act No. 364 of October 16, 1989, shall obtain and hold adequate, accurate and current information on the beneficial ownership of the trust, by which is meant information on the identity of the settlor, the trustee or trustees, the guardian or other person on behalf of the trustee, if any, the beneficiaries or class of beneficiaries and other natural persons exercising control over the trust and any other natural person ultimately exercising control over the property vested in the trust through direct or indirect ownership or through other means. Trustees of express trusts shall retain such information for a period of not less than five years after the termination of their status as trustees and shall make it readily available to the authorities.