Regulatory self-classification

PSS activities and services prevents money laundering, corruption and global financial terrorism.

FIA (Financial Institutions Act)
Private scandinatvian sparkasse, limited is a fully owned subsidiary of Scandinavia AS, which is a financial group according to Financial Institutions Act 2015.

MIFIS (Markets in financial instruments directive)
Private scandinavian sparkasse, limited is an “Eligible Counterparty” according to Art. 24(1) [2004/39/EC] and is an “Investment firm” according to Art. 4(1) [2004/39/EC].[These classifications will still apply under MIFID 2 (2014/65/EU)]

EMIR – Bilateral Margining Requirements
Private scandinavian sparkasse, limited is subjected to variation margin requirements from March 2017 according to Art. 11 EMIR (EU/648/2012); Delegated Regulation (EU2016/2251).

FinfraG (Finazmarktinfrastrukturgesetz)
Private Scandinavian sparkasse, Limited would be considered a financial counterparty+(FC+) according to FinfraG art 99 and is fully compliant with EMIR [EU/648/2012].

FATCA (Foreign Account Tax Compliance Act) / CRS (common reporting standard)
Private scandinavian sparkasse limited qualifies as a Reporting Norway financial institution for purposes of both U.S. FATCA (Foreign Account Tax Compaliance Act) and the Common Reporting Standard (CRS).

Business Strategy and Competitive Environment

The financial services’ sector has changed over last few decades and today there is an abundance of available data online. Artificial intelligence and the user’s role in Web navigation have allowed digitalization to become established as a fundamental right to society. Understanding such changes, PSS is consistently
transforming the way it operates; developing itself as a customer-centered organization.
We are consistently improving our competitive advantages in online trading and expanding our expertise in key sectors by uniting our traditional working practices
with new technology.

Digitalization
PSS intends to fundamentally reinvent financial trading services by digitalizing all services availed in the traditional financial service industry, as well as adapting and developing new Fintech products and services. PSS combines technology and design to ensure secure and efficient business processes for our customers using the following three tenets:

• Easy and efficient account processes
• Quick and accurate order settlements
• Wealth of online trading tools

Customer Centric
A strategic realignment which focus on digitalization for customers starts from an understanding that customers are what makes the day-to-day business reality in a B2C relationship (online or offline). Guided by PSS’ code of conduct, we prioritize building long-term relationships with our customers, with the following three objectives:

• Easy accessibility and fast processing
• Best value with competitive pricing
• Personalized support for a positive experience

Customer Segmentation
The comprehensive financial services offered at PSS meets all needs in three business sectors; individual and small business customers, institutional customers and corporate customers. This market division allows us to efficiently allocate our company resources to provide specialized services to all customers in each market sector.
For the individual and small business customer sector, PSS implements digital multi-channel services where each specialized team handles independent tasks to increase efficiency. For institutional customers, PSS offers a dedicate team focused on investment management and business development. For the corporate
customer sector, we provide a one-stop-shop service initiative with a dedicated specialist.

Consistent with PSS’ vision of being the most useful and ethical provider of financial services, globally, our primary strategy is to meet the financial service needs of our clients; our secondary strategy is to do so in a simplified organisational structure so that we can reduce our commission rates and fees. Our third strategy is to listen to what you want to achieve, not simply tell you what we can do for you.

Another important element of PSS’ strategy is the ongoing emphasis on combining people and technology in ways that facilitate the delivery of a full range of investment services while providing excellent value. People provide the client focus and personal touch that are essential in serving investors, while technology helps create services that are scalable and consistent. This combination helps PSS to both attract a broad spectrum of clients and deliver useful, relevant, value-added and growing array of investment, banking and lending products to them.

In serving these clients, PSS offers branch, telephonic and online service capabilities and an extensive product line. PSS’ networks of branches and regional telephone service centers are staffed with trained and experienced financial consultants focused on building and sustaining client relationships. In addition, PSS offers the ability to meet client trading and/or advice needs through a single ongoing relationship, even as those needs change over time. PSS also provides automated online and telephonic channels to provide quick and efficient access to an extensive range of information, research, tools, trade executions, and administrative services.

Competition in serving investors looking for an advisory relationship involves a variety of traditional brokerage, asset management, and wealth advisory firms. PSS‘ believes that our competitive strengths in this arena revolve around our ability to provide all our clients with an individually tailored solution – ranging from occasional consultations to frequent contact that will create an ongoing relationship with a PSS Consultant or Investment Specialist.

For active traders, PSS primarily competes with deep-discount, online-focused firms as well as certain larger financial institutions. Our management believes PSS can continue to attract these investors because we combine highly competitive pricing and optimized trading tools with extensive service capabilities – including experienced, knowledgeable teams of trading specialists and integrated product offerings. PSS also offers active investors access to all essential trading tools, financial products, and investment advice available to help them manage their diverse and complex portfolios.

For our Corporate Services, PSS competes with investment banks, hedge funds and asset management companies. PSS‘ management believes that our Corporate Services unit can maintain its market leadership position through a combination of superior service, scale, dedicated resources, and familiarity with the industry.

Overall, our management believes that PSS’ multichannel service delivery model of branch, phone and internet access is essential to its ability to compete effectively with the wide variety of financial services firms striving to attract clients and assets across the whole spectrum of investors. This way, PSS can offer personalized services at competitive prices while giving clients the choice of where, when and how they do business with us.

Code of business conduct

At PSS we are committed to be your reliable, long-term investment partner. We follow all relevant legislation, directives and market standards that govern the operation of financial institutions. We are also committed to maintaining the highest value of integrity, fairness and ethos all the time. Upon this foundation, we build our trust with our clients, from small business owners to corporate stakeholders.
At PSS, compliance is not only about following the law; it is an integral part of the culture and foundation of the company. We focus our compliance activities on preventing money laundering, terrorist financing, fraud, corruption and any other criminal offences pertaining to the transfer of funds. We are always looking for new ways to enhance our compliance and risk management while keeping up with all national and international laws.

Preventing Money Laundering & Terrorist Financing
Although money laundering and funding terrorism may sound like the same thing, they are different. Money laundering takes place when funds from criminal activities are put into the financial system to be ‘cleaned’, a process that makes them appear to have come from legitimate sources of income. In the case of terrorist financing, money from normal entities is sent to help fund terrorist attacks. At PSS, we work to prevent both money laundering and financing of terrorist activities, as both play a vital role in combatting international terrorism.
We use the Know-Your-Customer (‘KYC’) programme to identify and document the identity of our clients. You can rest assured your information and identity are
protected, while still benefiting from a high level of transparency, thanks to the KYC programme.

Sanctions & Embargos
Compliance helps us to guarantee and follow all relevant financial and economic sanctions, along with all regulatory requirements. At PSS, we use compliance to enact guidelines and instructions, inform our divisions and subsidiaries of sanction-related restrictions, and advise on how to implement and monitor these restrictions. Should PSS have business relationships with other countries affected by sanctions, these relationships are closely monitored and additional measures, up to termination of the partnership, are put in place.

Fraud Prevention
At PSS, we take widespread precautions to ensure our clients and employees do not become the victim or unwilling participant of a fraudulent act. We protect our products and processes against misuse and advocate for preventative, anti-fraud measures in all areas of business. We have widespread measures in place to prevent, uncover and respond to white-collar crime.
Our main goal of compliance is as follows: we want to protect your wealth. We make it one of our main priorities to combat all attempts at white-collar crime, regardless of who is involved. There is zero-tolerance for any fraudulent or criminal activities.

Conflicts of Interest
PSS is active in a variety of global industries, and sometimes conflict of interests can occur, especially when our business interests clash with those of our clients or suppliers. To avoid potential disagreements, we utilize a Conflict-of-Interest (‘COI’) tool to identify situations where a conflict-of-interest might arise. The COI tool provides a standard way to approach and document these situations, making COI-based decisions transparent and easy to understand.

Anti-Corruption
Corruption can come in many forms and take place across all areas of a business, which is why Sparkasse Group puts an emphasis on preventing and fighting
corruption. Anti-corruption compliance programme at PSS teaches our employees and business partners how to thwart fraudulent and/or corrupt activities
including: fraud, embezzlement, breach of trust, cartelisation and money-laundering.

Executive Decisions 2019

In the financial world, a period of readjustment is often followed by one of opportunity.
New opportunity arises quickly in the financial markets. The same can be said at PSS. In 2018, we made difficult decisions and initiated a Company-wide
transformation. Admittedly, some of the changes should have come sooner. But from a tightening of our focus, to significant additional reductions in our
expenses, to the return of our founder as Chief Executive Officer, we have not flinched from our responsibilities. We believe, passionately, that our short-term pain will lead to long-term gain—and that we have laid the foundation for the next great chapter in our history.

We sold our Saving Bank business to put the focus back where it belongs.
Simply put, we exited our savings bank operations to focus on the needs of investors and the
advisors who serve them. With the changes we’ve made, from i) active investors seeking great
prices and great services, ii) the independent-minded who need powerful tools and research, iii)
investors of all asset levels seeking full-service advice to iv) the independent advisors who many
investors turn to for money management and capital raising, PSS has the products, services and
pricing to serve them all without compromise. We don’t need to be all things to all people. We
just need to be ourselves.

It’s like starting a new company that just happens to handle kr 1 trillion in assets.
How are we doing? The fact is, investors are voting with their business. Net new assets in the final three months of 2018 totaled kr 16.8 billion—the highest level in over three years, excluding acquisition-related inflows. In December, account openings rose by 37% over the previous month, for our best tally since April 2017. For the year, client assets grew by 12%. Advisor assets in PSS Institutional increased by 21%. Assets in our corporate retirement plan business expanded by 14%. All promising developments. Stay tuned. We believe the best is yet to come.

Our prices now are not merely competitive but give us a competitive advantage.
The truth is, we don’t set prices. The market does. And so, we reduced our pricing across the board, cutting commissions twice in 2018. Delivering industry leading knowledge and integrity at a fair price not only attracts new investors, but it builds loyalty and business from current clients. We won’t be the lowest priced, but our goal is to restore PSS’s unrivaled value proposition. We don’t intend to lose it again.