World Forum of CSDs AGC answers · ️ The AGC questions and a report with only AGC answers will be generated ... of personal integrity and ethics, leadership qualities and a proven

WFC Single Disclosure Report 2019

AGC answers

Date submitted

02/12/2019 02:59:11

General information

1 G01Q001Please indicate the f ull name of the responding institution:

PFMI: Annex A - CSD disclosure template [CSD name]AGC: 0a

Euroclear Services f or Euronext Securit ies (ESES), composed of Euroclear Belgium (EBE), EuroclearFrance (EF) and Euroclear Nederland (ENL)

2 G01Q002Registered address:

PFMI: n/aAGC: 0c

ENL: Euroclear Nederland - Herengracht 469, 1017 BS Amsterdam, The Netherlands

EF: Euroclear France - 66 avenue de la Victoire, 75009 Paris, France

EBE: Euroclear Belgium - Avenue du Roi Albert II, 1, 1210 Brussels, Belgium

3 G01Q003Country of registered address:

PFMI: n/aAGC: 0d

ENL: The Netherlands ; EF: France ; EBE: Belgium

6 G01Q006The WFC, the AGC, CPMI and IOSCO encourage respondents to make their disclosure reports publiclyavailable. Do you agree to make your response publicly available?

PFMI: n/aAGC: 99

Yes, my f ull response will be publicly available. I agree that my response can be published on thewebsite of the WFC and on the website of the regional CSD association(s) which my CSD is a memberof . [A1]

7 G01Q007How will you be making your answers publicly available?

PFMI: n/aAGC: 99a

World Forum of CSDs AGC answers

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✔️ Website

✔️ Upon request

_ OTHER:

8 G01Q008This disclosure can also be f ound at the f ollowing web address(es):

PFMI: Annex A - CSD disclosure template [website URL]AGC: 99b

www.euroclear.com, https://my.euroclear.com/eses/shared/en/ref erence/due-diligence.html

9 G01Q009First and Last Name of the contact person:

PFMI: Annex A - CSD disclosure template [contact details]AGC: 99c

Véronique Lodico

10 G01Q009ADisclosure submission authorisation

✔️ I hereby certif y that I am authorised to submit this disclosure report on behalf of my institution.

11 G01Q010Email address of the contact person:

PFMI: Annex A - CSD disclosure template [contact details]AGC: 99h

[email protected]

12 G01Q011Telephone number (please include the international country code):

PFMI: n/aAGC: 99e

+33155345852

13 G01Q012How do you pref er to be contacted?

PFMI: n/aAGC: 99d

✔️ Telephone


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_ Fax

✔️ mail/air courier

✔️ e-mail

14 G01Q013Fax number

PFMI: n/aAGC: 99f

15 G01Q014What is the pref erred street address f or mailing requests?

PFMI: n/aAGC: 99g

66 avenue de la Victoire 75009 Paris

25 G01Q024I am submitt ing up-to-date inf ormation in response to:

✔️ The AGC questions and a report with only AGC answers will be generated

_ The PFMI questions and a report with only PFMI answers will be generated

_ Both the AGC and PFMI questions and a report with answers to both questionnaires will begenerated

Legal Basis (PFMI Principle 1)

27 G02Q002Under what regulation or statute is the CSD established and governed?

PFMI: n/aAGC: 7

EF / EBE / ENL are each separately a central securit ies depository within the meaning of the Regulation(EU) N° 909/2014 duly authorised by its competent authority:

EBE:

- Royal Decree n°62 of 10 November 1967 on the deposit of the f ungible instruments and thesettlement of transactions involving such instruments;

- Belgian Finality Law of 28 April 1999 transposing the Settlement Finality Directive 98/26/3C.;

- Law of 2 August 2002 governing the supervision of the f inancial sector and the f inancial services;

- Royal Decree of 26 September 2005.

EF:


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- Article L.330-1 of the French Monetary & Financial Code (M&F Code) with respect to the SSS;

- General Regulation of the AMF (Autorités des Marchés Financiers) and operating rules of EuroclearFrance

- approved by the AMF with respect to the activit ies as CSD and as operator of the SSS; Control of the

- Central Bank (Banque de France) f or the security settlement systems (article L.141-4 of the M&F

Code).

ENL:

- Securit ies Giro Act (Wet giraal ef f ectenverkeer).

- Act on the Financial Supervision (Wet Financieel Toezicht)

- Chapter 11A Bankruptcy Act transposing the Settlement Finality Directive 98/26/3C

28 G02Q003Is the regulation or statute electronically available?

PFMI: n/aAGC: 7a

Yes [Y]

29 G02Q004If regulation or statute is electronically available, please supply web address(es) here or uploaddocument(s).

PFMI: n/aAGC: 7b

"https://eur- lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014R0909&f rom=EN

ENL: www.wetten.overheid.nl

EF: http://www.amf -f rance.org/ http://www.legif rance.gouv.f r/

EBE: http://www.moniteur.be http://www.f sma.be http://www.nbb.be

30 G02Q005f ilecount - Please supply document(s) here:

PFMI: n/aAGC: 7c

0

Governance and ownership (PFMI Principle 2)

45 G03Q002What type of legal entity is the institution?

PFMI: n/aAGC: 3


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_ Public Company

_ Private Company

_ Central Bank (or part thereof )

_ Stock Exchange (or part thereof )

_ OTHER:

46 G03Q003Is the institution operated as a "f or prof it" or a "not f or prof it" organization?"

PFMI: n/aAGC: 4

47 G03Q004Please provide the names of the owners and their ownership interest percentages.

PFMI: n/aAGC: 5

48 G03Q005What is the date of establishment of the CSD?

PFMI: n/aAGC: 6a

04/08/1949

49 G03Q006What is the date that the CSD's operations began?

PFMI: n/aAGC: 6b

01/01/1950

50 G03Q007Are participants required to contribute capital to the CSD that would result in ownership of the CSD?

PFMI: n/aAGC: 18

No [A02]

51 G03Q008If yes, what f ixed amount is required or what f ormula is used to determine the appropriate contributionlevel?

PFMI: n/aAGC: 18a.


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secgen

Typewritten Text

EF: 04/08/1949 EBE: 04/01/1968 ENL: 01/07/1977

secgen

Typewritten Text

EF: 01/01/1950 EBE: 04/01/1968 ENL: 01/07/1977

59 G03Q016What are the roles and responsibilit ies of the CSD's board of directors (or equivalent), and are theyclearly specif ied? Please provide details of the structure and composition of your Board together withtheir industry experience and responsibilit ies in governing the CSD. What are the qualif ications tobecome a board member?

PFMI: Q.2.3.1AGC: 7d

61 G03Q018What are the election procedures?

PFMI: Q.2.3.2AGC: 7e

In accordance with legal requirements, Board members are appointed by the shareholders. For each ofthe ESES CSDs, the Board submits to the shareholders its proposals regarding appointment (and re-election) of Board members, supported by a recommendation of the Nominations and GovernanceCommittees which assess the Director against selection criteria. All nominations are made against meritand on the basis of a Director’s potential contribution in terms of knowledge, experience and inaccordance with the needs of the Board at the time of nomination. All nominations to the Board aremade with due regard to diversity on the Board, including gender. All directors have the highest degreeof personal integrity and ethics, leadership qualit ies and a proven ability to exercise sound businessjudgement.

62 G03Q019What is the maximum length of t ime a board member can serve?

PFMI: Q.2.3.2AGC: 7f

Board members are appointed by the general meeting of shareholders f or a term of up to three years(with possibility of renewal) in accordance with the Company’s Board and Board CommitteeComposition Policy.

63 G03Q020How are the voting powers distributed amongst the board members (i.e. does each board member haveone vote or do certain members have additional voting power)?

PFMI: Q.2.3.2AGC: 7g

The Board Members have each an equal voting right. In case of split votes, the vote of the Chairman ofthe Board is decisive.

65 G03Q022What are the procedures established to review the perf ormance of the board as a whole and theperf ormance of the individual board members? Who is responsible f or regulating the board members?

PFMI: Q.2.3.4AGC: 7h

The General Meeting of shareholders on the basis of Law and articles of association


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Comprehensive risk management (PFMI Principle 3)

88 G04Q003Any direct damages or losses to participants caused by the CSD as a result of f orce majeure events,acts of God, or polit ical events, etc.?

PFMI: Q.3.1.1AGC: 66x.

No [A02]

89 G04Q004If yes, please check all of the f ollowing that apply:

PFMI: Q.3.1.1AGC: 66y.

_ Financial limits are imposed on the amount of liability assumed by the CSD

_ The CSD assumes liability f or direct losses

_ The CSD assumes liability f or indirect or consequential losses

_ OTHER:

90 G04Q005In all cases where the CSD assumes responsibility f or direct or indirect or consequential losses, is theCSD's liability limited by a standard of care determination?

PFMI: Q.3.1.1AGC: 66+

Yes [A01]

91 G04Q006Please def ine the standard of care applied:

PFMI: Q.3.1.1AGC: 66*

Please ref er to the Section 13 of the ESES T&Cs Book I

Credit risk (PFMI Principle 4)

121 G05Q011Does the CSD have a guaranty f und independent of stock exchange or other market guarantees?

PFMI: Q.4.3.1AGC: 78


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No [A02]

122 G05Q012If yes, please respond to the f ollowing questions: What is the size of the f und?

PFMI: Q.4.3.1AGC: 78a.

123 G05Q013How is the size of the f und determined?

PFMI: Q.4.3.1AGC: 78b.

124 G05Q014How is the f und f inanced?

PFMI: Q.4.3.1AGC: 78d.

125 G05Q015If so, what is the amount or percentage per owner?

PFMI: Q.4.3.1AGC: 78e.

126 G05Q016If so, what is the amount or percentage per participant?

PFMI: Q.4.3.1AGC: 78f.

127 G05Q017Who is covered by the f und?

PFMI: Q.4.3.1AGC: 78h.

_ Direct CSD participants only

_ The benef icial owner also

_ OTHER:

128 G05Q018When is the guaranty f und used?

PFMI: Q.4.3.1


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AGC: 78j.

_ When a broker def aults

_ When a direct participant def aults

_ OTHER:

131 G05Q021Does the CSD have insurance to cover losses in the event of Def ault on settlement commitments bythe CSD or a participant?


No [A02]

132 G05Q022What is the amount of the coverage?

PFMI: Q.4.3.3AGC: 91a

133 G05Q023What is the amount of the deductible?

PFMI: Q.4.3.3AGC: 91b

134 G05Q024Please explain other loss or def ault protections:


135 G05Q025Does the CSD accept liability (independent of any insurance coverage) f or the f ollowing: Any directdamages or losses to participants caused by the CSD in its capacity as a central counterparty?

PFMI: Q.4.3.3AGC: 66q.

Not applicable [A03]


PFMI: Q.4.3.3AGC: 66r.



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_ OTHER:

Collateral (PFMI Principle 5)

141 G06Q001Summary narrative f or PFMI Principle 5. Please provide a summary narrative disclosure with suf f icientdetail and context, as well as any other appropriate supplementary inf ormation, to enable readers tounderstand the CSD's approach to or method f or observing the principle. Please use the f ollowingquestions as guidance f or the points of f ocus and level of detail it is expected to convey in thedisclosure. Cross ref erences to publicly available documents should be included, where relevant, tosupplement the discussion.)

PFMI: Annex A - CSD disclosure template - IV.P5AGC: 35c

Banque de France and de Nederlandsche Bank can give automatically intraday liquidity againstcollateral (repo) f or buyer participants.

Clients of the ESES markets can use the T2S auto-collateralisation mechanism to raise intradayliquidity or send collateral to their Central Bank.

Liquidity risk (PFMI Principle 7)

Sett lement f inality (PFMI Principle 8)

Money sett lements (PFMI Principle 9)

217 G09Q003Who accepts cash deposits (or makes payment credit accommodations) f or CSD transactions?


_ CSD

✔️ Central Bank

_ Banks appointed by CSD

_ Neither or others (e.g. credit lines used)

_ Not applicable

_ OTHER:

218 G09Q004Please indicate the name of the banks appointed by the CSD



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219 G09Q005Who processes cash clearing (or draws on credit lines, if applicable) f or CSD transactions?


_ CSD

✔️ Central Bank

_ Banks appointed by the CSD


_ Not applicable

_ OTHER:

220 G09Q006Please name banks appointed by the CSD


221 G09Q007Who controls the movement of cash f or cash deposits (or draws on credit lines, if applicable)?

PFMI: Q.9.1.1AGC: 33, 33b

_ CSD

✔️ Central Bank



_ Not applicable

_ OTHER:

222 G09Q008Please name banks appointed by the CSD


223 G09Q009Who controls the movement of cash f or cash clearing (or f or draws on credit lines, if applicable)?


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_ CSD

✔️ Central Bank



_ Not applicable

_ OTHER:

224 G09Q010Please name banks appointed by CSD


Physical deliveries (PFMI Principle 10)

239 G10Q005How are eligible securit ies lodged in the CSD system?

PFMI: Q.10.1.3AGC: 57, 57a

_ A registered certif icate in the name of the CSD is delivered to the CSD.

_ A participant delivers the security with a valid transf er deed or stock power or other transf erdocument to the CSD which then ef f ects registration.

_ A registrar re-registers the security in the name of the CSD.

_ Not applicable

✔️ OTHER: As per the answer on question 50, almost all the eligible instruments are held in adematerialized f orm. For the remaining part, bearer or registered certif icates into the name of the ESESCSDs may be lodged f or f urther book entries on ESES accounts. ENL: dematerialised securit ies aretransf erred via a valid legal deed of transf er to ENL bef ore registration. Globals are bearer certif icateswhich are deposited via physical delivery.

240 G10Q006When are securit ies lodged into the CSD ref lected in a participant's CSD account?

PFMI: Q.10.1.3AGC: 58, 58a

✔️ Securit ies are ref lected in the participant's CSD account immediately upon delivery to the CSD.

_ Securit ies are re-registered prior to being ref lected in the participant CSD account.

_ Not applicable


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_ OTHER:

241 G10Q007How long does it usually take to lodge securit ies with the CSD?

PFMI: Q.10.1.3AGC: 59, 59b

Other: The timef rame of lodging securit ies depends on the specif ications of the security. Depending onthe securit ies type, lodging of securit ies can be perf ormed anything between same day and 3 businessdays

242 G10Q008Please specif y


243 G10Q009During the process of lodging securit ies into the CSD, can the securit ies be traded?

PFMI: Q.10.1.3AGC: 60

Yes [A01]

244 G10Q010During the process of lodging securit ies into the CSD, can the securit ies be settled?


No [A02]

245 G10Q011During the process of lodging securit ies into the CSD, can the securit ies have ownership transf erred?


No [A02]

246 G10Q012If they cannot be traded, or if you answered other, please explain

PFMI: Q.10.1.3AGC: 60c

247 G10Q013If they cannot be settled, or if you answered other, please explain

PFMI: Q.10.1.3


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AGC: 60d

This will be possible af ter the lodging process is f inalised

248 G10Q014If ownership cannot be transf erred, or if you answered other, please explain


This will be possible af ter the lodging process is f inalised

249 G10Q015Are securit ies immediately available f or delivery upon transf er to the CSD?

PFMI: Q.10.1.3AGC: 61, 61d

Other: � Yes, securit ies transf erred via bookentry to the depository are immediately available f oronward delivery.

250 G10Q016If no: Securit ies are unavailable f or


251 G10Q017If more than 4 weeks, please specif y


252 G10Q018If not applicable, please explain


253 G10Q019What transf er process steps are involved when eligible securit ies are withdrawn f rom the CSD f orsaf ekeeping?

PFMI: Q.10.1.3AGC: 63, 63a

Other: Securit ies are re-registered into the name of the benef icial owner or a nominee; securit ies arere-certif icated and re-registered into the name of the benef icial owner or a nominee; securit ies are re-certif iated and delivered as bearer instruments; securit ies are transf erred as is any physical delivery inthe market. In most of the case it will be done through book-entry. Additionally, securit ies are


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centralised on the account of the SPA. On demandof the SPA (via "destruction f orm") the CSD willexecute the destruction of the requested number of securit ies. ENL: due to the immobilisation rule,withdrawal of securit ies f rom ENL is only allowed in limited circumstances laid down in the law

254 G10Q020How long does it usually take to remove securit ies f rom the CSD?

PFMI: Q.10.1.3AGC: 64, 64b

Other: The timef rame of removing securit ies depends on the properties of the security. Removing ofdematerialized securit ies usually takes 1 to 3 business days. See also 63a

255 G10Q021If more than 4 weeks, please specif y


256 G10Q022While the securit ies are being removed f rom the CSD, can they be traded? (Choose one)


Yes [A03]

257 G10Q023If they cannot be traded please explain


258 G10Q024While the securit ies are being removed f rom the CSD, can they be settled? (Choose one)


No [A01]

259 G10Q025If they cannot be settled, please explain


Settlement requires an adequate balance in the securit ies account

260 G10Q026While the securit ies are being removed f rom the CSD, can they have ownership transf erred? (Choose


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one)


Not applicable [A02]

261 G10Q027If ownership cannot be transf erred, please explain


263 G10Q029What are the vault security procedures f or the saf ekeeping of physical paper?

PFMI: Q.10.2.1AGC: 75

_ Not applicable, no vault is maintained

✔️ Electronic keys or combinations

✔️ Dual access control

✔️ Visitor logs

✔️ Vault counts

✔️ Intrusion alarms

✔️ Fire alarms

✔️ Guards

_ OTHER:

264 G10Q030Please indicate f requency of vault counts:

PFMI: Q.10.2.1AGC: 75a.

Annually

265 G10Q031Please explain:


Applicable to EBE and ENL, as EF do not maintain any vaults (outsourced to EBE)


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Central Securit ies Depositories (PFMI Principle 11)

271 G11Q002CSD FUNCTIONALITY AND SERVICES, USE OF AGENTS. Certain f unctionalit ies and services reducerisk to an investor if provided in an ef f icient manner. The purpose of this section is to identif y thosef unctionalit ies that may potentially be of f ered by depositories and clearing systems around the world,and ascertain whether they are of f ered by your institution. For which of the f ollowing security types doyou serve as a CSD or clearing system?

PFMI: n/aAGC: 26

✔️ Government securit ies

✔️ Equities

✔️ Corporate bonds

✔️ Corporate money market

_ Not applicable

✔️ OTHER: no Government securit ies in EBE

272 G11Q003Please name the other security types:

PFMI: n/aAGC: 26a.

EF and ENL: Exchange Traded Funds (ETF / Trackers), Funds, Warrants, Treasury Bills

EBE: Exchange Traded Funds (ETF / Trackers), Funds, Warrants

273 G11Q004Is the use of the CSD in your market compulsory by law or compulsory by market practice f or thesettlement or saf ekeeping of all instrument types in your market (e.g. equities, government securit ies,corporate bonds, money market instruments, warrants, derivatives etc).

PFMI: n/aAGC: 27, 27c

_ Yes by law f or settlement of all instrument types

_ Yes by law f or saf ekeeping of all instrument types

_ Yes by market practice f or settlement of all instrument types

_ Yes by market practice f or saf ekeeping of all instrument types

_ Yes by law f or settlement, but not f or all instrument types

_ Yes by law f or saf ekeeping, but not f or all instrument type

_ Yes by market practice f or settlement, but not f or all instrument types

_ Yes by market practice f or saf ekeeping, but not f or all instrument types

✔️ Neither


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✔️ OTHER: EBE: Yes by law f or settlement, but not f or all instrument types, yes by law f orsaf ekeeping, but not f or all instrument types, yes by market practice f or settlement but not f or allinstrument types, yes by market practice f or saf ekeeping bu not f or all instrument types. For EF: underFrench law, the use of the depositary is not per se mandatory f or the settlement or custody of thef inancial instrument. The obligation to select a depository f o custody is not directly provided f or underFrench law. The obligation to select a system f or the settlement and delivery of f inancial instruments isimposed by the markets themselves. For example, pursuant to Rule 4601 of the Harmonised Rule Bookof Euronext the transactions executed on a Euronext Securit ies Market must be settled through thesettlement organisations designed by Euronext. For ENL: Using ENL as depository (f or saf ekeepingf unctions) is not mandatory by law. Using ENL as settlement platf orm is not mandatory by law eitherbut it is market practice that the securit ies traded at Euronext Amsterdam stock exchange are settled ineither ENL or Euroclear Bank in their capacity as settlement organisations designated by Euronext.

274 G11Q005Please list the instrument types f or which it is not compulsory by law to: (i)settle in your CSD

PFMI: n/aAGC: 27a. (i)

275 G11Q006(ii) saf ekeep in your CSD:

PFMI: n/aAGC: 27a. (ii)

276 G11Q007Please list the instrument types f or which it is not compulsory by market practice to: (i)settle in yourCSD

PFMI: n/aAGC: 27b. (i)

277 G11Q008(ii) saf ekeep in your CSD:

PFMI: n/aAGC: 27b. (ii)

278 G11Q009Settlement and Saf ekeeping Percentages 28a Please list by instrument type the percentage of the totalmarket in your jurisdiction (either volume or value) settled within your institution, exclusive of your linkswith third parties.

PFMI: n/aAGC: 28 28a

Percentages are not available.

279 G11Q010Please list by instrument type the percentage of the total market in your jurisdiction (either volume or


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value) held in saf ekeeping within your institution.

PFMI: n/aAGC: 28b.

Percentages are not available.

281 G11Q012In the event a participant's single or main account is blocked f or any reason (e.g., insolvency, penalties,violations, liens), would securit ies held in any account or accounts on behalf of the participant's clientsbe accessible: By the participant's clients?


Other: NL: The Dutch Securit ies Giro Act (Wet giraal ef f ectenverkeer) prohibits the seizure of thesecurit ies ref lected in the accounts maintained with Euroclear Nederland. In the event of a bankruptcyof an ENL participant, the participant's clients ownership rights to the securit ies are protected. EF: Yes,only only f or segregated account at the request of the administrator of the account duly documented.Only in certain circumstances explicit ly provided by French law: (cf . article L431-6 Financial and MonetaryFrench Code). With the agreement of the liquidator or the administrator of the concerned participant,the client can ask f or the transf er of his securit ies to another participant. The liquidator/administratorinit iates the concerned moverments in our system. EBE: NO

282 G11Q013If yes, please describe brief ly how clients of participants would access their securit ies and whetherthere would be any delay in their ability to do so:


283 G11Q014By the intervening authorit ies controlling insolvency or other proceedings?

PFMI: Q.11.1.1AGC: 44d.

Yes [A01]

284 G11Q015If yes, please describe brief ly under what conditions access would be granted to the interveningauthorit ies:

PFMI: Q.11.1.1AGC: 44e.

The administrator or liquidator (appointed by the regulator or the commercial court) who manages thedef ault has f ull authority to access the account. In case of bankruptcy of the Participant, theParticipant's client's securit ies are protected and segregated f rom the bankruptcy estate.

285 G11Q016By the participant's creditors?

PFMI: Q.11.1.1


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AGC: 44g, 44i

No [A02]

286 G11Q017If yes, please describe brief ly under what conditions access would be granted to the participant'screditors:


287 G11Q018By the CSD's creditors?

PFMI: Q.11.1.1AGC: 44j.

No [A02]

288 G11Q019If yes, please describe brief ly under what conditions access would be granted to the CSD's creditors:

PFMI: Q.11.1.1AGC: 44k.

289 G11Q020What is your document and record retention policy f or documents and records described above in thissection?

PFMI: Q.11.1.1AGC: 47, 47a

Other: 10 years. ESES ESES complies with Central Securit ies Depositories Regulation (CSDR) Article 29of the CSD 585 Regulations (EU) No 909/20144, under which all data in the scope of our CSDRoperations will be retained f or a period of 10 years.

290 G11Q021Does the law protect participant assets f rom claims and liabilit ies of the CSD?

PFMI: Q.11.1.1AGC: 54

Yes [A01]

291 G11Q022Can the CSD assess a lien on participant accounts? (A lien would entit le the CSD to take and hold orsell the securit ies of the participant in payment of a debt.)

PFMI: Q.11.1.1AGC: 55

Other: YES f or EBE, NO f or EF and ENL


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292 G11Q023If yes, f or what reasons are liens or similar claims imposed?


_ Fees and expenses

_ Collateralization of overdraf ts

_ To secure payment f or purchased securit ies

_ OTHER:

293 G11Q024Please describe:


294 G11Q025Please indicate the limits of this lien as indicated below:


Other: For EBE only the lien is limited to securit ies



296 G11Q027If a lien is placed on a participant's account which has been designated f or its clients, will the CSDselect certain securit ies to be subject to the lien?


Other: YES f or EBE only and NA f or EF and ENL. ThE lien is placed only on client's own assets andselected depending of the circumstances.

297 G11Q028If yes, please indicate whether:




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299 G11Q030If no, please indicate whether the entire account will be subject to the lien.


300 G11Q031For accounts designated as client accounts, do procedures exist to restrict the placement of liens onlyto obligations arising f rom saf e custody and administration of those accounts?

PFMI: Q.11.1.1AGC: 55j

301 G11Q032If yes, are the restrictions accomplished by:

PFMI: Q.11.1.1AGC: 55k


PFMI: Q.11.1.1AGC: 55l

303 G11Q034Transf er of Legal Ownership. Does the CSD have legal authority to transf er t it le to securit ies?

PFMI: Q.11.1.1AGC: 56, 56e

No [A02]

304 G11Q035When does tit le or entit lement to CSD securit ies pass between participants?





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it depends of the applicable local law that will govern the transf er of ownership.

306 G11Q037Where does tit le or entit lement to CSD securit ies pass between participants?




309 G11Q040In what f orm does the CSD maintain records identif ying the assets of each participant?

PFMI: Q.11.1.2AGC: 45

✔️ Computer f ile

_ Microf iche

_ Hard copy

_ Computer tape

_ OTHER:

310 G11Q041In which f ormat is the source data maintained?


Original f ormat f or accounting data (account and subaccount ref erences, security code, quantity,amount if DVP...)

315 G11Q046If the securit ies held with the CSD are recorded by book-entry at the registrar, what are the controlf eatures at the registrar f or transf er of registrar posit ions to and f rom the CSD (e.g., authenticationprocedures, reconciliation, conf irmation of posit ion at registrar)? Please describe:

PFMI: Q.11.1.6AGC: 52i

318 G11Q049


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How are CSD eligible securit ies held by the CSD?

PFMI: Q.11.3.1AGC: 50, 50a

✔️ In dematerialized f orm

✔️ In certif icated f orm

_ OTHER:

320 G11Q051If CSD eligible securit ies are certif icated, can CSD eligible securit ies be held outside of the CSD?

PFMI: Q.11.3.2AGC: 51

Other: Certain designated securit ies may be held exceptionally outside the CSD

321 G11Q052If certain designated securit ies are held outside the CSD, please indicate under which conditions thesesecurit ies would be held outside the CSD:


322 G11Q053If CSD eligible securit ies are required to be centrally immobilized at the CSD, where and with whom arethe certif icates saf ekept? (then please answer 51c)


323 G11Q054Are these certif icates:


_ Bearer

_ Registered

_ OTHER:

324 G11Q055If registered, how are the CSD eligible securit ies registered?


_ In the name of the CSD


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_ In the name of the depositing participant or its nominee

_ In the name of a separate nominee of the CSD

_ OTHER:

325 G11Q056If in the name of a separate nominee, please identif y by name the nominee used:


326 G11Q057If CSD eligible securit ies may be held either in or out of the CSD, are these certif icates:


327 G11Q058What are the control f eatures f or receipt of certif icates to the CSD (e.g., authentication procedures,re-registration)? Please describe:


328 G11Q059If securit ies are dematerialized: May dematerialized security posit ions be re-certif icated and heldoutside the CSD?

PFMI: Q.11.3.2AGC: 52

Other: Yes f or EBE and EF; No f or ENL. EBE: Bearer securit ies have been dematerialized as f rom the1st January 2008. Euroclear Belgium, as settlement institution on the Belgian market, of f ersdematerialization services to all issuers of Belgian securit ies. EF: Under French law, a French centraldepository may re-materialize securit ies under the f orm “certif icats représentatif s de valeursf rançaises” (certif icates representing securit ies). Please note, however, that these certif icates mustonly circulate outside France. ENL: As f rom 2010, securit ies deposited with ENL are eitherdematerialised or embodied in a global and immobilised. Depending on conditions governing the issue,recertif ication is possible. Euroclear Nederland does not actively support recertif ication. If applicable,this is done by external transf er agents.

329 G11Q060Are the securit ies held:

PFMI: Q.11.3.2AGC: 52a, 52k

_ Through book-entry at the CSD

_ Through book-entry at a registrar or issuer

_ OTHER:


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330 G11Q061Please identif y which types of entit ies may act as registrars:


_ Issuers

_ Separate companies that perf orm registrar f unctions

_ CSD

_ OTHER:

331 G11Q062If the securit ies held by the CSD are recorded by book entry at the registrar, are the securit iesregistered only to the CSD, with the CSD providing the f unction of recording ownership on a centralizedbasis f or the market?


332 G11Q063If yes, how are securit ies held at the registrar f or the account of the CSD?




334 G11Q065If the securit ies held with the CSD are recorded by book-entry at the registrar but are not registeredexclusively to the CSD, may they be registered to:





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338 G11Q069Does the CSD accept liability (independent of any insurance coverage) f or the f ollowing: Reconciliationerrors with the registrar and/or the issuer that result in direct damages or losses to participants?

PFMI: Q.11.4.1AGC: 66, 66a, 66d

Other: The depositary is liable f or its negligence, f raud or willf ul misconduct. Its liability is limited todirect losses and capped according to the provisions of the ESES T&Cs. The depository is not liable incase of f orce majeure (as def ined in the ESES Terms and Conditions).


PFMI: Q.11.4.1AGC: 66b 66c




_ OTHER:

340 G11Q071Thef t of securit ies (either physical certif icate or electronically f rom accounts at the CSD) f rom the CSDthat results in direct damages or losses to participants?

PFMI: Q.11.4.1AGC: 66e, 66g, 66h

Other: The depositary is liable f or its negligence, f raud or willf ul misconduct. Its liability is limited todirect losses and capped according to the provisions of the ESES T&Cs. The depository is not liable incase of f orce majeure (as def ined in the ESES Terms and Conditions).






_ OTHER:

342 G11Q073Failure of the CSD's systems that result in direct damages or losses to participants because theycannot use either securit ies or f unds?

PFMI: Q.11.4.1AGC: 66i, 66l.

No [A01]


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PFMI: Q.11.4.1AGC: 66j, 66k




_ OTHER:

344 G11Q075Any direct damages or losses to participants caused by the CSD due to its errors, omissions or f raud?

PFMI: Q.11.4.1AGC: 66m, 66p.

✔️ Yes

_ No

_ Not applicable

_ OTHER:


PFMI: Q.11.4.1AGC: 66n.




✔️ OTHER: Liability f or direct loss that could be capped according to the provisions of the ESES T&Cs

347 G11Q078Is the CSD immune f rom legal action in its own jurisdiction?

PFMI: Q.11.4.2AGC: 68

No [A02]

349 G11Q080Does the CSD have Fidelity insurance (that is, insurance to cover loss of securit ies or money resulting,f or example, f rom acts such as f orgery, thef t, f raud and/or employee dishonesty)?


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PFMI: Q.11.4.3AGC: 92

Yes [A01]


PFMI: Q.11.4.3AGC: 92a.

Our coverage is € 265 million f or third party liability (e.g.. customers) and € 75 million f or ESES owndamages regarding Fraud/Crime.


PFMI: Q.11.4.3AGC: 92b.

This inf ormation is not made available to the public

352 G11Q083Does the CSD have insurance f or Operational Errors?

PFMI: Q.11.4.3AGC: 93

Other: Euroclear does not have an insurance to cover its own losses (except f raud) stemming f romoperational errors. Although, Euroclear's operational errors that would lead to (a) third party claim(s),e.g. f rom clients are well covered via the Crime and Civil Liability policy. A third party claim is mandatoryto trigger this policy. Our crime and civil liability insurance covers f idelity, f raud, errors and omissions,and computer manipulation f or an amount of EUR 265 million plus a reinstatement of respectively EUR245 million.


PFMI: Q.11.4.3AGC: 93a.


PFMI: Q.11.4.3AGC: 93b.

355 G11Q086


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Does the CSD have Errors and Omissions insurance?

PFMI: Q.11.4.3AGC: 94

Yes [A01]


PFMI: Q.11.4.3AGC: 94a.

Euroclear has an insurance cover f or errors and omission (including negligence), omission of Euroclearemployees (including employee inf idelity) and the trigger of such cover is a third party claim. Ourinsurance covers f or an amount of € 265 million


PFMI: Q.11.4.3AGC: 94b.

Inf ormation is not publicly available.

358 G11Q089Does the CSD have insurance f or the Premises?

PFMI: Q.11.4.3AGC: 95

Yes [A01]


PFMI: Q.11.4.3AGC: 95a.

Inf ormation is not publicly available but the ESES premises are insured to f ull value.


PFMI: Q.11.4.3AGC: 95b.

Inf ormation is not publicly available.

361 G11Q092Does the CSD have any other insurance?

PFMI: Q.11.4.3AGC: 96, 96d


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Yes [A01]

362 G11Q093If so, what is it f or?

PFMI: Q.11.4.3AGC: 96a.

Euroclear maintains insurance policies in relation with its activit ies (General Legal Liability, Directors &Of f icers…)


PFMI: Q.11.4.3AGC: 96b.



PFMI: Q.11.4.3AGC: 96c.


365 G11Q096Who is the insurance carrier? If more than one insurance carrier, please list each carrier here andprovide your responses to questions 97a and 97b in corresponding order.

PFMI: Q.11.4.3AGC: 97

We have several insurers; f or the list of main insurers f or our two key insurance policies, please ref erto the insurance certif icates provided in annex. For our insurers and we require that: • they have aStandard and Poor's insurer credit rating of minimum A- (or equivalent); • they are not related to theEuroclear group

366 G11Q097Who is the insurance carrier's parent company, if applicable? (If inapplicable, simply type n/a.)

PFMI: Q.11.4.3AGC: 97a.

We do not maintain a public record of our insurers' parent company. For the list of main insurers f orour key insurance policies, please ref er to the insurance certif icates provided in annex

367 G11Q098


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What is the term of the policy?

PFMI: Q.11.4.3AGC: 97b.

Yearly renewal

368 G11Q099Who does the insurance cover?

PFMI: Q.11.4.3AGC: 97c, 97d

✔️ CSD

_ Direct CSD participants

_ Final investors

_ Not applicable

✔️ OTHER: The insurances cover Euroclear Holding SA and all its subsidiaries.

369 G11Q100If you f eel that you would like to provide additional details on any of the given answers, f eel f ree toprovide any additional comments here (maximum of 5,000 characters) or prepare an additionaldocument identif ying the question(s) you are commenting on and upload the document under 98a:

PFMI: Q.11.4.3AGC: 98

N/A

370 G11Q101f ilecount - Upload document here:

PFMI: Q.11.4.3AGC: 98a.

0

371 G11Q102Do the CSD's written contracts, rules, or established practices and procedures provide protectionagainst risk of loss of participant assets by the CSD in the f orm of indemnif ication?

PFMI: Q.11.4.3AGC: 67a, 67b.

✔️ Yes

_ No

_ Not applicable

_ OTHER:


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372 G11Q103Please explain (then please answer 67c):

PFMI: Q.11.4.3AGC: 67b.

ESES CSDs assume liability f or direct losses only and in case of negligence, f raud, or wilf ulmisconduct. Negligence will be determined on the basis of the of actual circumstances, and assessedagainst the standard of a theoretical competent prof essional f acing the same circumstances.

373 G11Q104Please provide details of the relevant sections of the contracts, rules or practices where thisinf ormation is f ound

PFMI: Q.11.4.3AGC: 67c.

Section 1 of the ESES T&Cs Book I

374 G11Q105Insurance

PFMI: Q.11.4.3AGC: 67d.

✔️ Yes

_ No

_ Not applicable

_ OTHER:

375 G11Q106Please explain (then please answer 67f ):

PFMI: Q.11.4.3AGC: 67e.

Euroclear maintains insurance policies in relation with its activit ies (General Legal Liability, Directors &Of f icers…)

376 G11Q107Please provide details of the relevant sections of the contracts, rules or practices where thisinf ormation is f ound

PFMI: Q.11.4.3AGC: 67f.

Section 13 Book I of the ESES Terms and Conditions provides the liability regime of the ESES CSDs


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377 G11Q108Acknowledgement of liability f or losses caused by CSD's own actions.

PFMI: Q.11.4.3AGC: 67g.

Yes [A01]

378 G11Q109Please explain (then please answer 67i):

PFMI: Q.11.4.3AGC: 67h.

Limitation of liability to the amount paid out in the relevant case by the CSD's liability insurance

379 G11Q110Please provide details of the relevant sections of the contracts, rules or practices where thisinf ormation is f ound.

PFMI: Q.11.4.3AGC: 67i.

Section 13 Book I of the ESES Terms and Conditions provides the liability regime of the ESES CSDs

380 G11Q111Other

PFMI: Q.11.4.3AGC: 67j.

Yes [Y]

381 G11Q112Please explain (then please answer 67l:

PFMI: Q.11.4.3AGC: 67k.

Clients f inancial instruments are protected f rom losses in case of claims against the CSD or in case ofinsolvency of the CSD; this is due to the f act that under the applicable laws, clients f inancialinstruments never become the ownership of the CSD and are not available f or the satisf action ofclaims of the CSD's creditors.

382 G11Q113Please provide details of the relevant sections of the contracts, rules or practices where thisinf ormation is f ound.

PFMI: Q.11.4.3AGC: 67l.


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EBE: Royal Decree n°62 + article 13 of the ESES T&Cs

EF: Article 13 of the ESES T&Cs

ENL: Dutch Securit ies Giro Act + article 13 of the ESES T&Cs

384 G11Q115Are participants permitted to maintain more than one account at the CSD?

PFMI: Q.11.5.1AGC: 41

Yes [A01]

385 G11Q116If yes, please indicate number:

PFMI: Q.11.5.1AGC: 41a, 41c

✔️ An unlimited number of accounts

_ More than one account

_ OTHER:

386 G11Q117If more than one account what is the maximum?


388 G11Q119Are participants required/permitted to segregate assets held f or their own benef it f rom those they holdf or their clients?

PFMI: Q.11.5.2AGC: 42

✔️ Yes

_ No

_ Not applicable

_ OTHER:

389 G11Q120If yes, is segregation required or simply permitted?



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Permitted [A02]

390 G11Q121How does segregation occur?

PFMI: Q.11.5.2AGC: 42b, 42c

✔️ By separately designated participant accounts.

✔️ By sub-accounts within a single participant account.

_ By separately designated benef icial owner accounts.

_ OTHER:

391 G11Q122Does the CSD permit its participants to open accounts in the participant's own nominee name(s)?

PFMI: Q.11.5.2AGC: 43, 43b

Other: ENL: Euroclear Nederland admitted institutions hold omnibus accounts in their own name withEuroclear Nederland. These omnibus accounts ref lect nostro (own assets) and loro (clients) assets. Inaccordance with the Dutch Securit ies Giro Act, investors that deposit securit ies with admittedinstitutions become co-owners entit led to a pro rata share in a pool of f ungible securit ies. Admittedinstitutions may open additional accounts to segregate nostro f rom loro assets. Dutch law does notknow the concept of nominee, but recognizes nominee structures established under f oreign law. EF:Clients can open several accounts, with distinct denomination. A participant may act in his capacity ofregistered intermediary only on behalf of non-resident client. EBE: Clients can open several accounts,with distinct denomination. But clients cannot open accounts on behalf of other entit ies. Belgian lawdoes not know the concept of nominee, but recognizes nominee structures established under f oreignlaw. Nominees can become EBE clients, and open account in their name.

392 G11Q123If yes, do laws exist, which def ine as well as protect the rights of benef icial owners with respect tosecurit ies registered in nominee name?


393 G11Q124Does the CSD maintain records that identif y the assets of each participant and segregate the system'sown assets f rom the assets of participants?

PFMI: Q.11.5.2AGC: 53, 53a

_ Yes

_ No

✔️ Not applicable

_ OTHER:


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395 G11Q126Please indicate services you provide.

PFMI: Q.11.6.1AGC: 35

✔️ Own list or: AGC: Inf ormation in advance on corporate (annual or special) meetings in order thatowners can vote.

_ Tax assistance where f oreign holders may be entit led to tax relief at source or through a claim.

_ In order to avoid f ails, an automatic securit ies lending f acility - if requested - is provided f or.

✔️ Collateral handling in support of activit ies including securit ies lending, overdraf t coverage, cashmanagement,repurchase agreements, etc.

✔️ Same day turnaround settlements.

✔️ Inf ormation on distribution of new issues (IPO, Privatization).

_ Not applicable

_ OTHER:

396 G11Q127Automatic securit ies lending f acility is provided f or:


_ Brokers

_ Banks

_ Other f inancial institutions

_ OTHER:

397 G11Q128If collateral handling, please provide details


Banque de France and de Nederlandsche Bank can give automatically intraday liquidity againstcollateral (repo) f or buyer participants.

Clients of the ESES markets can use the T2S auto-collateralisation mechanism to raise intradayliquidity or send collateral to their Central Bank.

398 G11Q129Other, please explain:

PFMI: Q.11.6.1


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AGC: 35d

399 G11Q130What procedures are in place f or the processing of corporate action entit lements?

PFMI: Q.11.6.1AGC: 36

_ Credited to the securit ies account on the day indicated below regardless of whether actuallycollected by the CSD on the scheduled date.

✔️ Credited to the securit ies account upon actual receipt by the CSD.

_ Corporate action entit lements are handled by an entity separate f rom the CSD.

_ Not applicable

_ OTHER:

400 G11Q131Credited to the securit ies account:


_ On pay date.

_ On pay date +1.

_ On pay date +2.

_ OTHER:

401 G11Q132Name of entity:


402 G11Q133What procedures are in place f or the processing of interest and dividends?

PFMI: Q.11.6.1AGC: 37, 37d.

_ Credited to the cash account on the day indicated below regardless of whether actually collected bythe CSD on the scheduled date.

✔️ Credited to the cash account upon actual receipt by the CSD.

_ Income and dividend collection is handled by an entity separate f rom the CSD.

_ Not applicable


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✔️ OTHER: It depends of the choice of the issuer. It may appoint a bank which will payinterest/dividends to the holders upon evidence of their holding with a ESES CSD. the direct paymentsystem where the CSD is authorised to request debt to the cash account of the issuer (or the bankwhich assumes the f inancial services) in the central bank and simultaneously to credit the cash accountof the concerned ESES participants on pay date.

403 G11Q134Credited to the cash account:


_ On pay date.

_ On pay date +1.

_ On pay date +2.

_ OTHER:

404 G11Q135Name of entity:


Exchange-of-value sett lement systems (PFMI Principle 12)

409 G12Q003Does the CSD guaranty settlement?

PFMI: Q.12.1.1AGC: 66u.

No [A01]

410 G12Q004Please explain how this is accomplished. What are the procedures and saf eguards that permit the CSDto guaranty settlement?

PFMI: Q.12.1.1AGC: 66v.

412 G12Q006The Committee on Payment and Settlement Systems of the Bank f or International Settlements (BIS)has identif ied three common structural approaches or models f or linking delivery and payment in asecurit ies settlement system. Please indicate which model your procedures most closely resemble.

PFMI: Q.12.1.2AGC: 48

✔️ Model1


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_ Model2

_ Model3

_ Not applicable

_ OTHER:

413 G12Q007Please brief ly describe your settlement process, including how do your settlement procedures varyf rom the model chosen above?


ESES system is a Model 1 with instantaneous irrevocable settlement in real t ime, with a management ofcash posit ions in Target 2 environment ( T2 and T2S). T2S operates the settlement and delivery onbehalf of ESES and sends messages to ESES to apply those messages on ESES participants'accounts.

416 G12Q010Are the cash and security movements simultaneous?

PFMI: Q.12.1.3AGC: 49

Yes [A01]

417 G12Q011If cash and security movements are not simultaneous, please indicate the duration of the timing gap


Part icipant default rules and procedures (PFMI Principle 13)

422 G13Q004During the past three years, has there been a situation where a participant def aulted which resulted in asignif icant loss?

PFMI: Q.13.1.2AGC: 77

No [A02]

423 G13Q005How was the situation resolved? Or if you answered "Other," then please explain:



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424 G13Q006Does the stock exchange have def ault protections that extend to the CSD, such as the f ollowing?

PFMI: Q.13.1.2AGC: 80

_ Margin requirements f or stock exchange members

_ Guaranty f und f or stock exchange members

_ Financial requirements f or stock exchange membership

_ No


_ OTHER:



428 G13Q010Participant Def ault Protections Resulting f rom a Participant Failure. If a participant def aults, how is theloss covered? (Choose all that apply?)

PFMI: Q.13.1.4AGC: 76, 76d

_ CSD insurance covers the loss

_ The CSD guaranty f und covers the loss

_ Loss is shared among participants

_ Not applicable

✔️ OTHER: See below

429 G13Q011Please explain the process:


430 G13Q012Please explain the process of how the loss is shared:



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There is no loss that should be covered in case of participant's def ault

General business risk (PFMI Principle 15)

441 G14Q002Is a f inancial audit perf ormed by an Audit Firm, Regulatory Authority, or other external party?

PFMI: Q.17.2.3AGC: 15

Yes [Y]

442 G14Q003If yes, please state the name(s) of the entity(ies) who perf orm the f inancial audit.

PFMI: n/aAGC: 15a.

DELOITTE

443 G14Q004Please list the date of your last f inancial audit perf ormed by an Audit Firm, Regulatory Authority, orother external party:

PFMI: n/aAGC: 15b.

31/12/2018

444 G14Q005Please list the period that the audit covered:

PFMI: n/aAGC: 15c.

Start date: 01/01/2018End date: 31/12/2018

445 G14Q006How f requently does the f inancial audit occur?

PFMI: n/aAGC: 15d.

Annually [A02]


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446 G14Q007If less than annually, please explain:

PFMI: n/aAGC: 15e.

447 G14Q008Please select the statement that most accurately characterizes the results of the last f inancial audit:

PFMI: n/aAGC: 15g.

No material exceptions f ound. [A01]

448 G14Q009If minor or material exceptions were f ound, what actions were taken? Please describe:

PFMI: n/aAGC: 15h.

449 G14Q010Has there been any material loss by the CSD during the past three years?

PFMI: n/aAGC: 86

No [A02]

450 G14Q011If there has been a loss, please describe the cause, the f inal impact and the action taken to prevent arecurrence:

PFMI: n/aAGC: 86a.

451 G14Q012Has the CSD been subject to any lit igation involving a participant during the past three years?

PFMI: n/aAGC: 87

No [A02]

452 G14Q013Please explain the circumstances and resolution:

PFMI: n/aAGC: 87a.

453 G14Q014


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Has the CSD realized revenues suf f icient to cover expenses during the past three years?

PFMI: n/aAGC: 88, 88a

Yes f or all three years [A01]

454 G14Q015Has any participant suf f ered any losses in the past three years due to the CSD's perf ormance?

PFMI: n/aAGC: 30, 30m

Other: Claims f rom clients are handled on a case by case basis and may lead to payment or notdepending on ESES liability. Payments may also be ef f ected by the CSD on a goodwill basis, withoutacknowledgement of liability. Figures are not made public.

455 G14Q016If yes, please select all of the f ollowing in which loss has occurred. You will be prompted to enter thenumber of instances and total loss in USD thereaf ter.

PFMI: n/aAGC: 30a, 30j

_ Corporate Action

_ Settlement Process - Securit ies

_ Settlement Process - Cash

_ System Outage

_ OTHER:

456 G14Q017Corporate Action. Please specif y number of instances:

PFMI: n/aAGC: 30b.

457 G14Q018Corporate Action. Please specif y total loss in USD:

PFMI: n/aAGC: 30c.

N/A

458 G14Q019Settlement Process - Securit ies. Please specif y number of instances:

PFMI: n/aAGC: 30d.


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459 G14Q020Settlement Process - Securit ies. Please specif y total loss in USD:

PFMI: n/aAGC: 30e.

N/A

460 G14Q021Settlement Process - Cash. Please specif y number of instances:

PFMI: n/aAGC: 30f.

461 G14Q022Settlement Process - Cash. Please specif y total loss in USD:

PFMI: n/aAGC: 30g.

N/A

462 G14Q023System Outage. Please specif y number of instances:

PFMI: n/aAGC: 30h.

463 G14Q024System Outage. Please specif y total loss in USD:

PFMI: n/aAGC: 30i.

N/A

464 G14Q025For Other, please specif y number of instances:

PFMI: n/aAGC: 30k.

N/A


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465 G14Q026For Other, please specif y total loss in USD:

PFMI: n/aAGC: 30l.

N/A

469 G14Q030Does the CSD maintain a reserve f or operating losses?

PFMI: Q.15.2.1AGC: 89, 89b

Yes [A01]

472 G14Q033Please describe and indicate reserve (f or operating losses) amount:

PFMI: Q.15.2.2AGC: 89a.

Under the Internal Capital Adequacy Assessment Process (ICAAP), ESES CSDs are assessing the levelof capital that is reserved to cover operational risks, using the Standardised Approach (TSA) (i.e. 18%of the average gross income over three preceding years). Amounts are the f ollowing in 2019: EF: 25 € ;ENL: 5 M€ ; EBE: 3 M€

Custody risk (PFMI Principle 16)

486 G15Q003Are there any activit ies perf ormed by a third party on behalf of the CSD f or the CSD participants (e.g.,vaulting of physical securit ies, registration, entit lement processing, etc.)?

PFMI: Q.16.1.1AGC: 29, 29i

_ Yes

_ No

_ Not applicable

✔️ OTHER: No outsourcing of depository f unctions f or ENL and EBE and YES f or EF whichoutsources the vaulting of physical securit ies to EBE.

487 G15Q004If third parties are employed, please indicate which services they supply:

PFMI: Q.16.1.1AGC: 29a.


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488 G15Q005If third parties are employed, does the CSD assume liability f or losses incurred by participants as aresult of the actions/inactions of the third parties?

PFMI: Q.16.1.1AGC: 29b.

Yes [Y]

489 G15Q006If you acknowledge responsibility, please indicate whether your responsibility is assumed

PFMI: Q.16.1.1AGC: 29c, 29e.

_ regardless of whether such loss was caused by any action or inaction of the agent

_ if such loss was caused by the agent's action or inaction and such action or inaction was deemedto be negligence on the part of the agent

_ if such loss was caused by the agent's action or inaction and such action or inaction was deemedto be gross negligence on the part of the agent

_ if the loss was caused by the willf ul def ault or other willf ul conduct on the part of the agent

✔️ OTHER: Under the ESES Terms & Conditions (Book 1), it is provided that: 6.3.4 The CSD shall onlybe liable f or any Liabilit ies suf f ered or incurred by the Client as a result of any act or omission of (or adef ault Event af f ecting) any Sub-Custodian or Foreign CSD, including if such Sub-Custodian or ForeignCSD is an Other Euroclear Company, if , and to the extent that, (i) the CSD has been negligent in theselection or the supervision of the Sub-Custodian or Foreign CSD; or (ii) the CSD has recovered anyamount f rom the Sub-Custodian or Foreign CSD under the contractual documentation the CSD has inplace with the Sub-Custodian or Foreign CSD. 6.3.5 Unless the CSD has been negligent in the selectionor supervision of the Sub-Custodian or Foreign CSD, the liability of the CSD under Section 6.3.4 shallbe limited to the amount recovered f rom the Sub-Custodian or Foreign CSD af ter deduction of anyreasonable cost or expense in making, or attempting to make, such recovery. In all instances, anyamount which the Sub-Custodian or Foreign CSD may have applied by virtue of set-of f on the amountto which the CSD was entit led shall be added to the amount ef f ectively recovered by the CSD.

490 G15Q007If you acknowledge responsibility f or agents, your responsibility is assumed f or losses

PFMI: Q.16.1.1AGC: 29d, 29h.

_ without limit

_ which are not consequential losses

_ subject to a monetary limit not based on insurance limits

_ subject to a monetary limit based on insurance limits

✔️ OTHER: NA

491 G15Q008Please specif y limit:

PFMI: Q.16.1.1AGC: 29f.


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492 G15Q009Please specif y limit:

PFMI: Q.16.1.1AGC: 29g.

497 G15Q014Please describe brief ly the arrangements / procedures / f acilit ies you maintain to ensure that eligiblesecurit ies held at the CSD are handled at least as ef f iciently as compared to securit ies held outside theCSD, particularly in relation to income, corporate actions and proxy services.

PFMI: Q.16.3.1AGC: 62

ESES CSDs use the same automated processes (STP) f or securit ies held at or outside the system,and ensure procedures in place cope with local processes used by f oreign depositories, in order toguarantee timely payments and proper processing of corporate actions.

Operat ional risk (PFMI Principle 17)

515 G16Q011Internal Audit. Is an internal audit undertaken in your CSD?

PFMI: Q.17.2.3AGC: 14

Yes [Y]

516 G16Q012If yes, what areas does the audit cover (f inancials, operations, etc.) and which department in your CSDhandles it?

PFMI: Q.17.2.3AGC: 14a.

Our internal ESES audit covers Operations and the support services outsourced to Euroclear SA/NV(IT, Finance, Human Resources, Risk Management, Commercial, Product, Legal, Projects) and EuroclearBank (Collateral management, Network Management). All audits are handled by the Internal AuditDivision.

517 G16Q013Please list the date of your last internal audit and the period that the audit covered:

PFMI: Q.17.2.3AGC: 14b.

Start date: 01/01/2019End date: 06/05/2019Audit date: 06/05/2019


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518 G16Q014How f requently does the internal audit occur?

PFMI: Q.17.2.3AGC: 14c.

Two or more times a year [A01]


PFMI: Q.17.2.3AGC: 14d.

520 G16Q016Are the results of the internal audit publicly available?

PFMI: Q.17.2.3AGC: 14e.

No [N]

521 G16Q017Please select the statement that most accurately characterizes the results of the last internal audit:

PFMI: Q.17.2.3AGC: 14f.



PFMI: Q.17.2.3AGC: 14g.

524 G16Q020Is an operational audit perf ormed by an Audit Firm, Regulatory Authority, or other external party?

PFMI: Q.17.2.4AGC: 16

Yes [Y]

525 G16Q021If yes, please state the name(s) of the entity(ies) who perf orm the operational audit.

PFMI: Q.17.2.4AGC: 16a.

DELOITTE


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526 G16Q022Please list the date of your last operational audit perf ormed by an Audit Firm, Regulatory Authority, orother external party:

PFMI: Q.17.2.4AGC: 16b.

31/12/2018

527 G16Q023Please list the period that the audit covered:

PFMI: Q.17.2.4AGC: 16c.

Start date: 01/01/2018End date: 31/12/2018

528 G16Q024How f requently does the operational audit occur?

PFMI: Q.17.2.4AGC: 16d.

Annually [A02]


PFMI: Q.17.2.4AGC: 16e.

530 G16Q026Please select the statement that most accurately characterizes the results of the last operational audit:

PFMI: Q.17.2.4AGC: 16g.



PFMI: Q.17.2.4AGC: 16h.

538 G16Q034How is access to the physical building controlled?


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PFMI: Q.17.5.1AGC: 74

✔️ By guards

✔️ By electronic keys

_ personal ID card

✔️ By alarm system

_ OTHER:


PFMI: Q.17.5.1AGC: 74a.

542 G16Q038Regarding data security: Are passwords used by participants to access their accounts?

PFMI: Q.17.5.3AGC: 71 71a.

Yes [A01]

543 G16Q039Does each user have a unique user ID?

PFMI: Q.17.5.3AGC: 71c.

Yes [A01]

544 G16Q040Are passwords regularly changed?

PFMI: Q.17.5.3AGC: 71e.

Yes [A01]

545 G16Q041How of ten?

PFMI: Q.17.5.3AGC: 71f.

At least every month, or even every minute f or applications requiring ‘security ID' card.

546 G16Q042Is there a user lock-out af ter a pre-set number of unsuccessf ul User ID attempts?


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PFMI: Q.17.5.3AGC: 71h.

Yes [A01]

547 G16Q043How many?

PFMI: Q.17.5.3AGC: 71i.

3

551 G16Q047How quickly can the main system be reactivated in the event of an outage?

PFMI: Q.17.6.2AGC: 82

1 - 4 hours [A01]

554 G16Q050Will the CSD publicly announce any system interruption?

PFMI: Q.17.6.4AGC: 84

Yes [A01]

555 G16Q051To whom will the CSD disclose any system interruptions?

PFMI: Q.17.6.4AGC: 84a.

✔️ To the CSD regulators

✔️ To all direct participants

_ To direct and indirect participants

_ To the public via the internet

_ In the press

_ OTHER:

556 G16Q052If so, please list webpage address:

PFMI: Q.17.6.4AGC: 84b.

557 G16Q053


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If so, please list all publications:

PFMI: Q.17.6.4AGC: 84c.


PFMI: Q.17.6.4AGC: 84d.

CCP (LCH.SA), National Central Bank, Market participants

559 G16Q055How will the CSD disclose any system interruptions?

PFMI: Q.17.6.4AGC: 84e.

✔️ By e-mail

_ By telephone

_ Public announcement

_ Press release

✔️ OTHER: Automated mail with an external crisis notif ication tool, message on the workstation.


PFMI: Q.17.6.4AGC: 84f.

Automated mail with an external crisis notif ication tool, message on the workstation.

562 G16Q058If a back-up system exists, how quickly can the back-up system be activated in the event of the mainsystem f ailing?

PFMI: Q.17.6.5AGC: 83

1 - 4 hours [A01]

566 G16Q062BUSINESS RECOVERY PLAN. This section is intended to identif y key aspects of the CSD's BusinessRecovery Plan (BRP), including testing requirements and past results, expected recovery time periods,and the independent review and validation (if any) of the BRP. Do you have a f ormal business recoveryplan?

PFMI: Q.17.6.8AGC: 81

Yes [Y]


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567 G16Q063Does your Business Recovery Plan include:

PFMI: Q.17.6.8AGC: 81a, 81h.

✔️ Back-up of all computer f iles

✔️ Of f -site data storage

✔️ Back-up f iles stored and locked

✔️ Of f -site operations f acility

✔️ OTHER: Euroclear's data centre strategy enables the recovery of computerized services f ollowinglocal or regional disasters. Euroclear operates two data centres at suf f icient distance to mitigate therisk that a single event halts operations. Sites are linked by real- t ime synchronous data mirroring andload balanced networks. The ef f ectiveness of the data centres' operational and recovery proceduresare tested through the transf er of production activity between sites at least six t imes a year. A thirddata centre is located over three hundred kilometers f rom the primary and secondary sites to provide aregional disaster recovery capability by enabling the resumption of business crit ical services within thesame Business Day if a major incident af f ects the other two sites. The regional recovery capability istested annually

568 G16Q064Please identif y both the f requency and the last date of testing f or the f ollowing third party: CSDparticipants/members

PFMI: Q.17.6.8AGC: 81b.

Our IT disaster recovery tests are f ully transparent to the external world (participants / members),theref ore, there is no need to involve them in the testing. (see detailed description in 81h)

569 G16Q065Please identif y both the f requency and the last date of testing f or the f ollowing third party: Stockexchange

PFMI: Q.17.6.8AGC: 81c.

According to Euroclear internal policy, this Inf ormation cannot be disclosed f or security reasons.

570 G16Q066Please identif y both the f requency and the last date of testing f or the f ollowing third party: Centralbank

PFMI: Q.17.6.8AGC: 81d.


571 G16Q067


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Please identif y both the f requency and the last date of testing f or the f ollowing third party: Localbrokers

PFMI: Q.17.6.8AGC: 81e.


572 G16Q068Please identif y both the f requency and the last date of testing f or the f ollowing third party: Any otherthird party

PFMI: Q.17.6.8AGC: 81f.


573 G16Q069In the past three years, has it been necessary to activate the recovery plan in a live situation?

PFMI: Q.17.6.8AGC: 85

Other: According to Euroclear internal policy, this Inf ormation cannot be disclosed f or security reasons.

574 G16Q070If yes, how much time was needed to implement the recovery plan?

PFMI: Q.17.6.8AGC: 85a.

575 G16Q071How much time was needed to recover and restore business to normal operations?

PFMI: Q.17.6.8AGC: 85b.

576 G16Q072What was the impact to the market?

PFMI: Q.17.6.8AGC: 85c, 85d.

_ All securit ies settlements took place as scheduled on the same day with good value

_ All cash settlements took place as scheduled on the same day with good value

_ All securit ies settlements took place one business day late with good value

_ All cash settlements took place one business day late with good value

_ All securit ies settlements took place one business day late with value one day late


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_ All cash settlements took place one business day late with value one day late

_ All securit ies settlements took place more than one business day late

_ All cash settlements took place more than one business day late

_ As a result of the system f ailure, all f ines and penalties f or late settlements were waived

_ Even though there was a system f ailure, all f ines and penalties f or late settlements were stillassessed

_ OTHER:

577 G16Q073If no or other, please explain

PFMI: Q.17.7.4AGC: 40a.

579 G16Q075Are procedures and controls (f irewalls) in place to avoid systemic collapse or contamination if one ofthe linked entit ies should experience business interruptions f or whatever reason?

PFMI: Q.17.7.1AGC: 39

✔️ Yes

_ No

_ Not applicable

580 G16Q076Please explain



584 G16Q080Has a business interruption recovery plan been developed in the event the linkages should becomeinoperable f or any reason?

PFMI: Q.17.7.4AGC: 40

Yes [A01]

Access and part icipat ion requirements (PFMI Principle 18)

588 G17Q003Are prospective participants subject to an init ial review and approval process regarding compliance with


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eligibility requirements?

PFMI: Q.18.1.1AGC: 19

Yes [A01]

592 G17Q007What governs the relationship between the CSD and the participants?

PFMI: Q.18.2.2AGC: 20

✔️ Relevant law and regulation

✔️ Standard participation contract

✔️ Established terms and conditions of participation

_ By- laws of the CSD

_ Rules of the CSD

_ Not applicable

_ OTHER:



595 G17Q010PARTICIPANTS AND PARTICIPATION. The purpose of this section is to understand issues relating toparticipation in the CSD, including eligibility requirements, conditions of participation, and supervision ofparticipants. What types of entit ies are eligible to become participants and how many of each type arethere currently?

PFMI: Q.18.2.3AGC: 17, 17q

✔️ Banks

✔️ Brokers

_ Individuals

✔️ Foreign Institutions

_ Not applicable

✔️ OTHER: Pure Broker Dealers, indirect participant, Central banks, Ministries of Finance, Investmentcompanies, Caisse des depots et des consignations (EF), CSDs, non-SSS client Issuers (EF), CCPmembers, CCPs.


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596 G17Q011How many Bank participants are there currently? (then please answer 17b)

PFMI: Q.18.2.3AGC: 17a.

EBE: 77, EF: 212, ENL: 95)

597 G17Q012Please select the f eatures included in the eligibility requirements f or Banks.

PFMI: Q.18.2.3AGC: 17b, 17d

_ Financial Thresholds

_ Regulatory Oversight

_ Market Experience

✔️ OTHER: Banks established and regulated in the EU are considered eligible. Similar entit ies locatedoutside the EU are asked to provide f urther attestations/documentation to the CSD. The main eligibilitycriteria are: - Technical and operational capability - Monetary & Financial Code f or a participation in theSSS - Reputation in the Market- Anti-Money laundering Programme - Risk Assessment Detailsregarding eligibility requirements are described in the Operating rules, the ESES Terms and Conditionsand related admission policy.


PFMI: Q.18.2.3AGC: 17d.

599 G17Q014How many Broker participants are there currently? (then please answer 17f )

PFMI: Q.18.2.3AGC: 17e.

EBE: 51, EF: 14, ENL: 40

600 G17Q015Please select the f eatures included in the eligibility requirements f or Brokers.

PFMI: Q.18.2.3AGC: 17f, 17h



_ Market Experience

✔️ OTHER: Details regarding eligibility requirements are described in the ESES Terms and Conditionsoperating rules and related admission policy. The main eligibility criteria are: - Technical and operationalcapability - Monetary & Financial Code f or a participation in the SSS - Reputation in the Market- Anti-Money laundering Programme - Risk Assessment Details regarding eligibility requirements are described


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in the Operating rules, the ESES Terms and Conditions and related admission policy.

601 G17Q016How many Individual participants are there currently? (then please answer 17j)

PFMI: Q.18.2.3AGC: 17i.

602 G17Q017Please select the f eatures included in the eligibility requirements f or Individual participants.

PFMI: Q.18.2.3AGC: 17j.



_ Market Experience

_ OTHER:

603 G17Q018How many Foreign Institution participants are there currently?

PFMI: Q.18.2.3AGC: 17m.

EBE: 109, EF: 85, ENL: 121

604 G17Q019Please select the f eatures included in the eligibility requirements f or Foreign Institution participants.

PFMI: Q.18.2.3AGC: 17n, 17p.



_ Market Experience

✔️ OTHER: Details regarding eligibility requirements are described in ESES France Terms andConditions, operating rules and related admission policy. The main eligibility criteria are: - Technical andoperational capability - Monetary & Financial Code f or a participation in the SSS - Reputation in theMarket- Anti-Money laundering Programme - Risk Assessment

605 G17Q020If you have selected "Other entit ies" above, please explain:

PFMI: Q.18.2.3AGC: 17q.

Pure Broker Dealers, indirect participant, Central banks, Ministries of Finance, Investment companies,


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Caisse des depots et des consignations (EF), CSDs, non-SSS client Issuers (EF), CCP members,CCPs.

606 G17Q021Indicate how many "Other entit ies" are currently participants?

PFMI: Q.18.2.3AGC: 17r.

EBE: 13, EF: 94, ENL: 13

607 G17Q022Please select the f eatures included in the eligibility requirements f or the participants ref erred to aboveas "Other entit ies".

PFMI: Q.18.2.3AGC: 17s, 17u



_ Market Experience

✔️ OTHER: Details regarding eligibility requirements are described in ESES France Terms andConditions, operating rules and related admission policy. The main eligibility criteria are: - Technical andoperational capability - Monetary & Financial Code f or a participation in the SSS - Reputation in theMarket- Anti-Money laundering Programme - Risk Assessment

610 G17Q025Where can a description of the specif ic eligibility requirements f or Bank participants be f ound?

PFMI: Q.18.2.5AGC: 17c.

611 G17Q026Where can a description of the specif ic eligibility requirements f or Broker participants be f ound?

PFMI: Q.18.2.5AGC: 17g.

612 G17Q027Where can a description of the specif ic eligibility requirements f or Individual participants be f ound?

PFMI: Q.18.2.5AGC: 17k.


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613 G17Q028Where can a description of the specif ic eligibility requirements f or Foreign Institution participants bef ound?

PFMI: Q.18.2.5AGC: 17o.

614 G17Q029Where can a description of the specif ic eligibility requirements f or participants described above as"Other entit ies" be f ound?

PFMI: Q.18.2.5AGC: 17t.

615 G17Q030How does the CSD notif y participants of material changes to the conditions of participation?

PFMI: Q.18.2.5AGC: 22

✔️ By e-mail

_ By telephone

✔️ By public announcement

_ By press release

_ Not applicable

✔️ OTHER: Via the depository's website and via dedicated communication to User Committees andNewsletters.


PFMI: Q.18.2.5AGC: 22a.

Via the depository's website and via dedicated communication to User Committees and Newsletters.

618 G17Q033Who enf orces compliance with the CSD's conditions of participation?

PFMI: Q.18.3.1AGC: 23

✔️ The CSD

_ The exchange

✔️ The CSD's regulator


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_ Not applicable

_ OTHER:



620 G17Q035Does the CSD have f orms of oversight management f or assessing and monitoring of the f ollowing?

PFMI: Q.18.3.1AGC: 79

✔️ Participant eligibility requirements

_ Participant volumes

_ Participant f inancial strength

_ Other loss or def ault protections the CSD maintains

_ Collateral requirements f or participants

_ Debit caps f or participants

✔️ Settlement controls that minimize or eliminate the risk of def ault by a participant

✔️ Blocking of securit ies movement bef ore receipt of payment

✔️ Blocking payment until securit ies are moved

_ Not applicable

_ OTHER:

621 G17Q036Please explain other loss or def ault protections:


622 G17Q037Please explain the requirements:


623 G17Q038Please explain how these debit caps work:


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624 G17Q039What type or types of settlement controls

PFMI: Q.18.3.1AGC: 79d.

_ Blocking or f reezing of securit ies posit ions

_ Controlling DVP settlement

✔️ Simultaneous DVP

_ OTHER:


PFMI: Q.18.3.1AGC: 79e.


PFMI: Q.18.3.1AGC: 79f.


PFMI: Q.18.3.1AGC: 79g.

ESES of f ers a DVP settlement Model 1 (outsourced to T2S)

628 G17Q043Please identif y and explain:


629 G17Q044Please explain brief ly how these work:



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632 G17Q047What enf orcement actions are available to the enf orcement authority?

PFMI: Q.18.3.3AGC: 24

_ Fines

_ Restrictions on participation

✔️ Suspension of participation

✔️ Termination of participation

_ Not applicable

_ OTHER:



634 G17Q049Has there been any such enf orcement actions in the last three years?

PFMI: Q.18.3.3AGC: 25

No [N]

635 G17Q050If yes, please explain, including inf ormation relative to any suspensions of CSD participants:

PFMI: Q.18.3.3AGC: 25a.

Tiered part icipat ion (PFMI Principle 19)

Links (PFMI Principle 20)

652 G19Q004Please list all depositories or settlement systems to which you have an electronic link.

PFMI: Q.20.1.2AGC: 38

EBE - Euroclear Bank

ENL - Euroclear Bank


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EF - Iberclear, Maroclear, Euroclear Bank, NBB-SSS, Clearstream Banking Frankf urt and Monte T itoli

Eff iciency and effect iveness (PFMI Principle 21)

Communicat ion (PFMI Principle 22)

677 G21Q003Security Control. How do participants receive inf ormation (view actual settlement of trades, movementof securit ies on their accounts, etc.) and see the status of their accounts?

PFMI: Q.22.1.1AGC: 69

✔️ By direct electronic link

_ By receipt of physical account holding statements

_ Not applicable

_ OTHER:


PFMI: Q.22.1.1AGC: 69a.

679 G21Q005Do participants have access to af f ect their holdings, including conf irming and af f irming trades,movement of securit ies on their accounts, etc.?

PFMI: Q.22.1.1AGC: 70

Yes [A01]

680 G21Q006How is access given to participants?

PFMI: Q.22.1.1AGC: 70a.

✔️ By direct electronic link

✔️ OTHER: DEDICATED SECURED NETWORK

681 G21Q007Please select type of electronic link:


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PFMI: Q.22.1.1AGC: 70b.

_ Dial-up modem

✔️ Secured, leased, dedicated telephone line

✔️ Internet

_ Fax


PFMI: Q.22.1.1AGC: 70c.

Dedicated secured network

683 G21Q009Does the CSD communicate with other market entit ies such as stock exchanges, payment systems,clearing houses, etc., by secured linkages?

PFMI: Q.22.1.1AGC: 72

Yes [A01]



CCP LCH.SA, National Central Banks, ECB f or T2S.

685 G21Q011How does the CSD communicate with Stock Exchanges?

PFMI: Q.22.1.1AGC: 73 73a

_ Dial-up modem

_ Secured, leased, dedicated telephone line

_ Internet

_ Fax


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_ Paper

_ other


_ OTHER:

686 G21Q012How does the CSD communicate with Payment Systems?


_ Dial-up modem


_ Internet

_ Fax

_ Paper

_ other

_ Not applicable

_ OTHER:

687 G21Q013How does the CSD communicate with Clearing Houses?


_ Dial-up modem


_ Internet

_ Fax

_ Paper

_ other

_ Not applicable

_ OTHER:

688 G21Q014How does the CSD communicate with Registrars?



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_ Dial-up modem

_ Secured, leased, dedicated telephone line

_ Internet

_ Fax

_ Paper

_ other


_ OTHER:

Transparency and disclosure (PFMI Principle 23)

713 G22Q020Capital. Are annual f inancial statements publicly disclosed?

PFMI: Q.23.5.3AGC: 13

Yes [A01]

714 G22Q021If yes, the AGC requests a copy of the institution's annual report. Is the annual report availableelectronically?

PFMI: Q.23.5.3AGC: 13a.

Yes [Y]

715 G22Q022f ilecount - If yes, please upload the document(s) here or insert web link(s) in question 13d:

PFMI: Q.23.5.3AGC: 13b.

0

716 G22Q023f ilecount - If more than one document f or 13b, please upload the additional document here:

PFMI: Q.23.5.3AGC: 13c.

0

717 G22Q024Please insert web link(s) f or 13b here:

PFMI: Q.23.5.3AGC: 13d.


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https://my.euroclear.com/eses/shared/en/ref erence/due-diligence.html

https://www.euroclear.com/investorrelations/en/annual-reports.html

718 G22Q025If no, and annual report and/or f inancial statements are not disclosed, please state your share capital,reserves, and retained earnings (or equivalents as determined under local accounting standards). ShareCapital (then please answer 13f ):

PFMI: Q.23.5.3AGC: 13e.

719 G22Q026Reserves (then please answer 13g):

PFMI: Q.23.5.3AGC: 13f.

720 G22Q027Retained Earnings:

PFMI: Q.23.5.3AGC: 13g.

722 G22Q029AGC members f rom time to t ime receive requests f rom their direct investor-clients f or an inf ormationalcopy of a CSD's completed questionnaire. Such requests typically lead to interactions betweenpersonnel at the CSD in question and member personnel or client personnel, or both. Thoseinteractions take time and impose costs on both members and depositories. Do you approve of AGCmembers delivering a copy of your completed questionnaire to the member's direct client in response tothe client's request?

PFMI: Q.23.5.4AGC: 100

Yes [Y]

723 G22Q030Are the results of the f inancial audit publicly available?


Yes [Y]

724 G22Q031Are the results of the operational audit publicly available?


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Yes [Y]

Compliance with SEC Rule 17f-7

727 G23Q001

Rule 17f -7, by ref erence to Rule 17f -4, requires that, f or a CSD to be eligible to hold securit ies of U.S.registered investment companies (such depositories hereinaf ter ref erred to as “EligibleSecurit ies Depositories”), the CSD must be a “system f or the central handling of securit ies where allsecurit ies of any particular class or series of any issuer deposited within the system are treated asf ungible and may be transf erred or pledged by bookkeeping entry without physical delivery of thesecurit ies.”

Are all securit ies of a particular class or series of any issuer that are deposited in your institutiontreated as f ungible, and can they be transf erred or pledged by bookkeeping entry without physicaldelivery of the securit ies?

PFMI: n/aAGC: 1

Yes [Y]

728 G23Q002Please explain

PFMI: n/aAGC: 1a

Securit ies of a particular class or series of any issuer that are deposited in our institution are treatedas f ungible, and can be transf erred bookkeeping entry without physical delivery of the securit ies. Thepledge is not applicable.

729 G23Q003Rule 17f -7 also requires that an Eligible Securit ies CSD “acts as or operates a system f or the centralhandling of securit ies or equivalent book-entries in the country where it is incorporated,” or “acts as oroperates a transnational system f or the central handling of securit ies or equivalent book-entries.”Does your institution:

PFMI: n/aAGC: 2

✔️ Act as or operate a system f or the central handling of securit ies or equivalent book-entries in thecountry where it is incorporated?

_ Act as or operate a transnational system f or the central handling of securit ies or equivalent book-entries?

_ Act in another capacity with respect to the handling of securit ies or equivalent book-entries?

_ Not applicable


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_ OTHER:


PFMI: n/aAGC: 2a.

731 G23Q005Please specif y the types of securit ies f or which you act as or operate a system f or the central handlingofsecurit ies or equivalent book-entries:

PFMI: n/aAGC: 2b.

EBE: Euroclear Belgium manages a wide range of Belgian or f oreign securit ies such as equities,corporate bonds, warrants, commercial paper, ETFs and investment f unds.

EF: Euroclear France manages a wide range of French and f oreign securit ies a.o. government /corporates bonds, listed equities, short term papers, warrants, Funds, Treasury bills, ETF (ExchangeTraded Funds),...).

ENL: Euroclear Nederland manages a wide range of Dutch and f oreign equities, government andcorporate bonds, warrants, money market instruments, ETF, Treasury bills and Investment f unds,strips

732 G23Q006Rule 17f -7 requires that an Eligible Securit ies Depository regulated by a f oreign f inancial regulatoryauthority as def ined under section 2(a)(50) of the Act, with section 2(a)(50) establishing that z'f oreign f inancial regulatory authority' means any (A) f oreign securit ies authority, (B) othergovernmental body or f oreign equivalent of a self - regulatory organization empowered by a f oreigngovernment to administer or enf orce its laws relating to the regulation of f iduciaries, trusts, commerciallending, insurance, trading in contracts of sale of a commodity f or f uture delivery, or other instrumentstraded on or subject to the rules of a contract market, board of trade or f oreign equivalent, or otherf inancial activit ies, or (C) membership organization a f unction of which is to regulate the participationof its members in activit ies listed above.” Who regulates the activit ies of the CSD?

PFMI: n/aAGC: 8

✔️ A governmental body or regulatory organization empowered to administer or enf orce laws relatedto securit ies matters.

✔️ A governmental body or self - regulatory organization empowered to administer or enf orce lawsrelated to other f inancial activit ies.

_ A membership organization which regulates the participation of its members in securit ies matters orother f inancial activit ies.

_ OTHER:


PFMI: n/a


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AGC: 8a.

734 G23Q008Please provide the name of regulatory authority(ies) identif ied in question 8:

PFMI: n/aAGC: 9

For EBE: National Bank of Belgium (NBB) and Financial Services and Markets Authority (FSMA). For EF:Autorité des Marchés Financiers (AMF) and Banque de France (BdF). For ENL: Autoriteit FinancieleMarkten (AFM) and De Nederlandsche Bank (DNB)

735 G23Q009Rule 17f -7 requires that an Eligible Securit ies Depository is subject to periodic examination byregulatory authorit ies or independent accountants. Is the CSD subject to periodic examination by:

PFMI: n/aAGC: 10

✔️ Regulatory authorit ies?

✔️ Independent accountants?

_ OTHER:


PFMI: n/aAGC: 10a

737 G23Q011Name of Authority #1 (please answer 11a):

PFMI: n/aAGC: 11

For EBE: National Bank of Belgium (NBB) f or EF: AMF (Autorité des Marchés Financiers), For ENL:Autoriteit Financiele Markten (AFM)

738 G23Q012What enf orcement actions are available to regulatory authority #1 f or breach of applicable statute orregulatory requirements?

PFMI: n/aAGC: 11a.

✔️ Fines

✔️ Restrictions on CSD activit ies.

✔️ Suspension of CSD activit ies.

✔️ Termination of CSD activit ies.


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✔️ OTHER: For EBE: Financial Services and Markets Authority (FSMA). For ENL: De NederlandscheBank (DNB)


PFMI: n/aAGC: 11b.

740 G23Q013AName of Authority #2:

741 G23Q014What enf orcement actions are available to regulatory authority #2 f or breach of applicable statute orregulatory requirements?

PFMI: n/aAGC: 11c.

✔️ Fines

✔️ Restrictions on CSD activit ies.

_ Suspension of CSD activit ies.

✔️ Termination of CSD activit ies.

_ OTHER:


PFMI: n/aAGC: 11d.

743 G23Q016Has there been any use of such enf orcement actions in the last three years?

PFMI: n/aAGC: 12

✔️ Yes

✔️ No

_ OTHER:

744 G23Q017


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If yes, please explain:

PFMI: n/aAGC: 12a.

745 G23Q018Has the regulatory body with oversight responsibility f or the CSD issued public notice that the CSD isnot in current compliance with any capital, solvency, insurance or similar f inancial strength requirementsimposed by such regulatory body?

PFMI: n/aAGC: 90

No [A02]


PFMI: n/aAGC: 90a.

747 G23Q020In the case of such a notice having been issued, has such notice been withdrawn, or, has the remedyof such noncompliance been publicly announced by the CSD?

PFMI: n/aAGC: 90b.

748 G23Q021If yes, please describe:

PFMI: n/aAGC: 90c.

749 G23Q022If no, why not?

PFMI: n/aAGC: 90d.

750 G23Q023Rule 17f -7 requires that an Eligible Securit ies Depository holds assets f or the custodian thatparticipates in the system on behalf of the Fund under saf ekeeping conditions no less f avorable thatthe conditions that apply to other participants. Please conf irm that assets of f oreign investors held bycustodians as participants in the CSD are held under saf ekeeping conditions no less f avorable than theconditions that apply to other participants.

PFMI: n/aAGC: 21

Yes [A1]


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751 G23Q024If no, other or not applicable, please explain:

PFMI: n/aAGC: 21a.

752 G23Q025Please conf irm the basis f or the arrangements you have in place to ensure that the assets you holdf or custodians receive the same level of saf ekeeping protection as the assets held f or othercategories of participants.

PFMI: n/aAGC: 21b, 21c.

✔️ Relevant Law and Regulation

_ Standard participation contract

✔️ Established terms and conditions of participation

_ By- laws of the CSD

✔️ Rules of the CSD

_ OTHER:

753 G23Q027For each item in Question 21b that you checked, please brief ly supply ref erences or citations to thelaw(s), regulation(s), or CSD rule(s), participation condition(s), or participant contract provision (s), asapplicable.

PFMI: n/aAGC: 21d

EBE: Euroclear Belgium does not make any dif f erence in the way or level of assets saf ekeepingprotection on the category of participant, being custodian or other. Asset protection is guaranteed bythe Royal Decrees n°62 (see detail under answer 7).

EF: Euroclear France does not make any dif f erence in the way or level of assets' saf ekeepingprotection on the category of participant, custodian or other (see detail under answer 7).

ENL: Euroclear Nederland does not make any dif f erence in the way or level of assets' saf ekeepingprotection on the category of participant, custodian or other. Asset protection is guaranteed by theSecurit ies Giro Act (see detail under answer 7).

754 G23Q028Rule 17f -7 requires that an Eligible Securit ies Depository provides periodic reports to its participantswith respect to its saf ekeeping of assets, including notices of transf ers to or f rom any participant'saccount. Does the CSD make available periodic saf ekeeping reports to participants, including notices oftransf ers to or f rom the participant's account?

PFMI: n/aAGC: 46


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Yes [A01]

755 G23Q029If no or other, please explain

PFMI: n/aAGC: 46a.

756 G23Q030If yes, please indicate the scheduled f renquency:

PFMI: n/aAGC: 46b, 46c.

✔️ Daily

_ Weekly

_ Monthly

_ Quarterly

_ Annually

_ Upon request

✔️ OTHER: 10 years. ESES complies with Central Securit ies Depositories Regulation (CSDR) Article 29of the CSD 585 Regulations (EU) No 909/20144, under which all data in the scope of our CSDRoperations will be retained f or a period of 10 years.

Relevant RSSS recommendations

Appendices

765 G25Q002I am submitt ing up-to-date inf ormation in response to:


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Documents

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