mBank implements a compliance policy. Its goal is to ensure that the Bank complies with legislation and standards applicable to financial institutions. mBank’s compliance policy has a special focus on the following issues:

• prevention of money laundering and terrorist financing;
• appropriate handling of confidential information;
• protection of personal data;
• supervision of legal compliance in the brokerage and custody business;
• avoidance of conflicts of interest;
• compliance with rules of giving and accepting gifts by Bank executive officers and employees;
• verification of legal compliance under outsourcing agreements signed by the Bank;
• obligatory publication and reporting to relevant regulators on events in the operation of the Bank;
• advisory to organisational units of the Bank on compliance with new and existing legislation and market standards.

The compliance function is performed by a dedicated organisational unit, the Compliance Department.

Under the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (“The USA Patriot Act”), adopted following the terrorist attacks of 11 September 2001 and signed into law by President Bush on 26 October 2001, banks with a seat in the USA (i.e., local US banks and US branches and affiliates of banks from outside the USA) are required to obtain from each of their correspondent banks US Patriot Act Certification whereby the bank confirms the place of its physical seat, states that it does not co-operate with shell banks (banks without a physical seat) and does not make its accounts available to other banks for settlement of their operations and that it has its financial supervision, informs about the ownership structure, and appoints a process agent.

mBank S.A. co-operates with many banks with a seat in the USA, and has consequently published on its website (like other banks including Commerzbank) a duly signed certificate in compliance with the requirements of the US Patriot Act. It can be used by each bank which needs the certification for its files (which does not require any additional exchange of letters or the completion of a separate questionnaire to be sent to the bank requiring certification).

In this section please find certification pursuant to Sections 5318(j) and 5318(k) of Title 31 of the United States Code, as added by sections 313 and 319(b) of the USA PATRIOT Act of 2001 (Public Law 107-56).

The attached Certification may be used by any Financial Institution (as defined in the USA Patriot Act) that requires a Certification from mBank S.A.