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ASSET SAFEGUARDING POLICIES

  • In compliance with the applicable regulations, EST has taken appropriate measures to safeguard the property rights of their Customers. These measures are contained in EST's Policy for Safeguarding Assets, which is summarized below:

    1. Distinction between own assets and customer assets . EST has established in its computer system, a securities account structure that allows our own financial instruments account to be distinguished from the Customers' financial instruments, and within it, identifies the assets owned by each of them.

    2. Account Reconciliation. EST guarantees the accuracy of the internal records of financial instruments owned by the customers with regard to third parties who possess them, making the necessary reconciliation processes with regards to the type of financial instrument and the type of market (national or international).

    3. Selection of sub-custodians. EST uses the correspondent bank platforms as the custodian for settlement and custody operations in the various international markets where their customers operate. The criteria for selection of these sub-custodians are: recognized prestige, experience and reliability worldwide, based in countries with specific regulations and supervision on the holding and safekeeping of financial instruments, high volumes of custody in their markets.

    4. Non-use of customer financial instruments. EST, in compliance with the provisions of Article 19 of Directive 2006/73/EC, does not use financial instruments held by them on behalf of their Customers, to finance its own operations. The movements of financial instruments are based solely on instructions made by customers.

    5. Monitoring compliance with the Policy. EST has designed a system of controls to analyze compliance with this Policy.

    6. Transparency. EST will provide its customers with additional information on relevant aspects of asset safeguard material via two routes:

    7. Guarantee system. EST is integrated into the Deposit Guarantee Fund for Banking Institutions (Banks). This DGF is to insure deposits in money and financial instruments to the extent provided in the legislation.

 

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