Clause No

Clause Heading

Amendment(s)

n/a

TERMS AND CONDITIONS

We have taken the chance to specify that specific Product T&Cs may exist for particular products and will always take precedence in case of a collision with the generic Corporate T&Cs, as they are more regularly updated.

We are also noting that a copy of the current T&Cs is available on www.alphabanklondon.co.uk

n/a

DEFINITIONS

To provide additional clarity, we have updated and amended the following definitions: Electronic Deposit; Mandate and Rent Deposit Account.

We have also added new definitions for better clarification regarding the following: Clearing Agent; Correspondent Bank; Direct Debit; Direct Debit Guarantee Scheme; Fixed Deposit Account; Foreign Exchange; Notice Account; Remitter; Remitting Bank; and Signing Authorities.

1

General

We articulated our right to refuse the opening of an account, along with the potential change of the minimum required amount from time to time. More information is available on www.alphabanklondon.co.uk

Further information on Investments can be found in the Bank’s Terms of Business.

3

Account Management

We have moved the parts which refer to the process after the death of a sole Trader, or an individual who is part of a Partnership, Charity, Limited Company, or Corporate Entity account to Clause 33.

Furthermore, we added a new clause stating that our corporate clients will have a 30-day notice period to inform us about any changes to their provided information.

Lastly, we moved the last clause, about the statements sent from the Bank to section 6 titled “Statements”.

4.3

Credit Interest

We have changed our “Clearing Agent” from HSBC to NatWest.

We also provided clarification on amending the interest rates due to a change in the Base Rate of BoE and any other Central Bank.

Further we erased the changes in LIBOR and other money market rates as reasons for our Bank to amend its rate of interest.

Lastly, we provided reference to the Key Product Information for the minimum amount to be placed on a Fixed Deposit Account and for the minimum amount required to request a bespoke credit interest rate, which can be found on our website (www.alphabanklondon.co.uk/fixed-deposits).

5

Bank Charges

We have added that in the case in which ABL considers that there should be an additional fee for operating an account, this will be dealt with on a case-by-case basis.

6

Statements

We have amended the “Direct Debit Scheme” to “Direct Debit Guarantee Scheme”.

We also moved here the clause about the statements, which will be sent from the Bank to the various Business Addresses.

7

Accounts operated by more than one person

We clarified that the individuals from whom we may receive instructions are only authorized ones.

For better dispute resolution in the case of an Account being operated by more than one person, we have added a clause allowing us to insist on providing joint instructions regarding how we should move forward to have everyone’s consent.

8

Responsibility for unauthorised Payment Transactions

We clarified that in case of you failing to comply with the requirements of clause 18 “Reporting of lost means of payment”, you will be liable for all the losses incurred.

9

Responsibility for incorrectly executed Payment Transaction

We have added two clauses referring to the client’s obligation to advise the Bank about which Payment Service wishes to use and the information that should be contained in the Payment Instruction. For more information refer to the “Payment Instruction Information”.

12

Right to set off

We have clarified that if we have to exercise our right of set-off, we will try whenever possible to notify you in advance.

13

Inactive Accounts

We have amended the minimum period of no transactions on the account in order to be characterized as “inactive” from “1 or 2 years” to “1 to 3 years”. We also added for clarification purposes that if an account is classified as inactive, the account owner will not be able to deposit money, make payments, or withdraw funds from it.

In the case that an account is classified as “dormant” (inactive for 15 years), to reactivate the account the account owner needs to provide fresh identification evidence and satisfy all necessary due diligence requirements as also required for inactive accounts. That clause substituted the previous rights which we were given to our “dormant” account customers, which have now been erased.

Finally, we added a new clause for the case in which a company becomes dissolved or struck off, any balances belonging to such company will be forwarded to the Government’s Bona Vacantia Division.

16

Paying Cheques into your Account

Following the change of our “Clearing Agent” from HSBC to NatWest, we have updated the information on interest and funds’ availability whenever a cheque is deposited into your Account.

We have also clarified that by bank offices, we mean Alpha Bank Group’s branches, which are located outside of the UK.

17

Clearing Cheques

We clarified that a chequebook may be issued upon request for Current Accounts in Pounds Sterling.

19

Electronic Payments

In the “Internal Transfer” explanation we have clarified that the fund transfer on the same Business Day between two accounts refers only to same currency transactions.

20

Payments made into your Account by mistake or Fraud

We have amended the distinguishing period within which a mistaken payment took place before the Bank becomes aware of it and acts accordingly, from 2 to 13 months.

21.1

Payment Instructions to be executed by CHAPS/SWIFT/ Faster Payments/Standing Orders/Internal Transfers

We included the requirement of all payment instructions to be in accordance also with Clause 25 and we amended the “signing rules” to “Signing Authorities”.

Moreover, we amended the times by which we will be making the payments in GBP, USD, and EEA currency on the same day. Specifically:

i.                payments in USD via SWIFT changed from 3.30pm to 3pm

ii.               payments in GBP via standing order changed from 4.30pm to 3pm and

iii.              payments in either GBP, USD or EEA currency via internal transfer changed from 4.30pm to 3.30pm.

21.2

Payment Instructions to be executed by Direct Debit

We clarified that Payment Instructions may have been received by the Bank, not only on the Business Day when the Recipient’s bank requests the payment from the Bank, but may also have been received in advance.

21.3

Refusal of Payment Instructions

We have expanded upon the reasons for the Bank not following a payment instruction a Client may have issued, along with a clarification regarding the process that the Bank will follow in such a case.

We have also clarified that the only occasion in which the Bank may be held responsible for delays and losses is if the causing circumstances could have been reasonably anticipated.

22

Payment Services

We clarified the execution process for “Same Day” and “Next Day” payment services in the cases that the recipient is either in the UK, or within the EU/EEA, or outside the EU/EEA.

23

Specific conditions applicable to the Payment Services

We clarified that the prevailing exchange rate will be applied for payment instructions up to £5,000 or currency equivalent, but always with prior notice.

We also added a clause explaining the Bank’s “Confirmation of Payee (“CoP”)” process via NatWest Bank and your ability to opt-out, should you wish to.

24

Direct Debit Scheme

We amended the clause heading from “Direct Debit” to “Direct Debit Scheme” and we clarified that any refund you may be eligible to get by the organization or by the Bank, falls under the “Direct Debit Guarantee Scheme”.

25

Information to be provided by the Client when submitting a Payment Instruction

We have specified that in the case where the Payment Service has not been clarified, then the Payment Transaction will be processed using either the Same Day or the Next Day Payment Service.

We added a clause that, where possible, Payment Instructions should be sent to the Bank in English.

26

Revocation or amendment of a Payment Instruction

We added two clauses on amendments to Payment Instructions, one about the unpermitted amendment of an Instruction after its execution and another one about the case of refund to an already executed transaction.

27

Electronic Deposits received by a Client

We amended the cut-off time for receiving electronic deposits so that we can credit those in your Account from 5pm to 4.30pm on a Business Day. We also expanded the options offered to you in case you receive an Electronic Deposit in a currency that you don’t have an account in.

Furthermore, we have added a new clause to explain the Remitting process when electronic payments are made and how the various charges should be applied.

28

Foreign Exchange

This is a new section explaining the process of how we will be executing foreign exchange instructions. For daily exchange rates, clients can refer to our website https://alphabanklondon.co.uk/fx-rates-2, or speak to their Relationship Manager.

30

Accessibility

This is a new section explaining that if you are affected by a condition, you ought to notify us, so we may support you in operating your account.

31

Ending the agreement

We have added a clause to explain that the Bank will accept closing instructions signed in line with the Signing Authorities of the Account.

We have added another clause stating that if the balance of the account falls below the sum of 50,000 in any currency, it will rest on our discretion to close your account with 2 months’ prior notice.

We have also added two clauses to specify that the Bank reserves the right to end this agreement (or stop providing services or close your accounts) either in the case of a change in the Bank’s risk rating appetite, or in cases where a client may demonstrate violent behavior -verbal or physical- to the Bank’s members of staff. In each case we will give 2 months’ prior notice.

32

Right to cancel an Account or a service

We have restricted the list of accounts that you can cancel within 14 calendar days to erase Margin Accounts.

We have added a new clause to allow early withdrawals in Fixed Deposit Accounts in cases of financial hardships, provided that supporting documentation is provided.

33

Death of a customer

This is a new clause which contains previously published sub-clauses from clause 3 “Account Management”. We explain what happens in the case of death of a sole trader, or an individual who is a member of a Partnership, Charity, Limited Company, or Corporate Entity. For further information please refer to our website https://alphabanklondon.co.uk/deceased

36

Complaints

We have clarified the process of receiving your complaint(s) and the timescale within which we will act and stay in touch with you.

39

Deposits and Investments Protection

We have added a clause about Investments’ protection up to a total of £85,000 compensation per person. For more information please refer to our Bank’s Terms of Business document, which can be found on our website.