Clause No

Clause Heading

Amendment(s)

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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 Personal 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

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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: Account Holder; Agent; Clearing Agent; Correspondent Bank; Data Retention Policy; Direct Debit; Direct Debit Guarantee Scheme; Fixed Deposit Account; Foreign Exchange; Minor(s); Notice Account; Privacy Notice; Remitter; Remitting Bank; Signing Authorities; Third Party Provider; Unarranged Overdraft and Unauthorised Act.

1

General

We added a new clause regarding the minor(s) – aged between 7 and 18 – who can become joint account holders with their parents and what will be the identification and the authorization process in such cases.

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.

2

Arranged and Unarranged Overdrafts

We have added a new clause about the fee we may charge in cases where an account owner asks the Bank to make a payment and the request is refused due to the lack of funds.

3

Account Management

We have moved the parts which refer to the process after the death of an Account Holder of a joint or sole account to Clause 33.

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

4

Interest on balances

We amended the clause heading from “Interest Rates”

4.2

Debit Interest

We changed the frequency in which the Interest on arranged and unarranged overdrafts will be charged from quarterly to monthly.

4.3

Credit Interest

We have added a new clause and a table describing the process in cases where interest is payable to a customer by the Bank on his/her account.

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 clarified that for direct debits in Pounds, the account owner’s rights of “UK Direct Debit Scheme” will be applicable.

We have also added three new clauses in order to inform our customers about how the Bank will be correcting mistakes in entries, about charges for sending additional statements and about messages that the Bank might send to customers along with their statements.

7

Accounts operated by more than one person

This is a new clause.

7.1

Instructions on an Account operated by more than one person

We specified the maximum number of persons to operate an account and also 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.

7.2

Borrowing on an Account operated by more than one person

This clause was added to reinstate that everyone named on the Account will be jointly and severally (that is both individually and together) bound by these Personal T&Cs.

7.3

Removing someone from an Account operated by more than one person

This clause was added to clarify the process for removing someone from an Account.

7.4

Information about Accounts operated by more than one person

This clause was added to inform customers that the Bank may disclose to any person operating the Account any holding information, such as historical statement information, etc.

9

Responsibility for incorrectly executed Payment Transaction

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

11

Communication

We added that the Bank will only communicate confidential email information via the Bank’s portal.

12

Right to set off

This clause was amended to inform the customers that the Bank may use their funds in one of their accounts to repay outstanding amounts which are due for payment in other accounts. If the liability is jointly owned, the Bank may set off money held in a sole account against that liability. If money standing to credit of an Account is denominated in a currency which is different from the currency in which a liability is denominated, the Bank may convert the credit balance to that other currency at the time of the set-off. If the Bank has to exercise its right of set-off, the customer will be notified 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.

14 & 15

Data Protection & Tax Reporting

We segregated the Clause “Data Protection and Tax Reporting” to two separate Clauses.

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 amended the cut-off time for revoking payment instructions relating to a Direct Debit from 5pm to 2pm.

We also added three clauses on amendments to Payment Instructions, one about the cut-off time for amendments to a Standing Order, another 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 three clauses. The first clause explains that the Bank will accept closing instructions signed in line with the Signing Authorities of the Account. The second clause specifies that an account will not close until all outstanding amounts to the Bank have been settled. The third new clause clarifies that, upon the account’s closure, customers will not be able to use them anymore, or any of the linked services and benefits.

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 added a new clause to allow early withdrawals in Fixed Deposit Accounts in cases of financial hardships and health issues, 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 an Account Holder of a joint or sole account. For further information please refer to our website https://alphabanklondon.co.uk/deceased

35

Contact Details

We have clarified that the Bank may contact any customer at the email address that he/she has provided.

We have added a clause to reinstate that the Bank has policies relating to the transmission of confidential data outside of the Bank and this includes emails to customers, in which cases all communications are encrypted.

There are two further clauses to make sure that customers are aware and agree that the Bank may message them on any type of device and that any telephone calls may be recorded.

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. We also added that the Financial Ombudsman Service can be contacted within 6 months from the date of any final response or decision. Full details on feedback or complaints can be found on the Bank’s website.

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.

40

Variations to the Terms

We amended the clause heading from “Amendments to the Terms” to “Variations to the Terms”.