Due diligence
at PrismaLife AG

1. Scope of due diligence obligations:

PrismaLife AG, as well as its employees and the intermediaries affiliated with it, are required under the Liechtenstein Due Diligence Act and the Liechtenstein Due Diligence Ordinance to identify and verify the identity of the contracting party and the beneficial owner.

2. The identity of the contracting party (= policyholder) must be established and verified upon conclusion of a new contract.

2.1 Natural Person

If the contracting party is a natural person, the intermediary shall inspect an official identification document of that person and record, in particular, the key details in the application form (including surname, first name, date of birth, address, nationality, profession/industry, the reason for taking out the insurance, tax domicile, and tax identification number (e.g. tax number, AHV number, TIN)).

The following are considered valid identification documents, which must be provided either in the original or as a certified copy:

a. valid passport;
b. valid identity card / national identity card;;
c. other valid official photo identification bearing a signature;
d. in exceptional cases, a current proof of identity issued by the competent local authority of the person’s place of residence is sufficient.

A certified copy is a copy of a conclusive document on which the intermediary confirms with their signature, their intermediary number and with place and date that they have inspected the original and that the copy matches the original. The intermediary transmits the certified copy immediately to PrismaLife AG.

Suggested wording:

"I hereby confirm that I have inspected the original of the valid identification document and that the copy corresponds to the original. Place, Date, Signature, Intermediary Number" or "Copy made from the original. Place, Date, Signature, Intermediary Number."

2.2 Legal Entity

If the contracting party is a legal entity, the intermediary shall inspect a valid identification document of the legal entity and record the key details of the entity in the application form, including the name or company name, legal form, registered address, country of incorporation, date of incorporation and, if applicable, place and date of establishment or commercial register entry, the company tax number, as well as the names of the persons formally authorized to act on behalf of the legal entity.

Valid identification documents for legal entities, which must be provided either in the original or as a certified copy, are:

a. For legal entities registered in the Commercial Register/Public Register or a comparable register, the following is considered a valid identification document:

b. For legal entities not registered in the Commercial Register/Public Register or a comparable register, the following is considered a valid identification document:

In addition to the legal entity, the person signing the application on behalf of the legal entity (authorized representative) must also be recorded. The following information is required:

A confirmed copy is a copy of a valid identification document on which the intermediary confirms, with their signature, intermediary number, and the place and date, that they have inspected the original and that the copy corresponds to the original. The intermediary must promptly submit the certified copy to PrismaLife AG.

Suggested wording:

"I hereby confirm that I have inspected the original of the valid identification document and that the copy corresponds to the original. Place, Date, Signature, Intermediary Number" or "Copy made from the original. Place, Date, Signature, Intermediary Number."

3. Identity of the Beneficial Owner

The identity of the beneficial owner must be established and verified upon conclusion of a new contract using a valid identification document and by recording the key details. The intermediary shall make a copy of the identification document without the above-mentioned certification and promptly submit it to PrismaLife AG.

3.1 Beneficial Owners

For an insurance contract, the following is considered the beneficial owner:

a. the policyholder
b. the premium payer
c. a third party with an economic interest in the contract; that is, a person who is neither the policyholder nor the premium payer but still has an economic interest in the insurance contract.

3.2 Legal Entity

If the policyholder or the premium payer is a legal entity, the following are considered the beneficial owners of the insurance contract:

a. those natural persons who ultimately, directly or indirectly:

b. those natural persons who are members of the management body, if — after exhausting all possible means and provided that no grounds for suspicion exist — no persons have been identified pursuant to section 3.2(a).

3.3 Exceptions

Exemptions to the identification of the beneficial owner exist in the following cases:

a. For listed companies, insurers, territorial authorities and competent authorities, banks, investment firms, fund trading platforms in the EU, the EEA area and Switzerland: in this case, the natural persons behind the company do not have to be identified. The contractual partner is to be established and identified as described above under no. 2.

b. Only for Germany in the case of occupational pension schemes: in this case, the natural persons behind the company (i.e. employer) do not have to be identified. The contractual partner is to be established and identified in accordance with no. 2. Additionally, the insured person of the contract (i.e. employee) must be identified by means of a conclusive document, as the contract is usually concluded in their economic interest.

4. Application Form for a New Contract

The application form for a new contract must include all data truthfully and completely. Under the section Identification according to the Anti-Money Laundering Act (Due Diligence Check), the following information must be provided:

a. the details of the reliable document;
b. the origin of the assets contributed and the economic background of the total wealth;
c. the reason for entering into the insurance contract.

Important

The information on the origin of the contributed assets which are properly declared for tax purposes (source of funds) and on the economic background of the total assets must in any case be evidenced by copies for all products with an annual premium exceeding 60,000 EUR/ CHF, with a single premium at inception, an additional payment at inception or a subsequent additional payment exceeding 300,000 EUR/ CHF. The same applies if the fund value of 300,000 EUR/ CHF is exceeded as a result of a subsequent additional payment. For lower amounts, particularly for an annual premium exceeding 48,000 EUR/ CHF or a single premium or additional payment exceeding 100,000 EUR/ CHF, corresponding copies may be requested depending on the individual decision of PrismaLife AG. For this purpose, for example, the following documents or copies of these documents may be used:

The section on beneficial interest / beneficial owner must be completed if the economic interest in the contract does not lie with the policyholder but with a third party. In this case, it must be determined who is the beneficial owner of the contract. This person must be identified and verified using a reliable document, and the information must be entered in the corresponding section of the application or on a supplementary sheet, if applicable.

For the section Beneficiary / Recipient of the Insurance Benefit: the designation of the beneficiary in the event of survival or death should be formulated as clearly as possible. For beneficiaries specified as a named natural person, the intermediary records the name of this person as well as their date of birth.

5. Subsequent Contract Amendments

Even for subsequent contract amendments, the identity of the contractual counterparty and the beneficial owner must be determined and verified by inspecting a reliable document. A certified copy of a reliable document is only required in exceptional cases for contract amendments; otherwise, a non-certified copy by the intermediary is sufficient.

6. At the time of payment

At the time of payment, the identity of the claimant or payee must be determined and verified through appropriate measures. In particular, the following persons must be identified using a copy of an official identification document, whereby the intermediary’s certification mentioned above is normally not required:

a. the policyholder, if they have not already been identified with a current copy of an official identification document;
b. the account holder, if different from the policyholder;
c. the beneficiary in the event of survival or death, provided they ultimately receive the benefit.

If the claimant or payee is a legal entity, then, in addition to the legal entity and its acting representatives (see section 2.2), the beneficial owners of the legal entity must be identified and verified (see section 3.2).

In addition, the data collection form for payments must be submitted, and for a payment amount of EUR/CHF 15,000 or more, the purpose of the payment must be indicated on this form.

Payments outside the European Economic Area (EEA) are generally not permitted. Exceptions must be coordinated with the Compliance Officer and Management. Cash transactions are also not allowed.