Luciano Navarro

Head of Compliamce and AML for SG Group entities in Brazil. It covers three banks (one Corporate & Investment Bank, two Consumer Finance), one Leasing Company and one brokerage house. The main roles & responsibilities are: - setting policies and standards to cover compliance issues - advising line management of the impact on their businesses and functions of applicable external or internal regulations - supporting line management in their responsibilities to comply with applicable regulations (e.g. by reviewing new products/activities for compliance implications, identifying potential rule breaches, enforcing changes to relevant manuals to reflect regulatory requirements, monitoring the businesses for adherence to the regulations and providing input to audit and training programmes) - assisting line management in the conduct of “crisis” management (e.g. ad hoc investigations into rule breaches) - providing an independent reporting mechanism for all executives (local and offshore) - fostering good relations with the regulators - Coordinating the Local Compliance Officers appointed to each significant business segments in Brazil (Consumer and Leasing). Today the team (excluding myself) is composed by 01 headcount for Corporate & Investment Banking and other 04 in Consumer Finance. - Report line direct to the COO in Brazil and to the Global Head of Compliance in Paris.

Coordination of monthly meetings with 37 international banks to discuss issues related to compliance function. As well as participate in public hearing and discuss with local regulators through the association.

- Almost the same activities described above covering the following businesses: Corporate & Investment Banking, Treasury, Broker-dealer, Pension Funds and Securities Services. I acted as back up of the compliance of the Asset Management and Private Banking. I had 07 HCs under management during this period where 06 were based in São Paulo and 01 was based in Curitiba. - I assisted the South America (Chile, Uruguay, Venezuela, Argentina, Paraguay e Peru) Regional Compliance Officer based in São Paulo, Brazil to coordinate these countries and to consolidate their reports to main branch. I participated in the full review of the compliance department in Argentina and also in the due diligence (compliance and anti-money laundering perspective) of Lloyds Bank Paraguay acquired by HSBC in 2006.

Compliance Manager and Anti-Money Laundering Officer JUN/03 – SEP/04 • Almost the same activities described above covering the following businesses: Corporate & Investment Banking, Treasury, Securities Services, Cash Management and Trade Finance. Financial Manager – Staff Manager – Corporate Banking JAN/03 – JUN/03 • Worked analysing the business, financial control (forecast x actual) or strategy, which provide the whole business vision including environment assessment (competitors, regulators, market trends, etc.) for the Corporate Banking and Global Transaction Services’ head. It required broad and general knowledge of all areas of banking business. This skill is acquired by having work experience in a variety of areas in a bank. Also responsible to coordinate the Business Recovery Plan with Technology. Product and Relationship Manager – Securities Services AUG/99 – DEC/03 • I managed the relationship with international global custodians and broker/dealers, investment banks and European Private Banks, from which arose around 30% of the business annual revenues. • I developed and implemented new products and services such as local custody for ADR (American Depositary Receipts), Escrow Agent (Corporate Agency & Trust). • I participated in the steering committee of the new payment system implementation (SPB) as specialist in Stock, Commodities and Futures Exchanges and Clearinghouses. • I visited the main clients in US and Europe, improving the business relationship through a strategic approach of new products. • During this period I also trained the Citibank’s middle and back office of Securities Services based in Tampa – FL / USA about Brazilian securities markets.

Product and Relationship Supervisor – Securities Services JUL/99 – JAN/98 • Almost the same activities described above including the management of the middle and back office services, including: client services, cash and securities settlement, corporate action report and payments, custody position control and client’s billing. I was not responsible for relationship with clients at this time. Trade Finance and Services Analyst MAI/94 – DEZ/97 • I started as a trainee in May 1994 in the back office of the trade finance and services department and became an analyst in January 1995. From 1995 up to 1997 I worked with export and import collection, export pre-payment, export and import letter of credit, export and import financing, currency swaps, payment orders and financial foreign exchange contracts. It included a training period of three months in the FX trading desk as trader.