VIRGIN ISLANDS FINANCIAL SERVICES (PRUDENTIAL AND STATISTICAL RETURNS) (AMENDMENT) ORDER, 2021 ARRANGEMENT OF SECTIONS Section 1... Citation and commencement. 2… Section 4 amended. 3… Section 7 amended. 4… Section 8 amended. 5… Schedule 1 amended. 6… Schedule 2 amended. 7… Schedule 3 amended. 8… Schedule 4 amended. 9…. Schedule 5 amended.

VIRGIN ISLANDS STATUTORY INSTRUMENT 2021 NO. 13 FINANCIAL SERVICES COMMISSION ACT, 2001 (No. 12 of 2001) Financial Services (Prudential and Statistical Returns) (Amendment) Order, 2021 [Gazetted 11th February, 2021] The Financial Services Commission, acting in accordance with the powers conferred on it by section 56A of the Financial Services Commission Act, 2001 (No. 12 of 2001), makes the following Order.

1. (1) This Order may be cited as the Financial Services (Prudential and Statistical Returns) (Amendment) Order, 2021. (2) Subject to subsection (3), this Order shall come into force on the 15th day of February, 2021. (3) The offences and penalties referred to in, and the enforcement action the Commission may take under, section 10 shall not apply in relation to prudential or statistical returns due before the 30th day of June, 2021 if those returns are filed before that date.

2. Section 4 of the Financial Services (Prudential and Statistical Returns) Order, 2009 (“hereinafter referred to as “the principal Order”) is amended in subsection (3)⸻ (a) by deleting the words “; or” at the end of paragraph (c) and substituting a full- stop; and (b) by deleting paragraph (d).

3. Section 7 of the principal Order is amended⸻ (a) in subsection (1), by deleting the words “in accordance with Part I of Schedule 4”; (b) in subsection (2), by deleting the words “in accordance with Part I of Schedule 4”; and (c) by deleting subsection (3). Citation and commencement. Section 4 amended. S.I No. 47 of 2009. Section 7 amended.

4. Section 8 of the principal Order is revoked and substituted with the following section⸻

5. (1) For the purposes of sections 4, 6 and 7, a regulated person shall file a prudential or statistical return or effect a rectification of such return, in an electronic form. (2) The Forms specified in the Schedules shall be used for the purposes of subsection (1) and may be required in such medium as the Commission provides, including publication on its Internet site or other platform.”

6. The principal Order is amended in Schedule 1⸻ (a) by renaming the Schedule “Mutual Fund Annual Return”; and (b) by deleting the opening paragraphs to the Schedule and replacing them with the following new opening paragraph: “The Mutual Fund Annual Return shall be filed by regulated persons recognised or registered as follows pursuant to the Securities and Investment Business Act, 2010, on or before 30th June in respect of the year immediately preceding:  Private Funds  Professional Funds  Public Funds  Recognised Foreign Funds”;

7. The Principal Order is amended in Schedule 2, by deleting the opening paragraph to the Schedule and replacing it with the following new opening paragraphs: “The Prudential Return for Banks is to be completed and filed with the Financial Services Commission by a regulated person holding a banking licence pursuant to section 10 (1) (a) to (c) of the Banks and Trust Companies Act, 1990. This return shall be filed on a quarterly basis within 15 days following the end of the relevant quarter to which the return relates.” “Electronic filing of returns. Section 8 amended. Schedule 1 amended. Schedule 2 amended.

8. The principal Order is amended by revoking Schedule 3 and substituting with the following new Schedule⸻ “SCHEDULE 3 [Section 4] FIDUCIARY SERVICES BUSINESS ANNUAL RETURN The Fiduciary Services Business Annual Return is to be completed and filed with the Financial Services Commission by the following regulated persons, within 1 month after the end of each calendar year⸻ (a) a person holding any of the following licences issued pursuant to the Banks and Trust Companies Act, 1990⸻ (i) Class I Trust licence (ii) Class II Trust licence (iii) Class III licence (iv) Class IV trust licence (v) Class V licence (vi) Restricted Class II Trust licence (vii) Restricted Class III licence; and (b) a person holding a licence issued pursuant to section 4 (3) of the Company Management Act, 1990. Schedule 3 amended.

Fiduciary Business Annual Return FSC/RTN/0001 BVI FINANCIAL SERVICES COMMISSION FIDUCIARY SERVICES BUSINESS ANNUAL RETURN Banks and Trust Companies Act, 1990 Company Management Act, 1990 Financial Services (Prudential and Statistical Returns) Order, 2009 GENERAL INFORMATION Licensee Name: Licence Number: Licence Type (Tick as applicable): ☐ Class I Trust ☐ Class II Trust ☐ Class III ☐ Class IV Trust ☐ Class V ☐ Restricted Class II Trust ☐ Restricted Class III ☐ Company Management Reporting Period: Registered Agent: Registered Office Address: Jurisdictions in which the licensee’s operations are primarily based:

Fiduciary Business Annual Return FSC/RTN/0001

1. FINANCIALS Summary of Balance Sheet Information: Report in US Dollars ONLY ASSETS LIABILITIES Current Assets Current Liabilities 1.1 Cash and cash equivalents 1.16 Amounts due to related parties 1.2 Funds held for clients/in trust 1.17 Funds due to clients 1.3 Accounts receivable – clients 1.18 Licence fees invoiced – not received 1.4 Amounts due from related parties 1.19 Licence fees received – not paid to BVIFSC 1.5 Short Term Investments 1.20 Trade and other payables 1.6 Trade and other receivables 1.21 Deferred Income 1.7 Other Current Assets 1.22 Other Current Liabilities 1.8 Total Current Assets 1.23 Total Current Liabilities Non-Current Assets Non-Current Liabilities 1.9 Fixed Assets 1.24 Commissions Payable 1.10 Amounts due from related parties 1.25 Bank Loans, Overdrafts and Notes Payable 1.11 Long Term Investments 1.26 Amounts due to Parents and Affiliates 1.12 Deposit with BVIFSC 1.27 Accounts Payable and Accrued Liabilities 1.13 Other Non-Current Assets 1.14 Total Non-Current Assets 1.28 Total Liabilities 1.15 Total Assets SHAREHOLDERS’ EQUITY 1.29 Share Capital 1.30 Contributed Capital 1.31 Retained Earnings 1.32 Other Reserves 1.33 Total Liabilities & Shareholders' Equity Contingent Liabilities 1.34 Are there any Contingent Liabilities (e.g. pending litigation) which were not reported in the licensee's last audited financial statements or otherwise reported to the Commission? Select (Yes or No) 1.35 If yes, please provide details below.
2. CAPITAL 2.1 Total number of shares issued: 2.2 Form(s) in which share capital is contributed: 2.3 Institution where Share Capital is being held: Name: Address:

Fiduciary Business Annual Return FSC/RTN/0001 3. PROFESSIONAL INDEMNITY INSURANCE Select (Yes or No) 3.1 Does the licensee maintain professional indemnity insurance? 3.2 If the response to 3.1 is yes, complete items 3.2.1 to 3.2.6 below: Select (Yes or No) 3.2.1 Has the licensee's professional indemnity insurance coverage changed from the previous reporting period? 3.2.2 Provide details of the licensee's professional indemnity insurance (PII) coverage during the reporting period below: Name of Insurer Jurisdiction of Insurer Level of cover (USD) Level of excess payable Territorial limits Details of any exclusions Policy Effective Date Policy Expiration Date Details of any reinstatement Select (Yes or No) 3.2.3 Has the PII coverage been reassessed to ensure that it is appropriate taking into account the nature, size, complexity, structure and diversity of the licensee's business, during the reporting period? If Yes, last policy assessment date: 3.2.4 Number of notifications made by the licensee to the insurer relating to potential claims during the reporting period. 3.2.5 Details of claims paid to the licensee by the licensee's insurer during the reporting period: No. of Claims Total Value of Claims Select (Yes or No) 3.2.6 Has the licensee's PII coverage lapsed at any time during the reporting period?

Fiduciary Business Annual Return FSC/RTN/0001 4. FITNESS AND PROPRIETY Select (Yes or No) 4.1 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners convicted of any criminal offence by a court of Law during the reporting period? 4.2 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners the subject of a criminal investigation or extradition request during the reporting period? 4.3 Was the licensee or any of its directors, senior officers, shareholders or ultimate beneficial owners censured or disciplined by any professional body to which they belong or belonged during the reporting period? 4.4 Were any of the licensee's directors, senior officers, shareholders, controllers or ultimate beneficial owners dismissed from office or employment or refused entry to any profession or occupation, during the reporting period? 4.5 Did the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners file for bankruptcy or were adjudicated bankrupt by any court, during the reporting period? 4.6 Did the licensee or any of its directors, senior officers, shareholders or ultimate beneficial owners fail to satisfy any debt due and payable as a judgement-debtor under any court order, during the reporting period? 4.7 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners found liable in a civil suit which elicited dishonest or unlawful conduct, during the reporting period? 4.8 Was the licensee or any of its directors, officers, shareholders, controllers or beneficial owners, in connection with the formation, control or management of any corporate, partnership or unincorporated institution, adjudged by a court in any jurisdiction civilly liable for any fraud, malfeasance or other misconduct towards such a body or company, or towards any members thereof, during the reporting period? 4.9 Has any body corporate, partnership or unincorporated institution with which the licensee was associated as director, shareholder or controller, anywhere, been compulsorily wound up or made any compromise or arrangement with its creditors where they did not receive or have not yet received full a settlement of their claims, during the reporting period? 4.10 If the licensee has responded yes to any of the questions above, please provide full details including dates below:

Fiduciary Business Annual Return FSC/RTN/0001 5. BOARD MEETINGS 5.1 No. of Board meetings held during the reporting period: 5.2 Location(s) of Board meetings held during the reporting period: 5.3 No. of senior management reports submitted to the Board during the reporting period: 6. RECORD KEEPING Select (Yes or No) 6.1 Are the licensee's records sufficiently maintained in accordance with section 38 of the Regulatory Code, 2009, in an orderly manner? 6.2 Are the licensee's records and underlying documentation kept in accordance with section 98 of the BVI Business Companies Act, 2004? 6.3 If so, where? (specify physical address, including country/territory) If not, give reasons: 7. INTERNAL AUDIT Select (Yes, No or N/A) 7.1 Has the licensee carried out an internal audit during the reporting period in accordance with section 34(2) (b) of the Regulatory Code, 2009?

Fiduciary Business Annual Return FSC/RTN/0001 8. BUSINESS ACTIVITIES Tick all activities that apply 8.1 Types of activities undertaken by the licensee: ☐ Trustee ☐ Co-Trustee ☐ Protector ☐ Administrator ☐ Executor or Administrator (Estate of Deceased) ☐ Registered Agent ☐ Registered Office ☐ Director ☐ Nominee Shareholder ☐ Corporate Secretary 8.2 Indicate, as at the end of the reporting period, the total number of clients: 8.2.1 for which the licensee acts as a trustee of a trust 8.2.2 in or in relation to which the licensee acts as a co-trustee of a trust 8.2.3 in or in relation to which the licensee acts as a protector relative to trusts 8.2.4 in or in relation to which the licensee acts as an administrator of a trust 8.2.5 for which the licensee provides Incorporation/Continuation of companies services 8.2.6 for which the licensee acts as a registered agent 8.2.7 for which the licensee provides registered office services 8.2.8 for which the licensee provides director or officer services: i) Individual (Appointment of individuals from the licensee) ii) Corporate (Appointment of the licensee as corporate director/officer) 8.2.9 for which licensee's subsidiary(ies) provides director or officer services 8.2.10 for which an affiliated entity or person (i.e. a company within a wider Group of Companies or an individual employed with an affiliate) provides director or officer services 8.2.11 in which the licensee acts as a nominee shareholder 8.2.12 in which the licensee's subsidiary(ies) acts as a nominee shareholder 8.2.13 in which the licensee's employee acts as a nominee shareholder 8.2.14 in which an affiliated entity or person (i.e. a company within a wider Group of Companies or an individual employed with an affiliate) acts as a nominee shareholder 8.2.15 In each case under item 8.2.14, please include the name of the affiliated entity or person and the number of such appointments each such affiliated entity or person holds at the end of the reporting period. Name of Affiliated Entity or Person Nominee Shareholder (In the VI) Nominee Shareholder (Outside the VI) 8.2.16 in which the licensee is acting as an executor or administrator of the estate of a deceased person 8.2.17 for which the licensee is providing services listed in section 8.1 to both trusts and companies within a corporate structure. 8.3 Number of non-BVI trusts to which the licensee provides services listed in section 8.1. 8.4 Number of non-BVI companies to which the licensee provides services listed in section 8.1.

Fiduciary Business Annual Return FSC/RTN/0001 9. MANAGING TRUST COMPANIES Select (Yes or No) 9.1 Is the licensee a managing trust company? 9.2 If the response to 9.1 is yes, complete 9.2.1 to 9.2.7 below: 9.2.1 Number of managed trust companies that the licensee managed during the reporting period. 9.2.2 Number of staff dedicated to carrying out the activities of managed trust companies. 9.2.3 Indicate whether staffing resources are shared or dedicated to a specific managed trust company and if any amendments or restatements were made to the written management agreement during the reporting period. Name of Managed Trust Company Staff Allocation (Select Shared or Dedicated) Amendment or Restatement of Agreement (Select Yes or No) Select (Yes or No) 9.2.4 Did the licensee submitted any reports to the shareholders and/or beneficial owners of the managed trust companies during the reporting period? 9.2.5 If yes, state the nature of the report. Select (Yes or No) 9.2.6 Is the licensee providing similar managing trust company services for any non-BVI entities? 9.2.7 If yes, please provide the following details for each entity for which these services were provided: Name of Entity Nature of Services Staff Allocation (Select Shared or Dedicated) Date Services Commenced

Fiduciary Business Annual Return FSC/RTN/0001 10. PORTFOLIO ADMINISTERED 10.1 COMPANIES 10.1.1 Total number of companies for which the licensee carries out company management business: 10.1.2 Percentage of companies for which company management business is carried out by the licensee that fall within each of the following risk rating categories: % a. Low b. Medium c. High d. Un-rated TOTAL 10.1.3 Total value of assets held by the companies for which the licensee provides director services without acting as a trustee (US$): 10.2 PARTNERSHIPS 10.2.1 Total number of partnerships for which company management business and/or trust business is carried out by the licensee: 10.2.2 Percentage of partnerships for which company management business and/or trust business is carried out by the licensee that have a risk rating of: % a. Low b. Medium c. High d. Un-rated TOTAL 10.2.3 Total value of assets held by the partnerships for which the licensee provides director and/or trustee services or other administrative services (US$): 10.3 TRUSTS 10.3.1 Total number of trusts for which trust business is carried out by the licensee: 10.3.2 Percentage of trusts for which trust business is carried out by the licensee that have a risk rating of: % a. Low b. Medium c. High d. Un-rated TOTAL 10.3.3 Total value of assets held by trusts and any of its underlying companies for which the licensee provides trustee and/or director services (US$): PRIVATE TRUST COMPANIES (only applicable to Class I Trust licensees) 10.3.4 Total number of private trust companies administered by the licensee: VISTA (only applicable to trusts held under the Virgin Islands Special Trusts Act, 2000) 10.3.5 Please state the number of trusts held under the Virgin Islands Special Trusts, 2000 by the licensee: 10.4 BEARER SHARES 10.4.1 Number of clients for which the licensee held bearer shares in custody during the reporting period. 10.4.2 Number of clients for which bearer shares were transferred from one party to another during the reporting period and where there was a change in the custodian: 10.4.3 Number of clients for which bearer shares were transferred from one party to another during the reporting period and where the custodian remained the same: 10.4.4 If bearer shares were transferred, how many were transferred to:- i) a Recognised Custodian ii) an Authorised Custodian

Fiduciary Business Annual Return FSC/RTN/0001 11. DIRECTOR, SENIOR OFFICER AND PROTECTOR APPOINTMENTS 11.1 Total number of individuals within the licensee that performed the following duties on behalf of the licensee, during the reporting period: a) acting as a director of a company or other body b) acting as a senior officer of a company or other body c) acting as a protector of a trust 11.2 In each case, please include below the individual’s name and the number of appointments each such individual holds as at the end of the reporting period: Company or other body related appointments Name of Individual Senior Officer Appointments Directorships (BVI Entities) Directorships (Non-BVI Entities) Total Directorships Trust appointments Name of Individual Protector Appointments

Fiduciary Business Annual Return FSC/RTN/0001 12. SERVICES TO REGULATED ENTITIES Select (Yes or No) 12.1 Does the licensee provide services to other entities regulated by the Commission? 12.2 If yes, please indicate the number of each type of entity to which the licensee provides services: Type of Regulated Entity No. of Entities Approved Investment Managers Authorised Custodians Banking Licensees Company Management Licensees Financing Business Licensees Insurance Intermediaries (i.e. Insurance Agents and Brokers) Insurance Managers Insurers Investment Business Licensees Money Services Business Licensees Mutual Funds Private Investment Funds Trust Licensees Total

Fiduciary Business Annual Return FSC/RTN/0001 13. CLIENT BASE 13.1 Percentage of Licensee's Clients that are Introduced Clients Percentage of Licensee's Clients that are End-User Clients TOTAL 13.2 Provide the number of clients (settlors of a trust and/or beneficial owners of a company) that originate from each listed jurisdiction, broken down by the licensee's client base: INTRO CLIENTS END USER CLIENTS INTRO CLIENTS END USER CLIENTS Jurisdiction No. of Settlors Jurisdiction No. of Settlors Afghanistan Mexico Åland Islands Micronesia (Federated States of) Albania Moldova (the Republic of) Algeria Monaco American Samoa Mongolia Andorra Montenegro Angola Montserrat Anguilla Morocco Antarctica Mozambique Antigua and Barbuda Myanmar Argentina Namibia Armenia Nauru Aruba Nepal Australia Netherlands (the) Austria New Caledonia Azerbaijan New Zealand Bahamas (the) Nicaragua Bahrain Niger (the) Bangladesh Nigeria Barbados Niue Belarus Norfolk Island Belgium Northern Mariana Islands (the) Belize Norway Benin Oman Bermuda Pakistan Bhutan Palau Bolivia (Plurinational State of) Palestine, State of Bonaire, Sint Eustatius and Saba Panama Bosnia and Herzegovina Papua New Guinea Botswana Paraguay Bouvet Island Peru Brazil Philippines (the) British Indian Ocean Territory (the) Pitcairn Islands Brunei Darussalam Poland Bulgaria Portugal Burkina Faso Puerto Rico Burundi Qatar Cabo Verde Réunion Cambodia Romania Cameroon Russian Federation (the) Canada Rwanda Cayman Islands (the) Saint Barthélemy

Fiduciary Business Annual Return FSC/RTN/0001 Central African Republic (the) Saint Helena, Ascension and Tristan da Cunha Chad Saint Kitts and Nevis Chile Saint Lucia China Saint Martin (French part) Christmas Island Saint Pierre and Miquelon Cocos (Keeling) Islands (the) Saint Vincent and the Grenadines Colombia Samoa Comoros (the) San Marino Congo (the Democratic Republic of the) Sao Tome and Principe Congo (the) Saudi Arabia Cook Islands (the) Senegal Costa Rica Serbia Côte d'Ivoire Seychelles Croatia Sierra Leone Cuba Singapore Curaçao Sint Maarten (Dutch part) Cyprus Slovakia Czech Republic Slovenia Denmark Solomon Islands Djibouti Somalia Dominica South Africa Dominican Republic (the) South Georgia and the South Sandwich Islands Ecuador South Sudan Egypt Spain El Salvador Sri Lanka Equatorial Guinea Sudan (the) Eritrea Suriname Estonia Svalbard and Jan Mayen Ethiopia Swaziland Falkland Islands (the) [Malvinas] Sweden Faroe Islands (the) Switzerland Fiji Syrian Arab Republic Finland Taiwan (Province of China) France Tajikistan French Guiana Tanzania, United Republic of French Polynesia Thailand French Southern Territories (the) Timor-Leste Gabon Togo Gambia (the) Tokelau Georgia Tonga Germany Trinidad and Tobago Ghana Tunisia Gibraltar Turkey Greece Turkmenistan Greenland Turks and Caicos Islands (the) Grenada Tuvalu Guadeloupe Uganda Guam Ukraine Guatemala United Arab Emirates (the) Guernsey United Kingdom of Great Britain and Northern Ireland (the) Guinea United States Minor Outlying Islands (the)

Fiduciary Business Annual Return FSC/RTN/0001 Guinea-Bissau United States of America (the) Guyana Uruguay Haiti Uzbekistan Heard Island and McDonald Islands Vanuatu Honduras Vatican City State (Holy See) Hong Kong Venezuela (Bolivarian Republic of) Hungary Vietnam Iceland Virgin Islands (British) India Virgin Islands (U.S.) Indonesia Wallis and Futuna Iran (Islamic Republic of) Western Sahara Iraq Yemen Ireland Zambia Isle of Man Zimbabwe Israel Other Italy Unknown Jamaica Japan Jersey Jordan Kazakhstan Kenya Kiribati Korea (the Democratic People's Republic of) Korea (the Republic of) Kosovo (the Republic of) Kuwait Kyrgyzstan Lao People's Democratic Republic (the) Latvia Lebanon Lesotho Liberia Libya Liechtenstein Lithuania Luxembourg Macao Macedonia (the former Yugoslav Republic of) Madagascar Malawi Malaysia Maldives Mali Malta Marshall Islands (the) Martinique Mauritania Mauritius Mayotte

Fiduciary Business Annual Return FSC/RTN/0001 13.3 Provide the number of clients that undertake the business activities listed below: Type of Business Activity No. of Entities Holding Shares Holding Property Insurance Policy Holding Trust Assets Holding Investment Portfolio Bank Accounts Mining Factory Holding a Vessel Meat Packing Industry Other Unknown Total

Fiduciary Business Annual Return FSC/RTN/0001 14. EMPLOYEES 14.1 Please state the number of staff employed to carry on the licensee's regulated fiduciary business activities and any other activities in the table below: Types of Activities Number of Full-time (permanent/ temporary) staff (in the VI) Number of Part-time (permanent/temporary) Staff (In the VI) Number of Full-time (permanent/temporary) Staff (Outside the VI) Number of Part-time (permanent/temporary) Staff (Outside the VI) Regulated fiduciary activities Any other activities TOTAL 14.2 Please state the physical address of the licensee’s principal office or principal place of business outside the Virgin Islands and the number of staff employed at that location in the table below: Address of Principal Office or Principal Place of Business Outside the Virgin Islands No. of Staff 14.3 If any individual, in the Virgin Islands or elsewhere carries out regulated or any other activities on behalf of the licensee who is not an employee of the licensee, please state the number of individuals and country where they are located: Trust Business Only Type of Activities Number of Individuals Location of Individuals Regulated trust business activities Any other activities Company Management Business Only Types of Activities Number of Individuals Location of Individuals Regulated company management business activities: Any other activities: 14.4 Number of staff in the Virgin Islands that joined the licensee during the reporting period by position held: Position held Number of Staff 14.5 Number of staff in the Virgin Islands that let the licensee during the reporting period by position held: Position held Number of Staff

Fiduciary Business Annual Return FSC/RTN/0001 15. OUTSOURCING (Refer to the Explanatory Notes of section 50 of the Regulatory Code, 2009 for guidance on "Outsourcing".) Select (Yes or No) 15.1 Did the licensee have any agreements in place to outsource any of its activities to a service provider during the reporting period? 15.2 If yes, please provide below, in relation to each entity to which activities have been outsourced, the name of the entity, the activities outsourced to the entity and the entity’s jurisdiction: Name of Entity Outsourced Activities Jurisdiction of Entity 15.3 Indicate what functions have been outsourced, the volume of business outsourced in percentage and the jurisdiction(s)/entities to whom activities have been outsourced below: Trust Administration and Management Volume of Business Outsourced (Percentage) Jurisdiction(s) or Entity(ies) to whom activities have been outsourced Trust Administration Only Volume of Business Outsourced (Percentage) Jurisdiction(s) or Entity(ies) to whom activities have been outsourced Company Administration Only Volume of Business Outsourced (Percentage) Jurisdiction(s) or Entity(ies) to whom activities have been outsourced Accounting services for trust business Volume of Business Outsourced (Percentage) Jurisdiction(s) or Entity(ies) to whom activities have been outsourced

Fiduciary Business Annual Return FSC/RTN/0001 16. BUSINESS CONTINUITY AND USE OF TECHNOLOGY 16.1 Date when the licensee's Business Continuity Plan was reviewed and updated. Select (Yes or No) 16.2 Has the licensee's Business Continuity Plan been tested during the reporting period? 16.3 Does the licensee have appropriate policies and procedures in place for the proper use of its IT (technological) infrastructure to guard against internal abuses and misuse? 16.4 Does the licensee have appropriate policies and procedures in place to guard against external threats of its IT (technological) infrastructure? 17. OTHER ISSUES Select (Yes or No) 17.1 Are there any industry and/or market-related issues to which you wish to draw to the Commission's attention? 17.1.1 If the response to 17.1 is yes, provide details below:

Fiduciary Business Annual Return FSC/RTN/0001 18. DECLARATION DECLARATION ☐ I am authorised to complete this declaration on behalf of the licensee. I hereby certify that this return represents an accurate and fair view of the licensee's position at the above reporting period. I undertake that if other material facts are affecting the licensee's affairs which, in my judgement, should be disclosed, I will advise the Financial Services Commission. I understand that the Commission may take enforcement action against the licensee under the Financial Services Commission Act where false, inaccurate or misleading information is submitted within this return. Name (Last Name, First Name) Name of Organisation (if not within Licensee) Relationship to Licensee: ☐ Registered Agent ☐ Legal Representative ☐ Employee ☐ Director/Senior Officer ☐ Other (please specify): Email Address Telephone Number Date”

Captive Insurance Business Annual Return FSC/RTN/0002 8. The Principal Order is amended by revoking Schedule 4 and substituting the following new Schedule⸻ “SCHEDULE 4 [Section 4] CAPTIVE INSURANCE BUSINESS ANNUAL RETURN The following shall apply in relation to Captive Insurance Business Annual Returns⸻ (a) the Captive Insurance Business Annual Return is to be completed and filed with the Financial Services Commission by a person holding a Category C, Category D, Category E or Category F insurance licence issued pursuant to section 8 (2) of the Insurance Act, 2008; (b) with respect to the 2020 reporting period, regulated persons shall file their completed Captive Insurance Business Annual Returns with the Commission, on or before 15th May, 2021; and (c) regulated persons shall file completed returns for subsequent reporting periods, on or before the 31st March, with respect to the previous calendar year. Schedule 4 amended.

Captive Insurance Business Annual Return FSC/RTN/0002 BVI FINANCIAL SERVICES COMMISSION CAPTIVE INSURANCE BUSINESS ANNUAL RETURN Insurance Act, 2008 Financial Services (Prudential and Statistical Returns) Order, 2009 GENERAL INFORMATION Licensee Name: Licence Number: Authorised Class of Insurance Business (Tick as applicable): Property and Casualty Insurance Business Life and Health Insurance Business ☐ Class 1: Motor Insurance ☐ Class 9: Annuity Business ☐ Class 2: Property Insurance ☐ Class 10: Life Insurance ☐ Class 3: Liability Insurance ☐ Class 11: Life Insurance (Investment Related) ☐ Class 4: Financial Loss Insurance ☐ Class 12: Permanent Health Insurance ☐ Class 5: Marine and Aviation ☐ Class 13: Other Life and Health Insurance ☐ Class 6: Goods in Transit ☐ Class 7: Accidental and Health Insurance ☐ Class 8: Other Property and Casualty Insurance Reporting Period: Registered Agent: Registered Office Address: Jurisdictions in which the licensee’s operations are primarily based:

Captive Insurance Business Annual Return FSC/RTN/0002

1. FINANCIAL INFORMATION Summary of Balance Sheet Information: Report in US Dollars ONLY ASSETS LIABILITIES 1.1 Cash and cash equivalents 1.23 Unearned Premium and Fees Reserves 1.2 Bonds and Debentures 1.24 Claims Reserves 1.3 Preferred and Common Stocks 1.25 Catastrophe Reserves 1.4 Investment in Real Estate 1.26 Life Insurance and Annuity Reserves 1.5 Unit Trusts and Mutual Funds 1.27 Accident and Health Reserves 1.6 Alternative Investments 1.28 Property and Casualty Reserves 1.7 Derivative Instruments 1.29 Other Insurance Reserves 1.8 Secured Loans 1.30 Total Insurance Reserves 1.9 Mortgage Loans 1.10 Policy Loans 1.31 Insurance and Reinsurance Payable 1.11 Investments in Affiliates and Advances to Affiliates 1.32 Commissions Payable 1.12 Other Investments and Advances 1.33 Bank Loans, Overdrafts and Notes Payable 1.13 Total Cash, Loans & Investments 1.34 Amounts due to Parents and Affiliates 1.35 Accounts Payable and Accrued Liabilities 1.14 Investments Income Due and Accrued 1.36 Funds Held Under Reinsurance Agreement 1.15 Premium and Fees Receivable 1.37 Dividends Payable 1.16 Reinsurance Balances Recoverable 1.38 Derivatives Instruments 1.17 Funds Held by Ceding Reinsurers 1.39 Policyholders' Amounts on Deposit 1.18 Receivables from Parent and Affiliates 1.40 Other Liabilities 1.19 Fixed Assets 1.41 Total Liabilities 1.20 Deferred Policy Acquisitions Costs 1.21 Other Assets 1.22 Total Assets SHAREHOLDERS' EQUITY 1.42 Paid up Share Capital 1.43 Retained Earnings 1.44 Other Reserves 1.45 Total Liabilities & Shareholders' Equity Contingent Liabilities 1.46 Are there any Contingent Liabilities (e.g. pending litigation) which were not reported in the licensee's last audited financial statements or otherwise reported to the Commission? Select (Yes or No) 1.47 If yes, please provide details below:
2. CAPITAL 2.1 Total number of shares issued: 2.2 Form(s) in which share capital is contributed: 2.3 Institution where Share Capital is being held: Name: Address:

Captive Insurance Business Annual Return FSC/RTN/0002 3. FINANCIAL INFORMATION FOR PROPERTY & CASUALTY INSURER Details of Income Sheet Information - Property & Casualty: Report in US Dollars ONLY Motor Property Liability Financial Loss Marine Aviation Goods in Transit Accident & health Other Property & Casualty Current Year Totals Operational Direct Premiums Written (Gross) Premiums Assumed (Gross) Premiums Ceded Net Written Premiums Claims/Losses Incurred (Gross) Incurred & Paid Incurred, Reported But Not Yet Paid Incurred But Not Reported (IBNR) Claims/Losses Recoverable From Reinsurance Recovered & Received Recoverable, Reported, Not Yet Received Recoverable (IBNR) - Footnote 1 Net Claims/Losses Incurred Commissions Paid on Business Written/Assumed Commissions Received on Business Ceded Net Underwriting Income Unearned Premium Reserve Footnote 1 - since business written is reinsured, management should know, based upon the reinsurance arrangements in effect, the extent to which the IBNR amount should it crystalise, is recoverable from reinsurers and therefore an assessment of this amount is required. Gross Claims/Losses Outstanding Claims/Losses Brought Forward Less than 1 year old 2 - 5 years old More than 5 years old Claims/Losses Incurred Incurred in the current year Changes concerning claims/losses of prior years Changes concerning IBNR Claims/Losses Paid Current year claims Prior year claims Outstanding Claims/Losses Carried Forward Less than 1 year old 2 - 5 years old More than 5 years old Amounts Recoverable From Reinsurers Less than 1 year old 2 - 5 years old More than 5 years old

Captive Insurance Business Annual Return FSC/RTN/0002 4. PROPERTY & CASUALTY INSURER - REINSURANCE ARRANGEMENTS *Copy and use additional sheets where more than 3 re-insurers Legal Name of Reinsurer: Regulator: Rating: Rating Agency: Date of Rating: Motor US$ Property US$ Liability US$ Financial Loss US$ Marine US$ Aviation US$ Goods in Transit US$ Accident & Health US$ Other Property & Casualty US$ Licensee’s Credit & Liquidity Risk Assessment of Reinsurer Type of Reinsurance Quota Share Treaty Surplus Stop Loss Excess of Loss Facultative, Etc. Legal Name of Reinsurer: Regulator: Rating: Rating Agency: Date of Rating: Motor US$ Property US$ Liability US$ Financial Loss US$ Marine US$ Aviation US$ Goods in Transit US$ Accident & Health US$ Other Property & Casualty US$ Licensee’s Credit & Liquidity Risk Assessment of Reinsurer Type of Reinsurance Quota Share Treaty Surplus Stop Loss Excess of Loss Facultative, Etc. Legal Name of Reinsurer: Regulator: Rating: Rating Agency: Date of Rating: Motor US$ Property US$ Liability US$ Financial Loss US$ Marine US$ Aviation US$ Goods in Transit US$ Accident & Health US$ Other Property & Casualty US$ Licensee’s Credit & Liquidity Risk Assessment of Reinsurer Type of Reinsurance Quota Share Treaty Surplus Stop Loss Excess of Loss Facultative, Etc.

Captive Insurance Business Annual Return FSC/RTN/0002 5. FINANCIAL INFORMATION FOR LIFE & HEALTH INSURER Details of Income Sheet Information – Life & Health: Report in US Dollars ONLY Annuities (Lifetime & Fixed-Term) Life Insurance (Term Life, Whole Life & Endowment) Life Insurance Investment Related Permanent Health Other Life and Health Current Year Totals Operational Direct Premiums Written (Gross) Premiums Assumed (Gross) Premiums Ceded Net Written Premiums Claims/Losses Incurred (Gross) Incurred & Paid Incurred, Reported But Not Yet Paid Incurred But Not Reported (IBNR) Claims/Losses Recoverable From Reinsurance Recovered & Received Recoverable (Reported, Not Yet Received) Recoverable (IBNR) - Footnote 1 Net Claims/Losses Incurred Commissions Paid on Business Written/Assumed Commissions Received on Business Ceded Net Underwriting Income Unearned Premium Reserve Footnote 1 - since business written is reinsured, management should know, based upon the reinsurance arrangements in effect, the extent to which the IBNR amount should it crystalise, is recoverable from reinsurers and therefore an assessment of this amount is required. Gross Claims/Losses Outstanding Claims/Losses Brought Forward Less than 1 year old 2 - 5 years old More than 5 years old Claims/Losses Incurred Incurred in the current year Changes concerning claims/losses of prior years Changes concerning IBNR Claims/Losses Paid Current year claims Prior year claims Outstanding Claims/Losses Carried Forward Less than 1 year old 2 - 5 years old More than 5 years old Amounts Recoverable From Reinsurers Less than 1 year old 2 - 5 years old More than 5 years old

Captive Insurance Business Annual Return FSC/RTN/0002 6. LIFE & HEALTH INSURER - REINSURANCE ARRANGEMENTS *Copy and use additional sheets where more than 3 re-insurers Legal Name of Reinsurer: Regulator: Rating: Rating Agency: Date of Rating: Annuities (Lifetime & Fixed-Term) US$ Life Insurance (Term Life, Whole Life & Endowment) US$ Life Insurance Investment Related US$ Permanent Health US$ Other Life and Health US$ Licensee’s Credit & Liquidity Risk Assessment of Reinsurer Type of Reinsurance Quota Share Treaty Surplus Stop Loss Excess of Loss Facultative, Etc. Legal Name of Reinsurer: Regulator: Rating: Rating Agency: Date of Rating: Annuities (Lifetime & Fixed-Term) US$ Life Insurance (Term Life, Whole Life & Endowment) US$ Life Insurance Investment Related US$ Permanent Health US$ Other Life and Health US$ Licensee’s Credit & Liquidity Risk Assessment of Reinsurer Type of Reinsurance Quota Share Treaty Surplus Stop Loss Excess of Loss Facultative, Etc Legal Name of Reinsurer: Regulator: Rating: Rating Agency: Date of Rating: Annuities (Lifetime & Fixed-Term) US$ Life Insurance (Term Life, Whole Life & Endowment) US$ Life Insurance Investment Related US$ Permanent Health US$ Other Life and Health US$ Licensee’s Credit & Liquidity Risk Assessment of Reinsurer Type of Reinsurance Quota Share Treaty Surplus Stop Loss Excess of Loss Facultative, Etc

Captive Insurance Business Annual Return FSC/RTN/0002 7. BVI INSURER'S SOLVENCY ASSESSMENT FOR PROPERTY & CASUALTY (CATEGORY C, D, E & F LICENSEES) A. Calculation of Actual Solvency Margin (ASM)

1. Aggregate value of Allowable Assets at the end of the reporting period $
2. Aggregate value of Liabilities at the end of the reporting period (minus) $
3. Actual Solvency Margin A.(1) – A.(2) $ (N.B. See Regulatory Code for Non-Allowable/Allowable Assets) B. Calculation of Minimum Solvency Margin (MSM)
4. 20% if Annual Net Written Premium (ANWP) up to US$5M $
5. Where ANWP over US$5M: US$1M plus 10% of ANWP in excess of US$5M $ Total B.(1) + B.(2) (MSM) $ C. A.(3) (ASM) above as a percentage of (MSM) % Calculation Sheet for: ☐ Consolidated Business ☐ Domestic Business

Captive Insurance Business Annual Return FSC/RTN/0002 8. BVI INSURER'S SOLVENCY ASSESSMENT FOR LIFE & HEALTH (CATEGORY C, D, E & F LICENSEES) A. Calculation of Actual Solvency Margin (ASM)

1. Aggregate value of Allowable Assets at the end of the reporting period $
2. Aggregate value of Liabilities at the end of the reporting period (minus) $
3. Actual Solvency Margin A.(1) - A.(2) $ (N.B. See Regulatory Code for Non-Allowable/Allowable Assets) B. Calculation of Minimum Solvency Margin (MSM)
4. Life and Health only – Net Worth US$250,000 $ MSM $ C. A.(3) (ASM) above as a percentage B. (MSM) % Calculation Sheet for: ☐ Consolidated Business ☐ Domestic Business

Captive Insurance Business Annual Return FSC/RTN/0002 9. BVI INSURER'S SOLVENCY ASSESSMENT FOR LIFE & HEALTH AND PROPERTY & CASUALTY (CATEGORY C, D, E & F LICENSEES) A. Calculation of Actual Solvency Margin (ASM)

1. Aggregate value of Allowable Assets at the end of the reporting period $
2. Aggregate value of Liabilities at the end of the reporting period (minus) $
3. Actual Solvency Margin A.(1) – A.(2) $ (N.B. See Regulatory Code for Non-Allowable/Allowable Assets) B. Calculation of Minimum Solvency Margin (MSM)
4. 20% if Annual Net Written Premium (ANWP) up to US$5M $
5. Where ANWP over US$5M: US$1M plus 10% of ANWP in excess of US$5M $
6. Life and Health only - Net Worth US$250,000 $ Total B.(1) + B.(2) + B.(3) (MSM) $ C. A.(3) (ASM) above as a percentage of B. (MSM) % Calculation Sheet for: ☐ Consolidated Business ☐ Domestic Business

Captive Insurance Business Annual Return FSC/RTN/0002 10. POLICYHOLDERS IN THE VIRGIN ISLANDS 10.1 Total number of policyholders as of the end of the reporting period: 10.2 Total premium of policyholders as of the end of the reporting period: 10.3 Indicate below the total number of policyholders and total premiums by the class of insurance business: Property and Casualty Insurance Business No. of Policies Total Premium Class 1 - Motor Insurance Class 2 - Property Insurance Class 3 - Liability Insurance Class 4 - Financial Loss Insurance Class 5 - Marine and Aviation Class 6 - Good in Transit Class 7 - Accident and Health Class 8 - Other General Insurance Life and Health Insurance Business No. of Policies Total Premium Class 9 - Annuity Business Class 10 - Life Insurance Class 11 - Life Insurance (Investment Related) Class 12 - Permanent Health Insurance Class 13 - Other Long-Term Insurance 11. CLAIMS 11.1 Total number of claims filed within the reporting period: 11.2 Total amount claimed within the reporting period: 11.3 Attach report indicating the following with respect to each claim filed within the reporting period: Claim Number Deductible Reserve Amount Amount Paid 11.4 Indicate the total number of claims and total paid by class of insurance business during the reporting period: Property and Casualty Insurance Business No. of Policies Total Premium Class 1 - Motor Insurance Class 2 - Property Insurance Class 3 - Liability Insurance Class 4 - Financial Loss Insurance Class 5 - Marine and Aviation Class 6 - Good in Transit Class 7 - Accident and Health Class 8 - Other General Insurance Life and Health Insurance Business No. of Policies Total Premium Class 9 - Annuity Business Class 10 - Life Insurance Class 11 - Life Insurance (Investment Related) Class 12 - Permanent Health Insurance Class 13 - Other Long-Term Insurance 11.5 Total number of claims settled/closed within the reporting period: 11.6 Total number of claims that remained open at the end of the reporting period: 11.7 Total number of claims denied within the reporting period:

Captive Insurance Business Annual Return FSC/RTN/0002 12. FITNESS AND PROPRIETY Select (Yes or No) 12.1 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners convicted of any criminal offence by a court of Law during the reporting period? 12.2 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners the subject of a criminal investigation or extradition request during the reporting period? 12.3 Was the licensee or any of its directors, senior officers, shareholders or ultimate beneficial owners censured or disciplined by any professional body to which they belong or belonged during the reporting period? 12.4 Were any of the licensee's directors, senior officers, shareholders, controllers or ultimate beneficial owners dismissed from office or employment or refused entry to any profession or occupation, during the reporting period? 12.5 Did the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners file for bankruptcy or were adjudicated bankrupt by any court, during the reporting period? 12.6 Did the licensee or any of its directors, senior officers, shareholders or ultimate beneficial owners fail to satisfy any debt due and payable as a judgement-debtor under any court order, during the reporting period? 12.7 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners found liable in a civil suit which elicited dishonest or unlawful conduct, during the reporting period? 12.8 Was the licensee or any of its directors, officers, shareholders, controllers or beneficial owners, in connection with the formation, control or management of any corporate, partnership or unincorporated institution, adjudged by a court in any jurisdiction civilly liable for any fraud, malfeasance or other misconduct towards such a body or company, or towards any members thereof, during the reporting period? 12.9 Has any body corporate, partnership or unincorporated institution with which the licensee was associated as director, shareholder or controller, anywhere, been compulsorily wound up or made any compromise or arrangement with its creditors where they did not receive or have not yet received a full settlement of their claims, during the reporting period? 12.10 If the licensee has responded yes to any of the questions above, please provide full details including dates below:

Captive Insurance Business Annual Return FSC/RTN/0002 13. BOARD MEETINGS 13.1 No. of Board meetings held during the reporting period: 13.2 Location(s) of Board meetings held during the reporting period: 13.3 No. of senior management reports submitted to the Board during the reporting period: 14. ACTUARY 14.1 Has your actuary assessed the licensee's solvency during the reporting period in accordance with section 146(1) of the Regulatory Code, 2009? Select (Yes or No) 15. OUTSOURCING (Refer to the Explanatory Notes of section 50 of the Regulatory Code, 2009 for guidance on "Outsourcing".) Select (Yes or No) 15.1 Did the licensee have any agreements in place to outsource any of its activities during the reporting period? 15.1.1 If yes, please provide below, in relation to each entity to which activities have been outsourced, the name of the entity, the activities outsourced to the entity and the entity’s jurisdiction: Name of Entity Outsourced Activities Jurisdiction of Entity

Captive Insurance Business Annual Return FSC/RTN/0002 16. CLIENT BASE 16.1 Number of clients from each jurisdiction, per applicable class of insurance business (as at the end of the reporting period): Jurisdiction No. of Clients Jurisdiction No. of Clients Afghanistan Moldova (the Republic of) Åland Islands Monaco Albania Mongolia Algeria Montenegro American Samoa Montserrat Andorra Morocco Angola Mozambique Anguilla Myanmar Antarctica Namibia Antigua and Barbuda Nauru Argentina Nepal Armenia Netherlands (the) Aruba New Caledonia Australia New Zealand Austria Nicaragua Azerbaijan Niger (the) Bahamas (the) Nigeria Bahrain Niue Bangladesh Norfolk Island Barbados Northern Mariana Islands (the) Belarus Norway Belgium Oman Belize Pakistan Benin Palau Bermuda Palestine, State of Bhutan Panama Bolivia (Plurinational State of) Papua New Guinea Bonaire, Sint Eustatius and Saba Paraguay Bosnia and Herzegovina Peru Botswana Philippines (the) Bouvet Island Pitcairn Islands Brazil Poland British Indian Ocean Territory (the) Portugal Brunei Darussalam Puerto Rico Bulgaria Qatar Burkina Faso Réunion Burundi Romania Cabo Verde Russian Federation (the) Cambodia Rwanda Cameroon Saint Barthélemy Canada Saint Helena, Ascension and Tristan da Cunha Cayman Islands (the) Saint Kitts and Nevis Central African Republic (the) Saint Lucia Chad Saint Martin (French part) Chile Saint Pierre and Miquelon China Saint Vincent and the Grenadines

Captive Insurance Business Annual Return FSC/RTN/0002 Christmas Island Samoa Cocos (Keeling) Islands (the) San Marino Colombia Sao Tome and Principe Comoros (the) Saudi Arabia Congo (the Democratic Republic of the) Senegal Congo (the) Serbia Cook Islands (the) Seychelles Costa Rica Sierra Leone Côte d'Ivoire Singapore Croatia Sint Maarten (Dutch part) Cuba Slovakia Curaçao Slovenia Cyprus Solomon Islands Czech Republic Somalia Denmark South Africa Djibouti South Georgia and the South Sandwich Islands Dominica South Sudan Dominican Republic (the) Spain Ecuador Sri Lanka Egypt Sudan (the) El Salvador Suriname Equatorial Guinea Svalbard and Jan Mayen Eritrea Swaziland Estonia Sweden Ethiopia Switzerland Falkland Islands (the) [Malvinas] Syrian Arab Republic Faroe Islands (the) Taiwan (Province of China) Fiji Tajikistan Finland Tanzania, United Republic of France Thailand French Guiana Timor-Leste French Polynesia Togo French Southern Territories (the) Tokelau Gabon Tonga Gambia (the) Trinidad and Tobago Georgia Tunisia Germany Turkey Ghana Turkmenistan Gibraltar Turks and Caicos Islands (the) Greece Tuvalu Greenland Uganda Grenada Ukraine Guadeloupe United Arab Emirates (the) Guam United Kingdom of Great Britain and Northern Ireland (the) Guatemala United States Minor Outlying Islands (the) Guernsey United States of America (the) Guinea Uruguay Guinea-Bissau Uzbekistan Guyana Vanuatu Haiti Vatican City State (Holy See)

Captive Insurance Business Annual Return FSC/RTN/0002 Heard Island and McDonald Islands Venezuela (Bolivarian Republic of) Honduras Vietnam Hong Kong Virgin Islands (British) Hungary Virgin Islands (U.S.) Iceland Wallis and Futuna India Western Sahara Indonesia Yemen Iran (Islamic Republic of) Zambia Iraq Zimbabwe Ireland Other Isle of Man Unknown Israel Italy Jamaica Japan Jersey Jordan Kazakhstan Kenya Kiribati Korea (the Democratic People's Republic of) Korea (the Republic of) Kosovo (the Republic of) Kuwait Kyrgyzstan Lao People's Democratic Republic (the) Latvia Lebanon Lesotho Liberia Libya Liechtenstein Lithuania Luxembourg Macao Macedonia (the former Yugoslav Republic of) Madagascar Malawi Malaysia Maldives Mali Malta Marshall Islands (the) Martinique Mauritania Mauritius Mayotte Mexico Micronesia (Federated States of)

Captive Insurance Business Annual Return FSC/RTN/0002 17. BUSINESS CONTINUITY AND USE OF TECHNOLOGY 17.1 Date when the licensee's Business Continuity Plan was reviewed and updated. Select (Yes or No) 17.2 Has the licensee's Business Continuity Plan been tested during the reporting period? 17.3 Does the licensee have appropriate policies and procedures in place for the proper use of its IT (technological) infrastructure to guard against internal abuses and misuse? 17.4 Does the licensee have appropriate policies and procedures in place to guard against external threats of its IT (technological) infrastructure? 18. OTHER ISSUES Select (Yes or No) 18.1 Are there any industry and/or market-related issues to which you wish to draw to the Commission's attention? 18.1.1 If the response to 18.1 is yes, provide details below:

Captive Insurance Business Annual Return FSC/RTN/0002 19. DECLARATION DECLARATION ☐ I am authorised to complete this declaration on behalf of the licensee. I certify that this return represents a true and fair view of the licensee's position at the above reporting period. I undertake that if there are further material facts affecting the licensee's affairs which, in my judgement should be disclosed, I will advise the Financial Services Commission. I understand that the Commission may take enforcement action against the licensee under the Financial Services Commission Act where false, inaccurate or misleading information is submitted within this return. Name (Last Name, First Name) Name of Organisation (if not within Licensee) Relationship to Licensee: ☐ Registered Agent ☐Insurance Manager ☐ Employee ☐ Director/Senior Officer ☐ Other (please specify): Email Address Telephone Number Date”

9. The Principal Order is amended by revoking Schedule 5 and substituting with the following new Schedules “SCHEDULE 5 [Section 4] DOMESTIC INSURANCE BUSINESS ANNUAL RETURN The following shall apply in relation to Domestic Insurance Business Annual Returns – (a) the Domestic Insurance Business Annual Return is to be completed and filed with the Financial Services Commission by a person holding a Category A or Category B insurance licence issued pursuant to section 8 (2) of the Insurance Act, 2008; (b) with respect to the 2020 reporting period, regulated persons shall file their completed Domestic Insurance Business Annual Returns with the Commission, on or before 15th May, 2021; and (c) regulated persons shall file completed returns for subsequent reporting periods, on or before the 31st March with respect to the previous calendar year. Schedule 5 amended.

Domestic Insurance Business Annual Return FSC/RTN/0003 BVI FINANCIAL SERVICES COMMISSION DOMESTIC INSURANCE BUSINESS PRUDENTIAL RETURN Insurance Act, 2008 Financial Services (Prudential and Statistical Returns) Order, 2009 GENERAL INFORMATION Licensee Name: Licence Number: Authorised Class of Insurance Business (Tick as applicable): Property and Casualty Insurance Business Life and Health Insurance Business ☐ Class 1: Motor Insurance ☐ Class 9: Annuity Business ☐ Class 2: Property Insurance ☐ Class 10: Life Insurance ☐ Class 3: Liability Insurance ☐ Class 11: Life Insurance (Investment Related) ☐ Class 4: Financial Loss Insurance ☐ Class 12: Permanent Health Insurance ☐ Class 5: Marine and Aviation ☐ Class 13: Other Life and Health Insurance ☐ Class 6: Goods in Transit ☐ Class 7: Accidental and Health Insurance ☐ Class 8: Other Property and Casualty Insurance Name of Main Agent in the VI: Principal Office in the VI: Name of Insurance Intermediary(ies) that are representing the Insurer 1. 2. 3. 4. Name of Insurance Broker(s) that place(s) business with the Insurer 1. 2. 3. 4. Reporting Period: Registered Agent: Registered Office Address: Jurisdictions in which the licensee’s operations are primarily based:

Domestic Insurance Business Annual Return FSC/RTN/0003

1. FINANCIAL INFORMATION Summary of Balance Sheet Information: Report in US Dollars ONLY ASSETS LIABILITIES 1.1 Cash and cash equivalents 1.23 Unearned Premium and Fees Reserves 1.2 Bonds and Debentures 1.24 Claims Reserves 1.3 Preferred and Common Stocks 1.25 Catastrophe Reserves 1.4 Investment in Real Estate 1.26 Life Insurance and Annuity Reserves 1.5 Unit Trusts and Mutual Funds 1.27 Accident and Health Reserves 1.6 Alternative Investments 1.28 Property and Casualty Reserves 1.7 Derivative Instruments 1.29 Other Insurance Reserves 1.8 Secured Loans 1.30 Total Insurance Reserves (Sum 1.23 to 1.29) 1.9 Mortgage Loans 1.10 Policy Loans 1.31 Insurance and Reinsurance Payable 1.11 Investments in Affiliates and Advances to Affiliates 1.32 Commissions Payable 1.12 Other Investments and Advances 1.33 Bank Loans, Overdrafts and Notes Payable 1.13 Total Cash, Loans & Investments (Sum 1.1 to 1.12) 1.34 Amounts due to Parents and Affiliates 1.35 Accounts Payable and Accrued Liabilities 1.14 Investments Income Due and Accrued 1.36 Funds Held Under Reinsurance Agreement 1.15 Premium and Fees Receivable 1.37 Dividends Payable 1.16 Reinsurance Balances Recoverable 1.38 Derivatives Instruments 1.17 Funds Held by Ceding Reinsurers 1.39 Policyholders' Amounts on Deposit 1.18 Receivables from Parent and Affiliates 1.40 Other Liabilities 1.19 Fixed Assets 1.41 Total Liabilities (Sum of Rows 1.30 to 1.40) 1.20 Deferred Policy Acquisitions Costs 1.21 Other Assets 1.22 Total Assets (Sum of Rows 1.13 to 1.21) SHAREHOLDERS' EQUITY 1.42 Paid up Share Capital 1.43 Retained Earnings 1.44 Other Reserves 1.45 Total Liabilities & Shareholders' Equity Contingent Liabilities 1.46 Are there any Contingent Liabilities (e.g. pending litigation) which were not reported in the licensee's last audited financial statements or otherwise reported to the Commission? Select (Yes or No) 1.47 If yes, please provide details below:
2. CAPITAL 2.1 Total number of shares issued: 2.2 Form(s) in which share capital is contributed: 2.3 Institution where Share Capital is being held: Name: Address:

Domestic Insurance Business Annual Return FSC/RTN/0003 3. FINANCIAL INFORMATION FOR PROPERTY & CASUALTY INSURER Summary of Income Sheet Information - Property & Casualty: Report in US Dollars ONLY VI Jurisdiction Only World-Wide (incl. VI Jurisdiction) VI Operations as a % of Worldwide Operations Current Year Prior Year Current Year Prior Year Current Year Prior Year Premiums Direct Premiums Written (Gross) $ $ $ $ % % Premiums Assumed (Gross) $ $ $ $ % % Premiums Ceded $ $ $ $ % % Net Written Premiums $ $ $ $ % % Premiums Ceded: Premiums Written (Ratio) % % % % % % Claims/Losses Claims/Losses Incurred (Gross) Incurred & Paid $ $ $ $ % % Incurred, Reported But Not Yet Paid $ $ $ $ % % Incurred But Not Reported (IBNR) $ $ $ $ % % Claims/Losses Recoverable From Reinsurance Recovered & Received $ $ $ $ % % Recoverable (Reported, Not Yet Received) $ $ $ $ % % Recoverable (IBNR) $ $ $ $ % % Net Claims/Losses Incurred $ $ $ $ % % Commissions Commissions Paid on Business Written/Assumed $ $ $ $ % % Commissions Received on Business Ceded $ $ $ $ % % Net Underwriting Income $ $ $ $ % % General Expenses $ $ $ $ % % Investment Income, Net $ $ $ $ % % Net Income $ $ $ $ % %

Domestic Insurance Business Annual Return FSC/RTN/0003 4. FINANCIAL INFORMATION FOR PROPERTY & CASUALTY INSURER (CONT’D) Details of Income sheet Information - Property & Casualty: Report in US Dollars ONLY Motor Property Liability Financial Loss Marine Aviation Goods in Transit Accident & health Other Property & Casualty Current Year Totals Operational – VI Jurisdiction, Only Direct Premiums Written (Gross) Premiums Assumed (Gross) Premiums Ceded Net Written Premiums Claims/Losses Incurred (Gross) Incurred & Paid Incurred, Reported But Not Yet Paid Incurred But Not Reported (IBNR) Claims/Losses Recoverable From Reinsurance Recovered & Received Recoverable, Reported, Not Yet Received Recoverable (IBNR) - Footnote 1 Net Claims/Losses Incurred Commissions Paid on Business Written/Assumed Commissions Received on Business Ceded Net Underwriting Income Unearned Premium Reserve Footnote 1 - since business written is reinsured, management should know, based upon the reinsurance arrangements in effect, the extent to which the IBNR amount should it crystalise, is recoverable from reinsurers and therefore an assessment of this amount is required. Gross Claims/Losses – VI Jurisdiction Only Outstanding Claims/Losses Brought Forward Less than 1 year old 2 - 5 years old More than 5 years old Claims/Losses Incurred Incurred in the current year Changes concerning claims/losses of prior years Changes concerning IBNR Claims/Losses Paid Current year claims Prior year claims Outstanding Claims/Losses Carried Forward Less than 1 year old 2 - 5 years old More than 5 years old Amounts Recoverable From Reinsurers Less than 1 year old 2 - 5 years old More than 5 years old

Domestic Insurance Business Annual Return FSC/RTN/0003 Motor Property Liability Financial Loss Marine Aviation Goods in Transit Accident & health Other Property & Casualty Statistical Data– VI Jurisdiction Only No. of New Business Rate of Renewals (%) Aggregate Sums Insured (“ASI”) Aggregate Sums Insured, Reinsured (“ASIR”) Ratio – ASIR:ASI

Domestic Insurance Business Annual Return FSC/RTN/0003 5. PROPERTY & CASUALTY INSURER - REINSURANCE ARRANGEMENTS (VI Jurisdiction Only) *Copy and use additional sheets where more than 3 re-insurers Legal Name of Reinsurer: Regulator: Rating: Rating Agency: Date of Rating: Motor US$ Property US$ Liability US$ Financial Loss US$ Marine US$ Aviation US$ Goods in Transit US$ Accident & Health US$ Other Property & Casualty US$ Licensee’s Credit & Liquidity Risk Assessment of Reinsurer Type of Reinsurance Quota Share Treaty Surplus Stop Loss Excess of Loss Facultative, Etc. Legal Name of Reinsurer: Regulator: Rating: Rating Agency: Date of Rating: Motor US$ Property US$ Liability US$ Financial Loss US$ Marine US$ Aviation US$ Goods in Transit US$ Accident & Health US$ Other Property & Casualty US$ Licensee’s Credit & Liquidity Risk Assessment of Reinsurer Type of Reinsurance Quota Share Treaty Surplus Stop Loss Excess of Loss Facultative, Etc. Legal Name of Reinsurer: Regulator: Rating: Rating Agency: Date of Rating: Motor US$ Property US$ Liability US$ Financial Loss US$ Marine US$ Aviation US$ Goods in Transit US$ Accident & Health US$ Other Property & Casualty US$ Licensee’s Credit & Liquidity Risk Assessment of Reinsurer Type of Reinsurance Quota Share Treaty Surplus Stop Loss Excess of Loss Facultative, Etc.

Domestic Insurance Business Annual Return FSC/RTN/0003 6. FINANCIAL INFORMATION FOR LIFE & HEALTH INSURER Summary of Income Sheet Information – Life & Health: Report in US Dollars ONLY VI Jurisdiction Only World-Wide (incl. VI Jurisdiction) VI Operations as a % of Worldwide Operations Current Year Prior Year Current Year Prior Year Current Year Prior Year Premiums Direct Premiums Written (Gross) $ $ $ $ % % Premiums Assumed (Gross) $ $ $ $ % % Premiums Ceded $ $ $ $ % % Net Written Premiums $ $ $ $ % % Premiums Ceded: Premiums Written (Ratio) % % % % % % Claims/Losses Claims/Losses Incurred (Gross) Incurred & Paid $ $ $ $ % % Incurred, Reported But Not Yet Paid $ $ $ $ % % Incurred But Not Reported (IBNR) $ $ $ $ % % Claims/Losses Recoverable From Reinsurance Recovered & Received $ $ $ $ % % Recoverable (Reported, Not Yet Received) $ $ $ $ % % Recoverable (IBNR) $ $ $ $ % % Net Claims/Losses Incurred $ $ $ $ % % Commissions Commissions Paid on Business Written/Assumed $ $ $ $ % % Commissions Received on Business Ceded $ $ $ $ % % Net Underwriting Income $ $ $ $ % % General Expenses $ $ $ $ % % Investment Income, Net $ $ $ $ % % Net Income $ $ $ $ % %

Domestic Insurance Business Annual Return FSC/RTN/0003 7. FINANCIAL INFORMATION FOR LIFE AND HEALTH INSURER (CONT’D) Details of Income Sheet Information – Life & Health: Report in US Dollars ONLY Annuities (Lifetime) Annuities (Fixed￾Term) Life Insurance (Term Life) Life Insurance (Whole Life) Life Insurance (Endowment) Life Insurance Investment Related Permanent Health Other Property Life & Health Current Year Totals Operational – VI Jurisdiction, Only Direct Premiums Written (Gross) Premiums Assumed (Gross) Premiums Ceded Net Written Premiums Claims/Losses Incurred (Gross) Incurred & Paid Incurred, Reported But Not Yet Paid Incurred But Not Reported (IBNR) Claims/Losses Recoverable From Reinsurance Recovered & Received Recoverable (Reported, Not Yet Received) Recoverable (IBNR) - Footnote 1 Net Claims/Losses Incurred Commissions Paid on Business Written/Assumed Commissions Received on Business Ceded Net Underwriting Income Unearned Premium Reserve Footnote 1 - since business written is reinsured, management should know, based upon the reinsurance arrangements in effect, he extent to which the IBNR amount should it crystalise, is recoverable from reinsurers and therefore an assessment of this amount is required. Gross Claims/Loss Outstanding Claims/Loss Brought Forward Less than 1 year old 2 – 5 years old More than 5 years old Claims/Losses Incurred Incurred in the current year Changes concerning claims/losses of prior years Changes concerning IBNR Claims/Losses Paid Current year claims Prior year claims Outstanding Claims/Loss Carried Forward Less than 1 year old 2 – 5 years old More than 5 years old Amounts Recoverable from Reinsurers Less than 1 year old 2 – 5 years old More than 5 years old

Domestic Insurance Business Annual Return FSC/RTN/0003 Statistical Data – VI Jurisdiction Only No. of New Business Rate of Renewals (%) No. of Policy Surrenders US$ Value of Surrenders No. of Policy Terminations Contract based Other (incl. non-payment by policyholder) No. of Policy Payouts on Death US$ Value of Death Payouts Aggregate Reserves – Gross – Current Year Aggregate Reserves – Ceded – Current Year Aggregate Reserve – Gross – Prior Year Aggregate Reserve – Ceded – Prior Year

Domestic Insurance Business Annual Return FSC/RTN/0003 8. LIFE & HEALTH INSURER - REINSURANCE ARRANGEMENTS (VI Jurisdiction Only) *Copy and use additional sheets where more than 3 re-insurers Legal Name of Reinsurer: Regulator: Rating: Rating Agency: Date of Rating: Annuities (Lifetime) US$ Annuities (Fixed￾Term) US$ Life Insurance (Term Life) US$ Life Insurance (Whole Life) US$ Life Insurance (Endowment) US$ Life Insurance Investment Related US$ Permanent Health US$ Other Life & Health US$ Licensee’s Credit & Liquidity Risk Rating of Reinsurer Type of Reinsurance Quota Share Treaty Surplus Stop Loss Excess of Loss Facultative, Etc. Legal Name of Reinsurer: Regulator: Rating: Rating Agency: Date of Rating: Annuities (Lifetime) US$ Annuities (Fixed￾Term) US$ Life Insurance (Term Life) US$ Life Insurance (Whole Life) US$ Life Insurance (Endowment) US$ Life Insurance Investment Related US$ Permanent Health US$ Other Life & Health US$ Licensee’s Credit & Liquidity Risk Rating of Reinsurer Type of Reinsurance Quota Share Treaty Surplus Stop Loss Excess of Loss Facultative, Etc. Legal Name of Reinsurer: Regulator: Rating: Rating Agency: Date of Rating: Annuities (Lifetime) US$ Annuities (Fixed￾Term) US$ Life Insurance (Term Life) US$ Life Insurance (Whole Life) US$ Life Insurance (Endowment) US$ Life Insurance Investment Related US$ Permanent Health US$ Other Life & Health US$ Licensee’s Credit & Liquidity Risk Rating of Reinsurer Type of Reinsurance Quota Share Treaty Surplus Stop Loss Excess of Loss Facultative, Etc.

Domestic Insurance Business Annual Return FSC/RTN/0003 9. BVI INSURER'S SOLVENCY ASSESSMENT FOR PROPERTY & CASUALTY (CATEGORY A LICENSEE) A. Calculation of Actual Solvency Margin (ASM)

1. Aggregate value of Allowable Assets at the end of the reporting period $
2. Aggregate value of Liabilities at the end of the reporting period (minus) $
3. Actual Solvency Margin A.(1) – A.(2) $ (N.B. See Regulatory Code for Non-Allowable/Allowable Assets) B. Calculation of Minimum Solvency Margin (MSM)
4. 20% if Annual Net Written Premium (ANWP) up to US$5M $
5. Where ANWP over US$5M: US$1M plus 10% of ANWP in excess of US$5M $ Total B.(1) + B.(2) (MSM) $ C. A.(3) (ASM) above as a percentage of B. (MSM) % Calculation Sheet for: ☐ Consolidated Business ☐ Domestic Business

Domestic Insurance Business Annual Return FSC/RTN/0003 10. BVI INSURER'S SOLVENCY ASSESSMENT FOR LIFE & HEALTH (CATEGORY A LICENSEE) A. Calculation of Actual Solvency Margin (ASM)

1. Aggregate value of Allowable Assets at the end of the reporting period $
2. Aggregate value of Liabilities at the end of the reporting period (minus) $
3. Actual Solvency Margin A.(1) – A.(2) $ (N.B. See Regulatory Code for Non-Allowable/Allowable Assets) B. Calculation of Minimum Solvency Margin (MSM)
4. Life and Health only – Net Worth US$250,000 $ MSM $ C. A.(3) (ASM) above as a percentage of B. (MSM) % Calculation Sheet for: ☐ Consolidated Business ☐ Domestic Business

Domestic Insurance Business Annual Return FSC/RTN/0003 11. BVI INSURER'S SOLVENCY ASSESSMENT FOR LIFE & HEALTH AND PROPERTY & CASUALTY (CATEGORY A LICENSEE) A. Calculation of Actual Solvency Margin (ASM)

1. Aggregate value of Allowable Assets at the end of the reporting period $
2. Aggregate value of Liabilities at the end of the reporting period (minus) $
3. Actual Solvency Margin A.(1) – (A).2 $ (N.B. See Regulatory Code for Non-Allowable/Allowable Assets) B. Calculation of Minimum Solvency Margin (MSM)
4. 20% if Annual Net Written Premium (ANWP) up to US$5M $
5. Where ANWP over US$5M: US$1M plus 10% of ANWP in excess of US$5M $
6. Life and Health only – Net Worth $US250,000 $ Total B.(1) + B(2) + B(3) (MSM) $ C. A.(3) (ASM) above as a percentage of B. (MSM) % Calculation Sheet for: ☐ Consolidated Business ☐ Domestic Business

Domestic Insurance Business Annual Return FSC/RTN/0003 12. POLICYHOLDERS IN THE VIRGIN ISLANDS 12.1 Total number of policyholders as at the end of the reporting period: 12.2 Total premium of policyholders as at the end of the reporting period: 12.3 Indicate below the total number of policyholders and total premiums by class of insurance business: Property and Casualty Insurance Business No. of Policies Total Premium Class 1 - Motor Insurance Class 2 - Property Insurance Class 3 - Liability Insurance Class 4 - Financial Loss Insurance Class 5 - Marine and Aviation Class 6 - Good in Transit Class 7 - Accident and Health Class 8 - Other General Insurance Life and Health Insurance Business No. of Policies Total Premium Class 9 - Annuity Business Class 10 - Life Insurance Class 11 - Life Insurance (Investment Related) Class 12 - Permanent Health Insurance Class 13 - Other Long-Term Insurance 13. CLAIMS 13.1 Total number of claims filed in the Virgin Islands within the reporting period: 13.2 Total amount claimed within the reporting period. 13.3 Attach report indicating the following with respect to each claim filed within the reporting period: Claim Number Deductible Reserve Amount Amount Paid 13.4 Indicate the total number of claims and total paid by class of insurance business in the reporting period: Property and Casualty Insurance Business No. of Policies Total Premium Class 1 - Motor Insurance Class 2 - Property Insurance Class 3 - Liability Insurance Class 4 - Financial Loss Insurance Class 5 - Marine and Aviation Class 6 - Good in Transit Class 7 - Accident and Health Class 8 - Other General Insurance Life and Health Insurance Business No. of Policies Total Premium Class 9 - Annuity Business Class 10 - Life Insurance Class 11 - Life Insurance (Investment Related) Class 12 - Permanent Health Insurance Class 13 - Other Long-Term Insurance 13.5 Total number of claims settled/closed within the reporting period: 13.6 Total number of claims that remained open at the end of the reporting period: 13.7 Total number of claims denied within the reporting period:

Domestic Insurance Business Annual Return FSC/RTN/0003 14. ASSETS MAINTAINED IN THE VIRGIN ISLANDS Select (Yes or No) 14.1 Are assets maintained in the Virgin Islands in accordance with section 15 of the Insurance Act, 2008? 14.2 If the response to 14.1 is yes, compete the tables below based on the types of assets maintained: Domestic Business Trust Amount (US$) Name of Trustee Date Established Regulatory Deposit Amount US$ Date Established 14.3 Total domestic liabilities as at the end of the reporting period:

Domestic Insurance Business Annual Return FSC/RTN/0003 15. PROFESSIONAL INDEMNITY INSURANCE Select (Yes or No) 15.1 Does the licensee maintain professional indemnity insurance? 15.2 If the response to 15.1 is yes, complete items 15.2.1 to 15.2.6 below: Select (Yes or No) 15.2.1 Has the licensee's professional indemnity insurance coverage changed from the previous reporting period? 15.2.2 Provide details the licensee's professional indemnity insurance (PII) coverage during the reporting period below: Name of Insurer Jurisdiction of Insurer Level of cover (USD) Level of excess payable Territorial limits Details of any exclusions Policy Effective Date Policy Expiration Date Details of any reinstatement Select (Yes or No) 15.2.3 Has the PII coverage been reassessed to ensure that it is appropriate taking into account the nature, size, complexity, structure and diversity of the licensee's business, during the reporting period? If Yes, last policy assessment date: 15.2.4 Number of notifications made by the licensee to the insurer relating to potential claims during the reporting period. 15.2.5 Details of claims paid to the licensee by the licensee's insurer for the reporting period: No. of Claims Total Value of Claims $ Select (Yes or No) 15.2.6 Has the licensee's PII coverage lapsed at any times during the reporting period?

Domestic Insurance Business Annual Return FSC/RTN/0003 16. FITNESS AND PROPRIETY Select (Yes or No) 16.1 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners convicted of any criminal offence by a court of Law during the reporting period? 16.2 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners the subject of a criminal investigation or extradition request during the reporting period? 16.3 Was the licensee or any of its directors, senior officers, shareholders or ultimate beneficial owners censured or disciplined by any professional body to which they belong or belonged during the reporting period? 16.4 Were any of the licensee's directors, senior officers, shareholders, controllers or ultimate beneficial owners dismissed from office or employment or refused entry to any profession or occupation, during the reporting period? 16.5 Did the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners file for bankruptcy or were adjudicated bankrupt by any court, during the reporting period? 16.6 Did the licensee or any of its directors, senior officers, shareholders or ultimate beneficial owners fail to satisfy any debt due and payable as a judgement-debtor under any court order, during the reporting period? 16.7 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners found liable in a civil suit which elicited dishonest or unlawful conduct, during the reporting period? 16.8 Was the licensee or any of its directors, officers, shareholders, controllers or beneficial owners, in connection with the formation, control or management of any corporate, partnership or unincorporated institution, adjudged by a court in any jurisdiction civilly liable for any fraud, malfeasance or other misconduct towards such a body or company, or towards any members thereof, during the reporting period? 16.9 Has any body corporate, partnership or unincorporated institution with which the licensee was associated as director, shareholder or controller, anywhere, been compulsorily wound up or made any compromise or arrangement with its creditors where they did not receive or have not yet received full settlement of their claims, during the reporting period? 16.10 If the licensee has responded yes to any of the questions above, please provide full details including dates below:

Domestic Insurance Business Annual Return FSC/RTN/0003 17. BOARD MEETINGS 17.1 No. of Board meetings held during the reporting period: 17.2 Location(s) of Board meetings held during the reporting period. 17.3 No. of senior management reports submitted to the Board during the reporting period: 18. INTERNAL AUDIT Select (Yes, No or N/A) 18.1 Has the licensee carried out an internal audit during the reporting period in accordance with section 34(2) (b) of the Regulatory Code, 2009? 19. ACTUARY Select (Yes or No) 19.1 Has the licensee’s actuary assessed the licensee's solvency during the reporting period in accordance with section 146(1) of the Regulatory Code, 2009?

Domestic Insurance Business Annual Return FSC/RTN/0003 20. EMPLOYEES 20.1 Please state the number of staff employed to carry on the licensee's regulated insurance business activities and any other activities in the table below. Types of Activities Number of Full-time (permanent/ temporary) staff (in the VI) Number of Part-time (permanent/temporary) Staff (In the VI) Number of Full-time (permanent/temporary) Staff (Outside the VI) Number of Part-time (permanent/temporary) Staff (Outside the VI) Regulated insurance business activities Any other activities TOTAL 20.2 Please state the physical address of the licensee’s principal office or principal place of business outside the Virgin Islands and the number of staff employed at that location in the table below. Address of Principal Office or Principal Place of Business Outside the Virgin Islands No. of Staff 20.3 If any individual, in the Virgin Islands or elsewhere carries out regulated or any other activities on behalf of the licensee who is not an employee of the licensee, please state the number of individuals and country where they are located. Property and Casualty Business Only Type of Activities Number of Individuals Location of Individuals Regulated property and casualty business activities Any other activities Life and Health Business Only Types of Activities Number of Individuals Location of Individuals Regulated life and health business activities: Any other activities: 20.4 Indicate the number of staff in the Virgin Islands that joined the licensee during the reporting period by position held. Position held Number of Staff 20.5 Indicate the number of staff in the Virgin Islands that let the licensee during the reporting period by position held. Position held Number of Staff

Domestic Insurance Business Annual Return FSC/RTN/0003 21. OUTSOURCING (Refer to the Explanatory Notes of section 50 of the Regulatory Code, 2009 for guidance on "Outsourcing".) Select (Yes or No) 21.1 Did the licensee have any agreements in place to outsource any of its activities during the reporting period? 21.1.1 If yes, please provide below, in relation to each entity to which activities have been outsourced, the name of the entity, the activities outsourced to the entity and the entity’s jurisdiction: Name of Entity Outsourced Activities Jurisdiction of Entity

Domestic Insurance Business Annual Return FSC/RTN/0003 22. CLIENT BASE 22.1 Number of clients from each jurisdiction, per applicable class of insurance business: Jurisdiction No. of Clients Jurisdiction No. of Clients Afghanistan Moldova (the Republic of) Åland Islands Monaco Albania Mongolia Algeria Montenegro American Samoa Montserrat Andorra Morocco Angola Mozambique Anguilla Myanmar Antarctica Namibia Antigua and Barbuda Nauru Argentina Nepal Armenia Netherlands (the) Aruba New Caledonia Australia New Zealand Austria Nicaragua Azerbaijan Niger (the) Bahamas (the) Nigeria Bahrain Niue Bangladesh Norfolk Island Barbados Northern Mariana Islands (the) Belarus Norway Belgium Oman Belize Pakistan Benin Palau Bermuda Palestine, State of Bhutan Panama Bolivia (Plurinational State of) Papua New Guinea Bonaire, Sint Eustatius and Saba Paraguay Bosnia and Herzegovina Peru Botswana Philippines (the) Bouvet Island Pitcairn Islands Brazil Poland British Indian Ocean Territory (the) Portugal Brunei Darussalam Puerto Rico Bulgaria Qatar Burkina Faso Réunion Burundi Romania Cabo Verde Russian Federation (the) Cambodia Rwanda Cameroon Saint Barthélemy Canada Saint Helena, Ascension and Tristan da Cunha Cayman Islands (the) Saint Kitts and Nevis Central African Republic (the) Saint Lucia Chad Saint Martin (French part) Chile Saint Pierre and Miquelon

Domestic Insurance Business Annual Return FSC/RTN/0003 China Saint Vincent and the Grenadines Christmas Island Samoa Cocos (Keeling) Islands (the) San Marino Colombia Sao Tome and Principe Comoros (the) Saudi Arabia Congo (the Democratic Republic of the) Senegal Congo (the) Serbia Cook Islands (the) Seychelles Costa Rica Sierra Leone Côte d'Ivoire Singapore Croatia Sint Maarten (Dutch part) Cuba Slovakia Curaçao Slovenia Cyprus Solomon Islands Czech Republic Somalia Denmark South Africa Djibouti South Georgia and the South Sandwich Islands Dominica South Sudan Dominican Republic (the) Spain Ecuador Sri Lanka Egypt Sudan (the) El Salvador Suriname Equatorial Guinea Svalbard and Jan Mayen Eritrea Swaziland Estonia Sweden Ethiopia Switzerland Falkland Islands (the) [Malvinas] Syrian Arab Republic Faroe Islands (the) Taiwan (Province of China) Fiji Tajikistan Finland Tanzania, United Republic of France Thailand French Guiana Timor-Leste French Polynesia Togo French Southern Territories (the) Tokelau Gabon Tonga Gambia (the) Trinidad and Tobago Georgia Tunisia Germany Turkey Ghana Turkmenistan Gibraltar Turks and Caicos Islands (the) Greece Tuvalu Greenland Uganda Grenada Ukraine Guadeloupe United Arab Emirates (the) Guam United Kingdom of Great Britain and Northern Ireland (the) Guatemala United States Minor Outlying Islands (the) Guernsey United States of America (the) Guinea Uruguay Guinea-Bissau Uzbekistan Guyana Vanuatu

Domestic Insurance Business Annual Return FSC/RTN/0003 Haiti Vatican City State (Holy See) Heard Island and McDonald Islands Venezuela (Bolivarian Republic of) Honduras Vietnam Hong Kong Virgin Islands (British) Hungary Virgin Islands (U.S.) Iceland Wallis and Futuna India Western Sahara Indonesia Yemen Iran (Islamic Republic of) Zambia Iraq Zimbabwe Ireland Other Isle of Man Unknown Israel Italy Jamaica Japan Jersey Jordan Kazakhstan Kenya Kiribati Korea (the Democratic People's Republic of) Korea (the Republic of) Kosovo (the Republic of) Kuwait Kyrgyzstan Lao People's Democratic Republic (the) Latvia Lebanon Lesotho Liberia Libya Liechtenstein Lithuania Luxembourg Macao Macedonia (the former Yugoslav Republic of) Madagascar Malawi Malaysia Maldives Mali Malta Marshall Islands (the) Martinique Mauritania Mauritius Mayotte Mexico Micronesia (Federated States of)

Domestic Insurance Business Annual Return FSC/RTN/0003 23. BUSINESS CONTINUITY AND USE OF TECHNOLOGY 23.1 Date when the licensee's Business Continuity Plan was reviewed and updated: Select (Yes or No) 23.2 Has the licensee's Business Continuity Plan been tested during the reporting period? 23.3 Does the licensee have appropriate policies and procedures in place for the proper use of its IT (technological) infrastructure to guard against internal abuses and misuse? 23.4 Does the licensee have appropriate policies and procedures in place to guard against external threats of its IT (technological) infrastructure? 24. OTHER BUSINESS ACTIVITIES Select (Yes or No) 24.1 Does the licensee perform activities other than those licensed to perform under the Insurance Act or any relevant financial services legislation? 24.1.1 If response to 24.1 is yes, describe these activities below: 25. OTHER ISSUES Select (Yes or No) 25.1 Are there any industry and/or market-related issues to which you wish to draw to the Commission's attention? 25.1.1 If response to 25.1 is yes, provide details below:

Domestic Insurance Business Annual Return FSC/RTN/0003 26. DECLARATION DECLARATION ☐ I am authorised to complete this declaration on behalf of the licensee. I certify that this return represents an accurate and fair view of the licensee's position at the above reporting period. I undertake that if there are other material facts affecting the licensee's affairs which, in my judgement should be disclosed, I will advise the Financial Services Commission. I understand that the Commission may take enforcement action against the licensee under the Financial Services Commission Act where false, inaccurate or misleading information is submitted within this return. Name (Last Name, First Name) Name of Organisation (if not within Licensee) Relationship to Licensee: ☐ Registered Agent ☐ Legal Representative ☐ Employee ☐ Director/Senior Officer ☐ Other (please specify): Email Address Telephone Number Date

SCHEDULE 6 [Section 4] INSURANCE INTERMEDIARIES ANNUAL RETURN The following shall apply in relation to Insurance Intermediaries Annual Return – (a) the Insurance Intermediaries Annual Return is to be completed and filed with the Financial Services Commission by a person holding an insurance intermediary’s licence issued pursuant to section 40 (2) of the Insurance Act, 2008; (b) with respect to 2020 reporting period, regulated persons shall file their completed Insurance Intermediaries Annual Return with the Commission, on or before 15th May, 2021; and (c) regulated persons shall file completed returns for subsequent reporting periods, on or before 31st March, with respect to the previous calendar year.

Insurance Intermediaries Annual Return FSC/RTN/0004 BVI FINANCIAL SERVICES COMMISSION INSURANCE INTERMEDIARIES ANNUAL RETURN Insurance Act, 2008 Financial Services (Prudential and Statistical Returns) Order, 2009 GENERAL INFORMATION Licensee Name: Licensee’s dba Name: Licence Number: Type of Licence (Tick as applicable): ☐ Insurance Agent ☐ Insurance Broker Reporting Period: Registered Agent: Registered Office Address: Jurisdictions in which the licensee’s operations are primarily based:

Insurance Intermediaries Annual Return FSC/RTN/0004

1. ENGAGEMENT WITH INSURERS 1.1 Detail below the arrangements that the Insurance Agent or Broker has in place with each insurer it has entered into an agency or brokerage agreement. Name of Insurer Confirm if Affiliated (Select Yes or No) Agency or Brokerage Agreement (Select as applicable) Are books and records maintained? (Select Yes or No)
2. POLICIES SOLD 2.1 Detail below the total number of policies sold as an agent of or broker to each insurer and gross written premium. Name of Insurer No. of Policies Gross Written Premium

Insurance Intermediaries Annual Return FSC/RTN/0004 3. PROFESSIONAL INDEMNITY INSURANCE Select (Yes or No) 3.1 Does the licensee maintain professional indemnity insurance? 3.2 If the response to 3.1 is yes, complete items 3.2.1 to 3.2.6 below: Select (Yes or No) 3.2.1 Has the licensee's professional indemnity insurance coverage changed from the previous reporting period? 3.2.2 Provide details the licensee's professional indemnity insurance (PII) coverage during the reporting period below: Name of Insurer Jurisdiction of Insurer Level of cover (USD) Level of excess payable Territorial limits Details of any exclusions Policy Effective Date Policy Expiration Date Details of any reinstatement Select (Yes or No) 3.2.3 Has the PII coverage been reassessed to ensure that it is appropriate taking into account the nature, size, complexity, structure and diversity of the licensee's business, during the reporting period? If Yes, last policy assessment date: 3.2.4 Number of notifications made by the licensee to the insurer relating to potential claims during the reporting period. 3.2.5 Details of claims paid to the licensee by the licensee's insurer for the reporting period: No. of Claims Total Value of Claims Select (Yes or No) 3.2.6 Has the licensee's PII coverage lapsed at any times during the reporting period?

Insurance Intermediaries Annual Return FSC/RTN/0004 4. FITNESS AND PROPRIETY Select (Yes or No) 4.1 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners convicted of any criminal offence by a court of Law during the reporting period? 4.2 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners the subject of a criminal investigation or extradition request during the reporting period? 4.3 Was the licensee or any of its directors, senior officers, shareholders or ultimate beneficial owners censured or disciplined by any professional body to which they belong or belonged during the reporting period? 4.4 Were any of the licensee's directors, senior officers, shareholders, controllers or ultimate beneficial owners dismissed from office or employment or refused entry to any profession or occupation, during the reporting period? 4.5 Did the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners file for bankruptcy or were adjudicated bankrupt by any court, during the reporting period? 4.6 Did the licensee or any of its directors, senior officers, shareholders or ultimate beneficial owners fail to satisfy any debt due and payable as a judgement-debtor under any court order, during the reporting period? 4.7 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners found liable in a civil suit which elicited dishonest or unlawful conduct, during the reporting period? 4.8 Was the licensee or any of its directors, officers, shareholders, controllers or beneficial owners, in connection with the formation, control or management of any corporate, partnership or unincorporated institution, adjudged by a court in any jurisdiction civilly liable for any fraud, malfeasance or other misconduct towards such a body or company, or towards any members thereof, during the reporting period? 4.9 Has any body corporate, partnership or unincorporated institution with which the licensee was associated as director, shareholder or controller, anywhere, been compulsorily wound up or made any compromise or arrangement with its creditors where they did not receive or have not yet received a full settlement of their claims, during the reporting period? 4.10 If the licensee has responded yes to any of the questions above, please provide full details including dates below:

Insurance Intermediaries Annual Return FSC/RTN/0004 5. BOARD MEETINGS 5.1 No. of Board meetings held during the reporting period: 5.2 Location(s) of Board meetings held during the reporting period: 5.3 No. of senior management reports submitted to the Board during the reporting period: 6. INTERNAL AUDIT Select (Yes, No or N/A) 6.1 Has the licensee carried out an internal audit during the reporting period in accordance with section 34(2) (b) of the Regulatory Code, 2009?

Insurance Intermediaries Annual Return FSC/RTN/0004 7. EMPLOYEES 7.1 Please state the number of staff employed to carry on the licensee's regulated insurance business activities and any other activities in the table below. Types of Activities Number of Full-time (permanent/ temporary) staff (in the VI) Number of Part-time (permanent/temporary) Staff (In the VI) Number of Full-time (permanent/temporary) Staff (Outside the VI) Number of Part-time (permanent/temporary) Staff (Outside the VI) Regulated insurance business activities Any other activities TOTAL 7.2 Please state the physical address of the licensee’s principal office or principal place of business outside the Virgin Islands and the number of staff employed at that location in the table below. Address of Principal Office or Principal Place of Business Outside the Virgin Islands No. of Staff 7.3 If any individual, in the Virgin Islands or elsewhere carries out regulated or any other activities on behalf of the licensee who is not an employee of the licensee, please state the number of individuals and country where they are located. Property and Casualty Business Only Type of Activities Number of Individuals Location of Individuals Regulated property and casualty business activities Any other activities Life and Health Business Only Types of Activities Number of Individuals Location of Individuals Regulated life and health business activities: Any other activities: 7.4 Indicate the number of staff in the Virgin Islands that joined the licensee during the reporting period by position held. Position held Number of Staff 7.5 Indicate the number of staff in the Virgin islands that let the licensee during the reporting period by position held. Position held Number of Staff

Insurance Intermediaries Annual Return FSC/RTN/0004 8. OUTSOURCING (Refer to the Explanatory Notes of section 50 of the Regulatory Code, 2009 for guidance on "Outsourcing".) Select (Yes or No) 8.1 Did the licensee have any agreements in place to outsource any of its activities during the reporting period? 8.1.1 If yes, please provide below, in relation to each entity to which activities have been outsourced, the name of the entity, the activities outsourced to the entity and the entity’s jurisdiction: Name of Entity Outsourced Activities Jurisdiction of Entity 9. BUSINESS CONTINUITY AND USE OF TECHNOLOGY 9.1 Date when the licensee's Business Continuity Plan was reviewed and updated. Select (Yes or No) 9.2 Has the licensee's Business Continuity Plan been tested during the reporting period? 9.3 Does the licensee have appropriate policies and procedures in place for the proper use of its IT (technological) infrastructure to guard against internal abuses and misuse? 9.4 Does the licensee have appropriate policies and procedures in place to guard against external threats of its IT (technological) infrastructure? 10. OTHER ISSUES Select (Yes or No) 10.1 Are there any industry and/or market-related issues to which you wish to draw to the Commission's attention? 10.1.1 If the response to 10.1 is yes, provide details below:

Insurance Intermediaries Annual Return FSC/RTN/0004 11. DECLARATION DECLARATION ☐ I am authorised to complete this declaration on behalf of the licensee. I certify that this return represents an accurate and fair view of the licensee's position at the above reporting period. I undertake that if there are other material facts affecting the licensee's affairs which, in my judgement should be disclosed, I will advise the Financial Services Commission. I understand that the Commission may take enforcement action against the licensee under the Financial Services Commission Act where false, inaccurate or misleading information is submitted within this return. Name (Last Name, First Name) Name of Organisation (if not within Licensee) Relationship to Licensee: ☐ Registered Agent ☐ Employee ☐ Director/Senior Officer ☐ Other (please specify): Email Address Telephone Number Date”

SCHEDULE 7 [Section 4] INSURANCE MANAGER ANNUAL RETURN The following shall apply in relation to Insurance Manager Annual Returns – (a) the Insurance Manager Annual Return is to be completed and filed with the Financial Services Commission by a person holding an insurance manager’s licence issued pursuant to section 40 (2) of the Insurance Act, 2008; (b) with respect to 2020 reporting period, regulated persons shall file their completed Insurance Manager Annual Returns with the Commission, on or before 15th May, 2021; and (c) regulated persons shall file completed returns for subsequent reporting periods on or before 31st March, with respect to the previous calendar year.

Insurance Manager Annual Return FSC/RTN/0005 BVI FINANCIAL SERVICES COMMISSION INSURANCE MANAGER ANNUAL RETURN Insurance Act, 2008 Financial Services (Prudential and Statistical Returns) Order, 2009 GENERAL INFORMATION Licensee Name: Licence Number Reporting Period: Registered Agent: Registered Office Address: Jurisdictions in which the licensee's operations are primarily based:

Insurance Manager Annual Return FSC/RTN/0005

1. ENGAGEMENT WITH INSURERS 1.1 Select the business activities undertaken by the licensee: ☐ Representative for Foreign Insurer ☐ Directorship/Board Member ☐ Senior Officer ☐ Accounting ☐ Preparation of Prudential/Statutory Financial Return ☐ Underwriting ☐ Claims Handling ☐ Risk Management ☐ Investment ☐ Treasury ☐ Actuarial functions ☐ Internal Audit ☐ Compliance ☐ AML/CFT/Sanctions Compliance ☐ Money Laundering Reporting Officer ☐ Designated Representative ☐ Other (please specify activities):
2. CAPTIVES ADMINISTERED 2.1 Total number of captive insurers managed by the Insurance Manager. 2.1.1 Percentage of captives managed by the licensee that fall within each of the following risk rating categories: % a. Low b. Medium c. High d. Un-rated TOTAL
3. APPOINTMENTS BY INSURER 3.1 Details if all insurers for which the Insurer has been appointed: Name of Insurer Confirm If Affiliated (Yes/No) Services Provided Services Provided Are books and records maintained? (Yes/No)

Insurance Manager Annual Return FSC/RTN/0005 4. SERVICE AGREEMENT TERMINATIONS 4.1 Names any insurers from which service agreements were terminated during the period: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 5. NEW SERVICE AGREEMENTS 5.1 Names of any insurers with which the Insurance Manager has entered into services agreements during the reporting period: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10.

Insurance Manager Annual Return FSC/RTN/0005 6. PROFESSIONAL INDEMNITY INSURANCE 6.1 Does the licensee maintain professional indemnity insurance? 6.2 If the response to 6.1 is yes, complete items 6.2.1 to 6.2.6 below: 6.2.1 Has the licensee's professional indemnity insurance coverage changed from the previous reporting period? 6.2.2 Provide details the licensee's professional indemnity insurance (PII) coverage during the reporting period below: Name of Insurer Jurisdiction of Insurer Level of cover (USD) Level of excess payable Territorial limits Details of any exclusions Policy Effective Date Policy Expiration Date Details of any reinstatement Select (Yes or No) 6.2.3 Has the PII coverage been reassessed to ensure that it is appropriate taking into account the nature, size, complexity, structure and diversity of the licensee's business, during the reporting period? If Yes, last policy assessment date: 6.2.4 Number of notifications made by the licensee to the insurer relating to potential claims during the reporting period. 6.2.5 Details of claims paid to the licensee by the licensee's insurer for the reporting period: No. of Claims Total Value of Claims Select (Yes or No) 6.2.6 Has the licensee's PII coverage lapsed at any times during the reporting period?

Insurance Manager Annual Return FSC/RTN/0005 7. FITNESS AND PROPRIETY Select (Yes or No) 7.1 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners convicted of any criminal offence by a court of Law during the reporting period? 7.2 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners the subject of a criminal investigation or extradition request during the reporting period? 7.3 Was the licensee or any of its directors, senior officers, shareholders or ultimate beneficial owners censured or disciplined by any professional body to which they belong or belonged during the reporting period? 7.4 Were any of the licensee's directors, senior officers, shareholders, controllers or ultimate beneficial owners dismissed from office or employment or refused entry to any profession or occupation, during the reporting period? 7.5 Did the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners file for bankruptcy or were adjudicated bankrupt by any court, during the reporting period? 7.6 Did the licensee or any of its directors, senior officers, shareholders or ultimate beneficial owners fail to satisfy any debt due and payable as a judgement-debtor under any court order, during the reporting period? 7.7 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners found liable in a civil suit which elicited dishonest or unlawful conduct, during the reporting period? 7.8 Was the licensee or any of its directors, officers, shareholders, controllers or beneficial owners, in connection with the formation, control or management of any corporate, partnership or unincorporated institution, adjudged by a court in any jurisdiction civilly liable for any fraud, malfeasance or other misconduct towards such a body or company, or towards any members thereof, during the reporting period? 7.9 Has any body corporate, partnership or unincorporated institution with which the licensee was associated as director, shareholder or controller, anywhere, been compulsorily wound up or made any compromise or arrangement with its creditors where they did not receive or have not yet received a full settlement of their claims, during the reporting period? 7.10 If the licensee has responded yes to any of the questions above, please provide full details including dates below.

Insurance Manager Annual Return FSC/RTN/0005 8. BOARD MEETINGS 8.1 No. of Board meetings held during the reporting period: 8.2 Location(s) of Board meetings held during the reporting period: 8.3 No. of senior management reports submitted to the Board during the reporting period: 9. INTERNAL AUDIT Select (Yes, No or N/A) 9.1 Has the licensee carried out an internal audit during the reporting period in accordance with section 34(2) (b) of the Regulatory Code, 2009?

Insurance Manager Annual Return FSC/RTN/0005 10. EMPLOYEES 10.1 Please state the number of staff employed to carry on the licensee's regulated insurance business activities and any other activities in the table below. Types of Activities Number of Full-time (permanent/ temporary) staff (in the VI) Number of Part-time (permanent/temporary) Staff (In the VI) Number of Full-time (permanent/temporary) Staff (Outside the VI) Number of Part-time (permanent/temporary) Staff (Outside the VI) Regulated insurance business activities Any other activities TOTAL 10.2 Please state the physical address of the licensee’s principal office or principal place of business outside the Virgin Islands and the number of staff employed at that location in the table below. Address of Principal Office or Principal Place of Business Outside the Virgin Islands No. of Staff 10.3 If any individual, in the Virgin Islands or elsewhere carries out regulated or any other activities on behalf of the licensee who is not an employee of the licensee, please state the number of individuals and country where they are located. Property and Casualty Business Only Type of Activities Number of Individuals Location of Individuals Regulated property and casualty business activities Any other activities Life and Health Business Only Types of Activities Number of Individuals Location of Individuals Regulated life and health business activities: Any other activities: 10.4 Indicate the number of staff in the Virgin Islands that joined the licensee during the reporting period by position held. Position held Number of Staff 10.5 Indicate the number of staff in the Virgin Islands that let the licensee during the reporting period by position held. Position held Number of Staff

Insurance Manager Annual Return FSC/RTN/0005 11. OUTSOURCING (Refer to the Explanatory Notes of section 50 of the Regulatory Code, 2009 for guidance on "Outsourcing".) Select (Yes or No) 11.1 Did the licensee have any agreements in place to outsource any of its activities during the reporting period? 11.1.1 If yes, please provide below, in relation to each entity to which activities have been outsourced, the name of the entity, the activities outsourced to the entity and the entity’s jurisdiction: Name of Entity Outsourced Activities Jurisdiction of Entity 12. BUSINESS CONTINUITY AND USE OF TECHNOLOGY 12.1 Date when the licensee's Business Continuity Plan was reviewed and updated. Select (Yes or No) 12.2 Has the licensee's Business Continuity Plan been tested during the reporting period? 12.3 Does the licensee have appropriate policies and procedures in place for the proper use of its IT (technological) infrastructure to guard against internal abuses and misuse? 12.4 Does the licensee have appropriate policies and procedures in place to guard against external threats of its IT (technological) infrastructure? 13. OTHER ISSUES Select (Yes or No) 13.1 Are there any industry and/or market related issues to which you wish to draw to the Commission's attention? 13.1.1 If the response to 13.1 is yes, provide details below:

Insurance Manager Annual Return FSC/RTN/0005 14. DECLARATION DECLARATION ☐ I am authorised to complete this declaration on behalf of the licensee. I certify that this return represents an accurate and fair view of the licensee's position at the above reporting period. I undertake that if there are other material facts affecting the licensee's affairs which, in my judgement should be disclosed, I will advise the Financial Services Commission. I understand that the Commission may take enforcement action against the licensee under the Financial Services Commission Act where false, inaccurate or misleading information is submitted within this return. Name (Last Name, First Name) Name of Organisation (if not within Licensee) Relationship to Licensee: ☐ Registered Agent ☐ Employee ☐ Director/Senior Officer ☐ Other (please specify): Email Address Telephone Number Date

SCHEDULE 8 [Section 4] INVESTMENT BUSINESS ANNUAL RETURN The following shall apply in relation to Investment Business Annual Returns – (a) the Investment Business Annual Return is to be completed and filed with the Financial Services Commission by a person holding an investment business licence issued pursuant to section 6 (2) of the Securities and Investment Business Act, 2010; (b) with respect to the 2020 reporting period, regulated persons shall file their Investment Business Annual Returns with the Commission, on or before 15th May, 2021; and (c) regulated persons shall file completed returns for subsequent reporting periods, on or before 31st March, with respect to the previous calendar year.

Investment Business Annual Return FSC/RTN/0006 BVI FINANCIAL SERVICES COMMISSION INVESTMENT BUSINESS ANNUAL RETURN Securities and Investment Business Act, 2010 Financial Services (Prudential and Statistical Returns) Order, 2009 GENERAL INFORMATION Licensee Name: Licensee’s dba Name: Licence Number: Licence Type (Tick as applicable): Category 1: Dealing in Investments Category 5: Custody of Investments ☐ Subcategory A: Dealing as Agent ☐ Subcategory A: Dealing as Agent ☐ Subcategory B: Dealing as Principal ☐ Subcategory B: Dealing as Principal Category 2 Category 6: Administration of Investments ☐ Arranging Deals in Investments ☐ Subcategory A: Dealing as Agent ☐ Subcategory B: Dealing as Principal Category 3: Managing Investments ☐ Subcategory A: Segregated Portfolios (Excluding Mutual Funds) Category 7 ☐ Subcategory B: Mutual Funds ☐ Operating an Investment Exchange ☐ Subcategory C: Pension Schemes ☐ Subcategory D: Insurance Products ☐ Subcategory E: Other Types of Investments Category 4: Investment Advice ☐ Subcategory A: Segregated Portfolios (Excluding Mutual Funds) ☐ Subcategory B: Investment Advice (Mutual Funds) Reporting Period: Registered Agent: Registered Office Address: Authorised Representative: Jurisdictions in which the licensee’s operations are primarily based:

Investment Business Annual Return FSC/RTN/0006

1. FINANCIAL INFORMATION Summary of Balance Sheet Information: Report in US Dollars ONLY ASSETS LIABILITIES Current Assets Current Liabilities 1.1 Cash and cash equivalents 1.15 Amounts due to related parties 1.2 Funds held for clients 1.16 Funds due to clients 1.3 Accounts receivable – clients 1.17 Trade and other payables 1.4 Amounts due from related parties 1.18 Deferred Income 1.5 Short Term Investments 1.19 Other Current Liabilities 1.6 Trade and other receivables 1.20 Total Current Liabilities 1.7 Other Current Assets 1.8 Total Current Assets Non-Current Assets Non-Current Liabilities 1.9 Fixed Assets 1.21 Amounts due to related parties 1.10 Amounts due from related parties 1.22 Deferred Income 1.11 Long Term Investments 1.23 Other Non-Current Liabilities 1.12 Other Non-Current Assets 1.24 Total Non-Current Liabilities 1.13 Total Non-Current Assets 1.25 Total Liabilities 1.14 Total Assets Shareholders’ Equity 1.26 Share Capital 1.27 Contributed Capital 1.28 Other Reserves 1.29 Total Liabilities & Shareholders' Equity Contingent Liabilities 1.30 Are there any Contingent Liabilities (e.g.) pending litigation) which were not reported in the licensee's last audited financial statements or otherwise reported to the Commission? Select (Yes or No) 1.31 If yes, please provide details below:
2. CAPITAL 2.1 Total number of shares issued: 2.2 Form(s) in which share capital is contributed: 2.3 Institution where Share Capital is being held: Name: Address:

Investment Business Annual Return FSC/RTN/0006 3. PROFESSIONAL INDEMNITY INSURANCE Select (Yes or No) 3.1 Does the licensee maintain professional indemnity insurance? 3.2 If the response to 3.1 is yes, complete items 3.2.1 to 3.2.6 below: 3.2.1 Has the licensee's professional indemnity insurance coverage changed from the previous reporting period? 3.2.2 Provide details the licensee's professional indemnity insurance (PII) coverage during the reporting period below: Name of Insurer Jurisdiction of Insurer Level of cover (USD) Level of excess payable Territorial limits Details of any exclusions Policy Effective Date Policy Expiration Date Details of any reinstatement Select (Yes or No) 3.2.3 Has the PII coverage been reassessed to ensure that it is appropriate taking into account the nature, size, complexity, structure and diversity of the licensee's business, during the reporting period? If Yes, last policy assessment date: 3.2.4 Number of notifications made by the licensee to the insurer relating to potential claims during the reporting period: 3.2.5 Details of claims paid to the licensee by the licensee's insurer for the reporting period: No. of Claims Total Value of Claims $ Select (Yes or No) 3.2.6 Has the licensee's PII coverage lapsed at any times during the reporting period?

Investment Business Annual Return FSC/RTN/0006 4. FITNESS AND PROPRIETY Select (Yes or No) 4.1 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners convicted of any criminal offence by a court of Law during the reporting period? 4.2 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners the subject of a criminal investigation or extradition request during the reporting period? 4.3 Was the licensee or any of its directors, senior officers, shareholders or ultimate beneficial owners censured or disciplined by any professional body to which they belong or belonged during the reporting period? 4.4 Were any of the licensee's directors, senior officers, shareholders, controllers or ultimate beneficial owners dismissed from office or employment or refused entry to any profession or occupation, during the reporting period? 4.5 Did the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners file for bankruptcy or were adjudicated bankrupt by any court, during the reporting period? 4.6 Did the licensee or any of its directors, senior officers, shareholders or ultimate beneficial owners fail to satisfy any debt due and payable as a judgement-debtor under any court order, during the reporting period? 4.7 Was the licensee or any of its directors, senior officers, shareholders, controllers or ultimate beneficial owners found liable in a civil suit which elicited dishonest or unlawful conduct, during the reporting period? 4.8 Was the licensee or any of its directors, officers, shareholders, controllers or beneficial owners, in connection with the formation, control or management of any corporate, partnership or unincorporated institution, adjudged by a court in any jurisdiction civilly liable for any fraud, malfeasance or other misconduct towards such a body or company, or towards any members thereof, during the reporting period? 4.9 Has any body corporate, partnership or unincorporated institution with which the licensee was associated as director, shareholder or controller, anywhere, been compulsorily wound up or made any compromise or arrangement with its creditors where they did not receive or have not yet received a full settlement of their claims, during the reporting period? 4.10 If the licensee has responded yes to any of the questions above, please provide full details including dates below:

Investment Business Annual Return FSC/RTN/0006 5. BOARD MEETINGS 5.1 No. of Board meetings held during the reporting period: 5.2 Location(s) of Board meetings held during the reporting period: 5.3 No. of senior management reports submitted to the Board during the reporting period in accordance with section 181 of the Regulatory Code: 6. RECORD KEEPING Select (Yes or No) 6.1 Are the licensee's records sufficiently maintained in accordance with section 38 of the Regulatory Code, 2009, in an orderly manner? 6.2 Are the licensee's records and underlying documentation kept in accordance with section 98 of the BVI Business Companies Act, 2004? 6.3 If so, where? (specify physical address, including country/territory) If not, give reasons.

Investment Business Annual Return FSC/RTN/0006 7. EMPLOYEES 7.1 Please state the number of staff employed to carry on the licensee's regulated investment business activities and any other activities in the table below. (Refer to Guidelines) Types of Activities Number of Full-time (permanent/ temporary) staff (in the VI) Number of Part-time (permanent/temporary) Staff (In the VI) Number of Full-time (permanent/temporary) Staff (Outside the VI) Number of Part-time (permanent/temporary) Staff (Outside the VI) Regulated investment business activities Any other activities TOTAL 7.2 Please state the physical address of the licensee’s principal office or principal place of business outside the Virgin Islands and the number of staff employed at that location in the Table below. Address of Principal Office or Principal Place of Business Outside the Virgin Islands No. of Staff 7.3 Indicate the number of staff in the Virgin Islands that joined the licensee during the reporting period by position held. Position held Number of Staff 7.4 Indicate the number of staff in the Virgin Islands that let the licensee during the reporting period by position held. Position held Number of Staff 8. OUTSOURCING (Refer to the Explanatory Notes of section 50 of the Regulatory Code, 2009 for guidance on "Outsourcing".) Select (Yes or No) 8.1 Did the licensee have any agreements in place to outsource any of its activities during the reporting period? 8.1.1 If yes, please provide below, in relation to each entity to which activities have been outsourced, the name of the entity, the activities outsourced to the entity and the entity’s jurisdiction: Name of Consultant/Firm Area of Operation Jurisdiction

Investment Business Annual Return FSC/RTN/0006 9. INVESTMENT ACTIVITY REPORT 9.1 Total value of client assets for each applicable licence category/sub-category: Category 1 (Dealing in Investments) Category 4 (Investment Advice) Sub-Category A (Dealing as Agent) Sub-Category A (Excluding Mutual Funds) Sub-Category B (Dealing as Principal) Sub-Category B (Mutual Funds) Category 2 Category 5 (Custody of Investments) Arranging Deals in Investments Sub-Category A (Excluding Mutual Funds) Sub-Category B (Mutual Funds) Category 3 (Managing Investments) Sub-Category A (Segregated Portfolios) Category 6 (Administration of Investments) Sub-Category B (Mutual Funds) Sub-Category A (Excluding Mutual Funds) Sub-Category C (Pension Schemes) Sub-Category B (Mutual Funds) Sub-Category D (Insurance Products) Sub-Category E (Other Types of Investments) 9.2 Total number of clients for each applicable licence category/sub-category: Category 1 (Dealing in Investments) Category 4 (Investment Advice) Sub-Category A (Dealing as Agent) Sub-Category A (Excluding Mutual Funds) Sub-Category B (Dealing as Principal) Sub-Category B (Mutual Funds) Category 2 Category 5 (Custody of Investments) Arranging Deals in Investments Sub-Category A (Excluding Mutual Funds) Sub-Category B (Mutual Funds) Category 3 (Managing Investments) Sub-Category A (Segregated Portfolios) Category 6 (Administration of Investments) Sub-Category B (Mutual Funds) Sub-Category A (Excluding Mutual Funds) Sub-Category C (Pension Schemes) Sub-Category B (Mutual Funds) Sub-Category D (Insurance Products) Sub-Category E (Other Types of Investments) 9.3 Total number of active clients for each licence category/sub-category: Category 1 (Dealing in Investments) Category 4 (Investment Advice) Sub-Category A (Dealing as Agent) Sub-Category A (Excluding Mutual Funds) Sub-Category B (Dealing as Principal) Sub-Category B (Mutual Funds) Category 2 Category 5 (Custody of Investments) Arranging Deals in Investments Sub-Category A (Excluding Mutual Funds) Sub-Category B (Mutual Funds) Category 3 (Managing Investments) Sub-Category A (Segregated Portfolios) Category 6 (Administration of Investments) Sub-Category B (Mutual Funds) Sub-Category A (Excluding Mutual Funds) Sub-Category C (Pension Schemes) Sub-Category B (Mutual Funds) Sub-Category D (Insurance Products) Sub-Category E (Other Types of Investments) 9.4 Average client trading volume under each applicable sub-category: Category 1 (Dealing in Investments) Sub-Category A (Dealing as Agent) Sub-Category B (Dealing as Principal)

Investment Business Annual Return FSC/RTN/0006 9.5 Average value per client trade under each applicable sub-category: Category 1 (Dealing in Investments) Sub-Category A (Dealing as Agent) Sub-Category B (Dealing as Principal) 9.6 Aggregate value of deals made during the reporting period for each applicable sub-category: Category 1 (Dealing in Investments) Category 2 Sub-Category A (Dealing as Agent) Arranging Deals in Investments Sub-Category B (Dealing as Principal) 9.7 Number of account transactions that utilised leverage of over 100:1 during the reporting period for each applicable sub-category: Category 1 (Dealing in Investments) Sub-Category A (Dealing as Agent) Sub-Category B (Dealing as Principal) 9.8 Number of counterparties contracted to sell/market on behalf of a licensee for each applicable category/sub-category: Category 1 (Dealing in Investments) Category 2 Sub-Category A (Dealing as Agent) Arranging Deals in Investments Sub-Category B (Dealing as Principal)

Investment Business Annual Return FSC/RTN/0006 10. FUNDS AND PENSION SCHEME DETAILS 10.1 Details of each fund, per applicable category of licence (as at the end of the reporting period): Category 3 (Investment Management) Name of Fund Type of Fund # of Investors Total Assets Net Asset Value (USD) Jurisdiction of Incorporation Category 4 (Investment Advice) Name of Fund Type of Fund # of Investors Total Assets Net Asset Value (USD) Jurisdiction of Incorporation Category 5 (Custody of Investments) Name of Fund Type of Fund # of Investors Total Assets Net Asset Value (USD) Jurisdiction of Incorporation

Investment Business Annual Return FSC/RTN/0006 Category 6 (Administration of Investments) Name of Fund Type of Fund # of Investors Total Assets Net Asset Value (USD) Jurisdiction of Incorporation 10.2 Details of Pension Schemes under management (Applicable to licensees holding licences under Category 3, Sub-Category C (Managing Pension Schemes) Only) Name of Pension Scheme

of Investors in

Pension Scheme Asset Value of Pension Scheme

Investment Business Annual Return FSC/RTN/0006 11. CREDIT RISK EXPOSURE REPORT (Category 1 and 5 Licensees Only) 11.1 Overall value of exposure (includes commitments) listed by counterparty for the 5 largest exposures (as at the end of the relevant period): Name of Counterparty Value of Exposures (USD) 1. 2. 3. 4. 5. 11.2 Maximum potential exposure listed by counterparty for the 5 largest exposures. Name of Counterparty Potential Exposure (USD) 1. 2. 3. 4. 5. 11.3 Top 10 countries to which the largest exposures relate, as at the end of the reporting period. Country Exposure (USD) 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11.4 Has there been any material downgrading of short term or long term obligations including counterparties during the reporting period? Select (Yes or No) 11.4.1 If response to 11.4 is yes, provide details of downgrading below:

Investment Business Annual Return FSC/RTN/0006 12.1 Provide the number of clients originating from each jurisdiction, broken down by the licensee's category/sub-category of licence. Jurisdiction No. of CLIENTS Jurisdiction No. of CLIENTS Afghanistan Mongolia Åland Islands Montenegro Albania Montserrat Algeria Morocco American Samoa Mozambique Andorra Myanmar Angola Namibia Anguilla Nauru Antarctica Nepal Antigua and Barbuda Netherlands (the) Argentina New Caledonia Armenia New Zealand Aruba Nicaragua Australia Niger (the) Austria Nigeria Azerbaijan Niue Bahamas (the) Norfolk Island Bahrain Northern Mariana Islands (the) Bangladesh Norway Barbados Oman Belarus Pakistan Belgium Palau Belize Palestine, State of Benin Panama Bermuda Papua New Guinea Bhutan Paraguay Bolivia (Plurinational State of) Peru Bonaire, Sint Eustatius and Saba Philippines (the) Bosnia and Herzegovina Pitcairn Islands Botswana Poland Bouvet Island Portugal Brazil Puerto Rico British Indian Ocean Territory (the) Qatar Brunei Darussalam Réunion Bulgaria Romania Burkina Faso Russian Federation (the) Burundi Rwanda Cabo Verde Saint Barthélemy Cambodia Saint Helena, Ascension and Tristan da Cunha Cameroon Saint Kitts and Nevis Canada Saint Lucia Cayman Islands (the) Saint Martin (French part) Central African Republic (the) Saint Pierre and Miquelon Chad Saint Vincent and the Grenadines Chile Samoa China San Marino Christmas Island Sao Tome and Principe

Investment Business Annual Return FSC/RTN/0006 Cocos (Keeling) Islands (the) Saudi Arabia Colombia Senegal Comoros (the) Serbia Congo (the Democratic Republic of the) Seychelles Congo (the) Sierra Leone Cook Islands (the) Singapore Costa Rica Sint Maarten (Dutch part) Côte d'Ivoire Slovakia Croatia Slovenia Cuba Solomon Islands Curaçao Somalia Cyprus South Africa Czech Republic South Georgia and the South Sandwich Islands Denmark South Sudan Djibouti Spain Dominica Sri Lanka Dominican Republic (the) Sudan (the) Ecuador Suriname Egypt Svalbard and Jan Mayen El Salvador Swaziland Equatorial Guinea Sweden Eritrea Switzerland Estonia Syrian Arab Republic Ethiopia Taiwan (Province of China) Falkland Islands (the) [Malvinas] Tajikistan Faroe Islands (the) Tanzania, United Republic of Fiji Thailand Finland Timor-Leste France Togo French Guiana Tokelau French Polynesia Tonga French Southern Territories (the) Trinidad and Tobago Gabon Tunisia Gambia (the) Turkey Georgia Turkmenistan Germany Turks and Caicos Islands (the) Ghana Tuvalu Gibraltar Uganda Greece Ukraine Greenland United Arab Emirates (the) Grenada United Kingdom of Great Britain and Northern Ireland (the) Guadeloupe United States Minor Outlying Islands (the) Guam United States of America (the) Guatemala Uruguay Guernsey Uzbekistan Guinea Vanuatu Guinea-Bissau Vatican City State (Holy See) Guyana Venezuela (Bolivarian Republic of) Haiti Vietnam Heard Island and McDonald Islands Virgin Islands (British)

Investment Business Annual Return FSC/RTN/0006 Honduras Virgin Islands (U.S.) Hong Kong Wallis and Futuna Hungary Western Sahara Iceland Yemen India Zambia Indonesia Zimbabwe Iran (Islamic Republic of) Other Iraq Unknown Ireland Isle of Man Israel Italy Jamaica Japan Jersey Jordan Kazakhstan Kenya Kiribati Korea (the Democratic People's Republic of) Korea (the Republic of) Kosovo (the Republic of) Kuwait Kyrgyzstan Lao People's Democratic Republic (the) Latvia Lebanon Lesotho Liberia Libya Liechtenstein Lithuania Luxembourg Macao Macedonia (the former Yugoslav Republic of) Madagascar Malawi Malaysia Maldives Mali Malta Marshall Islands (the) Martinique Mauritania Mauritius Mayotte Mexico Micronesia (Federated States of) Moldova (the Republic of) Monaco

Investment Business Annual Return FSC/RTN/0006 13. BUSINESS CONTINUITY AND USE OF TECHNOLOGY 13.1 Date when the licensee's Business Continuity Plan was reviewed and updated. Select (Yes or No) 13.2 Has the licensee's Business Continuity Plan been tested during the reporting period? 13.3 Does the licensee have appropriate policies and procedures in place for the proper use of its IT (technological) infrastructure to guard against internal abuses and misuse? 13.4 Does the licensee have appropriate policies and procedures in place to guard against external threats of its IT (technological) infrastructure? 14. OTHER BUSINESS ACTIVITIES Select (Yes or No) 14.1 Does the licensee perform activities other than those licensed to perform under the Securities and Investment Business Act, 2010 or any relevant financial services legislation? 14.1.1 If the response to 14.1 is yes, provide details below: 15. OTHER ISSUES Select (Yes or No) 15.1 Are there any industry and/or market-related issues to which you wish to draw to the Commission's attention? 15.1.1 If the response to 15.1 is yes, provide details below:

Investment Business Annual Return FSC/RTN/0006 16. DECLARATION DECLARATION ☐ I am authorised to complete this declaration on behalf of the licensee. I certify that this return represents an accurate and fair view of the licensee's position at the above reporting period. I undertake that if there are other material facts affecting the licensee's affairs which, in my judgement should be disclosed, I will advise the Financial Services Commission. I understand that the Commission may take enforcement action against the licensee under the Financial Services Commission Act where false, inaccurate or misleading information is submitted within this return. Name (Last Name, First Name) Name of Organisation (if not within Licensee) Relationship to Licensee: ☐ Registered Agent ☐ Authorised Representative ☐ Employee ☐ Director/Senior Officer ☐ Other (please specify): Email Address Telephone Number Date

Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Return FSC/RTN/0007 SCHEDULE 9 [Section 4] ANTI-MONEY LAUNDERING/COUNTERING THE FINANCING OF TERRORISM (AML/CFT) RETURN The following shall apply in relation to Anti-money Laundering/Countering the Financing of Terrorism Returns – (a) the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) Return is to be completed and filed with the Financial Services Commission by the following regulated persons - (i) a person holding a licence issued pursuant to any of the following-  Section 10 (1) of the Banks and Trust Companies Act, 1990;  Section 4 (3) of the Company Management Act, 1990;  Section 6 (2) of the Securities and Investment Business Act, 2010;  Section 8 (2) of the Insurance Act, 2008;  Section 476 of the Insolvency Act, 2003;  Section 9 (2) of the Financing and Money Services, 2010; (ii) a person holding a licence as an insurance manager or insurance intermediary pursuant to section 40 (2) of the Insurance Act, 2008; and (iii) a person approved as an approved investment manager pursuant to regulation 7 (1) of the Investment Business (Approved Managers) Regulations, 2012; (b) with respect to 2020 reporting period, regulated persons shall file their Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) Returns with the Commission, on or before 15th May, 2021; and (c) regulated persons shall file completed returns for subsequent reporting periods, on or before 31st March, with respect to the previous calendar year.

Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Return FSC/RTN/0007 VI FINANCIAL SERVICES COMMISSION ANTI-MONEY LAUNDERING/COUNTERING THE FINANCING OF TERRORISM (AML/CFT) RETURN Anti-money Laundering Regulations, 2008 Anti-money Laundering and Terrorist Financing Code of Practice, 2008 Financial Services (Prudential and Statistical Returns) Order, 2009 GENERAL INFORMATION Licensee Name: Licence Number: Licence Type (Tick as applicable): ☐ Approved Investment Managers ☐ Banking Licensees ☐ Trust/Company Management Licensees ☐ Financing Business Licensees ☐ Insolvency Practitioners ☐ Insurers ☐ Insurance Managers and Intermediaries ☐ Investment Business Licensees ☐ Money Services Business Licensees Reporting Period: Registered Agent: Registered Office Address:

Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Return FSC/RTN/0007

1. CORPORATE GOVERNANCE 1.1 Board/Senior Management Oversight 1.1.1 How many Board meetings or Senior Management meetings has the licensee held within the last 12 months? (a) Board Meetings (b) Senior Management Meetings 1.1.2 In the last 12 months, how many times has AML/CFT appeared as am agenda item at these meetings? (a) Board Meetings (b) Senior Management Meetings 1.2 Policies and Procedures 1.2.1 How long has it been since the licensee’s AML/CFT policies and procedures were reviewed and updated? (a) Policies (b) Procedures 1.2.2 Was the review conducted internally or by a third party? 1.2.3 How often does the licensee prepare a report on the operations and effectiveness of its AML/CFT systems and controls? 1.2.4 Is the report prepared on the operations and effectiveness of the licensee’s AML/CFT systems and controls presented to the Board? 1.3 Institutional Risk Assessment 1.3.1 How long has it been since the licensee performed an assessment of the ML/TF risks for all of its business lines? 1.3.2 Did the Board approve the risk assessment? 1.3.3 Based on the risk assessment, what was the risk rating applied to each of the following? (a) Products/Services (b) Customers (c) Geography (d) Distribution Channels (e) Overall licensee rating
2. RECORD KEEPING 2.1 Does the licensee have policies and procedures in place regarding the records that must be retained, including retention periods, in accordance with the AMLTFCOP? 2.2 What channels does the licensee use to make these policies and procedures readily accessible by staff? ☐ Electronic Copies ☐Hard Copies ☐ Intranet Site ☐ Requests to Supervisors Managers 2.3 Are staff aware of the licensee’s policies and procedures for record retention? 2.4 Are the licensee’s records maintained in the Virgin Islands? 2.5 Do the records maintained by the licensee include transaction records? 2.6 Are the licensee’s records held in a readily retrievable format? 2.7 In what format are the licensee’s records held?

Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Return FSC/RTN/0007 3. RISK PROFILE 3.1 Products and Services 3.1.1 Approximately how many products and services are offered by the licensee? (a) Products (Total No.) (b) Services (Total No.) 3.1.2 What percentage of the licensee’s products and services fall into the following risk categories, as defined in the licensee’s ML/TF risk assessment? (a) High (b) Medium (c) Low 3.2 Distribution Channels 3.2.1 What percentage of the licensee's business relationships are conducted face-to-face? 3.3 Customer Exposure 3.3.1 What percentage of the licensee’s customers fall into the following risk ML/TF risk categories? (a) High (b) Medium (c) Low 3.3.2 What percentage of the licensee’s customers fall into each of the following customer types? (a) Retail (b) Institutional (c) Professional 3.3.3 What percentage of the licensee’s business has been established prior to verification procedures being completed? 3.3.4 Where the licensee has established a business relationship with incomplete customer verification, the licensee implements specific risk management procedures with respect to that relationship: 3.3.5 What percentage of business relationships have been rejected or terminated by the licensee due to concerns about CDD within the last 12 months? 3.3.6 What percentage of transactions have been rejected or terminated by the licensee due to concerns about CDD within the last 12 months? 3.3.7 What percentage of business relationships have been rejected or terminated by the licensee due to incomplete CDD information within the last 12 months? 3.3.8 What percentage of transactions have been rejected or terminated by the licensee due to incomplete CDD information within the last 12 months?

Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Return FSC/RTN/0007 3.4 PEPs 3.4.1 Does the licensee conduct screening to identify whether customers are PEPs? 3.4.2 Is this PEP screening initiated automatically or manually? 3.4.3 How frequently is enhanced monitoring of persons identified as PEPs conducted? 3.4.4 Of the licensee’s existing customer base, how many are PEPs? 3.4.5 What percentage of customers identified as PEPs have NOT been approved by senior management for onboarding/continuation of a relationship? 3.4.6 What percentage of customers previously classified as PEP have been declassified as PEPs within the last 12 months? 3.5 Targeted Financial Sanctions 3.5.1 What percentage of the licensee's business relationships are conducted face-to-face? 3.5.2 Is sanctions screening conducted automatically or manually? 3.5.3 How frequently is sanctions screening conducted? 3.5.4 Does the licensee’s screening measures include a screening of its entire customer base immediately after new persons are added to sanctions lists?

Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Return FSC/RTN/0007 4. RISK MONITORING 4.1 Policies and Procedures 4.1.1 Has the licensee implemented policies and procedures reflecting a risk-based approach to ongoing client monitoring aligned to the ML/TF risks presented by its business? 4.1.2 Has the licensee implemented policies and procedures for updating CDD information on existing customers as required by the AMLTFCOP? 4.1.3 Has the licensee implemented policies and procedures for carrying out ECDD on high risk customers as required by the AMLTFCOP? 4.1.4 Has the licensee implemented policies and procedures to identify complex or unusually large transactions with no visible economic or lawful purpose? 4.2 AML/CFT Audit Function 4.2.1 Does the licensee maintain an independent audit function, adequately resourced to test compliance with AML/CFT requirements? 4.2.2 Does the audit function include sample testing of client files? 4.3 Third-Party Reliance 4.3.1 Does the licensee place reliance on third parties for the introduction of an applicant for business as defined in the AMLTFCOP? 4.3.2 Are third parties within the same group structure relied on? 4.3.3 How many third party agreements does the licensee currently have in place? 4.3.4 What percentage of the third party agreements in place are group related? 4.3.5 Has the licensee assessed all existing third party agreements to ensure full compliance with AML legislation? 4.3.6 What percentage of the licensee’s business has been introduced by a third party? 4.3.7 Does the licensee have a programme in place for the regular testing and verification of AML/CFT documentation sourced through third parties to ensure: i) AML/CFT procedures applied by third parties reflect those of the licensee ii) AML/CFT information can be retrieved without delay iii) The quality of documents held by the third party are sufficient to ensure completeness of records in accordance with the AMLTFCOP 4.3.8 What is the frequency of testing of the third party arrangements currently in place? 4.3.9 Are records evidencing the testing of third party arrangements maintained by the licensee? 4.3.10 What percentage of the licensee’s business relationships or transactions established through third party relationships have been rejected or terminated by the licensee due to concerns about CDD within the last 12 months? 4.3.11 What percentage of the licensee’s business relationships or transactions established through third party relationships, have been rejected or terminated by the licensee due to incomplete CDD information within the last 12 months? 4.3.12 What percentage of the licensee’s third party agreements has the licensee terminated within the last 12 months?

Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Return FSC/RTN/0007 5. GEOGRAPHIC EXPOSURE 5.1 Insert the following in the table below: (a) the number of customers identified as PEPs from each jurisdiction listed * (b) the number of third party introducers from each jurisdiction listed * *Select N/A in the applicable drop boxes above where the licensee does not have PEP customers or third-party introducer arrangements. No. of PEPs No. of 3 rd party introducers No. of PEPs No. of 3rd party Jurisdiction Jurisdiction introducers Afghanistan Marshall Islands (the) Åland Islands Martinique Albania Mauritania Algeria Mauritius American Samoa Mayotte Andorra Mexico Angola Micronesia (Federated States of) Anguilla Moldova (the Republic of) Antarctica Mongolia Antigua and Barbuda Montenegro Argentina Montserrat Armenia Morocco Aruba Mozambique Australia Myanmar Austria Namibia Azerbaijan Nauru Bahamas (the) Nepal Bahrain Netherlands (the) Bangladesh New Caledonia Barbados New Zealand Belarus Nicaragua Belgium Niger (the) Belize Nigeria Benin Niue Bermuda Norfolk Island Bhutan Northern Mariana Islands (the) Bolivia (Plurinational State of) Norway Bonaire, Sint Eustatius and Saba Oman Bosnia and Herzegovina Pakistan Botswana Palau Bouvet Island Palestine, State of Brazil Panama British Indian Ocean Territory (the) Papua New Guinea Brunei Darussalam Paraguay Bulgaria Peru Burkina Faso Philippines (the) Burundi Pitcairn Islands Cabo Verde Poland Cambodia Portugal Cameroon Puerto Rico

Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Return FSC/RTN/0007 Canada Qatar Cayman Islands (the) Réunion Central African Republic (the) Romania Chad Russian Federation (the) Chile Rwanda China Saint Barthélemy Christmas Island Saint Helena, Ascension and Tristan da Cunha Cocos (Keeling) Islands (the) Saint Kitts and Nevis Colombia Saint Lucia Comoros (the) Saint Martin (French part) Congo (the Democratic Republic of the) Saint Pierre and Miquelon Congo (the) Saint Vincent and the Grenadines Cook Islands (the) Samoa Costa Rica San Marino Côte d'Ivoire Sao Tome and Principe Croatia Saudi Arabia Cuba Senegal Curaçao Serbia Cyprus Seychelles Czech Republic Sierra Leone Denmark Singapore Djibouti Sint Maarten (Dutch part) Dominica Slovakia Dominican Republic (the) Slovenia Ecuador Solomon Islands Egypt Somalia El Salvador South Africa Equatorial Guinea South Georgia and the South Sandwich Islands Eritrea South Sudan Estonia Spain Ethiopia Sri Lanka Falkland Islands (the) [Malvinas] Sudan (the) Faroe Islands (the) Suriname Fiji Svalbard and Jan Mayen Finland Swaziland France Sweden French Guiana Switzerland French Polynesia Syrian Arab Republic French Southern Territories (the) Taiwan (Province of China) Gabon Tajikistan Gambia (the) Tanzania, United Republic of Georgia Thailand Germany Timor-Leste Ghana Togo Gibraltar Tokelau Greece Tonga Greenland Trinidad and Tobago Grenada Tunisia Guadeloupe Turkey

Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Return FSC/RTN/0007 Guam Turkmenistan Guatemala Turks and Caicos Islands (the) Guernsey Tuvalu Guinea Uganda Guinea-Bissau Ukraine Guyana United Arab Emirates (the) Haiti United Kingdom of Great Britain and Northern Ireland (the) Heard Island and McDonald Islands United States Minor Outlying Islands (the) Honduras United States of America (the) Hong Kong Uruguay Hungary Uzbekistan Iceland Vanuatu India Vatican City State (Holy See) Indonesia Venezuela (Bolivarian Republic of) Iran (Islamic Republic of) Vietnam Iraq Virgin Islands (British) Ireland Virgin Islands (U.S.) Isle of Man Wallis and Futuna Israel Western Sahara Italy Yemen Jamaica Zambia Japan Zimbabwe Jersey Other Jordan Unknown Kazakhstan Kenya Kiribati Korea (the Democratic People's Republic of) Korea (the Republic of) Kosovo (the Republic of) Kuwait Kyrgyzstan Lao People's Democratic Republic (the) Latvia Lebanon Lesotho Liberia Libya Liechtenstein Lithuania Luxembourg Macao Macedonia (the former Yugoslav Republic of) Madagascar Malawi Malaysia Maldives Mali Malta

Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Return FSC/RTN/0007 Marshall Islands (the) Martinique Mauritania Mauritius Mayotte Mexico Micronesia (Federated States of) Moldova (the Republic of) Monaco

Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Return FSC/RTN/0007 6. SUSPICIOUS ACTIVITY REPORTING 6.1 How many suspicious activities/transactions were reported to the MLRO in the last 12 months? 6.2 How many of the suspicious activities/transactions reported to the MLRO in the last 12 months resulted in a SAR being filed with the FIA? 6.3 Where suspicious activities/transactions did not result in the filing of a SAR with the FIA, was the reason for such decision taken documented in each instance? 6.4 What is the value of the associated transactions of the SARs reported to the FIA? 6.5 What is the average time taken from the date of transaction to the time a suspicious activity is reported to the MLRO? 6.6 What is the average number of days taken by the MLRO to analyse a suspicious transaction before filing an SAR with the FIA? 7. OTHER ISSUES Select (Yes or No) 7.1 Are there any other AML/CFT issues to which you wish to draw the Commission’s attention? 7.1.1 If the response to 7.1 is yes, please provide details below:

Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Return FSC/RTN/0007 8. DECLARATION DECLARATION ☐ I am authorised to complete this declaration on behalf of the licensee. I certify that this return represents an accurate and fair view of the licensee's position at the above reporting period. I undertake that if there are other material facts affecting the licensee's affairs which, in my judgement should be disclosed, I will advise the Financial Services Commission. I understand that the Commission may take enforcement action against the licensee under the Financial Services Commission Act where false, inaccurate or misleading information is submitted within this return. Name (Last Name, First Name) Name of Organisation (if not within Licensee) Relationship to Licensee: ☐ Registered Agent ☐ Authorised Representative ☐ Insurance Manager ☐ Legal Representative ☐ Employee ☐ Director/Senior Officer ☐ Other (please specify): Email Address Telephone Number Date” "

SCHEDULE 10 [Section 9] ADMINISTRATIVE PENALTIES Section of Order Breached Category of Contravention ad Description Penalty (Maximum) 4 (1) (a) Failure to file a prudential or statistical return as required by the Order (where an extension is not granted pursuant to section 6) (b) Failure to file a prudential or statistical return within the period of extension (where an extension had been granted pursuant to section 6) $400 for the first thirty days, and $100 for each additional month or part thereof, during which the return remains outstanding $600, and $100 for each additional month or part thereof during which the return remains outstanding 4 (2) Failure to ensure that information contained in a prudential or statistical return is accurate and complete (this relates to information that is materially inaccurate or misleading) $300 7 (1) Failure to notify the Commission of knowledge of inaccurate or misleading information contained in a filed return and providing accurate information within the time prescribed $700 7 (2) Failure to provide accurate information as required by the Commission within the time prescribed to correct inaccurate information contained in a filed return. $700 Made by the Financial Services Commission on the 10th of February, 2021. (Sgd.) Kenneth Baker Managing Director Financial Services Commission