Instruction No. 13/2025

Instruction No. 13/2025
BO No. 10/2025 • 2025/10/15
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Topics
Supervision :: Registration
Index
Text of the Instruction
Annex I – Amendment of Annex I to Instruction No. 23/2018 regarding the Questionnaire on suitability, professional qualification, availability, independence and conflicts of interest
Annex II – Amendment of Annex III to Instruction No. 23/2018 regarding the validation list for the authorization process for the exercise of functions
Annex III – Republication of Instruction No. 23/2018

Text of the Instruction
Subject: Instruction that partially amends Instruction No. 23/2018, regarding the authorization for the exercise of functions by members of the administrative and supervisory bodies of institutions subject to the supervision of the Bank of Portugal

This Instruction partially amends the Bank of Portugal Instruction No. 23/2018, of November 5 (“Instruction No. 23/2018” or “Instruction”), regarding the authorization for the exercise of functions by members of the administrative and supervisory bodies of institutions subject to the supervision of the Bank of Portugal.

Through Instruction No. 23/2018, the Bank of Portugal regulated the procedures to be adopted by supervised institutions in the submission of requests for authorization to exercise functions as members of administrative and supervisory bodies and holders of essential functions (cf. Article 2 of the Instruction), requests for non-objection to the accumulation of a new administrative or supervisory post (cf. Article 7 of the Instruction) and requests for the registration of members in office (cf. Article 6 of the Instruction), as well as the communication of supervening facts to the authorization (cf. Article 3 of the Instruction).

Having passed almost seven years since the entry into force of the Instruction, and considering, above all, the experience acquired by the Bank of Portugal in the analysis and decision of the aforementioned requests and the concerns conveyed by the market for greater clarity and brevity in the processing of their respective procedures, it is opportune and necessary to review the same.

This Instruction updates the essential elements to be presented by institutions for the purposes of requests for authorization to exercise functions by members of the administrative and supervisory bodies and other requests included within the scope of application of the Instruction. Notwithstanding, these elements may be complemented with other diligences or interviews, to be carried out or requested on a case-by-case basis by the supervisor.

It is expected that the European Central Bank will develop a simplified approach regarding the documentation to be submitted in case of reappointment of members in institutions directly subject to its supervision (“significant institutions”), also taking into account the transposition by Member States of Directive (EU) 2024/1619 of the European Parliament and of the Council, of May 31, 2024 (“CRD VI”), so the simplification measures regarding the assessment of reappointed members adopted herein may also become applicable to significant institutions.

It was sought to clarify the text of the Instruction in cases where, from its practical application, doubts arose regarding completion by institutions and candidates, intending, thus, to ensure the collection, at the beginning of the process, of all indispensable data to carry out the assessment of suitability for the exercise of functions, with a view to reducing the need for sending subsequent information requests. Point changes were also introduced to the established procedures, whose relevance and/or necessity was revealed by practice.

Additionally, measures were introduced tending to promote the timely presentation of requests for authorization to exercise functions, namely, through the provision of deadlines for this purpose, in order to avoid the undesired and unjustified prolongation of the mandates of the administrative and supervisory bodies of institutions, with the consequent maintenance in exercise of functions of members of these bodies for an excessive period after the end of the mandates and/or the designation of the members chosen for the new term in the General Meeting.

For this purpose, a new deadline for the presentation of the request for authorization to exercise functions to the Bank of Portugal is established, namely, 30 working days after the date of the corresponding designation resolution (including reappointment), the aforementioned request for authorization not being presented after 8 months have elapsed from the date of the end of the mandate, except in duly justified circumstances accepted by the Bank of Portugal.

Regarding the aforementioned deadlines, the specificity of the Agricultural Mutual Credit Societies that integrate the Integrated System of Agricultural Mutual Credit (SICAM) was also sought to be safeguarded, resulting from the necessary presentation, with the request for authorization to exercise functions presented to the Bank of Portugal, of an opinion issued by the Central Agricultural Mutual Credit Society, as provided for in Article 10 of the Legal Regime of Agricultural Credit, approved by Decree-Law No. 24/91, of January 11.

The content of the Declaration of Compliance with the Duty of Information regarding the Processing of Personal Data, currently contained in point 2 of the questionnaire on suitability, professional qualification, independence and availability, annexed to Instruction No. 23/2018, is updated. Specifically, it contemplates the sharing of personal data with the European Supervisory Authorities Information System (“ESAs”), established by the ESAs Guidelines JC/GL 2024/88, of November 20. The possibility of collecting the candidate's voice in the context of personal interviews carried out by the Bank of Portugal is also provided for, in light of the provisions of paragraph 6 of Article 30-B of the RGICSF, through its recording, namely when the complexity of the request justifies it.

Additionally, the possibility of collecting personal data for purposes of investigation, quantitative analyses and statistical reports (at an aggregated and anonymized level) and the use of technological means with a view to increasing efficiency in the analysis of requests that are the subject of this Instruction is determined. In the latter case, the issuance of automated individual decisions remains excluded.

Following a recommendation of the National Data Protection Commission, the current possibility of identifying candidates through the attachment of a simple photocopy of the identification document to the file is replaced by a certified photocopy of this document, with a view to avoiding in-person identification.

The alignment of the requirements regarding Criminal Record Certificates to be submitted within the scope of these requests with European guidelines on this matter is also highlighted.

Regarding the assessment of the suitability requirement for members of the administrative and supervisory bodies, the obligation to report judicial or administrative proceedings is circumscribed based on temporal and material requirements. Regarding ongoing proceedings, those must be reported in which there are indications of the direct or personal involvement of the candidate in the practice of the facts in question or those in which, even if there are no such indications, the Institution and the candidate consider them likely to have a material impact on the assessment of the suitability requirement. As for proceedings concluded less than 10 years ago, these must be reported to the extent that responsibility or direct or personal involvement of the person concerned has been established or, when this is not the case, if the Institution and the candidate consider them likely to have a material impact on the assessment of the suitability requirement. However, the obligation to communicate proceedings concluded in which responsibility or direct or personal involvement of the person concerned has been established is maintained, even if concluded more than 10 years ago.

Finally, alongside other changes aimed at updating the questionnaire, a new questionnaire structure is proposed that will allow for better reading of the provided information, accompanied by additional instructions – in footnotes and in the filling instructions in the final part of the questionnaire – regarding its digital completion and uploading to the system.

In light of the changes now enshrined, it is also decided to republish Instruction No. 23/2018 with the changes introduced by this Instruction.

The draft of this Instruction was subject to public consultation, having heard the Securities Market Commission, the Insurance and Pension Funds Supervisory Authority and the National Data Protection Commission.

In these terms, the Bank of Portugal, in the exercise of the powers conferred upon it by Article 17 of its Organic Law, approved by Law No. 5/98, of January 31, and by the provisions of paragraph 8 of Article 30 and subparagraph f) of paragraph 1 of Article 116 of the RGICSF, approves the following Instruction:

Article 2.
Amendments to Instruction No. 23/2018 and its annexes 1 – Article 1 of Instruction No. 23/2018 shall have the following wording:
“Article 1.
[…]
1- […]
2- This instruction is also applicable:
a) To the assessment of the suitability of holders of essential functions of the Institutions, as provided for in the applicable legal and regulatory provisions, with the necessary adaptations; b) To supervening facts communicated in accordance with Article 32 of the RGICSF; and c) To requests for the accumulation of posts submitted in accordance with Article 33 of the RGICSF. 3- [previous paragraph 4]”

2 – Article 2 of Instruction No. 23/2018 shall have the following wording:
“Article 2.
[…]
1- […] a) […] b) Valid and updated criminal record certificate, issued by the competent authority of the country of nationality and, if different, of the country of habitual residence, referring to the last 10 years, or another equivalent document in accordance with national legislation.

Instruction No. 13/2025 BO No. 10/2025 • 2025/10/15 Topics Supervision :: Registration
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c) […] d) […] e) […] f) […]
2- […] a) When it concerns a request for authorization to exercise functions in a collegiate body, a collective assessment report prepared by the Institution containing the result of the appreciation of the body as a whole, with a view to verifying whether it has adequate and diversified professional qualification and experience, if it contributes to the fulfillment of the gender diversity objectives defined in its internal policy, as well as, when applicable, if it has sufficient availability to fulfill its functions and independence (hereinafter identified as “Collective Assessment Report”), in light of paragraphs 4 and 6 of Article 30 of the RGICSF, including the collective appreciation matrix of the body, according to the model annexed to this Instruction (Annex II), (hereinafter identified as “Collective Appreciation Matrix”); and b) […] 3- If it deems appropriate, the Institution may also send a certified photocopy of the identification document, which visibly contains the signature and the civil identification number of the Person (citizen card, identity card, passport or equivalent document), with a view to avoiding a possible need for in-person identification of the Person. 4- The criminal record certificates referred to in subparagraph b) of paragraph 1 of this article should, whenever possible, be requested specifically for the exercise of the functions of member of the administrative or supervisory body of a credit institution or financial company. 5- Regarding reappointed members, the delivery of the parts of the questionnaire referred to in subparagraph a) of paragraph 1 of this article that have not undergone changes compared to the last submitted version of the questionnaire, and of the collective assessment matrix referred to in the final part of subparagraph a) of paragraph 2, is dispensed with, if there is no change in the composition of the body nor in the assessment made by the Institution. 6- Changes to the questionnaires of reappointed members that are likely to affect their suitability shall be communicated in accordance with the provisions of subparagraphs a) and b) of paragraph 3 of Article 3 of this Instruction. 7- Regarding reappointed members, the individual assessment reports and collective assessment reports referred to in subparagraph c) of paragraph 1 and subparagraph a) of paragraph 2 of this article must contain:
a) The assessment of new facts or new functions likely to affect their suitability; b) The assessment of how the candidate exercised their functions during the last term, namely, whether their decisions and interventions in matters within their competence or of the body they are part of were made in a balanced and careful manner, revealing compliance with the suitability requirements and contributing to the adequate collective performance of the body; c) If all members of the same body are reappointed, the assessment of how that body performed its functions during the last term

3 – Article 3 of Instruction No. 23/2018 shall have the following wording:
“Article 3.
[…]
1- Institutions must submit a new Questionnaire for Persons for each request for authorization to exercise functions, except for the situation provided for in paragraph 5 of the previous article. 2- […] 3- If, during the term, any supervening fact occurs that is likely to affect the Person's suitability requirements and alters the information contained in the last submitted version of the questionnaire, the Institution, as soon as it becomes aware of the facts in question, must communicate them to the Bank of Portugal, together with the submission of the following elements:
a) Part of the Questionnaire containing the alteration to be considered, marking the part of the questionnaire that is altered; b) Declaration signed by the Person concerned and by the Institution itself from which it results that “The information provided in the parts (identify the Part and the specific point of the questionnaire that is altered) of the questionnaire now sent constitute the only alterations to the last questionnaire sent regarding (indicate name), with the other previously provided answers remaining unchanged”; and c) Assessment by the Institution regarding the impact of the communicated supervening facts. 4- […] 5- […]”

5 – Article 5 of Instruction No. 23/2018 shall have the following wording:
“Article 5.
[…]
1 - […]
2 - When not presented at a prior moment to the designation as provided for in paragraph 3 of Article 30-B of the RGICSF, the request for authorization to exercise functions must be presented to the Bank of Portugal within 30 working days after the date of the corresponding designation resolution, including reappointment. 3 - The request for authorization to exercise functions by members of the administrative and supervisory bodies, whether presented under the provisions of paragraph 2 or paragraph 3 of Article 30-B of the RGICSF, must be presented within 8 months from the date of the end of the mandate, except in duly justified circumstances accepted by the Bank of Portugal. 4 - For Agricultural Mutual Credit Societies integrated into the Integrated System of Agricultural Mutual Credit, considering the assessment obligations that fall on the central body, the 30 working day period referred to in paragraph 2 of this article begins after the date of issuance of the Opinion by the Central Society under Article 10 of the Legal Regime of Agricultural Credit and Agricultural Credit Cooperatives. 5 - The presentation of the request for authorization to exercise functions by members of the administrative and supervisory bodies by the institutions referred to in the previous paragraph must not exceed a period of 10 months from the date of the end of the mandate, except in duly justified circumstances accepted by the Bank of Portugal, whether presented under the provisions of paragraph 2 or paragraph 3 of Article 30-B of the RGICSF.”

6 – Article 6 of Instruction No. 23/2018 shall have the following wording:
“Article 6.
[…]
1 - When authorization for the exercise of functions has not been requested”

Instruction No. 13/2025 BO No. 10/2025 • 2025/10/15 Topics Supervision :: Registry
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previously to the designation under the terms of paragraph 3 of Article 30-B of the RGICSF, Institutions must request the Bank of Portugal to register the Persons designated ex novo within 30 days from their respective start date, in accordance with paragraph 1 of Article 71 of the RGICSF, such request being accompanied by the indication of the date on which they started their functions, in accordance with paragraph 1 of Article 69 of the RGICSF. 2 - When authorization for the exercise of functions has not been requested previously to the designation under the terms of paragraph 3 of Article 30-B of the RGICSF, and in cases of reappointment of all members composing the management or supervisory body, Institutions may request the Bank of Portugal to register the Reappointed Persons at the time of presenting the corresponding request for authorization for the exercise of functions, under the terms provided in paragraph 1 of Article 69 of the RGICSF. 3 - In cases where authorization for the exercise of functions has been requested previously to the designation under the terms of paragraph 3 of Article 30-B of the RGICSF, Institutions must request the Bank of Portugal to register the Persons designated ex novo or reappointed within 60 days from the date on which the aforementioned prior authorization was granted, under penalty of expiration of the same, such registration request being accompanied by a copy of the minutes containing the deliberation of the designation of the Persons, as well as the indication of the date of their respective start of functions, under the provisions of paragraph 3 of Article 30-B and paragraph 1 of Article 69 of the RGICSF. 4 - […]» 7 – Article 7 of Instruction No. 23/2018 shall have the following wording:
«Article 7.
[…]
1 - […]
2 - For the purposes of the assessment provided for in Article 33 of the RGICSF, the communication provided for in the previous paragraph must specifically indicate which new accumulated position is held and be accompanied by all elements necessary for the assessment of the request, namely the following:
a) […] b) […] c) Declaration, signed by the Member concerned and by the Institution itself, stating that “The information provided in the parts (identify the Part and the specific point of the questionnaire that is altered) of the questionnaire now sent on (date) constitute the only changes to the last questionnaire sent regarding (indicate name), with the remaining answers previously provided remaining unchanged”; and d) Assessment by the Institution regarding the impact of the accumulation of new positions on the assessment of the availability and independence of the Person concerned. 3 - In the cases provided for in paragraph 1 of this Article and not opposing the Bank of Portugal to the intended accumulation, the Institution must communicate to the Bank of Portugal the date on which the member concerned started the new functions within 15 business days after the start thereof.

Instrução n. o 13/2025 BO n. o 10/2025 • 2025/10/15 Temas Supervisão :: Registo
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Portugal the date on which the member concerned started the new functions within 15 business days after the start thereof.
4 - […]
5 - The new accumulated positions during the term of office that are not reappointable to management or supervisory functions shall be communicated by the Institution subject to the supervision of the Bank of Portugal as supervening facts, framed under the provisions of paragraph 3 of Article 3 of this Instruction, when they are capable of affecting the suitability requirements of the Person concerned.» 8 – Article 8 of Instruction No. 23/2018 shall have the following wording:
«Article 8.
[…]
1 - […]
2 - In cases where the authorization for the exercise of functions is refused, the documents shall be kept until after the administrative decision has consolidated its effects in the legal order and the legal period for review of the decision by the administrative entity itself has elapsed, and their presentation may be requested at any time by the Bank of Portugal, in accordance with the provisions of Bank of Portugal Instruction No. 11/2023.» 9 – The following parts of the questionnaire on suitability, professional qualification, availability, independence and conflicts of interests, annexed to Instruction No. 23/2018, are amended, and shall have the wording contained in Annex I to this instruction:
a) The Declaration for compliance with the duty of information regarding the processing of personal data by the Bank of Portugal, which corresponds to point 2; b) Part 3, relating to information about the candidate; c) Part 4, relating to the function for which authorization is requested; d) Part 5, relating to the suitability requirement; e) Part 6, relating to the qualification and professional experience requirement; f) Part 7, relating to the availability requirement; g) The title and filling instructions of Part 9, relating to the independence and incompatibilities requirement. 10 – Letters a) and b) of the validation list for the authorization process for the exercise of functions, annexed to Instruction No. 23/2018, are amended, and shall have the wording contained in Annex II to this instruction.

Instrução n. o 13/2025 BO n. o 10/2025 • 2025/10/15 Temas Supervisão :: Registo
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Article 3.
Republication
Instruction No. 23/2018 is republished in the annex with the amendments introduced by this Instruction.
Article 4.
Entry into force and transitional regime
1 – This Instruction enters into force on the day following its publication, applying to new requests submitted from that date.
2 – For Institutions that have already made the deliberation of designation of the members of their respective management and supervisory bodies on the date of entry into force of this instruction, the 30 business day period for submitting the request for authorization for the exercise of functions provided for in paragraph 2 of Article 5 of Instruction No. 23/2018 shall be counted from the date of entry into force of this instruction. 3 – For Credit Unions integrated into the Integrated System of Mutual Agricultural Credit, the 30 business day period provided for in paragraph 4 of Article 5 of Instruction No. 23/2018 shall be counted from the date of entry into force of this instruction, if on this date the opinion of the Central Credit Union has already been issued under Article 10 of the Legal Regime of Agricultural Credit and Agricultural Credit Cooperatives. 4 – For Institutions where the term of office of the members of the management and supervisory body has ended prior to the entry into force of this instruction, the periods of 8 and 10 months for submitting the request for authorization for the exercise of functions provided for in paragraphs 3 and 5 of Article 5 of Instruction No. 23/2018 shall be counted from the date of entry into force of this instruction. 14 October 2025 - The Governor, Álvaro Santos Pereira.

DECLARATION BY THE PERSON FOR WHOM AUTHORIZATION FOR THE EXERCISE OF FUNCTIONS IS REQUESTED
(hereinafter referred to as “Candidate”)
I, ________________________________ declare, under oath of honor, that the information provided in this questionnaire corresponds to the truth and is complete and that, based on the same, I consider myself to meet the necessary requirements, as defined by the General Regime of Credit Institutions and Financial Companies (“RGICSF”) and other applicable legislation, to contribute to the sound and prudent management of the Institution ___________________________________, or to its adequate supervision. I further declare that I am aware of the obligations arising from binding norms and soft law, both national and international, including those arising from national legislation and those issued by the Bank of Portugal, the European Central Bank (“ECB”) and the European Banking Authority (“EBA”) that are relevant for the functions I intend to perform and I manifest my purpose to continuously comply with them. I further declare, under oath of honor, that if during the term of office any supervening fact occurs to the authorization for the exercise of functions that is capable of affecting the suitability requirements and alters the information contained in this questionnaire, I will immediately inform the Bank of Portugal, through the Institution. I further declare that I am aware that the provision of false or omitted information may constitute grounds for refusal or revocation of the authorization for the exercise of functions, without prejudice to the eventual application of criminal or administrative sanctions. Date __ / __ / ____ ___________________________________________ (Signature of the Candidate)

Annex to Instruction No. 13/2025 BO No. 10/2025 • 2025/10/15
Topics Supervision :: Registry
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IN THE EVENT OF INABILITY TO PROCEED WITH THE DIGITAL SIGNATURE OF THIS DECLARATION, IT MAY BE PRINTED, SIGNED AND UPLOADED IN PDF FORMAT IN THE CORRESPONDING PROCESS.
2. COMPLIANCE WITH THE DUTY OF INFORMATION REGARDING THE PROCESSING OF PERSONAL DATA
This document explains the reasons for the collection and processing of your personal data, how they are used and how you can exercise your rights regarding your personal data. a) Responsible party, ground and purpose Personal data are processed by the Bank of Portugal, a public law legal entity with registration number 500 792 771 and headquarters at Rua do Comércio, No. 148, 1100-150, Lisbon, in compliance with the General Data Protection Regulation 1 (GDPR) and other applicable data protection legislation, for the exercise of public interest functions and the public authority powers vested in the Bank of Portugal, in compliance with the provisions of its Organic Law 2 and other applicable legislation and as established in Article 6(1)(c) and (e) of the GDPR. GDPR Organic Law of the Bank of Portugal The aforementioned data processing has as its purpose the assessment of suitability for the exercise of functions by members of management or supervisory bodies, branch managers or representatives’ offices or holders of essential functions by the Bank of Portugal and/or the European Central Bank (ECB), under the terms provided for in Articles 30 et seq. of the General Regime of Credit Institutions and Financial Companies 3 (RGICSF) and other applicable legislation, as well as the preparation of summaries relating to suitability assessment interviews conducted within the processes that include the authorization for the exercise of functions by candidates. To obtain more information about the suitability requirements assessed, the procedure, the competences and the applicable legislation, please consult here 4 . Personal data are also processed by the Bank of Portugal for the exercise of its prudential supervision and investigation and sanctioning powers, namely for the following purposes:
– Registration with the Bank of Portugal
Cfr. Articles 65 to 72 of the RGICSF and Article 35 of the Legal Regime of Payment Services and Electronic Money, approved by Decree-Law No. 91/2018, of 12 November (“RJSPME”) – Revocation of authorization for the exercise of functions Cfr. Article 30-C of the RGICSF – Application of sanctioning measures See, inter alia, Articles 201 et seq. (namely paragraph 1 of Article 213) of the RGICSF and Article 10 of the GDPR. – Publication of identification of members of management and supervisory bodies on the Bank of Portugal website Cfr. Articles 65 to 72 and letter f) of Article 93-A, all of the RGICSF, Article 35 of the RJSPME and Articles 5 and 14 of the Administrative Procedure Code.

1 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.
2 Approved by Law No. 5/98, of 31 January.
3 Approved by Decree-Law No. 298/92, of 31 December, in the wording in force.
4
Information available at https://www.bportugal.pt/page/adequacao-dos-membros-dos-orgaos-de-administracao-e-fiscalizacao-e-dos-titulares-defuncoes

Annex to Instruction No. 13/2025 BO No. 10/2025 • 2025/10/15
Topics Supervision :: Registry
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IN THE EVENT OF INABILITY TO PROCEED WITH THE DIGITAL SIGNATURE OF THIS DECLARATION, IT MAY BE PRINTED, SIGNED AND UPLOADED IN PDF FORMAT IN THE CORRESPONDING PROCESS. – Monitoring and surveillance of compliance with applicable legislation, namely the RGICSF, Regulation (EU) No. 575/2013 of the European Parliament and of the Council of 26 June 2013 and other applicable legislation, namely for risk assessment, issuance of recommendations, specific determinations or corrective measures, as well as for assessment of the granting of credit to related parties, assessment of the capacity to comply with the duties established in the applicable legislation, etc. See, inter alia, Article 116 of the RGICSF. – Disclosure of information in compliance with legal obligation Cfr., inter alia, see Articles 20 and 21 of Regulation (EU) No. 468/2014 of the European Central Bank of 16 April (MUS Framework Regulation), Articles 4 and 6 of Regulation (EU) No. 1024/2013 of the Council of 15 October (MUS Regulation), paragraphs 7 and 8 of Article 30-D of the RGICSF and paragraph 2 of Article 65 of the RGICSF. – Archive of public interest Cfr. General Regime of Archives and Archival Heritage, approved by Decree-Law No. 16/93, of 23 January. – Research and quantitative analyses and statistical reports at an aggregated level (in this case, personal data will be aggregated and sufficiently anonymized, so that persons cannot be identified at the aggregated level). Cfr., inter alia, paragraph 7 of Article 30 of the RGICSF, letter b) of paragraph 1 of Article 5, and paragraph 1 of Article 89 of the GDPR Within the scope of these purposes, data processing may involve the use of technological means, including the automated and standardized processing of information, as well as the phases of the decision-making processes, with the aim of improving the efficiency and performance of supervision functions. Although this use does not constitute an autonomous purpose, it integrates the processing process and contributes to the execution of the purposes described. In this context, it is important to clarify that decisions taken within the scope of the above-mentioned activities will not be based exclusively on automated processing that produces legal effects (or other equally significant effects) on the holders of personal data. In the case of assessment of suitability for the exercise of functions in significant institutions, the ECB, with headquarters at Sonnemannstrasse 20, D-60314 Frankfurt-am-Main, Germany, also processes personal data for the fulfillment of the aforementioned purpose and is responsible for the processing, in accordance with paragraph 8 of Article 3 of Regulation (EU) No. 2018/1725. The declaration for compliance with the duty of information of the ECB may be consulted here 5 . b) Categories of personal data and respective origin The following categories of personal data are processed:
(i) Personal data provided by the person:
a. Identification and contact data (name, address, e-mail, telephone contact, etc.); b. Data related to the assessment of suitability (such as information contained in the criminal record certificate, information about administrative, criminal or civil proceedings, including insolvency proceedings, recovery or liquidation of entities, dismissal proceedings, prohibition of exercise of functions, mentions of defaults in the credit responsibility center);

5 The declaration is available at https://www.bankingsupervision.europa.eu/home/data-protection/privacy-statements/FAP/index.en.html

Annex to Instruction No. 13/2025 BO No. 10/2025 • 2025/10/15
Topics Supervision :: Registry
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IN THE EVENT OF INABILITY TO PROCEED WITH THE DIGITAL SIGNATURE OF THIS DECLARATION, IT MAY BE PRINTED, SIGNED AND UPLOADED IN PDF FORMAT IN THE CORRESPONDING PROCESS.
c. Data related to the assessment of professional qualification (such as information about academic background and professional experience, including skills acquired in functions held and training);
d. Data related to the assessment of independence (information about personal, professional, financial, political conflicts of interest, including information about family relationships, loans, guarantees and other obligations); e. Data related to the assessment of availability (such as the hours intended to dedicate to the exercise of functions); f. Voice. (ii) Personal data provided by the supervised entity (such as in individual and collective assessment reports) related to the categories indicated above; (iii) Personal data that have come to the knowledge of the supervisor by other means (such as those communicated by the ECB, by the Securities Market Commission (CMVM), by the Insurance and Pension Funds Supervisory Authority (ASF), by the European Banking Authority (EBA), by similar authorities, by judicial authorities or data accessible in open sources available to the public); (iv) Personal data of persons related to the person/entity to be supervised (for example: of workers, clients or family members) provided within the scope of the communications referred to above; (v) Personal data obtained internally at the Bank of Portugal (such as the data contained in the Credit Responsibility Center regarding possible defaults). For a more detailed identification, please consult this instruction, as well as Instruction No. 7/2021. For additional information, please contact us through encarregado.protecao.dados@bportugal.pt. c) Obligation The provision of data necessary for these purposes is mandatory. The consequences of not providing the requested information will be determined on a case-by-case basis. The failure to provide the information may lead to a negative decision. The non-recording of interviews conducted within the processes that include the authorization for the exercise of functions by candidates may imply the impossibility of compliance, by the Bank of Portugal, with legal obligations. d) Retention Data will be kept for the time corresponding to the limitation period of the applicable criminal or administrative procedure for offenses related to the activity. In cases legally permitted, data may also be kept for purposes of public interest and/or historical archive. Interview recordings with the candidate will be immediately destroyed after the drafting and confirmation by the data holder of the content of the summaries, thus the Bank of Portugal will not retain the data.

Annex to Instruction No. 13/2025 BO No. 10/2025 • 2025/10/15
Topics Supervision :: Register
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IN THE EVENT THAT IT IS NOT POSSIBLE TO PROCEED WITH THE DIGITAL SIGNATURE OF THIS DECLARATION, IT MAY BE PRINTED, SIGNED, AND UPLOADED IN PDF FORMAT IN THE CORRESPONDING PROCESS.

e) Recipients
The data processed by Banco de Portugal are intended for internal use, in particular by the Prudential Supervision Department and the Investigation and Sanctioning Action Department, always respecting the principle of need-to-know access by Bank staff, including subcontractors acting under the instructions and on behalf of Banco de Portugal (such as specialist legal consultants), all of whom are bound by a duty of confidentiality. The information will not be shared with third parties, except in situations where the law requires it. Indeed, to fulfill its functions, Banco de Portugal may share personal data with a limited number of people:
(i) From Banco de Portugal and the ECB, in the exercise of their functions; and (ii) From other Union institutions, similar authorities, and national entities (such as the EBA, the CMVM, the ASF, as well as judicial authorities), within the scope of cooperation powers with these authorities.

f) Transfer of personal data
The collected personal data may be communicated to similar authorities, international organizations, and other entities in third countries, within the scope of cooperation powers with these authorities. In the absence of an adequacy decision, personal data will only be transferred to a third country or international organization through the provision of adequate guarantees, in compliance with Article 46 of the GDPR and Article 48 of Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 (Regulation (EU) 2018/1725). In exceptional situations, transfers of personal data may be carried out in compliance with Article 49 of the GDPR and Article 50 of Regulation (EU) 2018/1725. The data will be transmitted to the Information System of the ESAs established under Article 31-A of the founding Regulations of the EBA, ESMA, and EIOPA 6. Further information on the processing of data through this Information System can be consulted via the link DATA PROTECTION STATEMENT - ESAs INFORMATION SYSTEM 7.

g) Rights
Under the provisions of the Regulation and other applicable data protection legislation, the data subject has the right:
– To request access to the personal data concerning them, its rectification, and its deletion; and – To the limitation of processing.
The exercise of the right to rectify personal data provided by the candidate in the questionnaire is exercised under the terms provided for in paragraphs 3 and 4 of Article 3 of this Instruction.

6 Cf. Joint Guidelines of the EBA, ESMA and EIOPA No. JC/GL 2024/88, of 20 November 2024, under the name “Joint Guidelines on the system established by the European Supervisory Authorities for the exchange of information relevant for the assessment of the fit and proper status of holders of qualifying holdings, members of administrative, management and supervisory bodies and key function holders of financial institutions and participants in financial markets by competent authorities”. 7 https://www.eiopa.europa.eu/publications/joint-guidelines-exchange-information-relevant-fit-and-proper-assessments_en

h) Contacts
Data subjects, to exercise their rights, may contact:

The service points of Banco de Portugal;
By post; or
Via email to info@bportugal.pt.

i) Complaint
If they consider that their rights have not been duly attended to and wish to complain, data subjects may contact the DPO through the following means:

By email: encarregado.protecao.dados@bportugal.pt
By post:
Data Protection Office of Banco de Portugal
Rua do Comércio, 148
1100-150 Lisbon

j) Complaint to the National Data Protection Commission (CNPD) Finally, data subjects may always submit a complaint to the CNPD, as the supervisory authority.

k) Processing for subsequent purposes
The collected data will also be processed for other activities developed by the Bank, which integrate its supervisory powers, as well as for the exercise of other functions of public interest, including the application of sanctioning measures, based on the exercise of functions of public interest or under the powers of public authority vested in it (Article 6(1)(e) of the Regulation), being retained for the period of time strictly necessary for the pursuit of said purposes, and may be transferred under the terms described in point 6., with the data subject retaining the rights, as referred to above. By virtue of this processing, these data may be communicated to the following recipients: - European Central Bank, within the scope of the Single Supervisory Mechanism; - Securities Market Commission (CMVM), the Insurance and Pension Funds Supervisory Authority (ASF) and similar authorities, within the scope of cooperation powers with these authorities. The processing of data for the aforementioned purpose does not involve automated individual decisions.

I have taken note,
Date __ / __ / ____

(Signature of the Data Subject)

DECLARATION BY THE INSTITUTION SUBMITTING THE APPLICATION FOR AUTHORIZATION
(hereinafter referred to as the “Requesting Institution”) The undersigned, on behalf of the Requesting Institution, declare(s) the following:
To the best of the knowledge of the Requesting Institution, the information provided in this questionnaire corresponds to the truth and is complete.
(Yes/No)
If, during the mandate, they become aware of any fact subsequent to the authorization for the exercise of functions that is capable of affecting the candidate’s fit and proper requirements and alters the information contained in this questionnaire, the Requesting Institution will immediately inform Banco de Portugal. (Yes/No) The Requesting Institution has sought to obtain the most complete and up-to-date information possible about the Candidate, and this information has been duly weighed and taken into account in the assessment of the Candidate’s fit and proper status for the exercise of the functions in question. (Yes/No) The function for which this authorization is requested corresponds to that which is expected for the Candidate to effectively perform. (Yes/No) Based on the information it has sought to obtain regarding the Candidate and keeping in mind the fit and proper requirements for the exercise of functions established in the RGICSF and the provisions of the rest of the applicable legislation, the Requesting Institution considers that the Candidate is fit and proper for the exercise of the functions proposed, presenting the capacity to ensure, on a permanent basis, the sound and prudent management of the Requesting Institution or its adequate supervision, as stated in the respective individual assessment report. (Yes/No) The Requesting Institution has informed the Candidate about the legal and regulatory responsibilities associated with the functions they intend to perform. (Yes/No) They confirm that they have sufficient powers to make the above declarations and sign this questionnaire on behalf and in representation of the Requesting Institution. (Yes/No) Name of the Requesting Institution 8:

8 The person(s) signing the questionnaire on behalf and in representation of the Requesting Institution should be the person(s) or body to whom the responsibility for carrying out the assessment of the Candidate’s fit and proper status has been attributed, in accordance with Article 30-A, paragraph 2 of the RGICSF, whose identification is contained in the internal policy for the selection and assessment of fit and proper status of members of administrative and supervisory bodies approved by the General Meeting of the Requesting Institution.

Full name of the signatory(ies): _________________________________ Position(s)/Capacity: _________________________________ Signature(s): _________________________________ Date: //____

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PART 1. Type of Authorization
1.1 Prior authorization for appointment?
(Yes/No)

PART 2. Information on the Requesting Institution
2.1 Identification
2.1.1 Trade name or denomination:
2.1.2 Type of institution (credit institution, financial company, payment institution, or electronic money institution):
2.1.3 Is the institution in question part of the Public Business Sector, according to the terms of Decree-Law No. 133/2013, of 3 October?
(Yes/No)
2.1.4 Address:
2.1.5 Telephone:
2.1.6 Fax:
2.1.7 Email address:
2.1.8 Is it a Significant Institution?
(Yes/No)
(In the affirmative, it must be confirmed that the questionnaire in question is applicable, by consulting Banco de Portugal Instruction No. 7/2021)
2.2 Other national financial supervisory authority to which the Requesting Institution is subject:
2.2.1 ASF:
(Yes/No)
2.2.2 CMVM:
(Yes/No)
2.3 Contact person within the authorization process and subsequent registration:

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2.3.1 Name:
2.3.2 Position:
2.3.3 Professional address:
(fill in only if it does not coincide with the address indicated for the Requesting Institution)
2.3.4 Telephone:
2.3.5 Fax:
2.3.6 Email address:

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PART 3. Information on the Candidate
3.1 Identification and contacts
3.1.1 Full name:
3.1.2 Other names by which they are known (in English acronym AKA, “Also Known As”)
3.1.3 Gender:
(Female/Male)
3.1.4 Date of birth:
(Day/Month/Year)
3.1.5 Parish:
3.1.6 Municipality:
3.1.7 Country:
3.1.8 Nationality:
3.1.9 ID document number:
3.1.10 ID document validity date:
3.1.11 Tax identification number:
3.1.12 Usual residence:
(Street / No. / Floor)
3.1.13 Locality:
3.1.14 Postal Code:
3.1.15 Country:
3.1.16 Start date of this residence:
(Day/Month/Year)
3.1.17 Telephone contact:
3.1.18 Fax:
3.1.19 Email address:

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3.1.20
3.1.20.1 Did they reside or work in a country different from their country of nationality in the last ten years?
(Yes/No)
3.1.20.2 In case of an affirmative answer to question 3.1.20.1, indicate the country/countries where they resided.

3.2 Candidate’s Authorization for Banco de Portugal communications to be made via telephone, fax, or email, for the contacts mentioned above
(Yes/No)

3.3 Candidate’s authorizations or registrations, current or past, including any refusals, in national or foreign supervisory authorities (specifically regarding the exercise of functions as a member of an administrative or supervisory body, branch manager, representative office manager, acquirer of qualifying holdings, etc.)
(Add space and filling lines to this field as necessary to provide complete information)

National or foreign supervisory authority	Institution	Functions	Start Date	End Date	Assessment Date	Includes assessment on fit and proper? (Yes / No)	Summary conclusion of assessment 9

9 Ex. positive, positive with conditions, positive with recommendations, or negative.

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3.3.1 In case of refusal of authorization or registration, or of a positive assessment with conditions or recommendations, indicate in detail the reasons.

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PART 4. Function for which authorization is requested
4.1 Position:
(Indicate if it assumes presidency or vice-presidency of a collegiate body or if they are indicated as responsible for the internal control function)
4.2 Executive functions / daily management:
(Yes/No)
4.3 Portfolio:
(Concrete areas under the Candidate’s responsibility)
4.4 Is the Candidate indicated as the executive member of the administrative body responsible for the function of controlling compliance with the framework on money laundering and terrorist financing, for the purposes of Banco de Portugal Notice No. 1/2022?
(Yes/No)
4.5 As detailed a description as possible of the main duties, responsibilities, and tasks inherent to the functions for which authorization is requested, as well as indication of the number of subordinates and the number of hours per week and/or the number of days per year that the Requesting Institution considers necessary for the adequate exercise of the position. If applicable, indication of other functions that the Candidate will exercise in the Requesting Institution.
(This question is directed, primarily, to the Requesting Institution)
4.6 Indication of the committees that the Candidate is expected to join as a result of exercising the functions for which authorization is requested.
4.7 Is the Candidate indicated as independent for the exercise of the position?
(Yes/No/N/A)
4.8 Mandate:
(start year / end year)
4.9 Appointment date (planned):
(day/month/year)

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4.10
4.10.1 Designation ex novo:
(Yes/No)
4.10.2 Reappointment:
(Yes/No)

4.11
4.11.1 Was the application for authorization for the exercise of functions submitted within the deadlines established in paragraphs 2 to 5 of Article 5 of the Instruction, as applicable?
(Yes/No)
4.11.2 If the answer to question 4.11.1 is negative, indicate the reason.

4.12
4.12.1 Will the Candidate replace someone in the position? (this information is dispensed with in cases of appointment of members of the administrative or supervisory body for a new mandate):
(Yes/No)
4.12.2 In case of an affirmative answer to question 4.12.1, indicate who and the reasons.

4.13 Indicate the nature of the Candidate’s link with the Requesting Institution:
(Mandate, employment contract, service provision, or other)

4.14
4.14.1 Will the Candidate exercise the position on the board of directors as appointed under Article 390, paragraph 4 of the Commercial Companies Code?
(Yes/No/Not applicable)
4.14.2 In case of an affirmative answer to question 4.14.1, indicate the legal entity that appointed them.

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4.15
4.15.1 Will the Candidate exercise the position on the supervisory body in representation of a company (SROC or other)?
(Yes/No)
4.15.2 In case of an affirmative answer to question 4.15.1, indicate the company they represent.

PART 5. Suitability

The answers to the questions below should:
a) Take into account situations that have occurred in Portugal or abroad; b) Include the reporting of ongoing proceedings in which there are indications of the candidate's responsibility or direct or personal involvement in the commission of the facts in question; c) Include the reporting of ongoing proceedings not included in b) and which the Institution and the candidate consider to be likely to have a material impact on the assessment of the suitability requirement; d) Include the reporting of concluded proceedings in which responsibility or direct or personal involvement of the person concerned has been established, even if concluded more than 10 years ago; and e) Include the reporting of concluded proceedings less than 10 years old, not included in d) and which the Institution and the candidate consider to be likely to have a material impact on the assessment of the suitability requirement.

Indications of the candidate's responsibility are considered to exist, namely, in cases where the same has been made a defendant, accused or indicted for the commission of a crime or the commission of an offense. It is understood that the candidate's responsibility has been established, namely, in cases where the same has been convicted for the commission of an unlawful act of a civil, criminal, regulatory or other nature.

Direct or personal involvement of the candidate is considered to exist when, inter alia, the appointed person has been responsible for a division or line of business, a member of the management body with responsibility for the matter subject to the offense, or when the proceedings (including sanctions or measures imposed) or facts demonstrate an omission or inaction by the candidate. Situations should also be identified where it is considered that the candidate did not act with due diligence, honesty and integrity while holding an essential function, senior management position, member of the management body or manager. Conversely, there will be no direct or personal involvement if the appointed person does not hold any position in the institution at the time of the offense (for example, was not a member of the management body nor responsible for an area involved in the facts) 10.

As a general guideline, it may be considered that, in principle, proceedings of a regulatory nature instituted against the Requesting Institution or another entity controlled by it or in which the candidate exercised functions of administration, management or supervision, in relation to which no personal responsibility of the candidate has been established and the sanction applied was a reprimand or a fine of less than € 10,000.00, will not have a material impact on the assessment of the suitability requirement. Conversely, an accumulation of proceedings of the same nature or originating from the same area may be considered to have a material impact on the assessment, even if referring to offenses committed negligently or with the application of fines of a small amount.

With regard to the questions posed in the points below, the reference to proceedings for regulatory offenses or insolvency covers proceedings of an equivalent nature (i.e. transgression or liquidation proceedings), instituted under national or foreign legislation.

Questions addressed to the Candidate:

10 See also the definition of "direct or personal involvement" contained in the ECB Guide to the assessment of fitness and propriety.

5.1 Have you ever been refused, cancelled or revoked authorization, registration, admission or license to exercise a commercial, business or professional activity by a supervisory authority, professional order or body with similar functions, or have you ever been removed from the exercise of an office by a public entity, or have you ever been prohibited from such exercise by the competent authorities?
(Yes/No)
(In the affirmative, the answer to question 5.18 should cover authorities from the financial and non-financial sectors)

5.2 Have you ever been dismissed, had your employment terminated (involuntarily) or removed from a position that required a special relationship of trust?
(Yes/No)
(Ex: removal from the office of administrator or equivalent or request to resign from such office)

5.3 Have you ever been prohibited, by a judicial authority, supervisory authority, professional order or body with similar functions, from acting as an administrator or manager of a civil or commercial company or from performing functions therein?
(Yes/No)

5.4 Have you ever had a mention of non-compliance regarding you included in the credit responsibility central or in any other records of a similar nature, by the competent authority for that purpose?
(Yes/No)

5.5 Have you ever been declared insolvent or are there any insolvency proceedings pending against you?
(Yes/No)

5.6 Have you ever had insolvency declared or are there any insolvency proceedings pending against a company controlled by you or in which you were a director, manager or member of the management or supervisory body?
(Yes/No)

5.7 Are there any proceedings pending or concluded for the recovery or liquidation of entities managed by you or in which you were or are a holder of a qualifying participation?
(Yes/No)

5.8 Are there pending or concluded administrative proceedings, criminal proceedings or civil actions that may have a significant impact on your financial solidity or that of the Requesting Institution or another in which you exercised functions of administration and/or supervision, referring to the period in which you exercised functions, or are there other circumstances of this nature to be considered?
(Yes/No)

5.9 Have you ever been accused, indicted or convicted of crimes against property, crimes of forgery and falsity, crimes against the administration of justice, crimes committed in the exercise of public functions, tax crimes, crimes specifically related to the exercise of financial and insurance activities and with the use of payment means, and also crimes provided for in the Commercial Companies Code, or are there proceedings of this nature pending in which you are the target?
(Yes/No)

5.10 Are there any other criminal proceedings of this nature pending in any court against you or against any company controlled by you or in which you exercise or have exercised functions as director, manager or

member of the management or supervisory body, not referred to in the previous points, or have you or such company been convicted in proceedings of this nature? (Yes/No)

5.11 Have you ever been accused or convicted of non-compliance with legal or regulatory rules governing the activity of credit institutions, financial companies and pension fund management companies, as well as the rules governing the securities market and the insurance or reinsurance activity, including insurance or reinsurance mediation?
(Yes/No)
(Include in point 5.18 civil or criminal judicial proceedings, as well as regulatory proceedings instituted by the Bank of Portugal, the CMVM, the ASF, the Competition Authority or by a foreign supervisor, pending or concluded for any reason)

5.12 Has a company controlled by you or in which you exercised functions of administration, management or supervision ever been accused or convicted of non-compliance with legal or regulatory rules governing the activity of credit institutions, financial companies, payment institutions and electronic money institutions and pension fund management companies, as well as the rules governing the securities market and the insurance or reinsurance activity, including insurance or reinsurance mediation?
(Yes/No)
(Include in point 5.18 civil or criminal judicial proceedings, as well as regulatory proceedings instituted by the Bank of Portugal, the CMVM, the ASF, the Competition Authority or by a foreign supervisor pending or concluded for any

reason)

5.13 Are there pending or concluded any proceedings related to the infringement of disciplinary rules, or ethical or conduct rules within the scope of regulated professional activities?
(Yes/No)

5.14 Have you ever been subject to judicial removal, or judicial confirmation of removal for just cause, as a member of the management or supervisory body of any commercial company?
(Yes/No)
(In the affirmative, refer in point 5.18 to the specific facts that determined such removal or confirmation)

5.15 Have you ever been convicted, for damages caused to the company, to shareholders, to corporate creditors or to third parties, in the capacity of administrator, director or manager of any commercial company, or are there proceedings of this nature pending?
(Yes/No)

5.16 Has any of the proceedings of the types referred to above been resolved by agreement between the parties or within the scope of alternative dispute resolution? (if applicable)
(Yes/No)

5.17 Are there pending or concluded administrative proceedings, criminal proceedings or civil actions, not referred to in the numbers above, that may have a significant impact on your reputation or the reputation of the Requesting Institution or another in which you exercised functions of administration and/or supervision, referring to the period in which you exercised functions, or are there other circumstances of this nature to be considered?

(Yes/No)

5.18 In the event of an affirmative response to any of the previous questions and where the situations in question fall within those referred to in the introduction to Part 5 of the questionnaire, indicate:

Regarding any proceedings:
a) facts that motivated the initiation of the proceeding(s); b) type(s) of offense or crime; c) whether there was constitution as defendant, accusation, indictment, conviction and/or archiving of the proceeding; d) date of constitution as defendant, accusation, indictment, conviction and/or archiving of the proceeding; e) direct or personal involvement of the Candidate in the commission of the facts that motivated the initiation of the proceeding; f) the time elapsed and the conduct of the Candidate since the commission of the facts that motivated the initiation of the proceeding; g) penalty, fine or sanction applied; h) court or entity where the proceeding is or was pending; i) phase in which the proceeding is; and j) any other aggravating or mitigating circumstances.
Regarding any insolvencies:
a) name of the companies involved in insolvency proceedings; b) functions specifically exercised in that company; c) indication of whether the insolvency was considered fraudulent or negligent, under the Penal Code; and d) indication of whether the insolvency was qualified as culpable or fortuitous, under the Insolvency and Corporate Recovery Code.
Regarding any refusals of authorization, registration, admission or license to exercise a commercial, business or professional activity, the respective grounds.
Add any additional information that is considered relevant.

5.19 If applicable, indicate the questions to which the response was affirmative, but which do not fall within the situations provided for in the introduction of Part 5 and which, for this reason, the Institution considered that the existing proceedings against the Candidate or other institutions should not be reported, in the

terms above.

Questions addressed to the Requesting Institution:

5.20 Has the competent body of the Requesting Institution ever taken any decision on any aspects related to the suitability of the Candidate?
(Yes/No)

5.21 In the affirmative, explain the circumstances.

PART 6. Qualification and professional experience (minimum: last 10 years) – Curriculum Vitae

6.1 Professional Qualification
Course designation / training Area Start Date End Date Educational Institution

6.2 Professional Experience

6.2.1 Relevant professional experience in the banking or financial sector
Entity Size 11 Position (reporting level 12) Areas of activity Main responsibilities Number of subordinates Start Date End Date Reasons for termination

6.2.2 Relevant professional experience outside the banking or financial sector
Entity Size 13 Position (reporting level 14) Areas of activity Main responsibilities Number of subordinates Start Date End Date Reasons for termination

11 For example, annual total assets.
12 When the position is not that of a member of the management or supervisory body, indicate whether the position is one, two or more levels below the management body. 13 For example, total turnover and indication of international presence. 14 When the position is not that of a member of the management or supervisory body, indicate whether the position is one, two or more levels below the management body.

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6.2.3 Additional relevant information
(If there is additional information that is relevant to clarify the level of knowledge acquired through the training attended or experience resulting from the positions indicated in the tables above, this should be mentioned. For example, the nature and degree of complexity of the entity in which the Candidate exercised functions, including its organizational structure, decision-making powers and number of subordinates should be indicated. If appropriate, justification should also be presented for not attending training recommended by the Bank of Portugal in previous authorization requests.)

6.2.4 Compensating factors (e.g.: other types of professional experience, evidence of the Candidate's ability to challenge the other members of the body to which they belong and/or other bodies, overall adequacy of the other members of the body, specialized knowledge of the Candidate that is relevant to the functions for which they are proposed, a time-limited position that requires the person concerned to hold the position and justifies their appointment, among other specific situations)
(When there are no compensating factors, "Not Applicable" should be indicated)

6.2.5 Self-assessment of qualification and experience in the banking or financial sector according to the "Guidelines on the assessment of the fitness of members of the management and supervisory bodies and of the Holders of Essential Functions" of the EBA (EBA/GL/2021/06, of July 2, 2021 15)
Area Assessment (High, Medium-High, Medium-Low, Low) Financial markets Regulatory framework and legal requirements, including in matters of anti-money laundering and counter-terrorist financing Strategic planning and knowledge of the institution's strategy or business plan and their execution Risk management (identification, assessment, monitoring, control and mitigation of the main types of risk of an institution including environmental, governance and social risks and risk factors), and experience directly related to the responsibilities of the member Accounting and audit Assessment of the effectiveness of an institution's procedures, creating effective governance, supervision and control procedures Interpretation of an institution's financial information, identification of main issues based on this data and appropriate controls and measures

6.2.6 Other relevant specialized experience:
(Enumerate)

6.2.7 Will the Candidate attend specialized training before the start of functions or during the first year of functions?
(Yes/No)
In the affirmative, indicate
Content
Training entity
(Requesting Institution or indicate the name of the external entity) Start Date End Date

6.2.8 When the exercise of functions in a collegiate body is concerned, identify to what extent the Candidate contributes to the collective adequacy of the body. Also indicate, with reference to potentially identified weak points in the collective composition of the body, to what extent the appointment of the Candidate contributes to the resolution of all or some of these weak points.
(This question is directed, in the first place, to the Requesting Institution)

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PART 7. Availability
7.1 List of all executive and non-executive positions, as well as all professional activities that the Candidate intends to perform cumulatively
All corporate positions held in governing bodies (e.g., positions in administrative and supervisory bodies or in the Chair of the General Meeting) must be indicated, as well as other professional activities (management positions or roles as an employee in companies, activities as a lawyer, consultant, auditor, professor, etc.), regardless of whether these functions are performed under an employment contract, a service provision contract, or other link and whether they are performed in institutions of the banking and financial sector or in institutions of other sectors. Positions held in non-profit entities (e.g.: Foundations, Associations, etc.) must also be indicated. Regarding Candidates who are Official Auditors of Accounts ("OAs") and who perform their professional activity within an Official Auditors of Accounts Society ("OAAS"), the position held in the OAAS must be indicated (e.g.: manager of the OAAS or collaborator of the OAAS), and the time necessary for the performance of all OA positions that the Candidate holds in client companies of the OAAS (i.e., OA positions performed within the context of the OAAS and using its resources) shall be counted there. OA positions that are not performed in the context of the functions performed in the OAAS should only be listed separately. Otherwise, positions performed as a member of a supervisory body (including the position of Sole Auditor) must always be indicated autonomously, whether such positions are held on behalf of an OAAS or performed in one's own name. (Include in the table the position to which this questionnaire refers, indicating it first, followed by the other functions that the Candidate intends to perform in accumulation) If necessary, you may add space and filling lines to this field.

16 For example, total annual assets for financial institutions and total turnover and indication of international presence for other types of institutions. 17 At the Bank of Portugal, CMVM, ASF, or foreign supervisory authority. 18 If applicable, indicate in particular the participation or group relationships between the institutions referred to in the questionnaire (if possible, in percentage terms), if they depend on the same parent company or if there are shareholders or partners with significant influence.

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7.3 Was any of the positions referred to in 7.1 above authorized as an additional non-executive position, under the provisions of article 33.º, paragraph 7 of the RGICSF?
(Yes/No)
7.4 Based on the information contained in this Part 7 of the questionnaire, do the Candidate and the Requesting Institution consider that he ensures the
necessary availability for the performance of all activities he intends to exercise, taking into account the characteristics and requirements of the same, the need for continuous training and development, as well as the need for a margin for unexpected circumstances 19? (Yes/No)
7.5 Systemically Important Institutions (“O-SIIs”) 20
(Answer these questions only if this questionnaire concerns the exercise of functions as a member of the administrative or supervisory body of a Systemically Important O-SII Institution.)
7.5.1 Is the Candidate appointed as a member of the administrative or supervisory body of
a credit institution that benefits from extraordinary public financial support and was appointed specifically in the context of that support, under the provisions of paragraph 5 of article 33.º of the RGICSF? (Yes/No)
7.5.2 Does the request for authorization for the exercise of functions to which this questionnaire relates
correspond to a request for accumulation of an additional non-executive position under the

19 Unexpected circumstances include not only crisis situations related to the institution, but also circumstances capable of unexpectedly affecting the time dedicated to the exercise of the position (for example, judicial processes). 20 Institutions classified by the Bank of Portugal as Systemically Important Institutions, under article 138.º-Q of the RGICSF and identified in a list published by the Bank of Portugal.

21 "Close persons of the Candidate" include, in particular, their spouse, person with whom they live in a de facto union, person with whom they live in a common economy, descendant, ascendant or other members of the Candidate's household. 22 See note 21.

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8.3
8.3.1 Does the Candidate or any close person of the
Candidate 23 have any professional relationship (including the exercise of positions of administration or supervision, as well as top management positions 24) or any commercial relationship (whether direct or indirectly through a company to which this person is linked), or maintained such professional or commercial relationship during the last 5 years, with the Requesting Institution, its parent company or subsidiaries, with shareholders with a qualified participation in the Institution Requesting, its parent company or subsidiaries or with competitors of the Requesting Institution, its parent company or subsidiaries? (Yes/No)
8.3.2 If yes, explain the circumstances.
If it is a commercial relationship, indicate the following: (a) the financial value that this commercial relationship represents in the business of the Candidate or the close person of the Candidate, as applicable; (b) the description of the commercial relationship in question and the corresponding obligations of the parties; (c) the identification of the company through which the commercial relationship was or is developed, if applicable; and (d) the duration period.
8.4 Does the Candidate or any close person of the
Candidate 25 (personally or through a company to which they are linked) have any financial interest (such as share participation or investment) in the Institution Requesting, its parent company or

23 See note 21.
24 Positions that imply the exercise of executive functions with direct reporting to the administrative body of the institution.
25 See note 21.

8.7
8.7.1 Does the Candidate or any close person of the
Candidate 27 hold or held during the last 2 years any position of high political influence 28 (at national or local level)?
(Yes/No)
8.7.2 If yes, indicate the following: (a) the nature of the position in question; (b) the powers
inherent to the position in question, as well as their respective obligations; and (c) the relationship between the position in question (or the entity in which it was held) and the Institution Requesting, its parent company or subsidiaries.

26 See note 21.
27 See note 21.
28 There can be "high political influence" at various levels, notably in local political positions (for example, Mayor), regional or national (for example, member of the Council of Ministers); public officials (for example, in government bodies); and state representatives.

29 See note 21.

30 “Privacy statement for the processing of personal data in the context of prudential supervision under the Single Supervisory Mechanism”.

True and complete information
This questionnaire should be filled in truthfully and completely and contain information as up-to-date as possible.
Incorrect or incomplete filling of the questionnaire may cause a delay in the final decision of the Bank of Portugal regarding the request for authorization to exercise functions. The provision of false or omitted information may constitute grounds for refusal or revocation of the authorization to exercise functions, without prejudice to the eventual application of criminal or administrative penalties.
Filling in and signing of the questionnaire
The filling in of the questionnaire annexed to this Instruction should be done in the model provided by the Bank of Portugal in the SIRES application, and no changes to the document formatting are allowed. This document should not be printed and subsequently scanned for insertion into the process, with the digital version always being maintained. Manual signature should only be inserted in the declarations contained in Annex I, which, cannot be signed digitally, can be printed, signed and subsequently uploaded to the corresponding file. Unless otherwise indicated, the questionnaire fields are mandatory. Fields that are not filled in because there is nothing to declare regarding the questions posed there should be locked. If left blank, it will be presumed that there is nothing to declare regarding the questions posed there, which contributes to a negative decision, or, regarding Yes/No questions, that the answer is negative. The foregoing does not prejudice the possibility of the Bank of Portugal requesting confirmation of the answer.
Alteration of the questionnaire
If, during the mandate, any fact subsequent to the authorization to exercise functions occurs that is capable of affecting the Candidate's suitability requirements and alters the information contained in this questionnaire, without determining the presentation of an autonomous request under the terms of the RGICSF, both the Candidate and the Requesting Institution must immediately inform the Bank of Portugal. In this case, the Bank of Portugal must be sent (i) the Part of the questionnaire corresponding to the alteration

THIS DOCUMENT SHOULD NOT BE PRINTED FOR LATER SCANNING.
FILLING IN SHOULD BE DONE DIGITALLY AND INSERTED INTO THE FILE IN PDF FORMAT AFTER COMPLETION.
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ANNEX II – Amendment to Annex III to Instruction No. 23/2018 regarding the validation list for the
process of authorization to exercise functions This document contains a list for internal validation by Institutions regarding the complete and adequate instruction of authorization processes for the exercise of functions, and is not intended to be sent to the Bank of Portugal. This guide does not, of course, dispense with the development by Institutions of additional control procedures they deem necessary to ensure adequate quality of the reported information. Instruction Documents for the process ✓ or Were all documents submitted 31? a) Documents that are always necessary: Questionnaire (in the case of reappointment, the parts of the questionnaire in which alterations were registered), individual assessment report, certified copy of the identification document, criminal record certificate for all candidates and Updated Statutes. b) Documents that may be necessary: Appointment resolution (for requests submitted after the appointment), minutes referred to in article 2., paragraph 1, item f) (when the Candidate exercises functions in another Institution subject to the supervision of the Bank of Portugal), document mentioned in article 2., paragraph 1, item g) (for managers), declarations of conflicts of interests, collective assessment report and collective appreciation matrix, when there are new members and/or alterations registered regarding the reappointed members (collegial bodies). Are the submitted documents signed? Questionnaires (signed by the Candidate and the Institution), individual assessment reports, collective assessment reports, appointment resolution, minutes referred to in
article 2., paragraph 1, item f), document mentioned in article 2., paragraph 1, item g) and
declarations of conflicts of interests.
Were the questionnaires filled in all applicable fields? a) Suitability (Part 5): If affirmative answers were given to the questions in points 5.1 to 5.17 and 5.20 of the questionnaire, the situations in question are duly developed in points 5.18, 5.19 and 5.21, respectively? b) Availability (Part 7): Were all positions indicated in the table of Point 7.1 of the questionnaire all the positions that the Candidate intends to exercise?

31 Cf. article 2. of the Instruction.

THIS DOCUMENT SHOULD NOT BE PRINTED FOR LATER SCANNING.
FILLING IN SHOULD BE DONE DIGITALLY AND INSERTED INTO THE FILE IN PDF FORMAT AFTER COMPLETION.
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c) Availability (Part 7): In the case of G-SIIs, were the fields of the point 7.5 of the questionnaire filled in? d) Independence and conflicts of interests (Part 8): Were all situations of conflicts of interests identified in Part 8 of the questionnaires all effective or potential conflicts of interests identified? e) Collective appreciation matrix (Annex II): In cases of exercising functions in a collegial body, was the collective appreciation matrix filled in? f) The Institution subscribes to all the information contained in the questionnaires, signed the initial declaration included in 3. and participated actively in the answers to questions 4.5, 5.20, 7.4? Is consistency ensured between the information in the questionnaires and the assessment reports? a) The assessment of the Candidates contained in the individual assessment reports was carried out taking into account all the information collected through their respective questionnaires? b) Suitability: In case of an affirmative answer to any of the questions in points
5.1 to 5.17 and 5.20 of the questionnaires, the assessment that the Institution makes of the impact
of these situations on the suitability of the Candidates was sufficiently explained in the individual assessment reports? c) Professional qualification and experience: The assessment contained in the individual and collective assessment reports is in line with the information on the qualification and professional experience of the Candidates provided in Part 6 of their respective questionnaires? d) Professional qualification and experience: The assessment of the qualification and professional experience of the Candidates contained in the collective appreciation matrix is in accordance with the information provided in each of their respective questionnaires? e) Availability: The assessment contained in the individual assessment reports took into account the number and nature of the positions that the Candidates intend to exercise as indicated in Part 7 of the questionnaires? f) Availability: In the case of G-SIIs, all Candidates meet the quantitative limit of positions provided for in article 33., paragraph 3 of the RGICSF? The compliance with this limit is evident in the answers to the questions in Point 7.5 of the questionnaires and in the individual assessment reports? g) Independence and conflicts of interests: All situations of conflicts of interests identified in Part 8. of the questionnaires were analyzed in detail by the Institution, with weighting and eventual adoption of mitigating measures, in accordance with the Institution's conflicts of interests policy? This analysis is contained in the individual assessment reports

This Instruction is applicable to requests for authorization to exercise the following
functions:
a) Full and alternate member of administrative and supervisory bodies of institutions subject to the supervision of the Bank of Portugal (hereinafter designated as “Institutions” or “Institution”); b) Manager of branches, established abroad, of Institutions with headquarters in Portugal; and c) Manager of branches and representation offices, established in Portugal, of Institutions with headquarters in a country that is not part of the European Union or to which the regime established in article 189. of the RGICSF should be applied.
This instruction is also applicable:
a) To the assessment of the suitability of holders of essential functions of Institutions, in accordance with the provisions of the applicable legal and regulatory provisions, with the necessary adaptations; b) To communications of supervening facts presented in accordance with article 32. of the RGICSF; and c) To requests for accumulation of positions presented in accordance with article 33. of the RGICSF.
For the purposes of this Instruction, the persons to whom the requests referred to in the
previous paragraphs relate are identified as “Persons” or “Members”.
CHAPTER II – Authorization to exercise functions
Article 2.
Elements that must instruct the request
Requests for authorization to exercise functions are instructed with the following
elements, regarding each of the Persons:
a) Questionnaire, duly filled in, according to the model annexed to this Instruction

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as Annex I and which is available on the Bank of Portugal's website on the Internet (hereinafter identified as “Questionnaire”); b) Valid and updated criminal record certificate, issued by the competent authority of the country of nationality and, if different, of the country of habitual residence, with reference to the last 10 years, or another equivalent document in accordance with national legislation; c) Individual assessment report, prepared by the Institution, containing the result of the assessment of the suitability of each of the Persons for the exercise of the functions in question (hereinafter “Individual Assessment Report”) referred to in paragraphs 7 and 9 of article 30.-A of the RGICSF; d) Simple copy of a document proving the appointment of the Person to the position in question (by way of example, copy of the resolution of the general meeting or of the administrative body, when it is an appointment by co-optation in accordance with the provisions of article 393., paragraph 4 of the Commercial Companies Code), except in the case of prior authorization request before appointment referred to in paragraph 3 of article 30.-B of the RGICSF; e) When the request for authorization concerns a Person who is already authorized to exercise functions in another Institution subject to the supervision of the Bank of Portugal, a copy of the minutes of the meeting of the administrative body of the latter Institution proving that this body took note that the Person intends to exercise functions in another Institution; and f) When it is a request for authorization to exercise functions of managers of branches and/or representation offices, established in Portugal, of Institutions with headquarters in a country that is not part of the European Union or to which the regime established in article 189. of the RGICSF should be applied, a document proving that the Person has sufficient powers to definitively resolve in the Country all matters relating to their activity, in accordance with the provisions of article 49., paragraph 2 of the RGICSF, combined with article 57., paragraph 1 and with article 189., paragraph 1 of the RGICSF, as well as in article 64. of the same instrument.
2. The following documents must also be attached to the request:
a) When it is a request for authorization to exercise functions in a collegial body, a collective assessment report prepared by the Institution containing the result of the appreciation of the body as a whole, with a view to verifying whether it has adequate and diversified professional qualification and experience, if it contributes to the fulfillment of the gender diversity objectives defined in its internal policy, as well as, when applicable, if it has sufficient availability to fulfill its respective functions and independence (hereinafter identified as “Collective Assessment Report”) in light of paragraphs 4 and 6 of article 30. of the RGICSF, including the collective appreciation matrix of the body, according to the model annexed to this Instruction (Annex II), (hereinafter identified as “Collective Appreciation Matrix”); and b) Updated version of the Institution's articles of association.
3. If it deems appropriate, the Institution may also send a certified copy of the identification document, which contains visible the signature and the civil identification number of the Person

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(citizen card, identity card, passport or equivalent document), with a view to avoiding any eventual need for in-person identification of the Person.
4. The criminal record certificates referred to in paragraph b) of paragraph 1 of this article should, whenever possible, be requested specifically for the exercise of the functions of member of an administrative or supervisory body of a credit institution or financial company.
5. Regarding reappointed members, it is dispensed with the submission of the parts of the questionnaire referred to in paragraph a) of paragraph 1 of this article that have not undergone changes compared to the last submitted version of the questionnaire and the collective assessment matrix referred to in the final part of paragraph a) of paragraph 2, provided there is no change in the composition of the body nor in the assessment made by the Institution.
6. Changes to the questionnaire of reappointed members that may affect their suitability must be communicated in accordance with the provisions set out in paragraphs a) and b) of paragraph 3 of Article 3 of this Instruction.
7. Regarding reappointed members, the individual assessment reports and collective assessment reports referred to in paragraph c) of paragraph 1 and paragraph a) of paragraph 2 of this article must contain:
a) An assessment of new facts or new functions capable of affecting their suitability; b) An assessment of how the candidate exercised their functions during the last term, namely whether their decisions and interventions in matters within their competence or of the body they are part of were made in a measured and careful manner, revealing compliance with suitability requirements and contributing to the adequate collective performance of the body; c) If all members of the same body are reappointed, an assessment of how that body performed its functions during the last term and whether the collective composition remains adequate in terms of qualifications and professional experience, availability or independence; d) A reference to the assessment contained in the last report submitted in the parts that remain unchanged.
8. For the purposes of the provisions in paragraphs 5 to 7 of this article, reappointed members are considered to be members designated to continue exercising functions in the same body, even in cases where there is a change in functions.

Article 3.
Validity and Update of the Questionnaire

Institutions must present a new Questionnaire for Persons for each request for authorization to exercise functions, except for the situation provided for in paragraph 5 of the previous article.
The Questionnaire is available in Portuguese and in English.
If, during the term, any subsequent fact occurs that is capable of affecting the Person's suitability requirements and alters the information contained in the last submitted version of the questionnaire, the Institution, as soon as it becomes aware of the facts in question, must communicate them to Banco de Portugal, together with the sending of the following elements:
a) Part of the Questionnaire containing the alteration to be considered, marking the part of the questionnaire that is altered; b) A declaration signed by the Person concerned and by the Institution itself from which it results that "The information provided in the parts (identify the Part and the specific point of the questionnaire that is altered) of the questionnaire now sent constitute the only alterations to the last questionnaire sent regarding (indicate name), keeping the other previously provided answers unchanged"; and c) Assessment by the Institution regarding the impact of the communicated subsequent facts.
For the purposes of the provision in the previous number, subsequent facts are considered both those that occurred after the granting of authorization to exercise functions, and those that occurred prior but of which knowledge was only obtained after the granting of said authorization.

Article 4.
Collective Assessment Matrix

The Collective Assessment Matrix for administrative and supervisory bodies is available in Portuguese and in English.
The Collective Assessment Matrix does not replace the collective assessment report provided for in paragraph 4 of Article 30 of RGICSF.
A new Collective Assessment Matrix must be sent to Banco de Portugal, both in cases of a new term (when there is no total coincidence between the new composition and the previous composition of the body), and in cases of changes in members during the term.

Article 5.
Submission of the Request

Institutions must present a single request for authorization for all members of the administrative and supervisory bodies who intend to join the body, whenever these are, or are expected to be, designated at the same time.
When not presented at a time prior to designation as provided for in paragraph 3 of Article 30-B of RGICSF, the request for authorization to exercise functions must be presented to Banco de Portugal within 30 business days after the date of the corresponding deliberation of designation, including reappointment.
The request for authorization to exercise functions of members of administrative and supervisory bodies, whether presented under the provision in paragraph 2 or paragraph 3 of Article 30-B of RGICSF, must be presented within 8 months from the date of the end of the term, except in duly justified circumstances accepted by Banco de Portugal.
For Mutual Agricultural Credit Societies integrated into the Integrated System of Mutual Agricultural Credit, taking into account the assessment obligations that apply to the central body, the deadline of 30 business days referred to in paragraph 2 of this article starts after the date of issuance of the opinion by the Central Box under Article 10 of the Legal Regime of Mutual Agricultural Credit and Agricultural Credit Cooperatives.
The submission of the request for authorization to exercise functions of members of administrative and supervisory bodies by the institutions referred to in the previous number must not exceed a period of 10 months from the date of the end of the term, except in duly justified circumstances accepted by Banco de Portugal, whether presented under the provision in paragraph 2 or paragraph 3 of Article 30-B of RGICSF.

Article 6.
Registration with Banco de Portugal

When authorization to exercise functions has not been requested prior to designation as provided for in paragraph 3 of Article 30-B of RGICSF, Institutions must request Banco de Portugal to register the newly designated Persons within 30 days from their respective start date of functions, in accordance with paragraph 1 of Article 71 of RGICSF, such request being accompanied by the indication of the date on which they started functions, in accordance with paragraph 1 of Article 69 of RGICSF.
When authorization to exercise functions has not been requested prior to designation as provided for in paragraph 3 of Article 30-B of RGICSF, and in cases of reappointment of all members composing the administrative or supervisory body, Institutions may request Banco de Portugal to register the reappointed Persons at the time of presenting the corresponding request for authorization to exercise functions, in accordance with the provisions in paragraph 1 of Article 69 of RGICSF.
In cases where authorization to exercise functions has been requested prior to designation as provided for in paragraph 3 of Article 30-B of RGICSF, Institutions must request Banco de Portugal to register the newly designated or reappointed Persons within 60 days from the date on which said prior authorization was granted, under penalty of expiration of the same, such registration request being accompanied by a copy of the minutes stating the deliberation of designation of the Persons, as well as the indication of the date of their respective start of functions, in accordance with the provision in paragraph 3 of Article 30-B and paragraph 1 of Article 69 of RGICSF.
The provision in the previous numbers applies to the registration request of an alternate member in an administrative or supervisory body, with the necessary adaptations.

Article 7.
Accumulation of Offices

When, during the term, an effective member of an administrative or supervisory body intends to exercise a new office of administration or supervision in an institution not subject to registration with Banco de Portugal, the Institution subject to the supervision of Banco de Portugal in which that member exercises functions must communicate such intention to Banco de Portugal with a minimum advance of 30 days before the date planned for the start of the new functions.
For the purposes of the assessment provided for in Article 33 of RGICSF, the communication provided for in the previous number must indicate concretely which new accumulated office and be accompanied by the following elements necessary for the appraisal of the request:
a) New sheets referring to Part 7 of the Questionnaire (Availability) of the Member duly updated according to the new office that the same intends to exercise; b) New sheets referring to Part 8 (Independence and Conflicts of Interest), Part 9 (Independence and Incompatibilities) and Part 10 (Mutual Agricultural Credit Societies) of the Member's Questionnaire duly updated whenever the new office that the same intends to exercise determines some alteration to the previous version of these Parts of the Questionnaire; c) Declaration, signed by the Member concerned and by the Institution itself, stating that "The information provided in the parts (identify the Part and the specific point of the questionnaire that is altered) of the questionnaire now sent constitute the only alterations to the last questionnaire sent regarding (indicate name), keeping the other previously provided answers unchanged"; and d) Assessment by the Institution regarding the impact of the accumulation of new offices on the assessment of the availability and independence of the Person concerned.
In the cases provided for in paragraph 1 of this article and without Banco de Portugal opposing the intended accumulation, the Institution must communicate to Banco de Portugal the date on which the member in question started the new functions within 15 business days after the start thereof.
When, during the term, a Member intends to exercise a new office in an institution subject to the supervision of Banco de Portugal, Banco de Portugal's power of opposition is exercised within the framework of the Member's request for authorization to exercise the office, as provided for in paragraph 10 of Article 33 of RGICSF, in such cases such request being prepared in accordance with Article 2 and following of this Instruction.
New offices accumulated during the term that cannot be attributed to functions of administration or supervision must be communicated by the Institution subject to the supervision of Banco de Portugal as subsequent facts, framed in the provision in paragraph 3 of Article 3 of this Instruction, when they are capable of affecting the suitability requirements of the Person concerned.

CHAPTER IV – Conservation of Original Documents

Article 8.
Conservation of Original Documents

The originals of documents submitted electronically through the platform made available by Banco de Portugal for this purpose must be kept by Institutions in their archives, within the territory of the European Union, during the exercise of the function and after the cessation of functions, for a period corresponding to the limitation periods for criminal proceedings and for regulatory offenses applicable to illicit acts related to the activity.
In cases where authorization to exercise functions is refused, the documents will be kept until after the administrative decision has consolidated its effects in the legal order and the legal deadline for review of the decision by the administrative entity itself has elapsed, and their presentation may be requested at any time by Banco de Portugal, in conformity with the provision in Banco de Portugal's Instruction No. 11/2023.

CHAPTER V – Final Provisions

Article 9.
Entry into Force and Transitional Regime
This Instruction enters into force 30 days after the date of its publication, not applying to processes that are pending on the date of its entry into force.

Article 10.
Repealing Norm
Banco de Portugal's Instruction No. 12/2015, published in the Official Gazette No. 8/2015, of August 17, is revoked.

Annex I – Questionnaire on suitability, professional qualification, availability, independence and conflicts of interests
Before starting to fill out this questionnaire, read carefully its entire content, as well as its filling instructions.

DECLARATION BY THE PERSON FOR WHOM AUTHORIZATION TO EXERCISE FUNCTIONS IS REQUESTED
(hereinafter referred to as "Candidate")
I, ________________________________ declare, under oath, that the information provided in this questionnaire corresponds to the truth and is complete and that, based on the same, I consider myself to meet the necessary requirements, as defined by the General Regime of Credit Institutions and Financial Companies ("RGICSF") and other applicable legislation, to contribute to the sound and prudent management of the Institution ___________________________________, or to its adequate supervision. I further declare that I am aware of the obligations arising from binding norms and soft law, both national and international, including those arising from national legislation and those issued by Banco de Portugal, the European Central Bank ("ECB") and the European Banking Authority ("EBA") that are relevant for the functions I intend to perform and I manifest my purpose to continuously comply with them. I further declare, under oath, that if, during the term, any subsequent fact to the authorization to exercise functions occurs that is capable of affecting the suitability requirements and alters the information contained in this questionnaire, I will immediately inform Banco de Portugal, through the Institution. I further declare that I am aware that providing false or omitted information may constitute grounds for refusal or revocation of the authorization to exercise functions, without prejudice to the eventual application of criminal or regulatory sanctions. Date __ / __ / ____ ___________________________________________ (Signature of the Candidate)

COMPLIANCE WITH THE DUTY OF INFORMATION REGARDING THE PROCESSING OF PERSONAL DATA
This document explains the reasons for the collection and processing of your personal data, how they are used and how you can exercise your rights regarding your personal data. a) Responsible party, basis and purpose Personal data are processed by Banco de Portugal, a public law corporation with ID number 500 792 771 and headquarters at Rua do Comércio, n.º 148, 1100-150, Lisbon, in compliance with the General Data Protection Regulation 32 (GDPR) and other applicable data protection legislation, for the exercise of public interest functions and the public authority powers vested in Banco de Portugal, in compliance with the provision in its Organic Law 33 and other applicable legislation and as established in Article 6., paragraph 1, paragraphs c) and e) of GDPR. GDPR Organic Law of Banco de Portugal The aforementioned processing of data has as its purpose the assessment of suitability for the exercise of functions of members of administrative or supervisory bodies, managers of branches or representation offices or holders of essential functions by Banco de Portugal and/or the European Central Bank (ECB), as provided for in Articles 30 and following of the General Regime of Credit Institutions and Financial Companies 34 (RGICSF) and other applicable legislation, as well as the preparation of summaries relating to suitability assessment interviews carried out within the framework of processes that include the authorization to exercise functions by candidates. To obtain more information about the suitability requirements assessed, the procedure, the competences and the applicable legislation, please consult here 35 . Personal data are processed by Banco de Portugal also for the exercise of its prudential supervision powers and investigation and sanctioning powers, notably for the following purposes:
– Registration with Banco de Portugal
Cfr. Articles 65 to 72 of RGICSF and Article 35 of the Legal Regime of Payment Services and Electronic Money, approved by Decree-Law No. 91/2018, of November 12 ("RJSPME") – Revocation of authorization to exercise functions Cfr. Article 30-C of RGICSF – Application of sanctioning measures See, among others, Articles 201 and following (namely paragraph 1 of Article 213) of RGICSF and Article 10 of GDPR. – Publication of identification of members of administrative and supervisory bodies on the website of Banco de Portugal Cfr. Articles 65 to 72 and paragraph f) of Article 93-A, all of RGICSF, Article 35 of RJSPME and Articles 5 and 14 of the Administrative Procedure Code.

32 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.
33 Approved by Law No. 5/98, of January 31.
34 Approved by Decree-Law No. 298/92, of December 31, in the current wording.
35 Information available at https://www.bportugal.pt/page/adequacao-dos-membros-dos-orgaos-de-administracao-e-fiscalizacao-e-dos-titulares-defuncoes

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IN THE EVENT THAT IT IS NOT POSSIBLE TO PROCEED WITH THE DIGITAL SIGNATURE OF THIS DECLARATION, IT MAY BE PRINTED, SIGNED, AND UPLOADED IN PDF FORMAT IN THE CORRESPONDING FILE.

– Monitoring and surveillance of compliance with applicable legislation, namely the RGICSF, Regulation (EU) No. 575/2013 of the European Parliament and of the Council of 26 June 2013, and other applicable legislation, namely for risk assessment, issuance of recommendations, specific determinations or corrective measures, as well as for the assessment of credit granted to related parties, assessment of the ability to comply with the duties established in applicable legislation, etc. See, among others, Article 116 of the RGICSF.

– Disclosure of information in compliance with legal obligations See, among others, Articles 20 and 21 of Regulation (EU) No. 468/2014 of the European Central Bank of 16 April (MUS Framework Regulation), Articles 4 and 6 of Regulation (EU) No. 1024/2013 of the Council of 15 October (MUS Regulation), paragraphs 7 and 8 of Article 30-D of the RGICSF, and paragraph 2 of Article 65 of the RGICSF.

– Archiving for public interest
See General Regime of Archives and Archival Heritage, approved by Decree-Law No. 16/93 of 23 January.

– Investigation and quantitative analyses and statistical reports at an aggregated level (in this case, personal data will be aggregated and sufficiently anonymized so that individuals cannot be identified at the aggregated level). See, among others, paragraph 7 of Article 30 of the RGICSF, point (b) of paragraph 1 of Article 5, and paragraph 1 of Article 89 of the GDPR.

Within the scope of these purposes, the processing of data may involve the use of technological means, including the automated and standardized processing of information, as well as the stages of decision-making processes, with the aim of improving the efficiency and performance of supervisory functions. Although this use does not constitute an autonomous purpose, it integrates the processing process and contributes to the execution of the described purposes. In this context, it is important to clarify that decisions taken within the framework of the aforementioned activities will not be based solely on automated processing that produces legal effects (or other equally significant effects) on the data subjects.

In the case of assessing suitability for the exercise of functions in significant institutions, the ECB, with headquarters at Sonnemannstrasse 20, D-60314 Frankfurt-am-Main, Germany, also processes personal data to comply with the aforementioned purpose and is responsible for the processing, in accordance with paragraph 8 of Article 3 of Regulation (EU) No. 2018/1725. The ECB’s statement on the duty to inform can be consulted here 36.

b) Categories of personal data and their origin The following categories of personal data are processed:

(i) Personal data provided by the person:
a. Identification and contact data (name, address, e-mail, telephone contact, etc.); b. Data related to the assessment of integrity (such as information contained in the criminal record certificate, information about administrative, criminal, or civil proceedings, including insolvency, recovery, or liquidation proceedings of entities, dismissal proceedings, prohibition of exercising functions, mentions of defaults in the credit responsibility center);

c. Data related to the assessment of professional qualification (such as information about academic background and professional experience, including skills acquired in held positions and training);
d. Data related to the assessment of independence (information about personal, professional, financial, or political conflicts of interest, including information about family relationships, loans, guarantees, and other obligations); e. Data related to the assessment of availability (such as the hours expected to dedicate to the exercise of functions); f. Voice.

(ii) Personal data provided by the supervised entity (such as in individual and collective assessment reports) related to the categories indicated above; (iii) Personal data that have come to the supervisor's knowledge by other means (such as those communicated by the ECB, the Securities Market Commission (CMVM), the Insurance and Pension Funds Supervisory Authority (ASF), the European Banking Authority (EBA), by similar authorities, by judicial authorities, or data accessible in open sources available to the public); (iv) Personal data of persons related to the person/entity being supervised (for example: employees, clients, or family members) provided within the framework of the aforementioned communications; (v) Personal data obtained internally by the Bank of Portugal (such as data contained in the Credit Responsibility Center regarding possible defaults).

For a more detailed identification, please consult this instruction, as well as Instruction No. 7/2021. For additional information, please contact us at encarregado.protecao.dados@bportugal.pt.

c) Obligation
The provision of data necessary for these purposes is mandatory. The consequences of not providing the requested information will be determined on a case-by-case basis. Failure to provide the information may lead to a negative decision. The non-recording of interviews conducted within the processes that include authorization for the exercise of functions by candidates may imply the impossibility of compliance by the Bank of Portugal with legal obligations.

d) Retention
Data will be retained for the period corresponding to the statute of limitations for the applicable criminal or administrative offense proceedings related to the activity. In cases legally permitted, data may also be retained for purposes of public interest and/or historical archiving. Interview recordings with the candidate will be destroyed immediately after the drafting and confirmation by the data subject of the content of the summaries, thus the Bank of Portugal will not retain the data.

e) Recipients
The data processed by the Bank of Portugal are intended for internal use, particularly by the Prudential Supervision Department and the Investigation and Sanctioning Action Department, always respecting the principle of "need-to-know" access by Bank employees, including subcontractors acting under the instructions and on behalf of the Bank of Portugal (such as specialist legal consultants), all of whom are bound by a duty of confidentiality. Information will not be shared with third parties, except in situations where the law requires it. Indeed, to fulfill its functions, the Bank of Portugal may share personal data with a limited number of persons:
(i) From the Bank of Portugal and the ECB, in the exercise of their functions; and (ii) From other Union institutions, similar authorities, and national entities (such as the EBA, CMVM, ASF, as well as judicial authorities), within the framework of cooperation powers with these authorities.

f) Transfer of personal data
Collected personal data may be communicated to similar authorities, international organizations, and other entities in third countries, within the framework of cooperation powers with these authorities. In the absence of an adequacy decision, personal data will only be transferred to a third country or international organization upon the provision of adequate guarantees, in compliance with Article 46 of the GDPR and Article 48 of Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 (Regulation (EU) 2018/1725). In exceptional situations, transfers of personal data may be carried out in compliance with Article 49 of the GDPR and Article 50 of Regulation (EU) 2018/1725. Data will be transmitted to the Information System of the ESAs established under Article 31-A of the founding Regulations of the EBA, ESMA, and EIOPA 37. Additional information on the processing of data through this Information System can be consulted via the link DATA PROTECTION STATEMENT - ESAs INFORMATION SYSTEM 38.

g) Rights
Under the provisions of the Regulation and other applicable data protection legislation, the data subject has the right:
– To request the Bank to access the personal data concerning them, to rectify, and to erase it; and – To the limitation of processing.
The exercise of the right to rectify personal data provided by the candidate in the questionnaire is exercised under the terms provided in paragraphs 3 and 4 of Article 3 of this Instruction.

h) Contacts
Data subjects, to exercise their rights, may contact:

Bank of Portugal service points;
By post; or
Via e-mail to info@bportugal.pt.

i) Complaint
If they consider that their rights have not been duly attended to and wish to complain, data subjects may contact the DPO through the following means:

By e-mail: encarregado.protecao.dados@bportugal.pt
By post:
Data Protection Office of the Bank of Portugal Rua do Comércio, 148 1100-150 Lisbon

j) Complaint to the National Data Protection Commission (CNPD) Finally, data subjects may always file a complaint with the CNPD, as the supervisory authority.

k) Processing for subsequent purposes
The collected data will also be processed for other activities developed by the Bank, which are part of its supervisory powers, as well as for the exercise of other functions of public interest, including the application of sanctioning measures, based on the exercise of public interest functions or under the powers of public authority invested in it (Article 6(1)(e) of the Regulation), being retained for the period strictly necessary for the pursuit of these purposes, and may be transferred under the terms described in point 6, with the data subject retaining the rights, as referred to above. Due to this processing, these data may be communicated to the following recipients: - European Central Bank, within the Single Supervisory Mechanism; - Securities Market Commission (CMVM), the Insurance and Pension Funds Supervisory Authority (ASF) and similar authorities, within the framework of cooperation powers with these authorities. The processing of data for the aforementioned purpose does not involve automated individual decisions.

I have taken note,
Date __ / __ / ____

(Signature of the Data Subject)

DECLARATION OF THE INSTITUTION SUBMITTING THE AUTHORIZATION REQUEST
(hereinafter referred to as the "Requesting Institution")

The undersigned, on behalf of the Requesting Institution, declare(s) the following:

To the best of the Requesting Institution's knowledge, the information provided in this questionnaire corresponds to the truth and is complete.
(Yes/No)

If, during the mandate, the Requesting Institution becomes aware of any fact subsequent to the authorization for the exercise of functions that is capable of affecting the suitability requirements of the Candidate and alters the information contained in this questionnaire, the Requesting Institution will immediately inform the Bank of Portugal. (Yes/No)

The Requesting Institution has sought to obtain the most complete and up-to-date information possible about the Candidate, and this information has been duly weighed and taken into account in the assessment of the Candidate's suitability for the exercise of the functions in question. (Yes/No)

The function for which this authorization is requested corresponds to that which is expected for the Candidate to effectively perform.
(Yes/No)

Based on the information it has sought to obtain regarding the Candidate and having in mind the suitability requirements for the exercise of functions established in the RGICSF and the provisions of the remaining applicable legislation, the Requesting Institution considers that the Candidate is suitable for the exercise of the functions proposed, presenting the capacity to ensure, on a permanent basis, the sound and prudent management of the Requesting Institution or its adequate supervision, as stated in the respective individual assessment report. (Yes/No)

The Requesting Institution has informed the Candidate about the legal and regulatory responsibilities associated with the functions they intend to perform. (Yes/No)

They confirm that they have sufficient powers to make the aforementioned declarations and sign this questionnaire on behalf of and representing the Requesting Institution. (Yes/No)

Name of the Requesting Institution 39: _________________________________

Name of the signatory(ies): _________________________________ Position(s)/Capacity: _________________________________ Signature(s): _________________________________ Date: //____

DECLARATION OF THE INSTITUTION SUBMITTING THE AUTHORIZATION REQUEST
(hereinafter referred to as the "Requesting Institution")

The undersigned, on behalf of the Requesting Institution, declare(s) the following:

To the best of the Requesting Institution's knowledge, the information provided in this questionnaire corresponds to the truth and is complete.
(Yes/No)

The function for which this authorization is requested corresponds to that which is expected for the Candidate to effectively perform.
(Yes/No)

The Requesting Institution has informed the Candidate about the legal and regulatory responsibilities associated with the functions they intend to perform. (Yes/No)

They confirm that they have sufficient powers to make the aforementioned declarations and sign this questionnaire on behalf of and representing the Requesting Institution. (Yes/No)

Name of the Requesting Institution 39: _________________________________

Name of the signatory(ies): _________________________________ Position(s)/Capacity: _________________________________ Signature(s): _________________________________ Date: //____

who signs the questionnaire on behalf of and representing the Requesting Institution should be the person(s) or body to whom the responsibility of assessing the Candidate's suitability has been attributed, in accordance with Article 30-A, paragraph 2 of the RGICSF, whose identification is contained in the internal policy for the selection and assessment of suitability of the members of the administrative and supervisory bodies approved by the General Assembly of the Requesting Institution.

THIS DOCUMENT SHOULD NOT BE PRINTED FOR SUBSEQUENT DIGITIZATION.
FILLING SHOULD BE DONE DIGITALLY AND INSERTED INTO THE FILE IN PDF FORMAT AFTER COMPLETE FILLING.

PART 1. Type of Authorization
1.1 Prior authorization for appointment?
(Yes/No)

PART 2. Information on the Requesting Institution
2.1 Identification
2.1.1 Firm or name:
2.1.2 Type of institution (credit institution, financial institution, payment institution, or electronic money institution):
2.1.3 Is the institution in question part of the Public Business Sector, as per Decree-Law No. 133/2013 of 3 October?
(Yes/No)
2.1.4 Address:
2.1.5 Telephone:
2.1.6 Fax:
2.1.7 E-mail address:
2.1.8 Is it a Significant Institution?
(Yes/No)
(In the affirmative, it must be confirmed that the questionnaire in question is applicable, by consulting Bank of Portugal Instruction No. 7/2021)

2.2 Other national financial supervisory authority to which the Requesting Institution is subject:
2.2.1 ASF:
(Yes/No)
2.2.2 CMVM:
(Yes/No)

2.3 Contact person regarding the authorization process and subsequent registration:
2.3.1 Name:
2.3.2 Position:
2.3.3 Professional address:
(fill only if it does not coincide with the address indicated for the Requesting Institution)
2.3.4 Telephone:
2.3.5 Fax:
2.3.6 E-mail address:

3.1.20
3.1.20.1 Did you reside or work in a country different from your country of nationality in the last ten years?
(Yes/No)
3.1.20.2 In case of an affirmative answer to question 3.1.20.1, indicate the country/countries where you resided.

3.2 Candidate's Authorization for the Bank of Portugal to make communications via telephone, fax, or e-mail to the contacts mentioned above
(Yes/No)

3.3 Candidate's authorizations or registrations, current or past, including any refusals, in national or foreign supervisory authorities (specifically regarding the exercise of functions as a member of an administrative or supervisory body, branch manager, representative office manager, acquirer of qualifying holdings, etc.)
(Add space and filling lines to this field as necessary to provide complete information)

National or foreign supervisory authority	Institution	Functions	Start Date	End Date	Date of Assessment	Includes integrity assessment? (Yes / No)	Summary Conclusion of Assessment 40

3.3.1 In case of refusal of authorization or registration, or of a positive assessment with conditions or recommendations, indicate in detail the reasons.

40 Ex. positive, positive with conditions, positive with recommendations, or negative.

PART 4. Position for which authorization is requested
4.1 Position:
(Indicate if assuming presidency or vice-presidency of a collegiate body or if designated as responsible for internal control function)
4.2 Executive functions / current management:
(Yes/No)
4.3 Portfolio:
(Concrete areas under the Candidate's responsibility)
4.4 Is the Candidate designated as responsible for the function of controlling
compliance with the regulatory framework on money laundering and terrorist financing, for the purposes of Banco de Portugal Notice No. 1/2022?
(Yes/No)
4.5 Description as detailed as possible of the main duties, responsibilities and tasks
inherent to the functions for which authorization is requested, as well as indication of the number of subordinates and the number of hours per week and/or the number of days per year that the Requesting Institution considers necessary for the adequate exercise of the position. If applicable, indication of other functions that the Candidate will exercise in the Requesting Institution. (This question is directed, primarily, to the Requesting Institution)
4.6 Indication of the committees that the Candidate is expected
to join as a result of exercising the functions for which authorization is requested
4.7 Is the Candidate designated as independent for the
exercise of the position?
(Yes/No/NA)
4.8 Term:
(start year / end year)
4.9 Appointment date (expected):
(day/month/year)

Annex to Instruction No. 13/2025 BO No. 10/2025 • 2025/10/15
Supervision Topics :: Registry
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THIS DOCUMENT SHOULD NOT BE PRINTED FOR LATER DIGITIZATION.
FILLING IN SHOULD BE DONE DIGITALLY AND INSERTED INTO THE FILE IN PDF FORMAT AFTER COMPLETION.
PART 5. Suitability
The answers to the questions below should:
a) Take into account situations that occurred in Portugal or abroad; b) Include the reporting of ongoing proceedings where there are indications of responsibility 41 or of direct or personal involvement of the candidate in the practice of the facts in question; c) Include the reporting of ongoing proceedings not included in b) and that the Institution and the candidate consider to be likely to have a material impact on the assessment of the suitability requirement; d) Include the reporting of concluded proceedings in which responsibility 42 or direct or personal involvement of the person concerned was established, even if concluded more than 10 years ago; and e) Include the reporting of proceedings concluded less than 10 years ago, not included in d) and that the Institution and the candidate consider to be likely to have a material impact on the assessment of the suitability requirement. Indications of the candidate's responsibility exist, namely, in cases where the candidate has been charged, indicted or pronounced guilty for the commission of a crime or for the commission of an offense. Responsibility of the candidate is understood to have been established, namely, in cases where the candidate has been convicted for the practice of an unlawful act of a civil, criminal, regulatory or other nature. Direct or personal involvement of the candidate is considered to exist when, inter alia, the appointed person has been responsible for a division or business line, member of the administrative body with responsibility for the matter subject to the offense or when the proceedings (including sanctions or measures imposed) or facts demonstrate an omission or inaction by the candidate. Situations must also be identified where it is considered that the candidate did not act with due diligence, honesty and integrity while holding an essential function, senior management position, member of the administrative body or manager. Conversely, there will be no direct or personal involvement if the appointed person does not hold any position in the institution at the time of the offense (for example, was not a member of the administrative body nor responsible for an area involved in the facts) 43. As a general guideline, it may be considered that proceedings of a regulatory nature initiated against the Requesting Institution or another entity controlled by it or in which the candidate exercised functions of administration, management or supervision, in relation to which no personal responsibility of the candidate was established and the sanction applied was a reprimand or a fine of less than € 10,000.00, will not, in principle, have a material impact on the assessment of the suitability requirement. Conversely, a cumulative of proceedings of the same nature or originating from the same area may be considered to have a material impact on the assessment, even if referring to offenses committed negligently or with the application of fines of low amount. Regarding the
questions posed in the points below, the reference to proceedings for regulatory offenses or insolvency covers proceedings of an equivalent nature (i.e. proceedings for transgression or liquidation), initiated under national or foreign legislation.

41 Namely, in cases where the candidate has been charged, indicted or pronounced guilty for the commission of a crime or for the commission of an offense. 42 Namely, in cases where the candidate has been convicted for the practice of an unlawful act of a civil, criminal, regulatory or other nature. 43 See also the definition of "direct or personal involvement" contained in the ECB Guide to fit and proper assessments.

Regarding any possible proceedings:
a) facts that motivated the initiation of the proceeding(s); b) type(s) of offense or crime; c) if there was constitution as accused, indictment, pronouncement, conviction and/or archiving of the proceeding; d) date of constitution as accused, indictment, pronouncement, conviction and/or archiving of the proceeding; e) direct or personal involvement of the Candidate in the practice of the facts that motivated the initiation of the proceeding; f) the time elapsed and the conduct of the Candidate since the practice of the facts that motivated the initiation of the proceeding; g) penalty, fine or sanction applied; h) court or entity where the proceeding is or was taking place; i) phase in which the proceeding is; and j) any other aggravating or mitigating circumstances.
Regarding any possible insolvencies:
a) name of the companies involved in insolvency proceedings; b) functions specifically exercised in that company; c) indication on whether the insolvency was considered fraudulent or negligent, under the terms of the Penal Code; and d) indication on whether the insolvency was qualified as culpable or fortuitous, under the terms of the Insolvency and Corporate Recovery Code.
Regarding any possible refusals of authorization, registration, admission or license for the exercise
of a commercial, business or professional activity, the respective grounds.
Add any additional information that is considered relevant.
5.19 If applicable, indicate the questions to which the answer was affirmative, but which do not fall under the
situations provided for in the introduction of Part 5 and which, for this reason, the Institution considered that

44 For example, annual total assets.
45 When the position is not that of a member of the administrative or supervisory body, indicate if the position is one, two or more levels below the administrative body. 46 For example, total turnover and indication of international presence. 47 When the position is not that of a member of the administrative or supervisory body, indicate if the position is one, two or more levels below the administrative body.

6.2.4 Compensatory evaluation factors (e.g., other types of professional experience, evidence of the Candidate's ability to challenge the other members of the body to which they belong and/or other bodies, overall adequacy of the other members of the body, specialized knowledge of the Candidate that is relevant to the functions proposed, time-limited position requiring the person in question to hold the position and justify their appointment, among other specific situations)
(When there are no compensatory factors, "Not Applicable" should be indicated)

6.2.5 Self-assessment of qualification and experience in the banking or financial sector in accordance with the "Guidelines on the assessment of the fitness of members of the administrative and supervisory bodies and of Holders of Essential Functions" of the EBA (EBA/GL/2021/06, of July 2, 2021 48)
Area Assessment
(High, Medium-High, Medium-Low, Low)
Financial markets
Regulatory framework and legal requirements, including in matters of prevention of money laundering and financing terrorism Strategic planning and knowledge of the strategy or business plan of an institution and the execution thereof Risk management (identification, assessment,

48 In force from December 31, 2021.

6.2.6 Other relevant specialized experience:
(List)

6.2.7 Will the Candidate attend specialized training before the start of functions or
during the first year of functions?
(Yes/No)
If yes, indicate
Content
Training entity
(Requiring Institution or indicate the name of the external entity) Start date End date

Annex to Instruction No. 13/2025 Official Gazette No. 10/2025 • 2025/10/15
Supervision Topics :: Registry
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PART 7. Availability
7.1 List of all executive and non-executive positions, as well as all professional activities that the Candidate intends to perform cumulatively
All corporate positions held in corporate bodies (e.g.: positions in administrative and supervisory bodies or in the Board of the General Meeting) should be indicated, as well as other professional activities (management positions or functions as an employee in companies, activities as a lawyer, consultant, auditor, professor, etc.), regardless of whether these functions are exercised under an employment contract, a service provision contract or other link and whether they are performed in institutions of the banking and financial sector, or in institutions of other sectors. Positions held in non-profit entities (e.g.: Foundations, Associations, etc.) should also be indicated. Regarding Candidates who are Official Auditors of Accounts ("OACs") and who exercise their professional activity within an Official Auditors of Accounts Society ("OAAS"), the position held in the OAAS (e.g.: manager of the OAAS or collaborator of the OAAS) should be indicated, with the time necessary to perform all OAC positions that the Candidate holds in client companies of the OAAS (i.e., OAC positions performed within the context of the OAAS and using its resources) being counted there. OAC positions that are not performed within the context of the functions performed in the OAAS should only be listed separately. Otherwise, positions performed as a member of a supervisory body (including the position of Sole Auditor) must always be indicated autonomously, whether such positions are exercised on behalf of an OAAS or are performed in one's own name. (Include in the table the position to which this questionnaire refers, indicating it first, followed by the other functions that the Candidate intends to perform in accumulation) If necessary, you may add space and filling lines to this field.

49 For example, total annual assets for financial institutions and total volume of business and indication of international presence for other types of institutions. 50 At the Banco de Portugal, CMVM, ASF or foreign supervisory authority. 51 If applicable, indicate in particular the participation or group relationships between the institutions referred to in the questionnaire (if possible, in percentage terms), if they depend on the same parent company or if there are common shareholders or partners with significant influence.

7.4 Based on the information contained in this Part 7 of the questionnaire, do the
Candidate and the Requiring Institution consider that he ensures the necessary availability to perform all the activities he intends to exercise, taking into account the characteristics and requirements of the same, the need for continuous training and development, as well as the need for a margin for unexpected circumstances 52? (Yes/No)

7.5 Systemically Important Institutions ("O-SIIs") 53
(Answer these questions only if this questionnaire concerns the exercise of functions as a member of the administrative or supervisory body of a Systemically Important O-SII Institution.)

7.5.1 Is the Candidate appointed as a member of the administrative or supervisory body of
a credit institution that benefits from extraordinary public financial support and was appointed specifically in the context of that support, under the provisions of paragraph 5 of article 33.º of the RGICSF? (Yes/No)

7.5.2 Does the authorization request for the exercise of functions to which this questionnaire relates
correspond to a request for accumulation of an additional non-executive position under the

52 Unexpected circumstances include not only crisis situations related to the institution, but also circumstances capable of unexpectedly affecting the time dedicated to the exercise of the position (for example, judicial processes). 53 Institutions classified by the Banco de Portugal as Systemically Important Institutions, under article 138.º-Q of the RGICSF and identified in a list published by the Banco de Portugal.

7.5.3 Total number of executive positions if the position counting rules provided for in
paragraphs 4 and 6 of article 33.º of the RGICSF are applied.
(If applicable)

7.5.4 Total number of non-executive positions if the position counting rules provided for in
paragraphs 4 and 6 of article 33.º of the RGICSF are applied.
(If applicable)

7.5.5 If the position counting rules provided for in paragraph 4 of article 33.º of the RGICSF are applicable, indicate in detail if there are synergies
between the institutions that justify an overlap of the time spent in the positions performed in each of these institutions.

THIS DOCUMENT SHOULD NOT BE PRINTED FOR LATER DIGITIZATION.
FILLING SHOULD BE DONE DIGITALLY AND INSERTED INTO THE PROCESS IN PDF FORMAT AFTER COMPLETE FILLING.
Annex to Instruction No. 13/2025 Official Gazette No. 10/2025 • 2025/10/15
Supervision Topics :: Registry
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PART 8. Independence and Conflicts of Interest – Members of the administrative and supervisory body
8.1
8.1.1 Does the Candidate or any close person of the
Candidate 54 have a personal relationship with members of the administrative or supervisory body, holders of essential functions or shareholders with a qualified participation in the Requiring Institution, its parent company or subsidiaries? (Yes/No)
8.1.2 If yes, explain the circumstances.
8.2

8.2.1 Is the Candidate or any close person of the
Candidate 55 in any way involved in any judicial process or extrajudicial litigation against the Requiring Institution, its parent company or subsidiaries or against shareholders with a qualified participation in the Requiring Institution, its parent company or subsidiaries? (Yes/No)
8.2.2 If yes, indicate the content and current state of the judicial processes in question and
which entity/entities are involved.
8.3

54 "Close persons of the Candidate" include, in particular, their spouse, person with whom they live in a de facto union, person with whom they live in a common economy, descendant, ascendant or other members of the Candidate's household. 55 See note 52.

56 See note 52.
57 Positions that imply the exercise of executive functions with direct reporting to the administrative body of the institution.
58 See note 52.

8.6.2 If yes, indicate the following: (a) type of financial obligation; (b) value of the financial
obligation; (c) duration of the financial obligation; (d) indication of whether it was negotiated under market conditions; and (e) indication of whether it is in regular status.

8.7

8.7.1 Does the Candidate or any close person of the
Candidate 60 hold or held during the last 2 years any position of high political influence 61 (at national or local level)?
(Yes/No)
8.7.2 If yes, indicate the following: (a) the nature of the position in question; (b) the concrete powers
inherent to the position in question, as well as their respective obligations; and (c) the relationship between the position in question (or the entity in which it was held) and the Requiring Institution, its parent company or subsidiaries.

59 See note 52.
60 See note 52.
61 There can be "high political influence" at various levels, notably in local political positions (e.g., Mayor), regional or national (e.g., member of the Council of Ministers); public officials (e.g., in government bodies); and state representatives.

8.8.1 Does the Candidate or any close person of the
Candidate 62 have any other relationships, positions or involvements that have not been covered by the previous questions that are likely to negatively affect the interests of the Requiring Institution? (Yes/No)
8.8.2 If yes, explain the circumstances (in particular, nature, content, duration
and, if relevant, the relationship with the Requiring Institution, its parent company or subsidiaries).
8.9 If the answer to any of the previous questions is affirmative, indicate whether the potential
conflict of interest identified was considered significant or not significant. If it is considered significant, indicate how it is proposed to be mitigated and, if it is not considered significant, provide the corresponding justification. Include relevant documentation, if applicable (e.g.: internal policies).

62 See note 52.

9.1.1 Is the Candidate associated with any group
of specific interests in the Requiring
Institution or is in any circumstance likely to affect their impartiality of analysis or decision (under the provisions of
article 414.º, paragraph 5 of the Companies Code)?
(Yes/No)
9.1.2 If yes to question 9.1.1, specify.
9.1.3 Is the Candidate a holder or acts on behalf of or
for the account of holders of qualified participation equal to or greater than 2% of the share capital of the Requiring Institution?
(Yes/No)
9.1.4 Was the Candidate elected for more than three
mandates, continuously or intermittently?
(Yes/No)
9.1.5 In case of affirmative response to any of the above questions, specify.

PART 10. Credit Agricultural Mutual Societies

10.0 Does the Candidate intend to exercise functions in Credit Agricultural Mutual Societies?
(Yes/No)

If the Candidate does not intend to exercise functions in Credit Agricultural Mutual Societies, proceed to Part 11 of the questionnaire.

Questions directed to the Candidate

10.1 Have you been, or have you been, in default, in the last 180 days prior to the date of the election, regarding the fulfillment of obligations towards the Institution where you will exercise functions?
(Yes/No)

10.2 Has any company that is directly or indirectly controlled by you, or in which you are a director, manager, or executive, been or been in the situation referred to in the previous point, in the last 180 days prior to the date of the election?
(Yes/No)

10.3 Do you hold functions as administrator, manager, consultant, technician, promoter, prospecting agent, mediator, or agent of another credit institution, financial company, insurance or reinsurance company, national or foreign, with the exception of the Central Credit Agricultural Mutual Society and companies controlled by it?
(Yes/No)

10.4 Do you hold functions as administrator, director, manager, consultant, technician, or agent, or are you an employee of individuals or legal entities that hold more than one-fifth of the capital of any other credit institution, financial company, insurance or reinsurance company, or of companies controlled by these?
(Yes/No)

10.5. If you answered affirmatively to any of the previous questions, specify.

10.6 Do you hold functions of administration, management, or direction in any company whose object includes the supply of goods or services intended for:

10.6 a)
Productive activities in the sectors of agriculture, forestry, livestock, hunting, fishing, aquaculture, agritourism, or extractive industries?
(Yes/No)

10.6 b)
Transformation, improvement, conservation, packaging, transport, or marketing of agricultural, forestry, livestock, hunting, fishing, aquaculture, or extractive industry products? (Yes/No)

10.6 c)
Manufacture or marketing of products directly applicable in agriculture, forestry, livestock, hunting, fishing, aquaculture, agritourism, extractive industries, or provision of services directly related to these activities, as well as crafts? (Yes/No)

10.7

10.7.1 In case of an affirmative response to any of the sub-points of the previous point, clarify whether the companies in question are associated with any Credit Agricultural Mutual Society?
(Yes/No)

10.7.2 In the affirmative, indicate which CCAM.

10.7.3 In the negative, indicate whether they meet the requirements to be associated.

PART 11. References

Indicate at least two references of people with whom the Candidate has had a professional relationship, preferably in the banking or financial sector in the last three years.

The data in question here is intended exclusively to enable the Bank of Portugal to collect additional elements regarding the Candidate, and is not itself subject to processing by the Bank of Portugal.

PART 12. Additional Information

12.1 Is there any other circumstance that should be assessed regarding the requirements of suitability, professional qualification, independence, and availability for the exercise of the position in question?

12.2 Other information.

Part 13. Transmission and processing of personal data by the ECB

If it is necessary for the ECB to process personal data under the Single Supervisory Mechanism, the declaration for compliance with the ECB's duty to inform can be consulted on the ECB's institutional website (“Privacy statement for the processing of personal data in the context of prudential supervision under the Single Supervisory Mechanism”63).

63 “Privacy statement for the processing of personal data in the context of prudential supervision under the Single Supervisory Mechanism”.

FILLING INSTRUCTIONS

True and complete information
This questionnaire should be filled in truthfully and completely and contain information as up-to-date as possible.
Filling in the questionnaire incorrectly or incompletely may cause a delay in the Bank of Portugal's final decision on the request for authorization to exercise functions. The provision of false or omitted information may constitute grounds for refusal or revocation of the authorization to exercise functions, without prejudice to the eventual application of criminal or administrative penalties.
Filling in and signing of the questionnaire
The filling in of the questionnaire annexed to this Instruction should be carried out using the model made available by the Bank of Portugal in the SIRES application; alterations to the document's formatting are not permitted. This document should not be printed and subsequently scanned for insertion into the process; the digital version is always maintained. Manual signature should only be inserted in the declarations contained in Annex I, which, not being able to be signed digitally, may be printed, signed, and subsequently uploaded to the corresponding process. Unless otherwise indicated, the questionnaire fields are mandatory. Fields that are not filled in because there is nothing to declare regarding the questions posed therein should be locked. If left blank, it will be presumed that there is nothing to declare regarding the questions posed therein that contributes to a negative decision, or, regarding Yes/No questions, that the answer is negative. The foregoing does not prejudice the possibility of the Bank of Portugal requesting confirmation of the answer.
Alteration of the questionnaire
If, during the mandate, any fact subsequent to the authorization for the exercise of functions occurs that is capable of affecting the Candidate's suitability requirements and alters the information contained in this questionnaire, without determining the presentation of an autonomous request under the RGICSF, both the Candidate and the Requesting Institution must immediately inform the Bank of Portugal. In this case, the following must be sent to the Bank of Portugal: (i) the Part of the questionnaire corresponding to the alteration to be considered, indicating the part of the questionnaire that is altered; (ii) a declaration signed by the Person in question and by the Institution itself, resulting from which that “The information provided in the parts (identify the Part and the specific point of the questionnaire that is altered) of the questionnaire now sent constitute the only alterations to the last questionnaire sent regarding (indicate name), with the other previously provided answers remaining unchanged”; and (iii) the Institution's assessment of the impact of the subsequent facts communicated, as referred to in Article 3, paragraph 3 of this Instruction.
Independence and incompatibilities – Members of the supervisory body of any Institution (Part 9)
Answer only in the case of exercising functions as a member of the supervisory body of any Institution.
Credit Agricultural Mutual Societies (Part 10)
Answer only in the case of exercising functions in Credit Agricultural Mutual Societies.

Annex II – Matrix for collective appreciation by the institution of the administration and supervisory bodies

This matrix is a complementary tool for the assessment of the collective professional qualification and experience of the administration and supervisory bodies.

I. Knowledge, Qualification, and Experience

A classification should be assigned to each member of the administration or supervisory body, as follows:
R (Reduced): The evaluated person has minimal theoretical knowledge on the subject; MR (Medium-Reduced): The evaluated person has a good understanding of the subject; ME (Medium-High): The evaluated person has a good understanding of the subject and has experience in it but is not a specialist; E (High): The evaluated person knows the subject in question deeply, has experience, and is capable of autonomously producing an opinion or decision on it (expert).

Name

A. Governance, organization, and communication Possesses knowledge and experience in the management of internal processes inherent to the functioning of the institution. Possesses knowledge and experience associated with the performance of the functions of member of the corporate body for which they were appointed. Possesses knowledge on matters of corporate, ethical, and professional values, such as those resulting from rules and good governance practices (provided for, in particular, in corporate governance codes and the institution's code of conduct). Possesses knowledge of the legislation, regulations, recommendations, and internal norms applicable to the institution's activity and experience in monitoring compliance therewith. Possesses knowledge and experience in hiring and monitoring external experts, in order to ensure adequate service provision and, where applicable, their independence. Knows how and when to activate the appropriate means through which stakeholders - namely supervisory authorities, shareholders, clients, and external auditors - should be informed of relevant facts and irregularities impacting the institution's activity.

This matrix is a complementary tool for the assessment of the collective professional qualification and experience of the administration and supervisory bodies.

I. Knowledge, Qualification, and Experience

Name

Other relevant knowledge and experience in this domain:
(To be filled in, where applicable)

B. Products, services, and markets related to the Institution's activity Possesses qualifications and experience related to the products and services offered by the institution. Possesses knowledge and experience regarding relevant legislation, regulation, and recommendations, namely, the Commercial Companies Code, the General Regime of Credit Institutions and Financial Companies, the special regimes applicable to the institution's activity, and the regulation and recommendations issued by the competent supervisory authorities and the European Banking Authority (where applicable). Possesses knowledge and experience of the markets in which the institution operates. Possesses knowledge and experience regarding the institution's strategy and respective business models. Possesses knowledge and experience regarding the financial aspects of the products and services offered by the institution.

This matrix is a complementary tool for the assessment of the collective professional qualification and experience of the administration and supervisory bodies.

I. Knowledge, Qualification, and Experience

Name

Has knowledge of who the administrators and collaborators (within the administration body and at the level of internal audit) with relevant expertise in the suitability of products to target customer groups are. In the context of the assessment of the products and services offered by the institution and the markets where it operates, is able to identify long-term interests and contribute to decision-making in conformity therewith. Possesses qualifications and experience that allow them to analyze the institution's financial information, identify key issues arising from that information, and propose appropriate controls and measures. Possesses specific knowledge of the following products and/or services:
(To be completed by indicating the products/services and, if relevant, assigning the classification R, MR, ME, E)

C. Operational policies and processes
Is capable of assessing the organization and functioning of the institution's resources and its internal supervision and control mechanisms.
Is capable of assessing the functioning of the compliance function and of analyzing the record of non-compliance and the measures proposed by that function.

This matrix is a complementary tool for the assessment of the collective professional qualification and experience of the administration and supervisory bodies.

I. Knowledge, Qualification, and Experience

Name

Is capable of assessing the functioning of the internal audit function, of analyzing and monitoring its assessments and reports and respective recommendations. Has knowledge of the remuneration practices and policies in force in the institution and of how these should be implemented regarding members of corporate bodies and other covered collaborators. Has knowledge of the risk management policy and respective procedures and measures, being capable of questioning them critically with the corporate bodies and the risk management function. Is capable of actively participating in the decision-making of the bodies it integrates, contesting them critically and constructively, where applicable. Possesses a transversal knowledge of the most relevant risks inherent to the institution's activity, in the short, medium, or long term. Knows the institution's service outsourcing policy and is capable of raising critical questions on the matter. Is capable of assessing whether clients are treated adequately, in accordance with the provisions of the applicable legislation, regulation, and internal rules.

This matrix is a complementary tool for the assessment of the collective professional qualification and experience of the administration and supervisory bodies.

I. Knowledge, Qualification, and Experience

Name

Other relevant knowledge and experience in this domain (To be filled in, where applicable)

D. Decision-making
Knows the internal decision-making process.
Knows when, how, and to whom to turn in order to request all information necessary for adequate decision-making.
Has experience and is capable of contributing to ensuring that in each decision-making process sufficient alternatives are considered.
Knows how positions of all stakeholders should be weighed and evaluated in a decision-making process and has experience in this matter.
Has knowledge of and experience in matters relating to conflicts of interest, in order to be able to recognize and invoke them within the context of decision-making processes. Is capable of assessing, sufficiently and adequately, whether the decisions taken by the body it integrates are in consonance with the institution's strategy.

This matrix is a complementary tool for the assessment of the collective professional qualification and experience of the administration and supervisory bodies.

I. Knowledge, Qualification, and Experience

Name

Has experience in matters of the functioning of corporate bodies and in decision-making by them.
Other relevant knowledge and experience in this domain (To be filled in, where applicable)

Filling Instructions

I. This matrix is intended for a collective appreciation of the skills gathered in the institution's administration and supervisory bodies and is assessed by its entirety. The qualification of some of the items analyzed as “reduced” does not, by itself, imply an individual assessment of the person in question. Indeed, it is expected that in a collegiate body there are people with different characteristics, namely various levels of knowledge in the referred matters and different professional experience, within or outside the Institution.

II. A matrix should be presented for each collegiate corporate body.
Comments and/or explanatory notes relating to this matrix may be attached as a separate document.
Such comments and/or notes may contain indications on which measures the institution intends to take with a view to the professional development of the members of its corporate bodies, namely the frequency of training actions intended to provide

Annex to Instruction No. 13/2025 BO No. 10/2025 • 2025/10/15
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Annex III – Validation List for the Authorization Process to Exercise Functions
This document contains a list for internal validation by Institutions regarding the complete and adequate preparation of authorization files for the exercise of functions, and is not intended to be sent to the Bank of Portugal. This guide does not, of course, dispense with the development by Institutions of additional control procedures they deem necessary to ensure adequate quality of the reported information.

Instruction Documents for the file ✓ or
Have all documents been submitted? 64? a) Documents that are always necessary: Questionnaire (in the case of reappointment, the parts of the questionnaire where changes were recorded), individual evaluation report, certified copy of the identification document, criminal record certificate for all candidates, and updated Bylaws. b) Documents that may be necessary: Appointment resolution (for requests submitted after the appointment), minutes referred to in Article 2(1)(f) (when the Candidate holds functions in another Institution subject to the supervision of the Bank of Portugal), document mentioned in Article 2(1)(g) (for managers), declarations of conflicts of interest, collective evaluation report, and collective assessment matrix, when there are new members and/or changes recorded regarding reappointed members (collegial bodies).

Are the submitted documents signed?
Questionnaires (signed by the Candidate and the Institution), individual evaluation reports, collective evaluation reports, appointment resolution, minutes referred to in Article 2(1)(f), document mentioned in Article 2(1)(g), and declarations of conflicts of interest.

Were the questionnaires filled in all applicable fields? a) Suitability (Part 5): If affirmative answers were given to questions in points 5.1 to 5.17 and 5.20 of the questionnaire, are the situations in question properly developed in points 5.18, 5.19, and 5.21, respectively? b) Availability (Part 7): Were all positions the Candidate intends to hold indicated in the table of Point 7.1 of the questionnaire? c) Availability (Part 7): In the case of O-SIIs, were the fields of point 7.5 of the questionnaire filled in?

64 Cfr. Article 2 of the Instruction.

Annex to Instruction No. 13/2025 BO No. 10/2025 • 2025/10/15
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d) Independence and conflicts of interest (Part 8): Were all situations of actual or potential conflicts of interest identified in Part 8 of the questionnaires? e) Collective Assessment Matrix (Annex II): In cases of holding functions in a collegial body, was the collective assessment matrix filled in? f) Does the Institution subscribe to all information contained in the questionnaires, sign the initial declaration included in 3., and participate actively in the answers to questions 4.5, 5.20, 7.4?

Is consistency ensured between the information in the questionnaires and the evaluation reports? a) Was the evaluation of Candidates contained in the individual evaluation reports carried out taking into account all information collected through their respective questionnaires? b) Suitability: In case of an affirmative answer to any of the questions in points 5.1 to 5.17 and 5.20 of the questionnaires, was the Institution's assessment of the impact of these situations on the suitability of the Candidates sufficiently explained in the individual evaluation reports? c) Qualification and professional experience: Is the assessment contained in the individual and collective evaluation reports consistent with the information on the qualification and professional experience of the Candidates provided in Part 6 of their respective questionnaires? d) Qualification and professional experience: Is the assessment on the qualification and professional experience of the Candidates contained in the collective assessment matrix in accordance with the information provided in each of their respective questionnaires? e) Availability: Did the assessment contained in the individual evaluation reports take into account the number and nature of the positions the Candidates intend to hold as indicated in Part 7 of the questionnaires? f) Availability: In the case of O-SIIs, do all Candidates comply with the quantitative limit of positions provided for in Article 33(3) of the RGICSF? Is compliance with this limit evident in the answers to the questions in Point 7.5 of the questionnaires and in the individual evaluation reports? g) Independence and conflicts of interest: Were all situations of conflicts of interest identified in Part 8 of the questionnaires analyzed in detail by the Institution, with weighting and eventual adoption of mitigating measures, in accordance with the Institution's conflicts of interest policy? Does this analysis appear in the individual evaluation reports?

Annex to Instruction No. 13/2025 BO No. 10/2025 • 2025/10/15
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h) Independence and conflicts of interest: Does the assessment of the existence of a majority of independent members in the supervisory body, which must appear in the individual evaluation reports and/or the collective evaluation report, correspond to the information provided in each of the Candidates' questionnaires?

Final verification of the file
After collecting all relevant information and finalizing the documents to be submitted to the Bank of Portugal, has a final verification of the entire procedure been carried out by a person from the Institution who was not involved in the preparation of the file?

Instruction No. 13/2025

Lineage: In force