Explanatory note relating to ultimate beneficial owners (UBOs)

Ultimate Beneficial Owner (UBO) refers to the natural person(s) who, either directly or indirectly, own(s) or control(s) more than 25% of the shares or voting rights in a legal entity, or who otherwise exercise(s) effective control over the management of the legal entity.

In case of a holding chain, the determination of Ultimate Beneficial Owners shall be conducted by identifying the natural persons for each level of the holding chain and calculating for each natural person the holding percentage of share capital and voting rights.

In the examples below, the Ultimate Beneficial Owners of the A-Company (customer of HiPay ME) are determined as follows.

• Example 1: The Ultimate Beneficial Owners are Albert Dupont and Caroline Fichet, both natural persons holding more than 25% of the A-Company’s share capital. The B-company, as a legal person holding only 5% of the A-Company’s capital, is excluded from the ultimate beneficial owner identification process.

• Example 2: The Ultimate Beneficial Owners are Albert Dupont, who directly owns more than 25% of the A-Company’s share capital, and Louis Grand, who indirectly owns – through the B-Company – 29% of the A-Company’s share capital (percentage calculation is (58x50)/100=29). The other natural persons holding less than 25% of the A-Company’s share capital are not ultimate beneficial owners – François Duchamp owns only 5% ((10x50)/100), and Corinne Richard 16% ((32x50)/100) of the A-Company’s share capital –, unless these natural persons exercise effective control over the management of the legal entity.