CYPRUS EU CITIZENSHIP SCHEME 2019 by AMP Andreas Pantazis (Estate Agents) Ltd

EU/CYPRUS CIT IZENSHIP SC H E M E

F O R

22676423

NAT U R AL I S AT IO N

22673110

O F

IN V E ST O R S

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EX C E P T IO N

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POLITIA BUSINESS CENTRE, 23 ALKEOS STR., OFFICE SUITE 302, 2404 ENGOMI, P.O.BOX 27178, 1642 NICOSIA

CYPRUS INVESTMENT PROGRAMME ON THE BASIS OF SUBSECTION (2) OF SECTION 111A OF THE CIVIL REGISTRY LAWS OF 2002-2019 One of the main objectives of the economic policy of the Republic of Cyprus is to further encourage foreign direct investment and to attract high net worth individuals to settle and conduct their business in Cyprus. Key factors that make Cyprus an attractive destination for investment, is the highly specialized human capital, the reliable legislative and regulatory framework, the stable tax system and the safety and stability conditions prevailing in the country. Within this framework and taking into account the strong investor interest, the Government of Cyprus has established and revised the "Cyprus Investment Programme” on the basis of subsection (2) of section 111A of the Civil Registry Laws of 2002-2019, with specific incentives, terms and conditions and control procedures in order to prevent abuse. On the basis of the Programme, a non-Cypriot citizen may apply for the acquisition of the Cypriot citizenship through naturalization by exception, if he/she fulfils the financial criterion A.1 and one of the financial criteria A.2-A.5, either personally or through a company/ companies in which he/she participates as a shareholder – in proportion to his/her holding percentage, or through investments done by his/her spouse or jointly with the spouse or even as a high-ranking senior manager of a company/ companies that fulfils the financial criterion A.1 and one of the financial criteria A.2-A.5. Moreover, a high-ranking senior manager may apply, provided that he/she receives such a remuneration that generates for the Republic tax revenues of at least €100,000 over a three-year period and provided that this tax has already been paid or prepaid. The applicant should have made the necessary investments during the three years preceding the date of the application and must retain the said investments for a period of at least five years as from the date of the naturalization. It is understood that the investor may replace the investment during the said five-year period, provided that he/she has obtained beforehand an approval by the Ministry of Finance. In addition, the applicant must fulfil the Terms and Conditions set out in Part B. In case where, following a periodic inspection, it has been established that a Criterion, Term or Condition of the Programme has been breached, the granted naturalization may be revoked. None of the clauses mentioned in the Programme affects the absolute discretion of the Cabinet of Ministers on making a decision.

Α. FINANCIAL CRITERIA Α.1 Donation to the Research and Innovation Foundation and the Cyprus Land Development Corporation: (a) The applicant must have donated at least €75.000 to the Research and Innovation Foundation. It is noted that if the applicant wishes to donate an amount higher than the minimum of €75.000, this additional amount can be used for purposes of supplementing the total amount of the investment made on the basis of the criteria A.2-A.5. Furthermore, the aforementioned obligation is lifted, if the applicant has invested at least €75.000 in a certified innovative enterprise (i.e. an enterprise that had acquired the relevant certificate by the Ministry of Finance) or a certified social enterprise. In addition, the obligation is lifted, if the applicant has made an investment under the criterion A.3 (Purchase or Establishment or Participation in Cypriot Companies or Businesses) of a total amount equal to the 20% of the required investment amount (i.e. €400.000) of the abovementioned criterion A.3 in a company whose operations fall within the primary sector of the economy, or the secondary sector of the economy (excluding constructions), or in the sectors of research and development, education, health and renewable energy sources. (b) The applicant must have donated at least €75.000 to the Cyprus Land Development Corporation for the financing of housing schemes for affordable housing, but also for the materialization of other housing schemes/measures. It is noted that if the applicant wishes to donate an amount higher than the minimum of €75.000, this additional amount can be used for purposes of supplementing the total amount of the investment made on the basis of the criteria A.2-A.5. Α.2 Investment in real estate, land development and infrastructure projects: The applicant must have made an investment of at least €2,0 million for the purchase or construction of buildings or for the construction of other land development projects (residential or commercial developments, developments in the tourism sector) or other infrastructure projects. It is noted that investment in land under development is included in this criterion, provided that an investment plan for the development of the purchased land will be included in the 3 application. It is understood that investment in land that is situated in a building zone of zero development, is excluded.

Α.3 Purchase or Establishment or Participation in Cypriot Companies or Businesses: The applicant must have invested at least €2,0 million for the purchase or participation in companies or organizations established and operating in the Republic of Cyprus with investment costs of. The invested funds shall be channeled towards the financing of the investment objectives of these companies exclusively in Cyprus, based on a specific investment plan. Moreover, investments in the shipping sector are eligible on the basis of measurable criteria that will be determined jointly by the Ministry of Finance and the Shipping Deputy Ministry. The applications shall be evaluated to verify that the companies or organizations have proven physical presence in Cyprus, with significant activity and turnover and employ at least 5 (five) Cypriot citizens or citizens of European Union member-states. The minimum number of employees shall increase, if more than one applicant invests almost simultaneously in the same business or company. Α.4 Investment in Alternative or Registered Alternative Investment Funds or financial assets of Cypriot companies/organizations licensed by Cyprus Securities and Exchange Commission: The applicant should have bought units of at least €2,0 million from alternative investment funds (AIF) or Registered Alternative Investment Funds (RAIF) established in the Republic of Cyprus, licensed/registered and supervised by the Cyprus Securities and Exchange Commission (CySec) and whose investments are made exclusively in the Republic of Cyprus, in investments that meet the criteria of this Programme or in areas approved by the Minister of Finance. It is permitted for these AIFs or RAIFs to invest in secondary market stock-market values of the Cyprus Stock Exchange an amount that does not exceed the €200.000. In order to confirm that the investments that meet the criteria of the current Programme will be retained for at least 5 (five) years, the manager or the auditor of the Fund shall inform in writing and on an annual basis, the Ministry of Finance with reference to the value of the initial investment. The purchase of financial assets of Cypriot companies or organizations of at least €2,0 million, such as bonds, bills and securities, issued with the approval of the CySec, by companies that have proven physical presence and substantial economic activity in the Republic of Cyprus, and have as a purpose the financing of the investment plans of these companies or organizations exclusively in Cyprus, based on an investment plan, fall under this criterion. It is noted that the purchase by an AIF or RAIF of units of other AIFs or RAIFs is not considered eligible.

Α.5 Combination of the aforementioned investments: The applicant may proceed with a combination of the above investments, provided that the total investment will amount up to at least €2,0 million. B. TERMS AND CONDITIONS 1. Clean Criminal Record: the applicant must have a clean criminal record. Furthermore, his/her name must not be included in the list of persons whose assets, within the boundaries of the European Union, have been frozen as the result of sanctions. Moreover, an applicant whose application for citizenship in any other member-state of the European Union had been rejected, is not eligible to apply for the acquisition of the Cypriot citizenship through the Cyprus Investment Programme. 2. Schengen Visa: The applicant must hold a valid Schengen visa. Third-Country nationals that do not require an entry visa for travelling in European Union member-states, as well as citizens of European Union Member States are excluded from this obligation. It is noted that all the aforementioned in paragraphs 1 and 2 also apply for the family members of the investor that are eligible to apply for the acquisition of Cypriot citizenship. 3. Residence in the Republic of Cyprus: In all cases listed in Part A, the applicant must possess a permanent privately-owned residence in the Republic of Cyprus, the purchase price of which must be at least €500.000, plus V.A.T. It is noted that members of the same family, who apply separately as investors, can collectively acquire a residence, provided that the total value of this homeproperty covers the amount of €500.000 per each applicant. In case that the purchase value of the permanent privately owned residence in Cyprus exceeds the amount of €500,000, this additional amount can be used for purposes of supplementing the total amount of the investment made on the basis of the criteria of Part A above. Additionally, it is noted that if the applicant has invested in housing unit/units on the basis of the aforementioned criterion A.2, the purchase of another permanent residence in Cyprus will not be required, if at least one of these housing units is worth at least €500,000, plus VAT, provided that the applicant retains the possession of the residence for life. However, if the applicant has invested in housing units that have already being used for the purpose of acquiring the Cypriot citizenship via the Programme, the above provision will be in force provided that the total amount of the investments, including the privately-owned residence, is at least €2,5 million. 4. Residence Permit in Cyprus: The applicant, prior to his/her naturalization as a Cypriot citizen must hold a residence permit in Cyprus for a period of at least 6 (six) months.

If the applicant does not already hold a residence permit, he/she may apply for an immigration permit on the basis of Regulation 6(2) of the Aliens and Immigration Law, simultaneously with the application for naturalization. The applicant, prior to his/her naturalization as a Cypriot citizen must hold a residence permit in Cyprus for a period of at least 6 (six) months. If the application for acquiring an immigration permit is made solely for purposes of acquiring the Cypriot citizenship, in accordance with the provisions of this Programme, there are no other conditions than those stated in both Part A and Part B of this Programme. It is noted that all of the above also apply for the adult members of the family of the investor, who will apply for naturalization. In case the application for naturalization is rejected for any reason, the immigration permit, obtained in accordance with the provisions of this decision, will be canceled immediately. C. SUBMISSION OF DOCUMENTS For the evaluation of the applications the form (M127) as well as the following documents must be submitted: 1. Clean Criminal Record: (a) Certificate of Clean Criminal Record from the country of origin and the country of residence (if different). (b) Due Diligence Report issued through an internationally accepted database ensured through a subscription (e.g. Wolrd Check, LexisNexis Diligence, Regulatory DataCorp Inc. etc.). The report must be dated no later than thirty days from the date of its submission. (c) Declaration by the applicant concerning any citizenship applications he/she may have submitted in any other member-state or member-states of the European Union. 2. Schengen Visa: Copy of a valid Schengen Visa 3. Residence in the Republic of Cyprus: (a) Contract of Sale. (b) Title Deeds or Proof of Registration of the contract with the Lands and Surveys Department. (c) Proof of payment of the agreed purchase price. (d) Copy of the wire transfer to a Cypriot commercial banking institution in the name of the seller or the sellerâ&#x20AC;&#x2122;s company. (e) An evaluation certificate from an independent registered land surveyor, if required by the Ministry of Interior or the Ministry of Finance. (f) Town-planning permit, provided that it is required by the Town and Country Planning Law.

(g) Declaration by the mortgage lender in the benefit of whom the purchased property or properties is mortgaged that will waive the mortgage, provided that the investor or the seller will pay the lender the amount conscribed in the declaration (bank waiver). (h) Project completion certificate signed by the architect of the project. If the purchased property is under construction it is required either to maintain an amount equal to the 5% of the purchase value in a special account or for the seller to issue in the benefit of the purchaser a performance bank guarantee equal to the 5% of the purchase value. 4. Criteria regarding the investment (when applicable): (a) Certificate of Registration of the company/ companies by the Registrar of Companies. (b) Certificate of shareholders by the Registrar of Companies or certificates evidencing that the applicant is the beneficiary owner of the company/ companies. (c) Audited accounts of the company (or companies) for the last three years preceding the year of the application. (d) If the applicant is a high-ranking senior manager, the submission of the employment contract and the receipt from the Department of Inland Revenue are additionally required. (e) If the investment is made by the spouse of the applicant or jointly, a marriage certificate is required. Furthermore, depending on the case, the following are required: 1. Donation to the Research and Innovation Foundation and the Cyprus Land Development Corporation (a) Copy of the wire transfer of the donation to the Research and Innovation Foundation to an account in a Cypriot commercial banking institution in the name of the Foundation. (b) Copy of the wire transfer of the donation to the Cyprus Land Development Corporation to an account in a Cypriot commercial banking institution in the name of the Corporation. (c) Innovative enterprise certificate. (d) Investment Agreement in Cypriot company or companies. (e) Proof of payment of the agreed amount. (f) Certificate of shareholders by the Registrar of Companies. (g) Copy of the wire transfer to a Cypriot commercial banking institution in the name of the company or the organization. (h) Specific investment plan. (i) Copies of the employment contracts of the Cypriot or European Union citizens employed by the company in which the applicant has invested.

(j) Confirmation from the Social Insurance Department as to the insurable income of the Cypriot or European Union citizens employed in the company. (k) Registration Certificate (MEU1) or Permanent Registration Certificate of Union Citizen (MEU3) for employees that are European Union citizens. 2. Investment in real estate, land development and infrastructure projects (a) Contract of sale. (b) Title Deeds or Proof of Registration of the contract with the Lands and Surveys Department. (c) Proofs of payment of the agreed purchase price. (d) Copy of the wire transfer to a Cypriot commercial banking institution in the name of the seller or the sellerâ&#x20AC;&#x2122;s company. (e) An evaluation certificate from an independent registered land surveyor, if required by the Ministry of Interior or the Ministry of Finance. (f) Investment Plan for the development of the purchased land, if the investment involves the purchase of land under development. (g) Town-planning permit, provided that it is required by the Town and Country Planning Law. (h) Declaration by the mortgage lender in the benefit of whom the purchased property or properties is mortgaged that will waive the mortgage, provided that the investor or the seller will pay the lender the amount conscribed in the declaration (bank waiver). (i) Project completion certificate signed by the architect of the project. If the purchased property is under construction it is required either to maintain an amount equal to the 5% of the purchase value in a special account or for the seller to issue in the benefit of the purchaser a performance bank guarantee equal to the 5% of the purchase value. 3. Purchase or Establishment or Participation in Cypriot Companies or Businesses (a) Investment Agreement in Cypriot company or companies. (b) Proof of payment of the agreed amount. (c) Certificate of shareholders by the Registrar of Companies. (d) Copy of the wire transfer to a Cypriot commercial banking institution in the name of the company or the organization. (e) Specific investment plan. (f) Copies of the employment contracts of the Cypriot or European Union citizens employed by the company in which the applicant has invested.

(g) Confirmation from the Social Insurance Department as to the insurable income of the Cypriot or European Union citizens employed in the company. (h) Registration Certificate (MEU1) or Permanent Registration Certificate of Union Citizen (MEU3) for employees that are European Union citizens. 4. Investment in Alternative Investment Funds or Registered Alternative Investment Funds or financial assets of Cypriot companies or Cypriot organizations that are licensed by Cyprus Securities and Exchange Commission: (a) Title/Titles and other relevant documents of the financial assets / units purchased. (b) Copy of the wire transfer to a Cypriot commercial banking institution in the name of the company or the organization. (c) Specific investment plan. (d) Confirmation by the CySec.

Ministry of Interior 28.2.2019

INVESTOR’S FAMILY MEMBERS The decision of the Council of Ministers dated 13.2.2019 provides for the grant of the Cypriot citizenship to the spouse or partner of the investor, to the parents of the investor and to the financially dependent adult children of the investor as well. The minor children of the investor have the right to acquire the citizenship according to the provisions of section 110 (3) of the Civil Registry Law. According to abovementioned decision and the relevant legislation, the parents, the financially dependent adult children (18 years old and above) and the minor children (under 18 years old) may apply for citizenship after the acquisition of the Cypriot citizenship by the investor. However, concerning the investor’s spouse or partner the Council of Ministers decided to allow the submission of his/her (spouse’s or partner’s) application along with the application of the investor, so that both spouses/ partners will be able to acquire the Cypriot citizenship simultaneously. It is noted that the aforementioned decision clearly stipulates that the applicant must have a clean criminal record. Furthermore, his/her name must not be included in the list of persons whose assets, within the boundaries of the European Union, have been frozen as the result of sanctions. Additionally, an applicant whose application for citizenship in any other member-state of the European Union had been rejected, is not eligible to apply for the acquisition of the Cypriot citizenship through the Cypriot Investment Programme. Furthermore, the applicant must hold a valid Schengen visa. Third-Country nationals that do not require an entry visa for travelling in European Union member-states, as well as citizens of European Union Member States are excluded from this obligation. Moreover, it is also noted that, according to the provisions of the abovementioned decision, the adult family members of the investor prior to their naturalization as Cypriot citizens must hold a residence permit in Cyprus for a period of at least 6 (six) months. If the applicant does not already hold a residence permit, he/she may apply for an immigration permit on the basis of Regulation 6(2) of the Aliens and Immigration Law, simultaneously with the application for naturalization. The applicant, prior to his/her naturalization as a Cypriot citizen must hold a residence permit in Cyprus for a period of at least 6 (six) months. In case the application for acquiring an immigration permit will be submitted solely for the purposes of acquiring the Cypriot citizenship, in accordance with the provisions of this Programme, there are no other conditions than those stated in the Programme the details of which are explained below. Finally, if the application for naturalization is for any reason rejected, the immigration permit, obtained in accordance with the provisions of this decision, will be cancelled immediately.

Spouse/Partner The investor’s spouse or partner may acquire the Cypriot citizenship after filing the relevant application (Form M127). The applications are filed at the Ministry of Interior. In order to facilitate the procedure of the acquisition of the Cypriot citizenship by the investor’s partner or spouse, the Council of Ministers decided to allow the submission of the spouse’s or partner’s application along with the application of the investor, so that both spouses/ partners will be able to acquire the Cypriot citizenship simultaneously. Furthermore, the decision of the Council of Ministers clarifies that for the purposes of the Programme the term partner is interpreted in accordance with the provisions of the Civil Partnership Law 184(I)/2015. According to this law the State recognizes any civil partnership that had been concluded in the Republic of Cyprus, or any other state in accordance with the legislation of that state and is still in power. Minor Children The application for the grant of the Cypriot citizenship to the children of the investor that are under the age of eighteen is submitted after the investor had acquired the Cypriot citizenship and provided that the other parent consents to the grant of the citizenship. The application is filed at the Civil Registry and Migration Department. Adult Children The right to apply for citizenship is also granted to the financially dependent adult children of the Investor. The decision of the Council of Ministers has determined that it will regard as financially dependent adult children individuals belonging to one of the below categories: (a) students up to the age of 28 that are attending an institution of higher education aiming to obtain a diploma or an undergraduate or a master’s degree. The decision excludes individuals who are studying for the acquisition of a professional qualification (e.g. chartered accountants or barrister). (b) children with severe physical or mental disability that renders them unable to work. The application can be submitted after the investor had acquired the Cypriot citizenship. These applications (Form M127) are filed at the Ministry of Interior.

Investor’s Parents The parents of the investor may apply for citizenship after the investor had acquired the Cypriot citizenship. These applications (Form M127) are filed at the Ministry of Interior. In order for the investor’s parents to be able to apply for citizenship they need to hold a permanent privatelyowned residence in the Republic of Cyprus, the purchase price of which must be at least €500.000, plus V.A.T. It is noted the investor and his/her parents, may collectively acquire a residence, provided that the total value of this home-property is at least €1.000.000, plus V.A.T.

Ministry of Interior 28.2.2019

GUIDELINES FOR THE SUBMISSION OF AN APPLICATION FOR THE ACQUISITION OF AN IMMIGRATION PERMIT The Decision of the Council of Ministers dated 13.9.2016 provides that the investor and his/her adult family members, prior to their naturalization as Cypriot citizens, must hold a residence permit in Cyprus. If the applicant (either investor or family member) does not already hold a residence permit, he/she may apply for an Immigration Permit on the basis of Regulation 6 (2) of the Aliens and Immigration Law, simultaneously with the application for naturalization. In relation to the submission of an Immigration Permit application solely for the purposes of acquiring the Cypriot citizenship, in accordance with the provisions of this Scheme, there are no other conditions than those stated in the Scheme. In the case where the investor does not already hold a residence permit he/she will need to submit an application for acquiring an Immigration Permit, right after the submission of Naturalization application, following the procedure that is described below. It is noted that the procedure described below needs to be followed for the submission of the citizenship application of the investor’s adult family members (i.e. parents and financially dependent adult children of the investor as defined by the abovementioned Decision of the Council of Ministers dated 13.9.2016) that do not already hold a residence permit. The legislation pertaining to the grant of the Immigration Permit provides that only the spouse/ partner and minor children (under the age of eighteen) of an Immigration Permit holder are considered dependent family members and therefore they may acquire the Immigration Permit without the submission of separate applications. All the other family members (i.e. parents and financially dependent adult children of the investor) need to submit separate Immigration Permit applications. However, it goes without saying that concerning the acquisition of the Cypriot citizenship, each person needs to file a separate individual application. In the case where an Immigration Permit application is required to be submitted along with the Naturalization application the below procedure needs to be followed: I. Submission of the citizenship application at the Ministry of Interior The submitted application needs to be complete and accompanied with all the necessary documents (Concerning the application for naturalization, prior to its 2 submission, please see the relevant “Guidelines” documents that can be found on the website of the Ministry of Interior). Provided that the application is complete and accompanied by all the necessary documents the “Confirmation of Submission of Application for Naturalization by Exception” (not the same thing as the fees payment receipt) will be handed over to the applicant or his/her representative. This “Confirmation” will be used for the submission of the immigration permit application at the Civil Registry and Migration Department.

II. Submission of the immigration permit application at the Civil Registry and Migration Department For the submission of the immigration permit application the following documents need to be filed:

1. Form MIP1 2. Clean Criminal Record Certificate 3. Copy of Passport 4. Marriage Certificate/ Civil Partnership Certificate (where applicable) 5. “Confirmation of Submission of Application for Naturalization by Exception” by the Ministry of Interior. Having in mind that the documents 2-4 would have already been submitted in their original form at the Ministry of Interior along with the naturalization application, it is accepted to file copies of the submitted documents. The Marriage Certificate or the Civil Partnership Certificate will need to be submitted only if the spouse or partner of the investor wishes to acquire the immigration permit as the investor’s dependent. For the submission of the application for immigration permit an

appointment

needs

arranged

beforehand

via

the

atcharalambous@papd.mof.gov.cy. III. Collection of applicant’s biometric data For the issuance of the immigration permit the collection of the applicant’s biometric data (fingerprints and photograph) and signature is mandatory. In order for the biometric data to be collected the applicant is required to appear in person at the Civil Registry and Migration Department. Moreover, the applicant needs to present an original travel document. IV. Issuance of the Immigration Permit After the collection of the biometric data, the immigration permit (card) is issued within five working days. Please bear in mind that the applicant cannot be considered as a holder of a residence permit, unless the aforementioned procedure is completed and the immigration permit (card) issued. Moreover, it goes without saying that the applicant is obliged to pay all the fees required for the submission of the application and the issuance of the immigration permit. Finally, it needs to be noted that, when the naturalization procedure is completed and the applicant acquired the Cypriot citizenship, the immigration permit will be immediately cancelled. Moreover, if the application for naturalization is for any reason rejected, the immigration permit, obtained in accordance with the provisions of the decision of the Council of Ministers dated 13.2.2019, will be canceled immediately. Ministry of Interior 28.2.2019 14

Cyprus Investment Programme

Code of Conduct

June 2018

1. Introduction The provision of advisory services relating to the Cyprus Investment Programme (hereinafter the ‘Programme’) depends to a large extent on the ethical behaviour and the trustworthy professionalism of all the certified service providers. The responsible conduct of the service providers is based on the Code of Conduct which intends to create, enhance and maintain the trust of the applicants in the specific Programme on one hand and to protect the principles and individual parameters of the Programme on the other. Τhe Committee of Supervision and Control (hereinafter the ‘Committee’) which consists of representatives from the Ministry of Finance, Ministry of Interior and Invest Cyprus, is responsible for approving registrations of new members with the Registry of Service Providers of the Cyprus Investment Programme (hereinafter the ‘Registry’), as well as for supervising the adherence to the provisions of the Code of Conduct by its members. The Code of Conduct shall be adjusted by the Committee to reflect the needs, goals and challenges of the Programme from time to time. Consequently, the relevance and effectiveness of the Code of Conduct shall to a large extent depend on the response and support it receives by all parties involved. The Code of Conduct shall be subject to regular review and update at least annually or as determined by the Committee. 2. Purpose The primary purpose of the Code of Conduct is to set the parameters for the provision of services which will protect the service providers as well as the applicants they serve, from unprofessional, unethical and/or incompetent practices. Compliance with the Code constitutes a fundamental element for the support and further development of the Programme, protecting and simultaneously enhancing its reputation as well as the reputation of Cyprus in general. Τhe Code of Conduct cannot deal with every possible situation or misconduct, but includes the principles designed to govern the provision of services in relation to the Programme. By committing to this Code, members will be able to register with the Registry and shall be bound to adhere to the Code of Conduct in its entirety, recognising that any possible circumvention may lead to their exclusion from the Registry. The members of the Registry, who shall be accountable to the Committee, are obliged to renew their commitment every year and shall simultaneously be able to contribute to the improvement of the Code of Conduct through a specific consultation procedure with the Committee. The Committee shall provide timely information on possible changes or additions to the basic principles of the Code 3 of Conduct and shall also provide sufficient warning to the members of the Registry for possible deviations from the Code of Conduct.

3. Registry of Service Providers All natural and/or legal persons who will provide services related to the Programme are obliged to register with the Registry, which shall be maintained by the Committee. The registration application must be completed online through the website of the Ministry of Finance. By completing the application form, the member is bound to immediately apply all the provisions of the present Code of Conduct and undertakes the obligation of informing all its professional associates and partners of their own obligations. The members of the Registry are obliged to immediately inform the Committee in writing of any changes in relation to the details provided in the registration application they submitted, including the details of natural persons who act on their behalf as well as their professional associates for the purpose of the Programme, and/or of any other data or document which may have been requested. 4. Basic principles The members of the Registry have individual and joined responsibilities in order to actively contribute to the maintenance and enhancement of the integrity of the Programme. The members of the Registry are bound to fully adhere to the following basic principles: 4.1. Zero tolerance and/or engagement in unprofessional or unethical forms of practice. 4.2. Maintaining a high level of transparency in all transactions with clients, collaborators and other stakeholders. 4.3. Full compliance with applicable laws and regulations and the provisions of the Programme, in relation to eligible investments and the minimum required limit, as well as with the other terms and conditions of the Programme. 4.4. Encouraging all stakeholders in the Programme to adhere to the same ethical standards. 4.5. Refraining from behaviour which damages the integrity, reputation and image of the service providers, the government sector and the country itself. 4.6. Refraining from adopting practices which circumvent the financial goals of the Programme, either through reducing the real economic benefit for the country from investments pursuant to the Programme or otherwise. 5. Provision of Services The members of the Registry who act as service providers, including natural persons who act on their behalf, as well as their professional associates for the purposes of the Programme, must ensure their clients are informed in writing of the exact nature of their services and all relevant

commitments which relate to them, including their commitments pursuant to the Code of Conduct. Within this context, the following must be abided by: 5.1. Professional relationships between a member and a client must be described in a service agreement which must, inter alia, describe the rights and obligations of each party and include the applicable terms and conditions in case of disagreement during the process. 5.2. In the event of a variation of the terms of the above agreement, the member must obtain the written consent of the client to such variation. 5.3. Members must not make statements or provide or publish any false or misleading information related to the Programme. 5.4. Members who provide advice in relation to the process of the Programme must act in an efficient and professional manner and only within their area of competence. 5.5. Members must submit, on behalf of the applicant, the activity reports, which are required or may be required pursuant to the terms and conditions of the Programme. 6. Client Management Members of the Registry shall apply the following due diligence practices in relation to client acceptance, when examining the possibility of collaboration: 6.1. Recording and verifying information that fully and accurately identifies the potential client. 6.2. Undertaking, within the framework of the law, checks on the client, of its professional activities as well as its surroundings (including possible publications in the press or online). 6.3. Verifying the origin and legality of the investment funds of the client. 6.4. Providing a report of the findings of the due diligence review (due diligence report) from internationally recognised electronic databases, for the use of which a fee is payable (e.g. World Check, LexisNexis Diligence, Regulatory DataCorp Inc, etc). The report must be dated no later than thirty days from the date of its submission. Members must ensure that they take all required steps to secure the safety of their clientsâ&#x20AC;&#x2122; funds, as follows: 6.5. Maintaining client investment funds in separate bank accounts. 6.6. Reporting to clients as to the movement of their funds. 6.7. Reporting to clients on all expenses made and issuing relevant invoices with all necessary information, as provided by applicable law. 6.8. Returning to clients any possible excess of funds including interest, upon completion of the collaboration.

Members apply clear and distinct procedures to manage all clientsâ&#x20AC;&#x2122; information with due confidentiality and ensure that the information is made available only in cases where the members are obliged to disclose information through court or other legal proceedings, notifying their clients in advance. 7. Promotion and public relations Members of the Registry, including natural persons who act on their behalf, as well as their professional associates, for the purposes of the Programme, have an obligation to apply all the guidelines in relation to promotion, as these are noted in the attached Annex. The Guidelines codify the acceptable and non-acceptable methods of promotion of the Programme. The application of the Guidelines is obligatory and in case where the Committee finds deviation and non-compliance by a member and any other person acting on his/her behalf or collaborating with him/her, this will lead to exclusion from the Registry and/or non-acceptance of his/her professional associates to receive an application in the context of the Programme. The Committee shall monitor the process of provision of services by the members and shall intervene where this is deemed necessary, initially by sending a warning letter and if there is no compliance by deleting the service provider from the Registry. The material used by the providers should comply with the guidelines as noted in the Annex. 8. General Terms Members, including natural persons acting on their behalf, as well as their professional associates for the purposes of the Programme: 8.1. Have an obligation to maintain strong and ethical relations with the public sector and the authorities which handle the Programme. 8.2. Any act which intends to affect the work of the government authorities which handle the examination of applications is expressly prohibited. 8.3. Transparency must be established as a guiding principle in each communication between the member and the public sector. 8.4. Do not participate, directly or indirectly, in any form of bribery, nor do they imply/suggest any form of bribery or other unlawful or unethical behaviour, nor do they exercise any improper influence on governmental authorities or officials. 8.5. Cannot carry out any activity which is, or could be considered as wrong, corrupt, unethical or unlawful.

8.6. Under no circumstances, must they misinform their clients about their relationship with governments or government officials, especially so as to promote their services and/or to accelerate the examination process of their clientâ&#x20AC;&#x2122;s application. 8.7. Must avoid any conflict of interest which may occur between their organisations and their clients, business associates, government officers and other professional associates with which they collaborate in the application of the Programme. 8.8. Are obliged to immediately inform the applicant in writing if any real or potential conflict of interest occurs during the provision of their services. 9. Non-compliance consequences Members, including natural persons acting on their behalf, as well as their professional associates for the purposes of the Programme, are obliged to fully apply all procedures and regulations for the proper implementation of the Code of Conduct. Non-compliance with the Code of Conduct, may lead to deletion of the providers from the Registry. Within this framework: 9.1. The Committee, in the event of deletion from the Registry (voluntarily or after a decision of the Committee), shall announce the deletion by posting it in the websites of the Ministries of Interior and Finance and Invest Cyprus. 9.2. The Committee, when deemed necessary, maintains the right, at any given time, to call the applicants as well as the service providers for an interview for further clarifications. 9.3. The Committee will be able to receive complaints. Upon examination of the said complaints, the Committee will decide whether it will take any further actions or refer the issue to the relevant Ministries. 9.4. The Committee shall maintain the right not to register service providers in relation to the Programme who collaborate with companies which do not apply the relevant provisions of the Code of Conduct.

GUIDELINES FOR THE SUBMISSION OF THE INVESTOR’S APPLICATION The application for the naturalization by exception needs to be submitted at the Ministry of Interior and the amount of €2.000 as fees will need to be paid. For the submission of the application an appointment will need to be arranged beforehand via the email esavva@papd.mof.gov.cy. No application will be accepted for submission, if an appointment has not been arranged beforehand.

DOCUMENTS At the Ministry of Interior, the original documents should be submitted, along with a photocopy of all the documents. The list of the necessary documents is as follows: • Completed “Check List of Investors Application Documents” (is located on the Ministry of Interior’ website) • “Self-Declaration by the Applicant who has received services for the purposes of the Cyprus Investment Programme” duly completed and signed by the investor • “Self-Declaration by the Service Provider for the purposes of the Cyprus Investment Programme” duly completed and signed by the representative of the applicant • Letter by the applicant or by the representative of the applicant, in which the investment and criterion, under which the application is submitted, are briefly explained

APPLICANT’S PERSONAL DOCUMENTS • Application Form M127 fully completed and signed before a Registrar of a Cypriot court or a consular officer • Birth Certificate • True Copy of passport • Certificate of Clean Criminal Record from the country of origin and the country of residence (if different). The Certificate or Certificates must be dated no later than ninety days from the date of its submission • Due Diligence Report issued through an internationally accepted database ensured through a subscription (e.g. Wolrd Check, LexisNexis Diligence, Regulatory DataCorp Inc. etc.). The report must be dated no later than thirty days from the date of its submission • Declaration by the applicant concerning any citizenship applications he/she may have submitted in any other member-state or member-states of the European Union signed before a Registrar of a Cypriot court or a consular officer • Copy of valid Schengen Visa

• Marriage Certificate/Civil Partnership Certificate • Copies of advertisements in a daily newspaper two consecutive posts • Two passport size photographs • Curriculum Vitae • Copy of Residence Permit in the Republic of Cyprus. If the applicant does not already hold a residence permit, he/ she may apply for an immigration permit on the basis of Regulation 6 (2) of the Aliens and Immigration Law, simultaneously with the application for naturalization. For further information, please see the document “CYPRUS INVESTMENT PROGRAMME_15.5.2019_GUIDELINES FOR IMMIGRATION PERMIT APPLICATION” on the website of the Minister of Interior • If the applicant is a high-ranking senior manager the following documents should, also, be submitted:

RESIDENCE IN THE REPUBLIC OF CYPRUS • Contract of Sale • Title Deeds or Proof of Registration of the contract with the Lands and Surveys Department • Proof of payment of the agreed purchase price • Copy of the wire transfer to a Cypriot commercial banking institution in the name of the seller or the seller’s company • Town-planning permit, provided that it is required by the Town and Country Planning Law • Declaration by the mortgage lender in the benefit of whom the purchased property or properties is mortgaged that will waive the mortgage, provided that the investor or the seller will pay the lender the amount conscribed in the declaration (bank waiver) • Project completion certificate signed by the architect of the project. If the purchased property is under construction it is required either to maintain an amount equal to the 5% of the purchase value in a special account or for the seller to issue in the benefit of the purchaser a performance bank guarantee equal to the 5% of the purchase value

FINANCIAL DOCUMENTS These documents may include: • Certificate of Registration of the company/ companies by the Registrar of Companies • Certificate of shareholders by the Registrar of Companies or certificates evidencing that the applicant is the beneficiary owner of the company/ companies • Audited accounts of the company (or companies) for the last three years preceding the year of the application. 1. Donation to the Research and Innovation Foundation and the Cyprus Land Development Corporation • Copy of the wire transfer of the donation to the Research and Innovation Foundation to an account in a Cypriot commercial banking institution in the name of the Foundation • Copy of the wire transfer of the donation to the Cyprus Land Development Corporation to an account in a Cypriot commercial banking institution in the name of the Corporation • Innovative enterprise certificate • Investment Agreement in Cypriot company or companies • Proof of payment of the agreed amount • Certificate of shareholders by the Registrar of Companies • Copy of the wire transfer to a Cypriot commercial banking institution in the name of the company or the organization • Specific investment plan • Copies of the employment contracts of the Cypriot or European Union citizens employed by the company in which the applicant has invested • Confirmation from the Social Insurance Department as to the insurable income of the Cypriot or European Union citizens employed in the company • Registration Certificate (MEU1) or Permanent Registration Certificate of Union Citizen (MEU3) for employees that are European Union citizens 2. Investment in real estate, land development and infrastructure projects • Contract of sale • Title Deeds or Proof of Registration of the contract with the Lands and Surveys Department

• Proofs of payment of the agreed purchase price • Copy of the wire transfer to a Cypriot commercial banking institution in the name of the seller or the seller’s company • Investment Plan for the development of the purchased land, if the investment involves the purchase of land under development • Town-planning permit, provided that it is required by the Town and Country Planning Law • Declaration by the mortgage lender in the benefit of whom the purchased property or properties is mortgaged that will waive the mortgage, provided that the investor or the seller will pay the lender the amount conscribed in the declaration (bank waiver) • Project completion certificate signed by the architect of the project. If the purchased property is under construction it is required either to maintain an amount equal to the 5% of the purchase value in a special account or for the seller to issue in the benefit of the purchaser a performance bank guarantee equal to the 5% of the purchase value 3. Purchase or Establishment or Participation in Cypriot Companies or Businesses • Investment Agreement in Cypriot company or companies • Proof of payment of the agreed amount • Certificate of shareholders by the Registrar of Companies • Copy of the wire transfer to a Cypriot commercial banking institution in the name of the company or the organization • Specific investment plan • Copies of the employment contracts of the Cypriot or European Union citizens employed by the company in which the applicant has invested • Confirmation from the Social Insurance Department as to the insurable income of the Cypriot or European Union citizens employed in the company • Registration Certificate (MEU1) or Permanent Registration Certificate of Union Citizen (MEU3) for employees that are European Union citizens

4. Investment in Alternative Investment Funds or Registered Alternative Investment Funds or financial assets of Cypriot companies or Cypriot organizations that are licensed by Cyprus Securities and Exchange Commission: • Title/Titles and other relevant documents of the financial assets / units purchased • Copy of the wire transfer to a Cypriot commercial banking institution in the name of the company or the organization • Specific investment plan • Confirmation by CySec Note 1: The original application (M127) and all the required documents in their original form need to be submitted at the Ministry of Interior. Along with the original application and documents, an additional photocopy of the application and all the documents should also be submitted. Please ensure that all copies are clear and easy to read. The original documents and the copies need to be submitted in two separate and distinguished bundles. Moreover, the documents need to be placed in the bundles in the order that they appear on the “Investor’s Application Check List” (document “CYPRUS INVESTMENT PROGRAMME_15.5.2019_CHECK LIST INVESTORS” located on the website of the Ministry of Interior). In addition, on the upper left side of each document the number of the relevant document on the “Investor’s Application Check List” needs to be written by pencil. Note 2: The spouse/partner of the non-Cypriot investor has the right to apply for the citizenship simultaneously with the investor. For further information, see the Document “CYPRUS INVESTMENT PROGRAMME_15.5.2019_GUIDELINES FAMILY MEMBERSCITIZENSIP APPLICATION” posted on the website of the Ministry of Interior.

RATIFICATION OF ACCOMPANYING DOCUMENTS All the accompanying documents issued by a foreign authority should be duly authenticated. Specifically, they should bear the stamp «APOSTILE», if they are issued by countries that have ratified the Convention on the abolishing the requirement of legalisation for Foreign Public Documents of 1972 (Apostille stamp). Conversely, if they are issued by states that had not ratified the Convention on the abolishing the requirement of legalisation for Foreign Public Documents of 1972 (Apostille stamp), they should bear diplomatic ratification. The diplomatic ratification is acquired through one of the following ways:

I. If in the issuing country there is an accredited diplomatic/ consular authority of the Republic, the chain of certification is as follows: 1. Certification of the document by the Ministry of Foreign Affairs of the issuing country. 2. Certification of the signature of the officer of the Ministry of Foreign Affairs of the issuing country by an officer of the diplomatic/ consular authority of the Republic in the issuing country. 3. Certification of the signature of the officer of the diplomatic/ consular authority of the Republic in the issuing country by the Department of Certifications of the Ministry of Foreign Affairs of the Republic. II. If there is not an accredited diplomatic/ consular authority of the Republic in the issuing country, the chain of certification is as follows: 1. Certification of the document by the Ministry of Foreign Affairs of the issuing country. 2. Certification of the signature of the officer of the Ministry of Foreign Affairs of the issuing country by a diplomatic/ consular authority of the issuing country in a third country. 3. Certification of the signature of the officer of the issuing countryâ&#x20AC;&#x2122;s diplomatic/ consular authority in the specific third country by an officer of the diplomatic/ consular authority of the Republic in that third country. 4. Certification of the signature of the officer of the diplomatic/ consular authority in that third country by the Department of Certifications of the Ministry of Foreign Affairs of the Republic.

LANGUAGES OF THE ACCOMPANYING DOCUMENTS: All documents submitted with the application shall be in Greek or English. Otherwise, they must be accompanied by a certified translation into one of these languages, by the Press and Information Office or by a Consular Authority of the issuing country or by a governmental department/ service of the issuing country. Applications that are not complete (i.e. that do not include all the necessary documents) and that are not submitted in the way that is described above (distinct originals and copies) will not be accepted for submission.

EXAMINATION PROCEDURE OF THE APPLICATION Once an application is submitted the examination process begins. First of all, the documents relating to the business activities and investments of the applicant in Cyprus are sent to the Ministry of Finance for evaluation and comments on whether the applicant indeed meets any of the criteria established by the Council of Ministers. Simultaneously, the Ministry of Interior investigates whether the applicant meets the other conditions of the abovementioned decision of

the Council of Ministers. If the applicant meets the criteria and conditions of the decision, the Minister of Interior presents the case to the Council of Ministers for final decision. Please bear in mind that a decision of the Council of Ministers of the 21st of May 2018 has determined that the expected time-frame for the examination of any application submitted in accordance with the provisions of the Cyprus Investment Programme is 6 (six) months. It goes without saying that in order to uphold the six-month examination period the application needs to be duly submitted and accompanied by all the necessary supporting documents and the investor meets the criteria and conditions of the Programme. It should be noted that the application submission date is the date on which the submission fees were paid that is noted on the receipt issued by the Cashierâ&#x20AC;&#x2122;s Office of the Ministry. Once the application is approved, the applicant will be able to take all actions for the acquisition of the citizenship and the issue of a Cypriot passport. The procedure for the acquisition of the Cypriot citizenship will be completed, provided that the applicant holds a residence permit for a period of at least 6 (six) months. If the applicant does not hold a residence permit for the aforementioned time period, he/she will need to wait until the six-month period is completed. Afterwards, the Civil Registry and Migration Department issues the Certificate of Naturalization, following payment of the amount of â&#x201A;Ź5.000 that constitutes the Naturalization Certificate issuing fee. Subsequently, the applicant will need to give the Oath of Faith to the Cypriot Republic before a Registrar of a Cypriot court or a consular officer of the Republic of Cyprus. Once this procedure is completed the applicant will be able to acquire a Cypriot passport and Identity Card.

Ministry of Interior 28.2.2019