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ECFH Client Privacy Notice

ABOUT THIS NOTICE

The notice herein is being provided on behalf of ECFH Group comprising East Caribbean Financial Holding Co. Ltd, Bank of Saint Lucia Limited, Bank of Saint Lucia International Limited, EC Global Insurance Company limited, Property Holding and Development Company Limited and Mortgage Finance Company of Saint Lucia Limited. It covers all personally identifiable information about an individual’s current or former client relationships with these companies

This privacy notice is being provided to clients who purchase products and services from us for business, personal, family or household purposes. This notice tells you how we collect, handle and disclose personal information about you. The term “personal information” as used in this notice means information that identifies you personally. We may also use information which does not personally identify you to help us manage our business.

In keeping with our commitment, our Client Privacy policy is published on our website www.ecfh.com and is available to customers on demand. When significant changes are made, they will be highlighted on the Website.

We encourage you to read and retain this notice, and to call the Risk Management Department of the East Caribbean Financial Holding Co. Ltd if you have any questions about this notice.

OUR GOAL

Our goal is to maintain your trust and confidence when handling information about you. Keeping your information secure and ensuring your understanding of how we use that information is an important aspect of building and maintaining that trust.

RATIONALE FOR COLLECTION

Personal information is collected to enable us to provide products and services to you and to improve and conduct our business. For example, we collect personal information to:

Help us better evaluate your financial needs
Process your requests and transactions more efficiently
Keep you informed about new and existing products and services that may be of interest to you
Ensure that you are provided with effective and efficient customer service
Assess quality of our products and services

SOURCES OF INFORMATION

We collect information on you from a variety of sources, including:

Account applications and other forms that you submit to us, which provide information such as your name, address, e¬mail address, telephone number, date of birth, Social Security number or other tax identification number, occupation, financial goals, assets and income
Your transactions or experiences with us and our affiliated companies
Other members of the ECFH Group of companies
Other banks and financial institutions to confirm information that you have provided to us, particularly in the process of evaluating applications for loans
Other information submitted to us by you or a third party authorized by you to provide such to us on your behalf for the conduct of business with us and our affiliated companies.

TYPES OF INFORMATION COLLECTED

We will limit the collection, use and retention of your information to what we believe is necessary to provide you with exceptional quality service, comply with regulatory requirements, and make available to you other products, services, and opportunities that may be of interest to you. For example, your information may be used to evaluate your eligibility for a loan or other service, to improve our products and services or the way we deliver them to you, or to protect you from fraud. The information that we collect is limited to the following

Identification information such as names, address, telephone number, social security number etc.
Application information such as assets, income, debt, etc.
Transaction and experience information such as balance, payment history, account usage, etc.
Historical Information from other sources such as employment history, credit history, etc.
Compliance information – we collect information that may be required to ensure compliance with the laws of Saint Lucia such as Money Laundering (Prevention) Act.

DISCLOSURE OF INFORMATION

We will only disclose your personal information under the following circumstances:

So that you may be informed of other products and services.
In order to verify or complete a transaction.
To verify the existence and condition of your account at another financial institution.
To a third party performing a function on behalf of any member company or subsidiary of the ECFH Group.
To comply with any law, regulation or an order of the Court.
If you or any authorized person on the account gives us verbal or written permission to do so.

ACCESS TO PERSONAL INFORMATION

Only those employees who need to have access to your personal information to perform their jobs are given the access to your personal information. They may need access to your personal information to conduct business on your behalf, service your account, help you and your Financial Advisor pursue your financial objectives, and to conduct our business.

PROTECTION OF PERSONAL INFORMATION

The ECFH Group is committed to securing your personal information. We maintain your personal information and data according to strict standards of security and confidentiality.

We have ensured that employees who have access to your personal information maintain and protect the confidentiality of that information and must follow established procedures. Additionally, employees are required to acknowledge their responsibility to maintain the confidentiality of customer information through an oath of secrecy renewed annually.

When we use other companies to provide services for us, we require them to protect the confidentiality of personal information. They are required to sign a legally binding confidentiality agreement which limits their use of the personal information of customers.

We also maintain physical, electronic and procedural safeguards that meet required standards to protect your personal information from unauthorized use. This includes the use of 128 bit encryption browser, installation of firewalls, monitoring of our systems and other security enhancements.

Our ECFH website may contain links to third party sites. These links and pointers to third party sites are not part of ECFH Group. Further, these third party sites may have privacy policies different from those of the ECFH Group and third party sites may provide less security than the ECFH web site. You should therefore review their privacy and security policies, before you share any of your personal information. Neither the ECFH GROUP nor its affiliates make any representations or warranties regarding these third party sites. ECFH Group is not responsible for any losses or damages in connection with the information, security, privacy practices, availability, content or accuracy of materials of such third party sites.
Notwithstanding the above, protection of your personal information is a shared responsibility. You have a critical role to play in this process. The following are some steps that you can take to assist our efforts to protect your information

Review your monthly account statements thoroughly and report any suspicious activity immediately.
Report lost or stolen cheques, credit cards immediately.
Do not pre-print your driver’s license or social security number on cheques.
Safeguard all your ATM, credit and debit cards.
Memorize PINS (Personal Identification Numbers) and refrain from writing them down because you may lose them or leave them in a place that can be found by another party.
Do not share your PIN or passwords for online accounts with anyone.
Before you reveal any personally identifying information, find out how it will be used and whether it will be shared with others.
Put passwords on your credit card, bank and phone accounts.
If you believe that you have been a victim of identity theft or fraud, immediately contact your customer service representative.

SHARING INFORMATION WITH OUR AFFILIATES/ SUBSIDIARIES

We may share your personal information with our affiliates as required or permitted by applicable law. Our affiliates are companies that we control or own and include our subsidiary companies. This would be strictly for the purpose of marketing a suite of products and services tailored specifically to meet your needs. For example, we may share information with our subsidiary companies in order to:

Provide you with products and services that you have requested
Service your account
Process transactions relating to your account

We may share your name, contact information and information about our transactions and experiences with you with our subsidiaries so that they or we may offer products or services that may be appropriate for you and to conduct business . As one example, we may share your name, contact information and transactions and information about your experiences with us with our bank or mortgage subsidiaries to determine whether certain products or services that they offer might meet your specific needs, so that they could offer their products and services directly to you.

SHARING INFORMATION WITH NONAFFILIATED THIRD PARTIES

We are firm in our commitment that we will not rent or sell your personal information to any third party. However, we may share your personal information with companies that we hire to perform services for us, such as vendors that provide data processing, computer software maintenance and development, transaction processing and marketing services. We assure you that any company with whom we share your information agree to limit the use of such information to the purpose for which it was provided through the use of a duly signed legally binding confidentiality agreement.

Finally, we may disclose personal information to others, including nonaffiliated companies and regulatory authorities, as either required or permitted by applicable law. For example, we may disclose personal information to:

Comply with investigations by regulatory authorities or law enforcement agencies
Protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liabilities

HOW CAN YOU OPT OUT OR STOP DISCLOSURES ABOUT YOU

At this time, we do not intend to disclose the personal information of customers other than as noted above. If in the future, ECFH is required to disclose the personal information of customers other than the above, ECFH will provide an additional notice, and provide an opportunity to affected customers to opt out if applicable. The “opt out” option does not apply to disclosures that are legally permitted or required or to disclosures that ECFH makes to companies that perform services on our behalf or to other financial institutions.

ACCESSIBILITY OF YOUR PERSONAL INFORMATION

We will give you access to the information we have about you. It is your right.

Most of this information is in the form of your transaction records. These are available to you through your account statements or passbook updates, by visiting the branch or office where your account is held, or by accessing your account through our Complete Online Banking, Telebank (telephone banking) and automated banking machines.

If you require other information, simply contact or forward a written request to the branch or office where your account is held. We will ask you for specific details such as branch and account number. We will advise you in advance if a minimal charge will be required for conducting the search, and we will respond to your request within 5 - 10 working days.

Please note that we may not be able to provide information about you from those parts of our records which may contain references to other persons, are subject to legal privilege, contain confidential information proprietary to ECFH Group, relate to an investigation of a breach of agreement or contravention of laws, or cannot be disclosed for other legal reasons.

If you have any questions regarding decisions made about you, we will tell you the reasons for those decisions. Where relevant, we will provide you with the name and address of the third party from which a report was obtained.

ACCURACY OF YOUR PERSONAL INFORMATION

We strive to keep our customer files complete and accurate. Most of the information we collect about you is from applications that you submit to us to obtain our products or services and is reflected in account statements and other documentation you receive from us.

We encourage you to review this information and notify us if you believe any information should be corrected or updated. If you have questions or concerns about your personal information, please contact your customer service representative or the Risk Management Department to discuss concerns about this privacy policy.

Please note, UNDER NO CIRCUMSTANCE will ECFH or any of its subsidiaries request personal or account-related information from customers by email. Should you receive such an email message requesting personal or account-related information, you are advised to delete it immediately and notify the Risk Management Department or your customer service representative.

If you require any further information feel free to contact us.

Privacy Issue Update

We commit to provide periodic notices and updates on online privacy issues. We believe that the importance of protecting customer personal information from unauthorized use requires constant review of privacy issues and constant communication between the ECFH Group and our customers.

GOVERNANCE OF EAST CARIBBEAN FINANCIAL HOLDING COMPANY LIMITED

The Board of Directors of the East Caribbean Financial Holding Company Limited is responsible for the governance of the Group, and is committed to adhering to the highest standards of Corporate Governance, guided by a formal Corporate Governance Policy.

The Board is composed of appointed and elected directors who govern the affairs of the Group. It reviews the Group’s strategies, financial objectives and operating plans and plans for management succession. The Board meets every month and special meetings may be held when the need arises.

The Board provides leadership of the Group within a framework of sound governance practices, prudent and effective controls that facilitates risk assessment and management. It sets the Group’s strategic goals and objectives. The Board sets the company’s values and ensures that its obligations to its shareholders and other stakeholders are understood and met.

All Directors must take decisions objectively in the interest of the company.

There are clear delineation of responsibilities between the running of the Board and the executive responsibility for the running of the Group. No one individual has unrestricted powers of decision making. The roles of Chairman and Group Managing Director cannot be exercised by the same individual.

To facilitate accountability and transparency, no one individual or group of individuals dominates the decision making process.

The Board comprises eleven members, ten of which are elected or appointed by the holders of ordinary shares and one - the Group Managing Director, is an Executive Director. Collectively, the members of the Board must demonstrate a balance of skills and experience appropriate for the requirements of the business.

Criteria for membership on the Board include a candidate’s knowledge, skills, expertise, diversity of experience and that they should be a fit and proper person.

Subsidiary Boards

The ECFH Board must be aware of all material risks and other issues that may ultimately affect the Group. As some of these risks may originate in subsidiaries, it is necessary that the parent Board be able to exercise adequate oversight over the activities of the subsidiaries.

• Except for the Group Chairman and Group Managing Director, no Director holds more than three directorships in the Group.

• Except in exceptional circumstances, the chairmanship of subsidiaries will be held by a member of the ECFH Board.

• Non-executive Directors always constitute a majority of the Boards of subsidiaries and no subsidiary takes a decision where the majority in a quorum is of executive Directors.

• The Board ensures that adequate risk management procedures are in place to identify, assess and monitor risk activities and to provide the desired balance between risk acceptance and returns. The Risk Management Function of the Board is delegated to the Asset Liability Management Committee, which is chaired by the Group Managing Director. The committee meets quarterly and reports to the Board quarterly.

Committees of the Board

In an effort to effectively allocate tasks and responsibilities at the Board level, The Board has established committees with clearly defined objectives, authorities, responsibilities and tenure. These committees serve the Board of all subsidiary companies. The Board shall not delegate matters requiring special approvals to any of its committees.

These committees consist mainly of five independent Directors with at least one representative from each subsidiary. The committees meet at least three times a year or when the need may arise. The Committees are as follows:

Audit Committee

This committee is responsible for providing oversight of the company’s operations, in particular:
• The quality and integrity of the financial statements of the Group
• The effectiveness of the systems of internal control over financial reporting
• The internal and external audit processes, the Group’s processes for monitoring compliance with applicable laws and regulations, risk management processes and the code of conduct. The committee held meetings three times for the year.

The Committee comprises the following members:

o Victor Eudoxie – Chairman
o Emma Hippolyte
o Agosta Degazon
o Henry Mangal
o Vern Gill

During the year, the Group became a member of the newly formed Caribbean Association of Audit Committee Members Inc. (CAACM) whose objective is to improve the investment environment in the Caribbean by increasing the level of confidence of investors in the integrity of financial reporting and investor information.

Director Vern Gill, member of the Audit Committee, was elected to the Board of the Association.

Credit Committee

This committee considers and approves credit proposals in excess of management’s limit and meets on a needs basis. Three meetings of the committee were held during the year. The committee comprises the following members:

o Victor Eudoxie
o Emma Hippolyte
o Hildreth Alexander
o Henry Mangal
o Vern Gill
o Robert Norstrom
o Agosta Degazon

Human Resources Committee

This Committee is responsible for approving staff compensation, staff policies, appointment of Senior Management and Management succession planning. One meeting of the Committee was held during the year. The committee comprises the following members:

o Victor Eudoxie
o Hildreth Alexander
o Vern Gill
o Robert Norstrom
o Henry Mangal

Contact us

For questions regarding privacy issues, please send us an email at riskmanagement@ecfh.com or call your customer service representative or the Risk Management Department.

Department Contact Information

Switchboard 758-456-6000

Risk Management Department 758-457-7225
758-456-6814
riskmanagement@ecfh.com

Customer Service Departments

BOSL - Bridge Street Branch 758-456-6198     758-456-6123
758-456-6113     758-456-6110

BOSL – Gros Islet 758-456-6026     758-456-6004
758-456-6011

BOSL – Waterfront, Castries 758-456-6304     758-456-6307
758-456-6314     758-456-6313
758-456-6317

BOSL – Soufriere 758-456-6611     758-456-6614

BOSL – Vieux Fort 758-456-6405     758-456-6406

Bank of Saint Lucia Int’l Ltd. 758-452-0444

EC Global Insurance Co Ltd 758-456-6245

Property Holding & Development Co Ltd. 758-457-7129

Last updated: May 11, 2007