These Legal Notices detail the important information about how Yiasemis LLC provides services to our clients worldwide.

Please refer to the Definitions and Interpretation section for the meaning of capitalised terms and other expressions used in these Legal Notices.

Regulatory Regime and Requirements

Ioannis Yiasemis LLC is a limited liability company regulated by the Cyprus Bar Association. All partners and associates are in possession of practising certificates issued by the Cyprus Bar Association in accordance with the Advocates Law, Cap. 2 (as amended).

Data Protection

Yiasemis LLC complies with all obligations regarding the processing of personal data in Cyprus, as determined in accordance with DP Law.

Please refer to our Privacy Notice for information about what we do with personal data relating to you.

If you have any questions in this regard, or if you wish to exercise any of your rights as a data subject, please contact us at info@yiasemis.law.

Where, as part of any matter for you, we process personal data about any third party (including your employees, your customers and any other third parties involved in your matter), you agree that you shall be responsible for ensuring that each data subject to whom such personal data relates:

• receives a Processing Notice, where required in order for us to act for you on the relevant matter; and

• has provided their consent to our processing of their personal data, where such consent is necessary in order for us to lawfully process their personal data as part of acting for you.

Information Sharing and Use of Your Information

You agree that any information we obtain as a result of acting for you (which may include your confidential information and personal data) may be shared across the Group and with our suppliers to assist us in providing the services requested by you and complying with the Law.

All entities and individuals within the Group may use this information, or disclose it to third parties (and to the extent this information is privileged, you agree to waive that privilege on a limited basis with respect to these parties), for general business purposes, including any one or more of the following:

• for conflict checking;

• for the provision of our services to you;

• for disclosure to other third party advisers working for you on the same matter;

• for disclosure to third parties to whom we outsource relevant support services and where such disclosure may involve transfer, processing and storage of the information using third party software and hosting on third party platforms;

• for fraud prevention, anti-money laundering purposes, anti-bribery purposes and/or generally for the prevention or detection of crime;

• to comply with mandatory reporting obligations;

• to ensure the safety and security of our people and premises (where we may use CCTV);

• for disclosures to our auditors, our own legal and other professional advisors, our banks and insurers and insurance brokers;

• to administer your account with us, including tracing and collecting any debts;

• conducting specific tests on or developments to our existing or new systems, networks, applications and software and for the general improvement of our services;

• provided that you do not object to us so doing, for advertising, marketing and public relations, including sending you direct marketing communications;

• to manage our business performance, to assess client satisfaction (such as by asking you to participate in surveys) and generally to help improve our services;

• as otherwise required by Law;

• where you have given written consent to such use or disclosure.

Marketing, Seminars and Training Materials

We may use the contact details that you provide to us - including names, telephone numbers, addresses and email addresses - for sending out marketing communications including invitations to events, such as seminars or conferences, or briefings or similar publications which we think might be of interest to you.

If you do not wish to receive such communications, please let us know in writing by sending an email to info@yiasemis.law.

Anti-Money Laundering

In order to comply with the Law, Yiasemis LLC is obliged to undertake detailed client due diligence (CDD) and ongoing monitoring for both new and existing clients. Before accepting instructions, we are required to carry out due diligence to verify the identity of:

• all prospective clients; and

• all connected parties, such as the beneficial owners of a client;

and we are required to re-verify all checks periodically thereafter.

We may terminate the provision of any services to a client, or be instructed to do so by the relevant authorities, if such client fails to provide evidence of identity or if we suspect that the client or any other party connected with such client or with the matter is involved in any activities proscribed by relevant Law.

In providing CDD data to Yiasemis LLC, the client consents (and has obtained the consent of any individual whose personal data they provide) to such data being retained after our relationship with the client has ended. The period of retention we consider necessary takes into account our regulatory requirements and limitation periods for potential legal proceedings.

Communication and Information Security

We will communicate with you and, as appropriate, third parties using any normal means such as letters, e-mail, text, instant messaging, telephone, voicemail and video conferencing or using USB devices. If there is any mode of communication which you do not wish us to use, please notify the partner responsible for the matter in writing.

If you regard any communications from or to us as particularly confidential, or require particular security arrangements with regard to a matter or have alternative communication requirements please notify the partner responsible for the matter in writing.

Our anti-virus and anti-spam filters and other security arrangements may reject or filter legitimate emails. Please ensure that any important email you send is followed up by a telephone call if it has not otherwise been acknowledged.

The Group cannot guarantee the availability or security of its electronic information, storage and communications systems.

The Services We Provide

Our services are provided to and for the benefit of our client only. No other person may use or rely upon the services undertaken for you nor derive any rights or benefits from such services unless expressly agreed otherwise.

If there is any change in the Law after the date on which any services are provided, we have no responsibility to notify you of the change or the consequences of such change, unless expressly agreed otherwise.

We alone are responsible for the provision of the services. No Group Individual assumes any personal responsibility to you and accordingly, no Group Individual shall owe you any personal duty of care. Accordingly, when instructing us, you agree that (a) you will not bring any claim whether in contract, tort, under statute or otherwise against any Group Individual or any other member of Yiasemis LLC, and (b) Group Individuals and other members of Yiasemis LLC shall be entitled to rely upon this provision, save to the extent such agreement is prohibited by applicable Law.

Applying Agreed Liability Limits

Where we have agreed a monetary cap on our liability, the amount of such cap shall be the greater of (a) such amount agreed with you in writing and (b) the minimum amount permitted under applicable Law.

Where we have not agreed a monetary cap on our liability, our maximum liability shall be limited to €170,860, being the current minimum sum for which we are required to carry professional indemnity insurance for claims of negligence, in accordance with section 6E of the Advocates Law, Cap. 2 (as amended) and the relevant Directives of the Cyprus Bar Association. This amount is our maximum exposure to you all where there is more than one of you.

The relevant limit on our liability, shall be applied (a) to each matter upon which we act for you; (b) to Losses arising in any circumstances whatsoever, whether in contract, tort, under statute or otherwise, and howsoever caused (including our negligence or non-performance); and (c) as an aggregate cap on the liability of the Group.

Professional Indemnity Insurance

Yiasemis LLC maintains professional indemnity insurance which:

• covers our practice;

• extends to acts and omissions of Group Individuals; and

• meets the minimum insurance requirements of all professional regulations to which our practice is subject.

Handling of Client Monies: Cybercrime

Please be aware there is a significant risk posed by cybercrime fraud, specifically affecting email accounts and bank account details. Please be advised that you will not be notified of changes to Yiasemis LLC bank account details via email.

If you receive an email from someone purporting to be from the Group advising you of a change of bank account details, particularly during the course of a transaction:

• do not reply to the email;

• do not act on any information contained in the email; and

• immediately contact the person dealing with your matter.

If you are in any doubt, at any time, please do not send money to Yiasemis LLC electronically without speaking to the person dealing with your matter first to verify the account details. The Group does not accept liability in respect of a money transfer to a bank account which is not an Yiasemis LLC bank account.

Handling of Client Monies: Interest Policy

In the ordinary course when we act for you we will hold any money of yours in our general client account on your behalf.

When we pay out funds or on completion of the matter we will apply interest, in accordance with our current interest rate policy (interest rates are available on request and may be positive, negative or zero), to the money we have been holding for you.

We will pay interest to you, except when:

• in accordance with your instructions and/or applicable Law, we are not to apply any interest to any monies we hold for you;

• in accordance with your instructions or any agreement you have entered into or undertaking we have given on your instructions, the interest has been paid to a third party;

• the interest is less than £100.00; or

• the interest rate applied is zero or below zero.

Where you know or reasonably expect that we will hold a high value sum for you and/or that we will hold a sum for a considerable amount of time, you can request us to place the money in a designated account. In that event we would account to you for the full amount of any interest received in respect of such amount from the bank.

Where a negative interest rate or any other charges are applied to the money that we hold for you in a Yiasemis LLC account, we shall have the right to deduct such sums from the money that we hold on your behalf and you are responsible for any resulting shortfall in the money which we then transfer to the ultimate recipient (subject to our doing so in accordance with your instructions and applicable Law).

Financial Institutions and Systems

If you wish to know the name of the deposit-taking institution(s) where your client money is being held, please ask the partner responsible for any matter.

No entity or individual within the Group shall incur any liability caused by the act, omission, fraud, delay, negligence, insolvency, collapse or default of a deposit-taking institution or a financial clearing or payment system (save to the extent of any negligence on our part).

Charging Structure: Fees

In accordance with normal professional practice, our fees are based upon the time occupied on the work and the degree of skill and responsibility involved. The Matter Specification details the hourly charge-out rates of the personnel who may be involved in your matter and those rates reflect the legal expertise of those personnel.

Our services may be provided on a fixed fee basis or we may provide you with a fee estimate, both of which are assessed on a time and expertise basis. In general, the time and expertise required will depend on the complexity of the matter. For example: more complicated instructions and/or larger transactions which require a larger team of personnel; drafting and negotiation of complex documentation; examination of large quantities of data; novel issues which require research; are all likely to incur higher costs.

Where it has not been reasonably practicable to provide you with a fixed fee, fees accrue according to the time spent by individuals on your matter and calculated by applying their hourly rate. Fees accrue in this way for services where we have provided an estimated fee and for services we provide which fall outside the scope of work detailed in the Matter Specification or outside any element of the scope of work for which a fixed fee has been agreed.

Where we have provided you with an estimated fee, such fee estimate is given in good faith but is only a guide and is not an agreement to provide the services for a fixed fee. Our professional fees and costs for undertaking the matter may be more or less than our indicative estimate. It is often difficult to estimate how much time will be required to complete a matter and we will revise our fee estimate as necessary as the matter progresses and inform you accordingly.

Our fees are always detailed exclusive of VAT or any other applicable tax.

Charging Structure: Disbursements and Expenses

Fees for our legal services do not include third party disbursements we incur on your behalf or other expenses properly and reasonably incurred by us in relation to your matter, which will be charged in addition to our fees.

Professional services provided by third parties may include specialist advocate fees (consultant fees), overseas legal advice, expert fees, valuation fees and translation costs. If such services are required, we will agree this with you and the costs for such services, in advance. We shall engage any such third party as agent on your behalf and you shall remain responsible for their fees.

We shall inform you of the fixed or estimated costs of such third parties and shall not engage such third parties on your behalf without your prior approval.

Expenses (including for example, without limitation, courier services; specialist postal services; travel tickets) and disbursements will be invoiced to you at cost.

When we provide services ancillary to your matter the costs for these may include an element of profit and a full tariff for such internally provided services is available on request. Internally provided services include, without limitation, telegraphic transfers; catering; print room services; secretarial overtime.

We may levy a charge for retrieving and/or copying data, including documents, from storage at your request.

Where appropriate, VAT or any other applicable tax, will be applied on invoicing to the disbursements and/or expenses we have incurred related to the matter.

Increases to Charges

Where we become aware of anything which would make the costs significantly greater than indicated in the Matter Specification including where we have only been able to provide costs for part of the matter, or where the scope of the matter changes or any of the assumptions detailed is or becomes incorrect, we shall undertake a review of the costs.

We shall inform you when we become aware that such a review will be necessary and shall issue you with an updated Matter Specification.

Payment on Account

From time to time we may require an advance payment on account to be applied against anticipated fees and disbursements before we can start work, and we may at any time (particularly in litigation or contentious matters and before any hearing or trial) require further sums to be paid on account.

Where a payment on account of anticipated fees or disbursements is requested, we will be unable to commence or continue to provide services to you until such payment is received.

Any payment on account of anticipated fees and disbursements will be credited against the final invoice for the matter. Funds held on account will not be credited against interim invoices which remain payable in full on receipt by you.

Outstanding Payments

Where we hold funds received from you or received on your behalf in our client account and an invoice is outstanding for more than 3 months, and we have made reasonable attempts to contact you in the interim but have not received instructions, we may, and you hereby confirm that is in order for us to apply any such funds against the outstanding invoice.

Group Team

The Matter Specification details the supervising Matter Partner with overall responsibility for the matter.

You will be notified of the names and contact details for any other key Group Individual expected to work on your matter as and when relevant.

It may be necessary to include other personnel as the matter progresses or to temporarily or permanently replace personnel with one or more individuals of equivalent skill and comparable charge out rates in the event of illness, vacation or some other unavoidable reason. Any need for additional or replacement key personnel will be communicated to you.

Definitions and Interpretation

In these Legal Notices, the following expressions shall have the following meanings:

DP Law means all applicable Law relating to data protection, the processing of personal data and privacy in force in Cyprus and the European Union from time to time, including (a) The Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data Law of 2018 (Law 125(I)/2018); (b) The EU General Data Protection Regulation (Regulation (EU) 2016/679) (EU GDPR); and (c) the e-Privacy Directive (2002/58/EC) as transposed into Cyprus law. The terms processing, controller, processor, personal data, personal data breach, data subject and supervisory authority shall have the meanings given to them in applicable DP Law

Group means Ioannis Yiasemis LLC, Group Entities and Group Individuals

Group Entity means any entity owned or controlled by Ioannis Yiasemis LLC or any of its shareholders (other than Ioannis Yiasemis LLC), or owned or controlled by any other Group Entity or any of such Group Entity's shareholders, and Group Entities shall be construed accordingly

Group Individual means any shareholder, partner, director, officer or employee of, or any consultant or other advisor to, Ioannis Yiasemis LLC or any Group Entity such as Cyprus or English qualified lawyers, trainee lawyers, paralegals, lawyers qualified in other jurisdictions and support staff and Group Individuals shall be construed accordingly

Ioannis Yiasemis LLC means Ioannis Yiasemis LLC a limited liability company incorporated in Cyprus with registration number ΗΕ 486278, authorised and regulated by the Cyprus Bar Association and whose registered office is at Ellados 30, 7060, Larnaca, Cyprus and any successor practice

Law means Cyprus law and includes all applicable: (a) common law; (b) case law; (c) legislation, enactment, statute, statutory instrument, regulation, by-law; ordinance or subordinate legislation; (d) statutory, industry or other professional regulations, rules, codes, guidance, regulations, practice directions, instruments and provisions

Losses means all losses, liabilities, fines, damages, costs and expenses including legal fees on a solicitor/client basis and disbursements and costs of investigation, litigation, settlement, judgment, interest and penalties

Matter Specification means the matter-specific costs and services information we have set out in our engagement documents confirming your instructions on a matter

Processing Notice means information required to be provided to a data subject where personal data has been collected from or obtained in respect of such data subject, as set out in Article 13 and Article 14 of the EU GDPR or any similar requirement under DP Law

shareholder means someone who is a shareholder of Ioannis Yiasemis LLC or a shareholder of any Group Entity or an employee or consultant with equivalent standing based on their experience and/or qualifications. A list of our members' names may be inspected at our registered offices

we, us, and our, means Ioannis Yiasemis LLC or such other Group Entity with which the client has entered into a contract to provide services

Yiasemis LLC means Ioannis Yiasemis LLC together with each Group Entity

you means the client, being the person or persons identified by us as having provided our instructions and to whom we are providing the services and your shall be construed accordingly

use of the words other, includes, including, for example and in particular and similar words or phrases, do not limit the generality of any preceding words and any words which follow them shall not be construed as being limited in scope to the same class as preceding words where a wider construction is possible

references to us carrying out work for or providing advice to our clients, include all aspects of our services, for example drafting documents, negotiating on our client's behalf and advising on the Law

any reference to liability means that, notwithstanding any provision in these Legal Notices which details the extent to which the liability of entities and individuals within the Group is limited or excluded, nothing in these Legal Notices shall limit or exclude the liability of any entity or individual within the Group for death or personal injury arising out of negligence, fraudulent misrepresentation or any other matter which cannot be limited or excluded by Law

use of the words expressly agreed means we have given prior consent in writing