Pan Index Limited

PO BOX 559 T +353 1 224 4000 Dame Street F +353 1 671 6561 Dublin 2 Settlement Agreement between the Central Bank of Ireland and Pan Index Limited The Central Bank of Ireland (“the Central Bank”) has entered into a Settlement Agreement with effect from 25 August 2011 with Pan Index Limited (“the Firm”), a regulated financial services provider, in relation to breaches of Regulations 76 and 94 of the European Communities (Markets in Financial Instruments) Regulations 2007 (“MiFID”). Two breaches were identified. These breaches were:  Failure to ask clients or potential clients to provide the information regarding their knowledge and experience of spread trading as required by Regulation 76(4)(a) and as specified by 94(9) of MiFID; and  Failure by the Firm to take into account the information required pursuant to Regulation 76(4)(a) in order to assess whether the spread trading services sought by the client were appropriate for that client. The Central Bank reprimanded the Firm and required it to pay a monetary penalty of €40,000. These breaches were detected by the Central Bank during the course of a themed inspection of contracts for difference (“CFD”) and financial spread betting firms in March 2011. The Central Bank published the findings of the themed inspection of the CFD and financial spread betting firms on 16 June 2011, stating that “consumers need to be made fully aware of the complexity and very high risks of CFD and financial spread betting before making investment decisions”.