Compliance Solutions for Capital Markets MIFID Pal Ribarics

1. Compliance Solutions for Capital Markets MIFID Pal Ribarics Oracle, Financial Services Solution TeamEU Enlargement Countriespal.ribarics@oracle.comDubrovnik, 9 May 2007

2. Mantas Overview • Overview of Mantas/Reveleus/Oracle • MIFID • Mantas Trading Compliance Solution • Competitive Differentiation

3. Latest news • Oracle stake in i-flex goes up to 83% • Reveleus acquires Mantas • Citigroup signs Reveleus Operational Risk for an Enterprise-wide RCSA deployment • Reseller Agreement signed between Oracle & Reveleus for Reveleus Operational Risk • Reveleus Basel II solution is ranked in the Gartner leaders quadrant for 2006 as well, most competitors fall behind • Reveleus Operational Risk ranked among the top Operational Risk solutions globally by analysts • Reveleus ranked 4th in a Chartis Research Report covering the Top 100 Risk Management vendors worldwide.

4. i-flex Completes Acquisition of Mantas for $122M 03-Oct-06 i-flex solutions Completes Acquisition of Mantas Mantas Now a Wholly Owned Subsidiary of i-flex solutions; S.Ramakrishnan Appointed as CEOMumbai, October 3, 2006: i-flex® solutions (Reuters: IFLX.BO & IFLX.NS), a leading IT solutions provider to the global financial services industry, announced the closing of its previously announced acquisition of Mantas Inc., a provider of regulatory compliance, loss prevention and revenue generation solutions headquartered in Herndon, Virginia, USA.Under a definitive agreement announced on August 14th, Mantas was acquired in an all cash transaction of US $ 122.6 Million. With the completion of all regulatory approvals, Mantas is now a wholly owned subsidiary of i-flex solutions.S.Ramakrishnan, CEO of Reveleus-i-flex's Business Analytics division, will take additional charge as CEO of Mantas. SR has nearly 25 years of banking and technology experience spanning India, the Middle East, Singapore, New York and Silicon Valley, and has led Reveleus from a start-up to a leading product in the Risk and Compliance space.

5. Reveleus Enterprise Risk & Compliance Offerings EDW Risk & Compliance Infrastructure Reporting & Analysis Enterprise Risk & Compliance Applications Capital & Performance Management Internal Reporting & Analysis Credit Portfolio Optimization Economic Capital Basel II/ 1A Risk Based Pricing RAPM Risk & ComplianceRepository Enterprise Risk Analytics Loan Systems Aggregated & Relational Reporting Funds Transfer Pricing Interest Rate Risk Liquidity Risk Retail Credit Risk Corporate Credit Risk External Reporting Treasury Systems Risk & Compliance Business Metadata Operational Risk & Compliance Home/Host Reporting Collateral Systems General Ledger Economic Capital Process Mapping Action Planning Loss DB KRI Internal Controls RCSA Rule/Run Framework Capital Adequacy Reporting Information Vendors Anti - Money Laundering, Fraud & Surveillance Local Regulator Reporting OpRisk Data Modeling Framework Fraud & Anti Theft Transaction Monitoring Trading Compliance Broker Compliance KYC/CDD

6. Mantas OverviewIntroduction and Differentiators Only company demonstrably proven to provide integrated, single source compliance for all FS businesses anywhere in the world. Current surveillance statistics for Mantas Software: 125+ production deployments 211 jurisdictions - Trading Compliance 122 countries - AML 700 million transactions per day 16 languages The most coverage of any provider - nearly 300 different exposures/risk monitored 10 patents pending. Only compliance company in BTN Top 10, Waters “Best Compliance Firm” 2 years in a row. Only company providing surveillance for: Retails Banks Wholesale Banks Private Banking and Asset Management Institutional Brokerage Prop Trading Capital Markets Retail Brokerage Investment Banking Mutual Funds Insurance …. and hence offers a compliance TCO substantially lower than alternative compliance IT costs or piecemeal vendor selection. ROI counted in months if not weeks.

7. Market Leadership • A worldwide leader in enterprise AML, compliance, fraud, operational risk and business record assurance solutions for the most sophisticated financial institutions globally Representative Customers Industry Awards

8. Summary of MantasEvery Product, Every Business, Every Country, Every Size – Our Track Record is Impeccable 150,000.000 Trades a day analyzed. 10 million trades a day in London, Singapore and New York covering 150 exchanges. 300,000 accounts in Chicago area 50,000 High Net Worth Accounts in NE United States 200 million accounts in 61 countries. 2 million accounts in Switzerland. Mantas is worldwide leader in AML, compliance, fraud, operational risk and business record assurance solutions to the most sophisticated Financial institutions globally. Examples: Volumes/Size

9. Mantas Behavior Detection Platform SERVICES/TOOLS Real-Time Filtering · Case Management · Dashboard · Alert Management LOSS PREVENTION Fraud Management Operational Risk Management Identity Theft Basel II Capital Adequacy Self Assessment Consumer Credit Regulation Anti-Money Laundering Trading Compliance Broker Compliance USA Patriot Act EU MiFID EU Market Abuse Directive Terrorism Act 2000 REGULATORY COMPLIANCE REVENUE CAPTURE Client Assurance Margin Management Cross-Selling Customer Churn Contact Management BEHAVIOR DETECTION PLATFORM Multiple Detection Engines · Financial Services Data Model · Data Ingestion Specification Single Sign-On · Analysis & UI Toolkits · Web Services· Globalization DATA INTEGRATION SYSTEM INTEGRATION PARTNERS • Unmatched product coverage across widest set of possible transactions and events • 250+ different exposures / risks / opportunities monitored • Unparalleled accuracy of powerful behavior detection engines • Tremendous intellectual property and domain knowledge (10 patents pending) • Outstanding add-on tools that enhance the applicability of the Mantas products • Positions Mantas as a key integration component for workflow systems “Outstanding Coverage” – Trading Compliance User Group Meeting, December 2005 (ABN AMRO, Bear Stearns, Barclays Capital, Credit Suisse, Goldman Sachs, SSB)

10. Mantas Behavior Detection Platform Architecture. Packaged, Proven & Powerful... Document Management Active Pages • Fully integrated investigative workflow that connects to any other sources • Transparency and compliance to all activities within each investigation • Direct interface to other systems including law enforcement • Ad hoc real-time reports can be created in a matter of hours • Flexible and ad hoc visualization without encroaching on the discipline and rigor needed to manage compliance and risk • Very powerful graphical interface Case Management Alert Management Data Model & Behavior Detection Data Ingestion Data Ingestion Data Model Behavior Detection Alert Management Life cycle • Provides data consistency and transparency across the enterprise • Enables seamless, cost-effective expansion and customization • Required step in implementation of Mantas’ solution • Enables the world’s most accurate and sophisticated behavior detection analytics • Leveraged by Mantas customers, as part of their Six Sigma programs, operational dashboards and reconciliation processes • 10 patents pending • The most powerful set of approaches to solve each specific business situation being addressed • Flexible definition of behavior of interest that caters to each institution for any type of transactions • Highly flexible alert management allowing certain alerts to go to specific individuals and be scored in the most effective manner • Enables users to view alerts with full documentation and reporting requirements Tasks / Phases

11. Financial Services Data Model (FSDM) - Subject Areas CUSTOMER MARKET ENTERPRISE SECURITY ACCOUNT TRANSACTION TRADE

12. Trades in FSDM All Supported Asset Classes Demand for financial instrument to be bought or sold Means by which order is satisfied Combined demand and means by which Financial instrument is bought or sold 0 Order Summary Trade Summary 1 1 M 1 M M 1 1 1 0 M Execution Summary M 1 Order Events New Cancel Route Cancel & Replace Modify Desk M Trade Execution Events New Cancel Correction Cancel & Replace Order Interface Trade Execution Interface

13. At The Heart - Detection Engines Text Mining Text Mining Rule Patterns Sequence Matcher Sequence Matcher Link Analysis Link Analysis Link Analysis • Mantas uses a tested and proven combination of 5 behavior detection engines (most competitors use one , 2 at maximum) to apply the right technique to identify complexity and accumulate evidence. • Mantas currently has 14 patents pending around these activities and algorithms. Profiling Profiling

14. Increasing Detection Accuracy Profiling Profiling Text Mining Text Mining Outlier Detection Outlier Detection Rule Patterns Rule Patterns Rule Patterns Sequence Matcher Sequence Matcher Link Analysis Link Analysis Link Analysis BEHAVIORS FOCUSING ACCURACY Tune thresholds as necessary Suppression of non-exposures DAY-TO-DAY OPERATION Score against risk IMPLEMENTATIONSTAGES Settransactionthresholds Tune patterns to the data

15. Scenario Threshold Editor Increasing Accuracy Tune thresholds as necessary Suppression of non-exposures DAY-TO-DAY OPERATION Score against risk IMPLEMENTATIONSTAGES Tune scenarios to the data by setting initial limit thresholds Tune scenarios to the deployment by setting initial filter thresholds

16. The Goal…an alert

17. Integrated Alert Management and WorkflowIdentification of risk, complete end to end investigation

18. Transaction & Alert Repository

19. Mantas Overview • Overview of Mantas • MIFID • Mantas Trading Compliance Solution • Competitive Differentiation

20. Introduction to MiFID What is it? • Introduces a consolidated regulatory framework for European markets in financial instruments in order to deliver i) Retail Investor Protection ii) Investment Services ‘passport’ to market transparency • Part of the EU Financial Services Action Plan (FSAP) • One of the Lisbon 2000 Strategy reforms to create a single market for wholesale financial services • Supercedes the EU Investment Services Directive (ISD) • Enforced regulation in 28 EU countries • Implementation by November 2007

21. Introduction to MiFIDProvisions • Post-trade Transparency • Whether on regulated markets, MTFs or OTC, trading in shares are subject to a post-trade transparency obligation • Passporting Rights • Improves operation of single passport for investment activity • Firms able to establish branches in other member states and offer cross-border services • Host country responsible for ensuring compliance with conduct of business requirements • Pre-trade Transparency • Establishes minimum standards of pre-trade transparency for shares traded on regulated markets and MTFs • Obliges systematic internaliser to undertake public market-making obligation - must provide definite bid and offer quotes in liquid shares for orders below 'standard market size' MiFID • Client Management • Extensive and requires significant changes to the FSA's Handbook • Most sensitive is requirement for firms to conduct full suitability test on clients when providing investment advice or portfolio management • Order Handling & Execution • Firms must ensure best possible deal for clients taking into consideration price, cost, speed and likelihood of execution and settlement

22. Markets in Financial Instruments Directive (MiFID) • The Market in Financial Instruments Directive (MiFID) - Executive Summary • The Market in Financial Instruments Directive (MiFID) shares many commonalities with the Market Abuse Directive, enacted late last year. Both directives are aimed at the creation of a common financial services market throughout Europe. In most cases, the 42-step process derived by the European Union towards this goal has focused on a “harmonization” of existing regulations between member states. MiFID is a departure from this approach and instead introduces regulations more akin to best execution and advice regulations currently in force in the United States of America. MiFID, like any new regulation, presents financial institutions with a variety of choices: • They can take no action, and hope that current systems will satisfy the new regulatory requirement. • They can address each new directive and regulation independently. • They can adopt a comprehensive and holistic approach towards compliance that protects the firm • MiFID can be summarized into eight categories:

23. Markets in Financial Instruments Directive (MiFID) • The Market in Financial Instruments Directive – What is it? MiFID, is aimed at the creation of a common financial services market throughout Europe. Implementation Date: November 1, 2007 • Level 1 – Directive, adopted April 2004 • Level 2 – Technical implementing measures, Released February 2006

24. MiFID – Challenges Facing the Industry

25. Mantas Overview • Overview of Mantas • MIFID • Mantas Trading Compliance Solution • Competitive Differentiation

26. Mantas Trading Compliance in the Market (MiFID) • What is the solution ? • Mantas Trading Compliance Solution • What does the Mantas Trading Compliance Solution consist of? • 1. Scenarios & Analytics (E.g: Best Execution) • 2. Applications (E.g: Control Room) • 3. Platform (E.g: Ingest, Detection Engines, Data Model & User Interface) • Mantas Trading Compliance Overview: • Mantas Platform supports the automated review of processes, policies & controls (Governance) while providing solutions for risk assessment, case investigation & management (Risk) • Existing Mantas technology lends itself to key aspects of the directive, including best execution, trade transparency, conflicts of interest and best advice/customer suitability (Compliance) • Best Execution Class – Evaluates the quality of individual order execution • Proven & Deployed - Scenarios in this class examine prices and timing of orders and executions by comparing them to market conditions, and they generate alerts when customers did not get the best execution of their orders. Examples include: • Price Improvement Scenario • Price Disimprovement Scenario • Market Order Execution Untimeliness Scenario • Limit Order Execution Untimeliness Scenario • Unfilled Marketable Orders Scenario • Limit Order Display Scenario • Limit Order Protection Scenario

27. Mantas Trading Compliance in the Market (MiFID) • Trading Compliance Class – Detects behaviors that violate regulatory and internal policies and procedures Examples include: • Indications that one or more parties arranged trading activity for their own benefit • Cross Trading Listed Options and Futures Within A Narrow Time Window Scenario • Parking to Conceal Fixed Income Position Scenario • Parking Via Settlement Date Scenario • Monitors trading activity to detect situations when traders exchanged, or acted on, advance information about their customers’ orders. • Trading Ahead of Customer Scenario • Front Running Large Orders Scenario • Front Running with Related Products Scenario

28. Mantas Trading Compliance in the Market (MiFID) • Control Room Package – Detects behaviors that potentially indicate conflicts of interest and insider dealing/trading Examples Include: • Monitoring of trading activity against restricted securities (research, underwriting and primary market, book building, loans, credit derivatives) • Employee Trade Approval and Monitoring • Watch List and Restricted List Maintenance • Customer Suitability – Identifiestrades and portfolios that may be inappropriate given a customer’s profile Examples include: • Customers with unsuitable trades • Customers whose portfolios don’t match investment objectives • Portfolio Visualization and Analysis

29. Mantas Trading Compliance in the Market (MiFID) Mantas Trading Compliance Solution – Most widely adopted Trading Compliance Solution on the Market 2005 2006 2002 2003 2004

30. Mantas Overview • Overview of Mantas • MIFID • Mantas Trading Compliance Solution • Competitive Differentiation

31. Functional Comparison: Mantas offers cross enterprise Compliance and Operational Risk Management. Mantas wins when client understand this cross enterprise exposure challenge.