Is any of the directors or beneficial owners a politically exposed person?

PEP status is a fact, not an assessment

This is not a question where "probably not" is a good answer. The customer wants to know whether a director, shareholder or other stakeholder holds or has held a politically prominent position — or is a close family member or close associate of such a person. That is a verifiable fact per person, just as with the ultimate beneficial owners of the company: you can verify it per name, not as a general assessment for the company as a whole.

In practice, this recurs with the same persons who are also mentioned in the UBO question and in the sanctions list check : directors, supervisory board members and the natural persons behind the shares. Our system only fills in this field if there is an explicit PEP declaration per person in the chain file, with date. If that declaration is missing, or if it is older than the customer reasonably considers acceptable, the system does not propose a "no" — a PEP status can change without the company immediately realizing it, so an old declaration is not current.

Basis: client due diligence regarding politically prominent persons

This question does not come from a sustainability or cyber framework, but from the client due diligence that banks and other AML institutions are required to conduct on their customers, under the Anti-Money Laundering and Counter-Terrorist Financing Act. That law requires institutions to establish whether a client, or a UBO of the client, is a politically prominent person, and to conduct enhanced due diligence in the event of a positive outcome. This is why this field is often requested together with the UBO structure: the institution asking the question must be able to answer the question per natural person, not per company.