August 22, 2018

August 22, 2018 Sandra Bess Compliance Officer Economic Development Authority 8000 Nisky Shopping Center, Suite 620 St. Thomas, VI 00802 Re: Compliance Review Ms. Bess: This is in response to your letter of August 20, 2018 requesting information from Southern Trust Company, Inc.'s (STC) compliance with its certificate of tax incentives. You specifically requested the following: 1. 2013 - 2016 Fixed Asset Schedule — see attached 2. Name of employee(s) participating or who participated in the management training program: • Daphne Wallace 3. Name of employee(s) who received tuition reimbursement, employee training, and professional training: • Jeanne Brennan • Cecile de Jongh • Lucas Pascal • Una Pascal • Ann Rodriguez • Daphne Wallace • Sophia Mwaura 4. Name of employee(s) given time off to participate in and represent the Virgin Islands at athletic and sporting events: • No employee of STC requested or required such time off. I hope that this information meets with your satisfaction and, if you should have any questions, please do not hesitate to contact me at 340-775-2525. Sincerely, Cecile R. de Jongh Manager EFTA00809216