Common use of Managing Conflicts of Interest Clause in Contracts

Managing Conflicts of Interest. The Company has established suitable and adequate internal procedures for minimising any potential conflicts of interest. The Company maintains a compliance department that is an independent unit within the Company. Among the duties of the CO is to monitor any possible deviation from the Company’s internal policies and procedures as well as identifying and managing any possible conflicts of interest. Once a conflict has been identified it needs to be appropriately and adequately managed. The Compliance function will assess each conflict and determine if the conflict is actual or perceived and what the value of the conflict or exposure is and the potential reputational risk. Compliance will then decide whether it is viable to go ahead with the transaction or if the conflict is too severe. If Compliance decides that the particular conflict can be mitigated, then controls to manage the conflict should be put in place and documented. The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its employees and between its customers and to organise and control their internal affairs responsibly and effectively. The Company and its employees should act as per the principle of placing clients’ interests before self-interests and Company’s interests in order to avoid conflicts of interest in the fulfilment of professional activities on the securities market. To ensure client’s fair treatment, the Company will introduce the following procedures: • The Company shall avoid any conflict of interest with clients and, where such a conflict unavoidably arises, ensure fair treatment to the client by complete disclosure or by declining to act. • Employees are also prohibited to keep investor accounts in other Brokers without Company’s prior authorization and are obliged to bring this to Company’s attention. They are also obliged to authorize the Company to directly request transaction reports from the other Brokers. • If the Company has a material interest in a transaction to be entered into with or for a client, or a relationship which gives rise to a conflict of interest in relation to the transaction, the licensee shall not knowingly either advise, or deal in the exercise of discretion, in relation to that transaction. The only exception is when the licensee has fairly disclosed that material interest or relationship, as the case may be, to the client or the client has taken reasonable steps to ensure that neither the material interest nor relationship adversely affect the interests of the client. • There is a clear distinction between the different departments’ operations as these are described in the Company’s IOM. • The Company shall be informed promptly of any personal transaction entered into by a relevant person, either by notification of that transaction or by other procedures enabling the Company to identify such transactions. In the case of outsourcing arrangements, the Company shall ensure that the Company to which the activity is outsourced maintains a record of personal transactions entered into by any relevant person and provides that information to the Company promptly on request. • A person shall be replaced by another person in his/her duties only prior consent of the CO and approval by the Representative Officer. Such a consent will be given by the CO after all issues of possible conflict of interest have been reviewed. • The security features of the Company’s software prevents unauthorized access to sensitive information in order to benefit the Company over its clients or one client over another. • The Company’s employees are prohibited from investing in securities for which they have access to non-public or confidential information. • Transactions by the Company’s employees are neither performed nor executed by themselves, but by another member of staff of the Company concerning account opened with the Company. • A record shall be kept of the personal transaction notified to the Company or identified by it, including any authorisation or prohibition in connection with such a transaction. • The Company must take reasonable steps to ensure that neither it nor any of its employees or agents either offers or gives, or solicits or accepts, any inducement that is likely to conflict with any duties owed to its clients. • No employee shall either knowingly or recklessly make a statement, promise or forecast that is misleading, false or deceptive to any customer or conceal material facts at any time. More specifically, the Company states some of the policies and procedures that it has implemented for managing possible conflicts of interest below: • Effective procedures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities. • The separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company. • Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of the conflicts of interest. • The removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities. • Measures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients. The procedures followed and measures adopted in the Policy include the following, as are necessary and appropriate for the Company to ensure the requisite degree of independence: • No relevant person may purchase or sell a security or cause the purchase or sale of a security for any account while in possession of inside information relating to that security. • No relevant person may recommend or solicit the purchase or sale of any security while in possession of inside information relating to that security. • No relevant person may purchase or sell or cause the purchase or sale of a security for an employee or employee-related account or a proprietary account of the Company or an account over which an employee exercises investment discretion, while in possession of proprietary information concerning a contemplated block transaction in the security or for a customer account when such customer has been provided such information by any relevant person. • Procedures set for regular review and monitoring of the execution arrangements with the execution venue, hedging/ liquidity or price providers as well as on a continuous basis. • Procedures in regards to the monitoring of access to electronic data. • Relevant persons engaged in research activities should not discuss unreleased information, opinions, recommendations, or research analysis in progress with Company associated persons engaged in sales activities, or any person within or outside the Company who does not have a valid business need to know the information. • Establishment of an ongoing monitoring program based on which regular checks are conducted for the assessment of the Company’s procedures, policies and internal controls. • The Company may distribute marketing communication to its clients, only if the said communication is reviewed and approved by the CO prior to distribution. The CO also ensures that such communication have the appropriate disclosure statement as well as meeting the relevant definition of marketing communication. • The four-eye principle is implemented to avoid any abuse of position. • In order to minimise the relevant person’s own transactions personal account dealing restrictions are in place. The Company is committed to having an effective and appropriate compliance culture to enable it to deal with any new potential conflicts of interest which may arise in the future. The Company’s employees are therefore required to monitor any new circumstances giving rise to potential conflicts of interest and to implement appropriate measures to address these. For the purpose of this Policy, a “personal transaction” is considered a trade in a financial instrument effected by or on behalf of a relevant person, where at least one of the following criteria are met: • the relevant person is acting outside the scope of the activities he carries out in his professional capacity; • the trade is carried out for the account of any of the following persons: o the relevant person; o any person with whom he has a family relationship, or with whom he has close links; o a person in respect of whom the relevant person has a direct or indirect material interest in the outcome of the trade, other than obtaining a fee or commission for the execution of the trade. The Company shall maintain separate accounting records between its own assets and those of its clients to facilitate the protection of clients’ assets and the prevention of the use of customer assets by the Company or by other third parties so as to minimise the risk of the loss or diminution of client assets, or of rights in connection with those assets, as a result of misuse of the assets, fraud, poor administration, inadequate record-keeping or negligence. In addition, the Company has legally secure segregation of clients’ assets from the Company’s assets in case the Company becomes bankrupt. For this purpose, the Company maintains separate books and accounting records for each client.

Managing Conflicts of Interest. The Company has established suitable and adequate internal procedures for minimising any potential conflicts of interest. The Company maintains a compliance department that is an independent unit within the Company. Among the duties of the CO is to monitor any possible deviation from the Company’s internal policies and procedures as well as identifying and managing any possible conflicts of interest. Once a conflict has been identified it needs to be appropriately and adequately managed. The Compliance function will assess each conflict and determine if the conflict is actual or perceived and what the value of the conflict or exposure is and the potential reputational risk. Compliance will then decide whether it is viable to go ahead with the transaction or if the conflict is too severe. If Compliance decides that the particular conflict can be mitigated, then controls to manage the conflict should be put in place and documented. The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its employees and between its customers and to organise and control their internal affairs responsibly and effectively. The Company and its employees should act as per the principle of placing clients’ interests before self-interests and Company’s interests in order to avoid conflicts of interest in the fulfilment of professional activities on the securities market. To ensure client’s fair treatment, the Company will introduce the following procedures: •  The Company shall avoid any conflict of interest with clients and, where such a conflict unavoidably arises, ensure fair treatment to the client by complete disclosure or by declining to act. •  Employees are also prohibited to keep investor accounts in other Brokers without Company’s prior authorization and are obliged to bring this to Company’s attention. They are also obliged to authorize the Company to directly request transaction reports from the other Brokers. •  If the Company has a material interest in a transaction to be entered into with or for a client, or a relationship which gives rise to a conflict of interest in relation to the transaction, the licensee shall not knowingly either advise, or deal in the exercise of discretion, in relation to that transaction. The only exception is when the licensee has fairly disclosed that material interest or relationship, as the case may be, to the client or the client has taken reasonable steps to ensure that neither the material interest nor relationship adversely affect the interests of the client. •  There is a clear distinction between the different departments’ operations as these are described in the Company’s IOM. •  The Company shall be informed promptly of any personal transaction entered into by a relevant person, either by notification of that transaction or by other procedures enabling the Company to identify such transactions. In the case of outsourcing arrangements, the Company shall ensure that the Company to which the activity is outsourced maintains a record of personal transactions entered into by any relevant person and provides that information to the Company promptly on request. •  A person shall be replaced by another person in his/her duties only prior consent of the CO and approval by the Representative Officer. Such a consent will be given by the CO after all issues of possible conflict of interest have been reviewed. •  The security features of the Company’s software prevents unauthorized access to sensitive information in order to benefit the Company over its clients or one client over another. •  The Company’s employees are prohibited from investing in securities for which they have access to non-public or confidential information. •  Transactions by the Company’s employees are neither performed nor executed by themselves, but by another member of staff of the Company concerning account opened with the Company. •  A record shall be kept of the personal transaction notified to the Company or identified by it, including any authorisation or prohibition in connection with such a transaction. •  The Company must take reasonable steps to ensure that neither it nor any of its employees or agents either offers or gives, or solicits or accepts, any inducement that is likely to conflict with any duties owed to its clients. •  No employee shall either knowingly or recklessly make a statement, promise or forecast that is misleading, false or deceptive to any customer or conceal material facts at any time. More specifically, the Company states some of the policies and procedures that it has implemented for managing possible conflicts of interest below: •  Effective procedures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities. •  The separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company. •  Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of the conflicts of interest. •  The removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities. •  Measures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients. The procedures followed and measures adopted in the Policy include the following, as are necessary and appropriate for the Company to ensure the requisite degree of independence: •  No relevant person may purchase or sell a security or cause the purchase or sale of a security for any account while in possession of inside information relating to that security. •  No relevant person may recommend or solicit the purchase or sale of any security while in possession of inside information relating to that security. •  No relevant person may purchase or sell or cause the purchase or sale of a security for an employee or employee-related account or a proprietary account of the Company or an account over which an employee exercises investment discretion, while in possession of proprietary information concerning a contemplated block transaction in the security or for a customer account when such customer has been provided such information by any relevant person. •  Procedures set for regular review and monitoring of the execution arrangements with the execution venue, hedging/ liquidity or price providers as well as on a continuous basis. •  Procedures in regards to the monitoring of access to electronic data. •  Relevant persons engaged in research activities should not discuss unreleased information, opinions, recommendations, or research analysis in progress with Company associated persons engaged in sales activities, or any person within or outside the Company who does not have a valid business need to know the information. •  Establishment of an ongoing monitoring program based on which regular checks are conducted for the assessment of the Company’s procedures, policies and internal controls. •  The Company may distribute marketing communication to its clients, only if the said communication is reviewed and approved by the CO prior to distribution. The CO also ensures that such communication have the appropriate disclosure statement as well as meeting the relevant definition of marketing communication. •  The four-eye principle is implemented to avoid any abuse of position. •  In order to minimise the relevant person’s own transactions personal account dealing restrictions are in place. The Company is committed to having an effective and appropriate compliance culture to enable it to deal with any new potential conflicts of interest which may arise in the future. The Company’s employees are therefore required to monitor any new circumstances giving rise to potential conflicts of interest and to implement appropriate measures to address these. For the purpose of this Policy, a “personal transaction” is considered a trade in a financial instrument effected by or on behalf of a relevant person, where at least one of the following criteria are met: •  the relevant person is acting outside the scope of the activities he carries out in his professional capacity; •  the trade is carried out for the account of any of the following persons: o the relevant person; o any person with whom he has a family relationship, or with whom he has close links; o a person in respect of whom the relevant person has a direct or indirect material interest in the outcome of the trade, other than obtaining a fee or commission for the execution of the trade. The Company shall maintain separate accounting records between its own assets and those of its clients to facilitate the protection of clients’ assets and the prevention of the use of customer assets by the Company or by other third parties so as to minimise the risk of the loss or diminution of client assets, or of rights in connection with those assets, as a result of misuse of the assets, fraud, poor administration, inadequate record-keeping or negligence. In addition, the Company has legally secure segregation of clients’ assets from the Company’s assets in case the Company becomes bankrupt. For this purpose, the Company maintains separate books and accounting records for each client.

Managing Conflicts of Interest. The Company has established suitable and adequate internal procedures for minimising any potential conflicts of interest. The Company maintains a compliance department that is an independent unit within the Company. Among the duties of the CO is to monitor any possible deviation from the Company’s internal policies and procedures as well as identifying and managing any possible conflicts of interest. Once a conflict has been identified it needs to be appropriately and adequately managed. The Compliance function will assess each conflict and determine if the conflict is actual or perceived and what the value of the conflict or exposure is and the potential reputational risk. Compliance will then decide whether it is viable to go ahead with the transaction or if the conflict is too severe. If Compliance decides that the particular conflict can be mitigated, then controls to manage the conflict should be put in place and documented. The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its employees and between its customers and to organise and control their internal affairs responsibly and effectively. The Company and its employees should act as per the principle of placing clients’ interests before self-interests and Company’s interests in order to avoid conflicts of interest in the fulfilment of professional activities on the securities market. To ensure client’s fair treatment, the Company will introduce the following procedures: •  The Company shall avoid any conflict of interest with clients and, where such a conflict unavoidably arises, ensure fair treatment to the client by complete disclosure or by declining to act. •  Employees are also prohibited to keep investor accounts in other Brokers without Company’s prior authorization and are obliged to bring this to Company’s attention. They are also obliged to authorize the Company to directly request transaction reports from the other Brokers. •  If the Company has a material interest in a transaction to be entered into with or for a client, or a relationship which gives rise to a conflict of interest in relation to the transaction, the licensee shall not knowingly either advise, or deal in the exercise of discretion, in relation to that transaction. The only exception is when the licensee has fairly disclosed that material interest or relationship, as the case may be, to the client or the client has taken reasonable steps to ensure that neither the material interest nor relationship adversely affect the interests of the client. •  There is a clear distinction between the different departments’ operations as these are described in the Company’s IOM. •  The Company shall be informed promptly of any personal transaction entered into by a relevant person, either by notification of that transaction or by other procedures enabling the Company to identify such transactions. In the case of outsourcing arrangements, the Company shall ensure that the Company to which the activity is outsourced maintains a record of personal transactions entered into by any relevant person and provides that information to the Company promptly on request. •  A person shall be replaced by another person in his/her duties only prior consent of the CO and approval by the Representative Officer. Such a consent will be given by the CO after all issues of possible conflict of interest have been reviewed. •  The security features of the Company’s software prevents unauthorized access to sensitive information in order to benefit the Company over its clients or one client over another. •  The Company’s employees are prohibited from investing in securities for which they have access to non-public or confidential information. •  Transactions by the Company’s employees are neither performed nor executed by themselves, but by another member of staff of the Company concerning account opened with the Company. •  A record shall be kept of the personal transaction notified to the Company or identified by it, including any authorisation or prohibition in connection with such a transaction. •  The Company must take reasonable steps to ensure that neither it nor any of its employees or agents either offers or gives, or solicits or accepts, any inducement that is likely to conflict with any duties owed to its clients. •  No employee shall either knowingly or recklessly make a statement, promise or forecast that is misleading, false or deceptive to any customer or conceal material facts at any time. More specifically, the Company states some of the policies and procedures that it has implemented for managing possible conflicts of interest below: •  Effective procedures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities. •  The separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company. •  Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of the conflicts of interest. •  The removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities. •  Measures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients. The procedures followed and measures adopted in the Policy include the following, as are necessary and appropriate for the Company to ensure the requisite degree of independence: •  No relevant person may purchase or sell a security or cause the purchase or sale of a security for any account while in possession of inside information relating to that security. •  No relevant person may recommend or solicit the purchase or sale of any security while in possession of inside information relating to that security. •  No relevant person may purchase or sell or cause the purchase or sale of a security for an employee or employee-related account or a proprietary account of the Company or an account over which an employee exercises investment discretion, while in possession of proprietary information concerning a contemplated block transaction in the security or for a customer account when such customer has been provided such information by any relevant person. •  Procedures set for regular review and monitoring of the execution arrangements with the execution venue, hedging/ liquidity or price providers as well as on a continuous basis. •  Procedures in regards to the monitoring of access to electronic data. •  Relevant persons engaged in research activities should not discuss unreleased information, opinions, recommendations, or research analysis in progress with Company associated persons engaged in sales activities, or any person within or outside the Company who does not have a valid business need to know the information. •  Establishment of an ongoing monitoring program based on which regular checks are conducted for the assessment of the Company’s procedures, policies and internal controls. •  The Company may distribute marketing communication to its clients, only if the said communication is reviewed and approved by the CO prior to distribution. The CO also ensures that such communication have the appropriate disclosure statement as well as meeting the relevant definition of marketing communication. •  The four-eye principle is implemented to avoid any abuse of position. •  In order to minimise the relevant person’s own transactions personal account dealing restrictions are in place. The Company ICC Intercertus Capital is committed to having an effective and appropriate compliance culture to enable it to deal with any new potential conflicts of interest which may arise in the future. The Company’s employees are therefore required to monitor any new circumstances giving rise to potential conflicts of interest and to implement appropriate measures to address these. For the purpose of this Policy, a “personal transaction” is considered a trade in a financial instrument effected by or on behalf of a relevant person, where at least one of the following criteria are met: •  the relevant person is acting outside the scope of the activities he carries out in his professional capacity; •  the trade is carried out for the account of any of the following persons: o the relevant person; o any person with whom he has a family relationship, or with whom he has close links; o a person in respect of whom the relevant person has a direct or indirect material interest in the outcome of the trade, other than obtaining a fee or commission for the execution of the trade. The Company shall maintain separate accounting records between its own assets and those of its clients to facilitate the protection of clients’ assets and the prevention of the use of customer assets by the Company or by other third parties so as to minimise the risk of the loss or diminution of client assets, or of rights in connection with those assets, as a result of misuse of the assets, fraud, poor administration, inadequate record-keeping or negligence. In addition, the Company has legally secure segregation of clients’ assets from the Company’s assets in case the Company becomes bankrupt. For this purpose, the Company maintains separate books and accounting records for each client.

Managing Conflicts of Interest. The Company has established suitable and adequate internal procedures for minimising any potential conflicts of interest. The Company maintains a compliance department that is an independent unit within the Company. Among the duties of the CO Compliance Officer is to monitor any possible deviation from the Company’s internal policies and procedures as well as identifying and managing any possible conflicts of interest. Once a conflict has been identified it needs to be appropriately and adequately managed. The Compliance function will assess each conflict and determine if the conflict is actual or perceived and what the value of the conflict or exposure is and the potential reputational risk. Compliance will then decide whether it is viable to go ahead with the transaction or if the conflict is too severe. If Compliance decides that the particular conflict can be mitigated, then controls to manage the conflict should be put in place and documented. The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its employees and between its customers and to organise and control their internal affairs responsibly and effectively. The Company and its employees should act as per the principle of placing clients’ interests before self-interests and Company’s interests in order to avoid conflicts of interest in the fulfilment of professional activities on the securities market. To ensure client’s fair treatment, the Company will introduce the following procedures: • The Company shall avoid any conflict of interest with clients and, where such a conflict unavoidably arises, ensure fair treatment to the client by complete disclosure or by declining to act. • Employees are also prohibited to keep investor accounts in other Brokers without Company’s prior authorization and are obliged to bring this to Company’s attention. They are also obliged to authorize the Company to directly request transaction reports from the other Brokers. • If the Company has a material interest in a transaction to be entered into with or for a client, or a relationship which gives rise to a conflict of interest in relation to the transaction, the licensee Company shall not knowingly either advise, or deal in the exercise of discretion, in relation to that transaction. The only exception is when the licensee Company has fairly disclosed that material interest or relationship, as the case may be, to the client or the client has taken reasonable steps to ensure that neither the material interest nor relationship adversely affect the interests of the client. • There is a clear distinction between the different departments’ operations as these are described in the Company’s IOM. • The Company shall be informed promptly of any personal transaction entered into by a relevant person, either by notification of that transaction or by other procedures enabling the Company to identify such transactions. In the case of outsourcing arrangements, the Company shall ensure that the Company to which the activity is outsourced maintains a record of personal transactions entered into by any relevant person and provides that information to the Company promptly on request. • A person shall be replaced by another person in his/her duties only prior consent of the CO Compliance Officer and approval by the Representative Officer. Such a consent will be given by the CO Compliance Officer after all issues of possible conflict of interest have been reviewed. • The security features of the Company’s software prevents unauthorized access to sensitive information in order to benefit the Company over its clients or one client over another. • The Company’s employees are prohibited from investing in securities for which they have access to non-public or confidential information. • Transactions by the Company’s employees are neither performed nor executed by themselves, but by another member of staff of the Company concerning account opened with the Company. • A record shall be kept of the personal transaction notified to the Company or identified by it, including any authorisation authorization or prohibition in connection with such a transaction. • The Company must take reasonable steps to ensure that neither it nor any of its employees or agents either offers or gives, or solicits or accepts, any inducement that is likely to conflict with any duties owed to its clients. • No employee shall either knowingly or recklessly make a statement, promise or forecast that is misleading, false or deceptive to any customer or conceal material facts at any time. More specifically, the Company states some of the policies and procedures that it has implemented for managing possible conflicts of interest below: • Effective procedures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities. • The separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company. • Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of the conflicts of interest. • The removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities. • Measures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients. The procedures followed and measures adopted in the Policy include the following, as are necessary and appropriate for the Company to ensure the requisite degree of independence: • No relevant person may purchase or sell a security or cause the purchase or sale of a security for any account while in possession of inside information relating to that security. • No relevant person may recommend or solicit the purchase or sale of any security while in possession of inside information relating to that security. • No relevant person may purchase or sell or cause the purchase or sale of a security for an employee or employee-related account or a proprietary account of the Company or an account over which an employee exercises investment discretion, while in possession of proprietary information concerning a contemplated block transaction in the security or for a customer account when such customer has been provided such information by any relevant person. • Procedures set for regular review and monitoring of the execution arrangements with the execution venue, hedging/ liquidity or price providers as well as on a continuous basis. • Procedures in regards to the monitoring of access to electronic data. • Relevant persons engaged in research activities should not discuss unreleased information, opinions, recommendations, or research analysis in progress with Company associated persons engaged in sales activities, or any person within or outside the Company who does not have a valid business need to know the information. • Establishment of an ongoing monitoring program based on which regular checks are conducted for the assessment of the Company’s procedures, policies and internal controls. Client Services Agreement • The Company may distribute marketing communication to its clients, only if the said communication is reviewed and approved by the CO Compliance Officer prior to distribution. The CO Compliance Officer also ensures that such communication have the appropriate disclosure statement as well as meeting the relevant definition of marketing communication. • The four-eye principle is implemented to avoid any abuse of position. • In order to minimise minimize the relevant person’s own transactions personal account dealing restrictions are in place. The Company is committed to having an effective and appropriate compliance culture to enable it to deal with any new potential conflicts of interest which may arise in the future. The Company’s employees are therefore required to monitor any new circumstances giving rise to potential conflicts of interest and to implement appropriate measures to address these. For the purpose of this Policy, a “personal transaction” is considered a trade in a financial instrument effected by or on behalf of a relevant person, where at least one of the following criteria are met: • the relevant person is acting outside the scope of the activities he carries out in his professional capacity; • the trade is carried out for the account of any of the following persons: o the relevant person; o any person with whom he has a family relationship, or with whom he has close links; o a person in respect of whom the relevant person has a direct or indirect material interest in the outcome of the trade, other than obtaining a fee or commission for the execution of the trade. The Company shall maintain separate accounting records between its own assets and those of its clients to facilitate the protection of clients’ assets and the prevention of the use of customer assets by the Company or by other third parties so as to minimise the risk of the loss or diminution of client assets, or of rights in connection with those assets, as a result of misuse of the assets, fraud, poor administration, inadequate record-keeping or negligence. In addition, the Company has legally secure segregation of clients’ assets from the Company’s assets in case the Company becomes bankrupt. For this purpose, the Company maintains separate books and accounting records for each client.

Managing Conflicts of Interest. The Company has established suitable and adequate internal procedures for minimising any potential conflicts of interest. The Company maintains a compliance department that is an independent unit within the Company. Among the duties of the CO is to monitor any possible deviation from the Company’s internal policies and procedures as well as identifying and managing any possible conflicts of interest. Once a conflict has been identified it needs to be appropriately and adequately managed. The Compliance function will assess each conflict and determine if the conflict is actual or perceived and what the value of the conflict or exposure is and the potential reputational risk. Compliance will then decide whether it is viable to go ahead with the transaction or if the conflict is too severe. If Compliance decides that the particular conflict can be mitigated, then controls to manage the conflict should be put in place and documented. The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its employees and between its customers and to organise and control their internal affairs responsibly and effectively. The Company and its employees should act as per the principle of placing clients’ interests before self-interests and Company’s interests in order to avoid conflicts of interest in the fulfilment of professional activities on the securities market. To ensure client’s fair treatment, the Company will introduce the following procedures: • The Company shall avoid any conflict of interest with clients and, where such a conflict unavoidably arises, ensure fair treatment to the client by complete disclosure or by declining to act. • Employees are also prohibited to keep investor accounts in other Brokers without Company’s prior authorization and are obliged to bring this to Company’s attention. They are also obliged to authorize the Company to directly request transaction reports from the other Brokers. • If the Company has a material interest in a transaction to be entered into with or for a client, or a relationship which gives rise to a conflict of interest in relation to the transaction, the licensee shall not knowingly either advise, or deal in the exercise of discretion, in relation to that transaction. The only exception is when the licensee has fairly disclosed that material interest or relationship, as the case may be, to the client or the client has taken reasonable steps to ensure that neither the material interest nor relationship adversely affect the interests of the client. • There is a clear distinction between the different departments’ operations as these are described in the Company’s IOM. • The Company shall be informed promptly of any personal transaction entered into by a relevant person, either by notification of that transaction or by other procedures enabling the Company to identify such transactions. In the case of outsourcing arrangements, the Company shall ensure that the Company to which the activity is outsourced maintains a record of personal transactions entered into by any relevant person and provides that information to the Company promptly on request. • A person shall be replaced by another person in his/her duties only prior consent of the CO and approval by the Representative Officer. Such a consent will be given by the CO after all issues of possible conflict of interest have been reviewed. • The security features of the Company’s software prevents unauthorized access to sensitive information in order to benefit the Company over its clients or one client over another. • The Company’s employees are prohibited from investing in securities for which they have access to non-public or confidential information. • Transactions by the Company’s employees are neither performed nor executed by themselves, but by another member of staff of the Company concerning account opened with the Company. • A record shall be kept of the personal transaction notified to the Company or identified by it, including any authorisation or prohibition in connection with such a transaction. • The Company must take reasonable steps to ensure that neither it nor any of its employees or agents either offers or gives, or solicits or accepts, any inducement that is likely to conflict with any duties owed to its clients. • No employee shall either knowingly or recklessly make a statement, promise or forecast that is misleading, false or deceptive to any customer or conceal material facts at any time. More specifically, the Company states some of the policies and procedures that it has implemented for managing possible conflicts of interest below: • Effective procedures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities. • The separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company. • Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of the conflicts of interest. • The removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities. • Measures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients. The procedures followed and measures adopted in the Policy include the following, as are necessary and appropriate for the Company to ensure the requisite degree of independence: • No relevant person may purchase or sell a security or cause the purchase or sale of a security for any account while in possession of inside information relating to that security. • No relevant person may recommend or solicit the purchase or sale of any security while in possession of inside information relating to that security. • No relevant person may purchase or sell or cause the purchase or sale of a security for an employee or employee-related account or a proprietary account of the Company or an account over which an employee exercises investment discretion, while in possession of proprietary information concerning a contemplated block transaction in the security or for a customer account when such customer has been provided such information by any relevant person. • Procedures set for regular review and monitoring of the execution arrangements with the execution venue, hedging/ liquidity or price providers as well as on a continuous basis. • Procedures in regards to the monitoring of access to electronic data. • Relevant persons engaged in research activities should not discuss unreleased information, opinions, recommendations, or research analysis in progress with Company associated persons engaged in sales activities, or any person within or outside the Company who does not have a valid business need to know the information. • Establishment of an ongoing monitoring program based on which regular checks are conducted for the assessment of the Company’s procedures, policies and internal controls. • The Company may distribute marketing communication to its clients, only if the said communication is reviewed and approved by the CO prior to distribution. The CO also ensures that such communication have the appropriate disclosure statement as well as meeting the relevant definition of marketing communication. • The four-eye principle is implemented to avoid any abuse of position. • In order to minimise the relevant person’s own transactions personal account dealing restrictions are in place. The Company ICC Intercertus Capital is committed to having an effective and appropriate compliance culture to enable it to deal with any new potential conflicts of interest which may arise in the future. The Company’s employees are therefore required to monitor any new circumstances giving rise to potential conflicts of interest and to implement appropriate measures to address these. For the purpose of this Policy, a “personal transaction” is considered a trade in a financial instrument effected by or on behalf of a relevant person, where at least one of the following criteria are met: • the relevant person is acting outside the scope of the activities he carries out in his professional capacity; • the trade is carried out for the account of any of the following persons: o the relevant person; o any person with whom he has a family relationship, or with whom he has close links; o a person in respect of whom the relevant person has a direct or indirect material interest in the outcome of the trade, other than obtaining a fee or commission for the execution of the trade. The Company shall maintain separate accounting records between its own assets and those of its clients to facilitate the protection of clients’ assets and the prevention of the use of customer assets by the Company or by other third parties so as to minimise the risk of the loss or diminution of client assets, or of rights in connection with those assets, as a result of misuse of the assets, fraud, poor administration, inadequate record-keeping or negligence. In addition, the Company has legally secure segregation of clients’ assets from the Company’s assets in case the Company becomes bankrupt. For this purpose, the Company maintains separate books and accounting records for each client.

Managing Conflicts of Interest. The Company has established suitable and adequate internal procedures for minimising minimizing any potential conflicts of interest. The Company maintains a compliance department that is an independent unit within the Company. Among the duties of the CO Compliance Officer is to monitor any possible deviation from the Company’s internal policies and procedures as well as identifying and managing any possible conflicts of interest. Once a conflict has been identified it needs to be appropriately and adequately managed. The Compliance function will assess each conflict and determine if the conflict is actual or perceived and what the value of the conflict or exposure is exposureis and the potential reputational risk. Compliance will then decide whether it is viable to go ahead with aheadwith the transaction or if the conflict is too severe. If Compliance decides that the particular conflict can conflictcan be mitigated, then controls to manage the conflict should be put in place and documented. The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its employees and between its customers and to organise organize and control their internal affairs responsibly and effectively. The Company and its employees should act as per the principle of placing clients’ interests before self-interests and Company’s interests in order to avoid conflicts of interest in the fulfilment of professional activities on the securities market. To ensure client’s fair treatment, the Company will introduce the following procedures: •  The Company shall avoid any conflict of interest with clients and, where such a conflict unavoidably arises, ensure fair treatment to the client by complete disclosure or by declining to act. •  Employees are also prohibited to keep investor accounts in other Brokers without Company’s prior authorization and are obliged to bring this to Company’s attention. They are also obliged to authorize the Company to directly request transaction reports from the other Brokers. •  If the Company has a material interest in a transaction to be entered into with or for a client, or a relationship which gives rise to a conflict of interest in relation to the transaction, the licensee shall not knowingly either advise, or deal in the exercise of discretion, in relation to that transaction. The only exception is when the licensee has fairly disclosed that material interest or relationship, as the case may be, to the client or the client has taken reasonable steps to ensure that neither the material interest nor relationship adversely affect the interests of the client. •  There is a clear distinction between the different departments’ operations as these are described in the Company’s IOM. •  The Company shall be informed promptly of any personal transaction entered into by a relevant person, either by notification of that transaction or by other procedures enabling the Company to identify such transactions. In the case of outsourcing arrangements, the Company shall ensure that the Company to which the activity is outsourced maintains a record of personal transactions entered into by any relevant person and provides that information to the Company promptly on request. •  A person shall be replaced by another person in his/her duties only prior consent of the CO Compliance Officer and approval by the Representative Officer. Such a consent will be given by the CO Compliance Officer after all issues of possible conflict of interest have been reviewed. •  The security features of the Company’s software prevents prevent unauthorized access to sensitive information in order to benefit the Company over its clients or one client over another. •  The Company’s employees are prohibited from investing in securities for which they have access to non-public or confidential information. •  Transactions by the Company’s employees are neither performed nor executed by themselves, but by another member of staff of the Company concerning account opened with the Company. •  A record shall be kept of the personal transaction notified to the Company or identified by it, including any authorisation authorization or prohibition in connection with such a transaction. •  The Company must take reasonable steps to ensure that neither it nor any of its employees itsemployees or agents either offers or gives, or solicits or accepts, any inducement that is likely to conflict with any duties owed to its clients. •  No employee shall either knowingly or recklessly make a statement, promise or forecast that is misleading, false or deceptive to any customer or conceal material facts at any time. More specifically, the Company states some of the policies and procedures that it has implemented for managing possible conflicts of interest below: •  Effective procedures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities. •  The separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company. •  Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of the conflicts of interest. •  The removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities. •  Measures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients. The procedures followed and measures adopted in the Policy include the following, as are necessary and appropriate for the Company to ensure the requisite degree of independence: •  No relevant person may purchase or sell a security or cause the purchase or sale of a security for any account while in possession of inside information relating to that security. •  No relevant person may recommend or solicit the purchase or sale of any security while in possession of inside information relating to that security. •  No relevant person may purchase or sell or cause the purchase or sale of a security for an employee or employee-related account or a proprietary account of the Company or an account over which an employee exercises investment discretion, while in possession of proprietary information concerning a contemplated block transaction in the security or for a customer account when such customer has been provided such information by any relevant person. •  Procedures set for regular review and monitoring of the execution arrangements with the execution venue, hedging/ liquidity or price providers as well as on a continuous basis. •  Procedures in regards to the monitoring of access to electronic data. •  Relevant persons engaged in research activities should not discuss unreleased information, opinions, recommendations, or research analysis in progress with Company associated persons engaged in sales activities, or any person within or outside the Company who does not have a valid business need to know the information. •  Establishment of an ongoing monitoring program based on which regular checks are conducted for the assessment of the Company’s procedures, policies and internal controls. •  The Company may distribute marketing communication to its clients, only if the said communication is reviewed and approved by the CO Compliance Officer prior to distribution. The CO Compliance Officer also ensures that such communication have the appropriate disclosure statement as well as meeting the relevant definition of marketing communication. •  The four-eye principle is implemented to avoid any abuse of position. •  In order to minimise minimize the relevant person’s own transactions personal account dealing restrictions are in place. The Company Evalanch is committed to having an effective and appropriate compliance culture to enable it to deal with any new potential conflicts of interest which may arise in the future. The Company’s employees are therefore required to monitor any new circumstances giving rise to potential conflicts of interest and to implement appropriate measures to address these. For the purpose of this Policy, a “personal transaction” is considered a trade in a financial instrument effected by or on behalf of a relevant person, where at least one of the following criteria are met: •  the relevant person is acting outside the scope of the activities he carries out in his professional capacity; •  the trade is carried out for the account of any of the following persons: o the relevant person; o any person with whom he has a family relationship, or with whom he has close links; o a person in respect of whom the relevant person has a direct or indirect material interest in the outcome of the trade, other than obtaining a fee or commission for the execution of the trade. The Company shall maintain separate accounting records between its own assets and those of its clients to facilitate the protection of clients’ assets and the prevention of the use of customer assets by the Company or by other third parties so as to minimise the risk of the loss or diminution of client assets, or of rights in connection with those assets, as a result of misuse of the assets, fraud, poor administration, inadequate record-keeping or negligence. In addition, the Company has legally secure segregation of clients’ assets from the Company’s assets in case the Company becomes bankrupt. For this purpose, the Company maintains separate books and accounting records for each client.

Managing Conflicts of Interest. The Company has established suitable and adequate internal procedures for minimising any potential conflicts of interest. The Company maintains a compliance department that is an independent unit within the Company. Among the duties of the CO Compliance Officer is to monitor any possible deviation from the Company’s internal policies and procedures as well as identifying and managing any possible conflicts of interest. Once a conflict has been identified it needs to be appropriately and adequately managed. The Compliance function will assess each conflict and determine if the conflict is actual or perceived and what the value of the conflict or exposure is and the potential reputational risk. Compliance will then decide whether it is viable to go ahead with the transaction or if the conflict is too severe. If Compliance decides that the particular conflict can be mitigated, then controls to manage the conflict should be put in place and documented. The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its employees and between its customers and to organise and control their internal affairs responsibly and effectively. The Company and its employees should act as per the principle of placing clients’ interests before self-interests and Company’s interests in order to avoid conflicts of interest in the fulfilment of professional activities on the securities market. To ensure client’s fair treatment, the Company will introduce the following procedures: • The Company shall avoid any conflict of interest with clients and, where such a conflict unavoidably arises, ensure fair treatment to the client by complete disclosure or by declining to act. act • Employees are also prohibited to keep investor accounts in other Brokers without Company’s prior authorization and are obliged to bring this to Company’s attention. They are also obliged to authorize the Company to directly request transaction reports from the other Brokers. • If the Company has a material interest in a transaction to be entered into with or for a client, or a relationship which gives rise to a conflict of interest in relation to the transaction, the licensee Company shall not knowingly either advise, or deal in the exercise of discretion, in relation to that transaction. The only exception is when the licensee Company has fairly disclosed that material interest or relationship, as the case may be, to the client or the client has taken reasonable steps to ensure that neither the material interest nor relationship adversely affect the interests of the client. • There is a clear distinction between the different departments’ operations as these are described in the Company’s IOM. • The Company shall be informed promptly of any personal transaction entered into by a relevant person, either by notification of that transaction or by other procedures enabling the Company to identify such transactions. In the case of outsourcing arrangements, the Company shall ensure that the Company to which the activity is outsourced maintains a record of personal transactions entered into by any relevant person and provides that information to the Company promptly on request. • A person shall be replaced by another person in his/her duties only prior consent of the CO Compliance Officer and approval by the Representative Officer. Such a consent will be given by the CO Compliance Officer after all issues of possible conflict of interest have been reviewed. • The security features of the Company’s software prevents unauthorized access to sensitive information in order to benefit the Company over its clients or one client over another. • The Company’s employees are prohibited from investing in securities for which they have access to non-public or confidential information. • Transactions by the Company’s employees are neither performed nor executed by themselves, but by another member of staff of the Company concerning account opened with the Company. • A record shall be kept of the personal transaction notified to the Company or identified by it, including any authorisation authorization or prohibition in connection with such a transaction. • The Company must take reasonable steps to ensure that neither it nor any of its employees or agents either offers or gives, or solicits or accepts, any inducement that is likely to conflict with any duties owed to its clients. • No employee shall either knowingly or recklessly make a statement, promise or forecast that is misleading, false or deceptive to any customer or conceal material facts at any time. More specifically, the Company states some of the policies and procedures that it has implemented for managing possible conflicts of interest below: • Effective procedures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities. • The separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company. • Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of the conflicts of interest. • The removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities. • Measures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients. The procedures followed and measures adopted in the Policy include the following, as are necessary and appropriate for the Company to ensure the requisite degree of independence: • No relevant person may purchase or sell a security or cause the purchase or sale of a security for any account while in possession of inside information relating to that security. • No relevant person may recommend or solicit the purchase or sale of any security while in possession of inside information relating to that security. • No relevant person may purchase or sell or cause the purchase or sale of a security for an employee or employee-related account or a proprietary account of the Company or an account over which an employee exercises investment discretion, while in possession of proprietary information concerning a contemplated block transaction in the security or for a customer account when such customer has been provided such information by any relevant person. • Procedures set for regular review and monitoring of the execution arrangements with the execution venue, hedging/ liquidity or price providers as well as on a continuous basis. • Procedures in regards to the monitoring of access to electronic data. • Relevant persons engaged in research activities should not discuss unreleased information, opinions, recommendations, or research analysis in progress with Company associated persons engaged in sales activities, or any person within or outside the Company who does not have a valid business need to know the information. • Establishment of an ongoing monitoring program based on which regular checks are conducted for the assessment of the Company’s procedures, policies and internal controls. • The Company may distribute marketing communication to its clients, only if the said communication is reviewed and approved by the CO Compliance Officer prior to distribution. The CO Compliance Officer also ensures that such communication have the appropriate disclosure statement as well as meeting the relevant definition of marketing communication. • The four-eye principle is implemented to avoid any abuse of position. • In order to minimise minimize the relevant person’s own transactions personal account dealing restrictions are in place. The Company is committed to having an effective and appropriate compliance culture to enable it to deal with any new potential conflicts of interest which may arise in the future. The Company’s employees are therefore required to monitor any new circumstances giving rise to potential conflicts of interest and to implement appropriate measures to address these. For the purpose of this Policy, a “personal transaction” is considered a trade in a financial instrument effected by or on behalf of a relevant person, where at least one of the following criteria are met: • the relevant person is acting outside the scope of the activities he carries out in his professional capacity; • the trade is carried out for the account of any of the following persons: o the relevant person; Client Services Agreement o any person with whom he has a family relationship, or with whom he has close links; o a person in respect of whom the relevant person has a direct or indirect material interest in the outcome of the trade, other than obtaining a fee or commission for the execution of the trade. The Company shall maintain separate accounting records between its own assets and those of its clients to facilitate the protection of clients’ assets and the prevention of the use of customer assets by the Company or by other third parties so as to minimise minimize the risk of the loss or diminution of client assets, or of rights in connection with those assets, as a result of misuse of the assets, fraud, poor administration, inadequate record-keeping or negligence. In addition, the Company has legally secure segregation of clients’ assets from the Company’s assets in case the Company becomes bankrupt. For this purpose, the Company maintains separate books and accounting records for each client.

Managing Conflicts of Interest. The Company has established suitable and adequate internal procedures for minimising any potential conflicts of interest. The Company maintains a compliance department that is an independent unit within the Company. Among the duties of the CO Compliance Officer is to monitor any possible deviation from the Company’s internal policies and procedures as well as identifying and managing any possible conflicts of interest. Once a conflict has been identified it needs to be appropriately and adequately managed. The Compliance function will assess each conflict and determine if the conflict is actual or perceived and what the value of the conflict or exposure is and the potential reputational risk. Compliance will then decide whether it is viable to go ahead with the transaction or if the conflict is too severe. If Compliance decides that the particular conflict can be mitigated, then controls to manage the conflict should be put in place and documented. The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its employees and between its customers and to organise and control their internal affairs responsibly and effectively. The Company and its employees should act as per the principle of placing clients’ interests before self-interests selfinterests and Company’s interests in order to avoid conflicts of interest in the fulfilment of professional activities on the securities market. To ensure client’s fair treatment, the Company will introduce the following procedures: • The Company shall avoid any conflict of interest with clients and, where such a conflict unavoidably arises, ensure fair treatment to the client by complete disclosure or by declining to act. • ; Employees are also prohibited to keep investor accounts in other Brokers without Company’s prior authorization and are obliged to bring this to Company’s attention. They are also obliged to authorize the Company to directly request transaction reports from the other Brokers. • Brokers If the Company has a material interest in a transaction to be entered into with or for a client, or a relationship which gives rise to a conflict of interest in relation to the transaction, the licensee Company shall not knowingly either advise, or deal in the exercise of discretion, in relation to that transaction. The only exception is when the licensee Company has fairly disclosed that material interest or relationship, as the case may be, to the client or the client has taken reasonable steps to ensure that neither the material interest nor relationship adversely affect the interests of the client. client • There is a clear distinction between the different departments’ operations as these are described in the Company’s IOM. ; • The Company shall be informed promptly of any personal transaction entered into by a relevant person, either by notification of that transaction or by other procedures enabling the Company to identify such transactions. In the case of outsourcing arrangements, the Company shall ensure that the Company to which the activity is outsourced maintains a record of personal transactions entered into by any relevant person and provides that information to the Company promptly on request. ; • A person shall be replaced by another person in his/her duties only prior consent of the CO Compliance Officer and approval by the Representative Officer. Such a consent will be given by the CO Compliance Officer after all issues of possible conflict of interest have been reviewed. ; • The security features of the Company’s software prevents unauthorized access to sensitive information in order to benefit the Company over its clients or one client over another. ; • The Company’s employees are prohibited from investing in securities for which they have access to non-public or confidential information. ; • Transactions by the Company’s employees are neither performed nor executed by themselves, but by another member of staff of the Company concerning account opened with the Company. • A record shall be kept of the personal transaction notified to the Company or identified by it, including any authorisation authorization or prohibition in connection with such a transaction. ; • The Company must take reasonable steps to ensure that neither it nor any of its employees or agents either offers or gives, or solicits or accepts, any inducement that is likely to conflict with any duties owed to its clients. ; and • No employee shall either knowingly or recklessly make a statement, promise or forecast that is misleading, false or deceptive to any customer or conceal material facts at any time. More specifically, the Company states some of the policies and procedures that it has implemented for managing possible conflicts of interest below: • Effective procedures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities. ; • The separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company. ; • Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of the conflicts of interest. • ; The removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities. • ; and Measures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients. The procedures followed and measures adopted in the Policy include the following, as are necessary and appropriate for the Company to ensure the requisite degree of independence: • No relevant person may purchase or sell a security or cause the purchase or sale of a security for any account while in possession of inside information relating to that security. ; • No relevant person may recommend or solicit the purchase or sale of any security while in possession of inside information relating to that security. ; • No relevant person may purchase or sell or cause the purchase or sale of a security for an employee or employee-related account or a proprietary account of the Company or an account over which an employee exercises investment discretion, while in possession of proprietary information concerning a contemplated block transaction in the security or for a customer account when such customer has been provided such information by any relevant person. ; • Procedures set for regular review and monitoring of the execution arrangements with the execution venue, hedging/ liquidity or price providers as well as on a continuous basis. ; • Procedures in regards to the monitoring of access to electronic data. ; • Relevant persons engaged in research activities should not discuss unreleased information, opinions, recommendations, or research analysis in progress with Company associated persons engaged in sales activities, or any person within or outside the Company who does not have a valid business need to know the information. ; • Establishment of an ongoing monitoring program based on which regular checks are conducted for the assessment of the Company’s procedures, policies and internal controls. ; • The Company may distribute marketing communication to its clients, only if the said communication is reviewed and approved by the CO Compliance Officer prior to distribution. The CO Compliance Officer also ensures that such communication have the appropriate disclosure statement as well as meeting the relevant definition of marketing communication. ; • The four-eye principle is implemented to avoid any abuse of position. ; and • In order to minimise minimize the relevant person’s own transactions personal account dealing restrictions are in place. The Company is committed to having an effective and appropriate compliance culture to enable it to deal with any new potential conflicts of interest which may arise in the future. The Company’s employees are therefore required to monitor any new circumstances giving rise to potential conflicts of interest and to implement appropriate measures to address these. For the purpose of this Policy, a “personal transaction” is considered a trade in a financial instrument effected by or on behalf of a relevant person, where at least one of the following criteria are met: • the relevant person is acting outside the scope of the activities he carries out in his professional capacity; • the trade is carried out for the account of any of the following persons: o the relevant person; o any person with whom he has a family relationship, or with whom he has close links; o a person in respect of whom the relevant person has a direct or indirect material interest in the outcome of the trade, other than obtaining a fee or commission for the execution of the trade. The Company shall maintain separate accounting records between its own assets and those of its clients to facilitate the protection of clients’ assets and the prevention of the use of customer assets by the Company or by other third parties so as to minimise the risk of the loss or diminution of client assets, or of rights in connection with those assets, as a result of misuse of the assets, fraud, poor administration, inadequate record-keeping or negligence. In addition, the Company has legally secure segregation of clients’ assets from the Company’s assets in case the Company becomes bankrupt. For this purpose, the Company maintains separate books and accounting records for each client.

Managing Conflicts of Interest. The Company has established suitable and adequate internal procedures for minimising any potential conflicts of interest. The Company maintains a compliance department that is an independent unit within the Company. Among the duties of the CO is to monitor any possible deviation from the Company’s internal policies and procedures as well as identifying and managing any possible conflicts of interest. Once a conflict has been identified it needs to be appropriately and adequately managed. The Compliance function will assess each conflict and determine if the conflict is actual or perceived and what the value of the conflict or exposure is and the potential reputational risk. Compliance will then decide whether it is viable to go ahead with the transaction or if the conflict is too severe. If Compliance decides that the particular conflict can be mitigated, then controls to manage the conflict should be put in place and documented. The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its employees and between its customers and to organise and control their internal affairs responsibly and effectively. The Company and its employees should act as per the principle of placing clients’ interests before self-interests and Company’s interests in order to avoid conflicts of interest in the fulfilment of professional activities on the securities market. To ensure client’s fair treatment, the Company will introduce the following procedures: • The Company shall avoid any conflict of interest with clients and, where such a conflict unavoidably arises, ensure fair treatment to the client by complete disclosure or by declining to act. • Employees are also prohibited to keep investor accounts in other Brokers without Company’s prior authorization and are obliged to bring this to Company’s attention. They are also obliged to authorize the Company to directly request transaction reports from the other Brokers. • If the Company has a material interest in a transaction to be entered into with or for a client, or a relationship which gives rise to a conflict of interest in relation to the transaction, the licensee shall not knowingly either advise, or deal in the exercise of discretion, in relation to that transaction. The only exception is when the licensee has fairly disclosed that material interest or relationship, as the case may be, to the client or the client has taken reasonable steps to ensure that neither the material interest nor relationship adversely affect the interests of the client. • There is a clear distinction between the different departments’ operations as these are described in the Company’s IOM. • The Company shall be informed promptly of any personal transaction entered into by a relevant person, either by notification of that transaction or by other procedures enabling the Company to identify such transactions. In the case of outsourcing arrangements, the Company shall ensure that the Company to which the activity is outsourced maintains a record of personal transactions entered into by any relevant person and provides that information to the Company promptly on request. • A person shall be replaced by another person in his/her duties only prior consent of the CO and approval by the Representative Officer. Such a consent will be given by the CO after all issues of possible conflict of interest have been reviewed. • The security features of the Company’s software prevents unauthorized access to sensitive information in order to benefit the Company over its clients or one client over another. • The Company’s employees are prohibited from investing in securities for which they have access to non-public or confidential information. • Transactions by the Company’s employees are neither performed nor executed by themselves, but by another member of staff of the Company concerning account opened with the Company. • A record shall be kept of the personal transaction notified to the Company or identified by it, including any authorisation or prohibition in connection with such a transaction. • The Company must take reasonable steps to ensure that neither it nor any of its employees or agents either offers or gives, or solicits or accepts, any inducement that is likely to conflict with any duties owed to its clients. • No employee shall either knowingly or recklessly make a statement, promise or forecast that is misleading, false or deceptive to any customer or conceal material facts at any time. More specifically, the Company states some of the policies and procedures that it has implemented for managing possible conflicts of interest below: • Effective procedures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities. • The separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company. • Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of the conflicts of interest. • The removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities. • Measures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients. The procedures followed and measures adopted in the Policy include the following, as are necessary and appropriate for the Company to ensure the requisite degree of independence: • No relevant person may purchase or sell a security or cause the purchase or sale of a security for any account while in possession of inside information relating to that security. • No relevant person may recommend or solicit the purchase or sale of any security while in possession of inside information relating to that security. • No relevant person may purchase or sell or cause the purchase or sale of a security for an employee or employee-related account or a proprietary account of the Company or an account over which an employee exercises investment discretion, while in possession of proprietary information concerning a contemplated block transaction in the security or for a customer account when such customer has been provided such information by any relevant person. • Procedures set for regular review and monitoring of the execution arrangements with the execution venue, hedging/ liquidity or price providers as well as on a continuous basis. • Procedures in regards to the monitoring of access to electronic data. • Relevant persons engaged in research activities should not discuss unreleased information, opinions, recommendations, or research analysis in progress with Company associated persons engaged in sales activities, or any person within or outside the Company who does not have a valid business need to know the information. • Establishment of an ongoing monitoring program based on which regular checks are conducted for the assessment of the Company’s procedures, policies and internal controls. • The Company may distribute marketing communication to its clients, only if the said communication is reviewed and approved by the CO prior to distribution. The CO also ensures that such communication have the appropriate disclosure statement as well as meeting the relevant definition of marketing communication. • The four-eye principle is implemented to avoid any abuse of position. • In order to minimise the relevant person’s own transactions personal account dealing restrictions are in place. The Company ▇▇▇▇▇▇ Capital is committed to having an effective and appropriate compliance culture to enable it to deal with any new potential conflicts of interest which may arise in the future. The Company’s employees are therefore required to monitor any new circumstances giving rise to potential conflicts of interest and to implement appropriate measures to address these. For the purpose of this Policy, a “personal transaction” is considered a trade in a financial instrument effected by or on behalf of a relevant person, where at least one of the following criteria are met: • the relevant person is acting outside the scope of the activities he carries out in his professional capacity; • the trade is carried out for the account of any of the following persons: o the relevant person; o any person with whom he has a family relationship, or with whom he has close links; o a person in respect of whom the relevant person has a direct or indirect material interest in the outcome of the trade, other than obtaining a fee or commission for the execution of the trade. The Company shall maintain separate accounting records between its own assets and those of its clients to facilitate the protection of clients’ assets and the prevention of the use of customer assets by the Company or by other third parties so as to minimise the risk of the loss or diminution of client assets, or of rights in connection with those assets, as a result of misuse of the assets, fraud, poor administration, inadequate record-keeping or negligence. In addition, the Company has legally secure segregation of clients’ assets from the Company’s assets in case the Company becomes bankrupt. For this purpose, the Company maintains separate books and accounting records for each client.