B2C2 Ltd and its subsidiaries (collectively, "B2C2”) are committed to identifying, mitigating, and managing conflicts of interest to protect the interests of clients and partners while avoiding regulatory or reputational risks. A conflict of interest arises when competing interests may affect fair and ethical business conduct. This policy covers conflicts between B2C2 entities; Clients, employees; vendors or suppliers, and/or third parties.

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B2C2 has key measures in place to manage conflicts which include the following:

• Conflicts Register: Potential and actual conflicts are documented, monitored, and escalated as needed.
• Information Control: Adherence to the "Need to Know" principle and establishment of ethical walls to safeguard sensitive information.
• Monitoring Mechanisms:
  • Electronic Communications Surveillance: Compliance monitors communication for potential conflicts.
  • Trade Surveillance: Monitoring of trades and quotes to ensure market conduct compliance.
• Pre-Approvals:
  • Gifts and entertainment require pre-approval for amounts exceeding thresholds.
  • Certain employees must seek pre-approval for personal account trading in relevant assets.
• Disclosure to Third Parties as a Last Resort: If conflicts cannot be adequately mitigated, they may be disclosed to clients or third parties.

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Additional policies are also in place, covering:

• Outside Business Interests: Employees must declare external roles, investments, or activities that could lead to conflicts.‍
• Personal Relationships: Disclosure and pre-approval are required for conflicts related to hiring or working with family, friends, or partners.‍
• Trading: Controls and oversight ensure conflicts from principal trading are addressed.

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To ensure appropriate governance in relation to conflict management, the respective B2C2 Chief Compliance Officers oversee the conflicts framework and report appropriately to the Board(s). Regular training is also provided to employees to recognise and manage conflicts effectively.

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For further information or queries, please contact regulatory@b2c2.com.