CONFLICT OF INTEREST POLICY

As a principle, the Company is required to manage any situation of conflict of interest fairly, both between itself and its Clients and between a Client and another Client. The Board of the Company shall at all times be independent from that of any entity to whom it assumes an advisory role. It is acknowledged that the services of the Company to any of Clients will not be exclusive.

The policy with regards to conflicts of interest has been put in place to ensure that when a potential or actual conflict of interest arises, the Company pays due regard to the interests of each of the Clients and manage any such conflict of interest fairly.

The responsibilities of the Directors and the Officers of the Company with regards to avoiding conflicts of interest include:

• The Directors and the Officers shall promote, at all times, the best interests of Clients in accordance with the law;
• The Directors and the Officers shall make a prompt and full disclosure to the Board of the Company any situation or relationship which might involve a conflict of interest, including any relation to activities with Clients;
• The Directors and the Officers must provide the Board of the Company with information on any outside interests, or interest which The Directors and the Officers proposes to enter into, which are in conflict with the obligations and duties to the Company or its Clients.