CONFLICTS OF INTEREST POLICY
1. Introduction
1.1. FinTrade Limited is a limited liability company incorporated and registered under the laws of Mauritius,with Company number 0447 and whose registered address is at c/o Amicorp (Mauritius) Limited, 6thFloor, NeXTeracom Building, Ebene, Mauritius. The Company is authorized and regulated by theFinancial Services Commission in Mauritius (“FSC”) under the license number GB20025835 asInvestment Dealer (Full Service Dealer excluding Underwriting) (hereinafter referred to as the“Company”).
1.2. The Company is operating under the Securities Act 2005, the Financial Services Act 2007, theCompanies Act 2001, Securities (Licensing) Rules 2007, the Anti-Money Laundering and Combatting
the Financing of Terrorism and Proliferation (Miscellaneous Provisions) Act 2019 and 2020, theFinancial Intelligence and Anti-Money Laundering Act 2002, as amended from time to time (hereinafterreferred to as the “Applicable Laws, Rules and Regulations”).
1.3. In accordance with the Applicable Laws, Rules and Regulations, the Company is required to takereasonable steps to detect and avoid conflicts of interest and provide its clients with its Conflicts ofInterest Policy (hereinafter the “Policy”). The Company is committed to acting honestly, fairly andprofessionally and in the best interests of its clients and to complying, in particular, with the principles
set out in the above Applicable Rules and Regulations when providing its services.
2. Purpose and scope
2.1. The purpose of this Policy is to outline a suitable approach and response to the identification andmanagement of conflicts of interest. The Company will take all reasonable steps to identify conflicts ofinterest between itself, including its managers, employees or any person directly or indirectly linked tothe Company by control and its clients or between one client and another that arise in the course ofproviding services or between the Company and a relevant person of the Company or between a clientof the Company and a relevant person of the Company. Accordingly, this Policy sets out the necessary
procedures, controls and practices in place to ensure that any conflicts of interest are identified andprevented or appropriately managed.
2.2. The Company maintains and operates effective organizational and administrative arrangements toprevent and manage conflicts of interest that may arise during the provision of services, from adversely
affecting the interests of its clients. In case where, the aforementioned arrangements are not sufficient
to ensure, with reasonable confidence, that the risks of damage to the interests of the clients will beprevented, the Company shall clearly proceed with the disclosure of such conflict. The said disclosure
shall be done in a durable medium indicating the general nature and source of conflicts of interest, therisks to the client with sufficient details so as to allow the client to take an informed decision with theregards to its investment as well as the steps taken to mitigate such risks. Such disclosure shall be ameasure of last resort and shall include sufficient detail, taking into account the characteristics of theclient to enable that client to take an informed decision with respect to the service in the context ofwhich the conflict of interest arises.
2.3. The Company has the right to amend the current Policy at its discretion and at any time it considers
is suitable and appropriate. The Company shall review and amend the current policy at least on anannual basis to take account of changes to operations or practices and, further, to make sure it remains
appropriate to any changes in law, technology and the general business environment.
3.

Identification of conflict of interests

3.1. To adequately manage conflicts of interest, the Company shall identify all relevant conflicts timeously.
The Company will employ different mechanisms to ensure that all conflicts are identified.

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3.2. The Company shall identify all conflicts of interest, their severity and document controls to mitigate
the conflicts. It is not possible to list all situations which could constitute a conflict. The facts of eachsituation will determine whether the interest in question is such as to bring it within the area of
potential conflict.
3.3. All employees, including management, will be responsible for identifying specific instances of conflictand required to notify the compliance function of any conflicts they become aware of. The
Compliance Officer will assess the implications of the conflict and how the conflict should bemanaged in conjunction with the Board of Directors. In the case where a specific incident to bereported concerns the Compliance Officer, the notification shall be made to a member of theCompany’s management or as it is defined in the Law of Mauritius, the investment dealer team.
3.4. For the purposes of identifying the types of conflicts of interest that arise in the course of providing
services and whose existence may damage the interests of a client, the Company takes into account,by way of minimum criteria, the question of whether the Company or a relevant person, or a person
directly or indirectly linked by control to the Company, is in any of the following situations, whether
as a result of providing investment services or activities:••••The Company or a relevant person is likely to make a financial gain, or avoid a financial loss, atthe expense of the client;
The Company or a relevant person has an interest in the outcome of a service provided to theclient or of a transaction carried out on behalf of the client, which is distinct from the client's
interest in that outcome;
The Company or a relevant person has a financial or other incentive to favour the interest ofanother client or group of clients over the interests of the client;
The Company or a relevant person receives or will receive from a person other than the client,
an inducement in relation to a service provided to the client, in the form of monies, goods orservices, other than the standard commission or fee for that service.

3.5. For the purpose of this Policy, a “relevant person”, in relation to the Company means any of thefollowing:•••4.

a director, partner or equivalent, manager of the Company;a representative of the Company;
an officer or employee of the Company.

Procedures and controls to managing conflicts of interests

4.1. The Company has established suitable and adequate internal procedures for minimising any
potential conflicts of interest, ensure the fair treatment of all their customers and to reduce the risk ofclient disadvantage and legal liability.
4.2. The Company maintains a Compliance Department that is an independent unit within the Company.
Among the duties of the 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 andwhat the value of the conflict or exposure is and the potential reputational risk. Compliance will thendecide 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 conflictshould be put in place and documented.
4.3. The Company will manage conflicts of interest fairly, between itself and its clients, between itself andits employees and between its customers and to organise and control their internal affairs responsiblyand effectively.
4.4. 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 ofprofessional activities on the securities market. To ensure client’s fair treatment, the Company will

Email: info@xmtrading.com | Web: www.xmtrading.com | Address: c/o Amicorp (Mauritius) Limited, 6th Floor,NeXTeracom Building, Ebene, Mauritius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 toact.
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 Company
shall not knowingly deal in the exercise of discretion, in relation to that transaction. The onlyexception is when the Company has fairly disclosed that material interest or relationship, as thecase may be, to the client or the client has taken reasonable steps to ensure that neither thematerial interest nor relationship adversely affect the interests of the client.
There is a clear distinction between the different departments’ operations as these are describedin 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 toidentify such transactions. In the case of outsourcing arrangements, the Company shall ensurethat 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 onrequest.
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 accessto non-public or confidential information.
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 oragents either offers or gives, or solicits or accepts, any inducement that is likely to conflict withany duties owed to its clients.
No employee shall either knowingly or recklessly make a statement, promise or forecast that ismisleading, false or deceptive to any customer or conceal material facts at any time.

4.5. 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 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.
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 thoseactivities.
Measures to prevent or control the exchange of information between relevant persons engagedin activities involving a risk of a conflict of interest where the exchange of that information may
harm the interests of one or more clients.

4.6. The procedures followed and measures adopted in the Policy include the following, as are necessaryand 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 inpossession of inside information relating to that security.
Procedures set for regular review and monitoring of the execution arrangements with theexecution 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

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engaged in sales activities, or any person within or outside the Company who does not have avalid 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 ensuresthat such communication have the appropriate disclosure statement as well as meeting therelevant definition of marketing communication.
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’semployees are therefore required to monitor any new circumstances giving rise to potential
conflicts of interest and to implement appropriate measures to address these.

•••

5. Segregation of Company’s Assets from Clients’ Assets
5.1. The Company maintains 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 theCompany 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, pooradministration, inadequate record-keeping or negligence.
6. Forbitten Business Practices
6.1. The Company shall prohibit those business practices which in the regular course of events might giverise to conflicts of interest. The following business practices shall indicatively be forbidden:••••The provision to clients of investment services for the purpose of influencing the price of financial
instruments for the benefit of the Company or for the benefit of any relevant persons, or ofCompany’s clients in general, especially with regard to transactions that the Company or relevant
persons intend to carry out prior to or after the provision of the service.
The use by the Company or by its relevant persons of information regarding client transactions, forthe benefit of the Company, and the disclosure of such information to third parties.
Dealing by the Company itself or by any relevant persons in financial instruments in respect ofwhich the Company has drawn analysis reports or has made research findings prior to thepublication of the respective reports and findings.
The carrying out of transactions by relevant persons for their own account or for the account ofpersons related with them on the basis of confidential information that the above persons haveobtained in the course of their employment with the Company.

6.2. All employees must be aware of the above forbidden business practices, and shall have theresponsibility of informing the Compliance Officer immediately in case they monitor any violation of theabove provisions. Should you have any questions in relation to this Policy, please contact theCompliance Department of the Company.
7.

Disclosure of Conflicts of Interest

7.1. In case where, the organisational and administrative arrangements established by the Company toprevent or manage a conflict are not sufficient to ensure, with reasonable confidence, that the risks ofdamage to the interests of the clients will be prevented, the Company shall clearly proceed with thedisclosure of such conflict.
7.2. The management and employees of the Company should disclose the following information to the CO:••••

Opening and closing personal accounts at any other Broker for own investments purposes;
All personal transaction performed at any other Broker; notification should be provided within
24 hours;
Securities held by the employee;Transactions executed by the Company in which the employee may have an interest or aconflict.

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8. Record Keeping
8.1. The Company keeps and regularly updates a record in regards to the investment management andadvisory services or investment activity carried out by the Company in which a conflict of interest
entailing a material risk of damage to the interests of one or more clients. The following documentation
shall be maintained for a minimum period of seven (7) years:•••••

This Policy, any functional variations if applicable;
The conflicts log, the conflicts identification and its remedy;
Rules, procedures and processes;
Training material and training records;
Details of any review work carried out (including any decisions made on conflicts management);
and any other documentation used to demonstrate the management of conflicts of interest.

Email: info@xmtrading.com | Web: www.xmtrading.com | Address: c/o Amicorp (Mauritius) Limited, 6th Floor,
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