CONFLICT OF INTEREST MANAGEMENTPOLICY
Original Issue Date:

December 2018

Approver(s):Board of Directors

Owner(s):Contact Person:
Classification:

TTCM TRADERS CAPITAL LIMITED
Chief Executive Officer

Operational Applicability:

Conflict of Interest Management Policy
All personnel & Clients

Last Revision Date:
Last Reviewed Date:

December 2019
December 2019

Next Review Date:
Version:December 2022
2

Other Languages:

N/A

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

TABLE OF CONTENTS
1.
2.
3.
4.

INTRODUCTION ................................................................................................................................ 4
DEFINITIONS..................................................................................................................................... 6
PURPOSE .......................................................................................................................................... 7
SCOPE OF APPLICATION .................................................................................................................... 8
A. SUBJECTIVE SCOPE OF APPLICATION .............................................................................................. 8
B. OBJECTIVE SCOPE OF APPLICATION................................................................................................ 8
5. IDENTIFICATION OF CONFLICTS OF INTEREST ..................................................................................... 9
A. GENERAL PRINCIPLES .................................................................................................................... 9
B. EMPLOYEES AND BUSINESS AREAS AFFECTED .............................................................................. 10
C. POTENTIAL SCENARIOS THAT COULD CREATE ‘CONFLICTS OF INTEREST’ ....................................... 11
a. Potential ‘Conflicts of Interest’ that may arise in providing the service of receiving andtransmitting Client Orders in relation to one or more financial instruments .............................. 11
b. Potential ‘Conflicts of Interest’ that may arise in providing the service of discretionary, individual
management of investment portfolios in accordance with powers given by Clients ................... 12
c. Potential ‘Conflicts of Interest’ that may arise in providing the service of investment research andfinancial analysis or other forms.............................................................................................. 13
d. Retrocession fees .................................................................................................................... 13
e. Inducements and gifts ............................................................................................................. 14
f. Other ‘Conflicts of Interest’ that may arise............................................................................... 14
6. PROCEDURES AND MEASURES TO AVOID AND, WHERE APPLICABLE, MANAGE CONFLICTS OF
INTEREST........................................................................................................................................ 14
A. GENERALLY ................................................................................................................................. 14
B. BRIEF SUMMARY OF ORGANISATIONAL MEASURES ..................................................................... 15
C. DETAILED DESCRIPTION OF MAJOR ORGANISATIONAL MEASURES ............................................... 17
a. Compliance Department.......................................................................................................... 17
b. Confidentiality and Information Barriers.................................................................................. 17
c. Chinese walls .......................................................................................................................... 18
d. Separate Supervision and Segregation of Functions ................................................................. 19
e. Training and Monitoring ......................................................................................................... 20
f. Clients’ Orders – Order execution Policy ................................................................................... 20
g. Clients’ Orders - Allocation Policy ............................................................................................ 21
h. Inducements to the Company from Clients ............................................................................... 21
i. Inducements to Employees from Clients ................................................................................... 22
j. Appropriate Procedures for monitoring Inducements ............................................................... 23
k. Remuneration Policy ............................................................................................................... 23
l. Investment Research Policy ..................................................................................................... 24
TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

m. Personal account dealing ........................................................................................................ 25
n. Insider trading and market manipulation (market abuse) ........................................................ 27
o. Restricted List ......................................................................................................................... 29
p. Outsourcing arrangements...................................................................................................... 29
7. DISCLOSURE ................................................................................................................................... 30
8. PROCEDURE FOR ACTING IN CASES IN WHICH A CONFLICT OF INTEREST SITUATION HAS ARISEN ...... 32
9. RECORD KEEPING ........................................................................................................................... 32
10. MISCELLANEOUS ............................................................................................................................ 34

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

CONFLICT OF INTERESTMANAGEMENT POLICY1.
1.1.

INTRODUCTION

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and
6/132C(1) of the Companies Act 1981, registered with the Registrar of Companies under Company
number 54135 and with registered address 5th Floor, Andrew’s Place, 51 Church Street Hamilton HM 12
Bermuda.

1.2. The Company is operating in accordance with the above mentioned Laws.
1.3.

The ‘Conflicts of Interest Management Policy’ must include the following content:
a. it must identify, with reference to the specific investment services and/or ancillary services carriedout by or on behalf of the Investment Company, the circumstances which constitute or may giverise to a ‘Conflict of Interest’ entailing a material risk of damage to the interests of one or more
Clients; andb. it must specify procedures to be followed and measures to be adopted in order to manage such
‘Conflicts of Interest’.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

1.6.

These procedures must be aimed at:a. preventing or controlling 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;
b. ensuring the separate supervision of Relevant Persons whose principal functions involve carryingout 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 Investment
Company;c. removing 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;
d. ensuring measures to prevent or limit any person from exercising inappropriate influence over theway in which a Relevant Person carries out investment services and/or other ancillary services, or
any combination thereof;e. ensuring measures to prevent or control the simultaneous or sequential involvement of a Relevant
Person in separate investment services and/or other ancillary services, or any combination
thereof, where such involvement may impair the proper management of ‘Conflicts of Interest’.

1.7.

The process must entail the following actions:a. Identification of ‘Conflicts of Interest’ situations;b. Management of ‘Conflicts of Interest’ situations;c. Disclosure of ‘Conflicts of Interest’ in instances where such situations cannot be contained;
d. Keeping and updating records of identified ‘Conflicts of Interest’ situations.

1.8. This policy:
a. identifies, with reference to the specific investment services and activities and ancillary services
carried out by or on behalf of the Company, the circumstances which constitute or may give rise
to a ‘Conflict of Interest’ and represents a material risk of damage to the interests of one or more
Clients;b. specifies procedures to be followed and measures to be adopted in order to manage such
‘Conflicts of Interest’;c. documents the Company’s commitment to acting honestly, fairly and professionally and in thebest interests of its Clients and to complying, in particular, with the principles set out in the above
TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

legislation when providing investment services and/or ancillary services, or any combination
thereof, related to such Services.
1.9. This ‘Conflicts of Interest Management Policy’ is not intended to, and does not, create third party rights
or duties that would not already exist if the ‘Conflicts of Interest Management Policy’ had not been
made available, nor does it form part of any contract between the Company and any Client.

2.

DEFINITIONS

2.1.

For the purposes of this Policy:
a. “Company” shall mean ‘TTCM Traders Markets Limited’
b. “Client(s)” shall include all existing and potential Clients of the Company, as well as any past Clientsof the Company where fiduciary or other duties remain in place, regardless of their categorization
as a ‘Retail Client’ or ‘Professional Client’ (see further below).
d. “Relevant Person” shall mean any of the following: (a) a director, partner or equivalent, manager
or appointed representative (or where applicable, tied agent) of the Company; (b) a director,
partner or equivalent, or manager of any appointed representative (or where applicable, tiedagent) of the Company; (c) an employee of the Company or of an appointed representative (orwhere applicable, tied agent) of the Company; as well as any other natural person whose services
are placed at the disposal and under the control of the Company or a tied agent of the Company
and who is involved in the provision by the Company of regulated activities; (d) a natural person
who is involved in the provision of services to the Company or its appointed representative (orwhere applicable, tied agent) under an outsourcing arrangement for the purpose of the provisionby the Company of investment services and activities.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

2.2.

Unless the context otherwise requires, any capitalized words and expressions not specifically defined inthis Policy, shall have the meanings assigned to them in the “Client Agreement – Terms and Conditionsof Business”, as published on the Company’s official Website(s).

3.

PURPOSE

3.1.

The purpose of this Policy is to set out the Company’s approach to identify and manage ‘Conflicts ofInterest’ which may arise during the course of its business activities.

3.2.

As such, this Policy is aimed at identifying, managing and, where possible, preventing ‘Conflicts ofInterest’ which may arise between or among:a. the Company and its Clients;b. the Company’s Clients and the Company’s management, employees and tied agents, including
persons directly or indirectly linked to the aforesaid by control; and/orc. the Company’s Clients themselves.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

3.3.

In particular, this Policy is aimed at:
a. identifying the circumstances that do or may give rise to a ‘Conflict of Interest’ involving a serious
risk of damage to the interests of one or more Clients;b. specifying the procedures and measures to be adopted to manage such ‘Conflicts of Interest’;c. setting the rules for keeping records of investment and/or ancillary services, or any combination
thereof, in which a ‘Conflict of Interest’ has arisen, or may arise, in the case of on-going investment
and ancillary services or any combination thereof.

3.4.

Please note that, despite the best of the Company’s efforts, some ‘Conflicts of Interest’ cannot be
eradicated all together, and in such instances, the Company has adopted a transparent and fairapproach of disclosing such instances as soon as they become apparent. Accordingly, as stated further
below, non-manageable ‘Conflicts of Interest’ will be disclosed to the Client so that the Client can judge,
in accordance with the Client's categorization, whether the Client wishes to avail him/her/itself of theinvestment and/or ancillary services provided by the Company.

3.5.

Alternatively, as stated further below, if the Company is of the opinion (a) that disclosure is not
appropriate to manage the conflict properly, and/or (b) that it is not able to manage the ‘Conflict ofInterest’ in any other manner, the Company may decline to act for the Client.

4.

SCOPE OF APPLICATIONA.

SUBJECTIVE SCOPE OF APPLICATION

4.1.

This Policy applies to all directors, employees and/or tied persons of the Company, including persons
directly or indirectly linked to the aforesaid by control, who are, directly or indirectly, connected with
the Company (hereinafter called “Relevant Persons”) and refers to all interactions with the Company’s
Clients.

B.

OBJECTIVE SCOPE OF APPLICATION

4.2.

For the purposes of identifying the types of ‘Conflicts of Interest’ that may arise in the course ofproviding investment services and/or other ancillary services, or any combination thereof, and whose
existence may damage the interests of a Client, the Company takes into account whether the Company
or any Relevant Person is in any of the situations described below, whether as a result of providing

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

investment services and/or other ancillary services, or any combination thereof, or otherwise(“Conflict(s) of Interest”).
4.3.

Thus, generally speaking, a ‘Conflict of Interest’ will be considered to exist in instances in which theCompany may make a financial gain when providing investment services and/or ancillary services, or
any combination thereof, which is in turn detrimental to one or more Clients, or in cases in which one
or more Clients make a financial gain or avoid a loss when there is the possibility of concomitant loss toanother Client.

4.4.

There will, in any event, be a ‘Conflict of Interest’ when any one of the following situations arise:a. the Company and/or any Relevant Person is likely to make a financial gain, or avoid a financial loss,
at the expense of a Client;b. the Company and/or any Relevant Person has an interest in the outcome of a service provided toa Client or of a transaction carried out on behalf of a Client, which is distinct from the Client's
interest in that outcome;c. the Company and/or any Relevant Person has a financial or other incentive to favour the interestof another Client or group of Clients over the interests of a particular Client;d. the Company and/or any Relevant Person carries out the same business as a Client;e. the Company and/or any Relevant Person receives or will receive from a person other than a 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.

5.

IDENTIFICATION OF CONFLICTS OF INTEREST

5.1.

Identifying ‘Conflicts of Interest’ up front is the first stage in safeguarding of the position of the Client.
Possible conflicts between different activities and/or interests must be identified before rendering
investment and/or ancillary services to a Client.

A.

GENERAL PRINCIPLES

5.2.

A ‘Conflict of Interest’ entails any situation subject to at least two factors that are in conflict with eachother, the Client for whom the investment service is being provided always constitutes one factor, while
the Company forms the other. Situations are nevertheless also conceivable in which several factors on
the Company’s side are in conflict with the Client's interests.

5.3.

‘Conflicts of Interest’ routinely require a balanced adjustment between objectives. The legal regulations
require the objective of independent and uninfluenced investment service provision for protecting andsafeguardingthe
Client's
interests
be
given
the
highestpriority.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

5.4.

As the Company offers a wide range of investment and/or ancillary services, such, ‘Conflicts of Interest’
may occur in particular due to different areas of activity, different investment services and ancillary
services or any combination thereof, and also due to collaboration with related companies.

5.5.

In particular, as previously indicated, ‘Conflicts of Interest’ may occur in the context of any of thefollowing relationships:
a. between or among the Company and its Clients;b. between or among the Company’s Clients and the Company’s management, employees and tiedagents, including persons directly or indirectly linked to the aforesaid by control; andc. between or among the Company’s Clients themselves.

B.

EMPLOYEES AND BUSINESS AREAS AFFECTED

5.6.

In the context of the wide array of investment and/or ancillary services offered by the Company,‘Conflicts of Interest’ may, by way of example, occur within the context of:a. the investment services and/or ancillary services, or any combination thereof, provided by theCompany to, for and/or on behalf of its Clients; in particular, the investment services and/or
ancillary services that are provided by the Company and in the context of which possible ‘Conflictsof Interest’ may arise, are the following:
Investment services:(i)

reception and transmission of Client Orders in relation to one or more financial
instruments.

(ii) execution of Orders on behalf of Clients.
(iii) discretionary portfolio and/or asset management services provided by the Company to,for and/or on behalf of its Clients, in accordance with powers given by such Clients, as theCompany may have a (revenue) interest in selling financial instruments, particularly thoseoffered by the Company;
Ancillary services:(i) safekeeping and administration of financial instruments on behalf of Clients;(ii) foreign exchange transactions associated with investment services;(iii) investment research and financial analysis or other forms.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

b. inducements (e.g. sales commission, trailer fees or other rewards with a monetary value) received
or granted by or to third parties (e.g. selling commissions) received from or paid to third parties)
in connection with investment services and/or ancillary services, or any combination thereof,
provided by the Company to, for and/or on behalf of its Clients;c. performance-related remuneration paid to the Company’s staff and intermediaries in connection
with investment services and/or ancillary services, or any combination thereof, provided by theCompany to, for and/or on behalf of its Clients;d.

inducements granted to the Company’s staff and intermediaries in connection with investment
services and/or ancillary services, or any combination thereof, provided by the Company to, for
and/or on behalf of its Clients;e.

commission trading in connection with services and/or ancillary services, or any combination
thereof, provided by the Company to, for and/or on behalf of its Clients Client business;f. the Company’s relationship with the issuers of financial instruments, e.g. financial relationship,
joint issues and cooperation;
g. the preparation of financial analyses on securities offered for sale to the Company’s Clients;h.

access and use of information obtained by the Company or the Company’s staff and/or senior
management, which is not in the public domain, i.e. the Company or the Company’s staff and/or
senior management obtaining information, which has not been published;i.

personal relationships of the Company’s staff and/or senior management, or of any persons
associated with them, or the participation of these persons, in supervisory or advisory bodies.

C.

POTENTIAL SCENARIOS THAT COULD CREATE ‘CONFLICTS OF INTEREST’

5.7.

With respect to the investment services and/or ancillary services mentioned, the Company has
conducted an analysis of certain potential scenarios that could create ‘Conflicts of Interest’:a. Potential ‘Conflicts of Interest’ that may arise in providing the service of receiving andtransmitting Client Orders in relation to one or more financial instruments
5.8.

Where the Company is providing the service of receiving and transmitting Client Orders in relation to
one or more financial instruments, ‘Conflicts of interest’ could arise in cases in which Orders are received
at the same time from different Clients for the purchase or sale of certain financial instruments, such as
equity securities, with no counterpart existing in the market for the different Orders.

5.9.

The Company may be paid inducements by fund companies and issuing houses as remuneration for thesale of their financial instruments. This may include portfolio volume dependent trailer fees paid by fundcompanies out of the respective management fees collected from investors and the sales commissions
paid by issuers of securities in the form of placement commissions, reductions on issue prices

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

(discount/rebate) and trailer fees. In order to avoid any ‘Conflicts of Interest’, in those instances where
the Company is paid inducements by fund companies and issuing houses as a remuneration for the saleof their financial instruments, the Company has decided not to retain inducements paid in favour of theCompany, but to pass such payments through to its Clients.
5.10. Furthermore, in some instances, the Company may receive non-monetary inducements from otherservice providers in connection with its investment business, e.g. financial analyses or other data,
training and sometimes technical services and equipment for access to third-party information anddissemination systems. These inducements are not directly related to services provided to Clients andthe Company uses them to provide the high-quality services that Clients expect. They allow on-going
improvements to the Company’s Services.
5.11. With respect to the transactions conducted via its online trading platform(s), the Company charges
commissions according to the conditions as agreed with its Clients. The level of commission is based on
and limited to the respective surcharge as defined in the Company’s current schedule of fees andservices, which is accessible on the Company’s Website(s).

b. Potential ‘Conflicts of Interest’ that may arise in providing the service of discretionary,
individual management of investment portfolios in accordance with powers given by Clients
5.12. Where the Company is providing the service of discretionary, individual management of investment
portfolios, Clients delegate asset management to one of the Company’s a portfolio managers and withit the decision to buy or sell individual financial instruments. The Company, through its portfolio
managers, decides whether to buy or sell assets on the basis of investment guidelines agreed with the
Client, but it does not obtain Client approval each time.
5.13. In these instances, ‘Conflicts of Interest’ could arise in the following instances:a. in the event of the purchase or sale of financial instruments on behalf of Clients in illiquid or nontransparent markets; in some instances, this could result in a large profit for the Company or for
another Client.
b. the fee received by the Company’s employees providing portfolio or asset management services
may be based on the performance of the Client's portfolio they are managing; in this instance,
there may be an implicit incentive related to the increase in performance, which could lead tosituations where managers, at the time of providing the service, do not take into account the risks
inherent in their investment decisions, leading to action that is contrary to the interests of a Clientor group of Clients;c. the Company is the discretionary portfolio manager for more than one Client – in particular inrespect of issues related to allocation.
5.14. As such arrangements may exacerbate existing ‘Conflicts of Interest’, the Company, in order to counterthe associated risks, has introduced appropriate procedures as in particular by an investment selection

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

process based on each individual Client profile. Furthermore, all inducements received within the scopeof a portfolio management related Client relationship are passed through to the Company’s Clients.
5.15. Performance-related pay is another area where there is a potential ‘Conflict of Interest’ where theCompany is providing the service of discretionary, individual management of investment portfolios.
Here, it is impossible to exclude the possibility that a portfolio manager may take disproportionate risks
in order to maximise his/her performance-related pay.
5.16. Measures to reduce this risk include the internal monitoring of investment decisions by staff andcombining performance-related pay and fixed remuneration, as set forth in the Company’s‘Remuneration Policy’.

c. Potential ‘Conflicts of Interest’ that may arise in providing the service of investment research
and financial analysis or other forms
5.17. Where the Company is providing the service of investment research and financial analysis, ‘Conflicts ofInterest’ could arise in the following instances:a. a unit of the Company may be carrying out research or assessments of instruments while
operating together with a unit of the Company providing other investment services, such as
discretionary portfolio management;b. the Company may produce research material, which is to be used to support the Company’s sales
and trading activities, but which may at the same time be distributed to the Company’s Clientsand to the Company’s associates or some other person connected to the Company.
5.18. Whenever the Company prepares or distributes financial analyses, it provides Clients with information
on potential and relevant ‘Conflicts of Interest’.

d. Retrocession fees
5.19. Retrocession fees are the kickbacks, trailer fees, finder's fees and other payments paid to advisers or
distributors from asset managers. These payments are made from Client money but are often notdisclosed to Clients. One criticism raised against retrocession fees is that the system encourages advisers
to promote funds or products because they will receive a fee and not because they are the most suitablefor end-investors.
5.20. Retrocession fees are not accepted by the Company. A situation in which a supplier of a product gives apercentage of the fees received from another company (e.g., a distributor of this product) will be treatedas a retrocession fee and will not be accepted by the Company. In order to be deemed acceptable, allfees, commission or profits paid or received in connection with an investment and/or ancillary service
must be designed so as to improve the quality of the service in question and must be shared with the
Client.
5.21. Additionally, profits paid or received by the Company must in no way affect the Company’s duty to act
in the best interest of the Client.
TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

e. Inducements and gifts
5.22. Gifts and entertainments offered by the Company’s Clients may influence the behaviour of staff
members in a way that conflicts with the interest of the company or the Company’s (other) Clients.
5.23. In some circumstances, such gifts and/or entertainment could place the Company in a situation where
it would not be in compliance with the general duty to act in accordance with the best interests of its
Clients.
5.24. This could, for instance, be the case when the Company holds itself out as getting the best deal for its
Client, and the inducement influences its placement of business in a way that is contrary to its Clients'
interests, or the Company is involved in settlement of claims and also receives a profit commission that
influences how it settles claims on behalf of its Clients in a way that is contrary to its Clients’ interests.

f. Other ‘Conflicts of Interest’ that may arise
5.25. Finally, managers, employees, brokers or persons directly or indirectly associated with the Company bya control relationship, may be subject to potential ‘Conflicts of Interest’ by virtue of their family,
economic or professional links, or for any other reason related to a procedure, service or transaction, in
instances in which:a. they may obtain a financial gain or avoid a financial loss, at the expense of a Client;b. they have an interest in the outcome of the service provided to a Client or the transaction
performed on their behalf, other than the interest of the Client.
5.26. The Company itself may have a ‘Conflict of Interest’ in instances where it purchases a financial
instrument for a Client and then sells it immediately to one of its other Clients or vice-versa.

6.

PROCEDURES AND MEASURES TO AVOID AND, WHERE APPLICABLE, MANAGE
CONFLICTS OF INTERESTA.

GENERALLY

6.1.

The second stage in mitigating ‘Conflicts of Interest’ is the setting up of an internal control framework.
This framework consists of several Compliance Procedures via which the position of the Company’s
Clients is safeguarded.

6.2.

Accordingly, the Company endeavours to manage any ‘Conflicts of Interest’ which may arise from time
to time, promptly and fairly and has in place internal policies, procedures and controls designed toprevent and manage ‘Conflicts of Interest’.

6.3.

These policies, procedures and controls, as well as the content of this Policy, are designed to ensurethat the persons involved in the different activities, which may give rise to a ‘Conflict of Interest’, as

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

specified above, carry on those activities at an appropriate level of independence, these policies,
procedures and controls as well as this Policy are subject to on-going monitoring and review.
6.4.

To ensure that external interests do not influence the Company’s Order execution, portfolio and/or
asset management, financial analyses, etc., the Company and its staff are under an obligation tomaintain high ethical standards. Diligence and integrity are expected at all times, as is behaviour that is
professional and within the law.

6.5.

In addition, the actions of the Company and its staff must comply with market standards and inparticular due regard must be given to the interests of the Client. The Company has an independent
Compliance Department under the direct responsibility of senior management, which is responsible forthe identification, avoidance and management of ‘Conflicts of Interest’.

B.

BRIEF SUMMARY OF ORGANISATIONAL MEASURES

6.6.

In general, the procedures and controls, which the Company follows to manage identified ‘Conflicts ofInterest’, include the following measures:
a. independence of business areas that do or may involve a ‘Conflict of Interest’ (separate businessareas), and for which the following measures have been taken:
b. effective procedures to prevent or control the exchange of information among the Company andRelevant Persons engaged in activities involving a risk of a ‘Conflict of Interest’ and/or reciprocallyamong such Relevant Persons, where the exchange of that information may harm the interests of
one or more Clients; establishment of physical separation barriers and computer barriers,
passwords to files, databases, emails, etc. understanding these barriers to be physical, electronic,or any other kind of element, to ensure that the areas or departments separated are watertightcompartments; establishment of regular checks and tests to ensure the effectiveness of theaforementioned barriers; functional separation of the employees assigned to the various
departments, especially those related to the provision of different investment or ancillary services;c. 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;d. 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; In this regard, remuneration criteria have been established at the Company thatreasonably ensure the objectivity and independence of the services provided, without favouring
the interest of one business area over another; furthermore, remuneration schemes within eacharea have been designed so as to avoid creating ‘Conflicts of Interest’ between the Company andits Clients.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

e. measures to prevent or limit any person from exercising inappropriate influence over the way inwhich the Company and/or Relevant Person carry out investment services and/or other ancillary
services, or any combination thereof;
f. measures to prevent or control the simultaneous or sequential involvement of the Company
and/or a Relevant Person in separate investment services and/or other ancillary services, or any
combination thereof, or activities where such involvement may impair the proper managementof Conflicts of Interest. Such measures include the following:(i)a ‘need to know’ policy governing the dissemination of confidential or inside information(a) within the Company, (b) among the Company and Relevant Persons and/or (c)reciprocally among Relevant Persons;(ii)

Chinese walls restricting the flow of confidential and inside information within the
Company, and physical separation of departments;(iii)

procedures governing access to electronic data;(iv)

segregation of duties that may give rise to ‘Conflicts of Interest’, if carried on by a single
individual;(v)

personal account dealing requirements applicable to Relevant Persons in relation totheir own investments;(vi)

a gifts and inducements policy and log registering the solicitation, offer or receipt ofcertain benefits;(vii)

the prohibition of external business interests conflicting with the Company’s interests,
insofar as the Company’s officers and employees are concerned, unless approved by theCompany’s Board of Directors;(viii) a policy designed to prevent ‘Conflicts of Interest’ arising from the giving and receivingof inducements;(ix)

establishment of a Compliance Department to monitor and report on the above to theCompany’s Board of Directors, which is responsible for identifying and managing
potential ‘Conflicts of Interest’, for up-dating the relevant internal policies andprocedures and for ensuring compliance with such policies and procedures;(x)

appointment of an Internal Auditor to ensure that appropriate systems and controls aremaintained and properly reported to the Company’s Board of Directors;(xi)establishment of the ‘four-eyes’ principle in supervising the Company’s activities.

g. measures designed to hinder the exchange of information between separate business areas:

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

(i)establishment of physical separation barriers and computer barriers, passwords to files,
databases, emails, etc. understanding these barriers to be physical, electronic, or any
other kind of element, to ensure that the areas or departments separated arewatertight compartments.

(ii)

establishment of regular checks and tests to ensure the effectiveness of theaforementioned barriers.

6.7.

The Company also undertakes the continuous and regular monitoring of its business activities in orderto ensure that internal controls are appropriate.

C.

DETAILED DESCRIPTION OF MAJOR ORGANISATIONAL MEASURES

6.8.

The most crucial measures, which the Company follows to manage identified ‘Conflicts of Interest’, aredescribed below in further detail.

a. Compliance Department
6.9.

In order to comply with its legal requirements, the Company has established an effective ComplianceDepartment to monitor compliance with its legal obligations, Internal Procedures and/or industry
practice, on a full time and exclusive basis.

6.10. Apart from preventing misuse of insider information and market manipulation, one of the core tasks of
the Compliance Department is to identify and manage ‘Conflicts of Interest’ (potential, apparent andexisting) and to monitor measures implemented within the Company and adapt them where required.

b. Confidentiality and Information Barriers
6.11. There are effective controls in place to manage the exchange of information between Relevant Persons
engaged in activities involving a risk of a ‘Conflict of Interest’. Information barriers also include
separation of premises, personnel, reporting lines, files and IT-systems.
6.12. The Company respects the confidentiality of Clients’ information by operating a “Need to Know”
approach such that access to Clients’ information is restricted to those Relevant Persons who have asincere requirement for the information consistent with the scope of their responsibilities.

c. Chinese walls
6.14. The establishment of Chinese walls between the Company’s various areas of confidentiality ensures thatthe dissemination or communication of confidential information is limited to the extent necessary inthe ordinary course of business (exceptions require special approval). All employees are bound by
confidentiality, responsibilities and reporting lines are clearly defined and the sequential involvementof a relevant person in separate investment activities that would lead to ‘Conflicts of Interest’ is avoided.
The spatial segregation of sensitive departments is also enforced.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

6.15. The primary function of Chinese Walls is to control access to material\price sensitive and non-public
information by generally insulating department activities from one another in order to prevent thepotential or perceived misuse of that information and thus their application is central in the
management and mitigation of potential Conflicts of Interest. They can also prevent the flow ofconfidential information internally and thus assist in ensuring that insider trading does not occur.
6.16. In order to comply with this principle, all of the Company’s personnel is expected to observe thefollowing simple, but yet extremely important rules:
a. company employees must refrain from discussing confidential information in public places suchas elevators, hallways, restrooms or at social gatherings;b.

unauthorised persons and members of staff of other departments are not allowed to enter thepremises of the Company or other departments unless accompanied and supervised by relevant
members of staff;

c. company employees must avoid using speakerphones in areas where unauthorized persons may
over-hear conversations;d.

where appropriate, employees should maintain the confidentiality of the identity of Clients byusing code names or numbers for confidential projects;

e.

company employees are expected to exercise care to avoid placing documents containing
confidential information in areas where they may be read by unauthorized persons and store such
documents in secure locations when they are not in use;

f. when documents containing non-public material information are to be disposed of, they shall be
destroyed by shredding or some other secure manner, which can prevent readable copies from
accidentally falling in the hands of non-insiders;g. company employees are expected to destroy copies of confidential documents no longer needed
for a project or not otherwise required to be maintained under legislation;h. associated persons engaging in meetings with corporate officers of companies for the purpose ofgathering information for research reports or follow-up meetings with companies, shall maintain
written notes of said meetings including but not limited to:

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

(i) the names of Company representatives and of corporate officers of the subject company
in attendance(ii) the time, date and location of the meeting(iii) the purpose of the meeting(iv) notes on the conversations that took place between the corporate officers and Company
representatives in attendance(v) copies of any hand-outs or other written material given to Company representatives inattendancei.

all of the Company’s records that may contain material non-public information, must be kept inlocked drawers and file cabinets; they shall only be removed when needed for working on thespecific transaction or Client, and shall be locked up each evening.

j.

all of the Company’s employees executing different types of professional activity are placed indifferent rooms according to the functional characteristics; if for any reason all members of staff
leave the room where they are located during working hours, the door is locked.

k. if it is not possible, due to lack of space, to place employees of different departments in separate
rooms, the Compliance Officer must ensure that PC monitors are kept beyond the sight of
employees from other Departments;l.

access to the premises and the computer network of the Company during weekends and on
holidays is granted only if prior permission by an authorised person is obtained in advance.

m. it must be ensured that jalousie or special curtains are used for obscuring visibility by by-passers
in the rooms situated on the lower floors;n. at the end of each working day, all computers and peripherals (computers, printers, and copiers)
are shut down.
o. in case of absence of an employee from his/her working place, access to the Company network issuspended until his/her return.

d. Separate Supervision and Segregation of Functions
6.17. The principle of segregation of duties adopted within the Company is fundamental to prevent potential‘Conflicts of Interest’ to adversely affect the interest of the Company’s Clients. Accordingly, theseprinciples are reflected in the Company’s organisational structures, procedures and internal control.
6.18. The Company further manages potential ‘Conflicts of Interest’ by ensuring that:

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

a. supervisory arrangements provide for separate supervision of employees where necessary for thefair management of ‘Conflicts of Interest’;b. functions which could potentially yield conflict situations are segregated by means of separate
reporting lines;
c. no single employee is simultaneously or successively involved in two different Services when thatposes a potential ‘Conflict of Interest’;d. as far as possible, a third party cannot improperly influence the decisions taken by employees thatprovide the Services;e. Chinese Walls are maintained to restrict exchange of information between different Units or
Departments within the Company.
6.19. Four-eye supervision is conducted on all relevant persons whose principal functions involve the carryingout of activities on behalf of, or providing services to, Clients whose interest may conflict, or who may
otherwise represent different interests that may conflict, including those of the Company.

e. Training and Monitoring
6.20. The Company insists that in its dealings with Clients its employees must use the highest standard ofintegrity in their actions at all times.
6.21. The induction, on-going training and monitoring programs organized by the Company and, in particular,
the Company’s Compliance department, are designed to ensure that all relevant staff are familiar withand observe, inter alia, all applicable rules and procedures in relation to the provision of the Services
provided by the Company.

f. Clients’ Orders – Order execution Policy
6.22. Clients’ Orders must be executed in compliance with the Company’s ‘Order Execution Policy’.
6.23. In order to ensure fair treatment on all Clients’ Orders, the Company’s Execution Policy requires its
employees to take all reasonable steps to achieve the best overall trading result for Clients; to exercise
consistent standards; and to operate the same processes across all markets, Clients and financial
instruments in which it operates.
6.24. No undue preference may be given to any Client when trades are aggregated.
6.25. The same types of Clients’ Orders must be executed according to the sequence of their receipt.
6.26. The Company treats its Clients fairly in accordance with the criteria that it introduces and notifies tothem. In case of differentiated treatment of the Company’s Clients in the course of provision to them ofinvestment or non-core services, this shall occur on the basis of objective criteria, such as the volume
TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

of transactions, the amount of capital under Company’s management, the category to which the Client
belongs (Retail Client or Professional Client) which will have duly been notified by the Company to its
Clients.

g. Clients’ Orders - Allocation Policy
6.27. It is our policy to offer allocations to Clients for whom the investment is suitable, or appropriate, whohave sufficient funds in their account on the commitment date and who understand the investment’s
terms and conditions and are willing to be bound by them (including any special considerations, suchas selling restrictions, which are generally for a limited period of time). Our policy is to allocate
investments on a pro rata basis wherever practicable.
6.28. In order to ensure that deals cannot be allocated in favour of one group of Clients or staff, we operatedealing and allocation procedures which cover dealing fairly and in due turn, and how allocations should
be made if insufficient stock is available. Similarly, we have strict Personal Account Dealing rules in place
to ensure that staff cannot deal on their own account ahead of those of our Clients, or in a manner
contrary to our Clients' interests (see further below).

h. Inducements to the Company from Clients6.29. The Company, in providing Services, must act honestly, fairly and professionally in accordance with thebest interests of a Client.
6.30. In so doing, the Company may (i) receive a fee, commission or a non-monetary benefit from the Client
or a person acting on the Client’s behalf or (ii) pay a fee, commission or other nonmonetary benefit toa Client or a person acting on the Client’s behalf.
6.31. The Company may also (i) receive a fee, commission or a non-monetary benefit, from a third party or aperson acting on behalf of such third party; or (ii) pay a fee, commission or a nonmonetary benefit to athird party or a person acting on behalf of such third party, if:a.

prior to providing the Service, the Company discloses to the Client in a manner which iscomprehensive, accurate and understandable, the existence, nature and amount of fee,
commission or non-monetary benefit or where the amount cannot be ascertained, the method of
calculating that amount; andb. the fee, commission or non-monetary benefit is designed to enhance the quality of the Service to
the Client and does not impair compliance with the Company’s duty to act in the Client’s bestinterests.
6.32. In addition, the Company may pay or receive proper fees which are necessary for the Company to beable to provide the Service and which by their very nature cannot give rise to conflicts with theCompany’s duty to act honestly, fairly and professionally in the best interests of the Client such as
custody fees, settlement and exchange fees, regulatory levies and legal fees.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

6.33. As such, the Company may be paid inducements by fund companies and issuing houses as remuneration
for the sale of their financial instruments. This may include portfolio volume dependent trailer fees paidby fund companies out of the respective management fees collected from investors and the salescommissions paid by issuers of securities in the form of placement commissions, reductions on issue
prices (discount/rebate) and trailer fees. In order to avoid any ‘Conflicts of Interest’, in those instanceswhere the Company is paid inducements by fund companies and issuing houses as a remuneration forthe sale of their financial instruments, the Company has decided not to retain inducements paid infavour of the Company, but to pass such payments through to its Clients.
6.34. Furthermore, in some instances, the Company may receive non-monetary inducements from otherservice providers in connection with its investment business, e.g. financial analyses or other data,
training and sometimes technical services and equipment for access to third-party information anddissemination systems. These inducements are not directly related to services provided to Clients andthe Company uses them to provide the high-quality services that Clients expect. They allow on-going
improvements to the Company’s Services.
6.35. With respect to the transactions conducted via its online trading platform(s), the Company charges
commissions according to the conditions as agreed with its Clients. The level of commission is based on
and limited to the respective surcharge as defined in the Company’s current schedule of fees andservices, which is accessible on the Company’s Website(s).

i. Inducements to Employees from Clients
6.36. The Company has adopted an ‘Inducements Handling Policy’, which defines its pricing policy in relation
to commissions, charges and other costs and expenditures required to provide investment and ancillary
services and products, in an accurate, clear and detailed manner, and provides that the Company does
not pay, accept or allows its personnel, management, executive staff members and other persons
working under contract for the Company to pay, provide or receive any direct or indirect fees,
commissions, discounts or non-monetary benefits from Clients or third parties acting on behalf ofClients, except for those clearly defined for each case.
6.37. Under the Company’s ‘Inducements Handling Policy’, the Company’s employees are prohibited fromoffering or receiving, soliciting or accepting any inducements, gifts, benefits, compensation orconsideration that reasonably could be expected to compromise their own or another’s independence
and objectivity. Employees are prohibited from soliciting gifts for themselves, their family members or
related parties. Attempts by suppliers, Clients or third parties to solicit gifts during the course of theirinteraction with the Company’s employees, should immediately be reported to the company’s
Compliance Officer.
6.38. Small gifts under €10 -, such as pens, calendars, rugby tickets, theatre tickets, are acceptable and must
be recorded by the employee in the gift register held by the Compliance Officer of the company within
thirty (30) calendar days of receipt

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

6.39. Any gift, gratuity or other benefit, for which an arms-length payment was not required, received byCompany employees and having a value in excess of €10,- must be pre-approved and disclosed in writing
to the Compliance Officer, within twenty-four (24) hours of receipt.
6.40. The Compliance Officer will be responsible for updating the gift register, within forty-eight (48) hours
after approval was given by the Compliance Officer.
6.41. The acceptance of receipt of cash (bank notes or equivalent) is specifically prohibited.
6.42. The acceptance of discounts in excess of normal commercial practice or free memberships is prohibited.

j. Appropriate Procedures for monitoring Inducements
6.43. The Company’s Compliance Department shall ensure, together with the Company’s senior
management, that all relevant inducements have been identified and classified in relation to theService being proposed and conform with all the above conditions.
6.44. Any changes to any inducements in relation to existing Services are to be communicated immediately
to the Compliance Department for its review and approval.

k. Remuneration Policy
6.45. The Company has adopted a ‘Remuneration Policy’, which contains measures to reduce the risk ofpotential ‘Conflicts of Interest’ through the internal monitoring of investment decisions by staff andcombining performance-related pay and fixed remuneration. In this regard, remuneration criteria havebeen established by the Company, which reasonably ensure the objectivity and independence of theservices provided, without favouring the interest of one business area over another.
6.46. The Company has eliminated any direct link between the remuneration of relevant persons principally
engaged in one activity and the remuneration of different relevant person principally engaged inanother activity, where a conflict of interest may arise in relation to those activities. Under theCompany’s ‘Remuneration Policy’, the remuneration of Relevant Persons principally engaged in one
Service is not directly linked to the remuneration or income of other Relevant Persons principally
engaged in another Service.
6.47. Furthermore, remuneration schemes within each area have been designed so as to avoid creating
potential ‘Conflicts of Interest’ between the Company and its Clients.
6.48. In line with its ‘Remuneration Policy’, the Company undertakes to ensure that it does not give incentives
to activities that may lead to ‘Conflicts of Interest’. The Company will not offer remuneration packages
that reward behaviour that disadvantages the interests of Clients in favour of the Company or other
Clients. Employees are rewarded on the basis of merit.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

l. Investment Research Policy
6.49. The Company’s staff involved in investment research and analysis is guided by an ‘Investment Research
Policy’, which provides, inter alia, that the Company’s employees are expected to maintain a high levelof ethics and integrity, and must declare any ‘Conflict of Interest’ that may arise in executing their job
duties.
6.50. The Company’s financial analysts and employees involved in investment research and analysis shallconduct their research and prepare their analysis following the principle of conscientiousness andfairness and with due professional care and diligence required from the persons who perform
investment research and analysis within their professional competence. In performing investment
research and analysis, the Company’s financial analysts and employees involved will, as much as
possible, rely on third party research limited to a small number of renowned foreign correspondents. It
is the responsibility of the Company’s financial analysts and employees involved in investment research
and analysis to perform their investment research and analysis based on the different opinions sourced.
6.51. The Company’s financial analysts and employees involved in investment research and analysis areprecluded under the Company’s ‘Investment Research Policy’, from accessing information from othersections of the Company for the purposes of performing their investment research and analysis. If asituation arises where this is inevitable, then the financial analyst and/or employee concerned isimmediately required to declare any possible ‘Conflict of Interest’ that may arise to his/her line
manager.
6.52. The Company’s financial analysts and employees involved in investment research and analysis are alsoprecluded from performing personal transactions or trading in financial instruments to whichinvestment research refers, or with any related financial instruments, until such time as the said
investment research is published or made available to the Clients or parties for whom this investment
research is intended. Furthermore, the general prohibition of trading with knowledge of the likely timingor content of a particular report prior to its publication is implemented (applicable to all employees) on
a Company wide basis.
6.53. The Company’s financial analysts and employees involved in investment research and analysis areprohibited from entering into personal transactions related to such investment research or any otherrelated financial instruments if this is in contradiction of current recommendations. As such, they areprohibited from trading contrary to current recommendations (except in exceptional cases related tofinancial distress of the said persons and then only subject to the express and prior approval of theCompliance Department).

6.54. In addition, the Company, as well as the Company’s financial analysts and/or employees involved ininvestment research and analysis and/or any other relevant person involved in the production of theinvestment research and analysis, are strictly prohibited from accepting any inducement, in whatever
form or circumstance, from those with a material interest in the subject-matter of the investment
research and, more in particular, are strictly prohibited from promising issuers or providing issuers
favourable research coverage.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

6.55. Finally, issuers and/or any other, relevant persons (other than the Company’s financial analysts and/or
employees involved in investment research and analysis) shall not, before the dissemination of any
investment research and/or analysis, be permitted to review a draft of the investment research and/or
analysis, except if the draft investment research and/or analysis includes a recommendation or a target
price, and then only for the purposes of verifying the accuracy of factual statements made in that
research, or for the purpose of verifying compliance with the firm’s legal obligations. In those instances,
any such review shall be conducted in the presence and under the supervision of the Company’s
Compliance Officer.

m. Personal account dealing
6.56. The Company has implemented personal account dealing rules and procedures regulating its
employees' own or associated persons’ transactions (PA dealings) are laid out in the Company’s‘Employee Manual’ and are aimed at preventing ‘Conflicts of Interest’ between Clients and its
employees or resolving them in the Clients’ interests. Under the Company’s personal account dealing
rules and procedures, restrictions on trading on personal account are imposed on Company employees
and persons associated with them in situations where a ‘Conflict of Interest’ might be created.
6.57. Personal account transactions (PA dealings) mean trades in a financial instrument effected by or on
behalf of a Relevant Person, where at least one of the following criteria are met:a. that relevant person is acting outside the scope of the activities he carries out in that capacity;b. the trade is carried out for the account of any of the following persons:(i) the Relevant Person;(ii) any person with whom he or she has a family relationship, or with whom he or she has
close links;(iii) a person whose relationship with the Relevant Person is such that the relevant person has
a direct or indirect material interest in the outcome of the trade, other than a fee orcommission for the execution of the trade.
6.58. It is prohibited to enter into a personal transaction which meets at least one of the following criteria:
a. that person is prohibited from entering into it;
b. it involves the misuse or improper disclosure of confidential information;c. it conflicts or is likely to conflict with an obligation of the Company;

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

d. advising or procuring, other than in the proper course of his employment or contract for services,
any other person to enter into a transaction in financial instruments:(i) which if a personal transaction of the Relevant Person, would be considered as aprohibited personal transaction, as described in the preceding paragraph; or(ii) with knowledge of the likely timing or content of an investment research report that iscurrently been drafted which is not publicly available or available to Clients and cannot bereadily inferred from information that is so available, until the recipients of the investment
research have had a reasonable opportunity to act on it;(iii) which is contrary to current recommendations;(iv) which would constitute misuse of information relating to pending Client Orders.
e.

disclosing, other than in the normal course of his employment or contract for services, any
information or opinion to any other person if the Relevant Person knows, or reasonably ought toknow, that as a result of that disclosure that other person will or would be likely to take either ofthe following steps:(i) to enter into a prohibited transaction, as described hereinabove;(ii) to advise or procure another person to enter into such a transaction.

6.59. In order to ensure the proper handling of PA dealing, the Company has put the following arrangements
in place:a. each Relevant Person is aware of the restrictions on personal transactions, and of the measuresestablished by the Company in connection with this requirement.
b. the Company is to 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;c. In the case of outsourcing arrangements, the Company ensures that the firm to which the activity
is outsourced maintains a record of all personal transactions entered into by any Relevant Person
and provides that information to the Company promptly on request.
d. a record is kept of the personal transaction notified to the Company or identified by it, including
any authorization or prohibition in connection with such a transaction.
6.60. In addition, it is the policy of the Company to request all employees to provide a list of all affiliations
either directly or indirectly with any publicly registered companies. Such listing shall include the nameof the company, the nature of the affiliation, the percentage (%) ownership (either direct or indirect),
and the date in which the affiliation first existed.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

6.61. Each employee of the company signs the PA declaration and the Declaration of secrecy within one week
upon joining the company.
6.62. Duplicate statements and confirmations from other registered investment firms for each employee of
the Company are obtained on a regular basis (currently, on a quarterly basis). The information containedin such duplicate account statements as well as the account statements for employee affiliated accounts
held at the Company, is reviewed by the Compliance Department.
6.63. The Compliance Department monitors transactions to identify any potential breaches of the Company’s
personal account dealing rules and procedures. Any transactions that are traded in close proximity to
being in violation of the Company’s personal account dealing rules and procedures are also investigatedby the Compliance Department. The results of the investigation are prepared in writing and forwarded
to the Company’s Board of Directors for their review.

n. Insider trading and market manipulation (market abuse)
6.64. As part of its ‘Employee Manual’, the Company has issued internal guidelines and rules of conduct which
serve to comply with the legal requirement of preventing market abuse (insider trading and market
manipulation) by the Company and its employees.
6.65. Certain information received by the Company in the course of its activities may be "inside" information
which prohibits the fraudulent misuse of such information in connection with the purchase or sale ofsecurities.
6.66. According to the Market Abuse Law, ‘Inside information’ denotes information of a precise nature which
has not been made public, relating, directly or indirectly, to one or more issuers of financial instruments
or to one or more financial instruments and which, if it were made public, would be likely to have asignificant effect on the prices of those financial instruments or on the price of related derivative
financial instruments.
6.67. It is provided that information which, if it were made public, would be likely to have a significant effecton the prices of financial instruments or related derivative financial instruments, includes any
information a reasonable investor would be likely to take into account in taking his investment
decisions.
6.68. Information may be classified as inside information if there is a substantial likelihood that a reasonable
investor would consider the information important in deciding whether to purchase, hold or sell asecurity. In other words, there must be a substantial likelihood that disclosure of the information would
have been viewed by a reasonable investor as having significantly altered the total mix of information
made available. Information may be inside information even if it relates to speculative or contingent
events.
6.69. It should be noted that one of the major changes brought about by the Market Abuse Law is that for
persons charged with the execution of orders concerning financial instruments, "inside information"

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

shall also mean information conveyed by a Client and related to the Client's pending Orders, which is ofa precise nature, which relates directly or indirectly to one or more issuers of financial instruments or
to one or more financial instruments, and which, if it were made public, would be likely to have asignificant effect on the prices of those financial instruments or on the price of related derivative
financial instruments.
6.70. The Company may be exposed to “inside information” in a number of ways. Such information may
derive from an external source such as a Client, prospective Client, or other third party with the
expectation that the Company will keep the information confidential and use it only for the benefit of
the Client or prospective Client.
6.71. When performing investment and/or ancillary services, or any combination thereof, employees of theCompany may obtain material/price sensitive and non-public information. Information is non-public
when it is generally not available to investors in the marketplace or when it has not been circulated to
the general public by means such as media article, press release or filing with the supervisory authority
or when there has not been a reasonable amount of time for the information to be absorbed in themarket.
6.72. The employees of the Company who come into the possession of such information are prohibited from:a. taking advantage of material/price sensitive and non-public information by buying or sellingsecurities;
b. recommending or procuring a third party to buy or sell the securities;
c. disclosing material/price sensitive and non-public information to a third party otherwise than in
the proper performance of the employee’s duties.
6.73. Where a business unit of the Company becomes aware of unpublished, price sensitive information, aconflict may arise between its duty to enforce the insider regulation and its duty to act in the bestinterests of its Clients. This conflict is in general to be resolved by not making use of the inside
information.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

o. Restricted List
6.74. One of the most important tools to prevent/manage conflict of interests is the so called ‘Restricted List’.
6.75. The purpose of the ‘Restricted List’ is to inform staff members where restrictions/restraints on tradeactivities exist with respect to certain securities’
6.76. An issuer and its securities may be placed on the ‘Restricted List’ for a variety of reasons, including, but
not limited to, the following reasons:a.

the Company or any affiliated entity or relevant Person possesses inside price-sensitive
information;b.

other reasons, including cases where trading in the security is banned in view of applicablelegislative requirements or if restriction is initiated by a respective exchange (bourse).

6.77. Depending on the grounds for placing a security on the Restricted List, some or all of the below indicatedrestraints may be imposed:
a. a prohibition on personal trading (PA dealings) by employees and affiliated entities or Relevant
Persons;b.

a prohibition on the issuance of research reports or imposing restraints on issuing research
reports;c. a prohibition on soliciting Clients’ business, particularly for securities sold out of a proprietary
position;d. other prohibitions/restraints;
6.78. Once a security is placed on the ‘Restricted List’, and for as long as it remains there, transactions on thesaid security are monitored (earmarked) and reviewed by the Compliance Department on a daily basis.
6.79. Any infringement of the restrictions/restraints that are imposed (PA dealings inclusive) are qualified asa serious violation and may result in disciplinary action.

p. Outsourcing arrangements
6.82. All outsourcing service providers have signed relevant agreements with the Company, which envisage
the keeping of records of personal transactions of their employees.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

7.

DISCLOSURE

7.1.

Stage three in mitigating potential ‘Conflicts of Interest’ is to be transparent towards the Clients withregard to the identified conflicts that might arise, or are about to arise when conducting business.
Possible measurements will be implemented in order to act in the best interest of the Client.

7.2.

The purpose of this is to enable the Client to decide whether he wants to avail of the service
nevertheless. This will only be possible if the information given provides a sufficient basis for making
such a decision and for this reason, sufficient details of the conflict must be given. The degree of detailentered into requires that a relative assessment of the interests of other Clients is also carried out.
Insider information must not be disclosed. Thus, prior to making any disclosure, it must be checked
whether the particular information could turn into insider information at some point.

7.3.

Furthermore, where the organizational or administrative arrangements described in this Policy are notsufficient to ensure with reasonable confidence that risks of damage of Client interests will be
prevented, the Company clearly discloses the general nature and/or sources of ‘Conflicts of Interest’ to
the Client before undertaking business on its behalf. Disclosures to Clients are done in sufficient detailto enable the Client to make an informed decision about the investment or ancillary service in thecontext of which the conflict arises.

7.5.

In the event of any potential or apparent ‘Conflict of Interest’ which the employee responsible for theprovision of the Company’s services to the Client knows or should have known and which has not been
disclosed to Clients, the Company, in accordance with the prevailing circumstances and before theconclusion of the transaction, informs the Client in writing or by any other equivalent means (e.g. byelectronic mail), either generally and/or in abstract or in connection with the specific transaction, in
respect of the risks of ‘Conflicts of Interest’ between the Client and the Company, or between the Clientand other Clients of the Company.

7.6.

Information disclosed to the Client may, for example, include reference to the following issues:a. any kind of benefits, especially indirect, that the Company may obtain from the provision of
investment or non-core services through the use of any third parties;b.

the fact that the Company offers for sale of financial instruments in which the Company or its
associated persons have vested interests (e.g. they possess or have a claim in the specific financial
instruments);

c. the fact that the Company offers for sale financial instruments in respect of which one of its Clientshas already issued a significant sale or purchase Order or in which the said Client conducts a large
volume of transactions.
7.7.

The following conditions should be met with regard to disclosure:a. disclosure should be provided to the Client at the time the arrangement is proposed;

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

b.

the notification should contain information about the existence, nature and amount of the fee,
commission or benefit, and to the service or product to which it relates or, where the amountcannot be ascertained, the method of calculating that amount to such an extent that the Client
can make an informed decision on whether to proceed with the investment or service.

7.8.

The Client’s account manager involved is responsible for informing the Client. Such disclosure must takeplace either in writing or in a permanent medium prior to conclusion of a commercial transaction.

7.9.

The Client should be informed pro-actively and in a timely manner. The written message has to include
the relevant details of the (possible) conflict of interest in order for the Client to evaluate theconsequences. The following elements are mandatory:
a. the nature of the (potential) conflict;b. the parties involved (on an anonymous basis were required) and their role regarding the(potential) conflict;c. the Company’s involvement/role regarding the (potential) conflict; andd. the measures of control that are in place.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

7.10. In any event the Company must adopt all expedient measures in order to ensure that the Client wishes
to proceed to the conclusion of the transaction, notwithstanding the ‘Conflict of Interest’ disclosed tohim or her.

8.

PROCEDURE FOR ACTING IN CASES IN WHICH A CONFLICT OF INTERESTSITUATION HAS ARISEN

8.1.

It is the responsibility of each and every employee of the Company to familiarise themselves with thisPolicy and to immediately disclose ‘Conflicts of Interest’ or potential ‘Conflicts of Interest.

8.2.

When there is a conflict of interest, the person who detected the situation must immediately notify
his/her manager and the Compliance Department. Notifications should be made in the shortest timepossible and, in any case, before taking any decision which might be affected by the possible conflict ofinterest.

8.3.

The Compliance Department will inform the Risk Management Department and senior management of
the Company of the matter and the Compliance Department, the Risk Management Department andthe senior management of the Company will then jointly agree on the necessary measures for the
management of such ‘Conflicts of Interest’, always putting the interests of Clients before those of theCompany.

8.4.

In the event that it is considered that the measures taken are not reasonably sufficient to avoid the riskthat a Client’s interests may be harmed, the Client will be informed about the nature of the conflict andany other circumstances that will allow them to make an informed decision about the investment
service to be purchased from the Company, in each instance accordance with the provisions of Section
7 hereinabove.

9.

RECORD KEEPING

9.1.

The Compliance Department will arrange for the recording of any ‘Conflict of Interest’ in an appropriate
and separate ‘Conflicts of Interest’ register, and will inform the Risk Management, senior management
and Board of Directors of the Company of the matter and of any action taken.

9.2.

The information contained within the register will be kept for a minimum of five (5) years, with any
changes made in it will also being kept for the same period of time.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

notification shall be deemed as sufficient notice and it is your duty to consult and/or to check regularly
this ‘Conflicts of Interest Management Policy’ on our Website(s) regarding any such Changes. Therefore,
you should review this ‘Conflicts of Interest Management Policy’ from time to time so as to ensure thatyou will be aware of any such Changes.

10. MISCELLANEOUS
10.1. This ‘Conflicts of Interest Management Policy’ is not intended to, and does not, create third party rights
or duties that would not already exist if the ‘Conflicts of Interest Management Policy’ had not been
made available.
10.3. Should you have a question about ‘Conflicts of Interest’ at the Company, please direct your questions
to our Compliance Department: compliance@traders-trust.com.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.