Conflicts Policy – Introduction As a financial institution, Hantec Markets Limited (hereafter “HML”) faces actual and potential conflicts of interest from time to time. By identifying the existing and potential conflicts of interest, HML endorses all reasonable steps to establish, implement and maintain an effective conflict of interest policy to prevent any risk that may damage the interests of our customers. This statement discloses the conflicts of interest you, as an existing or potential customer, might face when engaging in business dealings with HML; the laws and regulations subject to conflicts of interest that HML is required to comply with; and the policy HML adopts for the aim of preventing and managing the conflicts of interest. Laws and Regulations Conflicts of interests exist in the financial services industry and the Code of Business Conduct issued by the Mauritius Financial Services Commission recognises that whilst situations of conflict of interests must be avoided, in case a conflict arises, customers should be treated fairly. Furthermore, as a licensee of the Mauritius Financial Services Commission under the Securities Act 2005, HML is required to manage the conflicts so that they do not damage the customers’ interest. Identification and Examples of Conflicts that might arise In general, conflicts of interest may be caused by the superior knowledge of employees and the variety of products on offer and may arise between a firm and a customer, or between a customer and another customer. When a firm provides service to a customer, conflicts of interest may arise in one or more of the following situations when a firm or a relevant person: is likely to make a financial gain, or avoid a financial loss, at the expense of the customer; has an interest in the outcome of a service provided to or a transaction carried out on behalf of the customer, which is different from the customer’s interest in that outcome; has financial or other incentives to favour the interest of another customer(s) over the interests of the customer; carries on the same business as the customer; or receives or will receive from a person other than the customer an inducement, other than standard commission or fee in relation to a service provided to the customer. In respect to HML, the following is the main conflict of interest that may occur when providing services to our customers. Hantec Markets Limited Policy As required by law, HML implements and maintains an effective conflict of interest policy for the aim of preventing conflicts of interest or potential conflicts of interest from causing a material risk of damage to the interests of customers. HML keeps records of our business activities so that we can identify any conflict that might arise that would have a material risk of damage to the interests of our customers. HML’s conflicts of interest policy adopts procedures and measures to manage and control the conflicts of interest identified, including segregation of duties and responsibilities; separate supervision of relevant persons; Personal Account Trading policy, Gifts and Inducement policy, prevention and control of the exchange of information; acting on the best interest of the customers; and in some cases declining to act for a customer or potential customer. Hantec Global Policy As required by law, HG implements and maintains an effective conflict of interest policy for the aim of preventing conflicts of interest or potential conflicts of interest from causing a material risk of damage to the interests of customers. HG keeps records of our business activities so that we can identify any conflict that might arise that would have a material risk of damage to the interests of our customers. HGs’ conflicts of interest policy adopt procedures and measures to manage and control the conflicts of interest identified, including segregation of duties and responsibilities; separate supervision of relevant persons; Personal Account Trading policy, Gifts and Inducement policy, prevention and control of the exchange of information; acting on the best interest of the customers; and in some cases declining to act for a customer or potential customer. Disclosure Whilst HML is devoted to implement and maintain our conflicts of interest policy, in some cases, such policy might not be sufficient to prevent risks of damage to the interest of a customer. In such a case, HML shall disclose the general nature and sources of conflicts of interest to the customer so that enables the customer to make an informed decision whether to proceed with the transaction in question. Review HML is devoted to providing more services and products to meet our customers’ demand. At the same time, HML frequently reviews and assesses our conflicts of interest policy so that can ensure the adequacy of such policy in compliance with applicable law.