Conflicts of Interest Policy

Introduction

The purpose of this Conflicts of Interest Policy (“the Policy”) is to outline a suitable approach
and response to the identification and management of conflicts of interest. Milton Global Ltd
(the “Company") will take all reasonable steps to identify conflicts of interest between itself,
including its managers, employees or any person directly or indirectly linked to the Company
by control and its clients or between one client and another that arise in the course of providing
any investment or ancillary services, or combinations thereof.

The Company maintains and operates effective organisational and administrative
arrangements to prevent and manage conflicts of interest that may arise during the provision
of any investment or ancillary 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 be prevented, 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,
the risks to the client with sufficient details so as to allow the client to take an informed decision
with the regards to its investment as well as the steps taken to mitigate such risks.

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 an annual 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.

Identification of potential conflicts of interest

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.

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 each situation will determine whether the interest in question is such as to bring
it within the area of potential conflict.

All employees, including management, will be responsible for identifying specific instances of
conflict and required to notify the Compliance function of any conflicts they become aware of.
The Compliance Officer (CO) will assess the implications of the conflict and how the conflict
should be managed in conjunction with the board.

For the purposes of identifying the types of conflicts of interest that arise in the course of
providing investment and ancillary services or a combination thereof 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 or ancillary services or investment activities:
• The Company or a relevant person is likely to make a financial gain, or avoid a financial
loss, at the expense of the client;
• The Company or a relevant person has an interest in the outcome of a service provided
to the client 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 of another client or group of clients over the interests of the client;
• The Company or a relevant person carries on the same business as 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 or services, other than the standard commission or fee for that service;
For the purpose of this Policy, a “relevant person”, in relation to the Company means any of
the following:
• a director, partner or equivalent, manager, or tied agent of the Company;
• a director, partner or equivalent, or manager of any tied agent of the Company;
• an employee of the Company or of a 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 investment services and activities;
• a natural person who is directly involved in the provision of services to the Company
or tied agent under an outsourcing arrangement for the purpose of the provision by the
Company of investment services and activities.

Managing conflicts of interest

The Company has established suitable and adequate internal procedures for minimising any
potential conflicts of interest. 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 and what the value of
the conflict or exposure is and the potential reputational risk. Compliance will then decide
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
conflict should be put in place and documented.

The Company will manage conflicts of interest fairly, between itself and its clients, between
itself and its employees and between its customers and to organise and control their internal
affairs responsibly and effectively.

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 of professional activities on the securities market. To ensure client’s fair treatment,
the Company will 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 to act.
• Employees are also prohibited to keep investor accounts in other Brokers without
Company’s prior authorization and are obliged to bring this to Company’s attention.
They are also obliged to authorize the Company to directly request transaction reports
from the other Brokers.
• 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 licensee shall not knowingly either advise, or deal in the exercise of
discretion, in relation to that transaction. The only exception is when the licensee has
fairly disclosed that material interest or relationship, as the case may be, to the client
or the client has taken reasonable steps to ensure that neither the material interest nor
relationship adversely affect the interests of the client.
• There is a clear distinction between the different departments’ operations as these are
described in 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 to identify such transactions. In the case of outsourcing
arrangements, the Company shall ensure that 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 on request.
• A person shall be replaced by another person in his/her duties only prior consent of
the Compliance Officer and approval by the Representative Officer. Such a consent
will be given by the Compliance Officer after all issues of possible conflict of interest
have been reviewed.
• 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 access to non-public or confidential information.
• Transactions by the Company’s employees are neither performed nor executed by
themselves, but by another member of staff of the Company concerning account
opened with the Company.
• A record shall be kept of the personal transaction notified to the Company or identified
by it, including any authorization or prohibition in connection with such a transaction.
• The Company must take reasonable steps to ensure that neither it nor any of its
employees or agents either offers or gives, or solicits or accepts, any inducement that
is likely to conflict with any duties owed to its clients.
• No employee shall either knowingly or recklessly make a statement, promise or
forecast that is misleading, false or deceptive to any customer or conceal material facts
at any time.

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 or ancillary
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.
• Measures to prevent or control the simultaneous or sequential involvement of a
relevant person in separate investment or ancillary services or activities where such
involvement may impair the proper management of the conflicts of interest.
• 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.
• Measures to prevent or control 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.

The procedures followed and measures adopted in the Policy include the following, as are
necessary and 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 in possession of inside information relating to that security.
• No relevant person may purchase or sell or cause the purchase or sale of a security
for an employee or employee-related account or a proprietary account of the Company
or an account over which an employee exercises investment discretion, while in
possession of proprietary information concerning a contemplated block transaction in
the security or for a customer account when such customer has been provided such
information by any relevant person.
• Procedures set for regular review and monitoring of the execution arrangements with
the execution 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 engaged in sales activities, or any person within or
outside the Company who does not have a valid 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 Compliance Officer prior to
distribution. The Compliance Officer also ensures that such communication have the
appropriate disclosure statement as well as meeting the relevant definition of
marketing communication.
• The four-eye principle is implemented to avoid any abuse of position.
• In order to minimize the relevant person’s own transactions personal account dealing
restrictions are in place.

Milton 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’s
employees are therefore required to monitor any new circumstances giving rise to potential
conflicts of interest and to implement appropriate measures to address these.

For the purpose of this Policy, a “personal transaction” is considered a trade in a financial
instrument effected by or on behalf of a relevant person, where at least one of the following
criteria are met:
• the relevant person is acting outside the scope of the activities he carries out in his
professional capacity;
• the trade is carried out for the account of any of the following persons:
o the relevant person;
o any person with whom he has a family relationship, or with whom he has close
links;
o a person in respect of whom the relevant person has a direct or indirect material
interest in the outcome of the trade, other than obtaining a fee or commission
for the execution of the trade.

Segregation of Company’s assets from clients’ assets

The Company shall maintain 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 the Company or by other third parties so as to minimize 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, poor administration, inadequate record-keeping or negligence. In
addition, the Company has legally secure segregation of clients’ assets from the Company’s
assets in case the Company becomes bankrupt. For this purpose, the Company maintains
separate books and accounting records for each client.

Forbidden Business Practices

The Company shall prohibit those business practices which in the regular course of events
might give rise 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 of Company’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, for the 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 of which the Company has drawn analysis reports or has made research
findings prior to the publication of the respective reports and findings.
• The preferential treatment of relevant persons to the detriment of its clients in the
course of the provision to them of investment or ancillary services.
• The carrying out of transactions by relevant persons for their own account or for the
account of persons related with them on the basis of confidential information that the
above persons have obtained in the course of their employment with the Company.

All employees must be aware of the above forbidden business practices, and shall have the
responsibility of informing the COMPLIANCE OFFICER immediately in case they monitor any
violation of the above provisions.
Should you have any questions in relation to the Company’s Conflicts of Interest Policy, please
contact the Compliance department of the Company.

Disclosure of conflicts of interest

In case where, the organisational and administrative arrangements established by the
Company to prevent or manage a conflict are not sufficient to ensure, with reasonable
confidence, that the risks of damage to the interests of the clients will be prevented, the
Company shall clearly proceed with the disclosure of such conflict.

Prior to carry out a transaction or provide an investment or an ancillary service to a client, the
Company should disclose any actual or potential conflict of interest to the client provided that
the measures taken by the Company are not sufficient to ensure that the risks of damage to
the interests of the client will be avoided.

The above disclosure shall include sufficient detail, taking into account the nature of the client,
source of conflicts of interest, the risks to the client to enable him to take an informed decision
with respect to the investment or ancillary service in the context of which the conflict of interest
arises. The Company reserves the right not to proceed with the transaction or matter giving
rise to the conflict if such disclosure is not sufficient to manage a conflict.

The Management and employees of the Company should disclose the following information
to the Compliance Officer:
• Opening and closing personal accounts at any other Broker for own investments
purposes
• All personal transaction performed. 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 a conflict