Conflict of Interests – FundBank (Europe) S.A.

Our declared objectives relating to Conflict of interests are the below:

• identify situations where potential, perceived or real conflict of interests may arise, entailing a material risk of damage to the client’s interests
• where relevant, inform client about conflict of interests
• establish appropriate procedures, mechanisms and systems that allow, to the greatest extent possible, to prevent the occurrence of real conflict of interests and to have appropriate measures and procedures for managing conflicts of interests that cannot be avoided
• maintain records of such conflicts of interests, including potential or perceived conflict of interests.

In case you would like to obtain more information on the Bank’s approach towards Conflict of interests, please address your request to your Relationship Manager.

CONFLICT OF INTEREST POLICY (KEY ELEMENTS)

1. SCOPE

In accordance with its legal and regulatory obligations, FundBank (Europe) S.A. (hereafter the “Bank” or “FundBank”) has established a Policy concerning the preventing, detecting and managing of conflict of interest (“the Policy”) which, among other things, has the purpose of detecting conflict of interest that may arise in connection with its provision of services to clients.

This document presents the key elements and summarises the principles of the Policy, which relates to all the rights and/or obligations of the employees of the Bank (temporary and permanent including the Board of Directors).

In addition, the Policy also concerns the Bank’s clients in the context of protecting their interests in their dealings with the Bank.

2. OBJECTIVES

In the course of its activities, the Bank maintains and implements the organisational and administrative provisions necessary to take all appropriate measures to prevent conflicts of interest from occurring.
The Policy is intended to identify circumstances which, in the context of the investment services and activities and other services that the Bank provides, give rise or are likely to give rise to a conflict of interest that could harm the interests of one or more clients.

It defines the procedures to be followed and the measures to be taken to manage these conflicts of interest by establishing principles and rules to be followed by Employees so that conflicts of interest are prevented, identified and managed at each hierarchical level.

The Policy defines notably the roles and responsibilities of the different stakeholders in the identification, assessment, management, mitigation, monitoring and reporting of conflicts of interest.

3. DEFINITION

A conflict of interest might arise during the normal course of business as a result of the interaction between FundBank, members of its Management Bodies, its employees and its clients and/or third party sub-contractors, where there is a risk that the interest of one is or could be impaired or influenced by a secondary interest. Conflicts of interest may be actual, potential (i.e. reasonably foreseeable) or perceived (i.e. by the public).

Conflicts of interest are defined as conflicts

• between the Bank (including its Employees) and its clients,
• between two clients during the provision of any investment service, ancillary service or combination of these services that could harm clients’ interests,
• between the Bank and its Employees, or
• between the Bank and its business partners (suppliers, subcontractors, counterparties

A conflict of interest could occur, for example, if the Bank or an Employee:

• stands to make a financial gain or avoid a financial loss at the expense of a client;
• has an interest in the outcome of a service provided to or transaction carried out on behalf of the client that is different from the client’s interest in that outcome;
• is led, for financial or other reasons, to favour the interests of another client or a group of clients over those of the client concerned;
• has the same professional activity as the client;
• receives or will receive from a person other than the client a benefit in connection with the service provided to the client, in the form of money, goods or services, other than the commission or charges normally invoiced for that service.

4. HANDLING OF CONFLICTS OF INTEREST

The conflict of interest handling measures introduced by FundBank include notably :

• an appropriate segregation of tasks and activities to guarantee a strict separation between operational management and financial intermediation entities;
• physical measures, such as access control systems for the employees and the retaining of documents in secure locations;
• operational measures, such as the 4 eyes principle;
• the introduction of a code of conduct and Ethics
• the continuous raising of the employees’s awareness of the applicable policy and their obligation to report any potential or proven conflicts of interest directly to the Compliance function or by using the whistleblowing system.

5. IDENTIFICATION

All employees are required to take all reasonable steps to identify conflict of interest which may arise and should take all reasonable steps to prevent or mitigate the conflict of interest or its effect.

The Bank has implemented a methodology of identification and analysis of conflict of interest situations.

The Compliance function supports the other departments in the identification of potential conflicts of interest and is responsible for monitoring them.

The Compliance function maintains a conflict of interest register, which shall set out all existing potential or actual conflicts of interest and the procedure for managing and mitigating them. The register is reviewed annually by the Authorised Management and the Board of Directors.

6. REPORTING AND ESCALATION

Any party/employee who becomes aware of a potential or actual conflict of interest or becomes a conflicted person shall report immediately the potential or actual conflict of interest to the Compliance function in accordance with the Policy.

The Compliance function will enter non material conflicts of interest into the register, including measures taken in order to manage it fairly and appropriately.

Conflicts of interest, which are material in nature, either by impact on the concerned Client, potential value or potential reputational risk, the Compliance function will escalate it to the Authorized Management, who will decide on the appropriate course of action or escalate to the Board of Directors if deemed necessary.

The Compliance function always has the possibility to address issues directly to the Board of Directors in case where necessary.

7. COMMUNICATION

If the arrangements put in place to manage conflicts of interest are not sufficient to ensure with reasonable confidence that the risk of damage to the interests of a party will be prevented, the general nature and sources of the conflict of interest must be disclosed to the involved party(ies).

8. RESPONSIBILITITES

It is the responsibility of the Authorized Management to ensure that the Bank organises itself, designs and implements the Policy (as approved by the Board of Directors) and measures defined

This includes training employees to ensure that they are able to identify situations where conflict of interest may exist and report them to the Compliance function.

The Compliance function is responsible for the ongoing maintenance, review and monitoring of the Conflict of Interest Policy.