Legal Documentation

1. Introduction

1.1 Hola Prime Markets (the "Company") is committed to conducting its business honestly, fairly, and professionally, in the best interests of its clients and in compliance with all applicable laws and regulatory requirements.

1.2 The Company recognises that conflicts of interest may arise in the course of providing investment and ancillary services — either between the Company (including its employees, directors or delegates) and a client, or between one client and another.

1.3 This Policy sets out the approach adopted by the Company to identify, manage and, where necessary, disclose conflicts of interest, to ensure that the interests of clients are not adversely affected.

2. Purpose & Scope

2.1 The purpose of this document is to establish procedures and controls for the effective identification, prevention and management of conflicts of interest which may present a material risk of damage to the interests of one or more clients.

2.2 This Policy applies to all directors, officers, employees, contractors, consultants, agents, delegates and any person directly or indirectly linked to the Company by control (collectively "Related Persons").

2.3 The Company will adopt appropriate organisational and administrative arrangements so that it can manage conflicts of interest effectively.

2.4 If the Company concludes that its arrangements are not sufficient to ensure, with reasonable confidence, that the risk of damage to a client's interests will be prevented, the Company shall provide clear, comprehensive disclosure to that client before undertaking the relevant business.

3. Identification of Conflicts of Interest

3.1 In assessing whether a conflict of interest may exist, the Company considers, at a minimum, whether a Related Person is or may be in any of the following situations:

a) Likely to make a financial gain, or avoid a financial loss, at the expense of a client;

b) Has an interest in the outcome of a service provided to a client or of a transaction executed on behalf of a client, which is different from the client's interest in that outcome;

c) Has a financial or other incentive to favour the interest of another client or group of clients over the interest of the client;

d) Engages in the same business as a client;

e) 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 standard commission or fee.

4. Procedures & Controls to Manage Conflicts of Interest

4.1 The Company has implemented procedures and controls for managing conflicts of interest, including but not limited to:

a) Identification of the services and activities carried out by or on behalf of the Company that may give rise to conflicts of interest;

b) Organisational and administrative measures designed to prevent or mitigate such conflicts, for example:

i) A "need-to-know" policy restricting access to confidential or inside information;

ii) Information barriers (Chinese walls) and physical or electronic segregation of functions or departments where appropriate;

iii) Separate supervision of persons whose principal functions involve carrying out activities for clients whose interests may conflict;

iv) Removal of direct remuneration links between staff whose activities could create conflicts;

v) Controls around personal account dealing by employees, officers or directors in instruments or markets in which the Company or its clients are active;

vi) Maintenance of a gifts, hospitality and inducements log recording offers, acceptance or provision of benefits by or to Related Persons;

vii) Prohibition (or requirement of prior approval) of outside business interests for Related Persons which are likely to create conflicts.

4.2 The Company monitors its business activities on an ongoing basis to ensure that its conflict-management arrangements remain appropriate and effective.

4.3 The Compliance Function is responsible for identifying and monitoring conflicts of interest, for maintaining records of actual or potential conflicts and for reporting to senior management.

5. Disclosure of Conflicts

5.1 In the event that the Company believes that its arrangements cannot ensure, with reasonable confidence, that the risk of damage to a client's interests will be prevented, the Company shall make a written disclosure to the client of:

a) The general nature and/or source of the conflict;

b) The risks to the client arising from the conflict; and

c) The steps taken to mitigate these risks.

5.2 The Company may decide not to proceed with the service or transaction if the conflict cannot be managed to the satisfaction of the Company and the client.

5.3 This Policy will be reviewed periodically (at least annually) by the Company, and may be amended from time to time. The most up-to-date version will be posted on the Company's website and made available to clients upon request.

6. Responsibilities & Enforcement

6.1 All Related Persons must be aware of this Policy and comply with its requirements.

6.2 The Compliance Function shall ensure that any breaches of this Policy are investigated promptly and that appropriate disciplinary or remedial actions are taken.

6.3 The Company prohibits retaliation against any individual who in good faith reports a potential conflict of interest or assists in an investigation.

7. Contact Information

HOLAPRIME LIMITED(CY) Limited is registered in the Republic of Cyprus under registration number HE 454359. Its registered office is located at 332 AGIOU ANDREOU, Limassol, Limassol 3035, CY.