Conflict of Interest Policy

Policy Statement

The Company is committed to maintaining the highest standards of integrity and impartiality in all business dealings. This Conflict of Interest Policy aims to ensure that employees act in the best interests of the Company and avoid situations where personal interests could conflict, or appear to conflict, with Company obligations.

Objectives

• Define what constitutes a conflict of interest and outline examples.
• Establish procedures for identifying, disclosing, and managing conflicts.
• Promote transparency and accountability in all professional relationships.
• Safeguard the Company's reputation and stakeholder trust.

Scope and Applicability

This policy applies to all employees, officers, directors, contractors, and consultants of the Company It covers potential conflicts arising from financial, personal, family, or external business interests that may affect decision-making.

Definition of Conflict of Interest

A conflict of interest occurs when an employee's personal interests interfere or could appear to interfere with their ability to perform their duties objectively and in the best interests of the Company.

• Having a financial interest in a vendor, supplier, or competitor.
• Accepting gifts or favors that may influence business decisions.
• Engaging in outside employment that competes with the Company's business.
• Using Company property or confidential information for personal gain.
• Favoring relatives or friends in recruitment or contract decisions.

Disclosure and Management

Employees must disclose any actual, potential, or perceived conflict of interest as soon as it arises. Disclosure should be made in writing to the Department Head or Compliance Officer using the Conflict of Interest Declaration Form.

• The Compliance Department will review the disclosure and determine if a conflict exists.
• Appropriate mitigation measures will be implemented, such as reassigning duties or recusing the employee from specific decisions.
• All disclosures and resolutions will be documented and retained for audit purposes.

Responsibilities

• Employees: Identify and promptly disclose any actual or potential conflicts.
• Department Heads: Review disclosures and escalate significant cases to the Compliance Department.
• Compliance Officer: Maintain conflict of interest records, review reported cases, and recommend actions.
• Management: Foster a transparent environment that encourages disclosure without retaliation.

Consequences of Non-Disclosure

Failure to disclose a conflict of interest, whether intentional or unintentional, may result in disciplinary action, including termination of employment. In severe cases, legal action may also be pursued under applicable laws.

Policy Review

This policy shall be reviewed annually or as required by changes in business or regulatory conditions. Revisions shall be approved by the Board of Directors and communicated to all employees.

Employee Acknowledgment

I acknowledge that I have read and understood the Conflict of Interest Policy of the Company I agree to comply with its provisions and to disclose any actual or potential conflicts in a timely manner.

Employee Name: __________________________

Signature: ______________________________

Date: _________________________________