CONFLICTS OF INTEREST POLICY

October 2025

Conflicts of Interest — Summary & How We Manage Them

We are committed to identifying, managing, and mitigating potential conflicts of interest to protect our clients' interests.

Potential Conflict Scenarios

1
When we route orders to liquidity sources
2
When we deal as principal in transactions
3
When we receive non-monetary benefits
Examples include:
Research services, preferential access to offerings, soft dollar arrangements

Our Management Controls

Segregation of duties and responsibilities
Best-execution controls and monitoring
Order routing oversight procedures
Disclosure of material benefits and arrangements
Client order handling standards
Personal dealing rules and restrictions
Governance escalation procedures

Disclosure basis: Broker-Dealer Rulebook, Part I(B)(1)(a). rulebooks.vara.ae