Conflicts of Interest Policy

1. Policy Statement

DB Finser recognises that conflicts of interest may arise in the course of our business activities. This policy establishes a framework for identifying, preventing, managing, and disclosing conflicts of interest to ensure that our clients' interests are protected and that we maintain the highest standards of integrity and professionalism.

We are committed to taking all reasonable steps to identify conflicts of interest that may arise between DB Finser and our clients, between our employees and our clients, or between different clients. Where conflicts cannot be avoided, we will manage them appropriately and make full disclosure to affected clients.

2. Definition of Conflicts of Interest

A conflict of interest arises where DB Finser, or any of our directors, employees, or other relevant persons, has an interest in a transaction or arrangement which may compete with or compromise the interests of a client.

2.1 Types of Conflicts

Conflicts of interest may arise in various forms, including but not limited to:

• Conflicts between DB Finser's interests and client interests
• Conflicts between different clients' interests
• Conflicts between employees' personal interests and client interests
• Conflicts arising from inducements or financial incentives
• Conflicts in allocation of investment opportunities
• Conflicts arising from personal account dealing

3. Identification of Conflicts

DB Finser maintains systems and controls designed to identify potential conflicts of interest. These include:

3.1 Regular Risk Assessments

We conduct regular risk assessments to identify areas where conflicts of interest may arise, considering:

• Our business activities and services
• Our organisational structure
• Our compensation and incentive structures
• Relationships with third parties
• Personal account dealing by employees

3.2 Specific Conflict Scenarios

We specifically monitor for conflicts that may arise from:

• Acting as principal in transactions with clients
• Receiving fees or commissions from third parties
• Allocation of limited investment opportunities among clients
• Aggregation of client orders
• Employee personal trading activities
• Relationships with affiliated companies

4. Prevention and Management Measures

Where conflicts of interest are identified, DB Finser implements appropriate measures to prevent or manage them effectively.

4.1 Organisational Measures

We implement organisational arrangements to prevent conflicts, including:

• Chinese walls and information barriers between different business areas
• Separation of functions that may give rise to conflicts
• Independent supervision and monitoring
• Clear reporting lines and accountability

4.2 Operational Measures

Operational controls include:

• Policies on personal account dealing
• Gifts and entertainment policies
• Remuneration policies that do not create inappropriate incentives
• Clear procedures for order allocation and aggregation
• Transparent pricing and fee structures

5. Disclosure of Conflicts

Where conflicts of interest cannot be adequately prevented or managed through organisational or operational measures, DB Finser will disclose the conflict to affected clients.

5.1 Disclosure Requirements

Disclosure will be made in a durable medium and will include:

• The nature of the conflict
• The risks arising from the conflict
• The steps taken to mitigate the conflict
• Clear, fair, and not misleading information
• Sufficient detail for the client to make an informed decision

5.2 Timing of Disclosure

Disclosure will be made in a timely manner, before we undertake business on behalf of the client, to allow the client to make an informed decision about whether to proceed with the service.

6. Personal Account Dealing

DB Finser maintains strict policies regarding personal account dealing by employees to prevent conflicts of interest with client interests.

6.1 Employee Trading Restrictions

Employees are subject to the following restrictions:

• Pre-clearance requirements for personal trades
• Blackout periods during sensitive information periods
• Prohibition of front-running client orders
• Restrictions on trading in instruments related to their work areas
• Mandatory reporting of personal trading accounts

6.2 Monitoring and Compliance

All employee personal trading is monitored by the Compliance Department, with regular audits conducted to ensure compliance with personal account dealing policies.

7. Inducements and Gifts

DB Finser maintains strict policies regarding inducements, gifts, and entertainment to prevent conflicts of interest.

7.1 Receiving Inducements

DB Finser will only accept fees, commissions, or non-monetary benefits from third parties if:

• They are designed to enhance the quality of service to the client
• They do not impair compliance with our duty to act in clients' best interests
• They are properly disclosed to clients
• They are reasonable in proportion to the service provided

7.2 Providing Gifts and Entertainment

Gifts and entertainment provided to clients or third parties must be reasonable, proportionate, and not designed to influence decision-making. All gifts and entertainment above de minimis thresholds must be pre-approved and recorded.

8. Order Handling and Allocation

DB Finser maintains fair and transparent procedures for handling and allocating client orders to prevent conflicts of interest.

8.1 Order Allocation Policy

Client orders are allocated according to the following principles:

• Fairness among clients
• Timeliness of order receipt
• Size of the order
• Client instructions, if any
• Prohibition of preferential treatment

8.2 Aggregation of Orders

When aggregating client orders, we ensure that allocation is made on a fair and equitable basis. Aggregated orders will only be executed if it is unlikely to work to the disadvantage of any client whose order is included.

9. Record Keeping

DB Finser maintains comprehensive records of conflicts of interest identification, management, and disclosure.

9.1 Records Maintained

We maintain records of:

• Conflict of interest risk assessments
• Identified conflicts and their management
• Disclosures made to clients
• Employee personal trading approvals and records
• Gifts and entertainment provided or received
• Order allocation decisions

9.2 Retention Period

All conflict of interest records are retained for a minimum of five years from the date of creation, in accordance with regulatory requirements.

10. Training and Awareness

All DB Finser employees receive regular training on conflicts of interest, including:

• Identification of potential conflicts
• Requirements of this policy
• Procedures for reporting conflicts
• Personal account dealing restrictions
• Gifts and entertainment policies

New employees receive conflict of interest training as part of their induction, and all employees receive annual refresher training.

11. Policy Review and Monitoring

This Conflicts of Interest Policy is reviewed at least annually by the Compliance Department, or more frequently if there are significant changes to our business activities or regulatory requirements.

The effectiveness of our conflicts of interest management is monitored through regular compliance reviews, internal audits, and management oversight. Material changes to this policy require approval by the Board of Directors.