Conflict of Interest Avoidance and Management Policy

General Provisions

This Policy on Avoidance, Identification and Management of Conflicts of Interest of SOLIDUS Securities Investment Services Firm ("the Company") ("the Policy") sets out measures to identify and avoid conflicts of interest that may arise in the course of the Company's activities as an Investment Services Provider and that may adversely affect the interests of the Company's Clients. The Policy also sets out the measures that the Company shall take to appropriately manage conflicts of interest arising in the Company's business.

The Policy has been developed taking into account the nature, scale and complexity of the Investment Services provided by the Company, as well as the size and operational/business organization features of the Company.

This Policy is intended to reasonably ensure that, in relation to the Company's Clients, damage to their interests is avoided or, if this is not possible, adequately managed and minimized.

Considering the size of SOLIDUS Securities Investment Services Firm, as well as the nature, scale, and complexity of its business activities, the possibility of conflicts of interest arising cannot be ruled out in advance between:

a. The employed persons of SOLIDUS Securities Investment Services Firm and its Clients, and on the other hand
b. Among the Company's clients - existing or potential.

A Conflict of Interest may arise in cases where the following situations exist:

a. SOLIDUS Securities Investment Services Firm or its Employed Persons are likely to derive financial benefit, in providing the service to the Client.
b. SOLIDUS Securities Investment Services Firm or its Employed Persons have conflicting interests from those of the Client regarding the outcome of a transaction or the result of the investment or ancillary service provided to the Client.
c. SOLIDUS Securities Investment Services Firm or its Employed Persons have financial or other incentives to favor the interests of other Clients over the interests of another Client in providing the investment service.
d. SOLIDUS Securities Investment Services Firm or its Employed Persons engage in the same business activity as the Client.
e. SOLIDUS Securities Investment Services Firm or its Employed Persons receive or will receive from a person other than the Client remuneration related to the service provided to the Client, in cash, goods, or services, in addition to their usual fee or remuneration for providing that service.

Measures and Procedures

To prevent and address the above conflict of interest situations, the Company takes necessary organizational and administrative measures - taking into account the size of SOLIDUS Securities Investment Services Firm, the type of conflict, the services that are been provided and the scale and complexity of its business activities.

Management of Information within the Company

a. Separation of the individual functions and activities of SOLIDUS Securities Investment Services Firm into autonomous departments, each of which employs its personnel and is organizationally and spatially differentiated from the others.
b. Provision and enforcement of prohibitions and restrictions on the breach of this separation and supervision of compliance with the restrictions and prohibitions by a dedicated Compliance Officer of SOLIDUS Securities Investment Services Firm.
c. Autonomous management of the flow of information circulating within the separate departments of SOLIDUS Securities Investment Services Firm, so that each department operates unaffected by the information available to other departments.
d. Maintenance of a computerized system allowing the detection of access, movements, modifications, and interventions of each user of the information system (audit trail).

Providing Priority to Clients Interests.

In cases of existing conflicts of interest between SOLIDUS Securities Investment Services Firm and the Client, the Company gives priority to the interests of the Client.

Confidentiality Maintenance – Compliance of Company’s Personnel

The personnel of SOLIDUS Securities Investment Services Firm who have access to personal data, privileged information, or other confidential information, e.g., related to clients or client transactions, handle this information in accordance with the Company's Security and Personal Data Protection Policy and the law, and maintain the confidentiality of the relevant information. The personnel of SOLIDUS Securities Investment Services Firm are subject to continuous guidance and training regarding the Company's Policy and are evaluated for their compliance with it.

Personal Transactions

SOLIDUS Securities Investment Services Firm has established rules regarding the execution and control of personal transactions of its Employed Persons in financial instruments, including the monitoring of transactions carried out by them in financial instruments on which other clients of the Company transact.

SOLIDUS Securities Investment Services Firm takes necessary measures to ensure that:

a. Each Employed Person is aware of the restrictions regarding their personal transactions, as well as the measures established by SOLIDUS Securities Investment Services Firm in relation to them and the disclosure policy towards it.
b. SOLIDUS Securities Investment Services Firm is immediately informed of any personal transaction of an employed person, either by disclosing the transaction or by implementing other procedures that allow the identification of these transactions.

Exercise of Separate Supervision on Specific Persons

SOLIDUS Securities Investment Services Firm exercises separate supervision over the Employed Persons, who, in the course of their duties, may provide services to clients who have or represent conflicting interests with those of SOLIDUS Securities Investment Services Firm.

Priority and Timely Execution of Orders - Equal Treatment of Clients

During the registration and execution of client orders, SOLIDUS Securities Investment Services Firm takes necessary actions to ensure equal treatment of clients and adherence to the timely execution of client orders.

Provision of Additional Information

The Client is entitled to request additional information from SOLIDUS Securities Investment Services Firm regarding the administrative and organizational procedures adopted by it for the prevention and resolution of conflicts of interest. Accordingly, the Client will address the Customer Service Department. SOLIDUS Securities Investment Services Firm informs the Client accordingly, being able to reasonably refuse the provision of confidential information, e.g., if its disclosure could jeopardize confidential professional and business information regarding SOLIDUS Securities Investment Services Firm.

Policy Implementation – Review

SOLIDUS Securities Investment Services Firm monitors the implementation of the Policy and periodically reviews its effectiveness once annually, making changes when and where necessary.

Conflicts of Interest - Archive Maintenance

SOLIDUS Securities Investment Services Firm ensures the maintenance of an archive for every investment or ancillary service or activity conducted by the Company or on its behalf and (a) concerning which a conflict of interest has arisen, posing a substantial risk of harm to the interests of one or more Clients, or (b) concerning ongoing service or activity, where a conflict of interest may arise. SOLIDUS Securities Investment Services Firm ensures the maintenance of a record of personal transactions of Employed Persons, which are disclosed or identified by it, including any approvals provided by authorized persons for the execution of personal transactions or their prohibition.

Outsourcing

In case of outsourcing contracts, SOLIDUS Securities Investment Services Firm ensures that the service provider maintains a record of personal transactions of the Employed Persons and provides relevant information to the Company without undue delay after being requested.