Conflict of Interest Policy

CONFLICTS OF INTEREST POLICY of Cambix S s.r.o.

This document has been amended for public consumption from the original internal version. Personal and confidential information has been removed.

Issuer: Chief Compliance Officer

Approved by: CEO

Purpose and scope

This policy outlines Cambix S s.r.o. (hereinafter - the Company) commitment to ethical conduct and client well-being. This simplified version applies to all website users and the Company’s employees, contractors, and leadership.

Understanding Conflicts of Interest

Individual Conflicts of Interest (CoI) arise when there are potential conflicts related to a specific employee's private interests or past or present personal or professional relationships. Such conflicts can also involve the interests of close family members or principals of the employee, to the extent that the employee is aware of them.

Consideration must be given to any personal or professional relationships from the past five years to assess whether an individual CoI exists. Examples of such conflicts include:

• Conflicts between an employee and a customer or customers of the Company.

• Conflicts between an employee and the Company itself.

• Conflicts that occur between different employees, including those involving management.

• Conflicts between an employee and third parties such as vendors or service providers.

Recognizing these potential conflicts ensures that all interactions remain transparent and in alignment with the Company's ethical standards. Employees are encouraged to disclose any suspected conflicts to maintain integrity and trust within the organization.

Identification of Conflicts of Interest

The Company must establish effective processes and controls to identify conflicts of interest. Each employee is responsible for recognizing CoI in their work and reporting them to their supervisor. The Company maintains a CoI register to document identified conflicts.

Subsidiaries and non-EEA branches manage their CoI registers locally and must provide extracts and relevant information annually or upon request from Group Compliance. The CoI register must be regularly updated, and both permanent organizational and individual CoI should be reviewed at least annually.

The annual review of organizational CoI includes each business area, department, and subsidiary evaluating their registered CoI to ensure all potential and existing conflicts are addressed. This review ensures that measures to manage CoI remain appropriate and effective in addressing conflicts arising from activities, including intragroup interactions.

Materiality of Conflicts of Interest

Each identified conflict of interest (CoI) must be evaluated for materiality, categorizing it as either material or non-material. The assessment of materiality should be conducted inherently, meaning it is evaluated prior to the implementation of any preventive or mitigating controls.

Materiality is determined based on the potential risk of harm it poses to the Company or its customers. A CoI is considered material when it is not insignificant and could reasonably lead to probable outcomes such as detriment to one or more customers, financial loss or liability for the Company, or reputational damage to the Company.

If a CoI is classified as material, it is imperative to implement mitigation measures, and corresponding Management Measures must be defined to address the conflict effectively.

Managing Measures

For all material conflicts of interest (CoI), effective managing measures must be defined and implemented. These measures include preventive or mitigating actions, with preventive measures prioritized first. If a CoI cannot be fully prevented, then mitigating actions should be employed.

Permanent CoIs require continuous or recurring managing measures that need to be reviewed at least annually to ensure their effectiveness. In contrast, non-permanent CoIs can typically be managed with one-time measures that address the specific instance of the conflict.

By establishing and maintaining these managing measures, the Company aims to effectively mitigate risks associated with conflicts of interest, ensuring compliance with internal policies and regulatory standards while protecting the interests of its customers.

Individual Conflicts of Interest Relating to External Engagements

The Company is committed to ensuring that employees' external engagements do not create material conflicts of interest, damage the Company's reputation, or adversely impact employees' work duties and capabilities. To this end, all external engagements require pre-approval from the employee’s direct supervisor.

Employees are prohibited from engaging in any external engagements that have not received prior approval, as well as from participating in offshore structures without explicit consent. It is the responsibility of each employee to seek approval from their supervisor for any external engagements before proceeding. Compliance should also be contacted for guidance before granting such approvals.

Any conflicts of interest arising from the roles or positions assigned to employees by the Company will be managed according to the principles governing institutional conflicts of interest. Employees are restricted from holding directorships in publicly traded or listed companies, competitor firms, or other entities involved in financial services. Furthermore, external directorships in family-owned businesses or trusts will be reviewed on a case-by-case basis and require approval.

By establishing these guidelines, the Company aims to maintain a high standard of integrity and accountability in all external engagements, safeguarding both its reputation and the professional responsibilities of its employees.

Disclosure to Customers

The Company acknowledges that it may not always be feasible to fully prevent or mitigate the risks associated with conflicts of interest (CoI) that may affect customers. In such instances, disclosure becomes a necessary measure to inform customers of the identified CoI and any residual risks that remain.

When providing investment services, distributing insurance-based investment products, or offering foreign exchange market services, disclosure should be employed only as a last resort, after all other potential measures have been thoroughly explored and deemed insufficient.

The disclosure must be documented in writing, including a clear explanation of the general nature and source of the CoI, as well as the specific actions taken by the Company to mitigate these risks. However, disclosure is not permissible if it could compromise the interests of one or more customers or involve the revelation of confidential information.

In cases where the Company engages in services or activities beyond the specified categories that pertain to corporate clients, disclosure of CoI can be utilized to ensure fair treatment and assist customers in making informed decisions regarding their engagements with the Company.

By adhering to these principles, the Company strives to maintain transparency and uphold its commitment to ethical practices while safeguarding the interests of its customers.

Reporting

The CEO and members of the Management Board (if elected) must receive annual reports on conflicts of interest (CoI) to ensure that all relevant conflicts are identified and managed effectively at the Company level. This reporting is essential for the CEO and the Management Board to oversee the successful implementation and ongoing maintenance of the directives related to CoI.

The annual report will provide insights into the CoI identified within the organization, detailing the measures taken to manage these conflicts and the effectiveness of those measures. This structured approach supports the Company’s commitment to transparency and accountability in its operations, enabling informed decision-making by the leadership team.

Roles and Responsibilities

All employees are required to report any identified CoI or changes to existing conflicts to their immediate supervisor or designated leader. Institutional conflicts of interest, along with any changes in circumstances regarding these conflicts, must be reported to the leader responsible for the unit or area affected by the CoI, such as the head of that unit. Such reporting must be done without undue delay to ensure timely management of the situation.

Consultants or individuals engaged in temporary assignments for the Company must also report any identified individual or institutional CoI to the relevant employee or supervisor overseeing their assignment. This individual will then be responsible for escalating the report in accordance with the procedures outlined earlier in this section.

The supervisor or leader receiving the CoI report is accountable for making decisions related to the management of the conflict and ensuring that all requirements set forth by this directive and supporting internal policies are followed appropriately.

Management Board Responsibilities

The Management Board, alongside the CEO, is accountable for establishing, approving, and overseeing the implementation and maintenance of effective policies to identify, assess, manage, and mitigate or prevent actual and potential conflicts of interest (CoI) at the institutional level. This includes considering the private interests of individuals subject to this directive.

The requirements related to external engagements do not apply to members of the Management Board. Members are prohibited from holding directorships in companies that compete with the Company unless those companies fall within the scope of prudential consolidation.

Members of the Management Board are required to proactively identify any CoI and disclose these without undue delay. If a conflict arises concerning the Chair, they must report it to the Chair’s alternate and the Board Secretariat. Additionally, members must recuse themselves from decision-making processes regarding matters that could be affected by the CoI.

In identifying and assessing CoI, it is important to consider not only actual conflicts but also the perception of conflicts. The ongoing requirement to identify emerging CoI is complemented by the suitability assessment of Board members, which also involves the identification and evaluation of individual CoI.

In instances where a material CoI is identified, the Chair of the Management Board will decide on appropriate preventive or mitigating measures, and where relevant, disclosures will be made to supervisory authorities. All identified CoI related to the Management Board or individual members must be documented accordingly.

CEO and Leadership Team Responsibilities

The CEO, in collaboration with the Management Board, holds the responsibility of establishing, approving, and overseeing policies that identify, assess, manage, and mitigate potential conflicts of interest at the institutional level, including addressing the private interests of individuals covered by this directive.

Each member of the Leadership Team is charged with ensuring the implementation of this directive and the accompanying guidelines within their respective areas of responsibility. This includes promoting effective CoI management, enabling objective decision-making, and preventing any detriment to the Company or its clients while appropriately managing intragroup conflicts.

When planning organizational changes, Leadership Team members are responsible for ensuring that these changes do not lead to increased CoI risk. Each member must also ensure that relevant training on conflicts of interest is delivered regularly to employees in their business area, fostering the skills necessary to identify both potential and actual conflicts and understand the reporting processes.

The CEO and each Leadership Team member are responsible for proactively identifying conflicts that may impact their roles and decision-making capabilities. Any identified CoI must be reported without undue delay to the CEO or their designated delegate. In situations where the conflict relates to the CEO, they must inform the Chair of the Management Board without undue delay. Each material CoI reported to the Chair of the Management Board or to the CEO should also be concurrently reported to the Chief Compliance Officer. Furthermore, any individual CoI or external engagement identified by a Leadership Team member or any direct report to the CEO must be reported to the Chief Compliance Officer.