Summary of Conflicts of Interest Policy

Policy Statement

Gate Technology FZE (“Company”, “we”, “us”, “our” or “ours”) conducts its business according to the principle that it must manage conflicts of interest appropriately. To do this, the Company and its staff must be able to properly identify a conflict of interest. As such, the Company has established a Conflicts of Interest Policy which sets out the Company’s internal policies for conflict of interest and includes those circumstances that have been identified by the Company as potentially giving rise to a conflict of interest which may damage the interests of clients. This Summary of Conflicts of Interest Policy (“Summary”) provides our clients with an overview of our stance on conflicts of interest, how we manage them and the register of conflicts of interests.

Objectives

In general, the Company undertakes to prevent the occurrence of adverse consequences for the Company and/or the clients as a result of the presence (the possibility of occurrence) of conflicts of interest. In the event that the Company cannot avoid conflicts of interest after using all reasonable efforts, it shall ensure that such conflicts of interest are disclosed to its affected clients, and such clients should be fairly treated by the Company.

Conflict of Interest

A conflict of interest is any situation in which a person or organisation is involved in:

(a) a direct or indirect financial interest;

(b) non-financial or personal interests; or

(c) competing loyalties between an organisation they owe a primary duty to and/or some other person or entity;

which could adversely influence the motivation or decision-making of that person or organisation to act in the best interest of clients or the Company. This could adversely affect the interests of the clients or the Company.

Even if not defined, a “conflict” includes situations in which the impartiality of an individual in discharging his/her duties could be called into question because of the potential, perceived or actual improper influence of personal, financial and other considerations on such individual’s discharge of his/her duties. Even a perception of competing interests, impaired judgement or undue influence may be damaging to the Company’s reputation.

The existence of an actual, perceived, or potential conflict of interest does not necessarily imply wrongdoing on anyone’s part. However, any private, personal, or commercial interests which give rise to such a conflict of interest must be recognised, disclosed appropriately and either eliminated or properly managed. Reporting, recording, and managing potential conflicts effectively protects Employees and can help to generate public trust and confidence.

Management of Conflict of Interest

The Company seeks to ensure that a conflict of interest does not adversely affect the interests of clients, the Company, its shareholders or other stakeholders through the identification, prevention or management of the conflict of interest. Some conflicts of interest are not permitted as a matter of law or regulation and others are permitted so long as the Company has appropriate means by which to manage them. The Company may utilise a number of means (which may be used individually or in combination) to manage a Conflict of Interest including:

(a) organisational arrangements such as segregation of duties;

(b) policies, procedures, systems and controls including but not limited to identification and escalation of a conflict of interest, maintaining a conflicts of interest register, setting up information barriers and establishing an approval process;

(c) disclosure designed to inform the affected parties of the conflict of interest and its likely impact on them, and, where applicable, obtaining consent from the affected parties; or

(d) avoidance of the service, activity or matter giving rise to the conflict of interest where the conflict of interest cannot be prevented or managed effectively usingother means.