CONTROL OF CONFLICTS OF INTEREST
To avoid conflicts of interest, the Company has implemented the following procedures. The procedures are constantly monitored and reviewed to implement corrective measures if any flaws are discovered.

In general, the procedures to be followed and measures to be taken to manage such conflicts in order to maintain the required level of independence include the following:

• Effective procedures for preventing or controlling the exchange of information between relevant persons engaged in activities that may result in a conflict of interest, where the exchange of that information may jeopardize the interests of one or more clients.
• Separate supervision of relevant persons whose primary responsibilities include carrying out activities on behalf of or providing services to clients whose interests may conflict, or who otherwise represent different interests, including those of the
  Company.
• The elimination of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of
  interest may exist.
• Measures to prevent or limit any person from wielding undue influence over the way a relevant person performs investment or ancillary services or activities.
• Measures to prevent or control a relevant person’s concurrent or sequential involvement in separate investment or ancillary services or activities where such involvement may impair proper conflict management.

More specifically, some of the procedures already established are as follows:

• Company employees must follow all rules, regulations, and directives issued by competent authorities, as well as the company’s code of ethics.
• Separation of duties that, if performed by the same person, may result in conflicts of interest.
• Gifts and inducements log, which records the solicitation, offer, or receipt of specific benefits.
• Company employees are strictly prohibited from trading for themselves on company’s platform or any other platform, whether directly or through an intermediary/related party, unless they obtain prior approval from management and their accounts are
  clearly labelled as employee accounts.
• Company employees must report any potential conflict of interest related to a proposed transaction to their supervisor.
• Company employees must report to their supervisor any special relationship they or any related party may have with a proposed transaction that may influence their decision-making.
• Company employees must consider commission rates as well as the ability to remain anonymous while minimizing market impact.
• Employees of the company must not trade on material non-public information. If an employee has material non-public information, he must report it to his supervisor or the compliance officer, and the financial instrument will be placed on the restricted or watch lists.
• The compliance officer documents and responds quickly to any compliance violations, taking appropriate disciplinary action on their own authority, independent of management as needed. If the compliance officer is unable to resolve any violations on his own, he should seek help from senior management, the Board of Directors, or outside counsel as needed. On a regular basis, the compliance officer should report violations and other issues related to the procedures to the Board of Directors or the supervisor.
• Physical division of departments. Information barriers will be put in place to prevent the communication of material information and other sensitive information in order to control the flow of such information.
• Procedures governing electronic data access. Material information will be restricted to those who need to know it in order to carry out their responsibilities