Conflict of Interest Policy

Definitecom Financial Brokerage Services L.L.C

Last updated: August 2026

1. Purpose

This Conflict of Interest Policy ('Policy') explains how Definitecom Financial Brokerage Services L.L.C ('Company', 'we', 'us' or 'our') identifies, prevents, manages and, where necessary, discloses conflicts of interest that may arise in the course of providing its services.

The Company is committed to acting honestly, fairly and professionally and to ensuring that the interests of clients take precedence over those of the Company or any Relevant Person in accordance with applicable laws and regulations of the United Arab Emirates, including those of the Capital Market Authority ('CMA').

This Policy does not form part of any contractual arrangement with clients and may be updated from time to time.

2. Scope

This Policy applies to all services, activities and business lines of the Company, as well as all directors, senior management, Approved Persons (being individuals approved by the Capital Market Authority to perform controlled functions within the Company), employees, interns, secondees, long-term temporary employees, outsourced employees and contractors on assignment (collectively referred to in this Policy as 'Relevant Persons').

3. What is a conflict of interest

A conflict of interest arises where, in the course of providing services, the interests of the Company, a Relevant Person, or another client compete with or diverge from the interests of a client, and this creates a material risk of damage to that client’s interests.

Conflicts may arise between:

(i) the Company and a client
(ii) a Relevant Person and a client
(iii) one client and another client
(iv) the Company and a third party, where this impacts a client.

A conflict may exist whether or not it results in financial loss and whether or not it is intentional.

4. When conflicts may arise

Conflicts of interest may arise in a variety of situations, including where the Company or a Relevant Person:

(i) may make a financial gain or avoid a loss at the expense of a client
(ii) has an interest in the outcome of a service or transaction that differs from the client’s interest
(iii) has an incentive to favour one client or group of clients over another
(iv) receives fees, commissions or other benefits from third parties
(v) has personal, financial or business interests that may conflict with those of a client.

Conflicts may also arise in connection with:

(i) relationships with affiliates, introducers, partners or service providers
(ii) relationships within the Company’s group, including where different entities within the group have competing interests or roles in a transaction
(iii) remuneration structures, including commissions, spreads or performance-based incentives
(iv) trading activities, including where the Company acts as principal or counterparty, or retains some or all resulting market exposure, hedges exposure with third-party liquidity providers, or where orders are aggregated or allocated across clients
(v) aggregation of client orders and allocation of trades, which may create a risk that one client is disadvantaged relative to another
(vi) situations where the Company or a Relevant Person trades in the same financial instruments as clients
(vii) situations where Relevant Persons have interests in financial instruments traded by clients.

The Company identifies conflicts on an ongoing basis, including during client onboarding, when introducing new products or services, or entering into new business relationships.

5. How we manage conflicts

The Company maintains effective organisational and administrative arrangements to prevent or manage conflicts of interest and to ensure that clients’ interests are not adversely affected.

These arrangements include, among others:

(i) clear organisational structures and segregation of duties
(ii) information barriers and controls governing the flow of confidential and, where applicable, inside information
(iii) supervision, escalation and monitoring mechanisms for identifying and managing conflicts of interest
(iv) controls designed to prevent Relevant Persons from being involved in activities where conflicts cannot be appropriately managed
(v) oversight by the Compliance function.

Where client orders are aggregated or allocated, the Company ensures that such processes are carried out fairly and do not operate to the disadvantage of any client.

The Company also maintains remuneration and incentive structures designed to avoid conflicts of interest, ensuring that remuneration is not structured in a way that creates inappropriate incentives or conflicts with the duty to act in the best interests of clients.

Where a conflict cannot be effectively managed, the Company will determine, in accordance with its internal policies and regulatory obligations, whether it is appropriate to proceed or to decline to act.

6. Disclosure of conflicts

Where the Company considers that its arrangements are not sufficient to ensure, with reasonable confidence, that risks of damage to client interests will be prevented, it will disclose the nature and/or source of the conflict to the client before undertaking the relevant business.

Any disclosure will be made in a clear, fair and not misleading manner and will include sufficient detail, taking into account the nature of the client, to enable the client to make an informed decision in relation to the relevant service.

Disclosure is a measure of last resort and does not replace the Company’s obligation to manage conflicts effectively.

However, the Company may also disclose conflicts of interest where appropriate in accordance with its internal policies and regulatory obligations.

7. Responsibilities

All Relevant Persons are required to:

(i) act with integrity, fairness and professionalism at all times
(ii) identify and avoid conflicts of interest where possible
(iii) promptly disclose any actual or potential conflict to the Compliance function, and
(iv) comply with this Policy and related internal policies.

Relevant Persons must ensure that their personal and external interests do not conflict with the interests of clients or the Company.

If a Relevant Person is uncertain whether a situation constitutes a conflict of interest, they must seek guidance from the Compliance function.

Failure to comply with this Policy may result in disciplinary action in accordance with the Company’s internal procedures.

8. Inducements, gifts and hospitality

The Company does not permit the offering or acceptance of any inducement that may impair independent judgement or create a conflict of interest.

The Company may give or receive fees, commissions or non-monetary benefits only where permitted under applicable laws and regulations and where theydo not impair the Company’s duty to act honestly, fairly and professionally in the best interests of the client.

Any gifts or hospitality must be reasonable, proportionate and consistent with applicable laws and internal standards.

9. Personal account dealing

Relevant Persons must ensure that personal investment activities:

(i) comply with applicable laws and internal policies
(ii) do not involve misuse of confidential or inside information,and
(iii) do not conflict with the interests of clients.

10. Outside interests

Relevant Persons must not engage in external business activities or hold interests that may give rise to a conflict of interest without prior approval from the Company.

11. Governance and oversight

The Board of Directors and Senior Management are responsible for ensuring that effective systems and controls are in place to manage conflicts of interest.

The Compliance function oversees the implementation and effectiveness of this Policy, including monitoring conflicts of interest, maintaining appropriate records, and reporting material conflicts to Senior Management where appropriate.

12. Record keeping

The Company maintains appropriate records of conflicts of interest and the measures taken to manage them, in accordance with applicable legal and regulatory requirements, which may include maintaining records such as a conflicts of interest register in accordance with internal procedures for a period consistent with applicable regulatory requirements.

13. Policy review

This Policy is reviewed periodically and may be updated to reflect changes in the Company’s activities or regulatory requirements.