Conflict of interest policy

In accordance with the requirements of the European Directive on Markets in Financial Instruments 2014/65/EC (“MiFID II”), Tendercapital Ltd has established policies and procedures to identify and manage conflicts of interest in order to ensure fair and ethical treatment for all the clients.

These policies and procedures aim to observe and maintain Tendercapital high standards of integrity, fair dealing and market conduct in the course of its business and in providing services to clients. The overall aim is to prevent conflicts of interest from arising by foreseeing circumstances and relationships between Tendercapital and its associates or between Tendercapital clients that could potentially result in a material risk of damage to the interests of clients. If a conflict is identified, Tendercapital will take all reasonable steps to mitigate against the conflict or in the unlikely event that a conflict of interest cannot be avoided, the Company will disclose details of such conflict to a client, or potential client or decline to act.

Tendercapital ensures that all employees are adequately informed of their duties under these policies and procedures.