Conflict of Interest Policy

1. Purpose

This policy sets out the arrangements VenturoFX Ltd has in place to identify, prevent, and manage actual or potential conflicts of interest that may arise in the course of providing investment services.

2. Identification of Conflicts

We have identified the following situations where conflicts may arise:

• Between the firm and a client
• Between two or more clients
• Between the firm and its employees or tied agents
• Between different business units within the firm

3. Management & Prevention Measures

To manage conflicts, we employ the following measures:

• Strict information barriers (Chinese walls) between departments
• Clear remuneration policies that do not create incentives for unsuitable recommendations
• Segregation of duties and independent oversight
• Personal account dealing policies for employees
• Gifts and inducements policy with strict approval requirements
• Regular conflict of interest training for all staff

4. Disclosure

Where organisational or administrative arrangements are not sufficient to ensure that risks of damage to client interests will be prevented, we will clearly disclose the general nature and/or sources of the conflict to the client before undertaking business on their behalf.