Conflict of Interest Policy

1. Policy Statement

Montrock Ltd is committed to identifying, managing, and where necessary disclosing conflicts of interest that may arise in the course of our business. We maintain a Conflicts of Interest Register that is reviewed quarterly.

2. Types of Conflict

Potential conflicts of interest may arise between: the company and its clients, between different clients, between employees and clients, and in the selection of counterparties and liquidity providers.

3. Management Controls

• Segregation of duties between front office and control functions
• Independent Risk and Compliance oversight
• Personal account dealing policy for all employees
• Gifts and hospitality register with monetary thresholds
• Disclosure of material conflicts to affected clients