Conflicts of Interest Policy

This policy summarises how Robokapital identifies, prevents and manages conflicts of interest that may arise in the course of providing its services.

1. What is a conflict of interest

A conflict of interest arises where the interests of Robokapital, its staff or connected persons may differ from the interests of a client, or where the interests of two or more clients may differ.

2. Identification

We have identified situations that may give rise to conflicts, including acting as counterparty to client transactions, remuneration structures, personal account dealing by staff, and the receipt of inducements.

3. Measures

• Segregation of functions and information barriers between departments
• Remuneration policies that do not reward staff for outcomes contrary to clients' interests
• Rules on personal account dealing and on gifts and inducements
• Independent compliance and risk management functions
• Regular training and monitoring

4. Disclosure

Where the measures in place are not sufficient to ensure, with reasonable confidence, that the risk of damage to a client's interests will be prevented, we will disclose the nature and source of the conflict to the client before providing the service.

5. Review

This policy is reviewed at least annually. Further details are available on request.