Conflict of Interest Policy

Introduction

No member of ABIGTL management or Staff shall derive any personal profit or gain, directly or indirectly, due to his or her participation with ABIGTL. This shall also include the member's business or other nonprofit affiliations, family and/or significant other, employer, or close associates who may stand to receive a benefit or gain. Each individual shall disclose to the ABIGTL senior management and Managing Director (MD) any personal interests which he or she may have in any matter pending before the organization and shall refrain from participation in any discussion or decision on such matter.

In addition, any member of ABIGTL senior management, Affiliates or employees shall refrain from obtaining any list of clients or brokers for personal or private solicitation purposes at any time during the term of their affiliation.

Purpose

This conflict of interest policy is put in place to ensure that ABIGTL's clients are treated fairly and at the highest level of integrity and that their interest upheld. This policy covers interactions and possible sources of conflict between:

a) ABIGTL and a Client;

b) Any ABIGTL employee or affiliate and a Client; or

c) Between two or more clients of ABIGTL.

ABIGTL will make sufficient efforts to identify circumstances which may give rise to conflicts of interest entailing a material risk of damage to its clients' interest and has established appropriate mechanisms and systems to manage those conflicts, and design systems to prevent damage to its clients' interests through identified conflicts.

Identification of Conflicts of Interest

ABIGTL will take adequate steps to properly identify conflicts of interest. For the purposes of identifying the types of conflict of interest, ABIGTL takes into account the question of whether ABIGTL, its employees or affiliates, directly or indirectly, whether as a result of providing or receiving services, are likely to - make a financial gain or avoid a financial loss at the expense of the client, have an interest in the outcome of a service provided to the client, have a financial or other incentive to favor the interest of one client over another or receives any kind of inducement apart from the standard commission or incentive.

Managing Conflicts of Interests

ABIGTL maintains and operates effective organizational and administrative procedures to identify and manage conflicts of interest. Any instance of conflict of interest brought directly or indirectly to its attention will be managed promptly and fairly. ABIGTL will ensure that processes are in place to ensure:

  1. Clear distinction between the different departments' operations;
  2. Information is not aggregated in the hands of few individuals, thus counterfeiting or hiding information from investors is minimized;
  3. Non-involvement of a concerned parties in activities where such involvement may impair the proper management of conflicts of interest is prevented or controlled;
  4. Separate supervision of concerned parties whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of ABIGTL;
  5. No direct link between the remuneration of concerned party principally engaged in one activity and the remuneration of, or revenues generated by, different concerned party principally engaged in another activity, where a conflict of interest may arise in relation to those activities;
  6. Employees are prohibited from investing in securities for which they have access to non-public or confidential information;
  7. Concerned parties are prohibited to recommend or solicit the purchase or sale of any security while in possession of inside information relating to that security;
  8. Concerned parties are prohibited to purchase or sell a security on behalf of another employee or employee-related account, while in possession of proprietary information concerning a contemplated transaction in the security or for a customer account when such customer has been provided such information by any relevant person;
  9. Employees sign a confidentiality agreement. No associated person may disclose inside information to others, except disclosures made in accordance with ABIGTL policies and procedures, to other personnel or persons outside ABIGTL who have a valid business reason for receiving such information;
  10. Effective procedures in place to prevent or control the exchange of information between concerned parties engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients;
    1. Information is recorded promptly in a secure environment to enable identification and management of conflicts of interests;
    2. Adequate records are maintained of the services and activities of the Company where a Conflict of Interest has been identified;
Information barriers

ABIGTL understands and respects the confidentiality of information it receives about its Clients and operates on a need-to-know approach and complies with all applicable laws in respect of the handling of that information. Access to confidential information is restricted to those who have a proper requirement for the information consistent with the legitimate interest of a client.

Separate supervision and functions

ABIGTL will provide for a clear distinction between the different departments' operations. Two departments or businesses will be managed by different senior staff members, if running them under supervision of one person, may create conflicts of interest.

Policies and procedures

ABIGTL has developed and implemented policies and procedures throughout its business to prevent or manage potential conflicts of interests. Its employees receive regular guidance and training in these policies and procedures, and they are subject to monitoring and review processes.

Remuneration Policy

Remuneration and bonuses are linked to the profits of the Company or the business or department where an employee works. Remuneration and benefits linked to the performance of another department, with possible conflicting interests, will be avoided at all times.

Gifts and Inducements

ABIGTL, its affliates or employees will not accept any gifts other than those considered normal in their line of business. ABIGTL also does not offer, solicit or accept any inducements. ABIGTL will only charge, proper fees for the provision of investment services, such as custody costs, settlement and exchange fees, regulatory levies or legal fees, and which cannot give rise to conflicts with ABIGTL's duties to act honestly, fairly and professionally in accordance with the best interests of its clients

Personal account dealing

To prevent conflicts arising from the use of information obtained from clients, and market abuse in general, all employees are subject to personal account dealing rules. ABIGTL requires all its employees to have their personal account trades approved before dealing to ensure that dealing does not occur in securities in circumstances where such dealings should be restricted. All employees will be regularly updated on the restrictions on personal transactions, and of the measures established by ABIGTL in connection with personal transactions and disclosure. ABIGTL must also be informed promptly of any personal transaction entered by a relevant person, either by notification of that transaction or by other internal procedures enabling ABIGTL to identify such transactions. ABIGTL will maintain a record of all such personal transactions notified or identified by it for a period it may so deem fit.

Disclosure requirement by ABIGTL

In cases where ABIGTL does not possess data or information to ensure, with reasonable confidence, that risks of damage to client interests will be prevented, ABIGTL may choose to decline a transaction or arrangement. It may also choose to, where confidentiality considerations permit, disclose the general nature and/or sources of conflicts of interest to the client or potential client before undertaking business on its behalf, in order to enable that client to take an informed decision with respect to the investment or ancillary service in the context of which the conflict of interest arises.

Periodic Review by ABIGTL

ABIGTL reserves the right to review and/or amend its conflict of interest policy and arrangements whenever it deems appropriate. It shall review and amend, if needed, this policy at least on an annual basis. ABIGTL will maintain an updated copy of its conflicts of interest policy posted on its Website.

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