PurposeThe purpose of this procedure is to describe how FXC (hereinafter "FXC" or "the Company") identifies and manages conflicts of interest that may arise through the Company's activities, and how the Company seeks to limit conflicts of interest to a minimum.

DefinitionsConflict of interest: A conflict of interest is a situation where there is a conflict between the interests of the Investment Firm and our customers, or between customers.

2.1 Board of DirectorsThe Board of Directors must be informed if the procedure is changed.

2.2 CEOThe CEO is responsible for ensuring that the procedure is followed and updated as necessary. Where conflicts of interest are identified, the CEO shall decide which measures are to be implemented to remedy the situation, and assess whether the measure is sufficient to remedy the conflict of interest that has arisen.

2.3 The individual employeeEach individual employee is responsible for familiarizing themselves with the contents of the procedure, and performing their work tasks in line with the duties and measures described in the procedure.
The customer must evaluate the risk associated with the relevant instrument and market in connection with the investment.

3.1 IntroductionThe Investment Firm shall at all times be organized in such a way that the risk of conflicts of interest is limited to a minimum. Through FXC's activities, possible conflicts of interest may nevertheless arise between the Investment Firm and its clients and between the clients themselves, including conflicts resulting from remuneration from parties other than the client or from the Investment Firm's remuneration or incentive schemes, which cannot necessarily be resolved solely by the organization chosen by the Investment Firm.
The starting point for conflicts of interest is that clients must be treated equally and that information must not be used in an illegal or improper manner for the benefit of other clients. Furthermore, the customers' interests must take precedence over the interests of the Company or associated persons.

3.2 Identification of conflicts of interestBased on the Company's activities and services, the Company has identified the following circumstances that may constitute or lead to a conflict of interest that entails a risk of one or more clients' interests being harmed:Between the Company and its customers:
The Company's, employees' and employee representatives' own offices and positions in companies in which the Company invests clients' assets or performs assignments forFee structure in the Investment Firm
Between customers:
Conflicts of interest between customers can arise when large customers are prioritized over smaller customers
Inherent conflict of interest between principal clients and investor clients

3.3 Measures to prevent and manage conflicts of interestIn order to prevent and manage conflicts of interest, the Investment Firm's starting point must be that the client's interests have priority. Investor clients shall have priority over client clients.
The Investment Firm shall not itself have positions in financial instruments and employees' proprietary trading in financial instruments is regulated by the proprietary trading regulations. The client's interests must always take precedence over the Company's financial interests. As a general rule, the Investment Firm does not receive fees from anyone other than the client.
If, in some cases, it becomes necessary to receive fees from anyone other than the client, the client must be informed of the nature, value or method of calculation of the fee in writing before the investment service is provided.
If an employee becomes aware that a conflict of interest may arise between the Investment Firm and one or more clients that are not covered by this procedure, the general manager must deal with these in line with the above principles. If the measures are not sufficient to mitigate the conflicts of interest in a satisfactory manner, the Investment Firm must inform clients of possible conflicts of interest.
To avoid conflicts of interest arising, the Investment Firm has established ethical guidelines for employees and procedures for employees' access to conduct business activities, including directorships. Possible conflicts of interest have been identified for several of the operational persons in FXC and these will be handled with strict requirements for formal processes as described in the routines for onboarding of projects etc. Disqualification may be required if an employee has more than one role at the customer.

3.3.1 Information barriers / Chinese wallsFXC's employees are physically separated from the other employees in the group in a separate room that requires regulated access (physical lock). FXC also has its own separate area on the data server where the CEO is the administrator and where only employees and close associated parties are given limited access on a needs-tested basis.
Everyone who works in the Company and those who participate in selected projects have a duty of confidentiality regarding the assignments they are given access to. This also applies to potential uncompleted assignments.

3.3.2 Internal conflicts of interestAll the Company's employees and owners must at all times keep an arm's length distance where conflicts of interest may arise. Possible conflicts of interest must be identified in deal committee meetings and an assessment made of whether projects can be implemented in accordance with internal guidelines. If conflicts of interest arise for the CEO of the Investment Firm, the assignment must never be approved. If possible conflicts of interest arise among other owners or the Board of Directors, it must be assessed on a project-by-project basis whether this person can be effectively disqualified and kept out of the project. If effective disqualification is not possible, the Investment Firm shall not accept the assignment.It is important to point out that all licensed activities must be carried out in the Company and that these licensed services cannot be carried out by related parties.
Owners in the Company also have external directorships in several companies. The same procedure will apply for disqualification if possible conflicts of interest should arise.

3.4 Disclosure to clientsIf measures to safeguard the client's interests are not considered sufficient, the Investment Firm must disclose the possible conflict of interest to the client. The information must state that organisational and administrative arrangements for the prevention and/or management of conflicts of interest are not sufficient with reasonable certainty to prevent the Client's interests from being harmed.
The information must include a separate description of the conflicts of interest that may arise in the provision of investment services and/or ancillary services, taking into account the nature of the Client receiving the information. The description shall explain in sufficient detail the general nature and sources of the conflicts of interest, as well as the risks that arise for the client as a result of the conflicts of interest and the measures taken to mitigate those risks, so as to enable the client to take an informed decision with regard to the investment or ancillary service to which the conflicts of interest relate.

The Investment Firm must document which investment services or ancillary services have been performed or are being performed by or on behalf of the Investment Firm where a conflict of interest has arisen or may arise, and which involve a real risk of damaging the interests of other clients. The CEO is responsible for following up that the procedure is complied with and that measures and results are documented.