Purpose

The purpose of this Conflict of Interest Policy is to protect the interests of LHFX, a broker authorized and regulated by the Financial Services Commission Mauritius under the Investment Dealer license number GB23202204, Code SEC-2.1B Office Address: Suite 102, 1st Floor, Sterling Tower, 14 Poudriere Street, Port-Louis, Mauritius, its clients, and other stakeholders by ensuring that decisions made by employees, officers, and directors are not influenced by personal interests. This policy aims to identify, disclose, manage, and resolve any conflicts of interest that may arise in the course of conducting the company's business.

Scope

This policy applies to all employees, officers, directors, contractors, and agents of LHFX (collectively referred to as "Covered Persons"). It covers all business activities and relationships, including those with clients, suppliers, partners, and competitors.

Definition of Conflict of Interest

A conflict of interest arises when a Covered Person's personal interests or relationships interfere, or appear to interfere, with the interests of LHFX or its clients. Conflicts of interest can be actual, potential, or perceived and may include, but are not limited to:

• Financial Interests: Ownership or investment in a company that competes with, does business with, or seeks to do business with LHFX.
• Personal Relationships: Relationships with clients, suppliers, or competitors that could influence decision-making.
• Outside Employment: Holding a job or providing services to another organization that competes with or does business with LHFX.
• Gifts and Entertainment: Accepting gifts, favors, or entertainment that could influence, or appear to influence, business decisions.
• Use of Company Resources: Using LHFX’s assets, including intellectual property, for personal gain.

Identification and Disclosure of Conflicts of Interest

Covered Persons must promptly disclose any actual, potential, or perceived conflicts of interest to their immediate supervisor or the Compliance Officer. Disclosure should be made in writing and include:

• A description of the conflict of interest.
• The nature of the personal interest or relationship.
• Any steps taken to mitigate the conflict.

Management of Conflicts of Interest

Upon disclosure, the Compliance Officer will review the conflict and determine the appropriate course of action. Possible actions include, but are not limited to:

• Allowing the Covered Person to proceed with the activity if it is determined that there is no significant conflict.
• Requiring the Covered Person to abstain from participating in the related decision-making process.
• Implementing measures to mitigate the conflict, such as divesting the personal interest or reassigning duties.
• In cases where a conflict cannot be adequately managed, requiring the Covered Person to discontinue the conflicting activity or relationship.

Record-Keeping

The Compliance Officer will maintain a written record of all disclosures of conflicts of interest and the actions taken to manage them. These records will be reviewed periodically to ensure compliance with this policy.

Training and Awareness

LHFX will provide training to Covered Persons on this Conflict of Interest Policy and the importance of identifying, disclosing, and managing conflicts of interest. Training will be conducted upon hiring and periodically thereafter.

Consequences of Non-Compliance

Failure to comply with this Conflict of Interest Policy may result in disciplinary action, up to and including termination of employment or contract. LHFX reserves the right to take legal action if necessary.

Review and Amendments

This policy will be reviewed annually and updated as needed to ensure its effectiveness. Any amendments to the policy will be communicated to all Covered Persons.

Contact Information

For questions or concerns regarding this Conflict of Interest Policy, please contact the support team at: support@lhfx.com.

Date of Implementation

This policy is effective as of the date of publication and will remain in force until further notice. By adhering to this Conflict of Interest Policy, LHFX aims to maintain the highest standards of integrity and transparency in all its business dealings, thereby fostering trust and confidence among its clients and stakeholders.