Conflict of Interests

1. Scope of the Conflict of Interests

This document is to ensure that the conflict of interests within the facilities of Fundiza Ltd. are identified and managed appropriately. Conflict of interests can emerge within the Company, its employees, managers, directors, and its Clients. The conflict of interest may occur through the following parties:

• - Between the Company and the Client
• - Between the Clients of the Company
• - Between the Company and its workforce, including its departments



If the Company finds an actual or potential conflict, the Company may:

• - Decline to act where there is a possible conflict
• - Cease engaging in the activity that caused the conflict
• - Accept the conflict but will take steps to protect the Client’s interest
• - Disclose the conflict of interests and oblige the Client to act

2. Identification and Management

The Company has established these procedures to identify and manage conflicts of interests. The Company implements several methods to manage and to control the movement of confidential information. The following are some occurrences that may cause the conflict of interests, without limitation:

• - If the Company or any of its employees make financial gains or avoids losses at the expense of the Client
• - If the Company is interested in the outcome of a service or a trade executed on behalf of the Client, which
• is different from the Client’s interest in that outcome
• - If the Company carries has a financial or incentive to favor the interest of another Client overt the interests of the Client
• - If the Company carries out the same business as the Client
• - If the Company receives an inducement from an unregistered third party in relation to a service provided
• to the Client, in the form of money, goods, or services, other than the standard commission or fee for that
• service