Conflict of Interest Policy

Genie has established this Conflicts of Interest Policy to identify circumstances in which conflicts may arise and to implement procedures designed to prevent, manage, or mitigate them. The Policy reflects the Company’s commitment to acting fairly, diligently, and in the best interests of clients at all times while maintaining compliance with applicable laws, internal governance standards, and regulatory principles.

A conflict of interest arises when Genie, its employees, directors, associates, related entities, or any person directly or indirectly connected to the Company has competing interests with a client or between clients. These conflicts may be actual or potential and may impair the Company’s ability to act independently, objectively, or impartially. Genie actively works to identify, monitor, and manage such situations so that all services are provided fairly and without bias.

This Policy applies to all directors, employees, and persons directly or indirectly linked to Genie, collectively referred to as Relevant Persons, and covers the Company’s dealings with all clients regardless of classification. Conflicts may arise between the Company and a client, a Relevant Person and a client, two or more clients of the Company, or any group company and a client. Genie applies conflict management measures across each of these scenarios to preserve transparency, impartiality, and fair treatment.

Where preventative measures are insufficient to eliminate a conflict of interest or fully protect the client’s interests, Genie will disclose the conflict to the client in sufficient detail before any relevant business is undertaken. This includes the nature, source, and potential impact of the conflict, together with the steps taken to avoid or mitigate it and any relationships or arrangements with third parties that could create the conflict. Such disclosure is intended as a last-resort measure so that the client can make an informed decision about whether to proceed despite the conflict.

To identify situations in which conflicts of interest may arise in connection with investment services, ancillary services, or any combination of them, Genie considers circumstances that may potentially harm the client’s interests. These include where the Company or a Relevant Person may obtain a financial or personal benefit, or avoid a loss, at the client’s expense; where there is an interest in the outcome of a service or transaction that differs from the client’s interest; where the Company or a Relevant Person carries on business activities similar to those of the client; where inducements such as gifts, payments, or other benefits may be received from third parties beyond standard fees or commissions; or where incentives may exist that favor one client or group of clients over another.

Genie has implemented a broad set of internal controls to identify, reduce, and manage conflicts of interest. These include ongoing oversight by the Compliance Department and reporting to the Board of Directors, supervision of Relevant Persons operating in potentially sensitive roles, controls over access to confidential and electronic information, restrictions on the exchange of information between personnel where client harm could result, clear segregation of duties, Chinese wall arrangements, and the four-eye principle for key activities. Additional controls include restricting conflicting external business interests without prior Board approval, preventing undue influence over service delivery, supervising third-party service providers, applying risk-adjusted remuneration methodologies where appropriate, and ensuring that all marketing communications are reviewed and approved by Compliance before release.

Genie maintains a Conflicts of Interest Control Register that is regularly updated by the Compliance Department. This register records all services and activities where actual or potential conflicts may arise, including the type of conflict, mitigating measures, and assigned responsibilities. On a case-by-case basis, Compliance and Senior Management determine whether an activity can proceed where a conflict cannot be fully resolved. Where no adequate resolution is available, the Company may disclose the conflict to the client so that the client can make an informed decision on whether to continue.

Employees and directors are prohibited from accepting gifts, hospitality, promotional offers, discounts, or any monetary or non-monetary benefit from clients or third parties where this could give rise to a conflict of interest. Staff must comply with Genie’s Gifts and Hospitality Policy to avoid undue influence over decision-making. In addition, Genie operates a Personal Account Dealing Policy governing personal investment transactions by employees, directors, and other relevant persons. Personal trading must never conflict with client interests, interfere with the execution of client orders, or compromise impartiality in the delivery of services.

As part of Genie’s Compliance Monitoring Plan, the Compliance Department conducts annual reviews of the effectiveness of all Conflicts of Interest systems, controls, and policies. Genie also maintains and regularly updates a register of services and activities where conflicts of interest have arisen or may arise, including those involving a material risk of client harm. The Compliance Department is responsible for maintaining this register, reviewing conflicts, and updating the Policy at least annually so that it remains compliant with regulatory and operational requirements. Genie reserves the right to review or amend this Policy and its associated procedures at any time, with annual review undertaken to ensure the Policy remains current, legally compliant, and effective in managing conflicts of interest.