Conflicts of Interest Summary Policy

CONFLICTS OF INTEREST SUMMARY POLICY FOR INVESTMENT SERVICES

We take the identification, prevention and management of conflicts of interest seriously. The below summarises our Conflicts of Interest Policy and provides examples of conflicts which may arise in the context of the Investment Services we will be providing to you.

Our Conflicts of Interest Policy:

• requires employees to report all potential conflicts to our internal Compliance Department immediately;
• provides guidance to employees on those circumstances that constitute, or may give rise to, conflicts of interest that may pose a material risk of damage to clients;
• sets out organisational and administrative arrangements that we have put in place to prevent, mitigate or manage those risks, and requires all staff to adhere to these.

Reporting potential conflicts

Employees must report potential conflicts of interest immediately.

We maintain a Conflicts of Interest Register that sets out the conflicts that BLME (including Nomo) is exposed to. If a specific conflict of interest arises and we consider that arrangements are such that we cannot with reasonable confidence ensure fair treatment for you as a client we will either decline to act or we will disclose details of the conflict of interest to you before you undertake any investment transaction.

Our Compliance Department is responsible for monitoring potential conflicts of interest and for ensuring that any significant issues identified are reported to senior management and handled appropriately.

Examples of circumstances that constitute, or may give rise to, conflicts of interest

Such circumstances would include situations where the Bank or its employee:

• is likely to make a financial gain, or avoid a financial loss, at the expense of its client;
• has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client's interest in that outcome;
• has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client;
• carries on the same business as the client;
• receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monies, goods or services, other than the standard commission or fee for that service.

Organisational Arrangements

BLME (including Nomo) must maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to prevent conflicts of interest from constituting or giving rise to a material risk of damage to the interests of its clients.

Several measures have been taken to manage the conflicts of interest, as follows:

Information barriers

BLME (including Nomo) has established controls over the handling of certain categories of sensitive information, including confidential and non-public price-sensitive information, especially inside information. These information barrier arrangements prevents or restricts the flow of confidential or non-public price sensitive information from one individual or part of the bank to another. This enables those outside the information barrier to continue to act without regard to that information and is often used to allow for conflicts of interest to be effectively managed.

Disclosure

If we cannot manage a conflict of interest using information barrier arrangements, we will disclose the source of conflict to you and potential risks to you before undertaking providing Investment Services to you. Areas of our business which are likely to give rise to conflicts of interest are described below:

• Inducements, Gifts and Hospitality

Our employees and agents do not solicit or accept inducements that could conflict with our obligations to you.

In any instance where we make a payment to a third party this will be disclosed to you in advance of any investment transaction taking place.

The giving or receiving of gifts, entertainment, or any form of gratuity or lavish hospitality by or to us or our directors or employees may create the appearance of a lack of impartiality and may lead to a potential conflict between the interests of the giver or receiver and you interests as a client. All directors and employees are bound by and must act in accordance with our Anti Bribery and Corruption Policy which includes appropriate measures to manage conflicts of interest with respect to gifts, benefits and hospitality.

• Outside Business Interests

BLME (including Nomo) operates with appropriate procedures for the disclosure of all outside business interests by our employees and directors. These are subject to review and oversight by our Compliance Department, who maintain a register of conflicts, to ensure that they are identified and appropriately managed.

• Third Party Suppliers

The appointment of third-party suppliers will be subject to internal controls including our Anti-Bribery and Corruption Policy and Third Party Supplier Management Policy. Where any employee has a link to a third-party supplier, this has to be disclosed to Compliance who will consider whether it is appropriate before making a decision to grant Compliance approval.

• Remuneration Policy

All relevant employees are paid by basic salary, which is not dependent on company performance. There is a discretionary bonus scheme which is linked to company performance as well as individual performance. Pay and bonuses are linked to numerous factors and a remuneration committee ensures that any incentives are consistent with the provision of fairness and do not create conflicts.

• Whistleblowing Policy

We operate with an internal Whistleblowing Policy so that directors and employees are aware of and receive an appropriate level of protection should they wish to report any wrongdoing.