The objective of this Conflict of Interest Policy is to establish a clear framework for identifying, managing, and mitigating conflicts of interest within IS6FX. By adhering to this policy, IS6FX aims to uphold the highest standards of ethical conduct, ensuring that decisions are made impartially, free from undue influence, and in the best interests of our clients, stakeholders, and the company.

A conflict of interest arises when an individual's personal or financial interests conflict with their responsibilities towards IS6FX or its clients. Such situations have the potential to compromise the individual’s professional judgment or actions, leading to decisions that may not align with the company’s or clients’ best interests.

This policy applies to all individuals affiliated with IS6FX, including but not limited to employees, contractors, consultants, directors, and any external parties acting on behalf of the company. It governs all professional activities, including those that involve clients, vendors, partners, and any third-party entities.

Conflicts of interest can take various forms. Examples of situations that may result in a conflict include, but are not limited to:

• Financial Interests
  Holding a personal financial stake in a client, vendor, or competitor that could influence decision-making.
• Family and Personal Relationships
  Having close family members or friends who hold significant interests in entities that do business with IS6FX.
• Dual Employment or Roles
  Engaging in outside employment or holding positions with competitors or partners that could interfere with IS6FX’s interests.
• Receipt of Gifts or Incentives
  Accepting gifts, entertainment, or other benefits from third parties that may influence impartial decision-making.

All IS6FX personnel have a duty to:

• Act with Integrity
  Ensure that their actions and decisions align with IS6FX’s core values and the best interests of the company and its clients.
• Disclose Conflicts
  Promptly report any situation that could create a potential or actual conflict of interest to the Compliance Officer.
• Avoid Conflicting Activities
  Refrain from engaging in any outside business activities or transactions that could conflict with their role at IS6FX unless approved in advance.
• Abstain from Decision-Making
  Avoid participating in any decisions or discussions where they may have a personal interest that could affect their impartiality.

To mitigate potential conflicts of interest, IS6FX will implement the following measures:

• Segregation of Functions
  We will separate duties among employees to reduce the risk of overlapping interests.
• Disclosure and Transparency
  Any conflict that arises will be disclosed transparently to affected parties, allowing for informed decision-making.
• Internal Controls
  Regular audits and oversight will ensure that conflicts are identified and addressed promptly.
• Independent Oversight
  The Compliance and Internal Audit departments will monitor conflicts of interest and ensure that employees act in compliance with this policy.

When a conflict of interest cannot be fully avoided or managed, IS6FX will provide full disclosure to the relevant clients. Clients will be given sufficient information to assess the potential impact of the conflict on their interests, and their consent will be obtained before proceeding with any transactions or services that could be affected.

IS6FX employees are prohibited from accepting personal incentives that could undermine their professional judgment. The remuneration of staff members will not be tied to individual transactions or client outcomes that could create conflicts of interest. Compensation structures are designed to promote fair and ethical behavior.

Employees are encouraged to report any conflicts or breaches of this policy immediately. The Compliance Officer is responsible for investigating reported issues and ensuring that conflicts are resolved in a manner that protects the integrity of IS6FX and its clients. Any unresolved conflicts will be escalated to senior management.

This Conflict of Interest Policy will be reviewed annually by senior management and the Compliance Department to ensure its continued relevance and effectiveness. Any amendments or updates will be communicated promptly to all relevant parties.

For any questions regarding this policy or to report a potential conflict of interest, please contact the Compliance Officer at compliance@is6.com.