Conflicts of Interest Policy

June 2022

1. Introduction
   

   Century Financial Consultancy LLC (“Century”, “Company”, “our”, “us”, “we”) provides herein below the summary of the policy we maintain to manage conflicts of interest to help us spot and handle any potential conflicts of interest when serving our clients. This Conflicts of Interest Policy (the "Policy") is provided to you (our “Client” or prospective Client) in accordance with the applicable laws which require the Company to take all reasonable measures to detect and avoid conflicts of interest.

2. Purpose
   

   The purpose of this policy is to outline the Company's approach to identifying and managing conflicts of interest that may arise during normal business operations. There may be a conflict of interest between various members of a group of businesses, between us and you as a Client, or between your interests and those of potential other clients. This policy's goal is to guarantee that all practical measures are taken to avoid conflicts of interest that could materially jeopardize our clients' best interests.

   Therefore, this Policy establishes the essential procedures, controls, and practices to appropriately recognize, avoid or handle any potential conflicts of interest.

   This Policy is not intended to create third-party rights or obligations, nor does it constitute a contractual agreement between the firm and any client. If there is a material change, this Policy may be amended and updated at any time, and it will be reviewed at least once a year.

   In case of any doubts or further clarifications regarding this policy please contact the Compliance Officer at compliance@century.ae.

3. What is a Conflict of Interest?
   

   Conflicts of interest appear in situations where the Company or its directors, managers and employees who directly or indirectly may affect the interest of the Clients or potential Clients, persons or services outsourced who directly or indirectly may affect the interest of the Clients (“Relevant Persons”).

   The Company has made efforts to identify and address potential conflicts of interest within its operations and implemented measures to do so related to the dispute in question in an effort to monitor, manage and regulate the potential impact that these disputes may have on its Clients

4. Identification of Conflicts
   

   Due to the current nature, size, and complexity of the Company's business, it is not possible to precisely define or create an exhaustive list of all relevant conflicts of interest that may arise. However, the following list includes situations that constitute or may give rise to a conflict of Interest that poses a material risk of harm to the interests of one or more Clients:

   • The Company or a Relevant Person is likely to make a financial gain, or avoid a financial loss, at the expense of the Client.
   • The Company or a Relevant Person 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.
   • The Company or a Relevant Person has a financial or other incentive to favour the interest of another Client or group of Clients over the interests of the Client.
   • The Company or a Relevant Person carries on the same business as the Client.
   • The Company or a Relevant Person 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.
     However, the examples above are not exhaustive and only represent situations where a conflict is anticipated and, as a result, due consideration will be given by the Company. As a result, any analysis of conflicts of interest should be used objectively and broadly in order to achieve the best possible outcome for the Client.
5. Preventing & Managing Conflicts of Interest
   

   In order to manage recognized conflicts of interest, the Company has implemented a variety of internal policies and processes, which are outlined in its Compliance Manual. These will be subject to the standard monitoring and review procedures of the Company. The measures for resolving conflicts are intended to ensure that Relevant Persons engaged in different business activities involving a conflict of interest conduct those activities with a degree of independence commensurate with the size and activities of the Company. The Company is aware that proper segregation of duties is a crucial element of an organization's prudential internal controls. Specifically, it helps to ensure that no one individual is able to fully commit the Company’s assets or incur its obligations. Segregation also ensures that the Company’s governing body receives impartial and accurate information regarding the Company’s financial performance, its risks, and the adequacy of its procedures.

   For the purpose of conflict management and mediation, the Company uses a variety of organizational and administrative strategies, such as:

   • Compliance Department: Establishment of an internal Compliance Department to provide continuous monitoring to verify that proper systems and controls for preventing and managing conflicts of interest are maintained and followed appropriately, and it reports to the Board of Directors of the Company.
   • Information Barriers: Establishing physical and electronic barriers to block and regulate the flow of information between particular sectors of the business. When necessary, the Company also handles conflicts of interest by instituting and maintaining internal restrictions on the flow of information within the Company. This mandates that information possessed by a person in the course of conducting one aspect of our business cannot be shared with or utilized by persons with or on whose behalf we conduct another aspect of our business. Such a system is known as a Chinese Wall and can incorporate hierarchical separation and physical barriers between activities likely to contain conflicts of interest, with the goal of preventing any inappropriate information flow.
   • Flow Of Information: Effective methods to prohibit or restrict the flow of information between relevant parties engaged in activities posing a danger of a conflict of interest, when such an interaction may be detrimental to the interests of one or more clients. Information is shared only on need-to-know basis.
   • Segregation of Duties: Preventing or limiting a Relevant Person's involvement in multiple services provided by the Company at once or in quick succession if such involvement could compromise the effective management of conflicts of interest.
   • Personal account dealing: Individual employees may only engage in lawful, ethical, and non-disruptive personal investment activities that do not interfere with their ability to perform their job duties or pose an unacceptable danger to the company's reputation. Moreover, business, and ethical conflicts of interest should be absent from all transactions. Employees are prohibited from ever misusing proprietary or client-confidential information. Personal relationships are prohibited, and employees must ensure that Clients are never disadvantaged as a result of their transactions.
   • Product governance: Conflicts of interest will be considered as part of any new product approval process and as part of ongoing product governance assessments, e.g., to ensure the product's suitability throughout the lifecycle of the relevant product or service;
   • Employment, external directorships, and business interests outside the company: No employee is permitted to engage in a second job without the Company's permission, under specific conditions, such consent may be withheld by the Company. Employees are prohibited from accepting personal fiduciary positions (such as trusteeships, directorships, or executorships) without prior written clearance from the Company.
   • Remuneration and Oversight: Company’s Senior Management/Board is responsible for overseeing management and determining the proper compensation of staff personnel. Compensation is based on the Company’s overall performance and not on individual performance. The staff is subject to the management and oversight necessary to ensure that the Company has put in place suitable and effective measures to ensure remuneration related conflicts of interest are managed effectively.
   • Incentives such as gifts and hospitality: Relevant Persons are forbidden to accept gifts, promotions, discounts or any other monetary or benefit in kind from Clients or third parties, which may create conflicts of interest. Gifts of low value to Relevant Persons may be accepted after approval from the Company. Employees may not accept gifts or other inducements from any individual that cannot be considered justifiable under any conditions.
   • Training: Staff are provided with internal guidance and training to ensure they are knowledgeable with and abide by the applicable regulations and the Company’s policies, as well as how to identify and manage conflicts of interest;
   • Reporting and escalation: When performing their duties, employees are obligated to examine conflicts of interest and the Company’s obligation in relation to them. If an actual or possible conflict of interest is detected, it must be reported to the Company’s Compliance Officer, which will evaluate the conflict in light of this Policy and remedy it as necessary.
   • Documentation: The Company maintains the Conflicts Register, which is an up-to-date record of the identified conflicts of interest and the mitigation strategies for each conflict;
   • Prohibitions:
     • Of the activity that gives rise to the conflict of interest in situation where the conflict cannot be appropriately managed in the Client's interests.
     • Prohibition on officers and employees of the Company having external business interests conflicting with the interests of the Company without the prior approval of the Company's Board of Directors.
   • Disclosure: When there is no other way to manage the conflict or when the measures in place do not, in the opinion of the Company, adequately protect the customer's interests, the conflict of interest should be disclosed to the customer so that the customer can make an informed decision about whether to continue doing business with the Company. The Company will only rely on disclosure of a conflict of interest when the organisational and administrative processes in place are insufficient to ensure, with reasonable assurance, that risks of harm to a client's interests will be avoided. This conflict will be reported prior to engaging in the relevant business and will include a description of the nature or sources of conflicts of interest, or both, as well as the measures taken to manage these risks.
   The Company continually conducts a comprehensive analysis of its business and organizational arrangements, including best execution arrangements, enticement practices, remuneration methods, and research/marketing communication protocols, to ensure that all potential conflicts of interest, regardless of their magnitude, are recognized.
6. Amendment of the Policy and Additional Information
   The Company may, at any time and without prior notice to the Client, review and/or alter this Policy and arrangements as it sees fit. If you require additional information or have issues regarding potential conflicts of interest, please direct your request and/or queries to this email address: compliance@century.ae.