LOGISTABLE LIMITED

SUITE 3A, TISA HOUSE
143 MAIN STREET
P.O.BOX 565
GIBRALTAR

Logistable's Conflict of Interest Policy

Logistable's Conflict of Interest policy sets out how Logistable will:

identify circumstances which may give rise to a conflict of interest entailing a material risk of damage to clients' interest;

establish appropriate mechanisms and systems to manage those conflicts; and

maintain systems in an effort to prevent actual damage to a clients' interests through the identified conflict.

What is a "Conflict Of Interest"

A conflict of interest under MiFID is a conflict that arises in any area of Logistable's business in the course of providing its clients with a service which may benefit Logistable (or another client for whom Logistable is acting) whilst potentially materially damaging another client where Logistable owes a duty to the client. There may be a conflict where Logistable (or anyone connected to Logistable):

is likely to make a financial gain (or avoid a loss) at the expense of its client;

is interested in the outcome of the service provided to its client where the interests of Logistable are distinct from that of the client;

has a financial or other incentive to favour the interest of one client over another;

carries on the same business as the client;

receives money, goods or services from a third party in relation to services provided to a client other than standard fees or commissions.

Logistable has carried out an exercise to identify conflicts of interest that exist in its business and has put in place measures it considers appropriate to the relevant conflict identified in an effort to monitor, manage and control the potential impact of those conflicts on its clients. The conflicts identified include:

those between clients with competing interests;

those between clients and Logistable where their respective interests in a particular outcome may be different;

those between the personal interest of staff of Logistable and the interests of Logistable or its clients where those interests may be different.

The measures adopted by Logistable in an effort to manage the conflicts identified are as follows:

Policies and Procedures

Logistable has adopted numerous internal policies and procedures in order to manage recognised conflicts of interests. These policies and procedures will be subject to Logistable's normal monitoring and review processes.

The following are the main ways Logistable manages conflicts of interest:

Segregation of duties: Key activities, which by their nature, can give rise to conflicts of interest are, where possible, segregated within Logistable. Furthermore the activities of departments within Logistable are, where possible, carried out with an appropriate level of independence.

Proprietary trading: Logistable will, on occasion, carry out its own proprietary trading activities. Logistable has implemented measures to reduce the occurrence of any potential conflicts of interest arising from said trading.

Staff matters: The following are the main measures taken by Logistable in relation to its employees:

Remuneration: The staff remuneration package is in no way linked to specific transactions.

Personal securities dealing: Internal rules prevent all staff from carrying out personal deals using Logistable's trading platform.

Gifts: Internal rules with respect to giving and receiving gifts are designed to ensure that employees do not use their position within Logistable for significant personal gain for themselves, their families or any other persons. All gifts above a designated value must be approved by the Chairman.

Secondary activities and external appointments: Employees are required to work exclusively for Logistable. They are not permitted to perform any paid or unpaid work for a third party, unless an exemption has been granted by the board of directors.

Training: Employees who are most likely to be exposed to conflicts of interest receive training to ensure they are aware of and can deal appropriately with this matter

Commissions:

Clients have been made aware, in writing, of the fact that from time to time commissions may be paid to Logistable Limited by certain financial institutions on the transactions executed on their accounts. These commissions enable and/or are necessary for the provision of investment services and may take the form of custody costs, service fees and settlement and exchange fees for executed transactions.

In order to enhance the transparency of the fee structure between Logistable Limited and its clients. Logistable Limited undertakes to repay all commissions received from its Custodian Bank, to its clients.

The detailed terms of all arrangements with financial institutions with regards to commisions are available to clients for inspection, upon request.

Disclosure:

Where there is no other means of managing the conflict or where the measures in place do not, in the view of Logistable, sufficiently protect the interests of clients, the conflict of interest will be disclosed to clients to enable an informed decision to be made by the client as to whether they wish to continue doing business within that particular situation.

Declining to Act:

Where Logistable considers it is not able to manage the conflict of interest in any other way it may decline to act for a client.

IMPORTANT NOTICE - This policy does not form part of any contract between Logistable Limited and any of its clients or prospective clients and is simply a statement of policy issued by Logistable Limited in accordance with its regulatory obligations.

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