Conflict of Interest Policy

This Policy is issued by SB Global Ltd (“the Company”), a licensed financial services provider incorporated under the laws of the Union of Comoros, operating the G4Trade brand.

It describes the arrangements established to identify, manage, and disclose conflicts of interest that may arise between the Company (including its employees and affiliates) and its clients, or between one client and another, in the course of providing investment or ancillary services.

The Company follows international best practices inspired by MiFID II and complies with the regulatory frameworks of the Union of Comoros and the Financial Sector Conduct Authority (FSCA) in South Africa.

All directors, officers, employees, and representatives of the Company must observe this Policy

Definition of Conflict of Interest

A conflict of interest is any situation in which the Company, an employee, or a related person has competing professional or personal interests that may:

• Make a financial gain or avoid a financial loss at the expense of a client;
• Have an interest in the outcome of a service provided to a client that differs from the client’s interest;
• Have a financial or other incentive to favor one client or group of clients over another;
• Receive from or provide to a third party any inducement in relation to a service provided to a client, other than a standard commission or fee;
• Engage in multiple roles that could compromise objectivity or independence.

Identification of Potential Conflicts

Conflicts may arise where the Company or any relevant person:

• Is likely to make a financial gain or avoid a financial loss at the expense of a client;
• Has an interest in the outcome of a service or transaction performed on behalf of a client;
• Receives remuneration, discount, or non-monetary benefit from a third party connected to a client’s transaction;
• Provides services to multiple clients with competing interests;
• Has close relationships (familial, financial, or professional) with another person involved in the client’s transaction.

The Company continually monitors its operations to identify and evaluate any circumstances that may give rise to a conflict of interest.

Organisational and Administrative Arrangements

To prevent and manage conflicts of interest, the Company has implemented the following measures:

• Segregation of Duties: Clear separation between departments to prevent inappropriate influence or information flow.
• Information Barriers (“Chinese Walls”): Restricted access to confidential information between functions handling proprietary and client-related data.
• Inducements Policy: All gifts, commissions, or benefits received or offered are recorded in the Gifts & Inducements Register and subject to compliance approval.
• Remuneration Controls: Staff compensation structures are designed to avoid incentives that conflict with clients’ best interests.
• Personal Account Dealing Rules: Employees must obtain prior approval before trading on their own behalf.
• Training and Awareness: Regular training to help staff recognize and mitigate potential conflicts.
• Compliance Oversight: The Compliance Officer maintains a permanent Conflicts of Interest Register, monitors adherence, and reports material issues to Senior Management.

Disclosure to Clients

When the Company’s arrangements are insufficient to ensure that clients’ interests are not adversely affected, the Company will clearly disclose the nature and source of the conflict before acting on behalf of the client.

Disclosures are made in a durable medium (such as email, written notice, or electronic platform message) and contain sufficient detail to enable the client to make an informed decision regarding the service.

Record Keeping

The Company maintains records of:

• Identified conflicts of interest and mitigation actions taken;
• Client disclosures and consent;
• Staff personal-account trades, gifts, and inducements;
• Annual policy reviews and updates.

Records are retained for a minimum of five (5) years, or longer if required by law.

Review of the Policy

This Policy is reviewed at least annually and whenever material changes occur in the Company’s business model, organizational structure, or regulatory environment.

The Compliance Officer ensures the effectiveness of the arrangements and proposes updates for approval by the Board of Directors.

Responsibilities

• Board of Directors: Approves and oversees the implementation of this Policy and ensures adequate governance frameworks are in place.
• Senior Management: Implements appropriate systems and internal controls to identify and mitigate conflicts.
• Compliance Department: Maintains the Conflict Register, provides training, and reports material conflicts to management and regulators.
• All Employees: Must avoid situations giving rise to conflicts and promptly report any actual or potential conflict to Compliance.

Monitoring and Enforcement

The Company’s Compliance Function performs periodic reviews of business activities, client interactions, and employee conduct to ensure compliance with this Policy.

Any breaches or significant findings are escalated to Senior Management and corrective actions are implemented promptly.

Communication to Clients

This Policy is available to all clients on the Company’s official website:

www.g4trade.com

Clients may request further information or clarification by contacting:

support@g4trade.com

Group Structure Disclosure

Other group entities operate under the G4Trade brand and are licensed in additional jurisdictions.

Each entity complies with the applicable regulatory requirements in its respective country, while maintaining adherence to the principles and controls set out in this Policy.

SB Global Ltd is committed to the highest standards of transparency, fairness, and professional conduct.

This Policy forms part of the Company’s overall compliance framework to ensure that the interests of all clients are safeguarded at all times.