Conflict of Interest Policy (Utmost Luxembourg)

Utmost Luxembourg S.A. (the “Company”) established a Conflict-of-Interest Policy (the “Policy”) in accordance with the applicable regulatory requirements.

Conflict of interest may be defined as the action to enter into a transaction or arrangement that:

• Benefits the private interest (or might result in a possible excess benefit) of the Company (and/or its representatives including its Staff Members) and/or one or several Clients and,
• Results in damage against the Clients and/or against the Company itself (e.g., financial damage or non-financial damage like quality of service, reputation etc.).

The purpose of this Policy is to provide rules to ensure that the circumstances which constitute (real) or may give rise to a (potential) conflict of interest are properly identified and managed and do not adversely affect the interests of the customers of the Company, especially, but not only, when the conflict of interest is triggered by an insurance distribution activity.

The Company operates a set of procedures and internal processes to identify potential CoI. To assist its Personnel to identify them, objective identification criteria have been defined in order to assure that values such as integrity, honesty and compliance with the regulatory standards are effectively respected and pursued by such Personnel.

For the purposes of identifying the types of CoI, the Company shall assess whether, in case of a (non-)insurance distribution activity, a relevant person or any person directly or indirectly linked to such Company by control, has an interest which (i) could potentially detriment the customer or potential customer (e.g., financial damage or non-financial damage like quality of service, reputation, etc.) and (ii) put the interest of the Company, its Personnel, Intermediaries or Partners ahead of those of the customer or potential customer.

The Company’s ultimate objective is to avoid the materialisation of CoI. This is safeguarded by the implementation of a series of procedures and mitigating actions to adequately (i) manage the impact of the potential/real CoI and (ii) prevent them from damaging the interests of the Customer. If a potential/real CoI identified cannot be avoided, the Company assures that this is escalated to the ExCo for its validation.

In case the residual risk remains, even after all the mitigating actions have been taken, the Company informs the concerned customers in all transparency on the general nature or sources of the conflict.

The Company ensures, at least on an annual basis, that its CoI assessments remain accurate and up-to-date in line with the documented procedures and that there is appropriate oversight of any conflict identified. The results of the monitoring shall be provided to the relevant Board committee.