This Policy is issued pursuant to, and reflects compliance with, the European Directive on markets in financial instruments (MiFiD) and with the implementing the Law on the Financial Instruments Market of the Republic of Latvia that apply to Renesource Capital.

RC’s Conflict of Interest policy identifies and discloses a range of circumstances which constitute or may give rise to a conflict of interest, in accordance with MiFID.

Compliance with the Renesource Capital Conflicts of Interest policy is a compulsory requirement of the employment of each and every staff member of Renesource Capital and the other Renesource Capital related companies or appointed agents to which the Renesource Capital Conflicts of Interest policy applies and any breach may lead to disciplinary proceedings.

The conflict of interests is a situation when performing professional duties two opposite interests get in confrontation, including the interest of staff members and professional interest, whether a situation when two opposite professional interests get in confrontation, for example, interests of two different clients or agents.

Circumstances giving rise to conflicts of interest occurs between:

• The employee of the RC and the client;
• The agent, introducer or white label of RC and the client;
• The counterparty and the RC;
• The employee or member of the board, or member of the council who directly or indirectly controls the RC and the client ;
• Clients of the RC;
• Parent company or enterprise of the group of the RC and the client.

To ensure the ethics and correct functioning of this Policy, RC’s analysts are required to disclose all personal interests relevant to their research activities. Analysts of RC are required to comply with our internal rules and procedures on personal account dealing. Market analysts are appraised independently from dealing and trading businesses.