Introduction

Bank of Solidus is committed to maintaining the highest standards of ethical conduct and integrity in our operations. This Conflict of Interest Policy outlines our approach to identifying, managing, and mitigating conflicts of interest to ensure that the interests of our customers, stakeholders, and the bank are protected.

Definitions

• Bank: Refers to Bank of Solidus.
• Employee: Refers to any individual employed by Bank of Solidus, including officers and directors.
• Conflict of Interest: A situation where an employee's personal interests could interfere with their duties and responsibilities at Bank of Solidus, potentially leading to a compromise of the bank's interests.

Identifying Conflicts of Interest

Employees of Bank of Solidus are required to identify and disclose any potential conflicts of interest. Examples of conflicts of interest include, but are not limited to:

• Personal Financial Interests: Holding financial interests in a competitor, supplier, or customer of the bank.
• Outside Employment: Engaging in employment or business activities outside of Bank of Solidus that could conflict with the employee's duties.
• Family and Personal Relationships: Having family members or close personal relationships with individuals or entities that have a business relationship with the bank.

Disclosure of Conflicts of Interest

Employees must promptly disclose any potential conflicts of interest to their immediate supervisor or the Compliance Officer. The disclosure should include:

• A description of the nature of the conflict.
• The parties involved.
• Any relevant financial or personal interests.

Managing Conflicts of Interest

Once a conflict of interest has been disclosed, the following steps will be taken to manage and mitigate the conflict:

• Review: The Compliance Officer will review the disclosed conflict to determine its significance and potential impact on the bank.
• Mitigation: Appropriate measures will be implemented to mitigate the conflict, which may include reassigning duties, establishing information barriers, or requiring the employee to divest certain interests.
• Monitoring: The conflict will be monitored on an ongoing basis to ensure that it is effectively managed.

Employee Responsibilities

• Awareness: Employees must be aware of potential conflicts of interest and remain vigilant in identifying and disclosing them.
• Transparency: Employees must be transparent and honest in disclosing potential conflicts of interest.
• Compliance: Employees must comply with the measures implemented to manage and mitigate conflicts of interest.

Consequences of Non-Compliance

Failure to disclose a conflict of interest or comply with this policy may result in disciplinary action, up to and including termination of employment. Bank of Solidus takes conflicts of interest seriously and expects all employees to adhere to this policy.

Review and Updates

This Conflict of Interest Policy will be reviewed regularly and updated as necessary to ensure its effectiveness and alignment with best practices and regulatory requirements.

Contact Us

If you have any questions about this Conflict of Interest Policy, please contact us at:
Bank of Solidus
Customer Support
Email: support@bankofsolidus.com