Conflicts of Interest Policy

• INTRODUCTION

  SB Global, operating the brand Stockbanx (www.stockbanx.com), is an Investment Firm registered in the Union of Comoros with company registration number 15825. The Company's registered office is located at Hamchako, Mutsamudu, Autonomous Island of Anjouan, Union of Comoros.

  SB Global adheres to the applicable legislative framework under the Comoros Securities Act and related regulations. The Company is committed to acting honestly, fairly, and professionally in the best interests of its clients while complying with relevant legal requirements.

  This Conflicts of Interest Policy (“Policy”) outlines the procedures in place for identifying, managing, and, where necessary, disclosing conflicts of interest to prevent disadvantage to clients and to protect the Company’s integrity and reputation.

• PURPOSE AND SCOPE

  The purpose of this Policy is to ensure that SB Global:

  • Identifies potential conflicts of interest that may arise in the course of its operations.

  • Implements robust procedures to responsibly manage and mitigate conflicts of interest.

  • Discloses conflicts where appropriate to ensure transparency with clients.

  This Policy applies to SB Global’s managers, employees, tied agents, and any other individuals or entities directly or indirectly linked to the Company by control (collectively referred to as "related persons") in all interactions with clients.

• IDENTIFICATION OF CONFLICTS OF INTEREST

  SB Global is committed to identifying and managing conflicts of interest that may arise between:

  • The Company and its clients.

  • Two or more clients.

  • The Company’s employees and its clients.

  • Different departments within the Company.

  • A conflict of interest may arise when:

    • The Company or a related person stands to gain financially at the expense of a client.

    • The Company has an interest in the outcome of a service or transaction that conflicts with the client’s interest.

    • The Company or a related person has a financial or other incentive to prioritize one client over another.

    • The Company or its employees participate in business activities similar to those of the client.

    • The Company receives an inducement from a third party, other than standard commissions or fees, related to services provided to clients.

• ORGANISATIONAL REQUIREMENTS

  To prevent conflicts of interest from adversely affecting client interests, SB Global has implemented the following measures:

  • Effective organizational and administrative arrangements.

  • Internal controls and risk assessment procedures.

  • Segregation of duties to avoid overlapping responsibilities.

  • Restrictions on the flow of confidential information between departments (e.g., "Chinese walls").

  • Monitoring of employee activities to ensure adherence to the Policy.

  • Procedures governing access to electronic data and physical separation of departments.

  • Record-keeping of any gifts, inducements, or benefits offered or received.

  • Clear guidelines to prohibit external business interests conflicting with the Company’s interests unless expressly approved by the Board of Directors.

• MANAGEMENT OF CONFLICTS OF INTEREST

  SB Global takes the following steps to manage conflicts of interest effectively:

  • Implementing a Best Execution Policy to ensure client orders are executed with the best possible results.

  • Monitoring client communications to identify potential conflicts.

  • Enforcing strict compliance procedures for all employees, including regular training and acknowledgment of the Policy.

  • Requiring employees to disclose personal transactions and external business interests that may lead to conflicts.

  • Establishing mechanisms to prevent or control the exchange of information that could harm client interests.

  • If conflicts of interest cannot be managed adequately, SB Global will disclose the nature and source of the conflict to the affected client(s).

• REPORTING A CONFLICT OF INTEREST

  Employees and related persons are encouraged to report potential conflicts of interest to the Compliance Department. All reported cases are escalated to the Company’s Senior Management for review. The process involves:

  • Identifying the nature of the conflict.

  • Assessing the material risks to clients and the Company.

  • Implementing corrective actions to mitigate the conflict.

  • Documenting the steps taken and notifying clients where applicable.

• RECORD-KEEPING

  SB Global maintains comprehensive records of:

  • Identified conflicts of interest.

  • Actions taken to manage or mitigate conflicts.

  • Relevant communications and assessments.

  Records are retained for at least seven years to ensure transparency and compliance with regulatory requirements.

• DISCLOSURE

  Where a conflict of interest is identified and cannot be effectively mitigated, SB Global will disclose the conflict to the client before proceeding with any related investment business. Disclosure will:

  • Be presented in a durable medium (e.g., written notice or email).

  • Include sufficient detail to enable the client to make an informed decision.

  • If disclosure is insufficient to manage the conflict, SB Global may opt not to proceed with the transaction or activity.

• REVIEW AND MONITORING

  SB Global regularly reviews and monitors this Policy to ensure its effectiveness. The Policy is updated as needed to reflect changes in the Company’s operations, regulatory environment, or market conditions. Amendments are communicated to clients via the Company’s website or direct notifications.

  For further inquiries or additional information about this Policy, please contact us at contact@stockbanx.com.