Conflicts of Interest Policy

Policy of Arev Securities hf. on Measures to Prevent Conflicts of Interest

Purpose

This policy is intended to ensure that in the course of its business, Arev Securities hf. (hereinafter referred to as Arev or the Company) takes all available measures to identify and address potential conflicts of interest. The policy aims to prevent conflicts of interest between the company and its clients, or between the company's clients themselves. By preventing conflicts of interest, the policy also seeks to preserve the company's integrity. This policy is established in accordance with Article 32 of the Markets in Financial Instruments Act No. 115/2021 and Commission Regulation (EU) No 2017/565.

Scope

This policy applies to conflicts of interest between:

(1) of the company itself, including between employees, agents, outsourcing providers or entities under the company's control on the one hand, and its clients on the other; or

(2) between the company's clients amongst themselves.

When a risk of conflicts of interest exists, the company must have an effective procedure in place to prevent conflicts of interest from harming the interests of the company's clients. The policy applies to all areas of the company's operations.

The policy applies to securities transactions between the company and its clients, regardless of whether they are classified as retail investors, professional investors or eligible counterparties.

Where this policy and the company's internal rules make different requirements for measures to be taken against conflicts of interest, the stricter requirements shall always apply.

Definitions

In this policy, 'means':

(1) An employee of the company:

director, manager, partner or equivalent,
1. an employee of the company, or any person acting under the company's management or on its behalf, who is involved in providing the company's services in the field of securities trading,
1. a person who is directly involved in providing a financial undertaking with a service under a contract for the outsourcing of securities services.

(2) A person connected to an employee of the company by family ties:

spouse, spouse in a registered partnership or cohabiting partner of an employee of the association,
1. child, adopted child or stepchild of an employee of the company who is dependent on them,
1. another relative of an employee of the company who has lived in the same household as him for at least one year as of the date on which the relevant transaction takes place.

(3) Personal transactions: Transactions in financial instruments carried out by or on behalf of an employee of the company when at least one of the following conditions is met:

the transaction takes place outside the scope of the relevant company employee's authority;
1. The transaction is carried out for the account of one of the following parties:
an employee of the association;
a person related by family ties to an employee of the company or a person closely associated with an employee of the company;
a party who is in such a relationship with an employee of the company that the latter has direct or indirect interests to be advanced by the outcome of the transaction, excluding any fee or commission for executing the transaction.

(4) Clients: Clients include current clients, prospective clients (with whom the firm is seeking to enter into a contractual relationship) and former clients, where a duty of confidence or other obligations are still in effect between the parties.

Analysis of Conflicts of Interest

The Association pays particular attention to conflicts of interest when providing services which consist of:

(1) asset management;

(2) corporate advisory, (including the sale by public offering of financial instruments, advice to companies on the structure of their own capital, strategy and related matters, and advice and services concerning corporate mergers and acquisitions)

A particular risk is considered to arise from conflicts of interest when the company or an associated party provides services in both of the aforementioned areas. The company considers that conflicts of interest may arise in connection with the services it provides, for example, in the following ways:

The firm trades in securities for the account of clients for which there is a limited supply, at the same time as other clients wish to buy or sell the same securities.
1. The firm recommends or sells a financial product issued by itself, when it provides clients with corporate advisory or asset management services.
1. The company's corporate advisory may be contracted by a particular company, but its asset management may simultaneously seek to buy or sell its shares in connection with the management of funds. Corporate advisory is then obliged to prioritise the interests of the company, whereas asset management must prioritise the interests of the fund.
1. The company may hold shares in a company about which it provides clients with corporate or investment advice. The company may also hold shares in a company in respect of which it provides corporate advisory or investment advisory services. Employees of the company who provide these services may be unaware that the company has other interests relating to shares in the company.
1. The company, a member of the company's staff, or a person who is directly or indirectly connected to the company through control may have a financial interest in the outcome of services provided to a client, or in the outcome of transactions carried out on behalf of a client.d. if the person:
realises a financial gain or avoids a financial loss at the expense of a client
operates in a similar way to the client,
receives a reward in connection with services provided to a client, other than the usual fee (e.g. money, goods or services), from a party other than the client.
1. The company carries out investment-related research (analyses) in relation to legal entities to which it also provides investment or corporate advice.
1. This concerns employees' personal transactions. Employees' personal transactions are subject to the company's rules on securities transactions.

The company records all transactions with its clients and with the company itself. The company regularly compiles information on transactions with related parties who are board members, executives, key employees and their immediate family members, as well as equivalent persons in subsidiaries and associated companies. The same applies to transactions with shareholders who directly or indirectly own 5% or a larger stake in the company, or who are among its ten largest shareholders, and with other parties as further defined in the company's board of directors' rules of procedure.

Handling of conflicts of interest

The Association takes, among other things, the following measures to prevent conflicts of interest:

(1) To prevent the unrestricted flow of information between business areas, the company restricts access to confidential information with the help of firewalls to those parties who, in the company's opinion, have a genuine need for such information and in accordance with the interests of the relevant client or the company itself.

Each division within the company operates independently. There is a separation in management, premises and information systems between the asset management and corporate advisory activities and other divisions, as the company's operations warrant;
1. In specific cases, at its discretion, the company may take additional measures to prevent the flow of information.

(2) Employees of the company are prohibited from trading in financial instruments without the prior written authorisation of the company's compliance officer.

(3) Employees of the company are prohibited from executing a transaction before a client if a request for the transaction has already been received from the client. Similarly, an employee who manages assets for a client must not trade for their own account before executing a trade for the client in the same financial instrument.

(4) Care should be taken to avoid an employee transacting in the same financial instruments as those they trade on behalf of a client in an asset management capacity.

(5) The company ensures that there is no direct link between the remuneration of employees who primarily handle one area of business and the remuneration of other employees who primarily handle other tasks, or the income they generate, if conflicts of interest could arise in relation to these areas of responsibility.

(6) The Association shall establish appropriate procedures, whether for incidents within the same department or between different departments of the Association, for cases that may lead to conflicts of interest or when conflicts of interest occur.

(7) The firm shall not authorise payments of commissions, agency fees or non-monetary benefits to third parties or to persons representing clients, or a third party or person on their behalf pays or provides unless the client has been clearly informed of the existence, nature and amount of such commission, agency fee or benefits. Such payments must also be intended to enhance the quality of the service provided to the client.

(8) If a conflict of interest arises, the company will inform the relevant client of it so that the client can make an informed decision about continuing the relevant business. Records of the service provided and the company's response shall be retained in the event of a conflict of interest.

(9) The Association may exclude related parties from specific transactions or the handling of conflicts of interest, provided that their participation in the relevant transactions or in the handling of conflicts of interest could lead to a conflict of interest.

The above list is provided for illustrative purposes only and is not intended to be exhaustive. The Compliance Officer urges employees to always be vigilant for similar matters, as well as other matters, which may present a risk of conflicts of interest. If an employee is in doubt, they should seek advice from the Compliance Officer.

Disclosure of Conflicts of Interest

Information for clients. If the firm considers its measures to address the main conflicts of interest to be insufficient, it shall provide clients with clear and unambiguous information about the nature and source of the conflicts of interest before entering into a transaction with the client. The firm shall send the client a written notification and seek their consent for it to continue providing the specific service despite the conflict of interest.

Registration of conflicts of interest. The Compliance Officer maintains a record of activities that constitute securities transactions and are conducted by the firm or on its behalf, where a conflict of interest has arisen, which entails a real risk that the interests of one or more clients will be, or have been, harmed.

The list shall be updated regularly. The register shall contain information on which clients were involved, what transactions were concerned, and the types of the relevant financial instruments and business transactions.

The Society's Procedures for Preventing Conflicts of Interest

The association has established the following internal rules to prevent conflicts of interest:

(1) Rules on the separation of areas of responsibility (chinese walls) and security and communication rules.

(2) Rules on personal transactions of employees and directors.

(3) Rules of procedure of the company's board, which contain provisions on the eligibility of board members to participate in the consideration of matters, and provisions for facilitating dealings with parties related to board members. The rules also address the right of directors and employees to serve on the board and to participate in business activities.

Monitoring the implementation of the policy

The Compliance Officer is responsible for overseeing the implementation of this policy, and clients shall have the opportunity to direct comments to the Compliance Officer should they believe that an employee has breached this policy.

Policy Review

The association regularly reviews the policy to assess its effectiveness in implementation, whether with regard to the activities of individual departments within the association or to the association as a whole, and the association shall amend the policy if it is found not to be sufficiently effective or if changes in law and government regulations affecting its content occur.

If changes are made to the policy, the company will inform its clients by publishing an updated extract from the conflict of interest policy on its website.

Should the company engage in investment research, market making or other financial services, this policy will be revised accordingly.

This policy is available on the association's website. www.arev.is.

Take effect

Approved by the Board of Directors of Arev Securities hf. on 27 March 2026.