CONFLICT OF INTEREST

Introduction

GreenFence provides a wide range of services and therefore carries out many transactions on a permanent basis. In the context of these activities, conditions may arise that lead to incidents of conflict of interest, either on an exceptional basis or on a recurring basis. This document reflects the policy adopted by the company regarding the procedures to be followed in the event that an incident of conflict of interest arises .

Definitions

Conflict of Interest: A conflict of interest exists when one or more persons face competing interests and serving the interest of one may work to the detriment of the other. A situation of conflict of interest also means any situation in which the possibility of independent and complete assessment, judgement, objectivity or decision-making of employees is affected or may be affected from personal interests, the satisfaction of which conflicts with the interests of the company, from the interests of third parties, from actions or omissions of the staff that may endanger the interests of the company and/or its customers (e.g. Obstructing the performance of duties, violation of regulations and instructions, breach of trust or acts that harm the prestige and reputation of the company).
Conflict of Interest Policy: It is the policy that defines the framework for identifying, managing, dealing with and avoiding a conflict of interest incident.
Economic Interest: Anything that brings economic or monetary benefit to a person.
Customer: Any natural or legal person or association of Persons who receives the services provided by the company, regardless of whether he is acting on his own behalf or on behalf of a third party.
Associated Persons: Associated persons are considered to be those who are connected in any of the following ways to the person carrying out the transaction. They are the spouse or partner of this person who is assimilated to a spouse according to the applicable legislation, the dependent children and/or the dependent stepchildren of the person carrying out the transaction and the other relatives of the person carrying out the transaction who, at the time of carrying out the transaction, lived for at least one year, in the same family home as the person carrying out the transaction.

Purpose of the Policy

The purpose of this policy is to establish a framework and provide guidelines for managing, dealing with and preventing conflicts of interest.

Specifically, the Conflict of Interest Policy contributes to the following:
- Identifying situations from which a conflict of interest may arise which will harm the interests of the client or the company.
- In the application of appropriate procedures and in the operation of mechanisms and systems for the management of conflicts of interest
- In the design and implementation of tactics with a preventive role against the damages that can be caused to clients and the company by possible conflicts of interest.

Field of application

This Policy extends to all activities and services provided by GreenFence to its customers and to all of the company’s employees, in particular to those employees who, due to their job position, carry out more frequent transactions. For the purposes of this Policy, customers of GreenFence are considered both existing and new customers. Every transaction and company activity is governed by the provisions of this policy and its content must always be taken into account.

POLICY

GreenFence adopts a policy to identify means of dealing with situations of conflict of interest and to prevent inappropriate behavior of personnel that may lead to situations of conflict of interest. For these reasons, GreenFence records and monitors staff transactions. Transactions carried out are kept on file and can be investigated whenever necessary.

Those carrying out the transactions should act according to the following:

Transactions should be carried out in a transparent manner to ensure their legality and correctness.
The transactions should not contradict the applicable legislation and the applicable regulations and should not contradict the content of this Policy.
Transactions should not distract the employee from the duties of his job.
Transactions should not threaten the reputation and prestige of the company.
Transactions should not involve the misuse or improper disclosure of confidential information.
Transactions should not be the result of abuse of power.
Transactions should not be against the interests of the company.
In order to effectively implement this Policy, GreenFence provides the required training and information to its employees regarding conflict of interest issues. Through this training, employees develop the ability to identify conflict of interest incidents and, once they have received the appropriate training, to be able to deal with and manage them. In addition, these training programs are suitable to enhance the awareness of staff regarding conflict of interest situations by providing the relevant information.
Finally, GreenFence, aiming at the early diagnosis of potential conflict of interest situations, applies the necessary procedures so that the incidents are identified and settled. All incidents of conflict of interest are recorded and kept on file.
In cases where, despite the fact that preventive measures have been implemented, but it is judged that the conflict of interest situation is unavoidable and its avoidance cannot be ensured, GreenFence informs its clients before performing the relevant act on their behalf.