5.1 This Policy is implemented through a combination of disclosure requirements, preventative measures, and monitoring systems.

5.2 Identification of Conflicts

(a) Employees must complete an annual declaration of interest form detailing any outside business activities, relationships, financial interests or factors listed in Section 4 that could lead to a Conflict of Interest;

(b) Lexim will provide regular training and awareness programmes to help employees and managers understand what constitutes a Conflict of Interest, how to identify potential conflicts in their daily activities, and how to manage a Conflict of Interest. These programmes shall include understanding the importance of maintaining professional boundaries and avoiding situations that could lead to a Conflict of Interest;

(c) If a potential Conflict of Interest is recognised, employees and managers are required to disclose or report any such conflicts as soon as possible to their immediate supervisor, who must relay the information to the CO. Such disclosure or report must include all relevant details, e.g., the nature of the conflict and the parties involved.

5.3 Management and Prevention Procedures

(a) For the purpose of taking into account the interests of all of its clients, Lexim shall establish and implement a remuneration policy that is approved by the board of directors ("Board of Directors") of Lexim, which include the following rules:

(i) Lexim shall preserve the integrity of the client's interests from the remuneration practices and provide fair treatment towards all of its clients; and

(ii) The remuneration policy shall not create a Conflict of Interest or incentive that may cause relevant individuals to prioritise their own interests or Lexim's interests, potentially harming the clients.

(b) Regarding the provision of advice or conducting portfolio management for the clients or any third party:

(i) Lexim shall not accept and retain fees, commissions, or any monetary or non-monetary benefits paid or provided by any third party or a person acting on behalf of a third party;

(ii) All commissions or monetary benefits received from the client or the relevant third party for the provision of services must be transferred in full to the client or the relevant third party;

(iii) Lexim shall establish and implement a policy to ensure transparency regarding any fees, commissions, or any monetary or non monetary benefits paid or provided by the client or any third party or a person acting on behalf of a third party;

(iv) Lexim must inform the clients about the fees, commissions, or any monetary or non-monetary benefits transferred to them through periodic reporting statements provided to the clients or the relevant third party; and

(v) Lexim is exempted from the provisions of Subsection (b) paragraph (i) to (iv) of this

Policy in the event that Lexim receives minor non-monetary benefits which may potentially enhance the quality of service provided to the client and are of a scale and nature that they would not be deemed to impair compliance with Lexim's duty to act in the best interest of the client.

(c) Lexim shall not receive any remuneration, discount, or non-monetary benefit for routing client orders to a particular trading venue which would infringe the requirements of Conflict of Interest or inducements;

d) The CO must maintain a Conflict of Interest register to document disclosures or reports of any Conflict of Interest ("Conflict of Interest Register") and regularly review such disclosures to identify any patterns or recurring issues.

(e) The CO must conduct periodic audits of employee activities and financial interests to identify any unreported conflicts.

(f) Where appropriate, Lexim may impose permanent or ad hoc information barriers, which may include the implementation of physical and/or procedural systems and processes, as detailed further in Clause 5.6 of this Policy below.

5.4 Resolution and management of Conflict of Interest

(a) When a conflict is identified, the CO should work with the employee or manager and their supervisor to develop and implement an appropriate mitigation strategy. This may include:

(i) reassigning the employee to a different tasks or role;

(ii) implementing additional oversight;

(iii) monitoring the employee's or the manager's activities; and/or

(iv) requiring the employee or manager to step away from certain decisions or transactions relating to the Conflict of Interest.

(v) promptly disclosing the nature of the conflict to any affected client(s) where Lexim is unable to avoid the conflict despite reasonable efforts, and taking all reasonable steps to ensure the fair treatment of such client(s).
(b) Conflicts Involving Board Members In cases where a member of Lexim's Board discloses to the Board that they have a material

interest in a transaction:

(i) The remaining Board members present at the meeting shall:

• assess whether the conflict may affect the objectivity of that Board member and/or their ability to perform their duties owed to Lexim adequately; and, on the basis of that assessment,

• decide whether the conflicted Board member may participate in related discussions or decision-making processes. The conflicted Board member will not be permitted to engage in any discussion of, or vote on, this matter.

(ii) If the remaining Board members present at the meeting decide it is not appropriate for the conflicted member to participate in related discussions or decision-making processes, corresponding restrictions will be placed on the conflicted Board member's voting and participation rights, and they may be asked to leave the Board meeting.

(iii) The conflicted Board member will not be permitted to use their personal influence to affect discussions, decisions, or outcomes relating to matters in which they are conflicted, both inside and outside Board meetings.

(iv) The conflict will be recorded by the Company Secretary in the minutes of the relevant Board meeting.

(c) Segregation of Duties and Preventive Measures

(d) Strict segregation of duties is to be enforced in areas where conflicts are likely, such as trading and compliance functions.

(e) If Lexim has any information or reason to believe any board member or staff is likely to cause or has caused, an actual or

potential conflict of interest, Lexim shall take all necessary actions to ensure such conflict of interest is removed, including but not limited to:

(i) procuring the relevant board member or staff to divest the relevant virtual asset positions or shareholding;

(ii) resign from the board of the other legal entity; or

(iii) any other action required to remove the conflict of interest, either with respect to the other entity or Lexim.

(f) procuring the relevant board member or staff to divest the relevant virtual asset positions or shareholding; resign from the board of the other legal entity; or any other action required to remove the conflict of interest, either with respect to the other entity or Lexim.

5.5 Disclosure to Affected Clients

In the event that Lexim cannot avoid a conflict of interest after using all reasonable efforts, Lexim shall:

(a) promptly disclose the nature and circumstances of the conflict to the affected client(s);

(b) to the extent that the affected client’s interests can be sufficiently protected, manage and minimise such conflict by adopting appropriate measures to ensure fair treatment of the affected client. Such measures may include establishing ad-hoc or permanent information barriers, such as those described in Clause 5.6 of this Policy below, and/or appropriately segregating employee duties, or supervision and reporting lines; and

(c) cease or decline to provide a client with relevant services, where Lexim believes a conflict of interest cannot be otherwise managed

Where a conflict of interest has resulted in the affected client(s) being adversely impacted, Lexim will, where appropriate and in accordance with applicable laws and regulations, provide compensation to the affected client(s) which it has reasonably assessed as adequate to address the loss or damage suffered by that client directly resulting from the conflict of interest, taking account of the circumstances and any available evidence of such loss or damage.