Conflicts of Interest Policy

HomeCubes

Version: 1.0
Date: 14 March 2025

1. Definitions

Homecubes: “We”, “we”, “Our”, “our” refers to Homecubes Management FZE and all affiliated entities, including subsidiaries and joint ventures under its control, with respect to policies and procedures.

Staff: “You”, “you”, “Your”, “your” refers to all Homecubes directors, officers, agents, employees, temporary workers, interns, consultants, contractors, vendors, or any other person employed by or working for Homecubes, regardless of the duration of their employment or contractual relationship.

2. Overview

Homecubes has a duty to minimize conflicts of interest between its employees and its clients. This policy sets out our framework for the identification, documentation, monitoring, and management of conflicts of interest. All conflicts of interest must be resolved by prioritizing client interests above those of the company.

This policy applies to all Homecubes employees. Employees must familiarize themselves with the requirements of this policy and fulfill the responsibilities outlined below.

Examples of conflicts of interest include:

Homecubes gains access to confidential information about an existing or former client that could benefit another client.
Homecubes engages services from an entity in which the Company’s Board members, directors, or representatives have controlling interests or substantial shareholdings.
Homecubes employees hold external positions that conflict with their fiduciary duties to Homecubes, such as serving on the board of a former, existing, or potential client’s company.

To address conflicts of interest, Homecubes follows this approach:

Decline to engage in the conflicted activity or transaction;
Disclose the material conflict of interest to the affected client; and
In certain cases, seek client consent or a waiver of the conflict.

3. Conflicts Identification

To identify actual or potential conflicts of interest, each employee must complete a Conflicts of Interest Declaration Form before commencing work at Homecubes. Employees must also promptly update the Compliance Officer on any changes.

The Declaration Form requires disclosure of:

Service on boards of directors, investment committees, outside business ventures, and other activities that could create conflicts of interest.
Situations that may involve insider trading risks or interfere with an employee’s duties to Homecubes.

If employees identify a potential or actual conflict of interest, they must report it to the Compliance Officer immediately and seek further guidance.

4. Conflicts Controls

To ensure fair and transparent operations and prevent conflicts of interest, Homecubes implements the following policies:

4.1 Information Barriers

Homecubes maintains Information Barriers to restrict information flows between different departments and prevent conflicts.
Duties are segregated for employees engaged in business operations and those responsible for recording and reconciliation of relevant information.

4.2 Board Members

If a Board member has a conflict of interest in a transaction, they must disclose it and abstain from voting.
The affected Board member must avoid influencing other Board members inside or outside of the meeting.
The conflict must be recorded in the relevant Board meeting minutes.

4.3 Employees’ Outside Business Activity

Employees are prohibited from serving as board members, employees, or consultants for external for-profit companies unless they obtain written approval from the Managing Director.
Employees must provide details about any proposed outside business activity, including the number of hours involved and any compensation received.
All outside business activities must be disclosed to and recorded by the Compliance Officer.

4.4 Transaction Restrictions

Employees are subject to personal trading restrictions, including:

Prohibition from engaging in transactions involving Virtual Assets listed on Homecubes’ internal control list.
Prohibition from holding shareholdings or directorships in entities listed on the internal control list.
Requirement to obtain prior written approval for certain trading activities.

4.5 Prior Approval

Employees must obtain written approval from the Compliance Officer before:

Opening, modifying, or closing any Virtual Asset positions held directly or indirectly.
Increasing or decreasing their shareholding in a legal entity other than Homecubes.
Taking up a directorship in any external legal entity.

4.6 Disclosure

Homecubes requires employees to report their holdings and activities every six (6) months, including:

All Virtual Asset positions held directly or indirectly.
Shareholdings and directorships in external legal entities.
Any changes in their financial interests that may pose a conflict.

If a conflict is identified, Homecubes may take action, including:

Requiring divestment of relevant assets or resignation from external directorships.
Implementing further internal controls to prevent conflicts of interest.

4.7 Other Measures

Implementation of a remuneration policy to prevent conflicts of interest.
Mandatory reporting of substantial gifts, entertainment, hospitality, and inducements.
Regular training for employees on identifying and managing conflicts of interest.

5. Recordkeeping

Homecubes maintains a register of conflicts of interest, including all reported conflicts and the measures taken to mitigate them.

6. Review of this Policy

The Compliance Department will review and update this policy periodically.

If material changes occur, the updated policy shall be circulated to all relevant stakeholders.

7. Conflicts of Interest Declaration Form

Homecubes monitors employee activities that may pose conflicts of interest. Employees must complete the following declaration:

1.) Do you expect to receive compensation or serve in an advisory role for any entity outside Homecubes?

□ Yes. Please provide details below.

□ No

2.) Are you or any immediate family members officers, directors, or significant shareholders in an entity that may relate to Homecubes’ business?

□ Yes. Please provide details below.

□ No

3.) Do you have any relationships or circumstances that may create a potential conflict of interest with Homecubes or its clients?

□ Yes. Please provide details below.

□ No

I confirm that the information above is true and complete. I agree to promptly notify Homecubes of any changes to the above information.

Employee/Contractor’s Signature

Name of Employee/Contractor