CONFLICTS OF INTEREST AND COMPETITORS

At BEE INVEST, we value integrity and respect for our organization. As employees,

we avoid situations giving rise to conflicts of interest where our private interest could influence the decisions we make. Accordingly, we preserve and implement effective procedures designed to identify potential conflicts of interest. We also strive to ensure that the internal systems, control mechanisms and procedures adequately serve the purpose of identifying and managing conflicts of interest.

1. We provide no advisory services to competitors of the Group.
2. We provide no services to the Group’s competitors under an employment contract or a mandate contract, nor do we hold any positions on the governing bodies of such companies.
3. We may only hold shares in a competitor in a number that precludes us from exerting any influence on the competitor’s business decisions.
4. We refrain from participating in or exerting an influence on the supplier selection process if we hold any shares in that supplier or if our relative or another closely related person is either an owner or employee of that supplier.
5. We never invest in shares of a supplier if we are involved, directly or indirectly as a supervisor, in the selection or assessment of, or are in negotiations with, that supplier.
6. We never invest in shares of a BEE INVEST supplier if we are responsible, directly or indirectly as a supervisor, for dealing with that supplier.
7. Any other relations with the Company’s competitors, customers or suppliers that may involve a conflict of interest must be reported to our manager, and handled in accordance with the relevant internal regulations. In particular, a written approval must be sought and, if doubts persist, the Ethics Committee must be consulted.
8. At BEE INVEST, we avoid situations that could raise a suspicion of nepotism, including in the manager/subordinate context, in relation to relatives or other closely related persons.