Conflict of Interest Policy

1. Scope

This policy applies to:

• All employees, officers, directors, and temporary staff (including interns).
• Third parties acting on behalf of Just Gold (e.g., advisors, consultants, contractors, suppliers, agents).
• Intercompany transactions within the Just Gold corporate structure.

This policy applies to all business activities, partnerships, and transactions, including dealings with clients, vendors, government agencies, investors, and regulatory authorities.

2. Definitions

• Conflict of Interest: Any situation where an individual’s personal, financial, or external interests compromise their ability to act in Just Gold’s best interests.
• Material Interest: A direct/indirect financial stake exceeding AED 5,000 annually in a competitor, supplier, or client.
• Immediate Family: Spouse, children, parents, siblings, or individuals residing in the same household.
• Compliance Officer: The designated authority responsible for conflict disclosures and oversight (📧 compliance@justgold.me).

3. Identifying Conflicts of Interest

Conflicts of interest may arise in various situations, including but not limited to:

4. Disclosure Requirements

• To ensure transparency, all employees and stakeholders must:
• Disclose conflicts within 3 business days of identification.
• Submit a written disclosure to the Compliance Officer detailing: Nature of the conflict, Parties involved, Potential impact on Just Gold, and Proposed mitigation steps.
• Failure to disclose may result in disciplinary actions, including termination, financial penalties, or legal proceedings.

5. Conflict Management Procedures

• Once a conflict is disclosed, the Compliance Officer will assess the conflict’s severity.
• Implement one or more of the following actions: Recusal (the individual is barred from related decision-making), Information Barriers (restricted access to sensitive internal data), Reassignment (transfer duties to an impartial employee or department), Transaction Termination (cancel dealings causing irreconcilable conflicts), and Stakeholder Notification (inform affected clients, partners, or investors if necessary).
• Document all actions in the Conflict Register for audit and compliance purposes.

6. Record Keeping

• All disclosures, actions, and resolutions will be retained for 5 years post-resolution.
• Records will be secured and accessible only to the Compliance Officer and the Board of Directors.

7. Compliance and Enforcement

• Annual Declarations: All employees and third parties must submit an annual conflict-of-interest declaration.
• Training & Awareness: Mandatory conflict management training is conducted during onboarding and annually thereafter.
• Penalties for Violations: Minor breaches may result in written warnings and additional training; major breaches may result in termination, contract suspension, financial penalties, or reporting to Meydan Free Zone authorities.
• Whistleblower Channel: Employees and stakeholders can report concerns anonymously via support@justgold.me.

8. Policy Review

• Annual Review: The Board of Directors will review this policy annually to ensure its effectiveness and compliance with UAE law.
• Communication: Updates will be communicated via email and the Company intranet.

9. Governing Law

• This policy is governed by UAE law and Meydan Free Zone regulations.