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7.4.4 Customer-related conflicts of interests
               Conflicts of interests must be avoided wherever possible. Where they cannot be avoided, there are
               clear  rules  which  establish  reporting  and  escalation  requirements  or  explicit  permissions  or
               authorisations to proceed. These rules are set out in detail in the Conflicts of Interests policy, which
               must be read in conjunction with this Code of Conduct.

               All actual and potential conflicts of interests must be recorded in the Conflicts of Interests register.

               Public representatives may include national or local political or public representatives, or persons
               carrying representative standing in the community.

               7.4.5 Personal conflicts of interests
                It is essential to ensure our personal interests do conflict with the wider interests of the Company or
               its customers. We must never misuse our position in the Company or use information obtained in the
               course of our employment to further our private interests or those of anyone with whom we have a
               relationship. We are required to always inform our line manager about any relationship that may
               affect our work by creating a conflict or even a perception of a conflict of interests. We must always
               take  ourselves  out  of  the  decision-making  process  where  there  is  an  actual  or  perceived  conflict
               between our own interests (or those of a person with whom we have a relationship) and that of the
               bank or its customers.

               As employees, we may not become involved in business or financial transactions with customers of
               the bank or transactions which could be perceived as being in competition with customers of the bank.
               Neither may we avail of any financial opportunities that arise or come to our attention in the course
               of employment because our personal interests could conflict (or be perceived as conflicting) with
               those of the Company or its customers.

               There is a range of activities which are specifically forbidden or limited, or for which prior authorisation
               is required. These include but are not limited to:

                   •  Personal dealing in shares and other financial instruments
                   •  Personal investment in private or unquoted public companies
                   •  External employment or business activities
                   •  Company directorships/officer positions (including acting as a shadow director)
                   •  Acceptance or proffering of gifts, benefits or inducements
                   •  Political activities/ holding public office.

               7.5 OUR STAFF
               Our success depends on our people and we strive to provide a stimulating workplace with a culture of
               openness and teamwork. We believe co-operation is key in maximising employee potential.

               Phil Reddin Financial Services Ltd. is an equal opportunity employer. We embrace diversity and oppose
               all forms of unlawful discrimination. We strive to  create a safe working environment and seek  to
               prevent any form of harassment or bullying. We make sure staff are treated with respect, dignity and
               fairness at all times. In summary, we treat others as we would like to be treated.

               We act with integrity and professionalism. We are held to high standards of personal behaviour and
               conduct, acting responsibly and promoting accountability in all areas of our work. We will always avoid
               situations which may give rise to conflicts of interests.





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