Conflict of Interest Policy Summary Notice

1. Introduction

Monolith Market is the trading platform operated by Monolith Private Wealth Limited ("MPW", the “Company”, "we", "us", or "our"), a company incorporated in the Republic of Mauritius and licensed by the Financial Services Commission (the “FSC”) as an Investment Dealer (Full Service Dealer, excluding Underwriting) and as an Investment Adviser (Unrestricted).

While providing brokerage and investment advisory services, situations can arise in which our interests, or the interests of our employees, officers, or affiliates, may conflict with the interests of our clients, or in which the interests of one client may conflict with the interests of another. The integrity of our business and the trust of our clients depend on how we identify, prevent, and manage these conflicts.

This Notice is a public-facing summary of MPW's internal Conflicts of Interest Policy, which is set out in Section 7 of MPW's Internal Operations Manual. It is provided in compliance with our obligation under the FSC Code of Business Conduct, the National Code of Corporate Governance of Mauritius (2016) and Section 4.4.2 of the Internal Operations Manual to make a description in summary form of our conflicts of interest policy available to clients in a durable medium. Further details of the underlying policy are available on request, free of charge.

2. Regulatory Framework

The Company's approach to conflicts of interest is based on, and complies with, the following principal Mauritian regulatory instruments:

• Securities Act 2005 — The licensing framework for investment dealers and investment advisers, which imposes conduct duties including the duty to act in the best interests of clients.

• Financial Services Act 2007 — FSC's regulatory mandate and licensee conduct standards.

• FSC Code of Business Conduct — In particular Guiding Principle 4.3 on Conflicts of Interest, requiring licensees to identify and manage conflicts fairly.

• The National Code of Corporate Governance of Mauritius (2016), Second Edition (November 2016_

• MPW Internal Operations Manual — Section 7 of the IOM (Conflicts of Interest), which sets out the binding internal framework that this Notice summaries.

3. What Is a Conflict of Interest?

A conflict of interest arises in any situation where MPW, or any of our employees, officers, directors, or affiliates, has an interest that may compromise — or may appear to compromise — the obligation to act in the best interests of a client. Following the framework adopted in Section 7.3 of the IOM, MPW considers that a conflict of interest may arise where MPW or a relevant person:

• Is likely to make a financial gain, or to avoid a financial loss, at the expense of the client;

• Has an interest in the outcome of a service provided to the client, or of a transaction carried out on behalf of the client, which is distinct from the client's own interest in that outcome;

• Has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client;

• Carries on the same business as the client; or

• Receives, or will receive, from a person other than the client, an inducement in relation to a service provided to the client — in the form of monies, goods, or services — other than the standard commission or fee for that service.

4. Types of Conflicts That May Arise

The following are illustrative — not exhaustive — examples of the kinds of conflicts that may arise while providing services through the Monolith Market platform:

5. How We Prevent and Manage Conflicts

The Company operates a four-tier framework for handling conflicts of interest, in line with FSC expectations and the principles set out in Section 7 of our Internal Operations Manual. The approach moves from prevention through to management, disclosure, and (in the last resort) refusal to act.

5.1 Tier 1 — Prevention

Prevention is the first line of defence. MPW puts in place organisational arrangements designed to ensure that conflicts do not arise in the first place, or if they do arise, that they cannot affect the client. Preventive measures include:

• Organisational separation of business units (“Chinese walls”) — the Back Office, Accounting, and Dealing Room functions are physically and operationally separated to prevent the flow of confidential information that could harm client interests;

• Independent supervision of employees whose principal functions involve carrying out activities for clients whose interests may conflict;

• Removal of any direct link between the remuneration of relevant persons in one activity and the revenues generated by another activity, where a conflict could arise;

• Restrictions on personal transactions by employees (see Section 6 below);

• Prohibition of certain transaction practices that are recognised as inherently conflicted (see Section 7 below); and

• Information barriers and access controls that prevent unauthorised exchange of client information across business units.

5.2 Tier 2 — Management

Where a conflict cannot be prevented entirely, the Company manages it through specific operational controls, which may include:

• Allocation of order flow among clients on a fair and equitable basis, in accordance with our Order Execution Policy;

• Independence of investment advice given to clients from MPW's proprietary positions;

• Approval requirements for outside business activities, directorships, and material personal investments by employees;

• Pre-clearance of gifts and hospitality above a defined threshold;

• Independent review of recommendations and discretionary decisions by the Compliance Officer where required;

• Escalation of any identified conflict to the Compliance Officer (and, where relevant, the MLRO) for assessment; and

• Engagement of independent third parties (e.g., external auditors, independent advisers) where additional assurance is required.

5.3 Tier 3 — Disclosure

Where a conflict of interest cannot be prevented or fully managed through internal arrangements, MPW will disclose the conflict to the affected client before providing the relevant service. In accordance with Section 7.3 of the IOM, the disclosure shall:

• Be made in a durable medium (in writing through the Monolith Market platform, by email, or by other suitable means);

• Be made before MPW provides the service in respect of which the conflict arises;

• Include sufficient detail — considering the nature and profile of the client — to enable the client to take an informed decision; and

• Be followed by the client's express consent, which shall be recorded by MPW.

5.4 Tier 4 — Refusal to Act

Where a conflict cannot be prevented, managed, or adequately addressed through disclosure — or where the Compliance Officer concludes that proceeding with the service would not be in the client's best interest — MPW will refuse to provide the relevant service. This is the last line of defence and reflects our commitment that the integrity of the client relationship is paramount.

6. Personal Transactions by Employees

The Company maintains specific arrangements, set out in Section 7.6 of the IOM, designed to prevent improper personal transactions by its employees and other relevant persons. In particular:

• Employees and other relevant persons are prohibited from entering into personal transactions that misuse confidential information or that conflict with their duties to clients;

• Employees are prohibited from advising or procuring any other person to enter into a transaction in financial instruments that they themselves would not be permitted to enter into;

• Employees are prohibited from disclosing — outside the normal course of their employment — any information or opinion that could enable another person to enter into such a transaction;

• MPW maintains procedures to be informed promptly of any personal transaction entered into by an employee, either through notification by the employee or through other identification procedures;

• MPW shall not misuse information relating to pending client orders and takes all reasonable steps to prevent the misuse of such information by any employee.

7. Prohibited Transaction Practices

In accordance with Section 7.4 of the IOM, the following practices are expressly forbidden and considered serious breaches of conduct at MPW:

• Providing services to a client with the purpose of influencing the transaction for the benefit of MPW or related persons, particularly with respect to transactions that MPW or related persons are about to effect before or after the service;

• Using client transaction information for MPW's own benefit, or disclosing that information to third persons;

• Preferential treatment of MPW employees or members of staff at the expense of clients during the provision of services;

• Effecting transactions by employees or directors for their own account, or for the account of persons related to them, based on confidential information acquired in the course of employment with MPW.

All employees are required to be aware of these forbidden practices and to report any actual or suspected occurrence to the Compliance Officer or MLRO immediately.

8. Conflicts Register

The Compliance Officer maintains a Conflicts Register recording the categories of investment service or activity carried out by the Company in respect of which a conflict of interest entailing a material risk of damage to client interests has arisen or is likely to arise. The Register includes:

• The nature and category of the conflict;

• The services or activities involved;

• The clients affected (or types of clients affected);

• The steps taken to prevent, manage, or disclose the conflict;

• Any consents obtained from clients following disclosure; and

• The outcome of the matter.

The Conflicts Register is reviewed by senior management on a regular basis and is made available to the FSC upon request. It is not made publicly available because it contains confidential business information.

9. Specific Situations — How We Handle Common Conflicts

The following examples illustrate, in plain terms, how the Company handles some of the most common situations that arise in the brokerage and advisory context:

9.1 Multiple Clients Seeking the Same Limited Opportunity

Where two or more clients wish to participate in the same investment opportunity, but capacity is limited, MPW allocates participation on a fair and equitable basis, applying objective criteria (e.g., time of request, pro-rata allocation, suitability of the investment for each client) and avoiding any favouritism.

9.2 Same-Direction Orders

Where multiple clients place orders in the same security in the same direction, MPW aggregates and executes those orders on a fair basis and allocates the resulting fills proportionally, in accordance with the Best Execution Policy.

9.3 Opposite-Direction Orders

MPW does not engage in matched-principal or internal-crossing transactions that would put one client on the opposite side of another client without specific safeguards and disclosures. Client orders are executed through external venues consistent with the Best Execution Policy.

9.4 Discretionary Management and Trading Decisions

Discretionary investment decisions made by MPW on behalf of clients are made by reference to each client's documented investment objectives, risk profile, and mandate, and not by reference to MPW's own commercial interests. Decisions are subject to compliance review against the client's Suitability Profile.

9.5 Investment Advice and Recommendations

Personal recommendations made to clients are made in accordance with the Suitability and Appropriateness Policy and are not driven by remuneration arrangements that incentivise the recommendation of particular products. MPW does not operate remuneration structures that link an employee's compensation to the volume of any specific product sold.

9.6 Receipt of Third-Party Inducements

MPW does not accept inducements from product providers, market makers, or other third parties that would conflict with its duty to act in the best interests of clients. Where the Company receives minor non-monetary benefits (e.g., generic market commentary, research access), these are subject to internal approval to confirm that they enhance the quality of service to clients without giving rise to a material conflict.

9.7 Affiliated Service Providers

Where MPW uses affiliated parties as service providers (e.g., for custody, clearing, technology, or administrative services), the engagement is conducted on arm's-length commercial terms reviewed by independent management. Use of an affiliate is disclosed where the relationship is material to the client.

9.8 Gifts and Hospitality

Employees may not solicit gifts or hospitality from clients, suppliers, or counterparties. Gifts and hospitality of any material value received by an employee must be pre-cleared by the Compliance Officer and recorded. The threshold for pre-clearance is set out in the internal Company’s policies and procedures.

9.9 Outside Business Activities

Employees and directors are required to disclose all outside business activities — including external directorships, consultancies, and significant personal investments — to the Compliance Officer. Activities that would create a material conflict with the employee's duties to MPW or to clients are not permitted.

10. What to do if you identify a Possible Conflict

If you become aware, or suspect, that a conflict of interest may exist or has not been properly managed in connection with the services provided to you, we encourage you to:

• Raise the concern with the relevant relationship manager or with our customer service team in the first instance;

• If the concern is not satisfactorily addressed, escalate the matter to the Compliance Officer at compliance@monolithmarket.com;

• If you remain dissatisfied, submit a formal complaint under the Complaints Handling Procedure (available on the Monolith Market website and in the mobile application); and

• If your complaint is not resolved to your satisfaction, you have the right to escalate to the Office of the Ombudsperson for Financial Services or to the FSC, as set out in the Complaints Handling Procedure.

MPW is committed to acting promptly and transparently in the face of concerns raised by clients regarding conflicts of interest and treats such concerns seriously.

11. Availability of the Full Policy

This Notice is a summary. The full Conflicts of Interest Policy is set out in Section 7 of MPW's Internal Operations Manual and forms part of MPW's internal compliance framework. Pursuant to Section 4.4.2 of the IOM, clients have the right to request further details of the Conflicts of Interest Policy at any time, in a durable medium and free of charge. Such requests may be made through the channels set out in Section 13 of this Notice.

Please note that certain elements of the full Policy contain confidential operational information (for example, the names and roles of specific personnel, internal monetary thresholds, and the specific contents of the Conflicts Register) and are not disclosed publicly. MPW will provide a redacted version of the relevant operational information where appropriate.

12. Policy Review and Updates

This Notice and the underlying Conflicts of Interest Policy are reviewed by MPW's Compliance Department at least annually, and earlier upon:

• Any material amendment to the Securities Act 2005, the Financial Services Act 2007, the FSC Code of Business Conduct, or related FSC rules and guidance;

• Issuance of any relevant circular, or guidance note by the FSC;

• Material changes in MPW's product offering, client base, distribution model, or affiliated structure;

• Findings from internal audit, compliance review, or FSC inspection relating to conflicts management; and

• Recurring patterns identified through the Conflicts Register or through complaints data.

Material amendments to this Notice will be published on the Monolith Market website and in the mobile application with reasonable advance notice.

13. Confidentiality & Non-Retaliation Undertakings

• All disclosures are treated with utmost confidentiality, subject to legal requirements and the provisions of the Data Protection Act 2017 which is harmonised with GDPR Regulations;

• Personal information in the Register of Interests protected appropriately;

• Individuals who report conflicts of interest are protected from retaliation;

• No adverse action against good-faith reporters;

• Violations of non-retaliation will result in disciplinary action.

14. Legal Disclaimer

Disclaimer: This Notice is a public-facing summary of MPW's internal Conflicts of Interest Policy and is provided for general informational purposes. It does not constitute legal or financial advice and does not create any contractual obligation between MPW and any reader. The detailed binding internal policy is set out in Section 7 of MPW's Internal Operations Manual. Where any conflict arises between this Notice and applicable Mauritian law, FSC rules, or the terms of the Client Agreement, the law, rules, or Client Agreement (as applicable) shall prevail. MPW reserves all of its rights under applicable law and the Client Agreement.