Conflicts of Interest Policy

1. Why this policy exists

MT Capital Markets Ltd, trading as RockLake Capital, aims to act honestly, fairly and professionally in your best interests. A conflict of interest can arise whenever our interests, or those of our staff, could compete with yours, or where the interests of two clients could compete with each other. This policy sets out how we try to identify, prevent, manage and, where necessary, disclose such conflicts.

2. Who and what it covers

This policy applies to our directors, officers and staff and to anyone connected to them, and to everything we do: choosing which products to make available, arranging investments, allocating limited opportunities, handling payments, and using information about clients and issuers.

3. Examples of conflicts we look for

• Where we or our staff hold a personal interest in a product offered on the Platform.
• Where a product on the Platform is offered by a party connected to us, or pays us a fee or commission for making it available.
• Where the interests of one client could be favoured over another, for example in how a limited allocation of a new issue or IPO is divided.
• Where a staff member's outside role, investment, or relationship could influence a decision they make for the Platform.
• Where, by arrangement with a client, we invest before their money has reached us. We then have a credit exposure to that client, and our interest in recovering the balance could differ from the client's interest.
• Where staff learn non-public information about an issuer, especially in a pre-IPO or new-issue setting, and could be tempted to trade on it or pass it on.
• Where pay or incentives could encourage staff to favour one outcome, product or volume of business over what is right for a client.
• Gifts, hospitality and other benefits offered to staff by anyone doing, or seeking, business with us.

4. How we manage conflicts

• Identifying likely conflicts before they arise, as part of how we design and review products and processes.
• Keeping decision-making about which products are offered separate from any commercial relationship with the party offering them, wherever practicable.
• Requiring staff to declare personal interests, outside roles and holdings that could conflict with their duties, and restricting their personal dealing where needed.
• Limiting access to non-public information to those who need it to do their jobs, and forbidding its use or disclosure for personal advantage.
• Applying fair, documented allocation approaches where demand for a limited product exceeds supply.
• Requiring gifts and hospitality to be declared and, above set limits, approved.
• Having our compliance function oversee this policy independently of the commercial teams, and giving staff a way to raise concerns.
• Maintaining a record of identified conflicts and how each was addressed.

5. Disclosure

Where a conflict cannot be fully managed by the steps above, we will disclose it to you clearly before you invest, so you can decide whether to proceed with that information. Disclosure is a safeguard we use when prevention and management are not sufficient on their own, not a substitute for them. If we cannot manage a conflict acceptably, we will decline to proceed.

6. Fees and connected parties

We may earn fees, commissions or other benefits in connection with products made available on the Platform, including from managers, issuers or other parties connected to a product. Where relevant, this is disclosed as part of that product's offering documents.

7. Your part

If you think we have a conflict that we have not told you about, or that is not being managed, please tell us at ir@rocklakecapital.com.

8. Reviewing this policy

We review this policy periodically and update it as our products, staff and business relationships change. The version and date at the top of this page show when it was last updated.

9. Contact

Questions about this policy, or a conflict you'd like to raise: ir@rocklakecapital.com.