Risk Disclosure

1. General

nealthy (hereinafter referred to as the “Company”) takes very seriously its Conflict of Interest as set out by the VARA.

We are dedicated to proactively addressing all forms of conflicts of interest and are committed to full transparency in disclosing any such conflicts.

Various guidelines and protocols are in place to safeguard our clients' interests at all times. For a more comprehensive understanding, you are welcome to review our conflicts of interest policy.

2. Purpose

The Company serves as a VASP providing a comprehensive range of wealth and investment services to its clients. Given the nature of financial services, conflicts of interest are inevitable in some activities. However, our primary concern is to protect the interests of our clients. Our Conflicts of Interest Policy is designed to do just that:

• Detect situations that may result in conflicts of interest, particularly those that could materially harm our clients' interests.
• Implement and sustain suitable mechanisms and systems to manage such conflicts effectively.

3. Objectives

The company aims to:

• Adopt and regularly update policies and procedures across all business units to manage conflicts of interest, subject to ongoing monitoring and reviews.
• Establish both physical and digital barriers to information flow to prevent the unauthorized exchange or misuse of confidential, non-public information.
• In cases where dual functions within Nealthy could lead to conflicts of interest, either separate these functions into distinct business units or assign them to different senior management personnel.
• Align compensation structures, including pay and bonuses, with the performance of Nealthy or specific departments, ensuring that this alignment does not create conflicts of interest.

4. Procedures to Counteract Conflicts of Interest

4.1. Policies and Procedures

The Company and its subsidiaries have adopted policies and procedures across their businesses to manage conflicts of interest. These will be subject to our regular monitoring and review processes.

4.2. Information Barriers

nealthy has established physical and electronic Information Barriers designed to prevent the exchange or misuse of material, non-public information. Employees are prohibited from inappropriately sharing sensitive information.

4.3. Separation of Functions

If a business with two functions within nealthy would lead to conflicts of interest, the functions may be separated into two independently managed businesses or overseen by different senior staff.

4.4. Pay

Pay and bonuses are often linked to the profits of nealthy or the specific department, without resulting in a conflict of interest.

5. Responsibilities

The Company will ensure that all staff are provided with the time, training and support to learn, understand and implement this policy and any related regulatory requirements. The Board is responsible for understanding the obligations under the regulatory system and for ensuring that they know, understand and comply with the Company’s objectives and approach to Conflicts of Interest.