NEXTARTFX Conflict of Interest Policy

The financial trading services offered by NEXTARTFX are provided by NEXTART CO.,LTD. (operating under the trade name "NEXTARTFX")

We have an affirmative duty of care, loyalty, honesty, and good faith to act in the best interests of our clients. All supervised persons must refrain from engaging in activities or having personal interests that create a "conflict of interest."

A conflict of interest may arise when a supervisee's personal interests interfere or appear to interfere with the interests of the firm or its clients. A conflict of interest may arise when a supervisee takes actions or has interests that make it difficult for him or her to perform his or her duties and responsibilities to the Company honestly, objectively, and effectively.

While it is impossible to describe every situation in which a conflict of interest may arise, the following are situations in which a conflict of interest is likely to arise and is prohibited by our Code of Ethics.

A covered person may not favor the interests of one client over another (e.g., larger versus smaller accounts, accounts that are compensated with management fees versus those that are not, accounts in which an employee has significant personal investments, accounts of a close friend or relative of the covered person). Such preferential treatment is a breach of fiduciary responsibility.
A covered person is prohibited from using knowledge of a pending or currently contemplated securities transaction for a client to obtain personal gain directly or indirectly as a result of that transaction, such as by purchasing or selling such securities.
A covered person is prohibited from recommending, conducting, or considering a securities transaction for a client without disclosing to the compliance officer ("CO") any material beneficial interest, business or personal relationship, or other significant interest in the issuer of the securities or any of its affiliates. determines, based on that information, to be a material conflict of interest, the target may not participate in any decision-making process regarding the issuer's securities.
Pursuant to section 3.4.1 of the Anti-Money Laundering and Countering the Financing of Terrorism Handbook issued by the FSC in January 2020 (the "FSC Handbook"), the situation of the CO may be such that the CO is responsible for other aspects of the company's operations in addition to the functions of the CO as defined by Mauritius law. In such cases, the company must identify, document, and properly manage any conflicts of interest between the responsibilities of the CO's role and those of the other functions. However, the CO should be independent of the firm's core business activities and should not be engaged in the business of soliciting business/soliciting investments.

The Company and its officers will act in the best interest of its clients.

Registration of interested parties will be handled by the Company.
The personal interests of a director or any person closely associated with a director must not take precedence over the interests of the Company and its participants.
Directors should use their best efforts to avoid conflicts of interest, or situations that might reasonably be perceived by others to present a conflict of interest.
Full and timely disclosure of conflicts of interest or potential conflicts of interest related to directors and management must be made in writing.
In the event of an actual or potential conflict, a director may participate in the discussion or express a vote on the matter, provided that he or she declares an interest and confirms that it is registered in the Company's register of interests, but such vote shall not count. In such circumstances, Directors must carefully consider the possible consequences to the Board and the Company.
Directors should recognize that their duty and responsibility as directors is to act at all times in the best interests of the Company and not any other party.
Directors and officers should treat as strictly confidential any confidential matters concerning the Company that come to their knowledge in the course of their duties as directors/officers and should not divulge them to anyone without the authority of the Board of Directors. With respect to such requests, the Board must consider the merits on a case-by-case basis.
Managing Conflicts of Interest
For a firm that engages in multiple regulated activities for its clients, it is critical to identify and manage any conflicts of interest that may arise in the course of providing such services.

Conflicts of interest may arise between the interests of the Company and its clients, and between the interests of one client and another. We seek to manage these conflicts of interest in the following ways

Establishing a clear Chinese Wall separating the administrative and advisory functions
Independent oversight
Disclosure of information
Declining to provide services
Gifts and entertainment
Covered Persons may not accept inappropriate gifts, favors, entertainment, special favors, or anything else of value that could influence a decision or cause an individual or firm to feel indebted. Similarly, Covered Persons may not offer gifts, favors, entertainment, special favors, or anything else of value that could be considered overly generous, intended to influence a decision or to make a customer feel indebted to the Company or Covered Person.

No Covered Person shall accept gifts, services, or other things of more than minimal value from any person or entity doing business with or on behalf of ID. No Target shall offer or give a gift of more than de minimis value to any existing or potential customer or any entity doing business with or on behalf of ID without prior written approval by the CO. Gifts of $250 or less received annually from the same donor are considered de minimis value. In addition, the receipt of an occasional dinner, tickets to a sporting event or theater, or comparable entertainment is also considered to be of minimal value if the person or entity providing the entertainment is present. All gifts given or received will be recorded on a log signed by the supervised person and the CO and kept in the supervised person's file

No Covered Person shall give or accept cash gifts or cash equivalents to or from clients, potential clients, or any entity doing business with or on behalf of the Advisor.

Bribes and kickbacks are criminal offenses and are strictly prohibited by law. Covered Persons must not offer, give, solicit, or accept any form of bribe or kickback.

Political Contributions and Charitable Contributions
Covered Persons who make political and charitable contributions in cash or services must report each such contribution to the CO, who will report such contributions in aggregate as required by the relevant regulations. Covered Persons are prohibited from considering ID's current or future business relationships as a factor when soliciting political or charitable contributions. This policy is only enforced when a government entity is a client of ours.

Supervised persons must respect the confidential nature of information learned in the course of their work and must not disclose such information unless authorized or legally required to do so. They must not use confidential information learned in the course of their work for personal gain. Supervised persons must keep in strict confidence all information concerning clients (including former clients), including the identity of the client (except with the client's consent), the client's financial condition, securities held by the client, and advice provided by the firm to the client.

Appointment to the Board of Directors
A supervised person shall not join the board of directors of a listed company without prior approval by the CO. Such approval will be given only if it is determined that such appointment to the board is in the best interests of the customer and the company, and if the person to be appointed to the board is separated from those who make investment decisions regarding the company in question through proper procedures. Directors of privately held companies may be asked to resign immediately or at the end of their current term if the company goes public during their term as directors.

Relationship with Regulatory Agencies
Directors may have contact with representatives of regulatory agencies in the course of their duties. Directors are expected to deal cooperatively with regulatory agencies and must respond promptly to any disclosure obligations.