Conflicts of Interest Policy

1. RFC shall avoid conflicts of interest where this is possible and, where it is not, ensuring – by way of disclosure, internal procedures or otherwise – that customers are treated fairly.

2. If in a particular situation RFC does not act independently of all product providers it will make clear to prospective customers its affiliations and the limitations as to the investment services it will provide.

3. Where RFC has a material interest in a transaction, before undertaking that transaction for or on behalf of a customer, RFC shall disclose the material interest to the client.

4. RFC, its directors and employees shall avoid placing themselves in a situation where a conflict with the interest of customers may arise. Employees and directors must disclose to the Compliance Officer any situations that reasonably would be expected to give rise to, or the appearance of, a conflict of interest.

5. No director or employee of RFC may take up an appointment as a Director or employee of an issuer of a Listed Security, or occupy a position of trust with such issuer.