Conflict of Interest Policy

Last Updated: November 2025

Purpose

InTech Next (“the Company”) is committed to the highest standards of integrity, transparency, and professionalism. This Conflict of Interest Policy (“Policy”) establishes clear rules for identifying, disclosing, and managing actual, potential, or perceived conflicts of interest to ensure that all decisions are made in the best interests of the Company, its clients, and stakeholders.

A conflict of interest arises when personal, financial, or other interests may compromise—or appear to compromise—professional judgment, independence, or objectivity.

1. Scope

This Policy applies to:

• All employees, directors, officers, contractors, consultants, and representatives of InTech Next.
• All business activities, projects, partnerships, and client engagements.
• Any external activities, financial interests, or relationships that could influence decisions or create a perception of bias.

2. Core Principles

• Integrity and Objectivity – All decisions must be made impartially and in the best interest of the Company and its clients.
• Transparency – Any actual, potential, or perceived conflict must be disclosed immediately.
• Accountability – Individuals must take responsibility for avoiding situations that could compromise professional judgment.
• Compliance – Adherence to all applicable laws, regulations, and contractual obligations is mandatory.

3. Examples of Conflicts of Interest

Conflicts may include, but are not limited to:

• Holding financial interests in clients, suppliers, or competitors.
• Personal or familial relationships influencing business decisions.
• Outside employment, consultancy, or business activities that compete with the Company.
• Receiving gifts, hospitality, or benefits that could influence professional judgment.
• Making decisions affecting entities in which the employee has a financial or personal stake.

4. Mandatory Disclosure

Employees, contractors, and representatives must:

• Immediately disclose any actual, potential, or perceived conflict to their direct manager or Compliance Officer.
• Provide complete details, including involved parties, nature of interest, and potential impact.
• Update disclosures promptly if circumstances change.

Failure to disclose a conflict will be considered a serious violation of this Policy.

5. Management of Conflicts

Upon disclosure, the Compliance Officer and senior management will:

• Assess the conflict’s nature, scope, and potential impact.
• Determine appropriate action, which may include:
• Recusal from decisions or projects
• Reassignment of responsibilities
• Termination or modification of conflicting activities
• Disclosure to clients or stakeholders when necessary
• Document all disclosures and actions taken for audit and compliance purposes.

6. Gifts, Hospitality, and Benefits

• Acceptance of gifts, hospitality, or other benefits is strictly prohibited if it could influence—or appear to influence—professional judgment.
• Any gift or benefit exceeding a nominal value must be reported in writing and approved by the Compliance Officer.

7. Confidentiality

All disclosures, reports, and discussions related to conflicts of interest will be treated confidentially, except where disclosure is required by law, regulation, or management oversight.

8. Compliance and Enforcement

• Compliance with this Policy is mandatory.
• Non-compliance may result in disciplinary action, up to and including termination of employment or contract, legal action, or financial penalties.
• The Company will periodically monitor and audit adherence to this Policy.

9. Reporting Concerns

For guidance or to report conflicts of interest:

Compliance Officer – InTech Next

Email: compliance@intechnext.com

Employees may report concerns confidentially without fear of retaliation.

10. Review and Updates

This Policy will be reviewed annually or as required to comply with changes in laws, regulations, or business practices. Updates will be communicated to all employees, contractors, and relevant stakeholders.