Protection of Client Interests

VERTEX 1 Brokers Limited (the “Company” or “we” or “us” or “our”) has been incorporated on 29 August 2025 under
the laws of the Republic of Mauritius as a global business corporation with registration number 225650 GBC and licence
number GB25205109. The Company is authorised and regulated as an Investment Dealer (Full Service Dealer, excluding
Underwriting) by the Financial Services Commission, Mauritius (“FSC”) as of [date].
The Company has adopted the following measures in line with the regulatory framework, i.e. to promote the
development, fairness, efficiency, and transparency of the financial markets, with a core objective of protecting the
interests of clients.

1. Client Onboarding & Suitability Assessment
The first and most crucial step in protecting a client is to have a robust process to ensure that the services and products
offered are suitable for the client.
This includes performing comprehensive due diligence on each client, including verifying their identity, financial
situation, investment objectives, and risk tolerance. This information is critical for providing appropriate advice and
services.
Before executing any transaction or providing advice, the Company must conduct a detailed risk profiling of the client.
The Company must ensure that any recommendation or investment decision aligns with the client's knowledge,
experience, financial situation, and investment objectives.
2. Safeguarding Client Assets
The Company has stringent procedures to protect client money and securities from misuse or loss.
• Segregation of Client Funds: Client funds and securities must be strictly segregated from the Company’s own assets.
This is fundamental to ensure that in the event of the Company’s insolvency, client assets are not used to pay off
the Company’s creditors and can be returned to the clients.
• Use of a Custodian: The Company ensures adequate protection of client assets through the use of licensed
custodians, responsible for the safekeeping of financial instruments and cash.
• Clear Procedures for Asset Transfer: The Company has clear and transparent measures regarding the transfer of
client assets, ensuring that assets can be returned to the client in a timely and efficient manner.
3. Fair dealings/treatment
The Company must deal fairly with clients at all stages of their relationship and make that fair handling an integral part
of its culture.
4. Disclosure and Transparency
The Company shall ensure the clarity and ease of understanding of the information related to the services and products
provided to clients, and make sure such information is up-to-date, clear, concise, accurate, non-misleading, and easily
accessible, especially its main terms and highlights.
Information shall also include clarification of the rights and duties of each party, details of prices and commissions
charged by the Company, exceptions and fines, mechanism of termination of the relationship and its consequences, in
addition to providing information on alternative products and services provided by the Company.
5. Educating and Raising awareness
The Company should develop appropriate programs and mechanisms to develop the knowledge and skills of customers,
raise their awareness levels, enable them to understand the basic risks, help them take rational and effective decisions,
and help them know the right source to obtain information when needed.
6. Work Ethics & Conduct
The Company must work in a highly professional manner that reflects on the interest of the clients and throughout the
relationship between them, where the Company is primarily responsible for protecting the interests of customers. The
Company must also provide the necessary human resources to achieve the above, carry out its work, serve its clients in
all regions where services are provided, serve clients and document channels of communication with them.
7. Protection from Fraud and Misuse
The Company must protect its clients’ assets from fraud and develop technical control systems with a high level of
efficiency and effectiveness to reduce and detect fraud, pilfering or abuse and take the necessary action if they occur, in
accordance with the relevant regulations and instructions.
8. Protection of Data & Information Confidentiality
The Company is committed to establishing appropriate mechanisms in accordance with the relevant applicable
regulations, instructions and policies to protect the financial, fiduciary, trading and/or personal information and data of
clients and to maintain their privacy, provided that they include all the rights mentioned in the data privacy principles,
and to develop high-level control systems that include appropriate mechanisms that determine the purposes for which
the data was collected.
9. Complaints’ Resolution
The Company provides an appropriate mechanism for clients for the submission of complaints and make sure the
mechanism is clear and effective, and the complaint must be studied and necessary measures and procedures should
be followed to address it fairly and effectively, and provide the best and most appropriate solutions without delay in
accordance with the relevant regulations and instructions.
10. Outsourcing
When outsourcing any of the services that involve dealing with clients, the Company shall ensure that the third party
complies with the requirements of these principles and rules – where applicable – and that it acts in the interest of its
clients and assumes responsibility for their protection, and the Company assumes responsibility in the event that the
third party assigned with the tasks does not comply with the laws, regulations and instructions in force in any of the
operations and tasks assigned to it in accordance with the relevant instructions issued by the regulator.
11. Conflict of Interests
The Company has a written policy on conflicts of interest that help detect potential conflicts of interest exist and are
being applied, and when a potential conflict of interest arises between the Company and any other party it must be
disclosed to the responsible party.
12. Code of Conduct
1. The Company should encourage clients to read their contracts and related terms and conditions, and any other
document that requires consent or signature or agreement of the client, in addition to providing updated terms and
conditions through the electronic channels of the Company.

2. The Company must provide information and/or documents to clients clearly and accurately, avoiding misinformation
and fraud.
3. The Company must include all terms and conditions for the product or service, provided that the warning statements
include the potential risks when using the product or service other than agreed. All terms and conditions must be
drafted in a simplified, clear and non-misleading manner, with an English version.
4. The Company shall inform the client through documented channels of any change to the terms and conditions (if
the agreement and the relevant instructions authorize such change) as provided under the client agreement.
5. The Company must provide the client with information on products and services and details of the calculation of
fees, commissions – if any – when concluding the agreement and obtain an acknowledgment from the client
confirming reading, understanding and approving its content.
6. The Company shall provide the client with electronic copy of all documents related to the products or services
through the approved channels, including website, trading platform or other electronic means.
7. The Company shall not make any change – increasing the fees and commissions – that clients have to pay after
obtaining the service or product and agreeing to the agreement or the like, except for fees and commissions related
to another party provided that they are related to the client’s use of the funded asset, and the client must be notified
of this when the contract is concluded.
8. The Company must place a list of fees and commissions (including third-party fees) in a clear so that it is easily
accessible by clients.
9. The responsibility of the clients’ data and information protection, and to maintain their privacy, is on the Company,
whether the information and the date are saved or with a third party, and the Company must adhere to the following:
• provide a safe and confidential environment in all its channels to ensure that the confidentiality of clients’ data
is maintained when carrying out operations, establish appropriate business procedures effective control systems
protect client detect address excesses have occurred or are expected occur,

• Obtain the signatures of all permanent or temporary employees and third-party employees on the Non-
disclosure agreement related to clients’ data and ensure that they do not disclose personal information to clients

and prevent access to it and limit it to authorized persons only, whether they are on the job or after leaving their
jobs,
• Preserve the confidentiality of client data in accordance with the relevant laws.
10. The Company must ensure that all electronic channels are available securely, and in the event that clients suffer a
direct loss as a result of the breach of these channels and/or their security failures, they must be compensated for
any losses resulting from this, and the following must be adhered to:
• Application/implementation of the highest standard for identity verification when accessing electronic services,
and taking the necessary measures to reduce electronic fraud;
• Including the purpose for which text messages are sent to clients, like for example: identification of a beneficiary,
reset password, account login, transfer of money.
11. The Company must verify the continuity of work of its systems and services and ensure their readiness to meet the
needs of clients at all times, and the Company should not benefit from any refunds that may arise due to a technical
error or malfunction and must return them to the affected client without delay, and clients who have experienced
the same error within (5) working days and without waiting to claim it, and the defect or malfunction must be fixed
according to the requirements of business continuity, and must be communicated with the affected clients informing
them of the error and corrective actions taken.
12. The Company must ensure that the tasks of all employees are performed efficiently and effectively and that they all
follow the behaviours and ethics, with utmost professionalism, with current or potential clients at all times, in
addition to training front-line employees who deal directly with clients periodically and work to obtain the necessary
professional certificates to familiarize themselves with the skills of dealing with clients, the products and services
provided to clients and the relevant instructions issued by the regulator.
13. Without prejudice to the relevant instructions, the Company shall follow up the employees, including third-party
employees, to ensure that best practices are followed when dealing with clients, and the regulatory guidelines as
well as and the products and services provided by the Company are observed, with regular reports to be submitted
to the senior management to monitor the performance of employees.
14. The Company must commit to continuously educating clients through all its channels, including at least: products
and services and their risks.
15. The Company must provide multiple channels to receive complaints, inquiries and requests so that clients can submit
complaints as they deem convenient and with ease at times convenient for them and in line with the nature of the
Company, provided that they include at least: toll-free phone, branches and/or website, smartphone applications,
e-mail. The complaint handling mechanism shall be made available in the Company’s website.
16. The Company must take into account humanitarian situations and its social responsibilities when dealing with clients
who have emergency financial difficulties and find appropriate solutions for them before starting to take legal action
against them.
17. The Company and its employees must not use or display any sort or form of discrimination while dealing with
potential and existing clients and avoid any unfair treatment which is based on their race, gender, color, age,
disability, marital status.
18. The Company must publish the principles and rules of protecting clients on its website.