Conflict of Interest Policy

Effective Date: 1^st July 1, 2024

Introduction

At Gruvest, we uphold the highest standards of integrity, professionalism, and ethical conduct. This Conflict of Interest Policy (“Policy”) sets forth our commitment to identifying, disclosing, managing, and resolving potential or actual conflicts of interest to protect the interests of our clients, partners, and the integrity of our operations.

Purpose

This Policy aims to prevent conflicts of interest from influencing our business decisions and to ensure that any such conflicts are managed transparently and fairly.

Scope

This Policy applies to all employees, officers, directors, and third-party agents of Gruvest (“Associates”) involved in operations where conflicts of interest could potentially arise.

Identification of Conflicts

Conflicts of interest may occur when an Associate’s personal interests, relationships, or external activities interfere with their ability to make objective decisions for Gruvest. Potential conflicts include, but are not limited to:

• Personal Benefits: Receipt of gifts, favors, compensation, or excessive hospitality from developers, investors, or other parties in exchange for preferential treatment.
• Financial Interests: Holdings in real estate properties, development companies, or entities that may conflict with Gruvest’s interests.
• Familial or Personal Relationships: Close connections with individuals involved in transactions facilitated by Gruvest.
• External Affiliations: Involvement with other organizations that might conflict with Gruvest’s interests.

Disclosure and Management

• Duty to Disclose: Associates must immediately disclose any potential or actual conflicts to the Compliance Officer in writing.
• Recusal: Associates affected by a conflict must abstain from related decision-making processes.
• Compliance Officer Role: The Compliance Officer reviews all disclosures to determine the existence of a conflict and recommends actions to mitigate or resolve it.
• Documentation: All conflicts and the actions taken to manage them are recorded for accountability.

Resolution

Appropriate actions to resolve conflicts may include:

• Mitigation: Measures such as reassigning responsibilities to unaffected Associates.
• Divestment: Associates may be required to divest interests that create conflicts.
• Removal: Removing the Associate from related projects or decision-making roles.
• Disciplinary Actions: For breaches of this Policy, disciplinary measures up to termination of employment or contracts may be enacted.

Proactive Measures

Associates are encouraged to consult the Compliance Officer proactively when considering external activities or investments that might lead to conflicts.

Training and Awareness

Regular training will be provided to all Associates to ensure understanding and compliance with this Policy.

Transparency

Gruvest is committed to transparency in its operations. Records of conflicts and their management are maintained and available for regulatory review.

Review and Updates

This Policy is reviewed annually and updated as necessary to stay aligned with legal requirements and best practices.

Contact Us

For any questions, concerns, or to report potential conflicts, please contact:

• Compliance Officer: Meir Sarig CEO
• Email: support@gruvest.com
• Phone: +36 70 674 8005
• Address: 1134 Budapest, Váci út 47/B. Ü-1.

By adhering to this Policy, Gruvest ensures that all business decisions are made in the best interest of our clients and the company, maintaining the highest ethical standards.