05 / HOW WE ARE GOVERNED 01 02 03 04 06 07 08 09 135 4. Managing Conflicts of Interest with Transparency and Discipline Conflicts of Interest, whether actual, potential, or perceived, can undermine objectivity and stakeholder confidence if not properly managed. The Group therefore maintains a structured framework through its Conflict Management Policy and the Guidance on Conflict of Interest for identifying, disclosing and managing conflicts of interest across its operations. The framework distinguishes between personal and business-related conflicts of interest and provides guidance on situations that may give rise to conflicts. Employees are expected to exercise sound judgement, remain vigilant to potential conflict situations and make timely disclosures where conflicts arise. Disclosures are supported by formal registers and escalation processes, enabling conflicts to be reviewed, assessed and managed through appropriate controls. In 2025, the Group placed strong emphasis on the importance of transparency and proactive disclosure as key elements of effective conflict management, supporting impartial decision-making, and reinforcing confidence in the Group’s integrity. 5. Preventing Improper Influence through Gifts, Entertainment, Hospitality, Donations and Sponsorships Controls governing gifts, entertainment, hospitality, donations and sponsorships form an important part of the Group’s anti-bribery and corruption framework. These controls, which include the Group Gift, Entertainment and Hospitality Policy and the Group Incoming Non-Commercial Sponsorship Policy, are designed to prevent improper influence, manage perception risks and ensure that objective decision-making. Employees are expected to exercise sound judgment and comply with these requirements at all times. Awareness efforts and monitoring mechanisms continued throughout 2025 to support understanding of the underlying principles and ensure effective oversight. 6. Safeguarding Market Integrity, Confidential Information and Fair Competition Ethical conduct extends beyond internal behaviour to interactions with markets, clients, and competitors. The Group remains committed to safeguarding market integrity and maintaining trust in the capital markets. Controls are in place to protect confidential and material non-public information, including information barriers and Chinese Wall arrangements. The Group Chinese Wall Policy governs the flow of confidential, material non-public and price-sensitive information across divisions, with information barriers designed to prevent insider trading and market abuse. The Group also maintains a framework to ensure compliance with competition and fair-trading requirements through its Group Competition Act Compliance Policy. This includes guidance on interactions with competitors, clients, suppliers and industry associations, as well as expectations on fair competition practices. In 2025, the Group continued to deepen awareness of these obligations as part of its broader ethics and compliance efforts, recognising that market confidence is closely linked to ethical conduct and compliance discipline. 7. Vendor Engagement and Third-Party Integrity The Group recognises that ethical conduct and compliance expectations extend beyond employees to vendors and other third parties engaged by the Group. In this regard, the Group has established standards governing vendor conduct, underpinned by the Group Policy on the Code of Conduct for Vendors, to promote integrity, transparency and responsible business practices across its value chain. Vendor engagement is further supported by the Group’s broader ethics and compliance framework, including the Employees Ethics Code and the AFBC Policy. These requirements highlight expectations of fair dealing, integrity in business relationships and compliance with ethical standards. Where appropriate, the Group may take necessary actions in response to vendor non-compliance. This structured approach supports effective third-party risk management and sustainable, ethical business relationships. ETHICS AND COMPLIANCE STATEMENT
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