Koobiz Statement on Conduct

Strategy and Business Model

All our strategies, business models, and decisions must ensure fair treatment of clients and maintain market integrity.

Culture and Behavior

Our employees are competent and committed to fair treatment, while safeguarding market transparency.

We are open to feedback, willing to acknowledge mistakes, correct them, and learn from errors.

We recognize and reward behaviors, performance, and attitudes that benefit clients fairly and uphold market transparency.

Our corporate culture supports employees and encourages them to act with integrity toward clients and the market.

Clients

Our products are designed to meet diverse needs, be easy to understand, and remain competitive.

Products and services deliver balanced value exchanges between Koobiz and clients. In sales and service, we act transparently, efficiently, and client-focused. We manage products and services to ensure client experiences align with expectations we set.

We understand our clients and their needs, actively listen, and ask relevant questions.

Market

Transactions are conducted transparently, timely, and under control, ensuring optimal outcomes for clients while preventing market manipulation.

We manage conflicts of interest and handle information appropriately to minimize abuse risks.

We proactively prevent and detect market misconduct and respond promptly when issues arise.

Governance and Oversight

We cooperate with regulators in a timely, transparent, and open manner.

All activities and decisions across business units, global functions, and Operations, Services, Technology teams must contribute to achieving the global conduct objectives.

Our governance framework ensures effective monitoring of fair client treatment and market transparency.

Complaint Handling

Our highest standards of conduct are reflected in our complaint handling policy, based on the following principles & Our global complaint policy sets standards to:

• Open to feedback, willing to acknowledge mistakes, correct them, and learn from errors.
• Investigate and resolve complaints promptly, fairly, and effectively.
• Train employees on complaint procedures, emphasizing client empathy.
• Provide clear information to clients on complaint channels (relationship managers, in-person, phone, online, written).
• Resolve complaints at the first point of contact where possible; otherwise, inform clients of the next steps.
• Provide periodic updates on resolution progress.
• Communicate investigation outcomes, including remedies or compensation if necessary.
• otify clients of appeal rights if unsatisfied.
• Review the root cause of complaints to improve processes and address systemic issues.

Product and Sales Governance

This conduct policy is reflected through standards for product and sales governance:

• Design, approve, and maintain products/services suitable for clients’ needs, knowledge, and experience.
• Communicate clearly, fairly, without misleading information, balancing risks and benefits.
• Follow advisory and non-advisory processes.
• Provide post-sale client support.
• Conduct periodic reviews to ensure products remain suitable and compliant with laws and regulations.
• Be sensitive and support vulnerable clients due to illness, loss, or changes in circumstances.
• Treat clients fairly when closing accounts or withdrawing/expiring products.
• Monitor third-party manufacturers and distributors.
• Develop staff competencies, training, licenses, and regulatory approvals.

The Charter enables employees who identify non-compliance with conduct standards to report:

• Directly to management, HR, or the Compliance Department, or
• Anonymously via support@koobiz.com or through our secure multi-channel disclosure and investigation service.