Market Abuse Prevention

1. Purpose

This policy (Ref: COMP-CE-005) establishes the Bank's framework for the prevention, detection, and reporting of market abuse. It implements the requirements of the EU Market Abuse Regulation (MAR — Regulation (EU) No 596/2014), MiFID II, and applicable national market conduct rules, including the FCA's Code of Market Conduct (MAR 1). Market abuse undermines market integrity and investor confidence, and the Bank takes a zero-tolerance approach to all forms of market misconduct.

2. Scope

This policy applies to all employees, officers, and directors of the Bank, as well as any person acting on behalf of the Bank who may have access to inside information or who is involved in activities related to financial instruments admitted to trading on a regulated market, MTF, or OTF, or whose price or value depends on or has an effect on such instruments.

3. Prohibited Conduct

3.1 Insider Dealing

It is prohibited to:

• Deal, or attempt to deal, in financial instruments on the basis of inside information.
• Recommend or induce another person to deal on the basis of inside information.
• Cancel or amend an order on the basis of inside information.

Inside information is defined as information of a precise nature, which has not been made public, relating to one or more issuers or financial instruments, and which, if made public, would be likely to have a significant effect on the price of those instruments.

3.2 Unlawful Disclosure of Inside Information

Inside information must not be disclosed to any person except where disclosure is made in the normal exercise of an employment, profession, or duties, and on a strict need-to-know basis. Employees who disclose inside information must ensure that the recipient is aware of their obligations and is bound by confidentiality.

3.3 Market Manipulation

It is prohibited to engage in or attempt to engage in market manipulation, which includes:

• Entering into transactions, placing orders, or engaging in any other behaviour that gives, or is likely to give, false or misleading signals as to the supply of, demand for, or price of a financial instrument.
• Entering into transactions, placing orders, or engaging in any other behaviour that secures, or is likely to secure, the price of a financial instrument at an abnormal or artificial level.
• Disseminating information through any channel that gives, or is likely to give, false or misleading signals about a financial instrument, where the person knew, or ought to have known, that the information was false or misleading.

4. Key Controls

4.1 Insider Lists

The Bank maintains insider lists in accordance with Article 18 of MAR. Any person who has access to inside information relating to a specific transaction or event must be recorded on the relevant insider list. Insider lists are maintained by the Compliance Department and must be updated promptly upon any change. Individuals on an insider list must be notified of their obligations and the consequences of misuse of inside information.

4.2 Personal Account Dealing (PAD)

Employees must comply with the Bank's Personal Account Dealing Policy (COMP-CE-003a). Pre-clearance is required before any personal transaction in a financial instrument that is covered by this policy. Trading is prohibited during closed periods and when the employee is in possession of inside information.

4.3 Information Barriers

The Bank operates information barriers ("Chinese walls") between business units that may hold inside information (e.g., corporate finance, M&A advisory) and those that make investment or trading decisions. Crossing an information barrier requires the prior approval of the Head of Compliance and must be documented.

4.4 Surveillance and Monitoring

The Bank operates automated trade and order surveillance systems to detect potential market abuse patterns, including:

All surveillance alerts must be reviewed by the Compliance Department within five (5) business days of generation.

5. Suspicious Transaction and Order Reports (STORs)

Where the Bank has reasonable grounds to suspect that a transaction or order constitutes insider dealing, market manipulation, or an attempted form thereof, a Suspicious Transaction and Order Report (STOR) must be filed with the relevant competent authority (e.g., FCA, BaFin, AMF) without delay. The Compliance Department is responsible for the preparation and submission of STORs.

6. Training

All employees in relevant functions (trading, sales, research, corporate finance, compliance) must complete market abuse awareness training annually. General awareness is included in the annual Code of Conduct certification for all employees.

7. Consequences of Non-Compliance

Market abuse is a criminal offence in most jurisdictions. Violations may result in criminal prosecution, regulatory sanctions (including fines of up to EUR 5,000,000 for natural persons under MAR), and termination of employment. The Bank will cooperate fully with regulatory and law enforcement authorities in the investigation of suspected market abuse.

8. Review

This policy is reviewed annually by Legal & Compliance. Next review: Q1 2027.