Social Media Policy

Social Media Policy

This policy sets out the standards expected of all Global Trust Bank employees regarding the use of social media, whether in a professional or personal capacity. Given the Bank's regulatory obligations and the potential for reputational harm, adherence to this policy is mandatory for all staff, contractors, and temporary workers across all jurisdictions.

Scope

This policy applies to all social media platforms, including but not limited to:

• LinkedIn
• X (formerly Twitter)
• Facebook / Instagram
• YouTube / TikTok
• Reddit and online forums
• Blogs and personal websites
• Messaging platforms with public-facing elements (e.g., WhatsApp status, Telegram channels)

Corporate Social Media Accounts

Only the Communications Team is authorised to post on official GTB social media accounts. These accounts include:

Departments wishing to publish content on corporate social media accounts must submit a request via the Comms Request Form on GTB Connect at least five business days in advance.

Personal Use — Guidelines

Employees are free to use social media in a personal capacity, subject to the following rules:

1. Do not disclose confidential information. This includes client names, deal information, financial data, internal strategies, and any material non-public information (MNPI). Breaches may constitute market abuse under MAR/FCA regulations.
2. Do not represent yourself as speaking on behalf of the Bank unless explicitly authorised by the Communications Team.
3. Identify your views as personal. If your employment at GTB is evident from your profile, include a disclaimer such as: "Views expressed are my own and do not represent Global Trust Bank."
4. Be respectful and professional. Do not post content that is discriminatory, harassing, defamatory, or otherwise brings the Bank into disrepute.
5. Do not comment on regulatory matters, legal proceedings, or ongoing investigations involving the Bank or its competitors.
6. Do not use social media during working hours for personal purposes, except during designated breaks.

LinkedIn — Specific Guidance

LinkedIn is recognised as a professional networking tool. Staff are encouraged to maintain an up-to-date LinkedIn profile. However:

• Your LinkedIn headline and summary must accurately reflect your current role and title as per your employment contract.
• Do not endorse or recommend GTB products or services on LinkedIn in a way that could be construed as a financial promotion.
• Sharing official GTB LinkedIn posts is encouraged and does not require prior approval.

Regulatory Considerations

Employees in regulated roles (Senior Manager Functions, Certified Functions under SM&CR) must be particularly cautious. Social media posts that constitute financial promotions, investment advice, or market commentary may breach FCA rules and expose both the individual and the Bank to regulatory action. If in doubt, seek guidance from Compliance before posting.

Monitoring and Enforcement

The Bank reserves the right to monitor publicly available social media activity. Breaches of this policy may result in disciplinary action, up to and including dismissal for gross misconduct. Serious breaches may also be reported to the relevant regulator.

Contact

For guidance on social media use, contact the Communications Team at social.media@globaltrust.com or Compliance at compliance@globaltrust.com.