Conflict of Interest Policy

1. Purpose

This Conflict of Interest Policy is established to ensure that all workers of EVO Marketer, engaged in providing marketing services, act in the best interests of our clients and maintain the integrity and transparency of our client relationships.

2. Scope

This policy applies to all workers of EVO Marketer involved in providing marketing services to clients.

3. Definition of Conflict of Interest

A conflict of interest arises when the personal interests, relationships, or affiliations of a worker interfere with their ability to act impartially or in the best interests of our clients, potentially compromising the quality or integrity of our marketing services.

4. Disclosure of Conflicts

All workers are required to promptly disclose any actual or potential conflicts of interest to their immediate supervisor or designated compliance officer. This disclosure should include a detailed explanation of the conflict and its potential impact on our clients' projects.

5. Evaluation and Management of Conflicts

Upon receiving a disclosure of a conflict of interest, the designated compliance officer will assess the situation and determine an appropriate course of action. This may involve recusal from certain client projects, restructuring of responsibilities, or other measures to mitigate the conflict and ensure the integrity of our services to clients.

6. Confidentiality

All disclosures of conflicts of interest and related discussions shall be treated with the utmost confidentiality. Information shared in the context of conflict resolution shall be limited to individuals directly involved in the evaluation and management process.

7. Documentation

All disclosures of conflicts of interest and actions taken to address them shall be documented in writing and maintained as part of EVO Marketer's official records for compliance and auditing purposes.

8. Annual Disclosure

Workers are required to provide an annual statement affirming their understanding of this Conflict of Interest Policy and disclosing any conflicts of interest that may exist or arise in the course of their engagement with EVO Marketer's clients.

9. Enforcement

Violations of this Conflict of Interest Policy may result in disciplinary action, up to and including termination of engagement, depending on the severity and circumstances of the violation.

10. Review and Amendments

This Conflict of Interest Policy shall be reviewed periodically by the compliance officer to ensure its effectiveness and relevance. Amendments to the policy may be made as necessary with the approval of senior management.

Date of Adoption: 11 April 2024

Date of Last Revision: 11 April 2024