Legal

Effective date: 2025-06-01

At Egram SIA (“Company”, “we”, “us”, or “our”), we are committed to acting with integrity and transparency in all of our business dealings. This Conflicts of Interest Policy outlines how we identify, prevent, and manage potential or actual conflicts of interest that may arise in the course of our operations.

1. Purpose

The purpose of this policy is to:

• Ensure that the interests of our clients are always placed first

• Prevent situations where personal, financial, or other interests may improperly influence our actions or decisions

• Promote transparency and trust in our professional relationships

2. Definition of a Conflict of Interest

A conflict of interest arises when an individual’s or entity’s personal interests (financial, professional, or otherwise) could interfere with their duties or obligations to the Company or its clients.

Examples may include:

• A staff member providing services to a competing business

• Personal relationships that influence business decisions

• Receiving gifts or incentives from vendors or partners

• External business activities that may compromise neutrality

3. Identification and Prevention

We take the following measures to identify and prevent conflicts of interest:

• Require all employees and contractors to disclose any potential conflicts

• Conduct periodic internal reviews and risk assessments

• Prohibit employees from accepting gifts, commissions, or benefits that may influence their judgment

• Restrict employees from engaging in outside business activities that could conflict with Company interests without prior written approval

4. Management of Conflicts

If a conflict of interest is identified, we will take appropriate steps to manage it, including:

• Removing the conflicted individual from the decision-making process

• Notifying affected clients if appropriate

• Implementing internal controls or oversight measures

• Documenting the nature of the conflict and actions taken

5. Employee and Partner Responsibilities

All employees, contractors, and partners are required to:

• Act in the best interest of clients and the Company

• Promptly disclose any actual or potential conflicts to management

• Cooperate with any investigation or review of conflict situations

Failure to disclose a conflict or act ethically may result in disciplinary action, including termination of contract or employment.

6. Clients and Third Parties

If a potential conflict of interest involving a client or third party is identified, we will:

• Notify the client promptly

• Take steps to ensure fair and unbiased treatment

• Offer the client the choice to proceed or discontinue the service if appropriate

7. Review and Updates

This policy is reviewed annually or as needed and may be updated to reflect regulatory or operational changes. The most recent version is always available on our website.

8. Contact

If you have questions or concerns about this policy or would like to report a potential conflict, please contact:

Email: [email protected]
Address: Lienes iela 16, Rīga, LV-1009