Common use of CONFLICT OF INTEREST MANAGEMENT POLICY Clause in Contracts

CONFLICT OF INTEREST MANAGEMENT POLICY. SGSS has established and maintains operational a policy for managing conflicts of interest pertaining to its own activities and taking into account its affiliation with the Societe Generale group. This policy groups together the various measures and procedures that have been established in order to detect situations of conflicts of interest arising during its delivery of investment services that could be harmful to the interests of its customers. This particularly involves conflicts of interest that could occur between its direct and indirect employees and its customers, or even between two of its customers, during the provision of investment services. In particular, SGSS has implemented procedures: • in terms of provisions applicable to remuneration, • pertaining to transactions made by its employees including on personal transactions of some of its employees, • by establishing a watch list that identifies issuers for which Societe Generale holds privileged information, • conducive to maintaining the confidentiality of information, procedures commonly called “Chinese walls”. They prevent undue circulation of confidential or privileged information among the group’s various departments. Nevertheless, if it appears that these measures and procedures are not sufficient to avoid, with reasonable certainty, the risk of harming the interests of an Account Holder, SGSS shall inform the Account Holder, clearly and in a sufficiently detailed manner, before acting in the Account Holder’s name, of the general nature or the source of these conflicts of interest so that the Account Holder can take an informed decision.

CONFLICT OF INTEREST MANAGEMENT POLICY. SGSS has established and maintains operational a policy for managing conflicts conflict of interest pertaining to management policy concerning its own activities and taking which takes into account its affiliation with place within the Societe Generale group. This policy groups together the various measures and procedures that have been established in order to detect situations of conflicts of interest arising during its delivery of investment services that and which could be harmful to the interests of its customersAccount Holders. This particularly involves conflicts of interest that could occur between its direct and indirect employees and its customersAccount Holders, or even between two of its customersAccount Holders, during the provision of investment services. In particular, SGSS has implemented procedures: • in terms of provisions applicable to remuneration, • pertaining to transactions made by its employees employees, including on the personal transactions of some of its employees, • by establishing a watch list that identifies issuers for identifying the issuing companies on which Societe Generale holds privileged inside information, • conducive to maintaining the confidentiality of information, — procedures commonly called referred to as “Chinese wallsinformation barriers”. They prevent undue circulation of confidential or privileged information among the group’s Group's various departments. Nevertheless, if it appears that these measures and procedures are not sufficient to avoid, with reasonable certainty, the risk of harming the interests of an Account Holder, SGSS shall inform the Account Holder, Holder clearly and in a sufficiently detailed manner, manner before acting in the Account Holder’s 's name, of the general nature or the source of these conflicts of interest so that the Account Holder can take an informed decision.

CONFLICT OF INTEREST MANAGEMENT POLICY. SGSS has established and maintains operational a policy for managing conflicts of interest pertaining to concerning its own activities and taking into account its affiliation with membership of the Societe Generale groupGroup. This policy groups together the various measures and procedures that have been established in order to detect situations of conflicts of interest arising during its delivery of investment services that could be harmful to the interests of its customersAccount Holders. This particularly involves conflicts of interest that could occur between its direct and indirect employees and its customersAccount Holders, or even between two of its customersAccount Holders, during the provision of investment services. In particular, SGSS has implemented procedures: • in terms of provisions applicable to remuneration, • pertaining to transactions made by its employees including on personal transactions of some of its employees, • by establishing a watch list that identifies issuers for lists the issuing companies on which Societe Generale holds privileged insider information, • conducive to maintaining the confidentiality of information, procedures commonly called “Chinese wallsinformation barriers”. They prevent undue circulation of confidential or privileged information among the group’s various departments. Nevertheless, if it appears that these measures and procedures are not sufficient to avoid, with reasonable certainty, the risk of harming the interests of an Account Holder, SGSS shall inform the Account Holder, clearly and in a sufficiently detailed manner, before acting in the Account Holder’s name, of the general nature or the source of these conflicts of interest so that the Account Holder can take an informed decision.

CONFLICT OF INTEREST MANAGEMENT POLICY. SGSS has established and maintains operational a policy for managing conflicts of interest pertaining to its own activities and taking into account its affiliation with the Societe Generale group. This policy groups together the various measures and procedures that have been established in order to detect situations of conflicts of interest arising during its delivery of investment services that could be harmful to the interests of its customers. This particularly involves conflicts of interest that could occur between its direct and indirect employees and its customers, or even between two of its customers, during the provision of investment services. GENERAL TERMS AND CONDITIONS In particular, SGSS has implemented procedures: • in terms of provisions applicable to remuneration, • pertaining to transactions made by its employees including on personal transactions of some of its employees, • by establishing a watch list that identifies issuers for which Societe Generale holds privileged information, • conducive to maintaining the confidentiality of information, procedures commonly called “Chinese walls”. They prevent undue circulation of confidential or privileged information among the group’s various departments. Nevertheless, if it appears that these measures and procedures are not sufficient to avoid, with reasonable certainty, the risk of harming the interests of an Account Holder, SGSS shall inform the Account Holder, clearly and in a sufficiently detailed manner, before acting in the Account Holder’s name, of the general nature or the source of these conflicts of interest so that the Account Holder can take an informed decision.

CONFLICT OF INTEREST MANAGEMENT POLICY. SGSS has established and maintains operational a policy for managing conflicts of interest pertaining to its own activities and taking into account its affiliation with the Societe Generale group. This policy groups together the various measures and procedures that have been established in order to detect situations of conflicts of interest arising during its delivery of investment services that could be harmful to the interests of its customers. This particularly involves conflicts of interest that could occur between its direct and indirect employees and its customers, or even between two of its customers, during the provision of investment services. In particular, SGSS has implemented procedures: •  in terms of provisions applicable to remuneration, •  pertaining to transactions made by its employees including on personal transactions of some of its employees, •  by establishing a watch list that identifies issuers for which Societe Generale holds privileged information, •  conducive to maintaining the confidentiality of information, procedures commonly called “Chinese walls”. They prevent undue circulation of confidential or privileged information among the group’s various departments. Nevertheless, if it appears that these measures and procedures are not sufficient to avoid, with reasonable certainty, the risk of harming the interests of an Account Holder, SGSS shall inform the Account Holder, clearly and in a sufficiently detailed manner, before acting in the Account Holder’s name, of the general nature or the source of these conflicts of interest so that the Account Holder can take an informed decision.