1. PURPOSE
Invest Business House investment service and ancillary services, i.a. in the form of:
• Receiving, conveying and executing orders for customers:
• Portfolio care.
• Investment advice.
• Storage and administration of financial instruments.
• Currency transactions as part of the provision of investment services.
• Preparation and publication of investment analyses and general recommendations.
In this connection, Invest Business House must, in accordance with current legislation, ensure that conflicts of interest are identified, prevented and handled in order to safeguard our customers’ interests as best as possible.

2. IDENTIFICATION OF CONFLICTS OF INTEREST.
Conflicts of interest can, for example, arise if:
• Invest Business House or an employee may gain an advantage by knowing customers’ interests or influencing customers’ dispositions, as well as if Invest Business House or an employee can benefit themselves or others at the expense of a customer.
Invest Business House or an employee may gain an advantage by putting the interests of a customer or a customer group above the interests of another customer:
• Invest Business House carries out the same transactions as a customer, or.
• Invest Business House or an employee receiving incentives from
other than the customer
Examples of identified conflicts of interest.
The conflicts of interest can, among other things, occur in the following situations:
• When preparing investment analyses or recommendations on financial instruments or an issuer where Invest Business House or an employee has a vested interest or where there may be business relations between the issuer and Invest Business House.
• When publishing investment analyses.
• If an employee gains knowledge of a customer’s intended purchase or sale plans, which may have an impact on other customers’ or Invest Business House’s own investment decisions.
• In case of simultaneous trading for Invest Business House’s own portfolio and for customers.
• If Invest Business House or an employee has a different interest in relation to the customer in the result of the service provided to the customer, or the transaction carried out on the customer’s behalf.
• For asset management where Invest Business House or an employee may have another interest in the same financial instruments.
• If Invest Business House or an employee in connection with the provision of investment services to a customer receives premiums from third parties.
• When analyzing or advising on trading in financial instruments issued by the Group.
• When analyzing or advising on trading in financial instruments where the issuer has a collaboration with the Invest Business House.

3. PREVENTION OF CONFLICTS OF INTEREST.
Invest Business House attaches great importance to providing investment services and ancillary services with a focus on the customer’s needs and wishes, thus safeguarding our customers’ interests in the best possible way.
This is supported both in Invest Business House’s organisation, policies, business processes, systems, composition of products and in the training of the employees.

Organization:
There is organizational separation for, for example, the following functions:
• Between employees who handle Invest Business House’s own portfolio and the market-facing functions:
• Between employees who handle Invest Business House’s own portfolio and the customer-facing functions – including, for example, asset management for customers.
• Between employees prepare investment analyses and employees in Invest Business House’s market-facing functions
An independent compliance function has been established in Invest Business House which continuously checks that Invest Business House complies with applicable legislation.

Salary policy
In Invest Business House, there are no bonus schemes in connection with the provision of investment services and ancillary services, neither in general nor in relation to trading in individual financial instruments.
Business processes, procedures etc.
In the relevant business units in Invest Business House, business processes and procedures have been drawn up which both identify, describe and prevent conflicts of interest.

There are i.a. developed:
• Rules for employees dealing with investment services, etc. regarding trading in financial instruments – i.a. are there rules for analysts who prepare investment analyses or recommendations? They may not own or trade positions in the securities where they prepare analyses or recommendations.
• Rules for publication of investment analyses. Prepared analyses also provide information on whether there may be business relationships between the issuer and Invest Business House.
• Rules and internal procedures to prevent the exploitation of knowledge about customer dispositions. These rules apply to all employees in connection with the provision of investment services and ancillary services.
• Procedures for investment advice, regarding this requirement that information be provided that investment advice is not provided on an independent basis and that the investment advice is based on an analysis of a limited number of different financial instruments from issuers or suppliers, some of which have close links with Invest Business House.
• Rules for the investment process in asset management.
• Rules for analysis, advice on or trading in own issues.

4. Invest Business House Share.
No analysis of the Invest Business House share is prepared.
For advice on and trading with the Invest Business House share, there are internal rules and procedures which ensure that employees of Invest Business House do not provide investment advice on the Invest Business House share to retail customers.