1. General Provisions

Eurovalley s.r.o. (hereinafter referred to as the "Intermediary" or "Company"), ID No.: 293 68 324, with its registered office at Příkop 6, 602 00 Brno, is a registered independent intermediary with the Czech National Bank (CNB) pursuant to Act No. 170/2018 Coll., on insurance and reinsurance distribution (hereinafter referred to as the "Insurance Distribution Act"). Contact details: Eurovalley s.r.o., Pražákova 66a, 639 00 Brno, telephone: +420 515 530 030; email: info@eurovalley.cz, and applies the following rules for identifying and managing conflicts of interest within the Company (hereinafter referred to as the "Conflict of Interest Management Rules") in accordance with the relevant official announcements of the Czech National Bank.

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The Conflict of Interest Management Rules contain the main principles and procedures for identifying and managing conflicts of interest within the Company, as well as for persons who are financially or otherwise connected with the Company, specifically for identifying potential conflicts of interest, preventing their occurrence, and managing any conflicts that arise.

The objective of the Conflict of Interest Management Rules is to ensure that the Company's insurance intermediation activities do not harm the interests of its customers and potential customers, or third parties (financial institutions, etc.).

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The Company's statutory body shall review the Conflict of Interest Management Rules at least once a year and, if necessary, take appropriate measures to remedy any shortcomings.

“Tied Agent” for the purposes of the Conflict of Interest Management Rules, means a tied agent within the meaning of Section 15 of the “Insurance Distribution Act”.

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2. Cases of Conflicts of Interest within the Company

The Conflict of Interest Management Rules contain rules for identifying and managing conflicts of interest between:

(a) the Company, its employees, Tied Agents and their employees, and customers and potential customers;

(b) a person who controls the Company, is controlled by the Company, or is controlled by the same person as the Company, and their board members and Tied Agents, and customers and potential customers;

(c) persons belonging to the same group as the Company, persons performing part of the Company's activities on a contractual basis (outsourcing), and persons representing the Company, and customers and potential customers;

(d) customers and potential customers among themselves.

For the purposes of the Conflict of Interest Management Rules, the customer and potential customer shall hereinafter, where appropriate, be jointly referred to as the “Customer”.

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3. Key Prerequisites for Effective Conflict of Interest Management

As part of effective conflict of interest management, the Company:

• has an organizational structure in place that ensures the personnel separation of individual organizational units in a way that effectively prevents undesirable information flow and its potential misuse (Chinese walls);
• ensures the functional and organizational independence of individual organizational units, which have sufficient material and organizational conditions for the objective performance of their activities;
• within its internal control system, ensures ongoing monitoring (compliance) of persons providing financial services on behalf of the Company and persons performing related activities;
• establishes remuneration rules for employees within the Company that prevent conflicts of interest.

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4. Identification and Management of Conflicts of Interest

When identifying and assessing conflicts of interest, the Company considers whether the Company or a person mentioned in Article 2 of this document:

• may obtain a financial gain or avoid a financial loss at the expense of the Client;
• has an interest in the outcome of a service provided to the Client or in the outcome of a transaction brokered for the Client that differs from the Client's interest;
• has an incentive (financial or other inducement) to prioritize the interest of another Client or group of Clients over the interests of the given Client;
• performs the same business activity as the Client;
• in connection with a service provided to the Client, receives or will receive an inducement in the form of monetary or non-monetary benefits or services from a person other than the Client.

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If a conflict of interest cannot be avoided, the Company will always prioritize the Client's interests over its own interests or the interests of persons financially or otherwise connected with the Company. If a conflict of interest arises between Clients, the Company will ensure a fair resolution for these Clients. If a fair resolution cannot be ensured, the Company may refuse to perform the service for the Client.

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If, despite the measures taken, the adverse impact of conflicts of interest on the Client's interests cannot be reliably prevented, the Company will inform the Client about the nature or source of the conflicts of interest before providing the service. The Company will provide the Client with information about the nature or source of the conflicts of interest on a durable medium (in paper form or electronically) in a manner and to an extent that takes into account the Client's nature and allows them to properly consider the conflict of interest related to the Company's service, enabling the Client to make an informed decision whether or not to use the services offered by the Company.

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5. Management of Significant Conflicts of Interest

As part of its internal control system, the Company identifies circumstances which, in relation to specific services and activities provided by the Company or another person on its behalf (e.g., employee, tied agent, tied agent's employee), may lead to a conflict of interest that poses a significant risk of harm to the Customer's interests (hereinafter referred to as "Significant Conflict of Interest").

The Company ensures that its employees involved in providing services associated with a Significant Conflict of Interest perform their duties with a degree of independence that is proportionate to the nature, scope, and complexity of the Company's activities and the severity of the risk of harm to Customers' interests.

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5.1 Procedures for Managing Significant Conflicts of Interest

• procedures to prevent or control the exchange of information between employees if such information is associated with a risk of conflict of interest and if its exchange could harm the Customer's interests,
• independent supervision of employees involved in providing services to Customers,
• prevention of a direct link between an employee's remuneration and the remuneration or income of another employee if a conflict of interest may arise in relation to these activities,
• measures that prevent the possibility of exercising undue or unjustified influence on how an employee provides services,
• measures that prevent an employee from participating in the provision of a service if doing so could jeopardize the proper management of conflicts of interest, or ensure supervision of this activity to prevent such jeopardy,
• other measures to prevent conflicts of interest, if specific situations or work procedures require it.

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The Company's senior management continuously, but at least once a year, evaluates reports on the management of significant conflicts of interest within the Company.

6. Key Instances of Conflicts of Interest

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INSURANCE BROKERAGE

In the context of insurance brokerage, conflicts of interest arise between the Company and the customer, as the Company is incentivized to distribute insurance based on an agreement concluded with the insurer.

This is a conflict of interest that the Company cannot effectively prevent, and therefore informs the Customer of this fact in advance so that they can make an informed decision.

Before concluding an insurance contract, the Company informs the customer that the Company and its Employees are remunerated by the insurer for whom the Company brokered the conclusion of the insurance contract.

The remuneration rules for employees, tied agents, and ancillary insurance intermediaries must not incentivize non-compliance with obligations under Act No. 170/2018 Coll., on insurance and reinsurance distribution, other legal regulations to the extent they relate to insurance distribution, and directly applicable European Union regulations in the field of insurance distribution, particularly concerning conduct rules. Furthermore, they must not incentivize recommending specific insurance products to Customers at the expense of other products that would better meet the Customer's needs.

Inducements

7. Definition of Inducement

A specific case of conflicts of interest involves so-called inducements. When providing financial services (insurance brokerage), the Company must not accept, offer, or provide any fee, commission, or other monetary or non-monetary benefit that could lead to a breach of the Company's duty to act competently, honestly, fairly, and in the best interests of Customers, or a breach of the duty to properly manage conflicts of interest.

For the purposes of insurance brokerage, an inducement is not considered permissible if it results in the provision of services to the Customer being biased or impaired.

The Company approaches the management of inducements in the same way as other conflicts of interest. This means the Company ensures the identification of inducements, takes measures to prevent their occurrence, and, if necessary, effectively manages them.

In general, the Company distinguishes the following categories of inducements that it may provide or receive.

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1) Customer Inducements

Inducements that are paid by the customer, on behalf of the customer, or paid to the customer, but only if they are in accordance with the law.

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2) Operational Inducements

Inducements that enable the provision of services or are necessary for this purpose, and which are permissible provided their nature does not conflict with the duty to provide services with professional diligence.

These incentives include:

• payments for accounting, legal, and tax services,
• costs associated with fulfilling obligations to the Czech National Bank (administrative fees, costs for reporting systems, etc.) and to customers,
• postage and other communication fees
• fees associated with maintaining a bank account,
• training mandated by legal regulations (e.g., AML).
• liability insurance premiums

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3) Other Incentives

Other incentives that do not fall under operational incentives, paid to or for a third party, or provided by or on behalf of a third party, which are permissible upon fulfillment of the following conditions.

• The Customer was clearly, understandably, and fully informed before the service was provided about the existence and nature of the incentive, its amount or value, or the method of its calculation, if these cannot be ascertained beforehand.
• The incentive contributes to improving the quality of the service provided.
• The incentive does not conflict with the Company's obligation to provide services with due professional care.

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The Company maintains a list of specific incentives and, upon the Customer's request, will provide details for each individual incentive.

Internal performance within the Company, which includes, for example, remuneration of employees, Tied Agents, branch equipment, etc., is not an incentive. The acceptance or provision of an incentive by Company employees outside this relationship is attributed to the Company.

8.  Forms of Specific Incentives within the Company

Specifically, the Company accepts the following incentives.

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INSURANCE INTERMEDIATION

Remuneration (commission) paid to the Company by the insurance company for mediating the conclusion of an insurance contract and related activities (subsequent care of the insurance contract, etc.). The remuneration usually consists of an initial commission and a subsequent commission.

Upon the Customer's request, the Company will specify its methods of remuneration.

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Brno, December 1, 2018

Eurovalley s.r.o.

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