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Conflict of Interest Policy

Version 1.0 · Effective April 2026 · IsoGentiX Ltd

Purpose

A conflict of interest arises when a personal interest — financial, relational, or otherwise — could improperly influence, or be perceived to improperly influence, a decision made in the course of IsoGentiX business. This policy sets out how conflicts must be identified, disclosed, and managed.

This policy applies to all directors, employees, and contractors of IsoGentiX.

What constitutes a conflict

A conflict may arise in circumstances including:

  • Holding a financial interest in a company that is a customer, supplier, competitor, or counterparty of IsoGentiX
  • Having a close personal or family relationship with a person employed by or representing a counterparty in a transaction involving IsoGentiX
  • Receiving gifts, hospitality, or secondary income from a party with a business relationship with IsoGentiX, beyond what is permitted under the Anti-Bribery and Corruption Policy
  • Taking on a directorship, advisory role, or employment with a third party that may conflict with IsoGentiX's interests
  • Using IsoGentiX resources, relationships, or confidential information for personal commercial benefit

Disclosure requirement

Any actual or potential conflict of interest must be disclosed to a director as soon as it is identified — including at the outset of engagement with IsoGentiX where a pre-existing conflict exists. Disclosure must be made in writing and recorded in the conflicts register.

Directors must disclose conflicts to the other directors and, where required by the Companies Act 2006, at a board meeting.

Management of conflicts

Following disclosure, the directors will determine the appropriate management step, which may include:

  • Recusal from the relevant decision or transaction
  • Divestment of the conflicting interest
  • Termination of the conflicting external engagement
  • Enhanced supervision or transparency measures

No person may participate in a decision in which they have an undisclosed conflict.

Reporting

Concerns about undisclosed conflicts of interest may be raised via the Grievance Policy process. No retaliation will be taken against a person who raises a concern in good faith.