Zero Conflict of Interest

1. Purpose

The purpose of this policy is to maintain the highest standards of integrity, transparency, and trust at Today Markets by eliminating all actual, potential, or perceived conflicts of interest. This ensures that all decisions made by employees, executives, and representatives are based solely on the best interests of the company and its clients.

2. Scope

This policy applies to:

• All employees (full-time, part-time, contract, temporary)

• Officers and directors

• Independent contractors

• Consultants and agents

• Any individual acting on behalf of Today Markets.

3. Definition of Conflict of Interest

A conflict of interest occurs when personal, financial, or other interests interfere—or appear to interfere—with the individual’s ability to make unbiased decisions in the best interests of Today Markets or its clients.

Examples include (but are not limited to):

• Personal financial interests in Today Markets vendors, clients, or competitors

• Accepting gifts, payments, or favors from clients, suppliers, or partners

• Using company resources for personal gain

• Employment or consulting roles with competitors or vendors.

4. Zero Tolerance Commitment

Today Markets adopts a Zero Conflict of Interest policy, which means:

• No employee or representative may have any interest, relationship, or engagement—financial or otherwise—that could compromise impartiality.

• All team members must act solely in the best interests of Today Markets and its stakeholders.

• Any potential conflict must be disclosed immediately and resolved or removed before any relevant decision, action, or negotiation takes place.

5. Disclosure Requirements

All covered individuals must:

• Disclose any existing or potential conflicts of interest in writing to their manager or the Compliance Officer.

• Submit an annual Conflict of Interest Statement affirming their compliance with this policy.

• Update disclosures promptly as circumstances change.

6. Prohibited Activities

The following activities are strictly prohibited:

• Holding financial interest in a supplier, client, or competitor of Today Markets (unless via publicly traded stock under 1% ownership).

• Using confidential information for personal gain or for the benefit of a third party.

• Accepting gifts, entertainment, or favors that exceed nominal value or could influence business judgment.

• Hiring, supervising, or making business decisions involving close family members without approval.

7. Compliance and Enforcement

• All employees are required to complete annual training on conflicts of interest.

• Violations of this policy may result in disciplinary action, including termination, legal action, and/or reporting to regulatory authorities.

• The Compliance Officer is responsible for monitoring compliance and investigating reported issues.

8. Reporting Concerns

Employees are encouraged to report suspected conflicts of interest to:

• Their direct manager

• The Compliance Officer

• The anonymous Ethics Hotline (details provided in the Employee Handbook)

No retaliation will be tolerated for good faith reporting.

9. Policy Review

This policy will be reviewed annually by the Compliance Department and updated as necessary to reflect changes in business operations or legal requirements.

Approved by:
P. Mathews, Chief Compliance Officer
Date: October 11, 2025