Conflict of Interest (COI) Policy Brief

All Business Units of Transcom Group

CONFLICT OF INTEREST DECLARATION-2023

The Transcom Group is committed to achieving the highest levels of integrity and transparency in
conducting its business. In that regard all “Personnel” are required to comply with the Transcom Group
policies on business practice.

Periodically, cases and circumstances can occur where Personnel find themselves in a position where there
may be, or there may be perceived to be, a conflict of interest. Such potential conflicts will often be
acceptable provided the employing or contracting company is aware of, and is given the opportunity to
oversee, the transaction to which the conflict of interest relates. There will also however be some scenarios
when it would be unacceptable for certain conflicts of interest to continue.

In order to comply with the Transcom Group policies on Business Practice and facilitate the management of
potential conflicts all Personnel are required to declare (on the attached form) any personal conflict of
interest situations that may exist. The intent is to ensure that such issues are understood and managed so
that the integrity of both the Personnel and of Transcom Group is not compromised or called into question.

‘Personal Conflicts of Interest’ may include, but not be limited to, the scenarios set out below:

• When Personnel have a ‘close personal relationship’ with someone working in Transcom Group or
in any business unit of Transcom Group.
• When Personnel holds any financial or other interest in a supplier, service provider, customer,
competitor or agent of Transcom Group.
• When Personal have a ‘close personal relationship’ with someone who has a financial or other
interest in a supplier, service provider, customer, competitor or agent of Transcom Group.
• When Personnel hold a financial or other interest in any other outside business, including the press
and news media.
• When the Employee has a ‘close personal relationship’ with someone who has a position of
influence or authority within any state entity or regulatory authority where that entity or authority
has an interest in the activities of Transcom Group.
• When Personnel have a ‘close personal relationship’ with someone who has a financial or other
interest in the press or other forms of news media.
‘Close personal relationship’ refers to a relationship with a spouse, parent, child, brother, sister, mother in
law, father in law, brother in law, sister in law, aunt, uncle, nephew, niece or any person living with you. An
‘other interest’ may include, but not be limited to, being an employee of, providing a loan to, being in debt
to, being either a lessee or lessor of property from / to, the person or entity involved.

Declarations to effect that no conflict of interest exists are required on an annual basis. Declarations of a
personal conflict of interest existing should be provided on an ad-hoc basis throughout the year as the
conflict is identified.

If you are in any doubt as to the meaning of any of the terms used above please consult your Line Manager
or, Head of Function or Director- Group HR or, any member of the Senior Management Team.

Failure to disclose personal conflicts of interest as set out above is a serious breach of Company Policy and
will, when identified, be treated as a disciplinary offence.

Read, understood & committed to comply.

ID No. __________________ Signature _____________________ Page 1 of 2

Conflict of Interest (COI) Declaration
TRANSCOM GROUP - 2023
PERSONAL CONFLICT OF INTEREST DECLARATION

My signature below confirms that I have read and understood the ‘CONFLICT OF INTEREST DECLARATION-
2023’ and that having read and understood that document I declare that:
(Tick √ mark below as appropriate)
□ I do not currently have, and I have not previously had any Personal Conflicts of Interest to declare.
□ I have one or more Personal Conflicts of Interest to declare as described below*:
□ I am aware of a potential Personal Conflict of Interest pertaining to another Employee as described below*:

Nature of Conflict Previously Date

(If necessary provide full Person / Company / Entity involved Declared Previously
description on an attachment) Y/N Declared

Employee Signature: _____________________________ Date: _____________________________

Employee Name: ________________________________ Employee ID: _______________________

Job Title/ Function: _______________________________ Company: __________________________

Signature of BU/ Function/ Department Head Signature of Corporate/ BU Head of HR

(As per line of Report) (As Applicable)

Name: _________________________ Name: ________________________

Designation: ____________________ Designation: _________________________

[*This declaration will be treated with appropriate and strictest confidence]

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