Non-Solicitation Policy

Clarity Global Inc. is fully aware of non-solicitation requirements and respects any regulatory framework. By adhering to this non-solicitation policy, we accord to the requirements of all the regulations, our partner banks’ guidelines and uphold the trust of our partners and maintain the reputation as a trusted financial services provider.

1. Scope

This policy applies to all employees of Clarity Global Inc.

2. Definition of Solicitation

For the purpose of this Policy solicitation refers to any attempt to actively target customers on markets outside Canada.

3. Marketing Channels

3.1. Clarity Global Inc. is using the following marketing channels to attract new customers:

- Introducers, Business Connections, Agents
- Outsourcing companies in the field
- Expos/ events

3.2. Using other marketing channels to attract new customers in all markets except Canada is prohibited, unless it is a commonly used market practice or we have a Legal Opinion issued by a reputable law firm explicitly stating that Clarity Global Inc. is permitted to do so.

4. Prohibited Activities

The following activities are prohibited for all employees of Clarity Global Inc. according to this Policy:

a. Active targeting potential clients through various channels

b. Engaging in promotions or activities aimed at delivering clients to Clarity Global Inc.

5. Permitted Activities

The following activities would not be considered as solicitation according to this Policy:

a. Provision of general information about services or products if requested by a potential client, except active promotion or endorsement.

b. Provision of explanations if requested by a potential client, that enable one to fully understand the nature and risks inherent in the services of Clarity Global Inc. and thus enabling them to make their own judgments regarding using of services of Clarity Global Inc.

c. Engagement in professional networking events and activities, refraining from actively attracting potential clients to Clarity Global Inc.

6. Compliance and Audit

6.1. Chief Compliance Officer will provide guidelines to the Sales & Marketing Department considering the permitted and prohibited activities and communication contents according to this Policy.

6.2. Compliance will review the source of each potential client of Clarity Global Inc. to assure adherence to the Policy before establishing contractual relations with the potential client.

6.3. Client’s source will be a part of Internal Audit to make sure that the provisions of this Policy are not violated in any way.

7. Consequences of Non-Compliance

Non-compliance with the provisions of this Policy may lead to the following consequences:

a. Violation of this policy by an employee may result in disciplinary action, up to and including termination of employment.

b. A Client acquired by means of a marketing practice, prohibited by this Policy may be rejected.

8. Acknowledgment

8.1. Non-solicitation provision will be included to the employment contracts of Clarity Global Inc. employees and contractors.

8.2. Requirements of the Policy and Consequences of Non-Compliance will be an integral part of the training materials for staff training to promote appropriate activities and adherence to this policy.

8.3. All employees are required to review and acknowledge this policy upon commencement of employment and completing the respective training and on an annual basis thereafter.

8.4. Failure to adhere to this policy may result in disciplinary action, including termination of employment.

9. Whistleblowing

9.1. Employees, contractors and representatives are encouraged to report any suspected violations of this policy to their supervisor or the designated compliance officer according to the Whistleblower Policy of Clarity Global Inc.

9.2. Clients’ complaints, consultations and so forth, if any, in relation to this Policy should be addressed to our The Complaint Handling Officer at: +17788193278 during our office hours 8.00-17.00 CET, Monday-Friday, or by email – [email protected].

10. Policy Review

This policy will be reviewed periodically, but not less than annually, to ensure its effectiveness and compliance with relevant laws, regulations and best practices.