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Group Conflicts of Interest Policy Summary

QBE requires all QBE employees to promptly disclose and report any actual, potential, or perceived conflicts of interest. This ensures they are managed appropriately and enables QBE to comply with ongoing obligations under applicable regulatory requirements in its jurisdictions of operation.

QBE’s Group Conflicts of Interest Policy (“Policy”) sets the expectations and responsibilities for QBE employees, officers, and directors in reporting conflicts of interests. The Policy supports the QBE Group Code of Ethics and Conduct and should be read in conjunction with the Group Whistleblowing Policy, Group Financial Crime Framework, Group Gifts and Entertainment Policy and any relevant QBE policies.

Under the Policy, a ‘conflict of interest’ arises at QBE where either: (a) an employee has a personal, financial or other interest that is contrary with the interests of QBE and/or its customers; or (b) QBE has a financial or other interest that conflicts with the interests of its customers.

All QBE employees are also required to complete any mandatory training and conflict of interest declarations.