Conflict of Interest Policy


Conflicts of interest exist in all commercial and financial services organizations. We live in a complex world where conflicts of interest can be seen everywhere. However, we realize that our business is based on the trust between us and our customers, and we are also obligated to identify and manage these conflicts.
Therefore, we have adopted a number of policies, procedures and methods to identify, evaluate and manage these conflicts of interest. The purpose of this disclosure statement is to use a summary to identify the conflicts we have encountered as an organization and explain how we deal with the challenges brought about by these conflicts.
Liability and conflict of interest
We are aware that under certain circumstances, there may be conflicts between QDM, its directors and employees, and other related group companies and affiliates. In order to prevent and minimize the risk of such conflicts that may cause damage to the interests of our customers, we have adopted several internal systems, procedures and control measures as follows:
• Personal account transaction restrictions for all employees.
• Internal disclosure requirements for all employees
• When multiple functions performed by the same person will increase the risk of conflict, separate internal functions.
• Maintain an independence policy, which requires our directors and employees to act in a manner that best suits the interests of our customers regardless of any conflict of interest.
• Restrictions on access to data stored in electronic or paper form.
• Except for disclosure required by law, our directors, managers and employees must keep all information entrusted to them confidential. In addition, employees must not use such information for personal gain.
When we believe that these measures are not sufficient to prevent the risk of damage to our customers from a particular conflict, we will make a general statement that allows our customers to consider their situation and decide whether to continue using our services. Such general disclosures can be made orally or in writing before or during the transaction. For any other conflicts that we believe will lead to the risk of damage, we will make a special disclosure orally or in writing when we discover the conflict.