Introduction
A conflict of interest occurs when an individual’s personal interests interfere, or appear to interfere, with their professional duties and responsibilities. This policy outlines the procedures for identifying, disclosing, and managing conflicts of interest to ensure the integrity and impartiality of our organization, Leet Capital.

Scope
This policy applies to all employees, officers, directors, shareholders, agents, and contractors of Leet Capital.

Policy
It is the policy of this organization to maintain the highest standards of ethical conduct and to avoid any actual or perceived conflicts of interest. All individuals are expected to act in the best interests of Leet Capital and to avoid any situations that could compromise their professional judgment or objectivity.

Procedures
Identification of Conflicts of Interest
Individuals are responsible for identifying any actual or potential conflicts of interest. A conflict of interest may arise in a variety of situations, including but not limited to:

• Financial interests in outside businesses or organizations that do business with Leet Capital.
• Personal relationships with individuals who do business with Leet Capital.
• Outside employment or activities that could interfere with the individual’s duties and responsibilities.
• Receipt of gifts or favors from individuals or organizations that do business with Leet Capital.

The Responsible Person implements screening measures during hiring, procurement, and partnership evaluations to proactively identify and mitigate potential conflicts of interest at an early stage.

• Hiring Process: Conduct background checks, including employment history, and affiliations with competitors or vendors.
• Procurement / Vendor Selection: Require bidders or suppliers to disclose any affiliations with company employees, board members, or decision-makers.
• Partnership Evaluations: Require partners to disclose existing partnerships that could create direct competition or conflicting commitments.

Disclosure of Conflicts of Interest
Leet Capital requires individuals, including employees, directors, and key stakeholders, to promptly and openly disclose any actual or potential conflicts of interest to relevant parties, such as management, the board of directors, or external stakeholders. Such disclosures must be made in writing to either their direct supervisor or the Chief Executive Officer and must include a detailed description of the conflict.

Management of Conflicts of Interest
The supervisor or Chief Executive Officer will review the disclosure and determine the appropriate course of action. The course of action may include:

• Recusal of the individual from the matter in question.
• Assignment of the matter to another individual, or segregation of duties.
• Appointment of an independent committee to make impartial decisions.
• Assignment of oversight responsibilities to the Compliance Officer to ensure the conflict is being managed effectively.
• Implementation of safeguards to mitigate the conflict.
• Termination of the relationship or activity that is causing the conflict.
• Restrict or limit the conflicted party’s access to sensitive information or resources

Record Keeping
All disclosures of conflicts of interest and the actions taken to manage them will be documented and maintained in accordance with Leet Capital’s record keeping policies.

Enforcement
Failure to comply with this policy may result in disciplinary action, up to and including termination of employment.

Conclusion
This policy is designed to protect the integrity of Leet Capital and to ensure that all individuals act in the best interests of Leet Capital. By following these procedures, we can identify, disclose, and manage conflicts of interest in a fair and transparent manner.