Scope
This policy applies to all employees, officers, directors, and temporary staff, third parties acting on JustGold's behalf (advisors, consultants, contractors, suppliers, agents), and intercompany transactions within the JustGold corporate structure — across all business activities, partnerships, and transactions with clients, vendors, government agencies, investors, and regulators.
Key terms
- Conflict of interest: any situation where personal, financial, or external interests compromise someone's ability to act in JustGold's best interests.
- Material interest: a direct or indirect financial stake exceeding AED 5,000 annually in a competitor, supplier, or client.
- Immediate family: spouse, children, parents, siblings, or others in the same household.
- Compliance Officer: the designated authority for conflict disclosures and oversight (compliance@justgold.app).
Identifying conflicts of interest
Financial conflicts include holding a material interest in a competitor, supplier, or client, receiving gifts or entertainment exceeding AED 1,000 from external parties, or using company assets for personal gain.
Personal and external conflicts include business dealings with immediate family or close associates, holding outside roles that compete with or influence JustGold, and accepting undisclosed commissions or incentives.
Operational and client conflicts include preferential treatment based on personal relationships, misuse of confidential information, and participating in decisions with a personal financial interest.
Intercompany conflicts include favoring affiliated entities without fair market justification.
Disclosure requirements
Conflicts must be disclosed to the Compliance Officer within 3 business days of identification, in writing, covering the nature of the conflict, the parties involved, the potential impact, and proposed mitigation steps. Failure to disclose may lead to disciplinary action, financial penalties, or legal proceedings.
Conflict management and record keeping
Once disclosed, the Compliance Officer assesses severity and may apply recusal, information barriers, reassignment, transaction termination, or stakeholder notification. All actions are documented in a Conflict Register for audit purposes.
Disclosures, actions, and resolutions are retained for 5 years post-resolution, accessible only to the Compliance Officer and the Board of Directors.
Compliance and enforcement
- Annual conflict-of-interest declarations are required from employees and relevant third parties.
- Conflict management training is provided at onboarding and annually thereafter.
- Violations may result in warnings, additional training, termination, contract suspension, financial penalties, or reporting to Meydan Free Zone authorities depending on severity.
- Concerns can be reported via support@justgold.app.
Policy review and governing law
The Board of Directors reviews this policy annually for effectiveness and compliance with UAE law, with updates communicated via email and internal channels. The policy is governed by UAE law and Meydan Free Zone regulations.