Zico Trust
Zico Trust

Conflict of Interest


1.1 This Policy is intended to guide the Associates to conduct business responsibly, with integrity, honesty, moral and adhere to high quality professionalism and ethical standards.

1.2 The Conflict-of-Interest Policy is intended to ensure that all associates practice professional independence and avoid any relationships or obligations that might be opposed to the interest of ZTB. Such relationships or obligations may impair their ability to make objective and professional judgement when performing their duties and give rise to conflict of interest.

1.3 This Policy guides us to prevent any conflict or potential of a conflict between ZTB’s interests and our personal interests. It establishes the standards and requirements for undertaking business transactions with complete loyalty and without personal conflicts.


2.1 Any modifications to this Policy shall be monitored and documented for further reference, and any changes must be implemented only with the Compliance Officer and/or Head of Human Resources’ prior approval.

2.2 The Compliance Officer and/or Head of Human Resources shall review and update this Policy on a regular basis to reflect applicable law(s) and/or the most recent notices issued by the regulating authorities from time to time.

2.3 The Compliance Officer and/or Head of Human Resources shall monitor and assess the efficacy and execution of the compliance principles outlined in this Policy on a regular basis, taking into account its appropriateness, adequacy and effectiveness.


This Policy applies to all of ZTB’s employees, Board Members, contractors, consultants, trainees, agents, as well as its subsidiaries, affiliates, group companies, and individual or entities contractually bound across the world.


4.1 Conflict of Interest

A conflict of interest arises when the employee is placed in a position where his/her personal interest interferes with the interests of ZTB. Such personal interests may exist when the employee uses its position or role in the Company to advance personal gain, including benefit for the family and friends, where such interest may conflict or potentially conflict with the interest of ZTB.

4.2 Scenarios

The following are some examples of circumstances, situations or relationships that may result in an actual, potential or perceived conflict of interest:

  • Participating in any form of paid/unpaid, verbal/contractual relationship, directly or indirectly, with any individual/entity with whom ZTB has a present or continuing relationship in a personal capacity.

  • Conducting business as the representative of ZTB with a company in which the Associates have financial or commercial stake or are associated. This interest may be held directly in personal capacity or indirectly through a closely connected individual.

  • Acting as consultants/advisors in any capacity to any government/regulatory body/industry association, which has the potential to impart ZTB’s operations.

  • Acceptance of personal gifts, illicit payments, compensation, contributions, or equivalent perks from competitors, clients, suppliers or potential suppliers. Accepting or provision of such gifts or hospitality that may sway the objective and professional judgement when performing their duties for ZTB. All such transactions must adhere to the guidelines outlined in the Anti-Bribery and Anti-Corruption Policy.

  • Engaging in business transaction with parties linked to the Associates or their family members which are or appeared to be detrimental to ZTB’s interests.

4.3 Relatives Working in The Company

A ‘Relative’ or a ‘Closely related person’ is defined by organisation as someone who is closely related by blood or marriage, or has other significant relationship (such as a spouse, son, daughter, mother, father, brother, sister, grandparent or grandchildren, step-parent, or step-children, step-sister, step-brother, in-laws, aunty, uncle, nephew, niece, first cousin, domestic partner), or any other relationship that the organisation deems to be a conflict of interest. The term “Relative” is defined as follows in the family tree:

  • Relatives should not work in a position where one relative can affect the employment of the other relative through decisions, recommendations or judgements regarding to daily working, job allocation, appraisal, remuneration, hiring, retention, transfer, leave requests and so on.

  • All present and prospective associates must provide the following information in accordance with the declaration as attached in Annexure A:
    • All relatives employed within the organisation or its subsidiaries;

    • If they are shareholders or owners of companies that engage directly or indirectly with ZTB or its subsidiaries; and/or

    • When their relative is an investor, owner or employee of a company that collaborates with ZTB as a business partner or vendor.

  • If a relative is found to be working in the same function or department, the organisation will ensure that either of the associate is re-assigned to a different role or department based on the associate’s qualification and background.

  • Every Associate is responsible for disclosing any change in relationship with respect to another associate who falls within the category of a relative, such as becoming a related of another associate (for example due to marriage, or any business association with ZTB or its subsidiaries).

  • ZTB shall not, under any circumstances, employ relatives in a supervisor-subordinate relationship or relatives in the same area of influence. Applicants who are considered for employed will not be assigned to a position that is in a reporting relationship or within the same function as a known related. Any relative proposed for employment by ZTB or any of its subsidiaries must be disclosed prior to the employing decision.

  • Hiring of relatives as interns on a temporary basis or project work assignments will be based on merit and the organisation’s recruiting processes.

4.4 Relationships with Competitors

  • Associates shall not own/purchase a share in any competitive Company without prior written consent unless it is bought through listed stock.

  • Any relative who works for a competitor, as well as any such links that may establish while working, must be declared using the method provided (As per Annexure A).

4.5 Employment Outside the Company:

  • Associates are not permitted to accept any employment or labour – remunerative or otherwise, outside ZTB that may impede, restrict or impair their capacity to carry their assigned tasks and obligations at ZTB.

  • Academic speaking engagements for restricted hours, remunerative or non-remunerative, may be approved if they do not interfere with the Associates’ job at ZTB; nevertheless, prior notification and approval of such engagement is required from ZTB Management Board.

  • All services or positions, whether remunerative or non-remunerative, including affiliation with charitable, not-for-profit, non-commercial organisations or any type of involvement, consulting or support in product creation, must be reported to ZTB’s Management Board.


5. Reporting and Complaint Process

5.1 ZTB is aware that some conflicting interests, such as a closely related individuals employed with a customer/vendor, cannot or are impractical to avoid.

5.2 This Policy is intended to uphold and promote the aforementioned framework. ZTB serves as a mechanism for all parties involved to report genuine concerns pertaining to unethical behaviour, actual or suspected fraud or violation of Conflict of Interest Policy without fear of retaliation.

5.3 A potential or actual conflict of interest must be reported to the Compliance Officer or Head of Human Resources as soon as possible via the channel provided (as per Annexure A). Associates must declare any possible or present conflict of interest during their employment with ZTB or at the time of joining.

5.4 In the meanwhile, all related work in ZTB must be avoided with the contentious party. An adequate response shall be delivered within thirty (30) days of the declaration’s submission.

6. Policy Violation

Any violation of the Policy including failing to disclose potential violations of compliance principles or relevant applicable legislation may result in disciplinary actions, including termination, suspension of employment or penalty.

7. Policy Exceptions

Any deviation from the principles outlined in this Policy must be approved in advance by the Compliance Officer, Head of Human Resources or the Management Board of ZTB.