Conflicts of Interest Policy

Purpose

The purpose of this policy is to ensure that Dominion Insurance Services, Inc. and First Dominion Corporation (collectively “Dominion”) and its employees act with integrity, fairness, and transparency when dealing with clients. Dominion is committed to identifying, managing, and disclosing any actual, potential, or perceived conflicts of interest in accordance with applicable laws and regulations in the United States.

Scope

This policy applies to:

All directors, officers, employees, contractors, and representatives of Dominion;

All business activities undertaken by Dominion in the arrangement, advising, placement, and servicing of insurance products;

Regulatory expectations under the National Association of Insurance Commissioners (NAIC) Model Acts and state insurance regulators; Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) rules where securities or investment-related insurance products are concerned.

Definition of Conflicts of Interest

A conflict of interest arises where the interests of Dominion, its staff, or its associates could interfere with the duty to act in the best interests of clients. Conflicts may be:

Actual: a current conflict exists;

Potential: a conflict may arise in the future;

Perceived: a reasonable observer may believe a conflict exists, even if not the case.

Examples include:

Receiving higher commissions, bonuses, or contingent compensation from recommending certain products;

Holding ownership or financial interests in insurers or intermediaries;

Acting simultaneously for both insurer and insured without adequate safeguards;

Personal or family relationships that influence professional judgment.

Policy Principles

Dominion will act honestly, fairly, and in the best interests of clients at all times.

Conflicts of interest will be identified, avoided where possible, managed through internal controls, and disclosed where necessary.

Clients must receive clear, fair, and not misleading disclosures about conflicts that may impact service.

Employees must not permit personal or financial interests to improperly influence professional judgment.

Identification and Management of Conflicts

Dominion will:

Conduct regular assessments of business practices, commission structures, and referral arrangements;

Implement controls, which may include:

Full disclosure to clients;

Independent review of advice or product recommendations where conflicts are present;

Declining to act if a conflict cannot be managed fairly;

Segregation of duties and reporting lines where appropriate.

Employee Responsibilities

Employees must immediately disclose any actual, potential, or perceived conflicts to Dominion's President.

Employees must not accept gifts, hospitality, or incentives from insurers or third parties beyond de minimis value.

All staff must complete regular conflict of interest and ethics training, with enhanced training for client-facing and senior management roles.

Disclosure to Clients

Where conflicts cannot be avoided, Dominion will provide clients with disclosure that includes:

The nature of the conflict;

How it may affect the service provided;

The steps taken to mitigate the conflict;

A reminder of the client’s right to request further information.

Disclosures will comply with applicable laws and regulations, including but not limited to, NAIC Model Regulations, state insurance laws, and SEC/FINRA requirements for securities-linked insurance products.

Governance and Oversight

Dominion's President is responsible for implementing this policy, monitoring potential conflicts, and reporting material issues to the Board of Directors.

Oversight will include periodic review of compliance with NAIC/state regulations and SEC/FINRA rules where relevant.

The Board of Directors will review this policy at least annually, and more frequently where regulatory changes occur.

Breaches

Failure to comply with this policy may result in disciplinary action, up to and including termination of employment. Regulatory reporting obligations may also apply.

This Policy has been initially approved by the Board of Directors and will be reviewed and reapproved annually on or before July 1st .

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