Client Confidentiality & Fiduciary Duty Statement

This Client Confidentiality & Fiduciary Duty Statement sets forth the legal, ethical, and professional obligations of Treasure Well concerning the handling, protection, and fiduciary responsibility over client information and interests.

Treasure Well is committed to maintaining the highest standards of confidentiality, discretion, and fiduciary responsibility in all professional engagements. This commitment extends to the protection of client communications, financial data, and privileged advisory relationships.

This Statement outlines the firm’s obligations, as well as the rights and expectations of our clients regarding the secure handling of their information and the ethical standards we uphold in the provision of our services.

Confidentiality Obligations

Non-Disclosure & Client Privilege

• Treasure Well upholds strict confidentiality obligations in relation to all client matters.

• All client communications, advisory reports, financial data, and strategic recommendations are considered privileged and confidential unless disclosure is required by law.

• Employees, consultants, and authorized affiliates are prohibited from disclosing, sharing, or using any client information for any purpose other than the expressly authorized provision of services.

• Confidential client information shall only be accessible to those individuals within Treasure Well who have a legitimate business or advisory purpose related to the client engagement.

Data Protection & Security Compliance

• Treasure Well implements robust security measures to protect client records, digital communications, and proprietary data from unauthorized access, theft, or breach.

• The firm complies with all applicable data protection regulations, including but not limited to:
  ✔ UK General Data Protection Regulation (UK GDPR)
  ✔ European Union General Data Protection Regulation (EU GDPR)
  ✔ Data Protection Act 2018 (UK)
  ✔ Financial Services Data Security Standards
  ✔ Jurisdiction-Specific Privacy & Financial Secrecy Laws

• Any suspected or confirmed breach of client confidentiality must be immediately reported to the firm’s Compliance & Risk Office, and appropriate remedial measures will be taken in accordance with regulatory requirements.

Legal Exceptions to Confidentiality

Treasure Well shall only disclose client information where:

• Required to comply with lawful orders, court subpoenas, or regulatory investigations;

• Necessary to prevent fraudulent, criminal, or unlawful financial activities, including but not limited to compliance with AML (Anti-Money Laundering) and CTF (Counter-Terrorism Financing) regulations;

• Expressly authorized by the client through written consent.

Treasure Well shall take all reasonable legal steps to contest or limit the scope of mandatory disclosures, ensuring that any release of information is lawful, proportionate, and necessary.

Fiduciary Duty & Professional Responsibility

Duty of Loyalty & Good Faith

• Treasure Well owes a fiduciary duty to its clients, meaning that all services rendered must be performed in the client’s best interest, free from conflicts of interest, and with the highest level of professional care.

• All advisory recommendations and financial structuring strategies must be objective, fact-based, and aligned with the client’s long-term objectives.

Conflict of Interest Policy

• Treasure Well does not engage in financial arrangements or third-party agreements that could create a conflict of interest or undermine our fiduciary obligations to clients.

• All employees and consultants must disclose any actual or potential conflicts of interest, including external financial interests that may compromise independent advisory judgment.

Independence of Advisory Services

• Treasure Well operates independently and does not receive commissions, referral fees, or incentives from financial institutions, investment programs, or third-party service providers.

• The firm’s recommendations are driven solely by legal, financial, and regulatory best practices, without external commercial influence.

Client Rights & Responsibilities

Client Rights Under This Policy

Clients of Treasure Well are entitled to:
✔ Full confidentiality regarding all personal, financial, and transactional matters.
✔ Transparent disclosure regarding the nature and scope of advisory services.
✔ Independent, conflict-free fiduciary representation that prioritizes their best interests.
✔ Timely updates and accurate advisory recommendations on financial, tax, and regulatory matters.
✔ The right to request, access, or amend any personal data held by Treasure Well in accordance with applicable privacy laws.

Client Responsibilities

To maintain regulatory compliance and fiduciary transparency, clients are required to:
✔ Provide accurate, complete, and lawful financial and transactional information.
✔ Disclose any material changes in circumstances that could affect advisory outcomes.
✔ Maintain compliance with all applicable financial, tax, and regulatory obligations.
✔ Abide by all contractual and legal obligations outlined in engagement agreements with Treasure Well.

Failure to comply with these responsibilities may affect the provision of advisory services and Treasure Well’s ability to act on behalf of the client in a fiduciary capacity.

Enforcement & Legal Remedies

Disciplinary Actions for Breaches

Any unauthorized disclosure, misuse, or breach of client confidentiality by Treasure Well employees, consultants, or third-party service providers shall result in:
✔ Immediate disciplinary action, including suspension or termination.
✔ Mandatory regulatory reporting where applicable.
✔ Potential civil and/or criminal legal proceedings under relevant data protection and financial privacy laws.

Legal Recourse for Clients

Clients who believe their confidentiality rights have been breached may:
✔ Submit a formal complaint to the firm’s Compliance & Risk Office.
✔ Request a review and corrective action in accordance with Treasure Well’s internal compliance procedures.
✔ Pursue legal remedies in accordance with applicable financial and data protection regulations.

Legal Disclaimer

• This Client Confidentiality & Fiduciary Duty Statement shall not be construed as creating a contractual or legal relationship beyond the scope of agreed-upon engagement terms.

• Treasure Well does not act as a legal representative or fiduciary beyond the provision of advisory services, and clients are encouraged to seek independent legal counsel for matters requiring formal legal representation.

• This policy shall be governed by applicable financial privacy and data protection laws, and Treasure Well reserves the right to modify, amend, or update this statement in response to regulatory changes or corporate governance requirements.