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HC-2.4.3

The Board should establish formal procedures for:

(a) Periodic disclosure and updating of information by each approved person on his actual and potential conflicts of interest; and
(b) Advance approval by directors or shareholders who do not have an interest in the transactions in which a card processing services', credit reference bureaus', and payment service providers' approved person has a personal interest. The Board should require such advance approval in every case.
October 2019