Conflicts of Interest Statement

Conflicts of interest may occur when:
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• Our interests (or those of our staff or partners) differ from the interests of a user;
• A staff member’s personal interests could interfere with their professional obligations;
• We receive incentives that could affect impartiality in how we serve users.

We maintain internal policies and procedures to identify, disclose, and manage such situations. These include:
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• A Conflicts of Interest Register
• Regular staff training on ethical conduct
• Segregation of duties where applicable
• Disclosure protocols when conflicts arise
• Declining to act where a conflict cannot be managed fairly

Where we collaborate with third parties, affiliates, or service providers (including crypto platforms or partners), we take care to:
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• Disclose any material relationships
• Avoid arrangements that unfairly influence user choice
• Ensure all partnerships are subject to independent vetting and due diligence

In jurisdictions where we offer digital asset services, we ensure that:
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• Our team does not engage in proprietary trading against clients
• Conflicts in referral commissions, custody decisions, or pricing mechanisms are disclosed where required
• Any personal involvement by staff in crypto assets is declared and monitored

All employees and management are expected to:
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• Act in the best interests of our users and the company
• Disclose any personal or financial interest that could interfere with objective service delivery
• Avoid accepting gifts or inducements that could create improper influence
• Uphold our compliance and conduct standards at all times

We encourage employees and stakeholders to promptly report any actual or perceived conflict of interest to our Compliance team. Disclosures are handled confidentially and reviewed according to our internal Conflict of Interest Policy.