Conflicts of Interest Disclosure

What this disclosure covers

Conflicts of interest may arise where our interests, the interests of our employees, managers, shareholders or affiliated persons, or the interests of one client, differ from the interests of another client. This may create a risk that a client's interests are affected.

Services concerned

• custody and administration of crypto-assets on behalf of clients;
• exchange of crypto-assets for funds;
• execution of orders for crypto-assets on behalf of clients; and
• transfer services for crypto-assets on behalf of clients.

Examples of potential conflicts

Conflicts may arise, for example, where we or a connected person could benefit financially at a client's expense, where we have an interest in the outcome of a service that differs from the client's interest, where one client may be favoured over another, where third-party benefits or incentives are involved, or where personal or business interests could affect independent decision-making.

How we manage and mitigate conflicts

• internal reporting procedures;
• confidentiality and access controls;
• limits on inappropriate information sharing;
• separate supervision and segregation of duties;
• controls against inappropriate influence;
• staff training and management oversight; and
• remuneration arrangements designed to reduce incentives that could harm clients' interests.

Disclosure to clients

If our organisational and administrative arrangements are not sufficient to prevent, with reasonable confidence, the risk of harm to a client's interests, we will clearly disclose the relevant conflict before providing the affected service so that the client can make an informed decision.