Conflicts of Interest Policy

This conflicts of interest policy (the “Conflicts of Interest Policy” or the “Policy”) sets out our approach to the management of conflicts of interest when acting as a Crypto-Asset Service Provider. This Policy has been drawn up in accordance with the requirements of Chapter 3 of the Virtual Financial Asset Rulebook (the “VFAR”).

Payhound shall establish, implement and maintain effective organizational and administrative arrangements appropriate to the size and organization and the nature, scale and complexity of its business, to prevent conflicts of interest from adversely affecting the interests of its clients.

Identification of conflicts of interest

A conflict of interest, whether actual or potential, arises or may arise when the interests of the Company (or of a Related Person, or of the personal interests of the directors, officials, or employees of the Company or such Related Person) conflicts, or appears to conflict, or are otherwise adverse to, or may appear to be adverse to:

i. The interests of a client or the duties owed to a client;

ii. The competing interests of different clients or the duties owed to different client. (in each case, whether the client is an existing client or a prospective client); and

iii. The interests of the company as a whole.

Circumstances giving rise to conflict of interest

The Board of Directors have identified the following circumstances as those circumstances that may give rise to a conflict of interest, whether actual or potential, and which may, therefore, conflict with the interests, or are otherwise adverse to, or may appear to be adverse to, the interests of the Company or of its clients:

i. The Company (or its directors, officials, or employees) or a Related Person is likely to make a financial gain or avoid a financial loss which would be detrimental to a client or the Company itself;

ii. The Company (or its directors, officials, or employees) or a Related Person has an interest in the outcome of a Crypto-Asset Service provided to the client or the Company or of a transaction carried out on behalf of a client, which is distinct from the clients’ or the Company’s interest in that outcome;

iii. The Company (or its directors, officials, or employees) or a Related Person receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monies, goods or services, other than the standard fee for that service and/or minor monetary and/or non-monetary benefit which would not be suitable to impair the conduct of the Company. For the purpose of this section, the term “minor” refers to goods and/or services having a value lower than €100 per individual;

iv. The Company (or its directors, officials, or employees) or a Related Person has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client causing an undue and unfair detriment to the latter;

v. The Company’s or Related Persons’ remuneration and incentive structures and systems;

vi. The Company (or its directors, officials, or employees) or a Related Person carries on the same business as the client (that is, where the client provides Crypto-Asset Service Provider services, or such equivalent or similar services, itself);

vii. The Company (or its directors, officials, or employees) or a Related Person act, or provides assistance or advice, for or against the client (or its directors, officers, employees or shareholders);

viii. The same individuals within the Company are assisting two clients at the same time where such clients are competing for the same business (for instance, where such business may only be undertaken on an exclusive basis, as in the case of a competitive tendering process or similar competitive process);

ix. The Company or a Related Person has obtained Confidential Information of a client, other than in the course of an engagement; or

x. The directors, officers, or other employees of the Company provide advice or other assistance (consultant,adviser, delegatee, outsource, service provider or other supplier) to the client in a capacity other than in the capacity as a Crypto-Asset Service Provider and it can be reasonably deemed from objective circumstances that there may be a conflict of interests.

The circumstances identified above are not exhaustive, and may be supplemented, altered, amended, or otherwise varied from time to time, in accordance with the prevailing circumstances from time to time.

Managing conflicts of interest

The Company manages conflicts of interest through:

• Disclosure: If a conflict of interest is identified, it must be promptly disclosed to the Compliance Officer. The Company will then determine the appropriate course of action, which may include disclosing the conflict to the affected clients.
• Avoidance: In cases where a conflict of interest cannot be managed or mitigated, the Company may choose to avoid the transaction or relationship entirely.
• Segregation of Duties: Implementing clear segregation of duties to ensure that conflicting roles or interests do not influence business decisions.
• Client Consent: In situations where a conflict of interest is unavoidable, obtaining informed consent from the affected client(s) before proceeding with the relevant transaction or decision.

Reporting and Escalation

Employees must report any conflicts of interest or potential conflicts to the Compliance Officer or through other designated channels. Clients may report any instances of conflicts of interest to the Compliance Officer on [email protected].