Prevention and Management of Conflicts of Interest Policy

This document is a public extract of FintechX OÜ’s internal Prevention and Management of Conflicts of Interest Policy. It is published to provide transparency regarding the principles and high-level arrangements the company has in place. The full policy contains additional internal procedures and controls and is not publicly disclosed.

Purpose

FintechX OÜ is committed to acting honestly, fairly and professionally in the best interests of its clients. The purpose of the Conflicts of Interest Policy is to identify, prevent, manage and, where necessary, disclose conflicts of interest that may arise in the course of providing crypto-asset services.

What constitutes a conflict of interest

A conflict of interest may arise where the interests of FintechX OÜ, its management, employees or other relevant persons conflict, or appear to conflict, with the interests of a client, or where the interests of one client conflict with those of another client.

Situations in which conflicts may arise

Conflicts of interest may arise in connection with:

• the provision of services to clients,
• personal or professional interests of relevant persons,
• relationships with third parties, 
• access to confidential or sensitive information.

Additional examples of conflict scenarios are maintained internally and used for training and awareness.

Prevention and management of conflicts

FintechX OÜ maintains internal organisational arrangements and procedures designed to prevent conflicts of interest from adversely affecting clients. These arrangements are proportionate to the nature, scale and complexity of the company’s activities and are subject to internal oversight.

We apply multiple controls to reduce the risk of conflicts and protect client interests, including:

• segregation of duties and clear reporting lines
• organisational separation between business units, including between first and second line of defence
• access controls and “need to know” handling of sensitive information
• procedures to prevent or control information flows in sensitive areas
• separate supervision where employees support activities that could create conflicting client interests
• rules on gifts, hospitality, and inducements, including disclosure requirements where applicable
• external engagement approval requirements for employees (including restrictions on roles that compete with or undermine company interests)
• escalation and governance arrangements for conflicts involving management board members (resolved under supervisory oversight)
  

These arrangements are further supported by the company’s certified management systems, including:

• ISO 37001:2025 Anti-Bribery Management System; and
• ISO 37301:2021 Compliance Management System.
  

Disclosure

Where a conflict of interest cannot be effectively prevented or managed through internal measures, the nature of the conflict shall be disclosed to the public in accordance with applicable legal and regulatory requirements.

Oversight and review

The Conflicts of Interest Policy is subject to ongoing oversight and is reviewed regularly to ensure it remains appropriate, effective and aligned with regulatory expectations.

Questions or Feedback?

If you have any concerns about how Kriptomat applies this policy or wish to report suspected inconsistencies, please contact [email protected].