Last Updated: 18 June 2026

Each Bitpace entity  (“we“, “us“, “our”) is committed to the identification, prevention, management, and disclosure of any conflicts of interest that may occur between:

• ourselves and the persons related to Bitpace (“Connected Persons”), as follows:
  i. our shareholders or members;
  Ii. any person directly or indirectly linked to us or our shareholders or members by control;
  iii. members of our management body;
  iv. our employees;
• our clients; or
• two or more of our clients whose mutual interests conflict.

Types of Conflicts

A conflict may arise where Bitpace, or one of its shareholders or members, members of our management body, employees, or Connected Persons:

• Is likely to make a financial gain, or avoid a financial loss, at the expense of a client;
• Has an interest in the outcome of a service provided to a client or a transaction executed on behalf of a client, which is distinct from the client’s interest in that outcome;
• Has a financial or other incentive to favour the interests of one client or group of clients over the interests of another client; or
• Receives or will receive from a person other than the client an inducement (i.e. a fee, a gift or entertainment) in relation to a service provided to the client, in the form of monies, goods or services, other than the standard commission or fee for that service.

Identification and Management of Conflicts of Interest

Regulators require organisations to maintain and operate effective governance and administrative arrangements, with a view to taking all appropriate steps to manage conflicts of interest and prevent them from constituting or giving rise to a risk of damage to the interests of their clients. Where it is not possible to avoid or manage a conflict of interest, Bitpace has the discretion to decline to provide the service requested. As part of Bitpace’s governance framework, a number of organisational arrangements, systems and internal controls have been implemented which are designed to identify and manage potential conflicts of interest to prevent damage to the interests of Bitpace’s clients. The controls include, but are not limited to:

• Governance structure;
• Senior management oversight, management information and reporting;
• Mandatory training, including treating customers fairly, conflicts of interest,  and corruption;
• Code of Conduct, which includes terms and conditions of employment;
• Conflicts of Interest Policy and Anti-Bribery and Corruption Policy for gifts and entertainment reporting.

In addition to the above controls, conflicts of interest are reported using a central conflicts of interest reporting registry and are reviewed by Compliance to establish mitigating controls. All employees (including executive and non-executive directors) are required to report perceived, possible or real conflicts of interest. Bitpace maintains a record of all identified situations that may give rise to a conflict of interest, along with a record of the controls recommended to manage such conflicts.

Examples of Conflicts of Interest and Mitigation Measures

We have identified conflicts of interest that may occur when operating our services. We pay particular attention to instances where the interests of Bitpace may conflict with the best interests of our clients. Set out below are some of the core conflicts of interest that may arise, with details of the relevant mitigation measures applied by Bitpace.

• Connected Persons involved in conflicting activities – to prevent these potential conflicts, Bitpace has implemented an appropriate segregation of duties within our internal organisation;

• Connected Persons involved in conflicting activities sharing information – Bitpace has established information barriers between business lines and units to prevent unnecessary sharing of information;

• Connected Persons supervising another Connected Person that is involved in activities conflicting with those of the supervising Connected Person – Bitpace ensures a separate supervision of Connected Persons who represent different interests that may conflict, including those of Bitpace;

• Connected Persons supervising two or more conflicting activities – Bitpace has taken the effort to separate conflicting business activities and their supervision within our organisation;

• Bitpace or a Connected Person has a holding in, is trading, or otherwise holds interest in one or more crypto-assets which are purchased or sold by our clients – to mitigate the probability of such conflicts occurring, Bitpace does not engage in principal trading or trading for its own account;
• A Connected Person engages in personal account dealing in respect of crypto-assets, and such dealing can potentially conflict with the interests of our clients – Bitpace has implemented measures to ensure that personal transactions initiated by Connected Persons are subject to prior approval by Bitpace.

Remuneration

Remuneration for employees, board members and other natural persons involved in the provision of Bitpace’s services may create a conflict of interest that encourages those persons to act against the interests of any of Bitpace’s clients or impair their abilities to fulfil their duties and responsibilities in an objective and independent manner.

Therefore, Bitpace has adopted a remuneration structure that is balanced between fixed and variable components, so that it does not favour the interests of its Connected Persons against the interests of any client, in both the short, medium and long term. This remuneration structure is based on both quantitative commercial criteria and qualitative criteria, reflecting compliance with applicable regulations and the fair treatment of Bitpace’s clients.

Inducements

In providing our services to clients, Bitpace may, from time to time, provide, accept, or retain certain minor non-monetary benefits to or from third parties. Should this occur, it may give rise to potential conflicts of interest in which such benefits could impair Bitpace’s obligation to act in the best interests of its clients. As part of Bitpace’s regulatory responsibilities and with regard to fiduciary obligations it owes to clients, it is Bitpace’s policy to avoid providing, accepting or retaining any fee, commission or monetary benefit to or from third parties, apart from minor non-monetary benefits. To further minimise the risk of conflicts, Bitpace has adopted a process for reporting Gifts and Entertainment under its Anti-Bribery and Corruption Policy. 

Non-advised Status

Bitpace maintains a non-advised status by not providing any form of investment advice or portfolio management services. Consequently, clients are solely responsible for determining the merits of their transactions and deciding whether to proceed with them.

This non-advised status is fundamental to managing conflicts of interest and maintaining our operational independence. 

Ancillary activities

Ancillary activities of Connected Persons may lead to conflicts of interest between the Connected Person and Bitpace or Bitpace’s clients. Therefore, ancillary activities are not allowed to be conducted by Connected Persons unless the corresponding Compliance Officer has granted permission for a specific activity, irrespective of whether the position is paid or unpaid.

***

For reference, the preceding iteration of this Conflicts of Interest Disclosure was published on this website on  February 13, 2026. This information is provided for reference.