Conflict of Interest Policy

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1. Purpose and Objective

The purpose of this Policy is to set out the framework for identifying, preventing, managing, and disclosing conflicts of interest that may arise in the course of PIL providing crypto-asset services. Our goal is to ensure that the interests of our clients are always prioritized and that the integrity of the market is maintained.

2. Scope

This Policy applies to all employees, directors, officers (collectively “Staff”), and any third-party service providers acting on behalf of PIL in the Ireland, Germany, France, and Lithuania markets.

3. Identification of Conflicts

A conflict of interest may arise when the interests of PIL (or its Staff/Group entities) compete with the interests of a client, or when the interests of one client compete with another. Potential scenarios include:

  • Proprietary Trading: PIL or its affiliates trading against clients on the OrderBook.
  • Personal Transactions: Staff using non-public information for personal crypto trading (Insider Trading).
  • Inducements: Receiving gifts or commissions from third parties that may influence professional judgment.
  • Custody Services: Relationships with third-party custodians (e.g., Banking Circle) where PIL might have undisclosed interests.

4. Management and Mitigation Measures

To ensure we “survive” regulatory scrutiny and protect our license, PIL implements the following “Chinese Walls” and controls:

  • Organizational Segregation: Clear functional separation between departments (e.g., Sales vs. Compliance vs. Asset Custody) to prevent the flow of sensitive information.
  • Personal Account Dealing (PAD) Policy: Staff must disclose their personal crypto holdings and obtain pre-clearance for trades involving assets listed on PIL.
  • Remuneration Policy: Staff compensation is structured to avoid incentives that lead to behavior detrimental to client interests.
  • Transparency in Custody: Disclosure of all technical and financial links with providers like Fiat Republic and Banking Circle S.A., as defined in our Custody and Administration Policy.

5. Disclosure to Clients

Where a conflict of interest cannot be fully avoided through administrative arrangements, PIL shall:

  1. Clearly disclose the general nature and sources of the conflict to the client before undertaking business.
  2. Provide sufficient detail via the End User Portal to enable the client to make an informed decision.

6. Record Keeping

In accordance with MiCAR requirements, PIL maintains a Conflict of Interest Register. All identified conflicts and the actions taken to mitigate them must be recorded and kept for a minimum of five years.

7. Breach Management

Failure to comply with this policy may result in disciplinary action and, as highlighted in our Risk Management Policy, could lead to significant regulatory fines from the Central Bank of Ireland (CBI).