Conflict Of Interest

The scope of the Policy adopted by Cryptos Fund Trading™ (the “Company”) consists of identifying and managing any Conflict of Interest that may arise between the company and its clients and to comply with all requirements of the applicable laws.

Cryptos Fund Trading™ establishes, implements, and maintains a Policy on Conflict of Interest and provides information regarding the adequate management of any Conflicts of Interest between itself, including its managers and employees and/or any associate, affiliate or subsidiary, as well as any person directly or indirectly linked to the company (the “Related Persons”), and its clients that arise in the course of providing its services.

Identification of Conflict of Interest

Situations in which Conflicts of Interest can occur include cases where:

1. Cryptos Fund Trading™ or a Related Person is likely to make a financial gain or avoid a financial loss, at the expense of the client.

2. Cryptos Fund Trading™ or a Related Person has an interest in the outcome of a service provided to the client, or of the transaction carried out on behalf of the client, which is different from the client’s interest in that outcome.

3. Cryptos Fund Trading™ or a Related Person has financial or other incentives to favor the interest of another client or group of clients over the interests of the client.

4. Cryptos Fund Trading™ 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 money, goods, or services, other than the standard commission or fee for that service.

5. A conflict of interest may arise, between the following parties :

• Between the client and Cryptos Fund Trading™;
• Between Cryptos Fund Trading™ and its Related Persons;
• Between a client of Cryptos Fund Trading™ and the Related Persons.

Conflicts may also arise from the jurisdictions or regulatory statuses of a client’s UBOs, which could impact the services provided.

Adopted Measures

The following measures have been adopted by Cryptos Fund Trading™ to prevent any conflicts of interest which might arise while Cryptos Fund Trading™ conducts its business:

1. Cryptos Fund Trading™ undertakes to carry out ongoing monitoring of its business activities to ensure that its internal control is adequate.

2. Cryptos Fund Trading™ undertakes effective procedures to prevent or control the exchange of information between the Related Persons engaged in activities involving a risk of a Conflict of Interest if the exchange of that information may harm the interests of one or more clients.

3. Cryptos Fund Trading™ takes measures to prevent or limit any person from exercising inappropriate influence over the way in which the Related Persons carry out its portfolio management services or ancillary services.

4. Cryptos Fund Trading™ ensures segregation of duties that may give rise to conflicts of interest if carried on by the same individual.

5. When Cryptos Fund Trading™ executes an order for a client it shall not give any preferential treatment to that client to the detriment of other clients or disclose the details of a client’s order to another client.

6. Cryptos Fund Trading™ executes all orders electronically, in accordance with policies that comply with relevant rules and regulations in relation to transactions which are executed for the account of the clients.

7. Cryptos Fund Trading™’s procedures ensure that Cryptos Fund Trading™’ and its Related Persons shall not misuse the information provided to them in relation to the portfolio management services carried out on behalf of clients.

8. All Related Persons of Cryptos Fund Trading™ are prohibited from dealing on personal accounts to avoid any actual or possible conflicts of interest.

9. All Related Persons of Cryptos Fund Trading™ are prohibited from accepting any inducements from any person, which are likely to conflict to a material extent with any duty which Cryptos Fund Trading™ and/or its Related Persons owe in connection with the fair conduct of the portfolio management services.

Implement procedures to monitor and ensure that clients’ UBOs comply with applicable laws and regulations to prevent conflicts arising from non-compliance.

Disclosure of Conflict of Interest

Prior to carrying out a transaction or providing a portfolio management service or an ancillary service to a client, Cryptos Fund Trading™ shall disclose any actual or potential Conflict of Interest. Conflicts of Interest shall be disclosed in sufficient time and in lasting form.
Any Conflict of Interest shall be reported to the manager of Cryptos Fund Trading™, who shall be responsible for keeping records of all Conflicts of Interest.

Clients are required to disclose any potential conflicts of interest arising from their UBOs’ jurisdictions or regulatory statuses that may affect the services provided.