Conflict of Interest Statement

BLOX B.V. (hereafter: “BLOX”) is committed to manage conflicts of interest that may arise while providing our crypto-asset services to our clients. BLOX implemented a Policy on Conflict of Interest to ensure a high level of transparency, fairness and integrity in our business operations and meet the regulatory requirements under the Markets in Crypto-Assets Regulation (“MiCAR”). This Policy outlines our approach to preventing, and insofar applicable identifying, mitigating, and managing, conflicts of interest to safeguard the interest of our clients.

1. Scope of the Policy on Conflict of Interest of BLOX

This policy applies to all employees, directors and affiliates of BLOX. It covers potential conflicts that may arise:

Between BLOX (and its affiliated entities) and its Clients.
Between employees or associates of BLOX and its Clients.
Between different (groups of) Clients.
In any other scenario where the interests of BLOX (and its affiliated entities), its employees, its members of the board of directors or its shareholders or associates might give rise to a conflict of interest.

2. Definition of Conflicts of Interest

Conflicts of Interest are situations where competing obligations or incentives may lead BLOX or its personnel to favour one interest over another. Such situations could result in a risk of harm or disadvantage to a our clients, either directly or indirectly. Common examples include:

BLOX or its personnel stand to gain financially at the expense of our clients.
BLOX or affiliated entities have a vested interest in the outcome of a service or order that is different from the interest of the client in that outcome.
BLOX has a financial or other incentive to favour one client or group of clients over another.

3. Identification of Conflicts

To effectively manage conflicts, BLOX is proactive in identifying potential and actual conflicts of interest that could arise during its Service provision and broader operations.

This involves:

Mapping potential conflicts within business processes, employee roles, and Client interactions.
Continuous training for the board of directors and employees on the identification and management of conflicts of interest.
Documentation of conflicts that have arisen or may arise, ensuring transparency and enabling systematic monitoring and review.

4. Preventive Measures

BLOX enforces several preventive measures to minimise the occurrence of conflicts of interest, including:

Segregation of Duties: BLOX enforces separation between members of the board of directors, departments and functions with potentially competing interests. Employees involved in different activities have appropriate independence to prevent conflicts of interest.
Confidentiality and Information Barriers: Sensitive information is accessible only to relevant employees, and information-sharing between departments is restricted to prevent conflicts arising from information asymmetry.
Anti-Bribery and Corruption Policy: BLOX enforces a policy related to gifts, hospitality and entertainment. Employees and directors are required to log certain received gifts, hospitality and entertainment, ensuring they do not influence business decisions.
Implementation of adequate policies: BLOX implemented various charters, policies and standards that should safeguard the best interest of our clients, including the Pricing Policy and the publication thereof on the website and in the application and the coin listing process in accordance with the Treasury Policy.
Second line activities: the Compliance Officer of BLOX monitors the decisions taken by the board of directors to assess whether this constitutes any material conflicts of interests and, if applicable, what follow-up procedures have been incorporated.
Unanimous decision-making: all important strategic decisions require the unanimous approval of all board members.
Sound and controlled remuneration practices: the Remuneration Policy of BLOX should withhold members of the board of directors and employees from prioritizing self-interest over the wider interest of BLOX and its clients.

5. Managing Conflicts of Interest

Where conflicts of interest cannot be prevented, BLOX has established measures to manage and mitigate them:

Disclosure to Clients: in cases where a conflict of interest may affect the interest of our clients, BLOX will disclose the conflict in clear and understandable terms before proceeding with the relevant Service or business activity. This disclosure allows clients to make well-informed decisions regarding the crypto-asset services offered by BLOX.
Annual third-party evaluation: a third-party performs and annual evaluation with respect to the adherence of identified conflicts of interest to the procedures described in the Policy on Conflict of Interest.
Enhanced Review for High-Risk Situations: some conflicts, such as those involving inducements or potential client favouritism or intra-group arrangements, undergo enhanced scrutiny to ensure that mitigation measures are sufficient and effective.
Reporting procedure: BLOX has a Whistleblowing Policy in place that enable anyone, including employees, to confidentially report any conflicts or breaches of this policy without fear of retaliation.

6. Disclosure and Client Consent

If BLOX determines that a conflict of interest cannot be prevented or sufficiently managed through internal control measures, it will inform the affected client(s). This disclosure includes:

A clear description of the nature of the conflict of interest.
The potential impact on the interest of the clients.
The measures taken by BLOX to mitigate the conflict.

Conflict Disclosures

BLOX is part of a group structure. The group structure of BLOX includes amongst other Coinmerce, Coinmerce Earn, QuantFi and Coinmerce Capital Management. As a result of the structure of the group, a (potential) conflict of interest could arise, because of the services provided by these entities in relation to crypto-assets, including (i.e.) the nature of the crypto-assets services of BLOX compared to Coinmerce.

Moreover, part of the members of the board of directors of BLOX, are also members of the board of directors of the other entities within the group, whilst a part of the indirect shareholders that have a majority interest in BLOX also have an interest in Coinmerce, Coinmerce Earn, QuantFi and Coinmerce Capital Management. Furthermore, part of the indirect shareholders that hold a minority interest in BLOX also have an interest in BTC Direct.

BLOX acknowledges the importance of an adequate and transparent disclosure towards its clients and would like to inform its clients in the same transparent manner about the mitigating measures that have been implemented to mitigate the inherent conflicts of interest from rising. These conflicts have been mitigated via (a.o.) the joint authorization of members of the board of directors, the unanimous decision-making for important strategic decisions, the monthly assessment of (potential) conflicts of interest by the board of advice, the strict handling of conflicts of interest situations in the decision-making process and the annual validation of a third party on adherence to the applicable policies and procedures to manage and monitoring conflicts of interest.

BLOX has not identified any other conflicts of interest that require disclosure to clients under applicable regulatory obligations. Should another conflict of interest arise in the future that cannot be adequately prevented or managed, BLOX will ensure that clients are promptly informed of such conflict. The disclosure will include the date the conflict came into existence and shall be displayed in chronological order below.