Summary of the Conflict of Interest Management Policy

At Floin, integrity, transparency, and fairness are core to how we operate. Our Conflict of Interest (CoI) Management Policy explains how we identify, manage, and, when necessary, disclose actual or potential conflicts of interest in line with the Markets in Crypto-Assets Regulation (MiCA).

Purpose

We aim to ensure that any conflict of interest that might affect our crypto-asset services is recognized early, managed appropriately, and clearly disclosed to clients where required. The policy applies to all employees, directors, officers, contractors, agents, and any connected person (any person with a relationship to Floin that may result in undue influence, including employees, family members, or partners) whose actions could impact client interests.

How Conflicts May Arise

Conflicts of interest can occur in situations such as:

• Floin or connected persons could gain financially at a client’s expense.

• Floin’s interest in a service outcome differs from that of a client.

• Incentives from third parties could influence services provided.

• Multiple clients have competing interests in the same matter.

• Floin trades in crypto-assets where it holds its own position.

• An employee has a financial stake in a project onboarded by Floin.

• An employee receives gifts or other benefits from a client or third party.

• Confidential client information is misused for advantage.

• Employees trade crypto-assets using insider knowledge.

• Floin acts as both issuer and service provider for a crypto-asset.

Furthermore, Floin considers the situations listed in Art 79 (2) MiCAR.

Prevention and Management

Floin applies robust measures to prevent and manage conflicts, including:

• Segregation of duties and independent oversight.

• Information barriers between departments.

• Remuneration policies aligned with long-term client interests.

• Disclosure and approval requirements for personal transactions.

• Ongoing compliance monitoring and periodic assessments.

Disclosure

If a conflict cannot be fully prevented, we will inform clients before providing services, in a clear and durable form, enabling them to make informed decisions.

Prohibited Transactions

Floin prohibits the following activities for its employees, management, and other connected persons:

• Using confidential information for personal gain.

• Front running client or company transactions.

• Undisclosed personal account dealing or external interests.

• Preferential allocation of tokens or assets.

• Unauthorized related-party transactions.

Oversight and Review

Floin keeps thorough records of identified conflicts, related actions, and client communications. We provide regular training to our personnel and review this policy annually to remain aligned with regulatory and operational developments.

Types of Potential Conflict of Interest Situations in Crypto-Asset Services

Conflicts of Interest Potentially Detrimental to Floin (Art 4 [4] lit a DelReg (EU) 2025/1142)

• A connected person holds shares, governance tokens, or other ownership interests in an entity with interests that may conflict with Floin’s;

• A connected person maintains, or has maintained in the last three years, a professional, personal, or political relationship with a party whose interests may conflict with Floin;

• A connected person performs roles or tasks that are inherently conflicting, or is under the supervision of someone with conflicting duties;

• A member of the management body, employee, or significant shareholder maintains contractual or financial ties (e.g., loans, service agreements) with third parties whose interests could compromise Floin’s objectivity.

Conflicts of Interest Potentially Detrimental to Clients (Art 4 [4] lit a DelReg (EU) 2025/1142)

• Floin or a connected person may obtain a financial gain or avoid a loss at the client’s expense;

• Floin has a distinct interest in the result of a client transaction or service that could misalign with the client’s objectives;

• Floin receives incentives (financial or otherwise) that may cause preferential treatment of one client over another;

• Floin conducts business activities in direct competition with a client’s services or products;

• Floin accepts inducements from third parties in connection with services rendered to a client, which may impair fair treatment or impartiality.

Conflicts of Interest Specific to the Placement of Crypto-Assets (Art. 79 (2) MiCA)

• Placement with own clients: Floin, while acting as placement agent, offers or allocates crypto-assets directly to its existing clients, creating a risk of preferential treatment or misalignment between issuer and client interests;

• Mispricing of placements: The proposed placement price (see IS22 - Internal Standard on Pricing & Execution and A16 - Fee Schedule & Price Register) is overestimated (harming clients) or underestimated (harming issuers), creating conflicts between Floin’s commercial interests, client expectations, and issuer requirements;

• Issuer incentives: Floin receives monetary or non-monetary incentives from the offeror (issuer), such as rebates, marketing contributions, preferential allocations, or fees (see IS22 - Internal Standard on Pricing & Execution and A16 - Fee Schedule & Price Register), which could compromise Floin’s impartiality in executing placements.

Custody and Administration of Crypto-Assets on Behalf of Clients (Art. 3 [16] lit a MiCA)

• Floin uses pooled wallets in a way that could obscure ownership and prioritise certain clients in access to assets;

• Employees with access to private keys have outside financial interests that may conflict with safeguarding client assets;

• Floin earns revenue from staking, lending, or rehypothecation activities that could conflict with the client’s best interest;

• Decisions about timing of return of assets could disadvantage one client to benefit another.

Exchange of Crypto-Assets for Funds (MiCA Art. 3 [16] lit c) and Exchange of Crypto-Assets for Other Crypto-Assets (Art. 3 [16] lit d MiCA)

• Floin benefits from spreads (see IS22 - Internal Standard on Pricing & Execution and A16 - Fee Schedule & Price Register) or execution arrangements that may not always secure best execution for clients;

• Pricing (see IS22 - Internal Standard on Pricing & Execution and A16 - Fee Schedule & Price Register) is derived from a single venue (Kraken); disruptions may create incentives for Floin to delay or reroute trades in ways that disadvantage clients;

• Floin earns higher fees or commissions (see IS22 - Internal Standard on Pricing & Execution and A16 - Fee Schedule & Price Register) from certain asset pairs, which could incentivise steering clients towards less favourable pairs;

• Manual interventions under fallback mechanisms could be used selectively in favour of certain clients.

Transfer Services for Crypto-Assets on Behalf of Clients (Art. 3 [16] lit j MiCA)

• Floin prioritises transfers for high-value clients, delaying execution for others;

• Employees involved in approving flagged transfers (due to AML or Travel Rule concerns) may have personal interests influencing their decision;

• Fee structures (see IS22 - Internal Standard on Pricing & Execution and A16 - Fee Schedule & Price Register) (e.g., charging higher priority fees) could incentivise Floin to recommend unnecessary “fast-track” execution;

• Technical incidents could be resolved in a way that benefits Floin’s proprietary wallets or related parties first.

Connected Persons

The following list of connected persons is established in accordance with Article 1(1) of the DelReg (EU) 2025/1142: