Summary of the Conflict of Interest Management Policy
Last updated: 31. August 2025
Last updated: 31. August 2025
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).
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.
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.
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.
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.
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.
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.