Conflict of Interest

Atremo Digital FZE ("Atremo") is committed to identifying, managing and, where appropriate, disclosing actual, potential and perceived conflicts of interest that may arise in connection with the provision of its Broker-Dealer Services. Where conflicts cannot be avoided, Atremo implements appropriate controls to ensure that clients are treated fairly and its regulatory obligations are met.
Business Conflicts of Interest
Conflicts of interest may arise in connection with the provision of Broker-Dealer Services, including:
Principal Dealing, Pricing and Fees – Atremo may act as principal or counterparty to client transactions and may earn transaction fees, spreads or mark-ups. Atremo seeks to ensure that pricing is applied consistently and transparently, and that applicable fees and charges are disclosed to clients.
Liquidity Provider Selection – Atremo may utilise one or more liquidity providers. Liquidity providers are selected based on factors including execution quality, pricing, available liquidity, operational resilience and counterparty risk, rather than commercial incentives alone.
Order Routing – Where Atremo has discretion in routing client orders, execution decisions are based on objective execution and operational considerations to support fair client outcomes.
Custody and Third-Party Service Providers – Atremo conducts due diligence and ongoing oversight of custodians and other key third-party service providers to help ensure they continue to meet operational, regulatory and risk management requirements.
Referral Arrangements – Atremo may receive client introductions from third parties. Such arrangements are subject to appropriate governance and Compliance review to ensure they do not compromise the fair treatment of clients. Atremo does not refer clients to third-party Virtual Asset Service Providers or receive benefits from outbound referral arrangements.
Managing Conflicts
Atremo manages conflicts of interest through:

• documented policies and procedures;

• segregation of duties and information barriers, where appropriate;

• Compliance oversight and periodic monitoring;

• due diligence and ongoing oversight of third-party service providers;

• governance over referral arrangements; and

• disclosure to clients where a conflict cannot be effectively avoided or managed.

Employee Responsibilities
All employees are expected to identify, disclose and appropriately manage actual, potential and perceived conflicts of interest by:

• acting with integrity in all business activities;

• considering potential conflicts in their day-to-day responsibilities;

• avoiding activities or relationships that could compromise, or reasonably appear to compromise, their professional judgement;

• obtaining approval before engaging in outside business or financial interests that may create a conflict; and

• promptly reporting any actual, potential or perceived conflict of interest to the Compliance function.

When assessing whether a conflict exists, employees should consider whether a decision could result in a personal benefit, impair their objectivity, involve a close personal or financial relationship, influence the fair treatment of clients, or adversely affect Atremo's reputation or regulatory obligations.