CONFLICT OF INTEREST DISCLOSURE

For the sake of transparency towards existing and prospective clients, Digital Assets d.o.o. (hereinafter: the Company), as a crypto-asset service provider, discloses the general nature and sources of conflicts of interest and the measures it undertakes for their timely identification, prevention, management and disclosure.

This disclosure has been prepared in accordance with Article 72(2) of Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets, establishing a regulatory framework for crypto-assets (MiCA – Markets in Crypto-Assets Regulation).

What is a conflict of interest?

A conflict of interest arises when the personal, financial or other interests of the Company, its employees, management board members or related persons may influence, or are perceived to influence, the impartial, objective and professional provision of services. Such a conflict may jeopardise the Company’s ability to act solely in the best interest of clients.

Conflicts of interest may arise:

• between the Company and clients
• between the Company and its employees, management board members or related persons (including those linked through control)
• between clients themselves when their interests are mutually opposed.

How does the Company manage conflicts of interest?

The Company has established internal policies, procedures and controls, tailored to its size, organisation and the nature of its business, with the aim of:

• timely identification of conflicts of interest
• their prevention and mitigation
• and, when necessary, disclosure to clients.

Measures implemented by the Company include:

• adoption and regular updates of the Conflicts of Interest Policy
• establishment of an internal control system ensuring that services are provided in the best interest of clients
• appointment of compliance and risk management functions, managed by independent and professionally trained employees
• implementation of an employee training programme on identifying and handling situations of potential conflicts of interest.

Documentation relating to conflicts of interest is reviewed regularly, at least once a year, by the Compliance Department.

Disclosure of conflicts of interest

If a conflict of interest cannot be avoided, the Company will:

• inform clients of its existence in a timely and clear manner
• provide all relevant information so that the client can make an informed decision on whether to continue using the service.

Disclosure of a conflict of interest constitutes a measure of last resort and is applied only if organisational and administrative measures are not sufficient to prevent or completely eliminate the conflict.

Examples of potential conflicts of interest

Suspension of trading

A conflict of interest may arise if the Company decides to temporarily suspend trading in a particular crypto-asset while at the same time having financial exposure to that asset. In such a case there is a risk that the decision is made to protect the interests of the Company, rather than on the basis of market circumstances or the client’s interests.

Trading in own products

The Company may simultaneously issue, promote or enable trading in a crypto-asset for which it also provides other related services (e.g. custody). This may create a financial interest leading to the favouring of the Company’s own products, regardless of whether they are most favourable for the client.

Encouraging trading activity

Since clients trading activity may have an impact on the Company’s revenue, there is a risk that volatile or popular crypto-assets are promoted on the platform in order to encourage trading, which may put the Company’s financial interest ahead of clients interests.

Note: Although the client always makes their own trading decisions, the Company still has an obligation to actively prevent or mitigate potential conflicts of interest.

Contact for additional information

For further clarification, clients may contact the Company at e-mail: zop@bitcoin-store.hr