Conflicts of Interest Disclosure

Introduction

As an authorised crypto-asset service provider under the Markets in Crypto Assets Regulation, Zero Hash Europe B.V. ("Zero Hash") is required to identify, prevent, manage and disclose conflicts of interest between Zero Hash and its shareholders or members, any person directly or indirectly linked to Zero Hash or its shareholders or members by control; members of its management body; its employees; or its clients; or between two or more clients whose mutual interests conflict.

Zero Hash will take all appropriate steps to identify and prevent or manage conflicts of interest, by:

• Identifying and preventing any potential circumstances which may give rise to conflicts of interest, and entail a material risk to or damage the interests of a customer;
• Establishing and maintaining appropriate processes and measures to manage and mitigate those conflicts, and
• Maintaining processes at all times to prevent actual damage to customers' interests through the identified conflicts.

Zero Hash acknowledges that conflict of interest may arise in several ways, including but not limited to situations where Zero Hash or a Zero Hash employee, including management:

• could make a financial gain, avoid a financial loss, or receive another benefit at the expense of a customer;
• has an interest in the outcome of a service provided to a customer that differs from the customer's interest;
• has a financial or other incentive to favour the interests of one customer over another;
• is engaged in the same business as a customer;
• receives an inducement from someone other than the customer in relation to a service provided.

This statement describes the general nature and sources of conflicts of interest and the steps taken to mitigate them.

Note: At this time, Zero Hash has not identified any conflicts of interest that have not been sufficiently mitigated.

Conflicts of Interest

Remuneration

Zero Hash's remuneration scheme may give rise to potential conflicts of interest, particularly if incentives are directly linked to the achievement of commercial targets such as acquiring new customers or increasing trading volumes.

Control Measures

Zero Hash has the following control(s) in place to manage this risk:

• Zero Hash applies prudent remuneration principles and has a written Remuneration Policy in place. Any variable remuneration is awarded on the basis of qualitative and quantitative criteria, which ensure an appropriate balance between financial and non-financial factors. The interest of Zero Hash's customers are incorporated in the remuneration system of Zero Hash pursuant to the written Remuneration Policy.
• Zero Hash uses Carta to determine compensation ranges and comparables in all markets and with all positions. This would include any executive compensation in the Netherlands.

Accepting Gifts

The acceptance of gifts, invitations or any other type of inducement by employees, including management board members, can potentially give rise to perceived conflicts of interest, particularly when such gestures come from third parties with whom Zero Hash maintains or may establish a business relationship.

Control Measures

Zero Hash has the following control(s) in place to manage this risk:

Zero Hash has a Gift Entertainment and Travel Policy which sets out five criteria that must be met for both gifts provided or received:

1. For a proper purpose, and not intended to secure an improper advantage or otherwise inappropriately influence the recipient.
2. Permitted by law,
3. Permitted by our policies,
4. Permitted by the recipient's policies, and
5. Reasonable in value and appropriate under the circumstances.

Zero Hash will conduct regular compliance training in line with the current program which is being run in the United States, which covers understanding and compliance with the policy and broader conflicts risks.

Employee Trading

Employees at Zero Hash, including management and board members, may hold or trade crypto assets relevant to the Zero Hash Platform privately, which may give rise to potential conflicts of interest.

Control Measures

Zero Hash has the following control(s) in place to manage this risk:

• Employees are required to refrain from trading based on material non-public information; and more in general all employees are bound by confidentiality obligations, and the obligation to immediately report the relevant information to the designated board member.
• Employees or former employees of Zero Hash in possession of material non-public information may not trade in crypto assets until that information has become public or no longer material.
• Under the Employee Trading Policy, employees must disclose all crypto assets held in any wallet or account at the start of their employment or when requested to do so. Employees must keep disclosures current, and provide a quarterly attestation confirming that their previously submitted disclosure remains accurate and up to date. Employees should disclose any conflict of interest to the Compliance function in accordance with the Conflict of Interest Policy.

Fund Segregation

Assets belonging to affiliated end customers may be held in Stichting Derdengelden Zero Hash Europe ("SDG Zero Hash") omnibus wallets, while Zero Hash Liquidity Services LLC ("ZHLS") may act as the settlement provider for related transactions. Because Zero Hash Group can be both the custody/service provider (via Zero Hash) and the settlement provider (via ZHLS), Zero Hash has an economic interest in these arrangements, which may give rise to potential conflict of interests.

Control Measures

Zero Hash has the following control(s) in place to manage this risk:

• Zero Hash has implemented a robust governance and fund segregation framework including processes with separation of roles and responsibilities between business operations and client asset administration.
• ZHLS executes a subordination agreement with Zero Hash and SDG Zero Hash that ensures that non-affiliated End Customers shall have first rights to all assets in the SDG Zero Hash Omnibus Wallets in the case of Zero Hash or ZHLS's insolvency.

Fully Disclosed Model

Zero Hash provides its services through partner platforms in a B2B2C model. This means your primary point of contact is your platform provider (the Platform Operator). Under our fully disclosed arrangement, you are also a customer of Zero Hash, although day-to-day communications will usually take place via your platform provider. Because we operate through platform providers while also serving end customers, this model may create potential conflicts of interest between Zero Hash, the Platform Operator, and customers.

Control Measures

Zero Hash has the following control(s) in place to manage this risk:

• Zero Hash has a detailed onboarding procedure for End Customers and undertakes all necessary controls and reviews to identify each End Customer. The services rendered to the End Customer are not tailored (with the exception of a rare OTC transaction) which leads to a lower need for detailed interaction with an End Customer.

Asset Quality

Economic incentives in the digital asset market may create a conflict of interest between Zero Hash and its customers. In some circumstances, Zero Hash may list or support lower‑quality or higher‑risk assets in a way that benefits Zero Hash but does not align with customers' best interests. Common industry incentives can encourage support for digital assets that may not be in customers' best interests. Supporting such assets may disadvantage customers, particularly those without the background needed to make an informed decision.

Control Measures

Zero Hash has the following control(s) in place to manage this risk:

• Zero Hash maintains a Token Acceptance Framework and a Token Listing Policy which set out the acceptance requirements for tokens.
• Zero Hash may also delist or cease supporting a token if it is determined to be a security issue.

Trading Suspensions

A decision by Zero Hash to suspend trading may create a conflict of interest between Zero Hash, end customers, and platform operators. In some circumstances, a suspension may benefit Zero Hash, by reducing its risk or providing an economic advantage, while restricting customers' ability to transact and potentially disadvantaging customers and platforms.

Control Measures

Zero Hash has the following control(s) in place to manage this risk:

• Zero Hash operates a dedicated, 24/7 Settlement Operations team that continuously monitors inventory and settlement activity.
• Zero Hash maintains a trading rulebook that sets out day to day trading procedures and the processes for trading halts and suspensions.

Group Structure and Prioritisation

Zero Hash Group comprises multiple, vertically integrated entities under common ownership and control. For revenue or strategic reasons, the Group may prioritise certain products, services, or entities over others. This creates potential conflicts of interest between Group entities. Decisions to favour one part of the value chain (or a particular entity) may disadvantage other entities and may impact customers or partners that rely on them—such as through reduced resources, slower development, or changes in commercial focus. At a global level, emphasising a specific process or product may limit the growth or competitiveness of other areas of the business.

Control Measures

Zero Hash has the following control(s) in place to manage this risk:

• Outsourced compliance activities between affiliates are overseen by a dedicated Chief Compliance Officer – International, who is separate and independent from the Chief Compliance Officer – North America.
• Zero Hash maintains detailed intercompany agreements that set out roles, responsibilities, and governance across Group entities.

Partner Prioritisation

Zero Hash may prioritise partners that are more commercially significant, creating a conflict of interest between Zero Hash, platform partners, and end users. Commercial arrangements may influence Zero Hash's neutrality and lead to disproportionate allocation of time and resources to certain partners. This could result in differentiated service levels or access to features, to the detriment of other platforms and their end users.

Control Measures

Zero Hash has the following control(s) in place to manage this risk:

• Platform Operators are required to notify Zero Hash of any changes to their customer onboarding programme.
• Zero Hash's Compliance leadership and teams hold regular meetings with relevant business and product functions to ensure compliance is integrated into product development and rollout, and to maintain awareness of relevant product considerations. The Compliance function also designs and implements specific controls to address unique risks associated with particular products, customers, or other factors.

Acting as Agent and Liquidity Provider

Zero Hash Group entities may, from time to time, act as both agent and liquidity provider in the same transaction. This dual role can create conflicts of interest: internally, over how obligations as an agent are prioritised against interests as a liquidity provider; and externally, between Zero Hash and end customers. In certain circumstances, prioritising one role over the other could disadvantage other Group entities or result in outcomes—such as pricing or execution—that are not aligned with customers' best interests.

Control Measures

Zero Hash has the following control(s) in place to manage this risk:

• Zero Hash maintains detailed agreements between Group entities that prescribe how we operate when acting as agent and/or liquidity provider. These agreements set clear roles and responsibilities, segregation of duties, order‑handling standards, pricing and quoting methodologies, and escalation routes for potential conflicts.
• An independent Trade Surveillance Manager and team monitor trading activity on a real‑time and post‑trade basis to detect issues such as self‑preferencing, unfair pricing, or improper handling of client orders. The team can escalate to Compliance and require remedial action where needed.
• Zero Hash's Internal Audit function conducts periodic reviews of dual‑role activity to assess adherence to policies, controls, and governance, and to verify that identified issues are remediated in a timely manner.
• Zero Hash performs regular spot checks comparing client executions against independent market data and benchmarks (for example, prevailing prices, spreads, and slippage) to evaluate execution quality and identify any anomalies.
• All transaction fees payable to Zero Hash are recorded and subject to ongoing monitoring by senior leadership and Compliance to identify outliers or changes that could indicate a conflict of interest or disadvantage customers.

Commingling of Funds

In some cases, assets belonging to end customers and to affiliated Zero Hash entities are held together in omnibus wallets. This commingling may create a conflict of interest. For example, if an affiliate were to withdraw all or a significant portion of the assets from an omnibus wallet, whether based on group-level information or otherwise, this could reduce the assets available to settle transactions and may adversely affect Zero Hash's ability to meet its obligations to customers.

Control Measures

Zero Hash has the following control(s) in place to manage this risk:

• Any affiliated Zero Hash entity withdrawal that would bring balances outside policy parameters requires prior approval by the Zero Hash Europe board. This ensures that adequate balances are maintained for the total custodied balance for the affiliate and the balance of any supported asset held for the affiliate.

Handling Unavoidable Conflicts of Interest

If there is a conflict of interest between Zero Hash and (one of its) customers, Zero Hash discloses that conflict of interest to the customer if Zero Hash determines that it cannot effectively reduce the risks of damage to the customer's interests through mitigating measures.