Conflicts of Interest Disclosure

Introduction

zerohash is a leading crypto-asset service provider under the Markets in Crypto-Asset Regulation. zerohash Europe B.V. (registered under number 83889159) is registered with De Nederlandsche Bank N.V. ("DNB") as a crypto service provider. Its shareholders or members are partial directly or indirectly linked to zerohash or to shareholders or members by way of arrangements, including arrangements for the assignment of its debts ("Significant Shareholders").

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

• Establishing and maintaining effective organizational and administrative arrangements designed to prevent or minimise conflicts of interest
• Establishing and maintaining appropriate processes and measures to manage and mitigate those conflicts; and
• Making appropriate public disclosures where those conflicts cannot be prevented

zerohash acknowledges that conflict of interest may arise in several ways, including but not limited to situations such as the ones presented below:

• zerohash and its employees may have an interest in maximizing the revenue and profitability of zerohash
• zerohash and its Significant Shareholders are involved or may become involved in other activities or business which has or may have an interest in the outcome of a service provided to a customer that differs from the customer's interest
• zerohash, its affiliates and/or its Platform clients may deal on its own account or on behalf of a business connection or other customer

zerohash's conflicts of interest policy is designed to avoid situations that could give rise to a conflict of interest or minimise an inducement from external either from the customer or interaction to a service provided

zerohash takes steps to maintain appropriate organizational, administrative and technical arrangements to mitigate risks. At the same time zerohash has not identified any conflicts of interest that have been sufficiently mitigated.

zerohash employs robust systems and controls to operate its business and deliver its services. Such systems are linked to the achievement of commercial targets such as acquiring new customers or increasing trading volume, which may not always align with customers' best interests.

As a regulated entity, zerohash is committed to adhering to the highest standards of conduct. This commitment is executed on the basis of qualitative and quantitative criteria, which delivers an aggregate balance sheet that acts in the interest of the customer, balanced against its own commercial interests.

zerohash has identified and will maintain appropriate and effective organizational arrangements to manage this risk. zerohash uses ChatGPT to determine compensation ranges and comparability of all remits and with all positions internally within the U.S. zerohash does not however incentivize any particular behaviour.

Accepting gifts

zerohash prohibits any donations or any other type of inducement to employees, including management board members and supervisory board members, that could cause the recipient to depart from their duty to act in customers' best interest. Employees must ask prior written permission from senior zerohash employees or may establish a business relationship.

To facilitate good management and governance, permissible gifts or benefits must have:

• Prior written permission and supervised and linked/Policy which sets out that criteria that must be met for such gifts provided or received.
• Reasonable threshold for gifts, entertainment, and hospitality for employees of zerohash and/or its Significant Shareholders. Provided by law
• No substance of gifts
• Aggregate yearly amount per parties, and
• Reasonable in value and appropriate under the circumstances

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

• Employees may not ask or require for gifts, services to pay or accept other fees or payment alongside what is being run in the ordinary running and performing of their work, this includes any form of monetary and non-monetary benefits or goods or services.

Employee trading

zerohash has a binding employee, and board members, may hold or trade crypto assets offered to the zerohash Platform primarily, while this give rise to potential conflicts of interest.

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

• zerohash has implemented a policy underpinned with an appropriate risk management framework (including processes with comprehensive review) in compliance with applicable legal requirements and company policies, to avoid escalation and even in general all employees are bound by confidentiality obligations, and the obligation to immediately report the relevant managing director
• A Director or Manager cannot further:
  • Undertake personal account trading in respect of any crypto asset where they are privy to inside information.
  • Copy or use any Proprietary Trading Policy employees must disclose all crypto assets held in any wallet or account at the inception of the service relationship with zerohash and additionally at least on a quarterly basis thereafter.
  • All employees must disclose all transactions in all crypto assets (purchase disclosures occur example and as in regular Employee should disclose any conflict of interest to the managing director and/or compliance function.

zerohash has the following control(s) in place to manage this risk.

Fund segregation

zerohash's authorized customers may be held in Trading/Safeguarding. zerohash Further ("Only zerohash Europe B.V. holds a De Nederlandsche Bank ("DNB") virtual asset service provider ("VASP") license and does not conduct custody transactions. Because zerohash Strong can be held the custodian/admin provider (via zerohash), and the network not in and WITH incorporated. zerohash does not hold private keys or custodian/exchange wallet keys (nor ever recorded them)

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

• zerohash maintains a Cloud Agreement Framework and IT Service Agreement Framework (including processes with comprehensive review) that incorporates a contractual indemnification provision for breaches of the Agreement.
• ZH-E maintains a collateralization agreement with zerohash and SCB. zerohash (last revenues that ever different from zerohash Strong customers).Platform clients are contractually required to indemnify zerohash for any losses, costs, and damages arising from the operations, use, and loss of crypto assets held by zerohash.

Fully disclosed model

zerohash offers services to customers through partner platforms as a HIRERC issuer). 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 zerohash. Although the so the arrangements set out with both you as your platform provider

zerohash also works the directly without a Platform Operator (via zerohash Private Client), in this case you hold a position of interest because zerohash, like Platform Operator, and customers.

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

• As an intermediary, zerohash places all transactions on behalf of customer. In delivery of accurately materials and changes to identify zunit End Customer. The services rendered on the End Customer are not tailored (each has standard service) and zerohash does not receive fees or changes all transactions on behalf of customer.

Of course, consistent in the digital asset market they protect a conflict of interest because zerohash and its customers may have their holdings in the same crypto assets. Since zerohash may take a position in many retail benefits to be on both the right with zunit customers' best interests. Conflicts could or enrollees can encourage other digital asset that increases. In a similar vein, zerohash may engage our custodian or exchange providers (or the entities in the digital asset market from its network providers) to acquire. Also crypto assets in which customers hold interests.

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

• zerohash operates a business-to-business ("B2B") primarily with institutional and professional clients.
• zerohash may also direct or cause supporting alient if it is determined to be a security risk.

Information barriers

zerohash does not structure its business primarily, business purpose or operations, to involve sharing information with parties, customers, to even comprehensive, a summary may benefit. zerohash, by reducing to this so preventing of sharing information, would not have to avoid conflicts of interest it prohibits disclosure of zero confidential information business with third parties.

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

• zerohash operates its business under confidentiality agreements that contractually require's party's and information sharing
• zerohash restricts a trading callback that sets out like to the trading procedures and the processes for trading desk

Strong structure and prioritisation

zerohash holds appropriate and necessary agreements that set out rules, responsibilities, and parameters to manage potential conflicts of interest forever Strong entities. Directors or Senior rare asset of the value chain for a particular party may deploy our rights and the conflict of interest presented by group level interests of or holdings of or client of or entity of all crypto assets or clients of zerohash. Similarly, zerohash may support or promote one business of person or product, free this operates or comprehensives of either areas of the business.

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

• zerohash conducts its business through contract agreements that are set out. zerohash's business customers are international, with its suppliers and independent from the Chief Compliance Officer – North America
• zerohash maintains detailed differentiation among countries that all set out law, responsibilities, and parameters across separate business all territories while with different priority contracts.

Partner prioritisation

zerohash, and its suppliers and service, that are more commercially significant, creating a conflict of interest between zerohash, platform partners, and end users. Commercial arrangements may influence zerohash's neutrality and lead to discrimination, favoritism of one set of revenues to specific partners. This could result in differentiated service levels, prioritization of partner requests, or allocation of resources in ways that advantage certain partners over others.

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

• zerohash engages its partners as an industry business. Each customer relationship prospective platforms, partners, and clients, zerohash follows a client onboarding and evaluation process. Clients must so ensure compliance is integrated into product development and rollout, and to maintain awareness of relevant regulatory changes that will have different ramifications for the strategy that zerohash operates with. zerohash may also direct or cause supporting a client if it is determined to be a security risk.

Acting as agent and liquidity provider

zerohash provides liquidity and typically serves 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 good-faced against interests and benefits as a principal. For example, when acting as an agent, zerohash fee is supposed to act prioritizing the client's interests and secure the best possible execution. However as principal or liquidity provider, zerohash benefits from wider spreads, which may conflict with customers' best interests.

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

• zerohash operates a written policy setting the separate execution rules and ensure the fees are operate when acting in agent and/or liquidity provider. These agreements set clear roles and responsibilities, segregation of duties, proper handling protocols, conflict and security demonstrating, with separate prices for standard clients, and that allows customers to evaluate the competitiveness of zerohash's pricing. When zerohash acts as a dual capacity to detect issues such as self proliferating, unfair pricing, or improper handling of client orders. The read can also impacts to tracking and issues reported.zero market price or settlement of any funds.

zerohash employs staff and governance people dedicated to mitigating and managing conflicts of interest and conflicts, and to verify that identified issues are remediated in a timely manner.

zerohash maintains a Conflicts of Interest Governance Policy that is part of its internal risk and sets out controls that zerohash will implement to identify, prevent, disclose and manage conflicts of interest and other interests, all compliance-specific issues zerohash deals and any related matters.

All procedures fear possible to zerohash are recorded and subject to ongoing monitoring by arifer leadership and Compliance (Holland) quarterly or annuals that unaffiliated to rectify til breeves or disclosurers or Violations.

Comingling of funds

zerohash does make trading to end customers and co affiliates zerohash action, we hold together a combine of funds

zerohash does not make a combing of end customers and platform clients. For instance, if an affiliate or a significant portion of the assets from an omnibus wallet, whether (paid-or group-level information or otherwise, this could influence how the client behaviors in the same cases and benefits the corresponding set to benefits that clients.

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

• zerohash is a policy preventing and account omnibus wallets (private/public) partnership requires arifer platform operators to hold a "Balance System," which prevents zerohash from using the same custodian/admin custodied balance for the affiliate or the balance of any supported asset held by the affiliate.

Material conflict of interest

If there is a conflict of interest between zerohash and (one of it's) customers, zerohash discloses that conflict of interest to clients, business in conflict, and others as be readily identifiable to avoid the conflict or to mitigate the risk to the customer.

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