CONFLICT OF INTEREST POLICY – Arbitex

1. PURPOSE AND SCOPE

1.1. Purpose

This Conflict of Interest Policy has been established pursuant to Articles 11 and 12 of the Communiqué on the Establishment and Operating Principles of Crypto Asset Service Providers (III-35/B.1) and within the scope of the Personal Data Protection Law No. 6698 dated 24/3/2016, for the purpose of ensuring the confidentiality and security of customer information. Arbitex Kripto Varlık Alım Satım Platformu A.Ş. (the Company) commits to protecting the rights of its customers and observing the market order by adhering to the principles of honesty, transparency, and fairness while conducting its activities. In this direction, the Company has established a corporate framework and implemented the necessary strategies in order to identify, prevent, and manage conflicts of interest that may arise within its own structure or among customers.

This policy includes the measures that can be taken to ensure that the services offered by the Company are aligned with the interests of the customers, to determine potential conflicts of interest, and to prevent such situations. This policy, which determines the procedures to be followed in the face of conflicts of interest that cannot be prevented, is periodically reviewed in order to sustain its effectiveness and is updated when deemed necessary, thereby maintaining its current validity.

1.2. Responsibility

The Board of Directors is obliged to establish and update a policy appropriate for the size, organizational structure, and the services and activities offered by the company. This policy is responsible for identifying, preventing, and managing conflicts of interest that may occur between the company, its managers, employees, partners, and the customers, or among our customers. Company employees and related persons must comply with the rules regulated by this policy.

1.3. Definitions

Company: Arbitex Kripto Varlık Alım Satım Platformu A.Ş.
Policy: Conflict of Interest Policy
Conflict of Interest: The situation that arises when a personal interest occurs that affects or may affect the objective fulfillment of the Company's purpose and duties.

1.4. Potential Situations That May Lead to a Conflict of Interest

While offering investment services and activities to customers, our Company commits to protecting their interests and preventing potential conflicts of interest. Within this scope, by meticulously analyzing the relationships between the company itself, its partners, employees, managers, and the persons with whom it is in a direct or indirect relationship, it takes the following matters into consideration within the scope of conflicts of interest:

Situations where they will obtain a financial gain or avoid a financial loss to the detriment of the customer.
Those who are in a position to gain an interest from the service and activity offered to the customer, even though the customer has no such interest.
Situations where they will obtain an interest as a result of a customer or customer group being preferred over another customer or customer group.
Situations where they will obtain a financial gain from a person, institution, or application other than the customer due to the service and activity offered to the customer, apart from the standard fees and commissions.
Situations where they will obtain a financial gain by making it mandatory to use the distributed ledger network belonging to themselves or their affiliates for the crypto assets to be listed.

1.5. Examples of Conflict of Interest

In the services offered within the scope of intermediation activities for crypto asset trading, there is a possibility that customers may incur losses due to the nature of the transactions carried out as a counterparty. In order to minimize the conflicts of interest that such situations may lead to, customer orders are processed in accordance with the document and record system within the framework of the relevant legal legislation. All transactions are carried out in accordance with the principles specified in the framework agreements drawn up in a provable format, and the necessary care and diligence are shown during the processing of orders.

In order to increase the reliability of the services to be offered to customers, detailed risk disclosures are provided to customers before they trade. This information process is supported through contracts, order execution policies, risk disclosure forms, and other legal documents. Thanks to this process, customers are informed before carrying out transactions about the potential losses that may arise from the nature of the services subject to the activity. The Company aims to create business processes that will prevent potential conflicts of interest by providing clear and understandable information to customers regarding commissions, fees, and expenses related to transactions before commencing the transaction. At the same time, comprehensive information is provided regarding the types of crypto assets in which customers will carry out transactions, the relevant commission rates, and other expense items, ensuring that customers are informed about all processes.

Our Company adopts a fair approach in cases where conflicts of interest among customers cannot be prevented and guarantees to offer an impartial service. In accordance with the understanding of fair service, critical matters such as transaction sequencing and pricing are conducted in a transparent manner in order to ensure that each customer has equal opportunities.

The security and confidentiality of customer information obtained within the scope of intermediation services for crypto asset trading are adopted as a fundamental principle. Within this framework, information belonging to customers is used solely for the purpose of service presentation, and cannot be used in any way in favor of or against the institution or third parties. Our Company prioritizes the principles of honesty and transparency in the services offered to customers, and does not give place to misleading advertisements, notices, publications, promotions, and announcements. Except for cases permitted by the legislation, no guarantee or commitment against any absolute return or loss can be made. Furthermore, all comments and recommendations offered to customers are based on reliable sources in accordance with the principle of transparency, and it is essential to disclose the source of the relevant information.

1.6. Identification and Management of Conflicts of Interest

Our Company adopts appropriate structural measures to prevent and manage conflicts of interest, conducts comprehensive risk analyses on this matter, and develops continuously updated procedures. Strategies directed towards the detection, evaluation, and management of conflicts of interest are determined and announced to all employees, and these processes are supported by regular training sessions. In this direction:

6.1. The organizational structure of the Company and the decision-making processes of the employees are structured in a way to minimize conflicts of interest.
6.2. The duties and responsibilities of the employees have been clearly defined, put into writing, and transmitted to the relevant persons.
6.3. In cases where conflicts of interest are unavoidable, fair treatment is provided to customers in accordance with general practices in the market.
6.4. Transparent and effective procedures regarding the recording and evaluation of customer complaints have been established.
6.5. Within the scope of measures regarding the prevention or management of information flow within the crypto asset service provider or among the members of the group of companies, an Information Protection Policy has been established and announced to the personnel.
6.6. The supervision of the units subject to conflicts of interest and the employees in these units is carried out by the internal audit unit.
6.7. Market conditions are taken into consideration in the remuneration of employees working in units subject to conflicts of interest.
6.8. In order to ensure the detection and management of conflicts of interest, customer information, orders, instructions, and transactions are recorded using methods compliant with the legislation, and the retention of records is ensured.
6.9. It is ensured that the legal texts and contracts to which the Company is a party are prepared in a way that will not allow conflicts of interest and the abuse of confidential information.
6.10. In order to prevent the flow of information within the Company, the system access authorizations of the personnel are granted in line with the role templates created in accordance with the units they work in and their job definitions.
6.11. The Company Internal Audit is responsible for the implementation of the conflict of interest policy and related policies and procedures, as well as the supervision and auditing of the units subject to conflicts of interest and the employees in these units. Findings detected by Internal Audit are shared with the Board of Directors and senior management to ensure that necessary actions are taken. All Personnel are obliged to avoid situations that may cause conflicts of interest; to act in accordance with the "Conflict of Interest Policy" and other regulations, and to detect and manage potential conflict of interest cases pursuant to these policies. In the event that the personnel has any suspicion as to whether a situation is related to a conflict of interest or a potential or realized conflict of interest, they shall immediately report this incident to their manager and the internal audit unit, and provide information regarding all personal or professional relationships and financial transactions that may create a conflict of interest. Detected conflicts of interest are examined by the relevant managers and the Internal Control Unit for the purpose of evaluating the adequacy of the internal control system and the measures taken, recorded, and necessary measures are taken.

1.7. Customer Complaints

Customers may report the problems they encounter during service presentation to the company through written, verbal, or electronic communication channels. In the process of evaluating and concluding customer complaints, the company's "Customer Complaints Procedure" is applied. Regular reporting is made to the relevant units in order to ensure that complaints are handled in a transparent manner.