Conflict of Interest Policy
Purpose and Scope
Northcrypto is committed to maintaining the highest standards of integrity, fairness, and transparency in its business activities. This Conflicts of Interest Policy is designed to identify, prevent, and manage any potential or actual conflicts of interest that may arise in the course of providing services to clients. The policy applies to all employees, board members, shareholders, and any other Connected Persons involved in the Northcrypto’s operations.
What is a Conflict of Interest?
A conflict of interest occurs when the interests of the Northcrypto, its employees, or Connected Persons may be inconsistent with or have the potential to interfere with the best interests of a client. Examples of conflicts of interest include:
- Employees benefiting personally from transactions made on behalf of clients.
- Favoring certain clients over others due to personal or financial relationships.
- Trading crypto-assets in a way that could disadvantage clients.
- Receiving gifts or incentives from third parties that may influence decision-making.
How Northcrypto Identifies and Prevents Conflicts of Interest
Northcrypto takes a proactive approach to identifying and mitigating conflicts of interest. The following measures are in place:
- Internal Controls: Northcrypto implements clear internal governance structures to separate business functions where necessary.
- Disclosure Requirements: Employees and Connected Persons must disclose financial interests, personal relationships, and any external engagements that could give rise to a conflict.
- Restricted Transactions: Employees are subject to restrictions on personal trading activities to ensure they do not exploit inside information.
- Fair Treatment of Clients: Northcrypto ensures equal access to services, fair pricing, and unbiased decision-making processes.
- Training and Awareness: Regular training sessions are conducted to help employees recognize and appropriately manage conflicts of interest.
Managing and Resolving Conflicts of Interest
If a conflict of interest is identified, Northcrypto takes one or more of the following steps to resolve it:
- Avoidance: Where feasible, Northcrypto may restructure processes to eliminate the conflict.
- Disclosure: If avoidance is not possible, clients will be informed of any potential conflict so they can make an informed decision.
- Monitoring: Ongoing oversight is conducted to ensure conflicts of interest do not compromise the integrity of the Northcrypto’s services.
Client Rights and Information
Clients have the right to receive fair treatment and transparent service. Northcrypto is committed to resolving any concerns related to conflicts of interest. If you suspect a conflict of interest in your interactions with the Northcrypto, you may report it to our compliance team.
Updates and Accessibility
This policy is reviewed regularly to ensure it remains effective and in line with regulatory requirements. The latest version of the Conflicts of Interest Policy is always available on our website.