As an authorised crypto-asset service provider under the Markets in Crypto-Assets Regulation (MiCA), WEB3 Technology B.V. is required to identify and mitigate conflicts of interest that may cause harm to its customers.The following passages outline the general nature of WEB3 Technology B.V.’s conflicts of interest and the efforts undertaken to prevent potential customer harm. Where we cannot fully mitigate a conflict, we are required to disclose it here on our website.
How Conflicts of Interest Can Occur
As a general matter, conflicts of interest may arise between the following parties:
- WEB3 Technology B.V. and its shareholders or members,
- WEB3 Technology B.V. and persons directly or indirectly linked to the company or its shareholders/members by control,
- Board members,
- Employees and contractors,
- Customers,
collectively referred to as Connected Persons.
Connected Persons are required to recognize potential conflicts of interest and promptly report any actual or potential conflicts to our Compliance Officer. Appropriate measures are then applied to prevent or mitigate adverse effects on customers or the company.
How Conflicts of Interest May Arise
Conflicts of interest may occur when a Connected Person:
- Could gain financially or otherwise benefit at the expense of a customer or the company;
- Has an interest in the outcome of a service or transaction that differs from a customer’s interest;
- Holds responsibilities, relationships, or external activities that interfere with their duties;
- Engages in activities that compete with the company or its customers;
- Receives inducements, benefits, or gifts from third parties that could influence decision-making.
Examples of Conflicts
Potential conflicts may include situations where:
- A Connected Person could favor one customer over another;
- Personal or professional relationships create competing interests;
- Dual roles or supervisory responsibilities could influence impartial decision-making;
- Ancillary activities, personal transactions, or external positions interfere with responsibilities to the company or customers.
Measures to Prevent and Manage Conflicts
Connected Persons may not accept gifts, payments, or other benefits that could influence their judgment or create the appearance of a conflict. Any gifts received are considered carefully to ensure independence and fairness in customer interactions.
Dual Roles and Oversight
Where Connected Persons have multiple responsibilities, or supervise activities that could create conflicting interests, measures are in place to maintain impartiality and prevent any undue influence on decisions.
Ancillary Activities
Connected Persons may engage in outside activities only if these do not interfere with their responsibilities to customers or create conflicts with the company’s interests.
Personal Transactions
Connected Persons are expected to avoid personal transactions that could create conflicts with their duties to customers or the company.
Remuneration
Remuneration policies are designed so that incentives do not conflict with customer interests. Compensation balances fixed and variable elements, considering both performance and adherence to principles of fair customer treatment.
Training and Awareness
All Connected Persons receive training and guidance to help them recognize and manage potential conflicts of interest, and to ensure that their decisions are objective and aligned with customer interests.
Monitoring and Updates
We maintain up-to-date records of all actual and potential conflicts of interest, including the services and activities involved and the measures taken to mitigate them.This disclosure is reviewed regularly and updated as necessary to ensure accuracy, effectiveness, and compliance with applicable regulations.
