Disclosure Conflict of Interests

CJ Digital EU B.V. (“Clear Junction”) has an internal Conflict of Interests Policy and conjuncting policies and procedures designed to manage any potential conflicts of interest between our business activities and our responsibilities to our Clients and to third-party business relationships including commercial relationships with vendors, exchanges, payment platforms, technology providers, or other counterparties in the digital asset and payments markets. If such relationships pose a conflict of interest, Clear Junction will identify, manage, and disclose it in line with applicable requirements. All Clear Junction employees are continuously trained, stimulated and expected to act with the highest standards of integrity to avoid any allegations of conflicts of interests.

Management of (potential) conflicts

Clear Junction systematically considers situations where the interests of Clear Junction or of any natural or legal person with whom Clear Junction has engaged, may be detrimental to Clients or Clear Junction. To this end, when onboarding new Clients or when engaging with third-party service providers or engaging new employees, Clear Junction conducts in-depth, risk-based due diligence to early-identify potential conflicts of interests. If such potential conflict existed, the staff responsible for onboarding or employee engagement would report potential conflicts to the entrusted Responsible Officer at Clear Junction, the line manager or relevant member of senior management, in accordance with the Clear Junction Code of Conduct..

The entrusted Responsible Officer at Clear Junction (c.q. the Head of Human Resources) is responsible for the identification, investigation, assessment, prevention, appropriate management and possible external disclosure of conflict of interests. She considers the necessary authority to discharge Clear Junction’s responsibilities appropriately and independently. The Responsible Officer may escalate matters directly to the Board, ensuring independence and transparency.

Clear Junction ensures the adequacy of staff in early signalling and the management of (potential) conflicts through policy adherence and in addition bespoke training and discussion of use cases / examples at annually recurrent, mandatory training and ad-hoc training on the prevailing policies and procedures and on its code of conduct.

Chinese Walls to prevent unauthorised information flows, complemented with an effective system of internal controls, a staff remuneration that avoids possible conflicts, and a Disciplinary Policy and Procedure further prevents Clear Junction’s staff from possible misconduct when observing potential conflicts of interest.

Realistic Examples and Use Cases of Conflict of Interests

(non-exhaustive Disclosure)

Sources of conflicts of interest	Description	Associated Risks	Mitigating measures
Financial Gains, Losses or Other Interest.	Might arise when the Connected Person (natural or legal person with whom Clear Junction has engaged) is likely to make a financial gain, or avoid a financial loss, at the expense of the Client or has an interest in the outcome of a service provided to the Client or of a transaction carried out on behalf of the Client, which is distinct from the Client’s interest in that outcome, or has a financial or other incentive to favour the interest of one Client over the interests of another Client.	The poor management and/or disclosure of such conflict would severely harm the reputation of Clear Junction as well as the confidence of its Clients and third parties in the integrity of the financial markets. Besides that, Clear Junction would incur the risks of legal claims by Clients or third party business relationships and of financial losses. Next, Clear Junction might become subject to regulatory sanctioning including but not limited to fines.	Clear Junction and each employee, manager, and director has adopted an internal Code of Conduct that provides clear guidance on how to manage such situations. They must immediately disclose a situation to the Senior Management who, in conjunction with the Responsible Officer, will then review the situation to determine if it poses a real Conflict of Interest. Moreover, it has adopted a Remuneration Policy that excludes any incentive to benefit from conflicts of interest.
Outside Financial Interest	Might arise when the Connected Person has a financial interest in the Client or third party business relationship. The above restriction does not apply in cases where the Connected Person or the Connected Person has holdings of publicly quoted securities.	Financial interests in the Client or in a third party business relationship may impair the objectivity of the Connected Person concerned and may as such harm the interests of other Clients and of Clear Junction. Moreover, it could severely harm the reputation of Clear Junction as well as the confidence of its Clients in the integrity of the financial markets.	By virtue of the prevailing internal policies and procedures and Code of Conduct the Connected Person must immediately disclose such interest to the Senior Management who, in consultation with the Responsible Officer, will then review the situation to determine if it poses a conflict of interest. If required, appropriate measures will be taken to eliminate such conflict and be disclosed to the Client or the third party business relationship.
Other Business Interest or Employment	The Connected Person engages in other (part-time) employment or with other business activity outside ClearJunction.	In the other business or employment the Connected Person may be (un-)intentionally associated with Clear Junction, with possible reputational exposure by Clear Junction. Depending on the nature of the other business or employment, the Connected Person may be exposed to commercial conflicts of interest at the expense of Clear Junction, its Clients, or third party business relationships.. Such other business or employment may deprive Clear Junction and its Clients of the Connected Person’s best effort on the job and harm or cause actual damage to the interests of the Client with possible financial claims and reputational damage for Clear Junction.	By virtue of the prevailing policies and procedures and the Code of Conduct, the Connected Person is required to discuss other engagements with the Responsible Officer, first. The approval of Clear Junction’s Board must be obtained before the Connected Person embarks on such engagement. Approval is granted only where the interest of Clear Junction is not prejudiced and where there is no potential conflict of interest.
Inducements, Entertainment & Gifts	Receiving of monies, goods or services, other than the standard commission or fee, including gifts can affect or be seen to affect business judgment hence giving rise to the Conflict of Interest.	Acceptance or provision of gifts and hospitality may create expectations about future compensation and distinct,unequal treatment of Clients or third party business relationships and harm the interests of other Clients, third Parties and/ or Clear Junction which would harm the reputation of Clear Junction.	By virtue of the prevailing internal policies and procedures and the Code of Conduct the acceptance or provision of gifts and hospitality is subject to strict pre-conditions and mandatory reporting to exclude potential future conflicts of interest. Gifts and Hospitalities are recorded in a designated Register.
Credit Facilities or other transactions	Derive any improper benefits by Connected Persons, their relatives or affiliated companies, either in kind or in monetary at the expense of Clear Junction or its Clients. The Connected Persons also must not obtain for themselves or any of their family members any property or any business advantage that properly belongs to Clear Junction or to its Clients.	Deriving such benefits harms the net income and interest of Clear Junction or Clients with severe impact on Clear Junctions’s reputation. Obtaining any such property business advantages may create expectations about future compensation and distinct, unequal treatment of Clients or third party business relationships and harm the interests of other Clients, other third parties and / or Clear Junction.	By virtue of the prevailing internal policies and procedures and the Code of Conduct the Connected Person is only under strict conditions allowed to derive aforementioned benefits or to obtain property or business advantage that belongs to Clear Junction, its Clients or its third party business relationships.
Personal Directorships	Connected Persons engaging in directorships at other legal entities.	In the case the legal entity were a competitor of Clear Junction Clear Junction might incur the risk that the other legal entity is favoured or confidential information of Clear Junction is shared at the expense of Clear Junction, its Clients or its third party business relationships. This would expose Clear Junction to commercial, reputational and regulatory risks and harm the public trust in the financial markets.	By virtue of the prevailing internal policies and procedures and the Code of Conduct the Connected Persons must not solicit personal directorships in another company without the prior approval of the Board. Note: A member of the Company Board of Clear Junction will never be allowed a directorship of the Dutch foundation, Stichting Derdengelden Clear Junction EU Custody which purpose it to safeguard Client assets and segregate these assets from the assets of Clear Junction.
Engagement and Contractual Integrity	Connected Persons engaging in or influencing the signing-up of services or products from any person with which economic or familial relationships exist.	Such involvement by Connected Persons may cause personal biases and decisions that are not in the best interest of Clear Junction or that are in conflict with Clear Junction’s ethical standards which would expose Clear Junction to financial risks, operational excellence / business risks and the risk of corporate values / culture detriment.	By virtue of the prevailing policies and procedures and Code of Conduct, Connected Persons shall not engage in or influence the signing-up of services or products from any person where a conflict due to economic or familial relationships exists. This guideline ensures that all decisions are made in the best interest of Clear Junction, devoid of personal bias, and in strict adherence to ethical standards.
Objectivity in Personnel Decisions	Influencing hiring, promotion, or appraisals that involve individuals with whom Connected Persons share personal or familial relationships.	Such favouring of personal and familial relationships would hurt staff, be detrimental to the corporate values / culture, impact the service levels, and risk demotion and resignation by qualified staff, at the expense of Clear Junction’s operational excellence and of its Clients. It would expose Clear Junction to business risks and the risk of corporate values / culture detriment.	By virtue of the prevailing internal policies and procedures and the Recruitment Policy & Procedure, to maintain the integrity and objectivity of Clear Junction’s operational decisions, Connected Persons are expressly prohibited from influencing hiring, promotion, or appraisal processes that involve individuals with whom they share personal or familial relationships. This rule ensures that such decisions are based solely on professional merit and the strategic needs of the organisation.
Fiduciary Duties and Authorisation	Partial execution of duties towards Clear Junction and its Clients due to fiduciary roles, mandates, or powers of attorneys that the Connected person agreed with persons outside Clear Junction Group.	A partial execution of duties would risk a negative impact on the quality of services provided, result in dissatisfaction of Clients, and substantial damage of staff motivation and Clear Junction’s reputation in the market. This would expose Clear Junction to business and reputational risks.	By virtue of prevailing internal policies and procedures and the Code of Conduct, Connected Persons must not accept fiduciary roles, mandates, or powers of attorney from Connected Persons outside the Group without obtaining explicit prior authorisation from the Responsible Officer and Senior Management.

Regular Review of the Policy and Disclosures

Clear Junction will review and update its Conflict of Interests Policy and conjuncting policies and procedures at least annually, immediately in case of material deficiencies and on an event-driven basis in case there are significant changes in our service offerings, the regulatory environment, or relevant market practices.

Following an update of the Conflicts of Interest Policy, Clear Junction will update its disclosures, notify its Clients and make the updated disclosures available for its Clients on the website. At request, Clear Junction will provide hard and soft copies of its Conflicts of Interest Policy to its Clients.