Conflict of Interest Management Policy

This Conflict of Interest Management Policy (hereinafter referred to as the “Policy”) outlines the primary approaches adopted by Ellyx (hereinafter also referred to as the “Company”) for managing conflicts of interest that may arise within the Company, between the Company and its clients, or directly between the Company’s clients. The Policy is reviewed and updated as necessary to reflect changes in the Company’s operations, procedures, and to ensure compliance with current legal, technological, and market conditions. This Policy applies to all actions carried out by Ellyx and its employees, particularly those related to facilitating P2P exchange transactions.

1. Role of Ellyx as a Technical Provider

   Ellyx does not act as a principal in transactions with clients nor does it hedge its net risk with counterparties, as it operates as a technical provider for P2P exchange transactions involving cryptocurrencies. Since Ellyx does not provide advice regarding the purchase or sale of cryptocurrencies or other assets, the likelihood of conflicts of interest is minimized. The Company offers a technical platform and ensures secure P2P exchange processes through KYC and KYT verifications, which significantly reduce the risks of potential conflicts during cryptocurrency transactions.

2. Identification and Mitigation of Other Conflicts of Interest

   Ellyx is committed to identifying and mitigating other potential conflicts of interest that may arise during client interactions and pose significant risks to their interests. Specifically, the Company analyzes and considers possible conflicts that may occur during P2P exchange transactions conducted for clients.

3. Measures for Managing and Resolving Conflicts of Interest

   1. Ellyx processes all client requests electronically, adhering to internal policies that ensure compliance with applicable standards and regulations for executing P2P exchange orders. These procedures guarantee the timely, fair, and efficient execution of client requests. Comparable requests are processed sequentially in the order they are received.
   2. Ellyx follows a procedure to promptly and accurately register client orders, ensuring that similar orders are addressed in a consistent manner, except in cases where market conditions require alternative actions in the client’s best interest.
   3. In accordance with Company procedures, Ellyx employees and affiliates are prohibited from improperly using information related to pending client orders.
   4. All Ellyx employees are forbidden from conducting transactions on personal accounts to eliminate the possibility of actual or perceived conflicts of interest.

4. Commitment to Corporate Culture and Conflict Resolution

   Ellyx strives to foster an effective corporate culture that prioritizes compliance with legal requirements and provides mechanisms for resolving any potential conflicts of interest. Company employees are required to monitor new circumstances that may lead to conflicts and take necessary measures to address them.

5. Client Notification in Rare Cases

   In rare cases where established Company procedures cannot fully eliminate risks to the client, Ellyx commits to informing the client of the nature and source of potential conflicts of interest before proceeding with any transactions.

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