CONFLICTS OF INTEREST DISCLOSURE

22.05.2026

BlockDev AD applies a Policy for the identification, prevention, management, and disclosure of conflicts of interest. The Company implements organizational, administrative, and control measures to ensure that conflicts of interest are identified, assessed, and managed in a manner that protects the interests of clients and ensures the honest, fair, and professional provision of services.

Conflicts of interest may arise between BlockDev AD and its clients, between different clients, and in connection with shareholders, members of the Board of Directors, employees, persons performing key functions, external contractors, payment/EMI partners, liquidity providers, wallet/custody infrastructure providers, technology providers, consultants, or other counterparties.

Potential conflicts of interest may arise, inter alia, where one person performs more than one function at the same time, in connection with external professional, or management engagements, family relationships, or close personal relationships between persons holding management, or key functions, the selection, and oversight of external providers, remuneration, or incentives, personal transactions in crypto-assets, and access to confidential, client, commercial, transactional, or other sensitive information.

BlockDev AD manages these risks through a clear allocation of functions and responsibilities, segregation between business functions and control functions, the independence of the regulatory compliance/AML/CFT function, internal escalation, a conflicts of interest register, restrictions on participation in decision-making where a conflict exists, controls over access to information, rules on gifts and incentives, rules on personal transactions in crypto-assets, controls over external providers, and periodic review of the applicable internal rules.

Where the organizational and administrative measures are not sufficient to ensure, with reasonable confidence, that the risk of damage to the client’s interests has been prevented, BlockDev AD will provide the affected client with additional information regarding the general nature and source of the specific conflict, the risk to the client, and the measures taken to mitigate that risk, before providing the relevant service.

Disclosure of a conflict of interest does not replace the Company’s obligation to prevent and manage conflicts through effective internal measures. Where a conflict cannot be effectively managed, or where the risk to the client remains unacceptable, BlockDev AD may refuse to provide the relevant service, or may terminate the relevant activity, to the extent necessary to protect the client and to comply with the applicable requirements.

This disclosure is kept up to date, and is reviewed periodically, as well as upon any material change in the business model, services, organizational structure, partnership model, external providers, or applicable regulatory framework.