Disclosure of conflicts of interest
22.05.2026
BlockDev AD implements a Policy for the identification, prevention, management and disclosure of conflicts ofinterest. The company takes organizational, administrative and control measures to ensure that conflicts of interestare identified, assessed and managed in a manner that protects the interests of clients and ensures honest, fair andprofessional provision of services.
Conflicts of interest may arise between BlockDev AD and its clients, between different clients, as well as in relationto shareholders, members of the Board of Directors, employees, key functionaries, external contractors,payment/EMI partners, liquidity providers, wallet/custody infrastructure providers, technology providers, consultantsor other counterparties.
Potential conflicts of interest may arise, inter alia, when more than one function is performed simultaneously by oneperson, in external professional or management engagements, in family or close personal relationships betweenpersons with management or key functions, in the selection and control of external suppliers, in remuneration orincentives, in personal transactions with crypto assets, as well as in access to confidential, client, commercial,transactional or other sensitive information.
BlockDev AD manages these risks through a clear allocation of functions and responsibilities, separation
between business and control functions, independence of the compliance/AML/CFT function, internal escalation, a registerof conflicts of interest, restrictions on participation in decisions in the presence of a conflict, control over access toinformation, rules on gifts and incentives, rules for personal transactions with crypto assets, control over external
providers and a periodic review of applicable internal rules.
When the organizational and administrative measures are not sufficient to ensure with reasonable confidence that the riskof harm to the client's interests is prevented, BlockDev AD will provide the affected client with additional informationregarding the general nature and source of the specific conflict, the risk to the client and the measures taken to limit it,before providing the relevant service.
Disclosure of a conflict of interest does not replace the company's obligation to prevent and manage conflicts througheffective internal measures. Where a conflict cannot be managed effectively or where the risk to the client remainsunacceptable, BlockDev AD may refuse to provide the relevant service or terminate the relevant activity, to the extentnecessary to protect the client and comply with applicable requirements.
This disclosure is kept up to date and reviewed periodically, as well as in the event of a material change in the businessmodel, services, organizational structure, partnership model, external providers or the applicable regulatory framework.