EU Internet Ventures B.V. (“EUIV”), Banxa’s European entity, is obliged to implement and maintain effective policies and procedures to identify, prevent, manage and disclose conflicts of interest. Through this disclosure, EUIV aims to inform you on the general nature and sources of conflicts of interest that have arisen or might arise, and the steps that EUIV has taken to mitigate these conflicts of interest.
General nature and sources of conflicts of interest
EUIV has identified two categories of potential conflicts of interest:
- Conflicts of interest potentially detrimental to clients of EUIV; and
- Conflicts of interest potentially detrimental to EUIV.
Conflicts of interest that are potentially detrimental to clients may arise when EUIV or EUIV shareholders or members, any person directly or indirectly linked to EUIV or EUIV’s shareholders or members by control, EUIV’s board members or EUIV’s employees (the Connected Persons) are in any of the following situations:
- EUIV or the Connected Person is likely to make a financial gain, avoid a financial loss, or receive another kind of benefit, at the expense of the client;
- EUIV or the Connected Person has an interest in the outcome of a crypto-asset service provided to a client of EUIV or of a transaction carried out on behalf of that client, which is distinct from that client’s interest in that outcome;
- EUIV or the Connected Person has a financial or other incentive to favour the interest of one or more clients of EUIV over the interest of another client of EUIV;
- EUIV or the Connected Person carries on the same business as the client of EUIV; or
- EUIV or the Connected Person receives or will receive from a person other than the client of EUIV an inducement in relation to a service provided to that client, in the form of monetary or non-monetary benefits or services.
Conflicts of interest that are potentially detrimental to EUIV may arise when a Connected Person:
- has an economic interest in a person, body or entity with interests conflicting with those of EUIV;
- has a personal relationship with a person, body or entity with interests conflicting with those of EUIV;
- has or has had a professional relationship with a person, body or entity with interests conflicting with those of EUIV;
- has a political relationship with a person, body or entity with interests conflicting with those of EUIV; or
- carries out conflicting tasks, is entrusted with conflicting responsibilities or is hierarchically supervised by someone who is in charge of conflicting functions or tasks.
Steps that EUIV has taken to mitigate these (potential) conflicts of interest
EUIV has implemented various measures to prevent the conflicts of interest set out above from arising:
- Through training, EUIV continuously ensures that Connected Persons are aware of the risks of conflicts of interest and the measures taken by EUIV to prevent them from arising.
- EUIV has implemented various strict policies and procedures that aim to prevent conflicts of interests from arising. These policies and procedures govern the following subjects:
- Remuneration
- Personal transactions
- Acceptance of gifts
- Promotion campaigns
- Commissions
- Ancillary activities
- Additionally, EUIV has implemented various measures in its internal governance to prevent conflicts of interest from arising within its organization and within the Banxa group.
Evaluation and updates
EUIV maintains up-to-date records of all situations giving rise to actual and potential conflicts of interests and of the measures taken to mitigate such conflicts. This disclosure is regularly updated on the basis of those records, and evaluated annually for its accuracy, effectiveness and compliance with applicable regulations, addressing any deficiencies in that respect.