conflicts of interest
General nature of conflicts of Interest
Tradias GmbH (“tradias”) is a provider of crypto – asset services under the German Securities Institutions Act (Wertpapierinstitutsgesetz - WpIG) and the Markets in Crypto Asset Regulation (MiCAR), licensed by the German Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht). tradias’ main business is exchanging crypto-assets for funds and other crypto-assets according to section 3 para. 1 no. 16 lit. c) and d) and no. 19 and 20 MiCAR.
tradias is committed to lawful and ethical behavior in all business relationships. This includes the identification and mitigation of potential conflicts of interest which may arise when tradias is conducting its business operations.
A conflict of interest may arise if there are conflicting interests of different parties which may impair the impartial, objective and dutiful provision of services. This includes actual as well as potential conflicts of interest as well as perceived conflicts of interest where the impression of a conflict arises although none actually exists.
Conflicts of interest may arise between tradias (including its managing directors and employees), and its clients, between tradias and the companies affiliated to tradias as well as between different clients of tradias.
Sources of potential conflicts of Interest
tradias has identified the following potential conflicts of interest:
Customer related conflict of interest
• tradias may provide various services to different clients, which may involve conflicting interests.
• tradias may pursue new business strategies, launching new products or services or expand its service geographically or to new client groups which may lead to conflicts with the interests of its current clients.
• tradias may prioritize certain client/s over others, especially in the case of manual trading actions during high volatility or large OTC - transactions
• tradias may carry out adjustments to the execution logic which may lead to conflicts of interest if such actions unintentionally favor specific counterparties
• tradias may apply error handling and correction procedures, such as trade cancellations or rebookings, in a manner that could unintentionally favor particular clients if not applied consistently
Company related conflict of Interest
• An employee or managing director of tradias may use access to sensitive information for personal investments.
• tradias or an employee or managing director of tradias may have a financial or other interest which could impair its or his or her judgement or objectivity in the performance of its or his or her duties and responsibilities to Tradias and/or to tradias’ clients.
• An employees or managing director’s outside-activity may conflict with interests of tradias and/or its clients.
• An employee or managing director receives a remuneration which is solely linked to the sale of a certain crypto-asset related service.
Steps taken to mitigate the potential conflicts of interest
tradias has implemented the measures to mitigate the potential conflicts of interest, e.g.:
Staff awareness:
tradias has implemented an internal Conflict of Interest Policy. Tradias regularly informs all employees and managing directors on the principles and responsibilities arising from this Policy in mandatory training sessions.
Reporting process for Conflicts of Interest:
tradias employees and managing directors are obliged to report (potential) conflicts of interest to the Compliance Department. Tradias has also implemented a whistleblower system to allow employees and managing directors to report via a confidential channel to the internal reporting function.
Manual trading controls:
tradias has implemented pre-defined procedures and approval requirements for manual interventions in trading activities. All manual actions, including order prioritization are subject to post-trade reviews by tradias’ middle office function.
Execution oversight:
Manual adjustments to execution logic are subject to defined, standardized procedures and controls. These actions are logged in the relevant trading systems and are regularly reviewed.
Standardised error handling procedures:
tradias has established documented protocols for trade corrections and error handling. Manual corrections must be justified, approved, and are reviewed by tradias’ middle office function.
Rules for employee transactions:
tradias has implemented an internal policy on employee transactions. Employees and managing directors are obliged to disclose private transactions and to comply with certain approval requirements and holding periods.
Rules on inducements :
tradias has implemented an internal policy on inducements which sets out in particular the rules for receiving or granting gifts, hospitality and business entertainment. For certain inducements, the pre-approval of the Compliance Department is required. Tradias trains its employees and managing directors regularly on the rules and their responsibilities.
Rules on outside activities:
Employees and managing directors have to disclose their outside activities and seek prior approval from the Compliance Department.
Remuneration principles:
Tradias has implemented a remuneration policy designed to ensure that employees and managing directors act in the best interest of the clients. Remuneration and other awards are linked to long-term performance and penalize any form of misconduct.
