This conflict of Interest Management Policy has been established to appropriately manage transactions that may cause a Conflict of Interest between customers and the Company or its stakeholders (this policy refers to our parent company and their employees, and the company’s employees), to prevent Interest of customers from unfair interest impairments.
1. Interest of Conflict Transaction
According to the Cabinet Office Ordinance No. 23-2-3 regarding Crypto Assets Exchange Businesses, the Interest of Conflict Transaction is defined as a transaction conducted by the Company to prevent the customers’ interest from being unfairly jeopardized in the Crypto Asset Exchange business.
2. Designated Method and Transaction subject of Interest of Conflict Management
The Company defines the above-mentioned provision no.1 「Interest of Conflict Transaction」shall be a transaction a subject to Interest of Conflict Management, and to specify them, the Company shall consider the following factors.
- In case the customer has a reasonable expectation that prioritizes the customers own interests
- In case there is a possibility to gain an economic benefit or to avoid economic loss at the customer’s own expense.
- In case the customer’s acquired interest is clearly distinguishable from the Company’s interest as a result of a transaction with the customer.
- In case of prioritizing economic motives etc. of other customers more than the concerned customer’s interest.
- In case of any inducement other than the general handling fee or costs, such as in the forms of money, property, or services, are gained or that will be received in the future relating to other transactions with non-customers.
Furthermore, to deem something falling under Interest of Conflict, the Company will take the composite and the circumstances of a matter into consideration, and consider if it has any effect on the Company’s reputation.
3. Types of Interest of Conflict
A Subject transaction may or may not qualify as a subject transaction depending on individual specific circumstances; for example, the following transactions may qualify as subject transactions
| Type | Customer and Company | The customer and our other Customers |
|---|---|---|
| Interest of Conflict Type | Interest of Conflict between Customer and Company | Transaction in which there is a conflict of interest between a customer and another customer of the Company |
| Competition Transaction | Transaction in which the customer and Company are competing | Transaction in which the Company’s customer and another customer are competing |
| Information Usage Type | Transaction in which the Company gaining interest from transactions by using acquired information of a customer through their connection. | Transaction in which the Company uses acquired information of a customer through their connection to earn interest for another customer of the Company. |
４. Interest of Conflict Management System
Along with assigning an Interest of Conflict Management Supervisor to oversee the maintenance and operation of the Interest of Conflict Management system, the Company shall establish an independent Interest of Conflict Management Control division that will identify and manage all the transactions in a unified manner. As a Subject Transaction Management Method, the Interest of Conflict will be managed in a step-wise combining the following methods with other selected appropriate measures.
Moreover, training and education will be implemented to exercise appropriate management. The Company will ensure all employees are aware of the importance of wallet services that store and manage crypto assets (cryptocurrencies) and other assets safely and securely, as well as trading and exchange providence services for Assets and other uniques assets.
- Information Blockade between departments by establishing Information Barriers
- Changes in either or both terms and conditions or measures of transaction with a customer whose interests may be impaired due to Interest of Conflict transaction (will be referred to as “concerned customer” in the next article )
- Cancellation of a transaction relating to Interest of Conflict or of a transaction with a concerned customer
- Disclosure of Interest of Conflict to the customer
- Other methods