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Conflict Of Interest Policy

This policy is designed to guide our employees, contractors, agents, and representatives (“Personnel”) in identifying, managing, and disclosing situations that may give rise to conflicts of interest within the context of our virtual asset custody service operations. At First Answer Middle East Limited, we recognize the importance of maintaining the trust of our clients, partners, and stakeholders. A conflict of interest arises when an individual’s personal interests, relationships, or financial considerations may interfere with their ability to act in the best interests of the Company and its clients. This policy establishes a framework for understanding, preventing, and addressing conflicts of interest to ensure that all decisions and actions taken by our Personnel are aligned with the highest standards of integrity, transparency, and professionalism. By promoting awareness and providing clear guidelines, we aim to cultivate a culture of openness, ethical behavior, and accountability.

This policy is an essential component of our commitment to upholding the reputation and trustworthiness of First Answer Middle East Limited in the virtual asset custody service industry. All Personnel are expected to familiarize themselves with the content of this policy, actively participate in its implementation, and seek guidance when faced with situations that may pose a conflict of interest. Through collective diligence and ethical decision-making, we can maintain the integrity of our operations and further the success of First Answer Middle East Limited.
Conflicts of Interest
The Firm must take all reasonable steps to ensure that conflicts of interest between itself and its clients, between its Employees and clients and between one client and another are identified and then prevented or managed, or disclosed, in such a way that the interests of a client are not adversely affected.

It is the Firm’s policy that we should, to the extent possible, aim to avoid conflicts of interest. However, at times, conflicts of interest cannot be avoided and may arise in any area of our business, between employees and the Firm, between employees and the Client or between the Firm and its clients and sometimes between clients. The determining factor in such potential conflicts of interest is the likelihood of an employee or the Firm making a financial gain (or avoiding a loss) at our clients’ or the Firm’s expense.

To manage potential or actual conflicts of interests, it is imperative that the confidentiality of client and the Firm data is maintained and that employees do not disclose or use this data inappropriately.

Directors, employees and where relevant contractors must advise the Compliance Officer of any potential or actual conflicts of interest. The following information is to be included in the notification:

  • names of the client or clients concerned
  • nature of the conflict
  • whether the conflict is deemed to be an actual conflict or a potential conflict

The Compliance Officer will review the notification and where required escalate it for consideration and action to the Senior Executive Officer or in case of an issue relating to the Senior Executive Officer or a major conflict, to the Board.

Either the Compliance Officer, the Senior Executive Officer or the Board (depending on who is independent and not party to the conflict) will determine the best way to address the conflict of interest, or perceived conflict of interest. If it is not possible to remove the conflict, or where the measures in place do not sufficiently protect a client’s interests, the Firm will disclose the conflict to the client.

The Firm may also decline to act for a client in cases where the conflict of interest cannot be managed in any other way. Where such a situation arises, the decision will be made by the Senior Executive Officer. In cases where the conflict relates to the Senior Executive Officer, a written decision by a member of the Board is required.

The Board reviews and approves our conflicts of interest policy. Internal auditors, as part of their annual audit, also review a sample of transactions to ensure that conflict notification, escalation, resolution and reporting are working as stated and any deficiencies are highlighted in the report which is submitted to the Board for comments and action.
Outside Business Interests
External directorships or outside business interests held by employees may result in a conflict of interest or the appearance of impropriety. All employees are required to declare such interests to the Compliance Officer for approval.

The Compliance Officer will retain a copy of any outside business interest approval. You are also required to notify the Compliance Officer in writing of any changes or additions to the information supplied.

The Firm may require employees to resign from an external directorship or outside business interest, at any time, if the Firm believes such interest to (a) create a conflict of interest, (b) contravene any law or regulation and/or (c) contravene any of the Firm Policies.