Last Updated: June 2026

Crosmsint Europe, S.L. (Crossmint Europe)

1.     INTRODUCTION AND REGULATORY CONTEXT

Crossmint Europe, S.L. (hereinafter, “Crossmint” or the “Entity”) is a provider of cryptoasset services, registered with the relevant official registry of the National Securities Market Commission (“CNMV”) and ESMA.

The regulations applicable to firms providing services related to crypto-assets, in particular Regulation (EU) 2023/1114 of the European Parliament and of the Council of May 31, 2023, on markets in crypto-assets and amending Regulations (EU) No. 1093/2010 and (EU) No. 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937 (hereinafter “MiCA”) and its implementing regulations, in particular Commission Delegated Regulation (EU) 2025/1142 of February 27, 2025, supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying the requirements applicable to the conflict-of-interest policies and procedures of crypto-asset service providers and the details and methodology regarding the content of the conflict-of-interest disclosure, require firms providing crypto-asset services to take all appropriate measures to identify, prevent, manage, and disclose conflicts of interest that may arise in the course of providing any crypto-asset or ancillary service, or a combination thereof, among the firms themselves—including their managers, employees, and tied agents—or any person directly or indirectly linked to them by control, and their clients or among clients.

To this end, firms providing crypto-asset services are required to adopt, implement, and maintain an effective conflict-of-interest policy that identifies, in relation to crypto-asset services and activities, the circumstances that give rise or could give rise to a conflict of interest involving a risk of prejudice to the interests of one or more clients. Such a policy must be appropriate to the firm’s size and organization and to the nature, scale, and complexity of its business. When the firm is a member of a group, the policy must also take into account any circumstances—of which the firm is aware or should be aware—that could give rise to a conflict of interest as a result of the corporate structure and business activities of other group members.

Therefore, the objectives of this policy are to establish comprehensive guidelines for identifying and preventing conflicts of interest and, where necessary, for effectively managing them so that they are properly resolved and do not harm the interests of clients or those of the Entity itself.

In this regard, in order to comply with the aforementioned obligations, the Entity has prepared this document, which sets forth the conflict of interest management policy (hereinafter, the “Policy”). 

2.     SCOPE OF APPLICATION

The obligations set forth in this Policy apply to all directors, executives, employees, and persons directly or indirectly involved in the provision of cryptoasset services by Crossmint (hereinafter, the “Subject Persons”).

Accordingly, a relationship between Crossmint and another natural or legal person shall be deemed to exist in the following situations: 

●      Direct ownership or control of 30% or more of Crossmint’s voting rights or capital. 

●      A controlling relationship between the parent company and a subsidiary in all cases provided for by applicable regulations. 

●      A permanent relationship arising from a controlling interest. 

●      A family relationship as defined by applicable regulations. 

This Policy has been circulated and is available to Affected Persons through the Entity’s designated internal communication channels, including, but not limited to, Notion, Slack, and Google Drive.

The Entity is authorized by the CNMV to provide the following services related to cryptoassets (hereinafter, the “Services”):

In connection with the provision of the aforementioned Services, Crossmint has developed this Policy, taking into account the scope, nature, and range of the cryptoasset services provided, to identify, prevent, manage, and disclose conflicts of interest between:

-        The Entity and: 

o   Its shareholders or partners;

o   any person directly or indirectly linked to the service providers or their shareholders or partners through a controlling relationship; 

o   the members of its governing bodies;

o   its employees; or

o   its clients.

-        Two or more clients whose mutual interests conflict.

-        The Entity and other companies in the group to which the Entity belongs (hereinafter, the “Group”).

The occurrence of such a situation may jeopardize the impartiality and independence of the Entity’s actions; therefore, the prevention and, where necessary, management of conflicts of interest is a priority, in accordance with the regulations in effect at any given time.

In accordance with MiCA, crypto-asset service providers, such as Crossmint, are required to address conflicts of interest, which are primarily classified into three categories based on the above criteria:

-        Conflicts of interest between Crossmint and its clients (first category).

-        Conflicts of interest between individual clients or groups of clients of Crossmint (second category).

-        Conflicts of interest that may prevent Crossmint’s Relevant Persons from performing their duties and responsibilities objectively and independently—that is, internal conflicts of interest (third category).

3.     DEFINITION OF A CONFLICT OF INTEREST

A conflict of interest is deemed to exist within the Entity when a situation arises in which the personal, financial, or professional interests of the Affected Persons interfere or may interfere with their duty or responsibility to act in accordance with the interests of our clients or the Entity.

These conflicts may arise in the following circumstances:

●      When the decisions or actions of any of the Affected Persons are influenced by their personal interests, to the detriment of the interests of clients or Crossmint.

●      When Affected Persons have business relationships that may compromise their objectivity and independence when providing services to clients.

●      When privileged or confidential information obtained through their position at Crossmint is used for personal gain or the benefit of third parties, affecting the fairness and transparency of service delivery.

4.     SCENARIOS OF POTENTIAL CONFLICTS OF INTEREST

In light of the above definition, the following is a non-exhaustive list of circumstances and situations that, for the purposes of this Policy, could give rise to a conflict of interest: 

-        Conflicts of interest in the first category: 

To identify a conflict of interest, consideration is given, as a minimum criterion, to whether the Entity or any entity within the Group, or a Subject Person, or a person directly or indirectly linked to the Entity or the Group through a controlling relationship, is in any of the following situations (whether as a result of the provision of the Services or for other reasons):

i)      It may obtain a financial benefit, or avoid a financial loss, at the client’s expense.

ii)     Has an interest in the outcome of a service provided to the client or a transaction carried out on the client’s behalf that differs from the client’s interest in that outcome.

iii)    Has financial or other incentives to favor the interests of another client or group of clients over the client’s interests.

iv)    Engages in the same business activity as the client.

v)     Receives or is set to receive from a person other than the client an incentive in connection with a service provided to the client, in the form of services or monetary or non-monetary benefits, in addition to the usual commission or fee for that service.

vi)    In the event that Crossmint executes cryptoasset orders on behalf of clients but also operates a cryptoasset trading platform, or an entity within its group operates such a platform.

     For these purposes, it shall not be considered sufficient that the Subject Person, the Entity, or any entity within the Group, or a person directly or indirectly linked to the Entity or the Group through a controlling relationship, may obtain a benefit if there is no potential harm to a client, or that a gain may be obtained or a loss avoided if there is no concomitant possibility of loss to a client. Furthermore, it is not essential that the risk of harming one or more clients materialize; rather, the mere existence of a situation of potential harm requires the application of this Policy.

-        Adverse Conflicts of Interest Among Clients (Second Category)

To identify a conflict of interest, the following situations are considered, as a minimum criterion: 

i)      When Crossmint has more than one client with an interest in the outcome of a transaction.

ii)     When Crossmint trades cryptoassets on its own account and, at the same time, executes orders involving cryptoassets on behalf of clients or receives and transmits orders involving cryptoassets on behalf of clients.

-        Conflicts of interest detrimental to Crossmint (third category)

To identify a conflict of interest, the following is considered, as a minimum criterion, if a Subject Person is in any of the following situations: 

i)      Has a financial interest in a person, body, or entity with interests in conflict with those of Crossmint.

ii)     Has or has had, for at least the past 3 years, a personal relationship with a person, body, or entity whose interests conflict with those of Crossmint.

iii)    Has or has had, for at least the past 3 years, a professional relationship with a person, organization, or entity whose interests conflict with those of Crossmint.

iv)    Has or has had, for at least the past 3 years, a political relationship with a person, organization, or entity whose interests conflict with those of Crossmint.

v)     Performs conflicting tasks or activities, is entrusted with conflicting responsibilities, or is supervised by a person in charge of conflicting functions or tasks.

For the purposes of identifying individuals, organizations, or entities with interests that conflict with those of Crossmint, consideration will be given, at a minimum, to whether such individual, organization, or entity is in any of the following situations: 

i)      is likely to obtain a financial benefit, or avoid a financial loss, at the expense of the crypto-asset service provider;

ii)     has an interest in the outcome of a crypto-asset service provided or an activity performed or decision made by the crypto-asset service provider that is distinct from the crypto-asset service provider’s interest in that outcome;

iii)    engages in the same activity as the crypto-asset service provider or is a client, consultant, advisor, delegate, subcontractor, service provider, or other supplier (including subcontractors) of the crypto-asset service provider, and it can reasonably be inferred from objective circumstances that a conflict of interest with the crypto-asset service provider may exist.

For the purpose of determining whether a Subject Person has any type of economic interest in a person, body, or entity with interests in conflict with those of Crossmint, consideration shall be given, at a minimum, to whether the Subject Person:

i)      holds shares, tokens (including governance tokens), or other ownership or equity interests in such person, body, or entity;

ii)     holds debt instruments or has other debt arrangements with that person, body, or entity;

iii)    has any type of contractual agreement, such as management contracts, service contracts, delegation or outsourcing contracts, or intellectual property licenses, with that person, body, or entity. 

Notwithstanding the foregoing, in the event that conflicts of interest cannot be avoided, they shall be resolved in accordance with the guidelines set forth in Section 5.3 of the Policy.

5.     GENERAL GUIDELINES FOR HANDLING CONFLICTS OF INTEREST 

With the purpose and objective of identifying, preventing, managing, and controlling—or, as a last resort, disclosing—the existence and nature of actual or potential conflicts of interest, and so that all persons involved and responsible for the process in question may make the appropriate decision in accordance with the provisions established by law, the Entity has adopted the following principles and measures to properly manage conflicts of interest:

●      Priority must be given to the legitimate interests of clients, striving to prevent them from coming into conflict and complying with legal requirements, exercising the utmost diligence, loyalty, and neutrality, and ensuring that any transaction involving conflicts of interest is conducted in the best interests of the clients.

●      No preferential treatment shall be given to any client when a conflict of interest exists among several clients.

●      Internal procedures for the approval of products and services will be followed, including the requirement to analyze potential conflicts of interest and implement measures to prevent conflicts of interest in any advertising communications. The selection of cryptoassets offered is made after analyzing their suitability and compliance with Crossmint’s internal policies in this regard, as well as their various risks, and they are continuously monitored. 

●      Intermediaries will be selected based on objective and independent criteria. 

●      It must be ensured that when Relevant Persons simultaneously engage in different activities involving conflicts of interest that could undermine the interests of Crossmint or its clients, they carry out such activities with a level of independence appropriate to the size and nature of Crossmint’s operations.

●      There is functional, hierarchical, and physical separation between management, administrative, risk, and control functions within Crossmint, with information barriers in place to prevent and control the exchange of information, as well as separate areas to prevent the flow of privileged or non-public information—known as “Chinese walls.” 

●      Employees of a given segregated area shall not perform functions for another segregated area, without prejudice to the functions—particularly those of supervision and coordination—exercised by management.

●      All other rules—whether derived from laws or regulations or adopted by Crossmint as supplementary measures—intended to prevent or properly address conflicts of interest shall be strictly observed and enforced.

●      Regulated Persons shall not engage in or promote any conduct that, by involving the improper use or disclosure of inside information or market manipulation, could constitute market abuse.

●      Authorized Persons may not use confidential information obtained by them personally at Crossmint—or, more generally, confidential information obtained by Crossmint—for their own benefit, either directly or by disclosing it to selected clients or third parties without Crossmint’s knowledge.

●      The activities carried out, as set forth in Crossmint’s program of activities, are reserved for professionals who are part of Crossmint in accordance with its organizational structure. These activities shall always be conducted on behalf of Crossmint, and engaging in other activities parallel to or outside the program of activities is prohibited.

●      The compensation policy for employees who make significant risk decisions—including management, control functions, and all those in the same compensation bracket—promotes robust risk management at Crossmint. Additionally, any direct link between the compensation of individuals performing one activity and the compensation of others performing a different activity—where a conflict of interest may arise between such activities—will be eliminated.

●      Provision of clear and complete information, in accordance with legal requirements, to potential clients prior to the transaction.

●      Separate supervision of employees whose primary duties involve providing services to clients and who have conflicting interests among themselves or with the Entity itself.

●      Limiting the possibility of undue influence being exerted on the manner in which a person performs their duties.

●      Prohibition on a person from participating simultaneously or consecutively in different activities when such participation could undermine the proper management of conflicts of interest.

●      Preventing Subject Persons who also act outside the Entity from exerting undue influence within the Entity in relation to those other activities.

●      Establishing procedures or policies to prevent the creation of conflicts of interest, as well as measures to ensure appropriate conduct by Subject Persons.

●      Promptly report and communicate to the Board of Directors any matter that may give rise to, or has given rise to, a conflict of interest.

●      Ensure that conflicting activities or transactions are assigned to different individuals.

●      Preventing members of the Board of Directors from holding executive positions at competing cryptoasset service providers outside the Group.

6. PROCEDURAL PRINCIPLES FOR RESPONDING TO A POTENTIAL CONFLICT OF INTEREST 

6.1. Identification 

All possible measures shall be taken to identify, in relation to the Services provided by the Entity, any circumstances that give rise to or may give rise to a conflict of interest and that pose a risk of harming the interests of one or more clients or of the Entity.

To this end, at a minimum, the situations referred to in Section 4 of this Policy will be taken into account. 

In order to assess the possible existence of conflicts of interest with respect to the Relevant Persons, the Compliance Unit may request the necessary information from them, and they shall be obligated to provide recent personal or professional information or circumstances that may influence the performance of their professional duties and decision-making, such as:

-        Financial interests that may pose a conflict of interest with Crossmint.

-        Personal or professional relationships with clients who hold a significant amount of cryptoassets.

-        Personal or professional relationships with Crossmint executives.

-        Professional activities conducted on their own behalf or at entities other than Crossmint.

-        Personal or professional relationships with Crossmint’s main business partners, third parties, and suppliers.

-        Public offices or positions of authority within the public administration.

In any case, employees are responsible for promptly reporting to their direct supervisor—who must then report to the Compliance Unit—any situation that arises and affects their personal or professional circumstances and that could potentially give rise to a conflict of interest with Crossmint.

All Affected Persons who are involved in or become aware of situations described in this Policy, or of any other situation or event that could give rise to a conflict of interest, must inform the Compliance Unit, which will make the appropriate decision regarding the conflict in accordance with the relevant procedures, as well as the principles and measures contained in this Policy.

The department or departments affected by the conflict of interest must provide all available information regarding the event or situation that gave rise to the conflict so that the Compliance Unit can properly address it. 

Covered Persons have a duty to report any individual or group conduct or activity that occurs in the context of their work and that may violate the provisions of this Policy or other internal policies, regardless of whether a supervisor has ordered or requested such activities.

To ensure that this Policy and other compliance efforts are effectively implemented, the Entity has established mechanisms for reporting and communication. Any questions or reports may be submitted through the internal reporting channel, which is available to all Covered Persons: 

Covered Persons may submit information regarding a potential conflict of interest to Crossmint’s internal reporting channel for this matter, which is as follows: Crossmint Reporting Channel.

Any suspicion, alert, or report may be submitted through the reporting channel, which is available to all Covered Persons. This is an anonymous channel that ensures Covered Persons can report any suspicious behavior without fear of retaliation or identification. This channel is operated by the legal and compliance team, thereby guaranteeing confidentiality and security.

5.2. Prevention and Mitigation

Efforts will be made to prevent conflicts of interest from arising; to the extent possible, guidelines and measures will be established for managing conflicts of interest that cannot be prevented, with the aim of avoiding harm to clients and Crossmint. To achieve this, the following measures will be implemented:

●      Crossmint will provide ongoing training to all Relevant Persons on the identification and management of conflicts of interest, fostering a culture of transparency and ethics.

●      Crossmint will conduct periodic reviews of policies and procedures related to conflicts of interest, adjusting them as necessary to address new circumstances or emerging risks.

●      Crossmint will carry out oversight and internal control activities to continuously monitor and review operations and activities. 

5.3. Resolution

Conflicts of interest will be resolved by the head of the affected area or department. If the conflict affects multiple areas, it will be resolved by the immediate supervisor of all such areas. In the event that none of the above rules apply, the conflict will be resolved by the Compliance Unit.

The following guidelines will be taken into account when resolving conflicts of interest:

i)      In the event of a conflict between the Entity and a client, the client’s interests must be safeguarded;

ii)     In the event of a conflict between clients:

-       favoritism toward any of them must be avoided;

-       under no circumstances may the transactions carried out by some clients be disclosed to others; and

-       a client may not be encouraged to carry out a transaction for the purpose of benefiting another client.

iii)    In the event of conflicts of interest between Crossmint and the Relevant Persons: 

Regulated Persons must always act in such a way that their personal interests, those of their relatives, or those of other persons with close ties to them do not take precedence over the interests of Crossmint or those of its clients. In this regard: 

a.     No one may approve, intervene in, or otherwise influence transactions in which employees or any person with a close relationship to them appear as beneficiaries or guarantors. 

b.     No payment, commission, gift, invitation, or compensation of any kind may be solicited or accepted from clients, suppliers, intermediaries, counterparties, or any other third party in connection with transactions carried out by the group, nor may one otherwise derive personal benefit from one’s position within the group. 

c.     Professional services may not be provided to other entities or competing companies, whether for compensation or not, unless expressly authorized by the Compliance Unit and the head of the relevant department. 

iv)    Conflicts of interest between Crossmint and its main business partners, third parties, and suppliers:

Employees may not participate in procedures for the procurement of products or services for Crossmint involving companies or individuals with whom the employee has a close connection or family relationship. In this regard:

●      Any form of interference that could affect impartiality or objectivity in the procurement of supplies and services or in the setting of their financial terms must be avoided. 

●      Whenever possible, exclusive relationships with suppliers of products and services must be avoided.

●      Special treatment or working conditions based on personal or family relationships must not be granted.

●      Retroactive inclusion of risk in variable compensation.

In any case, once the existence of a conflict has been established: 

●      Measures will be implemented to avoid it or, where appropriate, to manage it through the Compliance Unit in accordance with the relevant guidelines.

●      When the measures described above are not sufficient to guarantee, with a reasonable degree of certainty, that risks of harm to the client’s interests will be avoided, Crossmint will disclose the source and nature of the conflict to the client. The disclosure will be made in a durable medium and with sufficient detail so that the client can make a decision regarding the service in light of the conflict.

5.4. Disclosure

In cases where the guidelines and measures established by the Entity to manage conflicts of interest and prevent harm to its clients’ interests are insufficient to ensure, with reasonable certainty, that the risks of harm to the client’s interests will be prevented, the Firm will disclose the nature and source of the conflict to the affected clients prior to providing the service or concluding a transaction, as well as the measures taken to mitigate the risk of harm to the client. The Firm will obtain, if it deems it appropriate, the prior express consent of the affected clients, once they have been informed of the existence of the conflict.

The disclosure of conflicts of interest to clients must be considered, in all cases, a measure of last resort, applicable only if the measures established by the Entity to prevent or manage conflicts of interest are insufficient to ensure, with reasonable certainty, the prevention of potential harm to the client’s interests.

It is very important that the Entity inform its clients of the role and capacity in which it is acting when providing Services to a client. In fact, this may not always be clear to clients, especially when crypto-asset service providers operate in a vertically integrated manner or in close cooperation with affiliated entities.

In such situations, this information must be displayed prominently on the Entity’s website and, where applicable, include a prominent link to the statements on the website. To ensure the effectiveness of this information, clients must be able to access it at all times and from any device. When crypto-asset services are provided through another medium (such as a mobile app or other platform), the information must also be available on the relevant device, or the Entity must ensure that clients can access it at all times and on any device. Furthermore, the information must be provided in all languages used for marketing or communication with clients and must be kept up to date at all times to ensure its accuracy.

The disclosure must take into account the nature of the client, to ensure proper understanding and enable the client to make an informed decision regarding the service, and must include a specific description of the conflict of interest that indicates:

-   the cryptoasset services, activities, or situations that give rise to or may give rise to conflicts of interest;

-   the nature of the identified conflicts of interest;

-   the associated risks identified in relation to the detected conflicts of interest;

-   the steps and measures taken to prevent or mitigate the identified conflicts of interest and ensure that no residual risks remain.

This mechanism is intended to provide the client with sufficiently detailed information to make an informed decision, based on the specific circumstances, regarding the service in which the conflict of interest has arisen.

Excessive reliance on the disclosure of conflicts of interest is considered a shortcoming of this Policy and would necessitate a review and evaluation of the Policy.

6.     SPECIFIC PROVISIONS REGARDING PERSONAL TRANSACTIONS

A personal transaction is defined as a transaction involving a cryptoasset or providing exposure to a cryptoasset carried out by or on behalf of a Subject Person, when at least one of the following criteria is met:

-   The Subject Person acts outside the scope of the activities they perform in their professional capacity;

-   The transaction is conducted on behalf of any of the following persons:

●      The Subject Person themselves.

●      Any person with whom a Subject Person has a family relationship or close ties[1] .

●      A person in respect of whom the Subject Person has a direct or indirect material interest in the outcome of the transaction, other than the receipt of a fee or commission for executing the transaction.

The Entity shall ensure that Subject Persons do not engage in personal transactions that meet any of the following criteria:

-   Such a person is prohibited from participating under Title VI of MiCA.

-   It involves the misuse or improper disclosure of such confidential information.

-   It conflicts or may conflict with any of the Entity’s obligations under MiCA.

In addition, the Policy must always ensure the following: 

-   That Subject Persons are aware of the restrictions on personal transactions, as well as the measures established by the Entity regarding personal transactions.

-   That the Entity is informed without delay of any personal transaction carried out by a Subject Person, either through notification of such a transaction or through other procedures that allow for the identification of such transactions.

-   That a record is maintained of the personal transaction reported to or identified by the Entity, including any authorization or prohibition regarding such transaction.

7.     RECORD OF CONFLICTS OF INTEREST AND ANNUAL REPORT 

The Entity maintains a continuously updated record of those transactions and activities in which a conflict of interest has arisen or may arise that has posed or may pose a risk of harming the interests of one or more clients. The content of this record shall comply with the provisions of Annex I of this Policy. The Compliance Unit is responsible for maintaining and updating the aforementioned record.

This record shall include, in a clear, tamper-proof, and sequentially numbered format, details regarding the origin of the conflicts of interest, the individuals and departments involved, and a description of the conflicts themselves.

The information contained in this record must be retained for a minimum period of five (5) years, starting from the moment the conflict of interest or potential conflict of interest is identified; any changes made to the record must also be retained for the same period, without prejudice to the supervisor’s authority to extend this period to a maximum of seven (7) years.

The register shall include, but is not limited to, the following information:

-   Products or services to which the conflict relates.

-   A detailed description of the situations that gave rise to the conflict of interest.

-   Identification of the individuals who have been exposed to the conflict of interest.

-   Departments or areas involved.

-   Date on which the conflict of interest arose.

-   Description of the measures taken to manage the conflict, as well as the measures taken to prevent and mitigate conflicts of interest arising from or that may arise from the situations that occurred.

-   Deficiencies identified in policies, procedures, and provisions regarding conflicts of interest, and the measures taken to address them

At least once a year, the Entity’s senior management will receive information on any conflicts of interest that have been recorded, including potential conflicts that have occurred. 

In this regard, the reports from the Compliance Unit submitted to senior management annually must include any new conflicts of interest that have arisen during the relevant period, as well as a list of all conflicts that have occurred, covering the points mentioned above.

8.     CONFLICTS OF INTEREST REGARDING COMPENSATION

Crossmint will define and implement compensation procedures, policies, and agreements that take into account the interests of all its clients—in the short, medium, and long term—as well as the scale, nature, and range of the Services. The procedures, policies, and provisions regarding compensation will be designed so as not to create a conflict of interest or incentives that could lead the Relevant Persons to favor their own interests or those of Crossmint to the potential detriment of any client, or that could lead the persons to whom they apply to favor their own interests to the detriment of Crossmint.

9.     RESPONSIBILITIES

9.1. Board of Directors

The Board of Directors is responsible for approving this Policy and its subsequent updates. Additionally, it shall also be responsible for:

-        Ensuring its implementation, monitoring compliance, and periodically evaluating and reviewing its effectiveness and addressing any deficiencies in this regard.

-        Informing other members and abstaining from voting on any matter in which a member has or may have a conflict of interest or in which the member’s objectivity or ability to properly fulfill their obligations to the Entity may otherwise be compromised.

9.2. Compliance Unit

The Compliance Unit is responsible for:

-        Participating in the design, development, and updating of the Policy.

-        Ensuring that the content of the Policy complies with applicable regulations.

-        Taking appropriate measures to prevent conflicts of interest from arising, for which it will rely on the relevant business areas.

-        Developing general templates for disclosing conflicts of interest to clients.

-        Keeping the conflict of interest registry permanently up to date.

-        Ensure that Persons Subject to this Policy have adequate knowledge of it, proposing training initiatives deemed appropriate to promote awareness and understanding of the Policy.

-        Review, at least once a year, the Policy and the measures included therein, as well as the effective compliance with it by the Persons Subject to this Policy, and submit the results of the review to the Board of Directors and propose, where appropriate, amendments to the Policy when it identifies areas for improvement to align it with the actual reality of the Entity’s operations or to bring it into line with regulatory criteria or recommendations, or in response to changes in applicable regulations. 

In any case, the Compliance Unit is authorized to issue as many internal circulars as it deems necessary to elaborate on the content of this Policy or to clarify any questions that may arise regarding its practical application. 

These circulars will be communicated to all Persons Subject to the Policy and duly filed by the Compliance Unit.

9.3. Persons Subject to the Policy

All Persons Subject to this Policy are responsible for complying with its provisions, as well as for identifying, managing, and reporting to the Compliance Unit any conflict of interest that may arise.

10.  TRAINING FOR PERSONS SUBJECT TO THE POLICY

Conflicts of interest will be a mandatory topic in Crossmint’s annual training programs. 

To ensure that this Policy is effectively implemented and maintained, Covered Persons must possess the necessary skills, knowledge, and experience to fulfill the responsibilities assigned to them and shall have access to all relevant information. Furthermore, Covered Persons will receive appropriate training on this Policy upon joining the Entity.

Finally, to enable the Board of Directors to fulfill its responsibilities in accordance with MiCA’s provisions regarding conflicts of interest, it is essential that the individuals responsible for implementing, maintaining, and reviewing this Policy report directly to the Board of Directors at least once a year, as well as whenever material deficiencies are detected.

Notwithstanding that any amendments to this Policy will be immediately communicated to the Covered Persons, refresher training sessions will be held periodically.

11.  AVAILABILITY OF THE POLICY

Crossmint makes available, in a prominent location on its website, a summary of the Policy for access by its clients and potential clients, which outlines the general nature and origin of the conflicts of interest mentioned in the Policy, as well as the measures taken to mitigate them.

12.  APPROVAL, EFFECTIVE DATE, AND UPDATES TO THE POLICY

This Policy must be approved by the Entity’s Board of Directors and shall take effect on the date of its approval.

The Policy will be updated and/or amended, at a minimum, in the following cases:

-        Annually, and whenever there are sections that could be improved to achieve the proposed objectives or to adapt appropriately to the characteristics of the services offered by the Entity at any given time.

-        When legal or regulatory changes occur that affect the Policy.

-        At the request of the supervisory bodies.

APPENDIX I: TEMPLATE FOR THE CONFLICT OF INTEREST REGISTRY

[1] “The term ‘person with whom a related person has a family relationship’ means any of the following

(a) the spouse of the related person or any partner of that person considered by national law to be equivalent to a spouse;

(b) a dependent child or stepchild of the related person;

(c) any other relative of the related person who has shared the same household with that person for at least one year as of the date of the personal transaction in question or during the preceding 5 years.”