EU - Conflicts of Interest Disclosure

Last updated: March 9, 2026

Last Updated: February 2026

Crosmsint Europe, S.L. (Crossmint Europe)

1 Purpose of the disclosure

Crossmint Europe, S.L. (“Crossmint” or the “Entity”), as a crypto-asset service provider authorized/registered with the CNMV under number [●], has implemented and applies a Conflicts of Interest Management Policy in accordance with MiCA and its implementing regulations. The purpose of this policy is to identify, prevent, manage and, where appropriate, disclose conflicts of interest that may arise in the provision of crypto-asset services and ancillary services.

This statement provides an accessible summary of the general nature and origin of potential conflicts of interest, as well as the main measures applied by Crossmint to mitigate them.

2 Scope and types of conflicts

Crossmint manages conflicts of interest that may arise between::

  1. The Entity and: 

    1. Its shareholders or partners;

    2. Any person directly or indirectly linked to service providers or to their shareholders or partners through a control relationship; 

    3. lMembers of its management bodies; 

    4. Its employees; or

    5. Its clients.

  2. Two or more clients whose interests may conflict with each other.

  3. The Entity and other companies within the group to which the Entity belongs (the “Group”).

  4. Conflicts of interest that may prevent persons subject to Crossmint from performing their functions and responsibilities objectively and independently, i.e., internal conflicts of interest. For these purposes, Subject Persons include all directors, executives, employees and persons directly or indirectly involved in the provision of Crossmint’s crypto-asset services

3 Services covered

This statement applies to the crypto-asset services provided by Crossmint, including, among others:

  • Custody and administration of crypto-assets on behalf of clients.

  • Exchange of crypto-assets for funds.

  • Transfer of crypto-assets on behalf of clients.

4 Main scenarios of potential conflicts

Without being exhaustive, Crossmint considers the following as typical sources of conflict:

4.1 Conflicts between Crossmint and clients

To identify a conflict of interest, Crossmint considers as a minimum criterion whether the Entity, another entity of the Group, a Subject Person, or a person directly or indirectly linked to the Entity or the Group through a control relationship is in any of the following situations (whether as a result of providing the services or for other reasons:

  1. May obtain a financial benefit, or avoid a financial loss, at the expense of the client.

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

  1. Has financial or other incentives to favour the interests of another client or group of clients over the interests of the clien.

  1. Carries out the same activity as the client.

  2. Receives or will receive from a person other than the client an incentive in relation to a service provided to the client in the form of monetary or non-monetary services or benefits, other than the standard commission or fee for that service.

4.2. Conflicts between clients

To identify a conflict of interest, Crossmint considers, as a minimum criterion, whether any of the following situations arise:

  1. Crossmint has more than one client interested in the outcome of a transaction.

  2. The interests of one client may conflict with those of another client in terms of priority or treatment.

4.3. Internal conflicts

To identify a conflict of interest, Crossmint considers whether a Subject Person is in any of the following situations: 

  1. Has an economic interest in a person, body or entity whose interests conflict with those of Crossmint.

  1. Has or has had within the last three years a personal relationship with a person, body or entity whose interests conflict with those of Crossmint.

  1. Has or has had within the last three years a professional relationship with a person, body or entity whose interests conflict with those of Crossmint.

  1. Has or has had within the last three years a political relationship with a person, body or entity whose interests conflict with those of Crossmint.

  1. Performs contradictory tasks or activities, is assigned contradictory responsibilities, or is hierarchically supervised by a person responsible for conflicting functions or tasks.

For the purposes of identifying whether a Subject Person has an economic interest in a person, body or entity with interests conflicting with those of Crossmint, Crossmint will consider, at least, whether the Subject Person:

  1. Holds shares, tokens (including governance tokens), other ownership rights or membership interests in that person, body or entity;

  2. Holds debt instruments or has other debt arrangements with that person, body or entity;

  3. Has any contractual arrangement with that person, body or entity, such as management agreements, service agreements, delegation or outsourcing agreements, or intellectual property licensing agreements. 

5 General guidelines for managing conflicts of interest 

Crossmint applies a control framework designed to ensure that conflicts do not harm the interests of clients, including, among others:

  • Priority to client interests and fair treatment (no undue preferential treatment).

  • Functional, hierarchical and physical separation between management, administration, risk and control functions within Crossmint, including information barriers (“Chinese walls”) to prevent and control the exchange of sensitive or non-public information.

  • Objective selection of intermediaries and service providers.

  • Internal product and service approval procedures including conflict of interest analysis.

  • Controls to prevent undue influence and restrictions on participation in incompatible activities.

  • Prohibition of misuse of confidential information or conduct that may constitute market abuse, including the improper use or disclosure of inside information or market manipulation.

  • Remuneration policies for employees responsible for relevant risk decisions, including management and control functions, designed to promote sound risk management within Crossmint.

  • Periodic training and a strong compliance culture.

  • Procedures to promptly inform and report to the Board of Directors any matter that may give rise, or has given rise, to a conflict of interest.

  • Continuous supervision and controls carried out by the Compliance Unit, which reviews the Policy and the measures included in it at least annually.

6 Management procedure

6.1. Identification

Crossmint adopts all necessary measures to identify situations that may generate conflicts of interest in the provision of its services and that could harm clients or the Entity itself.

The Compliance Unit may collect information from Subject Persons to detect potential conflicts, including economic interests, relevant personal or professional relationships, external activities or public positions.

Subject Persons are required to:

  • Promptly communicate any situation that may constitute a conflict of interest.

  • Report conduct or facts that may breach this Policy.

  • Provide all necessary information for proper assessment.

Crossmint maintains an internal whistleblowing channel, anonymous and confidential, managed by the legal and compliance team: Canal de Denuncias de Crossmint.

  • Conflicts identified and the measures adopted are recorded in a Conflicts of Interest Register, maintained for the applicable period and reported at least annually to senior management.

5.2. Prevention and mitigation

The objective is to prevent conflicts from arising or, where this is not possible, to manage them appropriately to protect the interests of clients.

To achieve this, Crossmint:

  • Provides ongoing training on conflicts of interest.

  • Periodically reviews its policies and procedures.

  • Continuously monitors its operations and activities.

  • Applies organisational and internal control measures to minimise risks.

5.3. Resolution

Conflicts of interest are resolved by the head of the affected department or area. If multiple areas are involved, the immediate common hierarchical superior will resolve the matter. Where none of the previous rules apply, the conflict will be resolved by the Compliance Unit.

Key principles:

  • Priority to the client’s interest.

  • Prohibition of favouring one client over another.

  • Prohibition of disclosing transactions between clients.

  • Prohibition of requesting or accepting payments, commissions, gifts, hospitality or any other benefits from clients, suppliers, intermediaries, counterparties or third parties in relation to transactions carried out by the Group, as well as obtaining any personal benefit derived from the position held within the Entity.

  • Restrictions on relationships with suppliers and competitors.

If internal measures do not eliminate the risk with sufficient certainty, Crossmint will disclose the nature and origin of the conflict to the client on a durable medium as a last resort.

7 Disclosure to clients

Where, despite the measures applied, it is not possible to guarantee with reasonable certainty that risks of harm to the client will be avoided, Crossmint will disclose to the affected client the nature and origin of the conflict, as well as the mitigation measures adopted, prior to providing the service or carrying out the transaction.

The disclosure will be provided on a durable medium to enable the client to make an informed decision.

Disclosure is considered an exceptional measure of last resort, and recurrent use would require a review of the Policy.

The communication must consider the nature of the client to ensure proper understanding and enable an informed decision. It must include:

  • The crypto-asset services, activities or situations that give rise or may give rise to conflicts of interest.

  • The nature of the conflicts of interest identified.

  • The associated risks identified in relation to those conflicts.

  • The steps and measures taken to prevent or mitigate the conflicts and ensure no residual risks remain.

8 Conflicts of interest register and annual report

The Entity maintains an updated register of all actual or potential conflicts of interest that may pose a risk to clients. The Compliance Unit is responsible for maintaining this register.

The register:

  • Is clear, numbered and tamper-proof.

  • Includes the origin of the conflict and the persons and areas involved.

  • Details the services affected, the date of detection and the measures adopted.

  • Records identified deficiencies and corrective actions implemented.

  • Is retained for a minimum of 5 years (extendable to 7 years by the supervisor).

At least once per year, senior management receives a report including:

  • Newly identified conflicts.

  • Potential conflicts.

  • Measures adopted.

  • An overall evaluation of conflict management during the period.

9 Where to Find More Information / Contact

This statement is based on Crossmint’s Conflicts of Interest Management Policy.

For queries related to conflicts of interest or to report potential situations, Subject Persons must use the internal channels provided (including the whistleblowing channel). Clients may contact Crossmint at: support@crossmint.com.