Conflict of Interest Disclosure

Conflict of Interest Disclosure

At Wirex, we are committed to maintaining the highest standards of integrity, transparency, and fairness in all aspects of our crypto-asset services. As a trusted provider of custody, exchange, and transfer services for crypto-assets, we understand the critical need to manage potential conflicts of interest effectively. Our goal is to ensure that our clients' interests are always protected and that any conflicts are properly addressed.

Identifying and Managing Conflicts of Interest

As part of our commitment to transparency and fairness, Wirex has developed comprehensive policies to identify, manage, and prevent conflicts of interest that could affect our clients. This Conflicts of Interest Policy ensures that the interests of our clients are always prioritized. It is specifically designed to address and mitigate any potential conflicts arising from the crypto-asset services we provide, including exchanges, custody, and transfers.

Additionally, our Wirex Code of Conduct outlines the core principles that guide our employees' business activities and practices. This Code supports the effective implementation of our Conflicts of Interest Policy, reinforcing our dedication to maintaining integrity and safeguarding client interests in every aspect of our operations.

We recognize that conflicts can arise in a variety of ways, both within our organisation and between parties with a vested interest in our services. Conflicts of interest can arise in various scenarios, including:

• Between Wirex and Its Stakeholders
  Conflicts may occur between our services and the interests of our shareholders, directors, or employees. For example, if a shareholder or a related entity has a financial interest in certain crypto-assets, this could lead to potential conflicts in how services are offered.
• Within Wirex
  Conflicts may arise if members of our management or employees have personal financial interests in certain assets or transactions. We take proactive measures, such as internal controls and regular reviews, to ensure these personal interests do not influence client services or decision-making.
• Between Clients
  Conflicts can also arise between two or more clients with competing interests. For instance, if one client wishes to buy or sell a particular crypto-asset at a different price than another client, we ensure that both clients’ interests are treated fairly and impartially.
• External Relationships
  Conflicts may also arise from relationships with external partners or service providers. For example, if we have an exclusive agreement with a third-party provider for liquidity services, we ensure that this relationship does not unfairly benefit one group of clients over others.

Disclosing and Mitigating Conflicts

In accordance with applicable regulations, we transparently disclose to our clients both the nature and sources of any potential conflicts, as well as the measures we take to mitigate them.

Whenever new conflicts are identified, they are promptly reported to the Compliance Department. If a conflict of interest presents a risk to the interests of our clients and cannot reasonably be prevented, we ensure that this conflict is disclosed to clients prior to the provision of services.

Our disclosures are designed to provide sufficient detail, enabling clients to make well-informed decisions about using our services, fully aware of how any conflicts will be managed.

Furthermore, the key steps taken to manage each identified conflict are recorded in a Conflicts of Interest Register. This ensures that all conflicts are tracked and that our clients’ interests remain protected throughout all transactions and services.

Commitment to Client Interests

At Wirex, we prioritize our clients' interests above all else. Our comprehensive conflict of interest management approach is designed to ensure that no internal or external factors compromise the fairness, integrity, or transparency of our services. By adhering to our robust policies and continuously reviewing them, we aim to maintain the highest standards of compliance and client trust.

If you have any questions regarding our conflict of interest policy or would like further details, please do not hesitate to reach out to us. Our goal is to ensure that your experience with Wirex is both transparent and secure.