1. Our approach
CF Technologies Limited (the “Company”) is committed to acting in the best interests of its clients and to identifying, preventing and managing conflicts of interest that may arise in connection with the crypto-asset services it provides. This statement summarises the key principles of the Company’s internal Conflicts of Interest Policy.
2. Regulatory framework
The Company’s conflicts of interest arrangements are maintained in accordance with applicable requirements, including Regulation (EU) 2023/1114 on markets in crypto-assets (“MiCA”), Commission Delegated Regulation (EU) 2025/1142 on conflicts of interest for crypto-asset service providers, the Companies Act (Chapter 386 of the Laws of Malta), and applicable rules, guidance and communications issued by the Malta Financial Services Authority (“MFSA”).
3. When conflicts may arise
A conflict of interest may arise between the Company, its connected persons and one or more clients, or between different clients. The Company considers circumstances that may adversely affect the interests of clients or the Company, including situations where the Company or a connected person:
- may make a financial gain, avoid a financial loss or obtain another benefit at a client’s expense;
- has an interest in the outcome of a service, transaction, activity or decision that differs from the client’s or the Company’s interest;
- has an incentive to favour one client or group of clients over another;
- carries on the same business as a client, or has relevant economic, personal, professional, political or contractual relationships; or
- receives an inducement or other monetary or non-monetary benefit from a person other than the client in connection with a service provided to the client.
4. How we prevent and manage conflicts
The Company maintains arrangements designed to identify, prevent and, where prevention is not possible, manage and mitigate conflicts of interest. Depending on the circumstances, these measures may include:
- information barriers and information sharing on a need-to-know basis;
- segregation of roles and responsibilities and transparent reporting lines;
- controls against inappropriate influence and, where appropriate, controls over the simultaneous or sequential involvement of connected persons in conflicting activities;
- remuneration arrangements designed not to create incentives that could prejudice clients;
- requirements for members of the management body to declare relevant conflicts and abstain from discussion or voting where appropriate;
- controls, monitoring and oversight relating to personal transactions; and
- training, ongoing monitoring and escalation of material or unresolved conflicts.
Disclosure is not treated as a sufficient means of managing a conflict. It is used as a measure of last resort where the Company’s organisational and administrative arrangements are not sufficient to ensure, with reasonable confidence, that the risk of damage to client interests will be prevented.
5. Disclosure to clients
Where a conflict cannot be prevented or adequately managed, the Company will disclose the general nature and source of the conflict, the steps taken to mitigate it and any relevant remaining risks. Disclosures will be made in a manner intended to provide clients with sufficient information to make an informed decision regarding the relevant service.
6. Governance and records
The Compliance Officer is the designated individual responsible for overseeing the identification, prevention, management, disclosure and reporting of conflicts of interest and for keeping the relevant records up to date. Conflicts of interest are reported to the Board of Administration on a quarterly basis as part of the Compliance Report.
The Company maintains accurate and up-to-date records of actual and potential conflicts of interest and the measures taken to prevent or manage them. Records relating to conflicts of interest, including disclosures, assessments, decisions and mitigation measures, are retained for a minimum of five years.