Conflict of Interest Management

Komainu Holdings Limited’s subsidiaries and affiliates (together, “Komainu” or “we”) offer a number of services including custody, custodial staking, and collateral management to a diverse universe of clients.

Komainu believes the best way to build and to maintain trust is to conduct every element of our business according to the highest standards of integrity, and if a conflict of interest arises in the conduct of its business or in the provision of its services, Komainu manages such conflicting interests through its conflicts of interest policy.

We have principles, procedures and measures that are designed to ensure that the services provided, or activities conducted are carried out with an appropriate degree of independence to protect the interests of our clients.

These principles, procedures and measures include, but are not limited to, a robust and strong corporate structure, clear division of responsibilities with segregation of decision-making duties, conflicts register, providing training to employees in relation to conflicts of interest, requirements on our employees to identify and manage conflicts, risk and compliance committee oversight and on-going compliance monitoring.