Policy on the management of conflicts of interest and personal transactions

1. Introduction

CheckSig S.r.l. Benefit Company (hereinafter “CheckSig” or the “Company”) has always boasted a strong knowledge and sensitivity towards its customers, whose needs it pays the utmost attention to in order to ensure complete satisfaction, strengthen their trust, and, at the same time, preserve the good name of CheckSig. Pursuant to the Regulation (EU) of the European Parliament and of the Council of 31 May 2023 relating to Crypto-Asset Markets, and related implementing regulations (”MiCAR”), specifically in relation to the obligation for crypto-asset service providers to establish an effective policy on the management of conflicts of interest and personal transactions, CheckSig has fulfilled this obligation by drafting this document (hereinafter the ”Policy”) in order to identify, prevent and manage conflicts of interest taking into account its nature, size and organisation. 2. ## General aspects of the document

2.1. Purpose of the Policy

The Company believes that the best way to build and maintain trust is to conduct every aspect of its business with the highest standards of integrity. CheckSig maintains and applies effective organizational and administrative solutions in order to take all reasonable measures to identify, assess, mitigate and manage actual and potential conflicts of interest, as well as to prevent such conflicts from emerging. CheckSig implements and maintains effective policies and procedures, taking into account the scope, nature and range of crypto asset services provided, to identify, prevent, manage and communicate conflicts of interest between the Company and: a. its members, any Person Connected to the Company or its members; b. the members of its administrative body; c. its employees (interns and collaborators); d. its customers; e. two or more clients whose mutual interests are in conflict; f. the Company and other entities of the Group;
g. any Connected Person.

2.2. Recipients of the document and its update

This document is brought to the attention of customers through publication on the CheckSig institutional website and of CheckSig employees and collaborators (external consultants, interns, etc.) through its publication on the company drive at the following address Operational Guides. CheckSig also organizes training days dedicated to representing to all those involved in the process how to prevent and manage conflicts of interest. This Policy is prepared by the CEO, with the support of the managers of the operational company areas, and verified by the Compliance function, as well as approved by the Board of Directors. The same is subjected to periodic review, at least annually, also taking into consideration any updates necessary from time to time or the occurrence of significant circumstances that require its modification and/or integration. It is the responsibility of the operational company functions involved to report to the CEO any situations that cannot be managed based on the principles of the Policy and the related proposals for intervention and modification. The Compliance function, however, reports to the Board of Directors any needs to update the Policy in relation to external regulatory developments or following changes in the internal organizational or procedural structure.

2.3. Reference legislation

• EU Regulation 2023/1114 of the European Parliament and of the Council of 31 May 2023 relating to crypto-asset markets (“MiCAR”);
  • Commission Delegated Regulation EU 2025/1142 of 27 February 2025 supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying requirements relating to policies and procedures on conflicts of interest for crypto-asset service providers as well as details and methodology for the content of conflict of interest disclosures.

2.4. Definitions

• “Conflict of Interest”: a situation in which the personal or professional interests of a related person or the Company may interfere with the professional duties and obligation to act in the interests of the client;
  • “Group”: the group made up of the parent company and the companies controlled by it. CheckSig, Digital Gold Institute S.r.l. and CheckSig Suisse AG and represent the perimeter of the Company’s group;
  • “Related Person”: means a natural or non-natural person connected to the Company: i) the shareholders; ii) any person directly or indirectly connected to the Company or its members; iii) the members of the Board of Directors; iv) employees and collaborators;
  • “Remuneration”: means any form of payment or other financial or non-financial benefit provided directly or indirectly by the Company in providing services to customers;
  • “Relevant shareholding”: the holding by a single person of a set of shares or quotas representing a corporate shareholding that exceeds the pre-established threshold of 3% of the capital with voting rights, thus acquiring relevance. This threshold is raised to 5% of voting rights for SMEs;
  • “Relevant position”: means a position that involves the performance of administrative, management or control functions, including general manager.

2.5. Responsibility

The Board of Directors of the Company is the body responsible for the definition, adoption, implementation and control of compliance with the Policy, as well as the evaluation and periodic review of its effectiveness and the resolution of any deficiencies in this regard. In line with the Company’s links with the Group and the principle of proportionality and with the nature, size, complexity of the activity carried out and the range of services provided by the Company, the Board of Directors has identified the head of the Compliance function as the person responsible for the identification, prevention, management and disclosure of conflicts of interest in compliance with this Policy. This person, as part of the definition, adoption, implementation and control of the observation of a more general compliance program, supports and encourages an appropriate degree of risk culture which underlines the importance of the correct management of conflicts of interest. Specifically, the Manager is equipped with: i. the necessary legal skills to follow the evolution of sector legislation and regulations to ensure that the Company is always updated and compliant with current provisions;
ii. of the necessary management and technical-operational skills, also through dedicated training (application of internal procedures for the prevention, reporting and management of conflicts of interest; ability to prepare clear and verifiable reports and documentation); iii. the authority necessary to carry out his responsibilities appropriately and independently;
iv. of the necessary decision-making skills based on criteria of impartiality, correctness and integrity. The Manager annually has adequate financial and organizational resources for the correct carrying out of the activities envisaged by this Policy. If necessary, the manager can also make use of the support of adequately qualified external consultants (such as, for example, external law firms) to carry out the identification, prevention and evaluation of conflicts of interest. The activities of the manager, other than those attributed pursuant to this Policy, do not compromise his independence and objectivity. The Manager has access to all relevant information for the fulfillment of his responsibilities and reports directly to the CEO and the Board of Directors. The head of the Compliance function - in the annual report that the same head of the function presents to the Board of Directors - includes a specific note that contains at least the following elements: i. a description of the situations that give rise, or may give rise, to conflicts of interest (see in this regard Annex 2 - Mapping of conflicts of interest), including the role and capacity in which the Company acts when providing the service to the customer;
ii. any cases of conflict managed, as well as the measures adopted to prevent and mitigate conflicts of interest;
iii. any deficiencies identified in CheckSig’s conflict of interest policies, procedures and agreements (including remuneration policies, procedures and agreements) and the measures taken to remedy them. 3. ## Identification of conflict of interest The Company identifies potential conflicts of interest, which arise in the context of the provision of services, towards customers and towards itself as follows.

3.1. Conflicts of interest potentially harmful to clients

For the purposes of identifying the types of relevant conflicts of interest, the existence of which may harm the interests of one or more clients, the Company takes into consideration, at least, whether the same or any Related Person is in one of the following situations: a. is likely to achieve a financial gain, avoid a financial loss, or receive another type of benefit, at the customer’s expense;
b. has an interest in the outcome of a service provided to the customer or a transaction carried out on behalf of the customer, which is distinct from the customer’s interest in that outcome;
c. has a financial or other incentive to favor the interests of one or more customers over the interests of another customer;
d. carries out the same activity as the customer;
e. receives or will receive from a person other than the customer an incentive in relation to a service provided to the customer, in the form of monetary or non-monetary benefits or services.

3.2. Conflicts of interest potentially harmful to the Company

The Company also identifies conflicts of interest that are harmful to itself. In this context, (i) conflicts between the Company and the Connected Person, (ii) conflicts between the Company and people, bodies or other entities are relevant. For the purposes of identifying circumstances that could create conflicts of interest relating to the performance of the duties and responsibilities of a Person Connected to the Company, the latter takes into consideration at least the situations or relationships in which a Connected Person: a. has an economic interest in a person, body or entity with interests in conflict with those of the Company; in particular, at least the following situations or relationships in which the Connected Person:
1. holds shares, tokens (including governance tokens), other ownership or membership rights in such person, body or entity;
2. holds debt instruments or has other debt arrangements with such person, agency or entity;
3. has contractual arrangements of any kind, such as management, service, delegation or outsourcing agreements or intellectual property licenses, with such person, agency or entity;

b. has or has had in the last 3 years a personal relationship with a person, body or entity with interests in conflict with those of the Company;
c. has or has had in the last 3 years a professional relationship with a person, body or entity with interests in conflict with those of the Company;
d. has or has had in the last 3 years a political relationship with a person, body or entity with interests in conflict with those of the Company;
e. carries out conflicting tasks or activities, is entrusted with conflicting responsibilities or is subject to hierarchical supervision by a person responsible for conflicting functions or tasks. For the purposes of identifying persons, bodies or entities with interests in conflict with the Company, the latter takes into consideration, at least, whether such person, body or entity is in one of the following situations:
a. is likely to make a financial gain, or avoid a financial loss, at the expense of the Company;
b. has an interest in the outcome of a service or activity performed or a decision made by the Company that is distinct from the interest of the Company itself;
c. carries out the same activity as the Company or is a client, a consultant, an advisor, a delegate, a person to whom the Company outsources services/activities, a service provider or the sub-supplier of the Company’s supplier and it can reasonably be believed, based on objective circumstances, that there may be a conflict of interest with the Company. To identify and update potential conflicts, the Company requires Connected Persons to complete a declaration and update it in the event of significant changes or in the event of an update to this Policy (see Annex sub 1). The Company intends to verify these declarations by requesting, on a sample basis, the Connected Persons to send certificates or other supporting documentation to prove what has been declared.

3.3. Potentially harmful conflicts of interest for the Company and customers arising from intragroup relationships

The Company also identifies conflicts of interest that are harmful to the Company and the Company’s clients and which originate between the Group and the Related Persons (CheckSig, Digital Gold Institute S.r.l., CheckSig Suisse AG and the Related Persons). At least the following situations are relevant in this context: a. a Group company is likely to make a financial gain, or avoid a financial loss, at the expense of the Company or the Company’s customers;
b. a group company has an interest in the outcome of a service or activity carried out that is contrary to that of the Company itself;
c. the Connected Person has an economic interest or holds a role in another Group company that conflicts with those of the Company or the Company’s customers; d. a Group company, in particular CheckSig Suisse AG, starts a business or service that conflicts with the Company or the Company’s customers.

3.4. Mapping of conflicts of interest

To keep track of the identified situations of conflict of interest, the Company has prepared a “mapping” in tabular form with the description, in relation to the services or activities provided, of the circumstances that may give rise to a conflict of interest (on this point, see Annex 2 of this policy). It constitutes an integral part of this Policy. Since the Conflicts of Interest Mapping is a static representation, at a predetermined date, of a reality likely to change over time due to factors both endogenous and exogenous to the Company’s sphere of influence, the mapping itself requires updating on the basis, among other things, of information flows internal and external to the company organisation.

3.5. Preparation and updating of the mapping of conflicts of interest

At least every year, or in any case when the Policy is updated, the updating of the mapping is also evaluated on the basis of the identification criteria regulated above. The Compliance function is the entity that supports the census of conflict situations. In particular, the Compliance function receives, from the Connected Person, the following basic information set when completing or changing the declaration referred to in Annex 1 or following potential agreements that the Company intends to undertake with suppliers or partners: a. list of positions held by Connected Persons;
b. list of controlling shareholdings (de jure or de facto) of the Associated Persons in the company;
c. composition of the corporate bodies and ownership structures of the companies with which CheckSig intends to enter into an economic relationship. However, all Company personnel are obliged to promptly communicate the onset, occurrence and disappearance of possible conflict situations to the Compliance function. The Compliance function archives any communications received from CheckSig structures. The Compliance function, based on the information received and on the basis of its own analyses, prepares and updates the mapping of the cases of conflict of interest, with the consultative support of other corporate or external structures as well as adequately qualified external consultants (such as, for example, external law firms). Furthermore, the Compliance function reports to top management, possibly in the context of the audit reports and the annual report, on new conflicts of interest identified, requesting, if necessary, the adoption of new management measures. Based on the proposals put forward by the Compliance Function, it will be up to the Board of Directors:
i. the assessment of the relevance of each case identified;
ii. the definition of the measures deemed suitable for the management of the same case, in compliance with the principles and provisions of the current reference legislation and this Policy. In any case, even in the absence of reporting, annually, when the Policy is reviewed, the company functions, in concert with the Compliance function, evaluate the updating of the Connected Persons, the mapping and the register. A register is established in electronic format in which the individual events of potential conflicts of interest managed are reported in a detailed and progressive manner. The register indicates: (i) the date on which the conflict of interest situation was detected/communicated/managed; (ii) the description of the conflict of interest situation, (iii) the macro-category of conflict based on the situations identified in the mapping; (iv); the subjects involved in the operation subject to conflict of interest; (v) the measures identified/adopted to manage the conflict; (vi) cases in which specific communications were made to the customer. All information relating to any hypothesis of possible conflict of interest is kept in the aforementioned register for at least 5 years. The register is kept by the Compliance function. 6. ## Safeguards and measures for the prevention and management of conflicts of interest Conflicts, once identified, are managed. In this sense, in order to manage the situations of actual conflict detected, CheckSig, also taking into account the principle of proportionality of its corporate organisation, identifies below the organisational, procedural and control measures capable of containing the risk. Furthermore, in the mapping of the Company’s conflict of interest situations, for each type of conflict of interest contained (those with Connected Persons, those prejudicial to the Company and customers), further safeguards are indicated aimed at guaranteeing the management of potential conflict of interest situations.

4.1. General preventive measures

4.1.1. Organizational principals

The organizational safeguards include the adoption of a governance system that allows the potential risk of conflict of interest to be reduced. The organizational structure adopted by the Company provides for the clear definition of roles and responsibilities and the appropriate functional separation of activities deemed incompatible with the prevention of conflicts of interest within the framework of the internal procedural structure. This Policy is an integral part of the procedural corpus adopted internally by CheckSig, aimed at regulating and regulating the various management, functional, operational and organizational areas that characterize its typical activity and the provision of services. The set of internal procedures and regulations of the Company is aimed at regulating the behavior of directors, employees and collaborators, as well as in general of Connected Persons, personal operations and confidentiality obligations governed mainly by the Code of Ethics in its version in force from time to time. This Policy concerns the prevention or management of conflicts of interest and must also be read in conjunction with other already approved activity guidance and control tools. In addition to the channel of this Policy, an internal reporting channel is provided for any issue that may generate or has generated non-legitimate activity in conflict of interest (see in this regard the Policy on Whistleblowing). Executive members of the Board of Directors are prohibited from holding directorships in competing companies outside the same group.

4.1.2. Information barriers (Chinese walls)

The Company adopts measures to prevent the exchange of information between parties involved in potentially conflicting activities (for example, the Finance and Accounting function with respect to the Risk Management, Business Development and Marketing and Communications functions, the Technology area with respect to all other company functions). In particular, the information and documentation relating to each of the conflicting activities is not made available to the resources responsible for other activities; this prohibition can only be waived with prior authorization from the relevant organizational unit managers or the CEO. If there is a potential and mapped conflict of interest, the exchange of information between Connected Persons involved in the activities is controlled. A control is also envisaged on the exchange of information between Connected Persons engaged in activities that involve the risk of a conflict of interest, if the exchange of such information could influence the fulfillment of the duties and responsibilities of such Connected Person towards the Company.

4.1.3. Separate supervision

The subjects involved in activities in conflict of interest are hierarchically subordinate and report their activities to separate managers, without prejudice to the ultimate responsibility of the Board of Directors. For example: the Client Relations function reports to the Compliance function; the Marketing and Communications function reports to the AML function; the Corporate & Business Development function reports to the Risk Management function. The simultaneous or sequential involvement of a Connected Person in separate services or activities is prohibited, where such involvement could compromise the correct management of conflicts of interest.

4.1.4. Measures aimed at preventing or limiting undue influence

The Company prohibits exercising undue influence over the Company and the manner in which a Related Person performs services or relates to the Company. There is also a prohibition on allowing Related Persons who are active outside the Company to have inappropriate influence on the Company. Any person who believes they have been subjected to undue influence in carrying out their assigned activities can make a specific report to be addressed, even anonymously, to the manager of the Compliance function.

4.1.5. Deliberative process and minutes

In the event that the operation in conflict falls within the scope of application of the art. 2391 of the Civil Code, or with a Connected Person, and this generally involves an assessment of adequacy, or in any case it is deemed, following a preliminary assessment by the Board of Directors, to be relevant in terms of the assumption of risks by the company, it must be decided by the Board of Directors in compliance with the following provisions. The company representative involved or in any case who identified the conflict is required to declare to the Board of Directors the existence of a situation of conflict of interest, specifying its nature, terms, origin and extent. Before deciding on the transaction, the Board of Directors verifies the details of the conflict of interest; furthermore, it verifies that the transaction is attributable to ordinary company operations and that it is concluded under conditions equivalent to market standards. After the communication, if the company representative is directly affected by the potential conflict of interest, it is considered whether to physically remove himself from the session. In any case, he abstains, thus abstaining from participating in the discussion and voting relating to the potentially conflicting operation which is the subject of the resolution. The resolution, adequately motivated, must be adopted with the favorable vote of all members of the Board of Directors present at the meeting, without prejudice to the abstention of any company representative concerned. In particular, the resolution of the operations must provide adequate justification regarding: i. the opportunity and economic convenience of the operation;
ii. the reasons for any deviations, in terms of economic-contractual conditions and other characteristic profiles of the operation, compared to standard or market ones. Suitable elements to support this motivation must appear in the documentation accompanying the resolution. All decisions taken in collegial form regarding conflicts of interest are verbalized in an analytical manner and contain the reasons given, including the inherent profiles, the nature and impacts of the conflicts of interest, as well as evidence of an objective decision-making process. In the event that the conflict of interest situation cannot be resolved or uncertainties remain regarding its resolution, the Board of Directors denies authorization to carry out the transaction.

4.1.6. Residual measures

Where the organizational and administrative measures adopted to manage conflicts are not sufficient to ensure, with reasonable certainty, that the risk of harming the interests of customers or the Company is avoided, the latter \ - upon input from the CEO or the head of the Compliance function \ - requires that the adequacy of the operation and in particular the costs and real benefits of the same be assessed in advance. The Board of Directors expresses its opinion in this regard with objective and impartial decisions following the decision-making process indicated above. If the benefits are nevertheless negligible, the Board of Directors will refrain from proceeding. Members of the Board of Directors shall refrain 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 perform his or her duties to the Company may otherwise be compromised.

4.2. Special prevention measures

4.2.1. Remuneration

The remuneration of CheckSig’s staff (employees and collaborators) and members of the Board of Directors, as well as service providers, is designed so as not to create a conflict of interest or an incentive that could lead such persons to favor their own interests or those of the Company, to the potential detriment of any client, or, again, which could lead such persons to favor their own interests to the detriment of the Company. Any direct link between the remuneration provided to employees, delegates, outsourcers, subcontractors or members of the Board of Directors principally engaged in one activity and the remuneration or revenues generated by different employees, delegates, outsourcers, subcontractors or members of the Board of Directors principally engaged in another activity is prohibited, where a conflict of interest may arise in relation to such activities. The remuneration of staff and members of the Board of Directors is fixed, plus a variable form. Variable incentives are approved by the Board of Directors only if they do not put the Company’s liquidity needs or prudential requirements at risk. The variable remuneration is mainly based on quantitative commercial criteria. Quality criteria, if any, will be appropriate in accordance with applicable regulations, fair treatment of customers and the quality of services provided to customers, the absence of complaints from customers. Ex post correction measures linked to the risks to which the staff exposed the Company are also introduced. A balance is maintained between the fixed and variable components of remuneration, the latter cannot be four times higher than the fixed one. The remuneration structure, in fact, does not favor the interests of the Company or of people connected to them against the interests of any client. Any conflict of interest concerning the variable remuneration is subject to the deliberative and verbalization process (see par. 4.1.5 of this Policy).

4.2.2. Personal operations

CheckSig oversees the personal transactions carried out by Connected Persons as part of the services offered by the Company itself (i.e. custody and administration of crypto-assets, exchange of crypto-assets with funds and/or with other crypto-assets, execution of crypto-asset orders) to prevent phenomena that may generate a conflict of interest and any other undue advantage deriving from access to privileged information (as defined in MiCAR, art. 87), or to other confidential information relating to customers or operations with or for customers by virtue of an activity carried out on behalf of CheckSig. A personal transaction is a transaction in crypto-assets (ART, EMT and all other crypto-assets covered by CheckSig’s services) or resulting in a position or exposure in a crypto-asset made by or on behalf of a Connected Person[^1], when at least one of the following criteria is met: i. the Connected Person acts outside the scope of the activities he carries out in a professional capacity; ii. the transaction is made on behalf of one of the following persons:

1. the Connected Person;

2. any person with whom a Related Person has a family relationship or close ties[^2];

3. a person in respect of whom the Connected Person has a direct or indirect material interest in the outcome of the transaction, other than obtaining a fee or commission for executing the transaction. Connected Persons are prohibited from carrying out transactions in crypto-assets: i. in violation of the rules on market abuse (ex Title VI, MiCAR, see also the Policy on combating market abuse and public disclosure of inside information);
   ii. involving the misuse or disclosure of confidential information (including customer transactions, proprietary transactions and strategic initiatives or, more generally, non-public business plans);
   iii. which are in conflict or may be in conflict with an obligation of CheckSig (for example with the best execution duties of the Company in the context of the provision of the crypto-asset order execution service) pursuant to MiCAR or other relevant legislation pursuant to this Policy and sector regulations. Connected Persons are also prohibited from:
   i. suggest, advise or solicit the performance of operations which, if carried out by the Connected Person, would be prohibited;
   ii. carry out operations:

4. relating to crypto-assets included in a so-called Restricted List or a list of crypto-activities maintained by the Compliance function and subject to limitations or prohibitions. This list includes crypto-assets subject to orders of significant amounts by customers or crypto-assets linked to non-public corporate events;

5. during so-called periods of Black Out, i.e. the temporary ban windows established by the Compliance function[^3] during which all operations relating to certain crypto-activities are prohibited (for example during the planning of strategic projects for the Company, audits, infrastructural migrations, sensitive market events). CheckSig informs all Connected Persons of this Policy and requires them to keep it informed of any personal transactions carried out In order to allow the effective application of the safeguards provided for in this Policy, Connected Persons are required to only use the crypto-asset exchange services (with other crypto-assets and/or with funds) and the execution of crypto-asset orders offered by CheckSig. In particular, the commitment of CheckSig employees, interns and collaborators is declared at the time of hiring or in any case at the moment of establishment of the working relationship (on this point, see the ”Declaration of commitment” referred to in Annex 3 of this Policy). Failure to comply with the exclusivity obligation constitutes a violation of this Policy. There are exceptions to the exclusivity obligation, in particular where the Connected Person holds or intends to buy, sell or exchange crypto-assets that are not the subject of the services offered by CheckSig or where there are technical constraints (for example on specific blockchains or unsupported protocols). Exceptions are subject to notification and authorization by the Manager. The Connected Person can request prior authorization by completing the form available in the company drive at the following address Operating Guides (compare the ”Personal Operations Authorization Request Form” referred to in Annex 4 of this Policy). Alternatively, the Connected Person can direct the authorization request to the email address conflittointeressi@checksig.com. In this case, the request must contain the following minimum elements:

6. the type of crypto-asset involved in the operation;
   2. the type of operation (purchase, sale or conversion);
   3. the quantity and the equivalent value in EUR of the operation;
   4. the name of the CASP with which the Connected Person holds an account and/or intends to carry out the operation and/or the address of the self-hosted wallet used. The request must be submitted at least 48 hours before carrying out the operation. Following the aforementioned notification, or before a decision on the execution of the operation is adopted, the Manager carries out a preliminary assessment of compliance with the relevant legislation and if the value of the operation exceeds 10,000 euros, he submits the decision regarding its approval or prohibition on its execution to the Board of Directors. The final decision is communicated to the Connected Person via email within the working day following receipt of the request. The absence of a response from the Manager does not equate to consent on the operation performed. NB: If three or more Connected Persons intend to carry out the same personal transaction, in the same time frame, the same is subjected to scrutiny by the Board of Directors regardless of the value of the transaction itself. The Compliance function keeps an updated register of personal operations which contains at least the following information:
   i. the identification data of the Connected Person who requested the operation;
   ii. the data relating to the notification received (date, time and method of sending);
   iii. if this operation is among those prohibited or subject to limitation;
   iv. the counterparties involved;
   see the date and time of the operation;
   vi. the equivalent value in EUR and the volume of the operation; vii. the crypto-asset and the type of operation;
   viii. the outcome of the decision, or the authorization conditions. The records are kept for a period of 5 years. The Compliance function conducts ex post random checks on compliance with this Policy. In this context, the Compliance function - in the annual report that the same function manager presents to the Board of Directors - includes a note that contains at least the following elements:
   i. the number of requests for prior authorizations received up to 12/31 of each year;
   ii. the total amount and the overall EUR equivalent value of the personal transactions for which authorization has been requested, broken down by type of Connected Person;
   iii. the outcomes of the final decisions (authorization denied or accepted);
   iv. any violations of this Policy and any corrective measures adopted up to 12/31 of each year.

7. Violations

Violations of this Policy, and in particular violations relating to the execution of personal transactions, are assessed by the manager of the Compliance function. The head of the Compliance function can propose to the Board of Directors: a. written warnings;
b. suspension of operational powers;
c. (in the most serious cases) termination of the contractual relationship;
d. corrective measures (targeted training, strengthening of controls, procedural updates);
e. where necessary, reports to the Authorities and liability/compensation actions. 6. ## Training As part of the annual update of the Policy, the Board of Directors evaluates the training needs of company staff. 7. ## ​​Disclosure to the public about conflicts of interest At least every year, and in any case when the Policy is updated, CheckSig publishes this Policy on its institutional website for the benefit of actual and potential customers[^4]. The Policy is published in its full version, edited by the CEO with the support of the managers of the relevant operational company areas, including:

1. a specific and clear description on crypto-asset services, activities or circumstances that give rise, or may give rise, to conflicts of interest (mapping), including the role and capacity in which the Company acts when providing the service to the client;
   2. a specific and clear description of the nature of the conflicts of interest identified;
   3. a specific and clear description of the associated risks identified in relation to the conflicts of interest referred to in point (a);
   4. a specific and clear description of the measures adopted to prevent or mitigate the identified conflicts of interest;
   5. the Compliance function contact to whom actual and potential customers can contact if they need to acquire further information regarding this Policy.
   The Policy is made available to actual and potential customers at any time and in a format accessible on any device (e.g. downloadable document in .pdf[^5] format). The information is made available in the languages ​​used to market the services or communicate with customers, i.e. in Italian and English. The Policy contains the same level of detail for retail, corporate and institutional customers and does not provide differentiation for customers. Depending on the customer’s experience, an email channel is still available to request information or clarifications on the Policy. To this end, the following information is published on the Company’s website: ”The Policy on the management of conflicts of interest and personal operations adopted by the Company is published for information purposes with evidence of the crypto-asset services, the activities or circumstances that give rise, or may give rise, to conflicts of interest, including the role and capacity in which the Company acts when providing the service to the customer. Furthermore, the Policy highlights the potential conflicts of interest identified and the associated risks identified (see Annex 2 - Mapping of Conflicts of Interest). The measures adopted to prevent or mitigate identified conflicts of interest are indicated in the mapping. The Policy is published for the benefit of customers, both actual and potential, without distinction and can be downloaded in .pdf from the link indicated below. The Policy is available in Italian and English. Furthermore, the document contains a link to the Policy itself. For any further information or clarification please contact the Compliance function at the following email address: conflittointeressi@checksig.com.”

2. Information on other types of conflicts of interest

CheckSig will directly and adequately inform customers where it has not been possible to identify suitable organizational measures, or the organizational and/or administrative solutions adopted are not considered sufficient to eliminate the risk of harming customer interests, in order to allow customers to make an informed decision on the services, taking into account the context in which the conflict arises. This information is specific and personalized and describes the hypothesis of conflict of interest, the possible measures and solutions for the specific case, the reasons why such measures and solutions were not considered sufficient to eliminate the risk of harming the interests of customers. It is a measure of extrema ratio, made in written form, and sufficiently detailed, to allow the customer to make an informed decision on the services and evaluate whether to continue with the relationship, taking into account the context in which the conflict of interest arises. This information does not represent a measure for managing or mitigating potential conflicts of interest. [^1]: Within the scope of this par. the definition of Connected Person is here revised in a more restrictive manner, meaning a natural or non-natural person connected to the Company: i) members with qualified participation pursuant to MiCAR; ii) the members of the Board of Directors; iii) CheckSig employees and collaborators. [^3]: Such periods of Black Out are communicated from time to time via email. [^4]: The Policy is published on the website www.checksig.com for retail and corporate customers, while it is published on the website clear.checksig.com for institutional customers. [^5]: The downloadable document also contains the link to the CheckSig institutional website page where the Policy and the information referred to in the following paragraph are published. 7. ::: pdfdownload

Download the document in PDF

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