Conflict of Interest Disclosure

 

 1. Information on the resolution of conflicts of interest situations

The following section describes the general dealing of Alteway (Alteway UAB or Altepay.com SIA) regarding conflict of interests. Alteway strives to avoid any potential conflicts of interest between the customers and Alteway or any partner companies, as well as between other companies of the Alteway Group or between customers themselves.

A conflict of interest is defined as a situation in which the personal, financial, or other interests of Alteway, its employees, or its associated parties may potentially interfere with the ability to act impartially and in the best interests of customers and stakeholders.

A conflict of interest exists when the interests of Alteway and its obligation to protect the best interests of the customer conflict with one another. Alteway must also gain an advantage while, at the same time, the customer suffers or may suffer a disadvantage.

2. Potential conflict of interest situations

Conflicts of interest can take place:

• between customers and Alteway;
• between shareholders, members of the management and Alteway;
• between Alteway and its employees;
• between customers themselves.

3. Information on the acceptance of benefits

Advantages include, for example, commissions from third parties in connection with crypto asset services for customers. This category also includes non-monetary benefits from other service providers in connection with the offered transactions, such as financial analyses or other information material, training, technical services and the opportunity to access third-party information systems.

4. Information on the management of conflict of interest situations

Members of the management, employees and all business partners of Alteway act in a lawful, diligent and honest manner in the interest of the customer pursuant to the relevant legal provisions. The aim of these regulations is to identify conflicts of interest at an early stage, to avoid them as much as possible and where not possible - disclose them.

Alteway has implemented measures, internal policies and procedures appropriate to its size and organisation and the nature, scope and complexity of its business to prevent, disclose and manage conflicts of interest.

These guidelines and measures are reviewed by the Compliance department on an ad hoc basis, as well as at least annually, and are adjusted as necessary to ensure the best possible sustainable and effective management and avoidance of conflicts of interest.

The measures mentioned above include, in particular:

• Internal guidelines for raising and managing circumstances that significantly harm or could harm the interests of one or more customers.
• Effective internal control system to ensure that activities on behalf of customers or services provided to the customer are conducted in their best interest.
• Conflict of Interest Policy with detailed descriptions and mitigation measures to actual and potential conflict of interest situations.
• Independent Compliance function with employees properly skilled and trained to effectively manage conflict of interest situations.
• Monitoring of the measures taken by the Compliance officer to avoid conflicts of interest.
• Independent confidentiality areas to ensure that the disclosure of information within the Alteway does not exceed what is necessary for conducting regular business proceedings (need-to-know principle).
• Remuneration policy with clear rules for employee remuneration.
• Monitoring of employees’ personal transactions.
• Comprehensive compliance training program for employees to create awareness and to foster a culture of integrity.
• Alteway does not provide any advisory services or make any investment decisions for customers. Education material and controls are in place to support employees that have customer contact (like support) to stay within these guidelines.

5. Disclosure of conflict of interest situations

In individual cases, conflicts of interest may be unavoidable. In this case, Alteway will inform the customers regarding the conflict of interest and disclose it accordingly. It is then up to the customers to decide whether they wish to conclude the transaction despite the conflict.

The following potential conflicts of interest are disclosed by Alteway.

5.1. Potential conflict of interest situation in connection with own products

This potential conflict of interest situation may arise between the customer and Alteway in relation to Alteway promoting crypto assets for which it also provides services, such as exchange of crypto-assets. This creates a situation where Alteway may have a financial interest that conflicts with its duty to act in the best interests of the customer. In such cases, there is a risk that Alteway may prioritize its own products or those of affiliated entities over others, potentially leading to biased promotion of its own products.

5.2. Potential conflict of interest situation in connection with remuneration

This potential conflict of interest situation arises between the customer and Alteway in relation to the remuneration of employees. Specifically, employees of certain departments may receive remuneration, such as bonuses or commissions, that are linked to the promotion, sale, or recommendation of certain crypto assets. This may create a conflict where Alteway or its employees are financially incentivized to promote specific products, even when they may not align fully with the customer’s best interests.

5.3. Potential conflict of interest situations in connection with Alteway acting as the counterparty to customer trades

This potential conflict of interest arises from the fact that customers may be trading directly against Alteway, which acts as the counterparty in these transactions. In such situations, Alteway is taking an opposing position to its customers for a certain time by holding or acquiring crypto assets for its own account until it is exchanged with the customer. It might create a conflict where Alteway may have financial incentives that could influence its behavior in a manner that is not aligned with the best interests of the customer.