Conflict of interest policy

1. Purpose and Scope

As Paribu Kripto Varlık Alım Satım Platformu A.Ş. (Paribu Crypto Asset Trading Platform Inc.) ("Paribu"), our fundamental principle is to act in a fair, honest, and transparent manner, observing customer interests and market integrity in the investment and ancillary services we provide.

This policy sets out the procedures and principles for the prevention, identification, management, and transparent disclosure of the conflicts of interest set out below:

1. Between Paribu and customers,
2. Between customers themselves,
3. Between Paribu employees and customers,
4. Between Paribu and its employees — conflicts of interest that may arise or have the potential to arise are within the scope of this Policy.

In this scope, in order to prevent conflicts of interest, the necessary organisational structure has been established within Paribu, duties and responsibilities have been determined, and administrative controls and audit mechanisms have been put in place. In cases where a conflict of interest cannot be entirely prevented, customers must be meaningfully informed before the relevant activity is carried out.

The Policy covers all directors, employees, partners, affiliates of Paribu, and persons directly or indirectly connected with them.

2. Basis

This Policy has been prepared on the basis of the Capital Markets Law No. 6362, Articles 35/A and 35/C added to the said Law by Law No. 7518 dated 02.07.2024, the Communiqués No. III-35/B.1, III-35/B.2, and VII-128.10 published by the Capital Markets Board (SPK), and Paribu's employment contracts, disciplinary regulations, information security policy, code of ethics, and other internal regulations.

3. Definition of Conflict of Interest

A conflict of interest is a situation in which the interests of Paribu, its employees, directors, or related parties conflict with the interests of customers, and this situation may put the impartial and honest provision of services at risk and may produce results against or in favour of any party. This situation also covers conflicts of interest that may arise between one customer and another customer.

4. Situations That May Cause a Conflict of Interest

Situations that may give rise to a conflict of interest at Paribu may vary according to the specifics of the actual case; however, at a minimum, the following situations are evaluated within this scope:

1. Paribu or related parties obtaining a financial gain at the expense of the customer or avoiding a financial loss,
2. Even though the customer has no interest, Paribu or related parties obtaining a benefit through the relationship established with the customer,
3. Obtaining advantage by preferring one customer or customer group over others,
4. Obtaining non-standard fees, commissions, or benefits from third parties due to transactions related to the customer,
5. Obtaining direct benefit through the listing of crypto assets belonging to Paribu or related persons, or through making mandatory the use of distributed ledger infrastructure belonging only to such parties,
6. Paribu carrying out transactions that may produce a result in its own favour by taking a position against the customer,
7. Paribu or its liquidity providers carrying out transactions that have the potential to directly affect price formation,
8. During order execution, the orders submitted by Paribu or related parties being executed with priority compared to customer orders entered at the same price,
9. Persons with access to inside information using this information for their own benefit or for the benefit of third parties,
10. Earnings being obtained from price movements by taking short-term speculative positions following listing.

In addition, the following individual situations may also create a conflict of interest:

1. Personal Investments: Paribu employees making investments — in advance or in a manner that provides advantage — in crypto assets that are traded by Paribu or planned to be listed, in a way that gives rise to a conflict of interest,
2. Family and Close Relationships: Family members or relatives of employees holding positions with decision-making authority in institutions that have a business relationship with Paribu or that are competitors, or being in a financial/interest relationship with such institutions,
3. External Activities: Paribu employees working in or providing consultancy to competing companies, or being in a relationship of interest, without the Institution's knowledge,
4. Gifts and Hospitality: Employees accepting gifts, discounts, or other advantages of a value that may create a conflict of interest from current or potential customers, suppliers, or business partners,
5. Personal Relationships: The employee being in a personal relationship with the customer or business partner, and this situation having the potential to influence, or appear to influence, decision-making processes.

5. Conflict of Interest Measures

In order to prevent and manage conflicts of interest at Paribu, the following structural, technical, and organisational measures are applied:

1. Order Execution Fairness: Customer orders are executed according to the principles of price and time priority. For orders at the same price level, time priority is taken as the basis; no privilege is granted to any customer, employee, or related party.
2. Equal Treatment of Customers: Discrimination on the basis of gender, religion, language, race, ethnic origin, age, or similar reasons is not permitted. Services provided to customers cannot be differentiated in line with these principles.
3. Impartiality and Information Barriers in the Listing Process: Decisions regarding the listing and initial offering of crypto assets are taken by independent committees on the basis of objective criteria. Employees involved in the listing process are subject to information barriers and access restrictions.
4. Information Security and Confidentiality: Customer data are processed only for the purpose of providing services; these data cannot be taken out of the institution unless required by business, and may be disclosed only to legal authorities within the scope of the relevant legislation.
5. Limitations on Access to Inside Information: For employees with access to inside information, information barriers, access controls, and organisational separation measures are applied. The transaction records of these employees are logged and audited regularly.
6. Segregation of Duties and Authority: The distribution of duties and transaction authorities of employees is structured in a way that does not give rise to a conflict of interest. Duties that may create a conflict of interest are carried out within separate units.
7. Transaction Restrictions on Personal Accounts: Employees may only carry out transactions through individual accounts opened in their own names. These transactions are regularly monitored by the Internal Control and Compliance units.
8. Salary and Bonus Systems: Performance-based remuneration systems cannot be structured in a way that may produce results against customers. Remuneration policies are designed in a way that does not encourage conflicts of interest.
9. Restriction on Gifts and Incentives: Paribu employees cannot accept gifts or incentives of a value that may influence decision-making processes. Internal Control Unit approval is required for gifts above a certain monetary limit.
10. Compliance with Legislation and Training: All employees are obliged to fully comply with the applicable regulatory legislation, Paribu procedures, and internal regulations on the prevention of conflicts of interest. Employees involved in capital market activities are required to hold the necessary licences and to fulfil their registry obligations.

6. Situations Contrary to the Policy

In the event of any situation, whether covered by this policy or not, that carries a conflict of interest risk, the following processes are operated:

1. Employees immediately report their suspicions and concerns regarding situations that may potentially create a conflict of interest to the Paribu Internal Control Unit.
2. Customers communicate their concerns and complaints regarding conflicts of interest through the Paribu Customer Services channel.
3. The relevant notifications are reviewed by the Internal Control Unit, and coordination with the Compliance and Legal units is provided where deemed necessary.
4. In the event that a situation causing a conflict of interest is identified:
5. If customer harm has occurred, compensation for the damage is provided.
6. Action is taken against the employee causing the situation in question within the framework of the Disciplinary Regulation.
7. Oversight, identification, and follow-up of risks related to conflicts of interest is the responsibility of the Paribu Internal Control Unit.
8. The Paribu Board of Directors is ultimately responsible for the implementation and adequacy of this policy.

7. Records and Reporting

All conflict of interest suspicions, identifications, and measures taken in this scope reported to the Paribu Internal Control Unit are recorded in a chronological and auditable manner, together with the date, summary of the event, the assessment of whether a conflict of interest exists, and the controls and measures applied. These records are reported to the Paribu Board of Directors on a quarterly basis. Reporting includes analyses and assessments regarding the type, frequency, scope, and actions taken in respect of conflicts of interest. All records are kept securely for the minimum retention period stipulated in the legislation and are kept ready to be presented without delay if requested by the Capital Markets Board.

8. Audit, Monitoring, and Implementation Principles

All Paribu employees are obliged to immediately report in writing to the Paribu Internal Control Unit any situation that may create or be perceived to create a conflict of interest while performing their duties and responsibilities.

Employees act in full cooperation with the Internal Control and Compliance Units in the prevention and resolution of existing or potential conflicts of interest. After the notifications, whether a conflict of interest exists is evaluated by the Paribu Internal Control Unit. If deemed necessary, the Board of Directors is informed, and actions to eliminate the conflict of interest are determined and implemented. Measures taken in respect of situations where a conflict of interest is identified, the steps taken, and the related assessments are recorded and kept in a manner that may be referenced in the future. Sanctions may be applied to employees acting contrary to the provisions of the policy under the Paribu Disciplinary Regulation; depending on the severity of the violation, the necessary actions, including termination of the employment contract, may be initiated.

9. Review of the Policy

This policy is periodically reviewed by the Internal Control and Compliance Units in line with the applicable legislation, sector practices, and the organisational needs of the company. It is updated as necessary and submitted for the approval of the Board of Directors. Updated policy versions are announced to all employees through internal systems.

10. Effectiveness

This Conflict of Interest Policy enters into force on the date it is approved by the Paribu Board of Directors. The current version of the policy is announced to employees through internal communication channels and to users through the Paribu website.

Related articles

• Order execution policy
• Crypto and cash asset transfer policy
• Crypto asset services framework agreement
• Legal notices

1. Purpose and Scope

As Paribu Kripto Varlık Alım Satım Platformu A.Ş. (Paribu Crypto Asset Trading Platform Inc.) ("Paribu"), our fundamental principle is to act in a fair, honest, and transparent manner, observing customer interests and market integrity in the investment and ancillary services we provide.

This policy sets out the procedures and principles for the prevention, identification, management, and transparent disclosure of the conflicts of interest set out below:

1. Between Paribu and customers,
2. Between customers themselves,
3. Between Paribu employees and customers,
4. Between Paribu and its employees — conflicts of interest that may arise or have the potential to arise are within the scope of this Policy.

In this scope, in order to prevent conflicts of interest, the necessary organisational structure has been established within Paribu, duties and responsibilities have been determined, and administrative controls and audit mechanisms have been put in place. In cases where a conflict of interest cannot be entirely prevented, customers must be meaningfully informed before the relevant activity is carried out.

The Policy covers all directors, employees, partners, affiliates of Paribu, and persons directly or indirectly connected with them.

2. Basis

This Policy has been prepared on the basis of the Capital Markets Law No. 6362, Articles 35/A and 35/C added to the said Law by Law No. 7518 dated 02.07.2024, the Communiqués No. III-35/B.1, III-35/B.2, and VII-128.10 published by the Capital Markets Board (SPK), and Paribu's employment contracts, disciplinary regulations, information security policy, code of ethics, and other internal regulations.

3. Definition of Conflict of Interest

A conflict of interest is a situation in which the interests of Paribu, its employees, directors, or related parties conflict with the interests of customers, and this situation may put the impartial and honest provision of services at risk and may produce results against or in favour of any party. This situation also covers conflicts of interest that may arise between one customer and another customer.

4. Situations That May Cause a Conflict of Interest

Situations that may give rise to a conflict of interest at Paribu may vary according to the specifics of the actual case; however, at a minimum, the following situations are evaluated within this scope:

1. Paribu or related parties obtaining a financial gain at the expense of the customer or avoiding a financial loss,
2. Even though the customer has no interest, Paribu or related parties obtaining a benefit through the relationship established with the customer,
3. Obtaining advantage by preferring one customer or customer group over others,
4. Obtaining non-standard fees, commissions, or benefits from third parties due to transactions related to the customer,
5. Obtaining direct benefit through the listing of crypto assets belonging to Paribu or related persons, or through making mandatory the use of distributed ledger infrastructure belonging only to such parties,
6. Paribu carrying out transactions that may produce a result in its own favour by taking a position against the customer,
7. Paribu or its liquidity providers carrying out transactions that have the potential to directly affect price formation,
8. During order execution, the orders submitted by Paribu or related parties being executed with priority compared to customer orders entered at the same price,
9. Persons with access to inside information using this information for their own benefit or for the benefit of third parties,
10. Earnings being obtained from price movements by taking short-term speculative positions following listing.

In addition, the following individual situations may also create a conflict of interest:

1. Personal Investments: Paribu employees making investments — in advance or in a manner that provides advantage — in crypto assets that are traded by Paribu or planned to be listed, in a way that gives rise to a conflict of interest,
2. Family and Close Relationships: Family members or relatives of employees holding positions with decision-making authority in institutions that have a business relationship with Paribu or that are competitors, or being in a financial/interest relationship with such institutions,
3. External Activities: Paribu employees working in or providing consultancy to competing companies, or being in a relationship of interest, without the Institution's knowledge,
4. Gifts and Hospitality: Employees accepting gifts, discounts, or other advantages of a value that may create a conflict of interest from current or potential customers, suppliers, or business partners,
5. Personal Relationships: The employee being in a personal relationship with the customer or business partner, and this situation having the potential to influence, or appear to influence, decision-making processes.

5. Conflict of Interest Measures

In order to prevent and manage conflicts of interest at Paribu, the following structural, technical, and organisational measures are applied:

1. Order Execution Fairness: Customer orders are executed according to the principles of price and time priority. For orders at the same price level, time priority is taken as the basis; no privilege is granted to any customer, employee, or related party.
2. Equal Treatment of Customers: Discrimination on the basis of gender, religion, language, race, ethnic origin, age, or similar reasons is not permitted. Services provided to customers cannot be differentiated in line with these principles.
3. Impartiality and Information Barriers in the Listing Process: Decisions regarding the listing and initial offering of crypto assets are taken by independent committees on the basis of objective criteria. Employees involved in the listing process are subject to information barriers and access restrictions.
4. Information Security and Confidentiality: Customer data are processed only for the purpose of providing services; these data cannot be taken out of the institution unless required by business, and may be disclosed only to legal authorities within the scope of the relevant legislation.
5. Limitations on Access to Inside Information: For employees with access to inside information, information barriers, access controls, and organisational separation measures are applied. The transaction records of these employees are logged and audited regularly.
6. Segregation of Duties and Authority: The distribution of duties and transaction authorities of employees is structured in a way that does not give rise to a conflict of interest. Duties that may create a conflict of interest are carried out within separate units.
7. Transaction Restrictions on Personal Accounts: Employees may only carry out transactions through individual accounts opened in their own names. These transactions are regularly monitored by the Internal Control and Compliance units.
8. Salary and Bonus Systems: Performance-based remuneration systems cannot be structured in a way that may produce results against customers. Remuneration policies are designed in a way that does not encourage conflicts of interest.
9. Restriction on Gifts and Incentives: Paribu employees cannot accept gifts or incentives of a value that may influence decision-making processes. Internal Control Unit approval is required for gifts above a certain monetary limit.
10. Compliance with Legislation and Training: All employees are obliged to fully comply with the applicable regulatory legislation, Paribu procedures, and internal regulations on the prevention of conflicts of interest. Employees involved in capital market activities are required to hold the necessary licences and to fulfil their registry obligations.

6. Situations Contrary to the Policy

In the event of any situation, whether covered by this policy or not, that carries a conflict of interest risk, the following processes are operated:

1. Employees immediately report their suspicions and concerns regarding situations that may potentially create a conflict of interest to the Paribu Internal Control Unit.
2. Customers communicate their concerns and complaints regarding conflicts of interest through the Paribu Customer Services channel.
3. The relevant notifications are reviewed by the Internal Control Unit, and coordination with the Compliance and Legal units is provided where deemed necessary.
4. In the event that a situation causing a conflict of interest is identified:
5. If customer harm has occurred, compensation for the damage is provided.
6. Action is taken against the employee causing the situation in question within the framework of the Disciplinary Regulation.
7. Oversight, identification, and follow-up of risks related to conflicts of interest is the responsibility of the Paribu Internal Control Unit.
8. The Paribu Board of Directors is ultimately responsible for the implementation and adequacy of this policy.

7. Records and Reporting

All conflict of interest suspicions, identifications, and measures taken in this scope reported to the Paribu Internal Control Unit are recorded in a chronological and auditable manner, together with the date, summary of the event, the assessment of whether a conflict of interest exists, and the controls and measures applied. These records are reported to the Paribu Board of Directors on a quarterly basis. Reporting includes analyses and assessments regarding the type, frequency, scope, and actions taken in respect of conflicts of interest. All records are kept securely for the minimum retention period stipulated in the legislation and are kept ready to be presented without delay if requested by the Capital Markets Board.

8. Audit, Monitoring, and Implementation Principles

All Paribu employees are obliged to immediately report in writing to the Paribu Internal Control Unit any situation that may create or be perceived to create a conflict of interest while performing their duties and responsibilities.

Employees act in full cooperation with the Internal Control and Compliance Units in the prevention and resolution of existing or potential conflicts of interest. After the notifications, whether a conflict of interest exists is evaluated by the Paribu Internal Control Unit. If deemed necessary, the Board of Directors is informed, and actions to eliminate the conflict of interest are determined and implemented. Measures taken in respect of situations where a conflict of interest is identified, the steps taken, and the related assessments are recorded and kept in a manner that may be referenced in the future. Sanctions may be applied to employees acting contrary to the provisions of the policy under the Paribu Disciplinary Regulation; depending on the severity of the violation, the necessary actions, including termination of the employment contract, may be initiated.

9. Review of the Policy

This policy is periodically reviewed by the Internal Control and Compliance Units in line with the applicable legislation, sector practices, and the organisational needs of the company. It is updated as necessary and submitted for the approval of the Board of Directors. Updated policy versions are announced to all employees through internal systems.

10. Effectiveness

This Conflict of Interest Policy enters into force on the date it is approved by the Paribu Board of Directors. The current version of the policy is announced to employees through internal communication channels and to users through the Paribu website.