Conflicts of Interest Disclosure

At SwissBorg, we put our users first. That means identifying, preventing, and managing situations where our interests (or those of our people or partners) could conflict with yours. This page explains, in plain language, where conflicts might arise and how we deal with them.

What is a conflict of interest?

A conflict of interest is any situation where the personal, financial, or professional interests of SwissBorg, our employees, governance members, or related parties could interfere with our duty to act in the best interests of users.

Where might conflicts happen?

Conflicts of interest might happen between:

• BlockNodes and its shareholders or board members;
• BlockNodes and its Users;
• BlockNodes employees and BlockNodes or its Users;
• BlockNodes and the other entities of the group; and
• BlockNodes Users themselves.

How we manage conflicts

We aim to avoid conflicts where possible. When they cannot be fully avoided, we mitigate and disclose them. Key measures include:

• Internal Guidelines: clear internal channels for flagging any situation that harms or could harm users’ interests.
• Segregation of duties: separating teams that could have competing interests and preventing inappropriate influence.
• Internal control system: an internal control framework designed to ensure services are always delivered in users’ best interests.
• Formal policy: there’s a Conflicts of Interest Policy in place that describes common scenarios and the measures we use to prevent or mitigate them.
• Record-keeping and mapping: we maintain a detailed register of all identified potential and actual conflicts of interest. This register is kept up to date, categorised by type and business area, and reviewed regularly by Compliance to ensure that each conflict is either avoided, mitigated, or disclosed as appropriate.
• Information barriers: restricting access to non-public, price-sensitive, or client-specific information on a need-to-know basis.
• Fair pricing & allocation: procedures for placing activities to ensure fair treatment of users and issuer clients.
• Related-party transactions: conducted at market terms, subject to enhanced review and, where applicable, approval by senior governance bodies.
• Independent compliance oversight – a dedicated Compliance function monitors, records, and reviews conflicts and the effectiveness of controls, including an internal conflicts register and Board reporting.
• Employee training and adherence to conduct rules: regular training for directors and employees to raise awareness and ensure effectiveness of the internal process.
• Disclosure to users: where a residual, material conflict remains, we will explain it to you in a durable medium in good time so that you can make an informed decision about whether to proceed.

Specific disclosures

Below are examples of situations—relevant to our services—where a conflict could arise and how we address it. We will make a clear, timely disclosure to you where a material, residual conflict remains.

• Placing services for issuers. We provide placing/distribution services to crypto-asset issuers. This can create tensions between the interests of issuer clients and users trading the same assets. We separate pricing and allocation decisions from user-facing teams, remove remuneration links between these activities, and disclose any residual conflicts. We do not allow recommendations to be influenced by current or future issuer relationships.
• Incentives: A potential conflict may arise where we receive financial incentives from third parties. This can include payments, cost-sharing arrangements, rebates, or other benefits from service providers, partners, or affiliates, for example, in connection with listing certain crypto-assets or related services. Such arrangements could create an incentive to promote a product or service because of the financial benefit, rather than solely on the basis of what is in the user's best interests.
• BlockNodes acting as a member of a Group: A potential conflict may arise from our membership in a wider corporate group. Overlapping business activities and interrelationships within the group can create situations where decisions, recommendations, or service arrangements, such as which entity a user contracts with, could favor group interests over those of the user. While we work to ensure transparency and fair treatment, these risks cannot be entirely eliminated and may, in some cases, affect factors such as pricing, costs, or the range of available products and services.
• Incentives related to trading volumes. Our revenues may rise with user trading volumes. We mitigate this through fair pricing/allocation controls and compliance oversight to ensure users’ interests remain paramount.
• Affiliations and proprietary interests. The BORG token was issued by SBorg SA (the holding entity for the SwissBorg group). Certain shareholders and directors of that company are also shareholders/directors of BlockNodes and hold BORG. Any action that could affect the token’s value or awareness is subject to prior compliance review, and we disclose these interests to users in good time so they can make an informed decision.

If you would like more detail about particular situations, please contact us (see How to contact us below).

Oversight and review

• Our Board approves the framework, and senior management reviews it at least annually.
• The Legal team maintains the internal conflicts register and reports material matters to the Board.

How to contact us

Questions about this notice? Reach our team at legal@swissborg.com.

Updates

We may update this page when our services or regulatory requirements change. The effective date will always be shown at the top.