Conflict of Interest Policy

Updated: 2026.02.21

Slice Financial Conflict of Interest Policy

1. Definitions

  • Slice Financial / “The Company” / “We” / “Our”: All corporate entities, including our Delaware Incorporation headquarters, Slice Gmbh (Europe), our Middle East subsidiaries, and any joint ventures over which Slice Financial is able to exercise control regarding policies and procedures.

  • Staff / “You” / “Your”: All Slice Financial directors, officers, agents, employees, temporary workers, interns, consultants, and contractors, as well as any vendors acting for or on behalf of Slice Financial, regardless of the duration of their relationship or contract.

2. Overview Slice Financial has a fiduciary duty to minimize the possibility of conflicts of interest between our Staff and our clients. This policy sets out our framework for the identification, documentation, monitoring, and management of conflicts of interest. Conflicts of interest must always be resolved by putting the clients’ interests ahead of the Company’s.

This policy applies to all Staff. Employees must familiarize themselves with these requirements and fulfill the responsibilities outlined below.

Examples of conflicts of interest include, but are not limited to:

  • Slice Financial obtaining confidential information relating to an existing or former client that could be unfairly used to the advantage of other clients.

  • Slice Financial engaging services from an entity (such as a third-party vault, property manager, or appraiser) in which the Company’s Board, directors, or representatives hold controlling interests or substantial shareholdings.

  • Slice Financial employees possessing outside interests that conflict with their fiduciary responsibilities, such as sitting on the board of an existing or potential client’s company.

Slice Financial adopts the following approach to address a conflict of interest if it occurs or is likely to occur:

  • Decline to engage in the conflicted activity or transaction;

  • Disclose the material conflict of interest transparently to the client; and

  • In certain cases, seek the client’s explicit consent or a formal waiver of the conflict.

3. Conflicts Identification To proactively identify actual or potential conflicts of interest, every Employee must complete the Conflicts of Interest Declaration Form (Appendix B) prior to commencing work at Slice Financial. Staff must also promptly notify the Chief Compliance Officer (CCO) of any changes to their declared status.

The Declaration Form requires the disclosure of information relating to service on external boards of directors, investment committees, outside business ventures, and other activities. Such activities could lead to potential conflicts of interest or insider trading risks that may interfere with an Employee’s duties to Slice Financial.

If the CCO receives such a report, the Company is committed to disclosing the nature of the conflict to any affected clients. Should an Employee become aware of a potential or actual conflict of interest during their tenure, they must report it to the Compliance Department immediately and seek further guidance.

4. Conflicts Controls To promote fair and transparent markets, prevent conflicts, and ensure compliance with all relevant global regulatory frameworks (including SEC, MiFID/MICA, and VARA/DLD), Slice Financial implements strict policies to monitor the information, transactions, and positions of its employees.

4.1 Information Barriers The Company maintains robust Information Barriers designed to restrict the flow of sensitive information between different departments. These restrictions ensure that employees can execute business on behalf of clients without being influenced by non-public information held elsewhere within the Company. Furthermore, the Company strictly segregates duties between employees engaged in trading/business operations and those responsible for the recording and reconciliation of relevant data.

4.2 Board Members Should a member of the Board disclose a potential conflict of interest regarding a specific transaction, the remaining Board members hold the authority to request that the conflicted member leave the meeting. The conflicted member shall have no right to vote on the decision and must avoid influencing the remaining members either inside or outside the meeting. The Company Secretary shall formally record the conflict in the relevant Board minutes.

4.3 Employees’ Outside Business Activities Employees are prohibited from serving on the boards of directors, acting as an employee, or consulting for any outside for-profit company unless the service has been formally approved in writing by the Managing Director. Employees must provide full details concerning any proposed outside activity, including the estimated hours involved and the expected compensation. All such information will be provided to the CCO for recordkeeping.

4.4 Transaction Restrictions The following personal account trading restrictions apply to all employees on Slice Financial’s platform: a) Employees are prohibited from engaging in transactions, holding positions, or having economic interests in the Virtual Assets listed on the Company’s restricted internal control list. b) Employees are prohibited from holding any shareholding or directorship in legal entities listed on the internal control list. c) Employees are required to obtain prior written approval under the applicable Market Conduct Rulebooks (e.g., VARA) and provide necessary regulatory notifications.

4.5 Prior Approval Employees must obtain written approval from the Compliance Committee prior to taking actions reasonably likely to cause a conflict, including: a) Opening, modifying, or closing any Virtual Asset positions held directly or indirectly. b) Increasing or decreasing their shareholding in any legal entity other than Slice Financial. c) Taking up a directorship in any legal entity other than Slice Financial. d) Any additional actions stated by Slice Financial under regulatory Market Conduct rules. e) Note on Corporate Trading: Slice Financial may use corporate funds to take proprietary positions in Virtual Assets; however, it strictly maintains the segregation of its own assets from clients’ assets. Firewalls and access controls restrict information available to personnel handling the Company’s treasury.

4.6 Disclosure & Remediation At least every six (6) months, Slice Financial requires employees to report: a) Virtual Asset Positions: Descriptions, identifiers, transaction histories, sizes of positions, and the nature of transactions for any Virtual Assets held directly or indirectly. b) Outside Shareholdings/Directorships: The legal entity’s name, the purpose of the shareholding/directorship, the shareholding percentage, and details of any remuneration.

If Slice Financial has reason to believe an employee has caused or will cause a conflict of interest, the Company will take all necessary actions to remove it, including: a) Requiring the divestment of the relevant Virtual Asset positions or shareholdings. b) Requiring resignation from the board of the conflicting entity. c) Any other disciplinary or structural action required to neutralize the conflict.

4.7 Other Measures

  • Remuneration policies are structured to prevent the incentivization of conflicted behavior.

  • Strict protocols govern the reporting of substantial gifts, entertainment, hospitality, and inducements.

  • Periodic training is provided to all employees on the identification and management of conflicts of interest.

5. Recordkeeping The Company maintains a Register of Conflicts of Interest to document any identified conflicts and the management or remedial measures taken. All records are stored securely in accordance with regulatory retention laws.

6. Review of this Policy The Human Resources and Compliance Departments will review and update this Policy on a periodic basis. Material changes will be circulated to all relevant stakeholders.


7. Appendix A – Reserve Assets & Tokenization Operations This appendix covers specifics linked to Reserve Assets backing Asset-Referenced Virtual Assets (ARVAs) and tokenized Real World Assets (RWAs) issued under regulatory regimes such as VARA.

7.1 Scope Applies to all officers, directors, employees, contractors, and affiliated entities involved in the governance, structuring, valuation, custody, or oversight of the underlying physical assets (e.g., real estate, classic cars) and Reserve Assets.

7.2 Identification of Conflicts The Issuer shall implement a framework to identify conflicts, including:

  • Self-dealing or affiliated transactions relating to Reserve Assets.

  • Preferential treatment of specific third-party storage vaults (e.g., facilities in Vienna, Dubai, NJ, Florida, Hong Kong) or custodians.

  • Using insider knowledge to benefit from changes in Reserve Asset composition or token generation events (TGEs).

7.3 Prevention and Management The Issuer shall adopt measures to mitigate conflicts, including:

  • Separation of duties regarding Reserve Asset decisions.

  • Utilizing strictly independent, licensed third-party custodians and valuation agents for appraisals.

  • Implementing arm’s length policies for related-party transactions.

7.4 Public Disclosure & Governance The Issuer shall publicly disclose any material conflict of interest related to Reserve Assets via white papers, periodic reports, and public channels. A designated senior compliance officer or committee is responsible for monitoring compliance, reviewing disclosures, and reporting breaches to the Board and relevant regulatory authorities (e.g., VARA). Records of these conflicts shall be retained for no less than eight (8) years.


8. Appendix B – Conflicts of Interest Declaration Form

Slice Financial is required to monitor employee circumstances that may pose a potential conflict with the securities and virtual assets we deal with. Please complete this questionnaire and promptly notify the Compliance Department if any information ceases to be true and complete.

1) Is there any entity or person other than Slice Financial that you expect to: i. Receive compensation from? ii. Take an active advisory role in? iii. Serve as an employee, officer, director, partner, member, investment committee member, or similar position? iv. Provide any advice to regarding investments?

[ ] Yes. Please provide details below:



[ ] No

2) Are you or any of your immediate family members also officers, directors, partners, members, or owners of greater than 5% of the voting securities of a public company (or any other company) that may be the subject of, or relate to, an investment or potential investment by Slice Financial?

[ ] Yes. Please provide details below:



[ ] No

3) Are there any other circumstances or relationships which may create a potential conflict of interest between you and Slice Financial or its clients? (Note: If the potential conflict is due to an affiliated person [spouse, child, stepchild, adopted child, parent, sibling], please state their identity and your relationship to them).

[ ] Yes. Please provide details below:



[ ] No

Declaration: I confirm that the information provided above is true and complete. I agree to promptly notify Slice Financial of any changes to the above information.


Employee/Contractor Name (Printed)


Employee/Contractor Signature


Date

© 2026 Slice financial inc

Socials

Office Location

Privacy Preference

We use cookies on our website. Some of them are essential, while others help us to improve this website and your experience.

Ok / Back to Slice