Purpose and commitment

Northstake is committed to acting honestly, fairly, and professionally, ensuring that our services are always delivered in the best interests of our clients. This disclosure outlines how we identify, prevent, manage, and transparently disclose conflicts of interest in accordance with Article 72 of Regulation (EU) 2023/1114 (MiCA) and Commission Delegated Regulation (EU) 2025/1142.

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Scope

This policy applies to:

• Northstake's management, employees, and any controlled or affiliated entities.
• Situations involving competing interests between Northstake and our clients, or between multiple clients whose interests may diverge.

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Our Service and Role

Northstake is authorised by the Danish Financial Supervisory Authority (Finanstilsynet, FT-ID 17520) to provide the following crypto-asset services:

• Custody and administration of crypto-assets on behalf of clients
• Execution of orders for crypto-assets on behalf of clients
• Transfer services for crypto-assets on behalf of clients.

In all services, Northstake acts on behalf of and in the interest of the client.

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identified Conflict Scenarios

Given the nature of our services, the following situations have been identified as giving rise to actual or potential conflicts of interest:

• Northstake and its clients: Northstake earns service fees from order execution and custody. This could create an incentive to favour transaction volume over client outcomes. This is mitigated by our best execution obligation under Article 78 MiCAR, documented execution policies, and a fee structure that is disclosed to clients before each transaction.
• Between clients: Where multiple clients submit orders in the same crypto-asset, one client's execution could affect market conditions for another. This is mitigated by processing orders in strict chronological order and applying standardised allocation procedures for partial fills.
• Employees and personal transactions: Employees may hold crypto-assets that are also custodied or traded by Northstake on behalf of clients. This is mitigated by mandatory disclosure of personal holdings, a prohibition on insider trading and front-running, and a pre-clearance requirement for personal transactions in relevant assets.
• Management body and outside interests: Members of the management body may hold positions or interests in entities related to the crypto-asset industry. This is mitigated by mandatory annual disclosure of outside interests, abstention from decisions where a conflict exists, and a prohibition on holding management positions in competing crypto-asset service providers.
• Shareholders and related-party transactions: Shareholders who are also clients or suppliers could seek preferential treatment. This is mitigated by requiring all related-party transactions to be conducted at arm's length with independent review.
• Remuneration: Variable remuneration could incentivise staff to favour certain clients or transaction types. This is mitigated by ensuring that variable remuneration is never based solely on volumes or revenues.

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Measures to prevent and manage conflicts

Northstake implements the following measures:

• Segregation of duties across trading, compliance, and risk management functions.
• Information barriers restricting access to confidential client data on a least-privilege basis.
• Dedicated client accounts for funds and crypto-assets, fully segregated from Northstake's own treasury at all times.
• Best execution documented for every client order, with no payment-for-order-flow or rebate arrangements with execution venues.
• Pre-clearance and monitoring of personal transactions by employees and management in relevant crypto-assets.
• Annual disclosure of outside interests by all employees and management body members.
• Gifts and hospitality policy requiring reporting of any benefit above EUR 100.
• Conflict of interest register recording all identified actual and potential conflicts, the measures taken, and their outcomes. Records are retained for a minimum of five years.

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Roles & Oversight

The management body is responsible for adopting, implementing, and periodically reviewing the conflict of interest policies and procedures. A designated person is responsible for the ongoing identification, prevention, management, and disclosure of conflicts, reporting directly to the management body. Adequate resources and ongoing training are provided to ensure effectiveness.

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Disclosure to clients

Where a conflict of interest cannot be adequately prevented or managed, Northstake will disclose the conflict to the affected client before proceeding with the relevant service. The disclosure will include a description of the conflict, the risks to the client, and the measures taken to mitigate it. If disclosure alone is insufficient to protect the client's interests, Northstake may decline to act.

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Review & Continuous Improvement

At least annually, this policy is reviewed to ensure effectiveness. Any deficiencies identified are promptly addressed and corrected.

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Last review: May 1st 2026