Richtlinien

Conflict of Interest — Disclosure

Information on the identification, prevention, management and disclosure of Conflicts of Interest

This disclosure summarises the general nature and sources of Conflicts of Interest that may arise in connection with the crypto-asset Services SIA “Paybis Europe” (“PAYBIS”) provides, and the measures PAYBIS takes to prevent or mitigate them. It is prepared in accordance with PAYBIS internal Procedure for Prevention and Management of Conflicts of Interests and applicable MiCA requirements.

Conflict of Interest - A situation where the impartial and objective performance of a function is compromised by personal or financial interests that may potentially interfere with the ability to act impartially and in the best interests of Clients. A Conflict of Interest exists when the interests of PAYBIS and its obligation to protect the best interests of the Client conflict with one another.

Last updated: July 1, 2026

Potential Conflict of Interest situations

Conflicts of Interest can take place

Between PAYBIS and its shareholders, Board Members or employees.
Between PAYBIS and any person or entity connected to PAYBIS or its shareholders (through parent–subsidiary or group PAYBIS relationships).
Between PAYBIS and Client.
Between Clients themselves.

The nature of the Conflicts of Interest identified

Conflicts of Interest that PAYBIS monitors include, but are not limited to:

PAYBIS or its connected persons benefitting financially or otherwise at the direct expense of the Client or have interests in the outcome of a transaction or Service that differ from those of the Client.
Receipt of inducements, commissions, or benefits from third parties that could impact PAYBIS's decisions and reduce the Client’s best execution or fair treatment.
PAYBIS having incentives to favour one Client (or group of Clients) over another.
PAYBIS engaging in activities or transactions that may create interests differing from those of its Clients or may otherwise disadvantage Clients.
A connected person holding financial interests in entities whose objectives conflict with those of PAYBIS or its Clients.
Personal, professional, or political relationships creating outside influences that affect impartial judgment and result in preferential treatment, misuse of information, or pressures not aligned with Clients’ best interests.
Divided roles or conflicting responsibilities compromising effective oversight and the fair treatment of Clients.
Conflicts arising from relationships with affiliated entities, outsourcing providers, and other third-party service providers involved in the provision of Services.

Conflicts of Interest specific to crypto-asset Services

In addition to the Conflicts of Interest described above, PAYBIS recognises that specific Conflicts of Interest may arise in connection with the provision of crypto-asset Services.

Such Conflicts of Interest may include relationships with issuers of crypto-assets, liquidity providers, custodians, payment service providers, affiliated entities, or other business partners involved in the provision of Services, as well as personal transactions carried out by connected persons involving crypto-assets.

PAYBIS applies organisational, procedural, and technical controls designed to identify, prevent, manage, monitor and, where necessary, disclose such Conflicts of Interest in accordance with applicable legal and regulatory requirements.

Conflicts of Interest arising from group and affiliated arrangements

PAYBIS forms part of a group of companies and may cooperate with affiliated entities and business partners in connection with the provision of Services.

Conflicts of Interest may arise where such entities have interests that differ from those of PAYBIS or its Clients.

PAYBIS applies governance, oversight and monitoring measures to ensure that Clients are treated fairly and in their best interests.

General principles for monitoring circumstances that may indicate a Conflict of Interest

PAYBIS continuously monitors business activities, transactions and relationships for signs of Conflicts of Interest — including personal transactions, access to non-public information, market-making or related-party dealings — using automated alerts, transaction reviews and employee notifications. Suspicions or findings are promptly reported to the Compliance Department for assessment and, where needed, escalation to the Management Board.

Steps and measures PAYBIS takes to prevent or mitigate Conflicts of Interest

PAYBIS maintains multiple layers of controls and governance to prevent, detect and mitigate Conflicts of Interest, including:

Governance & oversight. Management Board with ultimate responsibility and an independent Compliance Department (headed by the Global Chief of Compliance Department) that identifies, assesses and reports Conflicts of Interest and proposes remedial action.
Policies & Procedures. Documented Procedure for prevention and management of Conflicts of Interest, covering identification, disclosure, escalation and remediation.
Register & Checklist. Internal, auditable Register and Checklist of connected persons and incidents to record Conflicts of Interest, personal transactions, decisions and remedial measures.
Segregation of duties. Organisational separation of functions and, where necessary, reallocation of responsibilities to remove the source of Conflict of Interest.
Restricted access. Limiting access to inside or confidential information only to designated Responsible Persons bound by confidentiality undertakings.
Pre-approval & monitoring of personal transactions. Connected persons must notify and (where required) obtain approval before personal crypto-asset transactions; ongoing monitoring is applied.
Enhanced monitoring & controls. Transaction monitoring and periodic reviews for Clients or connected persons subject to higher risk (e.g., related parties), including additional due diligence.
Remuneration safeguard. Remuneration structures that balance fixed and variable elements and include qualitative indicators (Client treatment), to reduce incentive-based Conflicts of Interest.
Disciplinary & corrective measures. From reassignment and training to suspension or termination of relationships where Conflicts of Interests cannot be mitigated.
Extraordinary measures & escalation. Where standard controls are insufficient, the Compliance Department and Management Board may apply extraordinary measures (temporary suspension of activities, restructuring, escalation to Shareholders or competent authorities).
Transparency & Client disclosure. This disclosure and other Client communications set out the general nature and sources of Conflicts of Interest and the steps PAYBIS takes to mitigate them.
Disclosure of residual Conflicts of Interest. Where PAYBIS determines that the arrangements established to prevent or manage a Conflict of Interest are not sufficient to ensure, with reasonable confidence, that risks of damage to Clients’ interests will be prevented, PAYBIS will clearly disclose the general nature and source of the Conflict of Interest to the affected Client before providing the relevant Service or proceeding with the relevant Transaction. Such disclosure will be made in a durable medium and will include sufficient detail to enable the Client to make an informed decision. Such disclosure does not replace the obligation of PAYBIS to maintain and operate effective arrangements to identify, prevent and manage Conflicts of Interest and shall not constitute a waiver of any rights of the Client.
Regular review. Periodic audits, at least annual reviews of the framework by the Compliance Department and independent testing by Internal Audit (or more frequently if required).

Monitoring of connected persons

PAYBIS's Compliance Department monitors whether connected persons have outside interests, activities, or relationships—such as involvement in crypto-asset projects, use of third-party providers, external business roles, or close personal, political, or financial associations—that could create Conflicts of Interest, and takes steps to review and address these situations on an ongoing basis.

The Compliance Department reviews any potential Conflicts of Interest to determine whether they could affect Clients or PAYBIS and, if risks are identified, recommends appropriate actions—such as requiring disclosure, reallocating responsibilities, suspending certain decisions, enhancing monitoring, mandating training, or, where necessary, ending conflicting activities or relationships—with final corrective measures adopted by the Management Board (or Shareholders, if Board Members are involved) to ensure full protection of Clients’ interests and compliance with laws and internal policies.

Supervision of connected persons involved in providing Services to the Clients

PAYBIS's Compliance Department supervises employees, contractors, and service providers whose roles may give rise to Conflicts of Interest, regularly reviewing their activities and relationships to detect potential issues, and, where Conflicts of Interest are identified, recommends corrective measures such as informing affected Clients, restricting or adjusting the Services provided, reassigning responsibilities, or, if necessary, suspending or terminating conflicting activities to ensure Clients’ interests are protected.

Counteracting undue influence on how the Services are provided

PAYBIS has strict safeguards to prevent any undue influence—such as financial inducements, pressure, or interference from Clients, shareholders, partners, or other third parties—from affecting how Services are provided. The Compliance Department continuously monitors for such risks, requires employees to report any attempts of improper influence, and, where necessary, recommends corrective measures such as restricting contact, terminating relationships with influencing parties, or escalating matters to regulators. These steps ensure that Services are delivered independently, fairly, and in the best interests of Clients.

Conflicts of Interest involving connected persons in other projects

PAYBIS takes steps to prevent Conflicts of Interest that may arise if employees or connected persons are involved in external crypto-assets or business activities that could compromise independence or impartiality. All such external roles must be disclosed and are closely monitored by the Compliance Department. Where a Conflict of Interest is identified, corrective measures may include adjusting or restricting the person’s activities, requiring withdrawal from the external role, reassigning responsibilities within PAYBIS, or, in serious cases, ending the cooperation—ensuring that Clients’ interests and PAYBIS's integrity are fully protected.

Prevention of Conflicts of Interest relating to insider dealing

To prevent Conflicts of Interest linked to insider dealing, PAYBIS strictly limits access to confidential Client and business information to authorized employees who are bound by confidentiality undertakings, enforces disciplinary measures in case of breaches, and maintains a formal register to ensure transparency, accountability, and compliance with applicable laws and supervisory requirements.

Prevention of Conflicts of Interest arising from the manner of remuneration of the employees of PAYBIS

PAYBIS recognises that the way employees, management, and external partners are remunerated can create risks of Conflicts of Interest, and therefore applies strict rules to ensure that pay and incentives never encourage behaviour that could harm Clients or compromise fairness. Remuneration includes all forms of payment or benefits, whether financial or non-financial, such as salaries, bonuses, stock options, commissions, gifts, or hospitality, and applies to employees, Board Members, consultants, tied agents, and outsourced providers involved in delivering Services. To avoid harmful incentives, remuneration is not based solely on sales or financial performance but also reflects compliance with regulations, the fair treatment of Clients, service quality, risk management, and Client satisfaction. Variable pay is kept in balance with fixed pay to prevent excessive short-term incentives, and all remuneration structures are regularly monitored by the Compliance Department to identify and address potential risks. Where necessary, corrective measures may include adjusting the way individuals are paid, reassigning their responsibilities, restricting their functions, or, in serious cases, ending employment or contractual relationships. These safeguards ensure that remuneration practices are fair, transparent, and fully aligned with the best interests of Clients.

Personal Transactions

Personal transactions are any crypto-asset dealings carried out by connected persons, either for themselves, through controlled entities, or on behalf of close family members, where such transactions may create Conflicts of Interest or misuse confidential information. This includes situations where knowledge of Client activity, market-sensitive events, or inside information is used for personal gain.

To prevent such risks, connected persons with access to confidential information must obtain prior written approval from the Compliance Department before executing any personal transaction. All transactions must be promptly reported and recorded, and individuals are prohibited from engaging in activities that would amount to market abuse, front-running, parallel trading, or other behaviour contrary to MiCA obligations.
The Global Chief of Compliance oversees these safeguards, ensures connected persons are informed of their obligations, and may issue binding instructions or updated regulations. Where activities are outsourced, service providers must apply equivalent controls and provide information to PAYBIS on request. These measures protect Clients, ensure market integrity, and prevent undue Conflicts of Interest.

Other specific rules on Conflicts of Interest potentially detrimental to PAYBIS includes:

Separation of activities or transactions contrary to the interests of PAYBIS. If any activity or transaction is found to create a significant Conflict of Interest with Clients or with PAYBIS itself, the Global Chief of Compliance will immediately raise the matter with the Management Board and recommend appropriate safeguards. These may include suspending the activity, restructuring or outsourcing it, or separating it into another business line or entity. The Management Board reviews and documents all such cases, and where necessary, the matter is escalated to the Shareholders to ensure that Clients are treated fairly and the integrity of PAYBIS's operations are protected.
Preventing inappropriate influence by connected persons in relation to their external activities. PAYBIS ensures that the external business or professional activities of its employees and connected persons—such as directorships, advisory roles, political functions, or significant shareholdings—do not create inappropriate influence over its operations. All such activities must be disclosed and are monitored by the Compliance Department. If undue influence is identified, corrective steps may be taken, including restricting interactions, suspending involvement in certain decisions or projects, or limiting access to sensitive information, to ensure that the Paybis Europe SIA remains impartial and Clients’ interests are fully protected.
Principles for prevention and management of Conflicts of Interest concerning members of the Management Board. PAYBIS applies strict rules to prevent and manage Conflicts of Interest involving members of its Management Board. Board Members must promptly disclose any actual or potential Conflicts of Interest, abstain from related decision-making, and avoid holding external roles or interests in competing crypto-asset or financial service providers. Any breaches are independently assessed by the Global Chief of Compliance and escalated to Shareholders, who may take corrective measures such as suspending or dismissing the Board Member. All actions are formally recorded to ensure transparency and protect the interests of Clients and the integrity of PAYBIS.
Extraordinary measures to prevent Conflicts of Interest. In exceptional cases where ordinary safeguards are not enough to prevent or manage a Conflict of Interest, the Global Chief of Compliance may recommend extraordinary measures to the Management Board. These may be applied, for example, in cases of systemic Conflicts of Interest, repeated breaches, or risks to PAYBIS's independence, market integrity, or Client protection. The Management Board reviews these recommendations, ensures risks are fully assessed, and implements additional safeguards where necessary to protect Clients and strengthen PAYBIS's internal controls.

Complaints relating to Conflicts of Interest

Clients who believe that a Conflict of Interest may have adversely affected the provision of Services may submit a complaint in accordance with PAYBIS's Complaints Handling Policy.

Important note

This disclosure is provided to give Clients clear, up-to-date information about the general nature and sources of Conflicts of Interest and the steps PAYBIS takes to mitigate them, but it is not a substitute for the proper identification, prevention and management of specific conflicts. Where an actual or potential Conflict of Interest is identified, PAYBIS applies the specific measures set out in PAYBIS's internal Procedure for prevention and management of Conflicts of Interests.