Conflict of Interest

1. PURPOSE AND APPLICABILITY

At World Golden Gate Virtual Assets Broker & Dealer Services L.L.C (WGG), we are committed to maintaining the highest standards of ethical conduct, regulatory compliance, and client trust. This policy outlines how WGG identifies, manages, and mitigates conflicts of interest that may arise in the course of our business operations. This summary applies to all employees, directors, consultants, and third-party service providers engaged with WGG.

2. CLIENT FIRST COMMITMENT

WGG upholds the principle that client interests always take precedence over internal or third-party considerations. We act fairly, honestly, and professionally in accordance with the best interests of our clients at all times.

3. WHAT IS A CONFLICT OF INTEREST?

A conflict of interest arises when a personal, financial, or external interest could improperly influence—or appear to influence—the objective performance of professional duties. Examples include:

• Board memberships or side businesses

• Close personal relationships with clients or vendors

• Ownership interests in competing entities

• Financial gain from trading decisions or referrals

4. IDENTIFICATION AND DISCLOSURE OF CONFLICTS

WGG employees and related parties are required to:

• Disclose all actual or potential conflicts upon joining and periodically thereafter

• Update their declarations if circumstances change

• Use designated forms submitted to our Compliance team

5. ROLES AND RESPONSIBILITIES

• Board of Directors: Approves this policy and ensures appropriate oversight.

• Compliance Officer: Maintains a Conflicts of Interest Register, reviews disclosures, and oversees mitigation.

• Staff and Contractors: Must proactively declare, avoid, and manage potential conflicts.

• Third-Party Providers: Must adhere to this policy and declare any conflicts relevant to services rendered.

6. CONFLICT MANAGEMENT FRAMEWORK

We manage conflicts through the following strategies:

• Avoidance: Refraining from conflicted activity where mitigation is not feasible.

• Disclosure: Transparently informing clients or relevant stakeholders.

• Client Consent: Seeking approval where applicable.

• Controls and Safeguards:

  • Information barriers (firewalls) between teams

  • Segregation of duties

  • Personal trading restrictions

  • Pre-approval for external business activity

7. THIRD-PARTY AND REFERRAL CONFLICTS

WGG may engage third-party service providers, referrers, or counterparties in delivering services. Where material conflicts arise—such as referral commissions or joint ventures—WGG will disclose such arrangements to clients before executing any transactions.

8. ONGOING STAFF RESPONSIBILITIES AND ETHICS

Employees are expected to:

• Act with integrity and objectivity

• Avoid situations where impartiality may be questioned

• Seek guidance when in doubt

Undergo periodic training on conflicts and ethics.

WGG enforces policies on:

• Gifts and hospitality: Restrictions on accepting benefits that may impair judgment

• Remuneration structures: Designed to avoid incentivizing conflicted behavior

• Personal trading: Restrictions apply to virtual asset holdings and trading activities

9. MONITORING, ESCALATION, AND COMPLIANCE OVERSIGHT

WGG maintains a dedicated Conflicts of Interest Register, documenting disclosures, controls, and resolution status. Conflicts that cannot be mitigated effectively are escalated to the Compliance Officer and, if needed, to senior management for resolution or client notification.

Periodic audits are conducted to ensure compliance and regulatory alignment.

10. POLICY UPDATES AND STAFF ACKNOWLEDGEMENT

This policy is periodically reviewed to reflect regulatory updates and organizational changes. Staff are notified of any material amendments and are required to acknowledge understanding and compliance on a recurring basis.

DISCLAIMER

This policy summary is provided for transparency purposes only. It does not constitute the full internal Conflict of Interest Policy adopted by WGG. Clients, regulators, or third parties seeking further clarification may contact our Compliance Department at compliance@worldgoldengate.com