Public Conflict of Interest Policy

Last updated October 6, 2025

1. PURPOSE, SCOPE, AND DEFINITION

This Policy applies to all Concerned Persons working for or on behalf of Relai. Its purpose is to ensure that any conflict of interest (“CoI”) is identified, prevented, managed, recorded and, where relevant, disclosed in accordance with Article 77 MiCA.

2. IDENTIFICATION OF CONFLICTS OF INTEREST (COI)

A conflict of interest (CoI) exists where a private, financial or professional interest could:

  • lead Relai or its staff to obtain a benefit at a client’s expense;
  • create an incentive to favour one client or transaction over another;
  • result in personal trading or outside activities that compromise impartiality;
  • involve gifts, inducements or relationships capable of influencing decision‑making.

3. MANAGEMENT

Where a conflict cannot be avoided, Relai implements measures such as: information barriers, staff reassignment, role segregation and a strict zero‑tolerance stance on bribery, corruption, insider trading and undue influence.

4. REPORTING

Relai staff must promptly declare any actual or potential CoI via the Conflict Declaration Form. The Head of Compliance, together with the Managing Director, assesses each case, records it in the CoI Register and decides the necessary action.Where appropriate, the controls are escalated to the Supervisory Board, which remains ultimately accountable for conflict resolution.

5. CONFIDENTIALITY AND DATA PROTECTION 

All CoI disclosures are handled confidentially in accordance with GDPR and Swiss data‑protection law and are shared only with personnel essential to their resolution and as the case may be with the competent authorities.

6. WEBSITE DISCLOSURE 

In line with MiCA Article 72(2), Relai publishes on its website the general nature and sources of conflicts of interest and the steps taken to mitigate them whenever disclosure is required.

7. TRAINING AND COMPLIANCE 

All staff must attest in writing that they have read and understood this Policy. Initial training is provided within 90  days of onboarding and annual refreshers are mandatory

8. VIOLATION 

Breaches of this Policy are investigated. Sanctions may include disciplinary measures, up to and including dismissal, and notification to the competent authority, where applicable. Any disciplinary actions shall be applied in accordance with Relai’s Internal Employee Regulations, to which this Policy is annexed and made binding.

9. EFFECTIVE DATE AND REVIEW

This Policy shall be approved by the Relai Executive Team and shall take effect immediately, applying equally to both Relai AG and Relai EU. The Supervisory Board shall be informed of the corpus of policies implemented and shall receive, on an annual basis, an update on any potential conflicts of interest identified.