Conflicts of Interest Disclosure

This page is also available in Italian. Questa pagina è disponibile anche in italiano.

Asset Reality S.r.l. is committed to conducting its business with integrity, transparency, and in the best interests of its clients. In accordance with Article 72 of Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCAR) and Commission Delegated Regulation (EU) 2025/1142, we have implemented robust policies and procedures to identify, prevent, manage, and, where necessary, disclose conflicts of interest that may arise in the course of providing crypto-asset services.

We define a conflict of interest as any situation in which the interests of Asset Reality S.r.l., its shareholders, management, employees, or other connected persons may diverge from those of our clients, or where the interests of one client may conflict with those of another.

The following are examples of circumstances that may give rise to a conflict of interest:

• Where Asset Reality S.r.l. or a connected person may make a financial gain or avoid a financial loss at the expense of a client;

• Where Asset Reality S.r.l. or a connected person has an interest in the outcome of a service provided to a client that is distinct from the client’s interest;

• Where Asset Reality S.r.l. or a connected person receives an inducement from a third party in relation to a service provided to a client;

• Where a connected person has a personal, professional, or political relationship with a party whose interests conflict with those of Asset Reality S.r.l. or its clients;

• Where the structure or activities of other entities within the Asset Reality Group may give rise to related-party conflicts.

To mitigate these risks, we have adopted the following measures:

• Implementation of internal procedures and controls to identify and assess potential conflicts;

• Maintenance of a Conflicts of Interest Register;

• Separation of duties and supervision to prevent undue influence or bias;

• Restrictions on personal transactions and outside business interests of staff;

• Independent oversight by a designated Conflicts of Interest Officer;

• Regular training and awareness programmes for all staff;

• Periodic review and update of our conflict management framework.

Where a conflict of interest cannot be effectively prevented or managed, we will disclose the nature and source of the conflict to the affected client(s) before proceeding with the relevant service or transaction. In certain cases, we may decline to act where the conflict cannot be resolved to an acceptable standard.

This disclosure is available in English and Italian and is reviewed regularly to ensure it remains accurate and up to date.

For further information or to request a copy of our Conflicts of Interest Policy, please contact compliance@assetreality.com

Last Updated: 3 Feb 2026 | Version: 1.0