Conflicts of interest that are potentially detrimental to clients may arise when the Company or the Company's shareholders or members, any person directly or indirectly linked to the Company or the Company's shareholders or members by control, the Company's board members or the Company's employees (the Connected Persons) are in any of the following situations:

• The Company or the Connected Person is likely to make a financial gain, avoid a financial loss, or receive another kind of benefit, at the expense of the client
• The Company or the Connected Person has an interest in the outcome of a crypto-asset service provided to a client of the Company or of a transaction carried out on behalf of that client, which is distinct from that client's interest in that outcome
• The Company or the Connected Person has a financial or other incentive to favour the interest of one or more clients of the Company over the interest of another client of the Company
• The Company or the Connected Person carries on the same business as the client of the Company
• The Company or the Connected Person receives or will receive from a person other than the client of the Company an inducement in relation to a service provided to that client, in the form of monetary or non-monetary benefits or services

Conflicts of interest that are potentially detrimental to the Company may arise when a Connected Person:

• has an economic interest in a person, body or entity with interests conflicting with those of the Company
• has a personal relationship with a person, body or entity with interests conflicting with those of the Company
• has or has had a professional relationship with a person, body or entity with interests conflicting with those of the Company
• has a political relationship with a person, body or entity with interests conflicting with those of the Company
• carries out conflicting tasks, is entrusted with conflicting responsibilities or is hierarchically supervised by someone who is in charge of conflicting functions or tasks

The Company has implemented various measures to prevent the conflicts of interest set out above from arising:

• Through training, the Company continuously ensures that Connected Persons are aware of the risks of conflicts of interest and the measures taken by SCE to prevent them from arising
• The Company has implemented various strict policies and procedures governing remuneration, personal transactions and insider trading, acceptance and/or receipt of gifts and entertainment, promotional campaigns, and outside business interests
• Additionally, the Company has implemented various measures in its internal governance to prevent conflicts of interest from arising within its organization and within the SwyftCap group