Conflict of Interest
We operate a compliance-first platform for private markets. This policy explains how we identify, disclose, and manage conflicts of interest across the company, partners, issuers, and investors.
We aim to detect conflicts early, disclose them where appropriate, and implement controls so that decisions remain fair, consistent, and in the best interests of users and market integrity.
This policy is informational and does not replace any signed agreements or applicable legal requirements. If you have a potential conflict to report, contact us.
Overview
A conflict of interest can arise when Monolith (or someone acting on its behalf) has competing interests that could influence, or appear to influence, objective decision-making. Conflicts can be actual, potential, or perceived.
Our baseline approach is: detect → disclose (when appropriate) → mitigate → document → review.
What is a conflict?
A conflict exists when a person or entity involved in the Services has an interest that could compromise impartiality, fairness, best execution principles (where applicable), or the integrity of controls (e.g., onboarding approvals, transfer rules, pricing windows, or access decisions).
Examples
Common scenarios we monitor and control:
- A Monolith team member (or close relative) has a financial interest in an issuer, investor, service provider, or an affiliated vehicle.
- Preferential treatment of one participant (issuer or investor) due to a commercial relationship.
- Compensation structures that could encourage steering users toward specific providers (e.g., custody, banking, admin) without clear disclosure.
- Partner arrangements where a third party receives payments based on volume or routing decisions (revenue share).
- Use of confidential information in a way that disadvantages other participants (information asymmetry).
- Conflicts between market integrity controls (e.g., transfer restrictions) and commercial pressure to “move faster.”
A conflict can be perceived even if no wrongdoing exists. We treat perceived conflicts seriously to protect trust.
Principles
Controls & governance
Controls used to prevent or manage conflicts may include:
- Disclosure & recusal: individuals must disclose relevant interests and step back from decisions.
- Segregation of duties: approvals and sensitive actions require independent checks.
- Access controls: least privilege, logging, and monitoring of sensitive data access.
- Partner due diligence: documenting commercial terms, incentives, and any revenue sharing.
- Audit trail: decisions and changes to rules/process are tracked for review.
Disclosure & transparency
Where appropriate, we disclose conflicts to affected parties in a clear and timely manner. The form of disclosure depends on the nature of the conflict and the relevant contractual/legal framework.
Disclosures may include: the nature of the relationship, potential impact, and mitigation steps (e.g., independent review, alternative provider options).
Report a conflict
If you believe there is an actual or potential conflict of interest related to the Services, please report it. Provide as much context as possible so we can triage quickly.
For sensitive security disclosures, please use Responsible Disclosure via the Security page.
Changes to this policy
We may update this policy from time to time. Material changes will be reflected by updating the “Last updated” date and, where appropriate, by providing additional notice.