Managing Conflicts of Interest

This policy applies to Monolith and all subsidiaries, employees, and appointed representatives. We maintain a conflicts register, use segregation of duties, and apply a best‑interest duty to clients.

Common situations include: (i) personal account dealing, (ii) fee or incentive misalignment, (iii) information asymmetry between business units, and (iv) allocations or order handling priorities.

Teams must assess new products, relationships, and campaigns for potential conflicts. High‑risk scenarios are escalated to Compliance and recorded in the conflicts register with mitigating controls.

Mitigations include walling‑off information, role‑based access, 4‑eyes approvals, incentive caps, and governance reviews. Where conflicts cannot be fully mitigated, we provide explicit disclosure or decline the activity.

Employees must pre‑clear trades where applicable, avoid misuse of confidential information, and adhere to blackout periods. Gifts and entertainment are recorded and subject to limits and approval.

We assess partners (custody, KYC, venues) for conflicts, require contractual safeguards, and monitor remuneration structures for alignment with client interests.

If a material conflict remains, we will disclose it in clear terms before proceeding, including nature, risks, and safeguards, so clients can make an informed decision.

Conflicts management is overseen by senior leadership and Compliance. The register and this policy are reviewed at least annually or upon material change.

Contact the Compliance team at compliance@monolith.xyz. For complaints, see our Complaints Policy.