The purpose of this policy is to establish a framework for identifying, preventing, managing, and disclosing Conflicts of Interest that may arise in the course of providing crypto-asset services. CF Technologies Limited (the 'Company') is committed to acting in the best interests of its clients, ensuring transparency and fairness in all business operations.
This policy applies to all employees, management, shareholders, and connected persons at CF Technologies Limited. It covers all crypto-asset services and activities provided by the Company and applies to situations where Conflicts of Interest may arise between the company, its connected persons, and its clients. The purpose of this Policy is to prevent Conflicts of interest from adversely affecting the clients' interests.
Formal documents underlying this policy include the following:
• Virtual Financial Assets Act (the "VFA Act");
• Virtual Financial Assets Regulations (the "Regulations");
• Virtual Financial Assets Rulebook Chapter 3 (the "Rulebook");
• MiCA Regulations (Regulation (EU) 2023/1114)
• ESMA Draft Technical Standards specifying certain requirements in relation to conflicts of interest for crypto-asset service providers under the Markets in Crypto Assets Regulation (MiCA);
• Companies Act, Chapter 386 of the Laws of Malta; and;
• Any guidelines on Conflicts of Interest as issued by the MFSA from time to time.
For this Policy, the following definitions shall apply:
Company
Shall mean CF Technologies Limited
Conflict of Interest
A conflict of interest is when someone in a position of trust has competing professional or personal interests. Such competing interests can make it difficult to fulfil his or her duties impartially. A conflict of interest may exist even if no unethical or improper act results from it.
Client /
Customer
This means any of the following:
• An existing customer of the company;
• A potential customer of the company (where the company is seeking to enter into a relationship with the potential customer in respect of services); or;
• A past customer where commitments and obligations are still in place.
Employee
Shall include a permanent or temporary employee of the company and all Directors.
Connected Person
Shall include direct and indirect shareholders, members of the management body and employees.
Group
means a parent undertaking and all its subsidiary undertakings.
Remuneration
means any form of payment or other financial or non-financial benefits provided directly or indirectly by crypto-asset service providers in the provision of cryptoasset services to clients.
Certain circumstances may arise during the provision of crypto-asset services where the interests of the company, its employees or related parties may conflict with those of its clients. These conflicts could potentially result in decisions or actions that may damage the interests of one or more clients.
For the avoidance of doubt, this policy covers any potential and existing Conflicts of Interest.
To safeguard the clients’ interests, the company has established clear policies to identify, manage, and, where necessary, disclose the Conflicts of Interest and its mitigating factors to prevent any possible adverse impact on the client. To mitigate this risk, the company identifies and monitors situations where a conflict of interest might occur when the company, its employees or any other connected person:
a. could potentially make a financial gain, avoid a financial loss, or receive another kind of benefit, at the expense of the client;
b. have an interest in the outcome of a service provided to the client or of the transaction carried out on behalf of the client, which is distinct from the client's interest in that outcome;
c. have financial or other incentives to favour the interests of another client or group of clients over the client's interests;
d. carry out the same business as the client;
e. receive or will receive from a person other than the client, an inducement in relation to a service provided to the client in the form of monetary (other than the standard commission or fee for that service) or non-monetary benefits or services such as, gifts, goods or services.
The above circumstances constitute or may give rise to a Conflict of Interest which may lead to the possible adverse impact on the interests of one or more Clients.
Certain circumstances may give rise to Conflicts of interest related to the performance of a connected person’s duties and responsibilities. For this reason, the company takes into account, at least, situations or relationships where a connected person:
(a) has an economic interest in a person, body or entity with interests conflicting with those of the Company;
(b) has or has had within at least the last 3 years a personal relationship with a person, body or entity with interests conflicting with those of the Company;
(c) has or has had within at least the last 3 years a professional relationship with a person, body or entity with interests conflicting with those of the Company;
(d) has or has had during at least the last 3 years a political relationship with a person, body or entity with interests conflicting with those of the Company;
(e) carries out conflicting tasks or activities, is entrusted with conflicting responsibilities or is hierarchically supervised by a person in charge of conflicting functions or tasks.
In order for the Company to identify and establish an economic interest, a connected person shall:
(a) hold shares, tokens (including governance tokens), other ownership rights or membership in that person, body or entity;
(b) hold debt instruments of or has other debt arrangements with that person, body or entity; (c) has any form of contractual arrangements, such as management contracts, service contracts, delegation or outsourcing contract or intellectual property licenses with that person, body or entity.
In order for the Company to identify the persons, bodies or entities with conflicting interests to the Company, the company takes into account, at least, whether that person, body or entity is in anyof the following situations:
(a) it is likely to make a financial gain, or avoid a financial loss, at the expense of the Company; (b) it has an interest in the outcome of a crypto-asset service provided or an activity carried out or decision taken by the Company, which is distinct from the company’s interest in that outcome;
(c) it carries out the same business as the Company or is a client, consultant, adviser, delegatee, outsourcee, service provider or other supplier (including subcontractors) of the company and it can be reasonably deemed from objective circumstances that there may be a conflict of interests with the company.
The company provides guidelines to situational conflicts of interest and the duty to declare. Typical examples of situational conflicts can give rise to conflicts and include, but are not limited to the following.
If a director has a conflict of interest in relation to any matter, such conflict of interest shall be declared at the earliest available opportunity, and a record of such declaration shall be entered into the company's minute books. The following procedure should be followed during the Board meeting:
● A member who is in any way, directly or indirectly, interested in any contract, arrangement or any other matter which is being or is about to be discussed by the Board or which is being or may be entered into by the Company should declare the nature of the interest to the other members at the meeting at which the matter arises or if the member was not interested in the matter at the date of the meeting then at the next meeting held after the member became interested. In the case where such a member becomes interested in a contract, arrangement or other matter after it is made, the said declaration shall be made at the first meeting of the Board of administration held after such member becomes so interested;
● Unless agreed by the other members, a member shall avoid entering into a discussion in respect of any contract or arrangement in which s/he is interested and should withdraw from the meeting while the matter he is interested in is being discussed;
● The interested members should abstain from voting at a meeting regarding any contract or arrangement they are interested in. Alternatively, their vote shall not be counted as part of the quorum; and
● The minutes shall accurately record the sequence of such events and the conflict of interest declaration by the member.
A situational Conflict may arise if the Auditor, who is in a position of trust, has a competing professional or personal interest and thus it makes it difficult for the auditor to fulfil his duties impartially. The Company recognises its’ obligation not to appoint an independent auditor/compliance officer who is: ● an individual or audit firm who is an Administrator, Qualifying Holder, Officer, representative or employee of the Company;
● the partner of, or in the employment of, any person in (a) above;
● the spouse, civil partner, parent, step-parent, child, step-child or other close relative of any person in (a) above;
● a person who is not otherwise independent of the Company;
● a person disqualified by the MFSA from acting as an Auditor of a Company. Also, the Auditor shall not be regarded as an Officer or an employee of the Company.
This policy has been prepared taking into account the scale, nature and range of crypto-asset services and other activities provided or carried out by the Company and the group to which it belongs.
The Company implements effective measures to manage Conflicts of Interest that are identified and may arise during the provision of crypto-asset services aiming to ensure transparency, fairness, and the protection of the clients' interests in line with the regulatory requirements.
The Company maintains robust procedures for identifying Conflicts of Interest that may arise between the Company, any connected persons or between one or more clients. These conflicts could impact the impartiality and objectivity of decisions taken by the Company, adversely affecting the best interests of its clients.
The Company also takes into account any circumstances which may give rise to a conflict of interest due to the structure and business activities of other entities within the group. In this regard, the Company aims to prevent any abuse that may result from concentrated control and management of related-party transactions, including those involving affiliated companies and transparency of related-party transactions.
When a Conflict of interest is identified, the following steps should be followed:
• Immediate Notification:
The individual identifying the potential / existing Conflict of Interest must notify the Designated Responsible Person in writing as soon as possible by filling in the ‘Conflict of Interest Disclosure Form’ which can be found in Annex A.
If the individual identifies the possibility of an potential or existing Conflict of interest of a third party, information shall be discussed confidentially with the Designated Responsible Person, who shall assess and assist on whether the circumstances shall be notified as Potential or Existing Conflict or otherwise, and in case a Conflict of interest is identified, the Designation Responsible Person, proposes the mitigating measures.
• Confidentiality:
The reporting of Conflicts of Interest is treated confidentially. Any sensitive information provided as part of the report will be protected and only shared on a need-to-know basis.
Upon receiving a conflict of interest report, the Designated Responsible Person will:
1. Acknowledge the Report: Confirm receipt of the report within two (2) business days.
2. Investigate the Conflict: Investigate to determine the nature, scope, and potential impact of the conflict.
3. Propose Mitigation Measures: Based on the findings, recommend appropriate actions to manage or mitigate the conflict, including:
o Adjusting roles or responsibilities to reduce exposure to the conflict. o Implementing information barriers or rotating personnel.
o In extreme cases, escalating the matter to senior management for resolution.
4. Communication of Outcome: The responsible person will communicate the outcome of the investigation and the mitigation measures to the individual who reported the conflict, as well as to any other relevant stakeholders. This will include any follow-up actions required by the individual or team involved.
5. Escalation: If the conflict cannot be managed internally, the responsible person will escalate the matter to the Board of Administration, for possible further action.
The Company implements various measures to prevent conflicts of interest. Such measures include:
• implementing the conflicts of interest policy including the conflicts of interest form and the process to be adhered to for connected persons to declare any potential/existing conflict immediately;
• established a process to review the declared Conflict of interest, which shall include any mitigating measures, if the conflict of interest could not be eliminated/ prevented;
• maintain records of all disclosures, evaluations and mitigating measures acted on for a defined period of time, in line with the GDPR and keeping these records should be consistent with its document retention policy. Records shall include any decisions related to transactions involving an actual or possible conflict of interest;
• Control measures implemented when a conflict could not be eliminated
Connected persons engaged in different business activities that may give rise to a potential or actual conflict of interest shall carry out these activities at a level of objectivity and independence appropriate to the scale, nature and range of crypto-asset services provided by the crypto-asset service provider and of the group to which it belongs, whilst also taking into consideration the risk of damage to the interests of one or more clients or the interests of the company.
When a Conflict of Interest could not be eliminated, the Company implements adequate measures to mitigate the conflict of interest that may be either detrimental to clients or even detrimental to the Company itself. To safeguard itself and its clients, the company adopts the following principles:
• prevents and controls the exchange of information between connected persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more clients; or where the exchange of that information may affect the performance of such connected person’s duties and responsibilities to the company. Information barriers through information sharing on a need to know basis and the segregation of roles and responsibilities, are implemented throughout the organisation, taking into account the nature and the scale of the company. The company established transparent reporting lines within its organisation in order to ensure that issues involving risks of non-compliance with conflicts of interest rules are given the necessary priority.
• prevents any person from exercising inappropriate influence over the way in which a connected person carries out the crypto-asset services; moreover prevent connected persons who are also active outside the company from having inappropriate influence within the company in relation to those other outside activities;
• prevents or controls the simultaneous or sequential involvement of a connected person in separate crypto-asset services or activities where such involvement may impair the proper management of conflicts of interest. Staff rotation may be implemented;
• eliminates any direct link between the remuneration provided to the employees, delegatees, outsourcees, subcontractors or members of the management body principally engaged in one activity and the remuneration of, or revenues generated by, different employees, delegatees, outsourcees, subcontractors or members of the management body of the company principally engaged in another activity, where a conflict of interest may arise in relation to those activities; A remuneration policy is in place.
• provides sufficient guidance and training on the identification and management of conflicts of interest that may impede the ability of members of the management body to take objective and impartial decisions that aim to fulfil the best interest of the company; A responsible dedicated person has been identified for conncected persons to discuss any queries should they need assistance in determining whether a potential/existing conflict exist.
• establishes the responsibility of the members of the management body to inform other members of and abstain from voting on any matter where a member has or may have a conflict of interest or where the member’s objectivity or ability to properly fulfil his or her duties to the company may be otherwise compromised;
• prevents members of the management body from holding other directorships in competing companies outside of the same group;
The Company acknowledges that disclosure of a conflict of interest shall not be considered a sufficient measure to manage or mitigate such conflict. Disclosure shall only be used as a measure of last resort, where the organisational and administrative arrangements established by the Company are not sufficient to ensure, with reasonable confidence, that the risks of damage to client interests will be prevented.
To ensure the effective identification, management and reporting of the Conflicts of Interest, the following roles and responsibilities are assigned:
• Identify and Report: all employees, managers, Board members, and any other connected persons are responsible for identifying potential or actual Conflicts of Interest in the course of their work and shall report these conflicts immediately to the Designated Responsible Person, in accordance with the procedures outlined.
• Compliance: all employees must comply with all internal policies and procedures related to Conflicts of Interest and refrain from engaging in any activities that could create conflicts unless these are appropriately disclosed and managed.
• Ongoing Awareness: Individuals must remain vigilant in identifying and reporting Conflicts of Interest as they arise and participate in any required training to ensure awareness of their responsibilities.
• conducts regular reviews of the Conflicts of Interest policy, at least once annually, to ensure ongoing compliance with both internal policies and external regulatory requirements. Any material changes or risks identified during these reviews will be promptly reported to the Board, along with recommended actions for improvement.
• Identifying and assessing Conflicts of Interest: The responsible person shall monitor the business activities of the Company, identifying potential or actual/ existing conflicts, and ensures appropriate measures are taken including the conduct of the risk assessment on the reported conflict to manage associated risks.
• Record Keeping: The responsible person shall maintaining a Conflicts of Interest Register to document all reported conflicts, actions taken, and the final outcomes. This register will be reviewed periodically and updated as necessary.
• Investigation and Reporting: The responsible person will investigate any reported conflicts and provide recommendations for managing or mitigating the conflict. Clear communication is to be maintained with the individual who reports the conflict and escalate unresolved or severe conflicts to senior management and/or the Board.
• Escalation: Reporting directly to the Board on conflict of interest matters, including providing regular updates and making recommendations for improving conflict management practices.
• Regulatory Reporting: Where required, the Compliance Officer will liaise with regulatory authorities to provide updates or reports on Conflicts of Interest that pose material risks to the company or its clients.
• Training and Education: The responsible person ensures that all employees and connected persons receive regular training on conflict of interest policies and their responsibilities, enhancing awareness across the Company and their role to adhere to this policy.
The Designated Responsible Person operates independently of any business functions that could give rise to Conflicts of Interest, ensuring objectivity and impartial decision-making. This independence is critical to maintaining the integrity of the conflict of interest management process.
The Designated Responsible Person shall be granted full access to all necessary information, personnel, and records within the Company to ensure comprehensive oversight and prompt resolution of any Conflicts of Interest. This ensures the role is effectively carried out with the appropriate resources.
The Company has appointed the Compliance Officer, as the designated individual responsible for the identification, prevention, management, disclosure, reporting and keeping up to date records of Conflicts of Interest. The Compliance Officer holds the necessary authority, skills, and independence to oversee all processes related to identifying, preventing, managing, and disclosing Conflicts of Interest. The designated responsible person may be changed from time to time, as decided by the Board of Directors subject to holding the necessary authority, skills and independence to oversee all processes related to identifying, preventing, managing, disclosing and reporting Conflicts of interest.
As part of the Compliance Monitoring plan, the Compliance Officer also ensures ongoing monitoring of potential Conflicts of Interest and the effectiveness of implemented measures. The Compliance Officer also ensures that it keeps records updated including the Conflicts of Interest Register.
• Support and Escalation: Senior management is responsible for providing support in complex or severe conflict of interest cases that cannot be resolved through routine procedures. Senior management shall review escalated conflicts and ensure appropriate action is taken to resolve or mitigate the risks against the company and its clients.
• Policy Review: Senior management must regularly review the effectiveness of the conflict of interest policy and recommend any significant changes to the policy. In addition, Senior management shall review the performance of the designated responsible person in carrying out their duties.
• Oversight and Governance: The Board of Administration is responsible to define, adopt, implement and monitor compliance with the company’s conflict of interest policies as aligned with the Regulatory requirements. The Board of Administration oversees the implementation of the governance arrangements to ensure effective and prudent management of the company, including the segregation of duties to prevent conflicts of interest. In this regard, the Board of Administration periodically assesses and reviews the effectiveness of the policy and procedures adopted and address any deficiencies in this respect.
• Strategic Decision Making: In cases where Conflicts of Interest involve strategic decisions, the members of the Board shall ensure that these decisions are made objectively and in the best interest of the company and its clients, without undue influence from conflicting interests. Any conflicting interest shall be communicated and reported as detailed in this policy under section 5.3 of this policy.
The Company takes into account the interests of all their clients, in the short, medium or long term, as well as the scale, the nature and range of crypto-asset services provided when putting into place the remuneration arrangements so as not to create a conflict of interest or incentive that may lead the persons to whom they apply to favour their own interests or the company’s interests to the potential detriment of any client or that may lead the persons to whom they apply to favour their own interests to the detriment of the company.
The company ensures that remuneration processes apply to its employees and any other natural person whose services are placed at the disposal and under the control of the company who is involved in the provision of crypto-asset services; members of its management body; and any natural person directly involved in the provision of services to the company provided under an outsourcing arrangement for the purpose of the provision of the crypto-asset services.
In order to further safeguard the interest of its clients, remuneration and similar incentives shall not be solely or predominantly based on quantitative commercial criteria, and shall take into account appropriate qualitative criteria reflecting compliance with the applicable regulations, the fair treatment of clients and the quality of services provided to clients. A balance between fixed and variable components of remuneration shall therefore be maintained at all times, so that the remuneration structure does not favour the interests of the company or its connected persons against the interests of any client.
Any direct links between the remuneration provided to the company’s employees, delegatees, outsourcees, subcontractors or members of the management body principally engaged in one activity and the remuneration of, or revenues generated by, different employees, delegatees, outsourcees, subcontractors or members of the management body of the company principally engaged in another activity, are removed if a conflict of interest may arise in relation to those activities.
A Personal Transaction is a transaction in a crypto-asset or resulting in a position in or exposure to a crypto-asset effected by or on behalf of a connected person, where at least one of the following criteria are met:
• the connected person is acting outside the scope of the activities he carries out in his professional capacity;
• the transaction is carried out for the account of anyof the following persons:
• the connected person;
• any person with whom a connected person has a family relationship or close links;
• a person in respect of whom the connected person has a direct or indirect material interest in the outcome of the transaction, other than obtaining a fee or commission for the execution of the transaction.
A personal relationship is defined as one of the following:
(a) the spouse of the connected person or any partner of that person considered by national law as equivalent to a spouse;
(b) a dependent child or stepchild of the connected person;
(c) any other relative of the connected person who has shared the same household as that person for at least one year on the date of the personal transaction concerned or the previous 5 years.
A connected person shall:
• be aware of the restrictions on personal transactions, and of the measures established by the Company in connection with personal transactions;
• promptly inform the Company of any personal transaction entered into by a connected person, either by notification of that transaction or by other procedures enabling the Company to identify such transactions;
The company shall record the personal transaction notified to the Company or identified by the company, including any authorisation or prohibition in connection with such a transaction.
The Company shall ensure that an employee or its officials do not enter into a personal transaction which meets any of the following criteria:
• that person is prohibited from entering into a personal transaction if the transaction may give rise to Market Abuse or inside information or insider dealing or market manipulation. Please refer to the Prevention of Market abuse policy for further details on this matter.
• transaction involves the misuse or improper disclosure of confidential information; or;
• transaction conflicts or is likely to conflict conflicts or is likely to conflict with an obligation of the company under the MICA Regulation (EU) 2023/1114.
In the case of outsourcing arrangements, the Company shall ensure that the entity to which the activity is outsourced maintains a record of personal transactions entered into by any connected person and provides that information to the company promptly on request.
A separate Personal Transactions Reporting policy is in place to support employees or its officials and have clear guidelines and adequate arrangements regarding personal transactions performed by themselves, which may give rise to Conflict of Interest.
The Company ensures that adequate arrangements are in place to identify, prevent and manage conflicts of interest arising from personal transactions. Such arrangements include pre-transaction controls, ongoing monitoring and post-transaction review, as further detailed in the Personal Transaction Reporting Policy. The Company ensures that personal transactions are subject to appropriate oversight by the Compliance Officer and that any conflicts of interest arising are promptly identified, recorded and mitigated.
All Conflicts of Interest reports and their outcomes will be documented and securely saved in accordance with company policy. The Designated Responsible person will maintain a Conflicts of Interest Register to track all reported conflicts, including:
• The date of the report.
• The nature of the conflict.
• The parties involved.
• The actions taken to mitigate or resolve the conflict.
• The final outcome.
Up-to-date records of all situations giving rise to actual and potential conflicts of interest shall be kept, including the relevant crypto-asset services or activities, and of the measures taken to prevent or manage such conflicts in the relevant situations.
The Company shall ensure that all information relating to conflicts of interest, including the Conflicts of Interest Register and any related documentation, is kept accurate, complete and up to date at all times. Any changes to previously recorded conflicts, mitigation measures or outcomes shall be recorded promptly.
All records relating to conflicts of interest, including disclosures, assessments, decisions and mitigation measures, shall be retained for a minimum period of five (5) years.
Conflicts of Interest are reported to the Board of Administration on a quarterly basis, as part of the Compliance Report which is prepared by the Company’s Compliance Officer. The Conflict of Interest register shall remain available for inspection by regulatory authorities upon request.
For any conflict of interest that requires ongoing monitoring, the Designated Responsible Person will:
• monitor the situation;
• conducts regular follow-up reviews to ensure effective controls of such conflict of interest;
• updates the Board as necessary on the status of the conflict.
The Company is committed to providing clients with clear and sufficient information regarding any Conflicts of Interest that may arise and could affect the services provided.
Where a conflict of interest cannot be prevented or managed, the Company will disclose the general nature, source, and mitigation measures of the potential / existing Conflict of Interest to its clients, to allow clients to make an informed decision about whether to proceed with the service. Information shall include the steps the Company has taken to mitigate the conflict, as well as any remaining risks that the client should consider to ensure full transparency and compliance with regulatory obligations. In such circumstances, the Company shall put this information in a prominent place on its website, disclosing to its existing clients and prospective clients the general nature and sources of conflicts of interest and the steps taken to mitigate them.
The purpose of disclosing Conflicts of Interest is to ensure transparency and allow clients to make informed decisions based on situations that may influence the services they receive or the impartiality of the Company.
Disclosure shall only be made where the Company reasonably considers that the arrangements in place are not sufficient to prevent the risk of damage to client interests.
11.1 Disclosure Content• Nature of the Conflict: A concise description of the conflict of interest, explaining the activities or relationships that create the conflict.
• Source of the Conflict: Information on the source of the conflict, whether it is internal (e.g., personal interests or business ties of connected persons) or external (e.g., relationships with third parties or investments).
• Impact on Clients: An explanation of how the conflict may impact the services provided to clients or the impartiality of decision-making.
• Steps Taken to Mitigate the Conflict: A description of the measures taken by the Company to mitigate or manage the conflict, such as the implementation of information barriers, the segregation of duties, or the use of independent decision-makers.
11.2 Disclosure CommunicationDisclosures shall be available to clients at all times and on any devices. Where the company makes disclosures available on the relevant device, the company should also provide a link to the disclosures on its website. The following methods in all languages used by the Company to market its services:
• Website Disclosure: Disclosures will be made available in a clear and prominent location on the Company's website, providing clients with easy access to information on Conflicts of Interest.
• Direct Communication: For specific conflicts related to individual clients, disclosures will be made directly to the client through email or another agreed method of communication.
11.3 Disclosure TimingDisclosures will be made as soon as a conflict of interest is identified and cannot be fully mitigated by internal controls. This ensures that clients receive timely information, enabling them to make informed decisions regarding their services.
11.4 Clients’ RightsClients will be provided with sufficient information to decide whether to proceed with the service in light of the disclosed conflict of interest. Clients have the right to:
• request further details on the nature and mitigation of the conflict;
• discuss alternative measures or request additional safeguards from the Company; or;
• decline the service if they believe the conflict poses a significant risk to their interests.
The Compliance Officer shall regularly review and recommend update on the Conflicts of Interest policy to ensure that they remain effective and compliant with evolving regulatory requirements. The review shall cover:
• An annual review of internal systems and controls to identify any gaps or areas for improvement.
• Regular training of employees to ensure they are aware of their responsibilities in preventing, managing, and disclosing Conflicts of Interest.
• Monitoring compliance with policies and reporting to senior management as necessary.
The Board of Administration is responsible for approving the Conflicts of Interest Policy at least, once annually.
The Board of Administration shall seek advice from the Compliance Unit prior to approving any changes to this Policy. Approved changes will be documented in this Policy, which will be distributed to all identified staff as defined within this policy, and clients, as detailed in this policy.
Please disclose below any areas and/or circumstances in which you are involved that may contribute to a Conflict of Interest, such as outside work, ownership, investment and relationships.
Date of
Reported
Conflict
Name of the person
declaring a conflict
Position
Meeting or event where conflict arose
Details of the conflict
Action taken
in
response to the conflict
I hereby certify that the above information is true and complete to the best of my knowledge and belief. I have read, understand, and agree to the Conflicts of Interest Policy. I recognise that I have an obligation to notify the Compliance Officer of the above-mentioned Conflict of Interest and to abstain from any participation in the matter until the Company can determine whether a conflict exists and how that conflict shall be resolved.
________________________ __________________________
Employee's Name and Surname Employee's Signature
________________________
Date of notification
For Internal Use
Reference Number:
Received on:
Acknowledged on:
Compliance Officer
Recommendations:
Compliance Officer Signature:
Board of
Administration Decision:
BoA Signatures
Employee Informed
Recorded in the
Conflict of Interest
Register
I have read CF Technologies Limited's Conflict of Interest Policy approved by the Board of Administration and understand that as an employee of the Company, it is my obligation to act in a manner that promotes the best interest of CF Technologies Limited and to avoid Conflicts of Interest when making decisions and taking actions on behalf of CF Technologies Limited.
Should a possible conflict of interest arise in my responsibilities to CF Technologies Limited, I have an obligation to notify the Compliance Officer and abstain from any participation in the matter until the Company can determine whether a conflict exists and how such conflict will be mitigated.
I understand that the information on this form is solely for use by CF Technologies Limited and is considered confidential information. Therefore, the release of this information within CF Technologies Limited will only be on a need-to-know basis. Release to external parties will only be made when required by law.
____________________________________________________________
Name, Signature & Date
