Conflict of Interest Policy for Users

introduction
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This Conflict of Interest Policy (hereinafter also the "Policy") is provided to users of YouHodler Italy s.r.l. (hereinafter also the "Company") in accordance with Article 72 of Regulation (EU) 2023/1114 of May 31, 2023, "Regulation on Markets in Crypto-Assets" ("MiCAR"): its purpose is to help users understand what a conflict of interest is, how we manage it, and what this means for you as customers.
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If you have any questions, our support team is here to help.

What is a Conflict of Interest?
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A conflict of interest occurs when personal or financial interests could influence, or appear to influence, the actions or decisions made by our Company or its employees. This could affect the integrity and fairness of our services, or your experience as a user.
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YouHodler Italy S.r.l. has divided Conflicts of Interest involving Clients into 2 categories:
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First category
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This includes conflicts of interest between the Company and clients. An example of this category could be, for instance, when we execute orders on behalf of clients, and at the same time operate a crypto-asset trading platform, or a group entity is operating that platform.
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Second category
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Includes conflicts of interest between individual clients and groups of clients of the Company. An example of this category is when two clients separately seek to purchase a specific service at the same time, and the Company is obligated to sell that asset to one of the clients after the terms and all relevant information regarding the transaction have already been agreed upon.

Other Examples of Conflicts of Interest
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Some situations that could create conflicts of interest include:

When an employee of YouHodler Italy S.r.l. has a personal or financial interest in your transaction

When YouHodler Italy S.r.l. or its staff receive incentives from third parties that could influence the services or advice provided to you

When the Company’s own investments or positions could influence the execution or settlement of your transactions

Our Approach to Conflicts of Interest
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 YouHodler Italy S.r.l. is committed to managing conflicts of interest in an honest and fair manner. Our approach includes:
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Identifying and assessing areas where conflicts may arise.
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Avoiding conflicts of interest whenever possible.
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Maintaining records of identified conflicts and their management.
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Implementing internal controls and a strict code of ethics for staff.
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Training staff to recognize and manage conflicts.
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Timely and clear disclosure of significant conflicts to users.

The Company has established various systems to prevent conflicts of interest. A non-exhaustive list of these measures includes the following:

Clear rules for the management and allocation of client orders

Executes and allocates client orders based on predefined and transparent criteria (e.g., time/price priority)
Prohibits preferential treatment of certain clients over others in the same situation

Segregation of roles and separation of functions

YouHodler Italy S.r.l. separates, where feasible, the functions of trading, execution, custody, and advisory/marketing, so that one client cannot gain an unfair advantage over another (e.g., access to order flow or other clients’ positions)

Restrictions on Information Sharing (“Chinese Walls”)

The Company implements controls to prevent the sharing of non-public or sensitive information about a client (positions, orders, strategies) that could benefit another client

Fair pricing and non-discriminatory terms

Applies the same prices, commissions, and execution terms to comparable clients and comparable transactions, unless objectively justified and clearly documented

Controls on personal and proprietary trading

The Company establishes rules governing personal transactions by employees and related parties to ensure that they do not engage in front-running or otherwise harm any client, and ensures that such transactions are conducted on arm’s-length terms

Prohibition or restriction of certain high-risk arrangements

Avoids, or strictly controls, arrangements that clearly create conflicts among clients (e.g., commingling of client assets with group entities that are also clients; systematic internalization without safeguards)

Document retention and monitoring of conflict cases

Maintains a conflict of interest register for all identified and managed conflicts among clients and periodically reviews the effectiveness of controls and policies

Last resort – refusal or termination of service

When a conflict between clients cannot be prevented or adequately mitigated, YouHodler Italy S.r.l. refrains from acting or providing the service to one or more of the affected clients.

User Rights and Information
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We will always inform you if a significant conflict of interest arises that could affect you.
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You have the right to request more information about our conflict management at any time.

Key Principles
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Integrity: We prioritize fairness and transparency in all our actions.

Protection: We protect users’ interests and aim to prevent any harm resulting from conflicts of interest. Transparency: We clearly disclose any conflicts that could influence your decisions as a user. Updates

This Policy may be updated periodically to ensure compliance with legal requirements. The most recent version is always available on our website.

Contact
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If you have any questions or concerns, or if you believe there may be a conflict of interest, you can contact us at support@youhodler.com

Last updated: December 1, 2025