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Conflict of Interest Policy

1. Introduction

This Conflict of Interest Policy (hereinafter — the “Policy”) is provided to clients (hereinafter — the “Client” or “you”) by ORAX CORPORATION LLC, incorporated under the Marshall Islands Business Corporations Act and having its registered address at Marshall Islands, Majuro, P.C. 9696, Ajeltake Road No.1 (hereinafter — the “Company”).

The purpose of this Policy is to identify potential conflict of interest situations and to establish measures taken by the Company to prevent or manage such conflicts in order to safeguard the interests of Clients and ensure fairness, transparency, and integrity in the Company’s operations.

2. Scope of the Policy

This Policy applies to all Company activities, its employees, independent contractors, and affiliated entities, including management of Clients’ funds, execution of investment operations, and interaction with third parties.

3. Definition of Conflict of Interest

A conflict of interest arises when the impartial and objective performance of the Company’s duties or those of its representatives is threatened due to:

  • personal benefit (financial or otherwise);
  • family or professional relationships;
  • affiliations with other entities;
  • any other circumstances that may influence impartial decision-making.

A conflict of interest may exist even when the Company derives no actual benefit, provided the circumstances create a risk of compromising objectivity and independence.

4. Examples of Potential Conflicts of Interest

  • Simultaneous provision of services to multiple Clients with overlapping investment interests;
  • Interaction between the Company or its employees and affiliated organizations (including subsidiaries or business partners);
  • Situations where employees or contractors hold personal investments in assets similar to those of the Clients;
  • Preferential treatment of certain Clients for personal reasons (financial or otherwise).

5. Measures to Prevent and Manage Conflicts of Interest

  • Developing and agreeing upon an investment strategy with each Client prior to providing services;
  • Applying a collective investment strategy that avoids contradictions among different Clients’ interests;
  • Implementing standardized operational and internal control procedures to ensure fair treatment of all Clients;
  • Requiring employees to disclose any personal interests that could affect their duties, including shareholding, positions, or other affiliations in external organizations;
  • Prohibiting personal transactions in virtual assets without prior approval from the Company and requiring disclosure of such transactions;
  • Enforcing a gift and entertainment policy that prohibits or requires prior approval of any benefits that could compromise independence.

6. Engagement with Third Parties

The Company may engage third-party service providers (e.g., IT, legal, consulting) to deliver its services. In doing so:

  • Selection of third parties is based on quality and compliance with the Company’s standards;
  • The Company ensures that Clients’ interests are not adversely affected by such engagements;
  • Potential conflicts of interest between third-party providers and Clients are duly assessed and mitigated.

7. Investments Using Company’s Own Funds

When the Company invests its own funds alongside Clients’ investments:

  • The principle of equal treatment of the Company’s and Clients’ interests applies;
  • The Company undertakes not to use insider information to the detriment of Clients;
  • All strategies are agreed upon with Clients prior to service provision.

8. Fees and Remuneration

  • The Company applies a transparent fee structure that avoids incentives conflicting with Clients’ interests;
  • Employee compensation is based on fair remuneration and is not linked to preferential treatment of specific Clients.

9. Compliance and Review of the Policy

  • This Policy is reviewed at least annually or upon changes in the legislation of the Marshall Islands;
  • All Company employees are required to undergo training on this Policy upon onboarding and on a recurring basis.