Conflicts of Interest Disclosure – BITX, S.L.

1. Why this disclosure is published

1.1 BITX, S.L. ("BITX") provides the crypto-asset service of exchange of crypto-assets for funds, acting as principal. Article 72 of Regulation (EU) 2023/1114 (MiCA) requires BITX to maintain and implement a policy to prevent, identify, manage and disclose conflicts of interest, and to inform its Clients and prospective Clients of the general nature and sources of the conflicts that may arise and of the steps taken to mitigate them. This document contains that information. It summarises BITX's Conflicts of Interest Policy, which is approved by BITX's management body and applies to its directors, employees and persons acting on its behalf (the "Relevant Persons").

1.2 A conflict of interest arises where the interests of BITX, of a Relevant Person or of a person linked to BITX differ from those of a Client, or where the interests of two Clients differ, in a way that could damage a Client's interests.

2. General nature and sources of conflicts of interest

2.1 BITX as the Client's counterparty. BITX does not act as the Client's agent: it sells crypto-assets to the Client from its own inventory and buys crypto-assets from the Client on its own account. BITX's remuneration is the margin included in the price it quotes. BITX therefore has an interest in the price it quotes that differs from the Client's interest in obtaining the lowest price for a purchase or the highest price for a sale.

2.2 Management of BITX's own positions. BITX holds and manages its own inventory of crypto-assets and funds, and covers the positions it takes with Clients by buying or selling on the trading venues of its choice. The timing and the venues of that cover, and BITX's own treasury decisions, may affect the reference prices BITX observes and the margin it applies.

2.3 Related entities. BITX's sole shareholder controls other companies, one of which provides BITX with information-technology support services. Contracts between BITX and related entities give rise to a potential conflict between the interests of BITX, and indirectly of its Clients, and those of its shareholder.

2.4 Other activities of Relevant Persons. Members of BITX's management body and other Relevant Persons may hold positions, interests or professional activities outside BITX, including in companies active in the crypto-asset, payments or financial sectors, and may have personal or professional relationships with Clients, providers or business partners of BITX.

2.5 Personal transactions. Relevant Persons may hold and deal in crypto-assets on their own account and could be in a position to use information about Clients' transactions or BITX's positions for their own benefit.

2.6 Remuneration. The remuneration of Relevant Persons could create an incentive to favour BITX's interests, or their own, over the interests of Clients.

2.7 Providers and outsourced functions. BITX relies on third-party providers, including identity-verification, blockchain-analytics, cloud and compliance-support providers and liquidity venues. The selection of providers, and any benefit a Relevant Person might receive from them, could conflict with the interests of BITX and its Clients.

2.8 Between Clients. Information about one Client's transactions could be used to the advantage of another Client, or one Client could be favoured over another in the allocation of BITX's liquidity.

2.9 Gifts and inducements. Relevant Persons could receive gifts, hospitality or other benefits from Clients, providers or third parties that could influence their conduct.

3. Measures adopted by BITX

3.1 Price transparency and a single pricing method. BITX applies to every Client the price-formation method described in its Pricing, Costs and Fees Policy, published on this website, and states the all-in price, the margin and any fee in every Quote before the Client accepts it. The Terms and Conditions disclose that BITX acts as principal, that its remuneration is included in the price and that it does not owe best execution. Reference prices, their sources and the margin applied are recorded for every transaction and can be reviewed after the event.

3.2 Firm prices and market risk. Once a Client accepts a firm price, BITX bears the market risk until settlement and does not pass on subsequent market movements to the Client. BITX covers its positions on its own account and never uses the funds or crypto-assets of one Client to serve another.

3.3 Related-party arrangements. Contracts with related entities are concluded on arm's-length terms, documented in accordance with the rules on related-party transactions and transfer pricing, submitted to BITX's management body with the abstention of any conflicted director, and kept under review. Related providers have no access to Client files or to BITX's private keys.

3.4 Identification, registration and escalation. Relevant Persons must report to the compliance function any circumstance that may give rise to a conflict of interest, including outside activities, relationships with Clients or providers and public offices. The compliance function assesses each case and decides how it is managed; conflicts that cannot be resolved at departmental level are decided by the compliance function. BITX keeps a register of the conflicts identified, the persons and departments involved and the measures taken; the register is retained for at least five years, or up to seven years if the CNMV so requests, and is reported to the management body at least annually.

3.5 Rules of conduct in case of conflict. Where a conflict arises between BITX and a Client, the Client's interest prevails. Where it arises between Clients, BITX does not favour either of them, does not disclose to one Client the transactions of another and does not encourage a Client to transact in order to benefit another. Where a conflict cannot be managed by these means, BITX refrains from acting or, where the law so requires, informs the Client concerned before acting.

3.6 Personal transactions. Relevant Persons are subject to rules on personal transactions in crypto-assets: they must inform BITX of their personal transactions, which are recorded, and they may not carry out transactions that are prohibited by MiCA, that involve the misuse or improper disclosure of confidential information or that conflict with BITX's obligations. The same rules apply to transactions carried out through persons closely associated with them.

3.7 Remuneration. BITX's remuneration arrangements are designed so as not to create incentives that could lead Relevant Persons to favour their own interests or BITX's interests to the potential detriment of Clients.

3.8 Confidentiality and segregation. Relevant Persons are bound by confidentiality obligations. Access to Client files and transaction records is restricted to the persons who need it for their functions, and decisions concerning Clients' transactions are taken independently of any area whose interests might differ from those of the Client.

3.9 Providers. Providers are selected and reviewed on objective criteria. Relevant Persons may not accept gifts, hospitality or other benefits from Clients, providers or third parties beyond a reasonable value, and must declare any that they receive.

3.10 Training and review. Relevant Persons receive training on the Policy. The compliance function reviews the Policy and this disclosure at least annually and whenever BITX's activities or organisation change, and reports its findings to the management body.

4. Further information

4.1 Clients may request further information about BITX's management of conflicts of interest by writing to legal@bitx.es.