Conflicts of Interest Disclosure

Last Updated: 18 March 2026

1. Purpose of this disclosure

This disclosure applies to the Due group as a whole and is prepared in accordance with Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA) and its implementing legislation, in particular Commission Delegated Regulation (EU) 2025/1142.

This document provides an accessible description of the general nature and origin of potential conflicts of interest that may arise in the provision of crypto-asset services by Due, as well as the main measures applied to identify, prevent, manage and, where appropriate, disclose them.

2. Scope

This disclosure applies to all crypto-asset services provided by any entity within the Due group. Due manages conflicts of interest that may arise between:

  1. The Entity and its connected persons, meaning:
    •  Its shareholders or partners.
    • Any natural or legal person directly or indirectly linked to Due or to its shareholders through a control relationship.
    • Members of its management body
    • Its employees.
    • Its clients.
    • Other relevant third parties: delegates, subcontractors, consultants or service providers of Due, to the extent that their relationship with the Entity may give rise to a conflict of interest.
  2. Two or more clients whose interests may conflict with each other through the services provided by Due.
  3. The Entity and other companies within the Due group.
  4. Connected persons among themselves, where such a situation may compromise the objective and independent performance of their functions.

3. Main scenarios of potential conflicts of interest

3.1 Conflicts between Due and its clients

Due identifies the following as potential sources of conflict between the Entity and its clients:

  1. Due, an entity within the group, a connected person, or a third party linked through a control relationship may obtain a financial benefit or avoid a financial loss at the expense of the client.
  2. A connected person has an interest in the outcome of a service provided to the client or a transaction carried out on the client’s behalf that differs from the client’s interest in that outcome.
  3. There are financial or other incentives to favour the interests of one client or group of clients over the interests of another client.
  4.  Due carries out the same activity as the client, competing with them.
  5. Due or a connected person receives from a third party an incentive — monetary, non-monetary or in the form of a service — in relation to a service provided to the client, beyond the standard commission or fee agreed with the client.

3.2 Conflicts between clients

Due identifies the following as potential sources of conflict between clients:

  • Due has more than one client with an interest in the outcome of the same transaction.
  • The interests of one client may conflict with those of another in terms of priority or treatment in the execution of the service.

3.3 Internal conflicts: economic interests within the group

Due identifies the following as potential sources of internal conflict: 

  • A connected person holds an economic interest in a person, body or entity whose interests conflict with those of Due.
  • A connected person has or has had within the last three years a personal, professional or political relationship with a person or entity whose interests conflict with those of Due.
  •  A connected person performs contradictory tasks, holds incompatible responsibilities, or is subject to hierarchical supervision by a person responsible for conflicting functions. 

4. General measures for managing conflicts of interest

Due applies a control framework designed to ensure that conflicts of interest do not harm the interests of its clients or the integrity of the Entity. The main measures are: 

  • Priority to client interests: Priority is given to the client’s interest and fair treatment, with no undue preferential treatment between clients.
  • Segregation of functions: Functional, hierarchical and physical separation between commercial, compliance, risk management and client complaint-handling functions.
  • Information barriers: Information barriers to prevent and control the exchange of sensitive or confidential information between persons or areas whose activities may conflict.
  • Neutral remuneration: Variable remuneration policies do not create incentives that lead employees or managers to prioritise commercial results over client interests or regulatory compliance.
  • Incompatibility of roles: Directors and key staff of Due may not hold management positions in competing crypto-asset service providers outside the Due group.
  • Management body declarations: Members of the management body are required to declare any personal interest before deliberating on matters in which they may be involved, and to abstain from voting in such cases.
  • Internal reporting channel: Any connected person must promptly and confidentially report any situation that may give rise to a conflict of interest. No reprisals will be permitted against those who report in good faith.
  • Conflicts register: All identified conflicts of interest, the measures taken and their resolution are documented in an internal register available to the competent authorities.
  • Ongoing supervision and annual review: The compliance officer reviews this policy at least once a year and issues periodic reports to senior management.
  • Training: Due provides periodic training to its employees and managers on the identification of conflicts of interest and their applicable obligations.

5. Management procedure

5.1 Identification

Due’s compliance officer takes all necessary measures to identify situations that may give rise to conflicts of interest. Connected persons are required to:

  • Promptly communicate any situation that may constitute a conflict of interest.
  • Report conduct or facts that may breach this policy.
  •  Provide all information necessary for a proper assessment of the conflict.

5.2 Prevention and mitigation

The objective is to prevent conflicts from arising or, where this is not possible, to manage them in a way that protects the interests of clients. To this end, Due:

  •  Provides ongoing training on conflicts of interest.
  •  Periodically reviews its policies and procedures.
  •  Continuously monitors its operations and activities.
  •  Applies organisational and internal control measures to minimise risks.

5.3 Resolution

Conflicts of interest are resolved by the head of the affected area. Where multiple areas are involved, resolution falls to the nearest common hierarchical superior. Where neither of the foregoing rules applies, the conflict is resolved by the compliance officer.

Key resolution principles:

  • Priority to the client’s interest.
  •  Prohibition on favouring one client over another.
  •  Prohibition on disclosing transactions between clients.
  • Prohibition on soliciting or accepting payments, commissions, gifts or any other benefits from clients, suppliers, intermediaries or third parties in connection with the Entity’s transactions, or on obtaining any personal benefit derived from the position held.
  •  Restrictions on relationships with suppliers and competitors.

6. Disclosure to clients

Where internal measures are not sufficient to neutralise the risk with reasonable certainty, Due will disclose the conflict of interest to the client clearly, before providing the affected service, so that the client can make an informed decision.

This communication will be made on a durable medium (email or platform notification) and will include:

  • The nature and origin of the conflict of interest.
  • The measures taken to mitigate it.
  • The potential impact on the service or transaction in question.

Conflicts that may affect a large number of clients or the integrity of the market will also be notified to the relevant competent authority.

7. Contact

For any enquiries regarding this disclosure or to request the full text of the Conflicts of Interest Management Policy, please contact us at:

compliance@due.network

This document is a summary of the Due Group Conflicts of Interest Management Policy, prepared in accordance with Article 72(2) of Regulation (EU) 2023/1114 (MiCA). In the event of any discrepancy between this summary and the full text of the internal policy, the full text of the policy shall prevail.

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