Conflict of Interest Policy Statement
UPDATED SEPTEMBER 2025
Introduction
MANTRA Finance FZE (“MANTRA Finance” or the “Firm”) is committed to maintaining the highest standards of integrity, fairness, and professionalism in all our operations. Our Conflict of Interest Policy is designed to protect the interests of our clients and stakeholders by ensuring that all business decisions are made solely in the best interest of the Firm and its clients, free from any personal bias or competing interests. This policy outlines our arrangements for identifying, preventing, and managing conflicts of interest in accordance with the rules set forth by Dubai’s Virtual Assets Regulatory Authority (VARA).
What is a Conflict of Interest?
A conflict of interest arises in any situation where the personal interests of an individual or the interests of the Firm could potentially or actually interfere with their duty to act in the best interests of our clients. This can include financial interests, family ties, or other personal relationships that may compromise impartiality. At MANTRA Finance, we address actual, potential, and even perceived conflicts with equal seriousness to maintain unwavering trust.
Scope and Applicability
This policy is binding on all MANTRA Finance FZE board members, senior management, employees, consultants, and contractors (the “MF team”). It covers all activities where a conflict could arise, ensuring that our collective actions are always aligned with our clients' best interests.
Our Approach to Managing Conflicts of Interest
Our framework for managing conflicts is built on transparency, diligence, and ethical conduct. We take proactive steps to identify, prevent, and manage any conflicts that may arise.
Identification and Disclosure: Every member of the MF team has a mandatory duty to promptly disclose any actual or potential conflict of interest to our Compliance Officer. An open culture of disclosure is fundamental to our approach.
Prevention and Management: We implement robust preventative measures, including requiring prior written approval for all personal virtual asset trades and for accepting any outside directorships or advisory roles. When a conflict is identified, we take decisive action to manage it, which may include recusing individuals from decision-making or declining to proceed with a matter.
Transparency with Clients: In the rare event that a conflict of interest cannot be reasonably avoided, we are committed to disclosing the nature of the conflict to any affected clients to ensure they are treated fairly and can make fully informed decisions.
Monitoring and Review: All disclosed conflicts and the measures taken to manage them are recorded in a formal register. We conduct continuous monitoring to ensure compliance with this policy, and any violations are subject to disciplinary action.
Our Commitments to You
To ensure our interests are aligned with yours, MANTRA Finance adheres to the following strict operational commitments:
No Speculative Proprietary Trading: MANTRA Finance is prohibited from actively or speculatively trading a portfolio of Virtual Assets for its own account. Any trading on the Firm's own account is strictly limited to the prudent management of our treasury and liquid assets and is never for speculative gain.
Strict Personal Trading Rules: We enforce stringent internal controls over the personal trading activities of our entire team. All team members must obtain prior written approval from our Compliance department before conducting any personal transaction in a Virtual Asset and must formally declare their holdings on a semi-annual basis. This helps prevent market abuse and ensures our clients' interests come first.
Upholding Independence: When MANTRA Finance represents itself as being independent in conducting any activity, we do not receive fees, commissions, or any other benefits from any party other than our client. We avoid any relationships that could impair our ability to act independently and in your best interest.
Disclosure and Management of Specific Conflicts
To ensure full transparency, MANTRA Finance wishes to disclose the following potential and actual conflicts of interest and the steps we take to manage them:Service Fees: MANTRA Finance earns revenue through fees and commissions charged for the services we provide. The Firm, therefore, benefits from client activity on our platform, regardless of whether such activity is profitable for the client. To manage this conflict, we are committed to full transparency. Our complete fee schedule is publicly available on our website, ensuring you are aware of all costs associated with our services before you transact.Supporting Virtual Assets: The decision to support or not support a Virtual Asset on our platform may present a potential conflict of interest, particularly if the Firm receives any form of compensation from a third-party project issuer. Should the Firm receive a listing fee or any other benefit for supporting a Virtual Asset, we will clearly disclose this information to our clients. Importantly, any such commercial arrangement does not guarantee inclusion on our platform. Every Virtual Asset must pass our rigorous internal due diligence and assessment framework to be supported by the Firm.Proprietary Trading: MANTRA Finance is prohibited from engaging in speculative proprietary trading. We do not operate a business that trades on our platform for our own speculative benefit. Any trading conducted for the Firm’s own account is strictly limited to the prudent management of our treasury and net liquid assets, as required for our operational and regulatory obligations.Referrals and Third-Party Services: MANTRA Finance does not engage in referral arrangements where we would receive a commission for introducing clients to other Virtual Asset Service Providers or other entities. Furthermore, the Firm does not hold funds, provide clearing services, or act as a custodian for other VASPs. Our operational focus remains solely on serving our direct clients.Client Responsibility: MANTRA Finance is committed to treating all clients fairly and ethically. However, unless explicitly stated in the terms of a specific service (such as our Terms of Services published on our website), the Firm does not act in a fiduciary capacity and has no duty to act on your behalf. You are solely responsible for your own decisions and for determining whether our services are suitable for your individual circumstances and risk tolerance.
Conclusion
Our Conflict of Interest Policy is a cornerstone of our commitment to building and maintaining the trust of our clients and the integrity of our services. We are dedicated to ensuring that all business decisions are made objectively, fairly, and in the best interest of those we serve.