Conflict of interest management policy
Latest update: January 2026
Introduction
Fipto PI SAS ("the Company") has integrated, as part of its activities, a conflict of interest management policy (hereinafter the "Policy") when the following services are performed:
- Payment services:
- 3. The execution of payment transactions associated with an account, including fund transfers to an account with the user's payment service provider or with another payment service provider:
- c) credit transfers, including standing orders
- 5. Acquisition of payment orders
- 3. The execution of payment transactions associated with an account, including fund transfers to an account with the user's payment service provider or with another payment service provider:
- The custody and administration of crypto-assets on behalf of clients;
- The exchange of crypto-assets for funds;
- The exchange of crypto-assets for other crypto-assets;
- The execution of orders on crypto-assets on behalf of clients;
- The providing of crypto-asset transfer services on behalf of clients.
The Company is authorized to perform the aforementioned services as it is licensed by the Autorité de Contrôle Prudentiel et de Résolution as a payment institution under number 17908 and by the Autorité des Marchés Financiers (hereinafter "AMF") as a crypto-asset service provider under number A2026-009, in accordance with the provisions of Regulation 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets ("MiCA").
As a payment institution and crypto-asset service provider, the Company may be faced with situations where the interests of a client could conflict with (i) those of another client or (ii) those of the Company and one of its employees, managers, or shareholders.
Thus, in accordance with Article 72 of MiCA, the Company has implemented a permanent management system for potential conflicts of interest that may arise during the exercise of its activities. This system is organized around the detection, prevention, and management of conflicts of interest.
The objective of this Policy is to ensure that the Company respects good professional practices and carries out its activities in an honest, fair, and professional manner, respecting the primacy of the interests of its clients.
The primacy of client interests is absolute, surpassing not only the personal interests of employees but also those of the company itself. Particular attention is paid to the fair treatment of all clients, so that none receive an undue advantage to the detriment of another.
This summary may be subject to additional information upon request from the client addressed to the Company.
Conflict of Interest
A conflict of interest situation occurs when a person, whether an individual or an entity, faces several divergent interests within the scope of their personal or professional activities. This may lead them to favor one of these interests to the detriment of others, notably to the detriment of the interests of clients or any entity of the Company, thus compromising the independence, loyalty, impartiality, and objectivity expected in the performance of their duties.
The three main categories of potential conflicts of interest are as follows: i) conflicts involving one client and another client; ii) those involving the Company and its clients; iii) those involving the Company's employees or the interests of its clients.
Detection of Conflict of Interest Situations
The Company has implemented adequate internal controls and defined criteria to identify the existence of potential conflicts of interest.
The Company also has alert and complaint procedures related to potential and actual cases of conflicts of interest.
The detection of conflicts of interest is carried out by the Company's compliance department. As such, this department maintains a register of identified conflicts of interest and updates it regularly.
Prevention of Conflicts of Interest
The Company has implemented risk mitigation measures listed in the risk map and described in this document:
- Training: The Company's compliance department sets up training programs. These programs are mandatory and raise awareness of the legal, financial, and reputational risks incurred by the Company when a conflict of interest situation arises and affects the interests of clients.
- Policies and procedures related to professional ethics: This includes, in particular, systems for declaring personal interests and transactions, declaring gifts and invitations, and the implementation of a code of conduct.
- Maintaining a register of conflicts of interest by the compliance department to record all actual or potential conflicts of interest.
- Organizational and administrative arrangements to ensure the independence of employees, mainly through the separation of activities and operations, control of information exchange, and management of outsourcing.
- Implementation of internal controls: The Company implements a permanent and periodic internal control system. This system allows for corrective measures and, if necessary, appropriate sanctions.
Management of Conflicts of Interest
When preventive measures are not sufficient to completely eliminate the risk of harm to the interests of one or more clients, specific actions are put in place to manage the conflict of interest. These actions are adapted to the level of risk to which the client(s) are exposed, notably through the adoption of organizational or administrative arrangements aimed at maintaining the required independence of employees in the performance of their duties.
The Company implements a prior conflict of interest declaration regime for all Employees upon taking office.
In certain cases, the Company may decide on its own to waive an operation or transaction generating a conflict of interest in order to preserve the interests of the clients concerned.
When the measures taken to manage a conflict of interest are not sufficient to ensure, with reasonable certainty, that risks of harm to client interests will be avoided, the Company clearly informs the client of the general nature and/or source of these conflicts of interest, as well as the measures taken to mitigate these risks. This information is provided before acting on behalf of the client to allow them to make an informed decision regarding the investment or ancillary service provided.
Policy Update
This Policy is updated when necessary, particularly in the context of the following events:
- To reflect any change concerning the Company's activities;
- To comply with applicable regulations.
The Company will inform clients by email of any update to this Policy.