Conflicts of interest disclosure
Our business is about people and trust. Only by acting professionally and with integrity we can maintain our stakeholders’ confidence and preserve our reputation. We take measures to prevent conflicts of interest occurring between Amdax and our clients or employees, as well as between one client and another, or between a client and an Amdax employee.
Amdax’s policy on conflicts of interest aims to:
Amdax’s policy on conflicts of interest applies to the whole organization, including its shareholders and members, everyone working for or on behalf of Amdax, including third parties, temporary staff, as well as senior managers and board members.
We have identified the following services, activities or circumstances giving rise, or that may potentially give rise to one or more conflicts of interest, from the perspective of our clients, our employees or ourselves or any representative or entity belonging to the Amdax group.
Nature of Risk: A potential conflict of interest can occur when client orders are routed to trading venues or liquidity providers, where Amdax may receive financial incentives such as rebates or discounts from certain execution venues.
Risk Description: This creates the possibility that Amdax prioritizes its own financial benefits over the client’s best interest, potentially leading to the selection of venues that offer less favorable execution quality. As a result, clients may experience inferior pricing or execution outcomes.
Mitigating Action: To address this, Amdax enforces a strict order execution policy that disallows the acceptance of any financial incentives from execution venues. All routing decisions are based exclusively on objective criteria — including price, liquidity, execution speed, and likelihood of execution — to ensure optimal outcomes for clients.
Nature of Risk: A conflict of interest may emerge if Amdax were to give preferential treatment to related parties or high-volume clients, prioritizing their orders over others. This could result in disparities in execution quality or speed.
Risk Description: The incentive to favor clients with significant trading volumes or personal affiliations could undermine the principle of fair and equal treatment, causing delays or suboptimal execution for other clients.
Mitigating Action: To prevent such bias, Amdax employs a smart order routing system that evaluates and processes all orders using objective execution factors — including price, liquidity, and timing — without regard to client identity, ensuring consistent and impartial treatment for all clients.
Nature of Risk: In the context of portfolio management, conflicts of interest can arise when performance-based fee structures are used, potentially incentivizing portfolio managers to pursue higher-risk strategies to boost returns.
Risk Description: This may lead to investment decisions that deviate from a client’s established risk profile or long-term goals, increasing the exposure to market volatility or potential losses in pursuit of higher fees.
Mitigating Action: Amdax mitigates this risk by clearly disclosing all fee structures, including performance-based arrangements, on its website. Moreover, all investment strategies are tailored to the client’s individual risk profile and subject to internal oversight to ensure adherence to the agreed investment mandate and prevent undue risk-taking.
Nature of Risk: A conflict of interest may occur if portfolio managers engage in personal trading based on non-public information about upcoming client transactions, potentially executing their own trades before fulfilling client orders.
Risk Description: Such front-running behavior places employee interests above those of clients, potentially resulting in adverse price movements for clients. This can negatively impact the timing and pricing of client transactions, leading to diminished investment performance.
Mitigating Action: Amdax strictly prohibits front-running and enforces a comprehensive personal trading policy. The company has implemented a Prevention of Market Abuse Policy, and any personal trades involving low-liquidity crypto-assets require pre-clearance by the Compliance department. These trades are also closely monitored to ensure adherence to ethical standards and to safeguard client interests.
Nature of Risk: A conflict of interest could arise if Amdax were to commingle client assets with its own, potentially compromising asset integrity and client protection, particularly in the event of insolvency.
Risk Description: The mixing of assets may obscure ownership rights and increase the risk of misappropriation or loss of client funds. In scenarios involving insolvency, clients could experience delays, inaccessibility, or even loss of their assets due to a lack of clear legal segregation.
Mitigating Action: To eliminate this risk, Amdax enforces strict legal and operational segregation of client assets. Crypto-assets are held via a dedicated, separate custody vehicle that is bankruptcy-remote and designed exclusively to safeguard client holdings, thereby ensuring clarity of ownership and protection under all circumstances.
Nature of Risk: A conflict of interest may arise if Amdax were to stake client-owned crypto-assets for its own benefit, potentially generating revenue (e.g., staking fees) from assets that belong to clients.
Risk Description: Such actions could compromise asset availability or liquidity, and expose clients to risks such as crypto-asset loss or delayed access, particularly if those assets are locked up or affected by network-level risks during staking.
Mitigating Action: Amdax mitigates this risk by maintaining a strict policy of not staking client crypto-assets for its own benefit. This ensures client holdings remain fully accessible, liquid, and free from any unintended exposure or use for proprietary purposes.
Nature of Risk: A conflict of interest may occur if overlapping or undisclosed fees are charged across different services, leading to a lack of clarity in the total cost borne by the client.
Risk Description: Insufficient fee transparency can result in clients being unaware of the full charges they incur, potentially leading to overpayment or confusion about the services received and their respective costs.
Mitigating Action: Amdax ensures complete fee transparency by clearly itemizing fees for each service. All charges are disclosed upfront and published in a comprehensive fee schedule available on the company’s website, allowing clients to fully understand and anticipate service costs.
Nature of Risk: A conflict of interest may arise if client data collected through one Amdax service is used inappropriately across other services for Amdax’s proprietary benefit. This includes the potential misuse of sensitive client information internally.
Risk Description: Improper use of confidential client data may lead to unauthorized exposure or exploitation, compromising client trust and breaching data privacy expectations.
Mitigating Action: To safeguard client information, Amdax has established strict internal data governance measures, including role-based access controls and confidentiality policies. These controls ensure that access to client data is limited to authorized personnel and only for purposes directly related to the provision of the relevant service.
Nature of Risk: A conflict of interest may arise if employee compensation or incentive structures are tied to metrics such as trading volume, revenue, or profit, potentially motivating staff to prioritize Amdax’s financial outcomes.
Risk Description: This alignment may lead employees to promote services or make investment decisions that benefit the company rather than the client, resulting in biased advice, misaligned service delivery, or suboptimal client outcomes.
Mitigating Action: Amdax addresses this risk through its Remuneration Policy, which is designed to align staff incentives with the best interests of clients. The policy ensures that compensation structures do not create undue pressure to prioritize revenue over client needs, thereby supporting fair and objective service provision.
Nature of Risk: A potential conflict of interest may arise due to overlapping leadership roles, board memberships, or decision-making authority among entities within the Amdax group. Such overlap can create situations where decisions at one entity may inadvertently or deliberately favor the interests of affiliated entities over those of clients.
Risk Description: Dual roles or shared leadership can compromise objectivity, leading to biased decisions that prioritize group-level profitability or strategic interests over equitable client treatment. This may result in diminished independence at the board level and raise concerns about the integrity of governance processes.
Mitigating Action: Amdax mitigates this risk through a robust corporate governance framework that includes clearly defined rules for decision-making, a multi-member board structure to incorporate diverse and independent viewpoints, and a formal governance charter. This model is designed to uphold governance integrity and ensure that all decisions consistently reflect the best interests of clients.
Nature of Risk: A conflict of interest may arise when Amdax enters into transactions with related parties, such as (indirect) loan agreements involving a major shareholder. These arrangements can present opportunities for preferential treatment that may not align with fair market practices.
Risk Description: If not properly structured and scrutinized, related-party transactions may lead to biased decision-making, favoring certain entities within the group. This can undermine objectivity, create inequities, and damage Amdax’s integrity and reputation.
Mitigating Action: To mitigate this risk, all related-party transactions undergo review and validation by the Head of Finance to ensure they are conducted at arm’s length and under market-consistent conditions. In addition, Amdax involves external accountants and tax advisors in the evaluation of such arrangements to ensure transparency, compliance, and fairness.
In individual cases, conflicts of interest may be unavoidable. In this case, Amdax will inform the client(s) regarding the conflict of interest and disclose it accordingly. It is then up to the client(s) to decide whether they wish to conclude the transaction despite the conflict. The disclosure of conflicts of interest is to be regarded as an ultima ratio and not as an alternative to conflicts of interest management measures.
We use cookies to personalize content and advertisements, to offer social media features and to analyze our website’s traffic. We’ll also share information about your usage with our partners for social media, advertising and analysis. These partners can combine this data with data you’ve already provided to them, or that they’ve collected based on your use of their services.