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Conflict of Interest Policy

This document explains how Unramp OOD identifies, prevents, manages and discloses situations that may give rise to a conflict of interest when providing crypto-asset services to our clients.

Under MiCA Article 72 and Commission Delegated Regulation (EU) 2025/1142 specifying the requirements for conflict of interest policies for CASPs, crypto-asset service providers (CASPs) must establish and maintain a written internal conflict of interest policy and must disclose on their website the general nature and sources of conflicts of interest and the measures taken to mitigate them. This requirement is implemented in Bulgarian law through ZPKA and is applied by the Bulgarian Financial Supervision Commission (FSC) as the competent supervisory authority.

This document is a high-level overview for clients and does not reproduce our full internal procedures. Our complete internal Conflict of Interest Policy is maintained as a confidential regulatory document and is available to the FSC upon request.

What Is a Conflict of Interest

A conflict of interest may arise when the interests of Unramp OOD, our staff members or related parties do not align with, or may be in conflict with, the interests of a client or group of clients — or when the interests of two or more clients are directly competing.

In practice, conflicts of interest can be:

  • Firm vs client: where Unramp's own financial interest could influence the terms or quality of service offered to a client — for example, where we trade the same crypto-assets on our own account as those we offer to clients.

  • Staff vs client: where a staff member's personal interests, personal transactions or remuneration incentives create a risk of bias in the service provided.

  • Client vs client: where serving the interests of one client could disadvantage another client — for example, through differential pricing or priority of execution.

  • Third-party vs client: where relationships with liquidity providers, payment processors or other business partners could influence the conditions offered to clients in a way that is not in their best interest.

Illustrative examples of potential conflicts at Unramp:

  • Unramp trades crypto-assets on its own account (proprietary trading) while also providing exchange services to clients in the same assets — creating a potential tension between its position and the rates offered to clients. Staff personal transactions in crypto-assets available through the Platform are subject to pre-clearance requirements and must be reported to the MLRO/CCO within three business days of execution.

  • Unramp's revenue depends on commission and spread income, which could create an incentive to quote less favourable rates than the market would otherwise support.

  • Unramp selects liquidity providers and payment processors based on ongoing commercial relationships, which could influence the pricing or execution quality available to clients.

Identifying Conflicts of Interest

Unramp maintains an internal framework to systematically identify potential and actual conflicts of interest. This framework takes into account:

  • our business model and the specific nature of the exchange services we provide;

  • relationships with related parties, including group entities, key liquidity providers, payment processors and strategic partners;

  • remuneration structures and incentive schemes applicable to our staff;

  • typical scenarios in which Unramp's interests, staff interests or third-party interests may conflict with those of clients.

This assessment is reviewed at least annually and whenever there are material changes to our services, product range, business relationships or regulatory environment. The results are documented and reported to senior management.

Preventing and Managing Conflicts of Interest

Our priority is to prevent conflicts of interest wherever possible. Where they cannot be fully avoided, we manage them in a way that protects clients' interests and market integrity.

Organisational measures

  • Information barriers: we maintain organisational separation between teams where conflicts of interest may arise, including between any proprietary trading activity and client-facing operations.

  • Remuneration controls: our remuneration structures are designed to avoid incentivising staff to prioritise Unramp's interests or their own interests over those of clients. Variable remuneration linked to individual transaction volume or revenue is subject to specific restrictions.

  • Personal account dealing: staff are subject to restrictions and internal approval requirements for personal transactions in crypto-assets that are also available through the Platform, to prevent front-running or other conflicts.

Operational measures

  • Counterparty selection: we apply standardised, documented criteria for the selection and assessment of liquidity providers, payment processors and other counterparties. Selection is not based solely on internal commercial interests.

  • Transaction monitoring: we monitor our own transactions and those executed for clients to identify any patterns that may indicate a conflict of interest or market abuse.

  • Pricing transparency: all commission and spread applied to client transactions are disclosed to the client in the transaction summary before confirmation, in accordance with MiCA Article 66(4).

Governance measures

  • Periodic review of the conflict of interest register by senior management;

  • staff training on recognising and escalating situations that may involve a conflict of interest;

  • a clear escalation path for staff to report potential conflicts to the compliance function.

The conflict of interest register is maintained in writing and updated following each annual review or whenever a new conflict is identified. A summary of the register is available to the FSC upon request.

Disclosures to Clients

Where a specific conflict of interest cannot be fully prevented or eliminated through the organisational and operational measures described above, Unramp will disclose to the affected client:

  • the general nature of the conflict of interest;

  • its main sources (for example, Unramp acting as counterparty to the transaction, a relationship with a related party, or the way remuneration is structured);

  • the key steps we have taken or propose to take to mitigate the associated risk.

Disclosures are made in a clear and understandable way before the client decides whether to use the relevant service. Depending on the nature of the conflict, disclosure may be made:

  • in the Terms and Conditions, where the conflict is systemic and applies to all clients;

  • in the pre-transaction information flow on the Platform, where the conflict relates to a specific transaction or product;

  • in separate written communication to the client, where the conflict is specific to that client's circumstances.

Importantly, disclosure is an additional safeguard and does not replace our obligation to take all reasonable steps to prevent and manage conflicts of interest in the first place. Disclosure is used only where residual risk remains after all available organisational and operational measures have been applied.

Situations Where We May Refuse or Restrict a Service

In some cases, where a conflict of interest cannot be managed in a way that reasonably protects clients' interests — even after applying all available measures and making appropriate disclosures — Unramp may:

  • decline to provide a specific service or execute a particular transaction;

  • decline to provide further services to a particular client where the conflict cannot be adequately resolved;

  • impose additional conditions, limitations or requirements (for example, transaction limits, a change of counterparty or pricing adjustments) in order to reduce the risk of harm to the client.

Such decisions are taken only where the residual risk to clients remains excessive and cannot be reduced further by other means. Where legally permissible, we will inform the client of the reason for any restriction or refusal.

A client who believes that a conflict of interest has adversely affected their transaction may submit a complaint in accordance with our Complaints Handling Policy.

This summary should be read together with the following documents, all of which are available on our website:

  • Terms and Conditions — including pre-transaction disclosures and conflict of interest acknowledgements

  • Complaints Handling Policy — for clients who believe a conflict of interest has adversely affected their transaction

  • AML/CFT Statement — for information on how we manage financial crime risks

  • Privacy Policy — for information on how we process personal data in connection with conflict management

  • Pricing and Fees Policy — for full details of fees, commission and spread

In case of any inconsistency between this summary and applicable laws or regulatory requirements, the latter shall prevail.

Questions about this Policy

Please contact us:

Email: [email protected]

Post: Unramp OOD, 22 San Stefano Str., San Stefano Plaza, entr. B, 5th fl., office 16, Sofia 1504, Bulgaria

Website: unramp.com

This document is a client-facing summary of Unramp OOD's internal Conflict of Interest Policy, published in accordance with MiCA Article 72 and ZPKA. It does not constitute legal advice and does not reproduce the full internal policy. The full internal policy is maintained as a confidential regulatory document.