C.6 Conflict of Interest Policy

PART C.6 — CONFLICT OF INTEREST POLICY

This page forms part of Part C (ODIX Deposit by Card). It explains how the Conflict of Interest Policy of our card-purchase partner, a licensed on/off-ramp partner (the "Card Purchase Partner"), applies when you use Deposit by Card in the ODIX Pay App, and summarises its main points.

Important: this is a summary prepared by ODIX for your convenience. The legally binding document is the Card Purchase Partner's Conflict of Interest Policy, which is shown to you at checkout before you accept it and is available on request from support@odixpay.com. If this summary and the partner's document differ, the partner's document applies.

1. HOW THIS RELATES TO ODIX

ODIX makes Deposit by Card available in the ODIX Pay App. The service itself — the card payment, the exchange and the delivery of Digital Assets to your ODIX Wallet — is provided entirely by the Card Purchase Partner, which for customers in the United Kingdom and the European Economic Area is a company of its group established in the European Union.

ODIX and the Card Purchase Partner have a commercial arrangement under which ODIX makes the Card Purchase Partner's service available in the ODIX Pay App. ODIX may receive a commission or other payment from the Card Purchase Partner in connection with orders placed through the App. This does not change the price the Card Purchase Partner shows you, and you can always see the full price before you confirm.

ODIX does not give advice or recommendations about buying Digital Assets, and nothing in the App should be read as a recommendation to use Deposit by Card.

2. SCOPE

The policy of the Card Purchase Partner's EU company covers all its crypto-asset services and conflicts between the Card Purchase Partner and its clients, between clients, and involving its shareholders, board members, employees and affiliated companies.

3. CONFLICTS THE CARD PURCHASE PARTNER HAS IDENTIFIED

The Card Purchase Partner making a financial gain at a client's expense; receiving third-party commissions that could affect client outcomes; favouring some clients over others; connected persons with conflicting financial interests; personal or professional relationships that could create bias; combined roles that weaken oversight; relationships with affiliates and service providers; and conflicts specific to crypto-assets, such as relationships with issuers, liquidity providers and custodians.

4. HOW THE CARD PURCHASE PARTNER MANAGES THEM

Oversight by its Management Board and an independent Compliance Department; documented procedures to identify and escalate conflicts; segregation of duties and restricted access to information; approval and monitoring of employees' personal transactions; enhanced monitoring of higher-risk relationships; balanced remuneration; disciplinary measures; and, where needed, extraordinary measures such as suspending an activity.

5. DISCLOSURE TO YOU

Where its arrangements cannot ensure with reasonable confidence that your interests will not be harmed, the Card Purchase Partner will clearly disclose the remaining conflict to you on a durable medium before providing the service.

6. REVIEW

The Card Purchase Partner monitors its activities continuously, its Compliance Department reviews the policy at least once a year, internal audit tests it independently, and the Card Purchase Partner keeps a register of conflicts, personal transactions and decisions taken.

7. FULL DOCUMENT AND QUESTIONS

The complete Conflict of Interest Policy of the Card Purchase Partner is shown to you at checkout before you accept it and is available on request from support@odixpay.com. The Card Purchase Partner may update it at any time; the version it currently publishes is the one that applies.

Questions about the card-purchase service go to the Card Purchase Partner through the support channels shown at checkout, or via support@odixpay.com. Questions about the ODIX Pay App go to us at support@odixpay.com.