Bequant — Institutional Trading Infrastructure & Prime Services

1. Legal Basis

This Conflicts of Interest Disclosure is published pursuant to Article 72(2) of Regulation (EU) 2023/1114 on markets in crypto-assets (“MiCA”) and Commission Delegated Regulation (EU) 2025/1142 (“CDR (EU) 2025/1142”). It is reviewed and updated at least annually, or whenever a material change in identified conflicts occurs. The purpose of this disclosure is to inform clients of conflicts of interest that exist or may arise and that carry a material risk of damage to client interests, together with the measures taken to manage those conflicts.

1.1

This disclosure applies to all services provided by Bequant Pro Limited (“BEQUANT PRO”) under its Class 3 VFA Licence (Licence No. VFA/06) and, upon authorisation, under MiCA. It is made available to all clients prior to the provision of services and is published on the BEQUANT PRO website.

1.2

This document is reviewed annually by the board of Bequant Pro Limited. The date of the most recent review is 08 April 2026.

2. Identified Conflict

2.1

UBO / CEO Dual Role.The ultimate beneficial owner (“UBO”) of Bequant Pro Limited holds the position of Chief Executive Officer (“CEO”) of the company. This dual role creates a structural conflict of interest: the individual who holds the ultimate economic interest in the business also exercises day-to-day management authority. This arrangement has the potential for personal financial interests to influence business decisions, including but not limited to pricing, counterparty selection, fee structures, and resource allocation.

2.2

Nature and Scope of the Conflict.Specifically, the conflict may arise in circumstances where the CEO/UBO makes or influences decisions that affect the profitability of BEQUANT PRO and, by extension, his own economic position as beneficial owner. Potential areas of concern include: (a) decisions regarding proprietary trading positions; (b) selection and terms of engagement with counterparties and service providers; (c) remuneration decisions for senior staff; and (d) allocation of business opportunities between BEQUANT PRO and affiliated entities. BEQUANT PRO considers this conflict to be material and has implemented the measures described in Section 3 below to manage it.

3. Mitigation Measures

BEQUANT PRO has implemented the following measures to identify, prevent, manage, and disclose conflicts of interest in accordance with MiCA Article 72 and CDR (EU) 2025/1142:

Written Conflicts of Interest Policy. A comprehensive written policy governing the identification, classification, management, and disclosure of conflicts of interest is maintained. The policy is reviewed and approved by the board of BEQUANT PRO at least annually.

Conflicts Register. A Conflicts Register is maintained and updated upon identification of any new or materially changed conflict. The Register records the nature of each conflict, the parties affected, and the controls in place.

Information Barriers.Structural information barriers (“Chinese walls”) are maintained between BEQUANT PRO's proprietary trading operations and its client-facing functions, limiting the flow of material non-public or commercially sensitive information across business lines.

Pre-Service Disclosure to Clients. Prior to the provision of any service, clients are notified in writing of all material conflicts identified in the Conflicts Register, including this disclosure. Disclosure is made in a manner that allows the client to make an informed decision.

Independent Compliance Function. An independent compliance function is maintained with a direct reporting line to the board, separate from commercial and operational management. The compliance function has authority to escalate conflicts concerns directly to the board without interference from management.

Personal Account Dealing Prohibition. Senior officers and employees in roles with access to client order flow or material non-public information are prohibited from dealing on personal account in instruments that could disadvantage clients.

Escalation Procedure. A defined escalation procedure is in place for conflicts that cannot be adequately managed or mitigated by existing organisational controls. In such cases, the conflict is escalated to the board and, where appropriate, to the MFSA, and the relevant client is notified.

Annual Staff Training. All relevant staff receive mandatory annual training on the identification, escalation, and management of conflicts of interest. Training records are maintained by the compliance function.

Remuneration Structures. Remuneration structures for management and staff are reviewed annually to ensure they do not create incentives that are misaligned with client interests or that could give rise to undisclosed conflicts.

10.

Annual Board Review. The board of Bequant Pro Limited reviews and formally approves the updated Conflicts Register on at least an annual basis, including a sign-off confirming that the existing controls remain adequate and proportionate.

4. Other Potential Conflicts

4.1

Proprietary Trading and Client Order Flow.BEQUANT PRO deals on its own account in crypto-assets and may simultaneously handle client orders. This creates a potential conflict between BEQUANT PRO's proprietary interests and the interests of its clients. This conflict is mitigated by the information barriers described in Section 3.3, which prevent the flow of client order information to proprietary trading functions, and by BEQUANT PRO's order handling and best execution policies.

4.2

Affiliated Entities.BEQUANT PRO may, from time to time, engage with or refer business to affiliated entities operating under the Bequant brand, including Bequant Prime Limited (Seychelles). Any such engagement is disclosed to affected clients in advance and is conducted on arm's-length commercial terms. Affiliate arrangements are reviewed by the compliance function and subject to board approval.

5. Review and Updates

5.1

This disclosure is reviewed at least annually and updated whenever a material change in identified conflicts occurs. Clients will be notified of any material update to this disclosure prior to it taking effect.

5.2

Date of last review: 08 April 2026. Next scheduled review: April 2027 (or earlier if a material conflict change is identified).

6. Contact

Purpose	Contact
Compliance enquiries	compliance@bequant.pro
Registered office	The Core, Valley Road, Msida, MSD 9021, Malta