At Norwegian Block Exchange AS (NBX), we are committed to acting in the best interests of our clients and maintaining the highest standards of integrity and transparency in the provision of our crypto-asset services.

In accordance with Article 72(2) of Regulation (EU) 2023/1114 (MiCA), we hereby disclose the general nature and sources of potential conflicts of interest that may arise in the course of our business, as well as the measures we have implemented to mitigate such risks.

General Nature and Sources of Conflicts of Interest

Conflicts of interest may arise where:

• NBX provides multiple crypto-asset services to the same client or to different clients whose interests may diverge;
• NBX has a financial or other incentive to prioritize its own interests or those of its partners, affiliates, or employees over those of its clients;
• NBX or its employees engage in personal transactions or hold positions in crypto-assets that are subject to client orders;
• NBX acts both as a market operator and as a liquidity provider or market maker in the same trading pair;
• NBX has commercial arrangements with issuers or promoters of certain crypto-assets listed or traded on its platform.
• NBX issues EMTs while also providing custody, trading, and exchange services for EMTs, which may create a potential conflict between NBX’s role as issuer and its role as service provider to clients.

Steps Taken to Mitigate Conflicts of Interest

NBX takes a risk-based and proportionate approach to managing conflicts of interest, in line with its size, structure, and the nature of its crypto-asset services.

To help identify and manage situations where conflicts may arise, NBX has implemented the following general measures:

• Maintaining internal procedures for identifying and assessing potential conflicts on an ongoing basis;
• Encouraging a culture of transparency, where employees are expected to disclose any personal interests or relationships that might give rise to a conflict;
• Segregating roles and responsibilities, and requiring employees to step aside from decisions where their impartiality may reasonably be questioned;
• Addressing identified conflicts through appropriate mitigation or, if necessary, disclosure to the client concerned;
• Providing guidance to employees on expected conduct through this Code of Conduct and related internal policies;
• Applying the same listing, trading, and surveillance rules to EMTs as to other assets, with no preferential treatment;
• Ensuring EMT issuance and redemption are handled under separate governance and executed strictly at par value;
• Disclosing to clients that NBX acts both as issuer of EMTs and as provider of custody and trading services.

NBX reviews its approach regularly to ensure that it remains fit for purpose and aligned with applicable legal and regulatory requirements, including the Markets in Crypto-Assets Regulation (MiCA).

Further details are available in our full Conflicts of Interest Policy, which may be provided upon request.

For questions or concerns related to this disclosure, please contact us at [email protected].