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Bequant Pro Limited · Company No. C 88065 · Malta

Conflicts of Interest Disclosures

MiCA Article 72(2) · CDR (EU) 2025/1142Effective: 08 April 2026
Disclosure made pursuant to Article 72(2) of Regulation (EU) 2023/1114 (MiCA) and Commission Delegated Regulation (EU) 2025/1142.

1. Background

Bequant Pro Limited (“BEQUANT”, “we”, “us” or “our” or “Company”) is a private limited company incorporated in Malta with its principal place of business at The Core, Valley Road, Msida, MSD9021, Malta.

For licence status, please refer to the Legal and Compliance Information section.

For Company's services' description, please refer to the Terms of Business.

This disclosure is made in addition to, and does not replace, the organizational and administrative arrangements the Company has implemented to identify, prevent and manage conflicts of interest.

2. Identified Conflict of Interest

The Company has identified the following conflict of interest arising from its governance structure:

The Ultimate Beneficial Owner (“UBO”) of the Company also serves as its Chief Executive Officer (“CEO”). This concentration of ownership and executive management in a single individual creates a situation in which the interests of the UBO as shareholder may not always be fully aligned with the interests of clients. In particular, decisions relating to the Company's commercial strategy, fee structures, or counterparty relationships may be influenced by the shareholder's financial interests in a manner that could, in the absence of adequate controls, be detrimental to clients.

3. Steps Taken to Mitigate This Conflict

The Company has implemented the following measures to prevent or manage this conflict of interest:

Independent Board Chairperson:The Board of Directors is chaired by an independent Maltese Non-Executive Director who is not involved in the day-to-day management of the Company. This ensures that the body responsible for overseeing the CEO's conduct and the Company's strategic direction is led by a person who is independent of the UBO/CEO.
Independent Committee Oversight:The Company has established independent committees, including a Compliance Committee chaired by the Head of Compliance and a Risk Committee chaired by the Head of Risk, among others. These committees operate independently of the CEO and provide structured, ongoing oversight of matters relevant to their respective mandates, including the identification and management of conflicts of interest, ensuring that key risk and compliance decisions are not subject to the influence of the UBO/CEO.
Independent Compliance Oversight:The Company's Head of Compliance, who also chairs the Compliance Committee, is responsible for the identification, prevention, management, and disclosure of conflicts of interest and reports directly to the Board of Directors, independently of the CEO.
Independent Risk Oversight:The Company's Head of Risk chairs the Risk Committee, providing an additional layer of independent oversight over risk matters, including risks arising from conflicts of interest.
Board-Level Controls:The UBO/CEO and all Directors participating in the Board of Directors are required to declare any matter in which a personal interest may conflict with the interests of the Company or its clients, and to abstain from voting on such matters at management body level.
OTC Only:The Company operates exclusively on an OTC, matched principal basis and does not hold proprietary trading positions. This structurally eliminates the risk of the Company trading against its clients.
Outsourced Custody:Client crypto-assets are held by an independent, regulated third-party custodian, removing direct control by the UBO/CEO over client assets.
Remuneration Controls:The Company's remuneration policies are designed to ensure that they do not create incentives that could lead connected persons to favor their own interests or the Company's interests to the potential detriment of clients.
Personal Transaction Monitoring:Transactions effected by or on behalf of connected persons, including the UBO/CEO, are subject to monitoring and scrutiny under the Company's conflicts of interest policies.
Annual Review:The Company's conflicts of interest policy is assessed and reviewed at least annually by the management body, and this disclosure is kept updated at all times.
This disclosure should be read together with the Company's Terms of Business, Risk Disclosure Statement, Complaints Handling Procedure and other applicable policies.

4. Contact

If you have any questions regarding this disclosure or the Company's management of conflicts of interest, please contact the Compliance Department at compliance@bequant.io

PurposeContact
Compliance enquiriescompliance@bequant.io
Registered officeThe Core, Valley Road, Msida, MSD9021, Malta

© 2026 Bequant Pro Limited. Last updated: 8 April 2026. Disclosure made pursuant to MiCA Article 72(2) and Commission Delegated Regulation (EU) 2025/1142.