POWEREX DISPUTE POLICY
PURPOSE AND SCOPE
This Powerex Conflict of Interest Policy ("Policy") is intended to monitor customer interests and the market integrity within the scope of the services provided by Powerex Crypto Asset Purchase and Sale Platform Anonim Şirketi ("Powerex"), to detect and prevent potential conflicts of interest and to manage these situations in accordance with the legislation, within the framework of the relevant legislation, primarily the Communiqué on the Establishment and Operation Principles of Crypto Asset Service Providers numbered III-35/B.1 of the Capital Markets Board. prepared for the purpose.
In accordance with its obligations arising from legal regulations, Powerex hereby foresees possible conflicts of interest and organizes the necessary measures with this Policy;
In the relationship between itself and the customer, its partners, employees, managers and persons directly or indirectly related to them and its customers and
between a customer and another customer
When creating the Policy, Powerex takes into account the transaction volume, the number of customers, the number of listed crypto assets and
It has taken into account its diversity, complexity of its activities, organizational structure and the services it is authorized to provide.
DEFINITIONS
Conflict of Interest: A situation where the interests of a crypto asset service provider and/or its customers and/or partners or employees directly or indirectly conflict.
Interest: Any kind of material or moral, financial, commercial, professional or personal advantage that provides is a benefit.
Employee: All full/part-time, contracted and/or temporary personnel employed by Powerex.
Customer: A real or legal person who receives or applies to receive services from a crypto asset service provider.
POSSIBLE SITUATIONS THAT MAY BE CONTRARY TO THE CUSTOMER'S INTERESTS
Situations where financial gain is obtained or financial loss is avoided against the customer.
Even though the customer has no interest, Powerex gains from the services and activities provided.
Using a preference in favor of a customer or group, against other customers or groups.
Using Powerex’s non-standard financial gain from a third party person, institution or application other than the customer. to obtain.
In listing transactions, income is provided on condition that Powerex or its affiliates' distributed ledger network is preferred.
MEASURES REGARDING CONFLICTS OF INTEREST
The rules for preventing conflicts of interest that may occur within the scope of the issues exemplified above are as follows:
It is essential that employees do not allow conflicts of interest between their own and/or Powerex interests and customer interests in their work and transactions.
Employees shall conduct their work with complete impartiality They are obliged to do so, in no way to put their own interests above the interests of the customers, and not to allow a situation that would create a preference between their personal interests and the interests of the customers while performing their professions.
Where the interests of the customers exist, the personal interests of the employees should not be in question in any way, directly or indirectly.
Within this framework, employees;
Cannot obtain any benefit from customers, cannot have any They cannot transfer benefits by establishing an intermediary relationship.
They treat all customers equally and fairly when there is a conflict of interest between customers.
They prevent situations that will prevent personal interests from performing their duties impartially; in the event of such situations, they report to the Internal Control and Compliance Unit through their unit managers. As a result of the reporting, action is taken to prevent potential conflicts of interest.
In addition to the principles listed above, employees must comply with the following rules to prevent conflicts of interest:
Not to act as a guarantor for customers and not to accept their guarantees.
Opening accounts with customers, such as debt-receivables and joint accounts Not to enter into relationships that are incompatible with customary practices.
Not to participate in invitations or overseas trips paid for by customers, in whole or in part, except in cases with the knowledge and permission of the General Manager.
Not to accept gifts from customers that are out of the ordinary and of a nature and value that may create a liability for them.
Not to give high-value gifts to existing or potential customers, without the knowledge of the General Manager, in a manner that is not in accordance with the CMB legislation, and not to use one's position to deviate from the customer's business area, beyond its purpose, and outside of normal practices. not to provide any benefits.
In addition to these measures for employees, the following measures must also be followed.
Information walls (Chinese Wall) are applied to prevent the flow of information between units that may cause conflict of interest.
The units with the potential for conflict of interest are closely monitored.
The compensation of employees in positions that carry the risk of conflict of interest is determined objectively and customer-oriented.
IN CASE OF NOT PREVENTING A CONFLICT OF INTEREST PROCEDURE
Generally
Powerex is obliged to manage existing or potential conflicts of interest in order to fulfill its obligations to customers arising from laws and regulations regarding the services it will provide.
In order to best protect the interests of Powerex and its customers and to prevent customers from entering into conflicts of interest with each other or with Powerex, for all transactions, before any customer instructions are processed The potential for a conflict of interest should be considered first.
Employees must perform their duties impartially. If this situation becomes suspicious for any reason, including family or private relationships, economic interest, or a common interest with another person, the existence of a conflict of interest should be questioned and reported to the Internal Control and Compliance Unit through the unit manager.
This Policy is distributed to each employee, ensuring that they read and sign. In this context, each employee is expected to evaluate the situations they encounter and act in accordance with this Policy. In the event of a conflict of interest, Powerex
may reverse the transaction.
accepts that there is a conflict of interest, takes material preventive measures and provides protection to the customer and/or
explains that there is a conflict of interest, obtains a waiver or approval from the customer.
Internal decision regarding the organizational structure and assignment of personnel on a case-by-case basis The action of the Control and Compliance Unit is essential.
Employees must fully explain to their customers the measures to be taken to manage conflicts of interest. Depending on the situation, the explanation to be made to the customer may be verbal or written and may be related to a general / specific material interest or conflict. In case of doubt, for the appropriate explanation, contact the Internal Affairs Directorate. The Control and Compliance Unit should be consulted.
Separations that Ensure Independence and Prevent Information Flow
Some permanent and critical potential conflicts of interest should be separated as much as possible so that they can be carried out independently from other transactions. In this way, a permanent action is taken. This action is supported by organizational measures such as different reporting chains, different business units and restricting access to these business units, embargoing information, and determining which issues are related to each other. These types of arrangements are called “Information Walls (Barriers)”.
Information walls are physical or administrative walls created between units and, in some special cases, between different project teams in the same units, in order to prevent and control the flow of information that may create a conflict of interest. Thanks to these information walls, while some employees have price-sensitive information, others have the opportunity to conduct transactions securely against possible abuse claims they may be exposed to.
To create information walls, The main tools used are:
ÇPhysical separation of work areas,
ÇEncrypted entry to work areas,
List of personnel with confidential information,
ÇWorking Principles,
Separation of project teams.
Follow-up of Decisions and Incidents
The main responsibility for decision-making lies with the managers of the business units, and the approval of the Internal Control and Compliance Unit is obtained.
Incidents are situations where the conflict of interest situation is not correctly indicated. Examples of this may include a report being prepared by the Inspection (Internal Audit) Unit or regulatory bodies, being subject to a sanction or a customer complaint. Such cases are monitored by the relevant business or support unit, under the control of the Internal Control and Compliance Unit and the Legal Unit. The investigation of the issue may be conducted by the inspection unit.
... There is no practice where the customer's encouragement of risky transactions increases the employees' earnings.
If a conflict of interest is detected, the employee who detected it should immediately report the situation to the unit manager and Internal Affairs Director. Reports to Control and Compliance Unit.
Compliance Unit analyzes the conflict of interest in the incident and takes the necessary measures.
In a way that will reduce or eliminate the impact of the conflict of interest situation;
Transaction is rejected,
Customer is informed and their explicit consent is obtained,
Organizational assignment is made to be carried out with neutral persons.
DATA SECURITY
Confidentiality and security of customer information Law No. 6698 on the Protection of Personal Data and other legislation provisions
Likewise, in every activity including the transfer of customer data within or between units, the principles regulated by the Law on the Protection of Personal Data No. 6698 dated 24/3/2016 are observed. In case of doubt, the opinion of the Compliance Unit should be obtained first, and if necessary, professional legal support should be obtained as an external service on the subject.
RECORDING, REPORTING AND AUDIT
Identified cases are archived in writing. Internal; The Control Unit monitors and reports the implementation of this Policy within the scope of the annual audit plan.
As part of the CMB audits, necessary updates and improvements are made and will be published on the website.
IN EFFECTIVE
This Policy entered into force with the Board of Directors Decision No. 2025-8 dated 28.03.2025. It is reviewed at least once a year. It is revised more frequently in cases where the need for updating arises.
