Conflicts of Interest Management

Introduction

ICEBLOCK is committed to ensuring the primacy of its clients' interests, maintaining a high level of integrity, and complying with regulatory requirements, in particular Regulation (EU) 2023/1114 (MiCA) and Delegated Regulation (EU) 2025/1142. This page summarizes ICEBLOCK's ethical principles and internal procedures relating to the prevention, identification, and management of conflicts of interest, while providing a clear and transparent overview for its clients and partners.

Updated: March

ICEBLOCK confirms that, as of the date of publication of this communication, no actual or potential conflict of interest situation requiring specific disclosure has been identified within its activities or toward its clients.

Why this page?

ICEBLOCK considers that transparency and proactive communication are essential in order to:

• Strengthen the trust of its clients;
• Ensure compliance with supervisory authorities (AMF, ACPR);
• Clarify the ethical obligations applicable to its Staff and its clients.

This page aims to:
Set out ICEBLOCK's regulatory framework and general principles;
Present at-risk situations, even in the absence of proven conflicts;
Explain the prevention and management measures in place;
Guarantee access to ICEBLOCK's internal policy (adapted version).

Regulatory context and general principles

1. Legal and regulatory framework

ICEBLOCK applies the following rules:

• Regulation (EU) 2023/1114 (MiCA): Requires proactive management of conflicts of interest for crypto-asset service providers;
• Delegated Regulation (EU) 2025/1142: Specifies the requirements regarding policies, procedures, and communication;

2. ICEBLOCK's ethical principles

All ICEBLOCK Staff undertake to:

• Act with loyalty and fairness, in the best interests of clients and ICEBLOCK;
• Carry out their activities with competence and diligence;
• Avoid conflicts of interest or, failing that, manage them transparently;
• Respect the confidentiality of sensitive information;
• Comply with all applicable regulations.

Ethics: The set of rules and duties applicable in a professional context, governing the relationships between ICEBLOCK, its Staff, its clients, its suppliers, and the supervisory Authorities.

At-risk situations: what you need to know

ICEBLOCK identifies the following potential situations, in accordance with MiCA requirements and French regulations:

Conflicts of interest between ICEBLOCK and a client
ICEBLOCK could derive a financial or commercial advantage to the detriment of a client. For example, pressure on a Staff member to favor a client or a client segment.

Conflicts of interest between two clients
One client could be treated unfairly compared to another. For example, the use of privileged information to favor a client.

Conflicts of interest involving an Affiliated Person
An Affiliated Person (shareholder, executive, employee) could pursue a divergent personal or financial interest. For example, the acceptance of undeclared gifts or benefits by a Staff member.

Conflicts of interest arising from personal, professional, or political relationships
Such relationships could influence ICEBLOCK's independence or objectivity. For example, an executive maintains a personal relationship with a business partner.

Conflicts of interest involving external third parties
Service providers, partners, or competing clients could pursue divergent incentives. For example, a technology service provider has access to sensitive client data.

Personal transactions in crypto-assets
Staff must not trade on the basis of privileged information held by ICEBLOCK. For example, a Staff member buys or sells a crypto-asset using internal information.

External activities of Staff
Staff may not serve as directors of another company without ICEBLOCK's prior approval. For example, a Staff member becomes a member of the board of directors of a competing company.

Affiliated Person: Shareholders, partners, members of governing bodies, employees, clients, or any person directly or indirectly connected to ICEBLOCK.

Measures for the prevention and management of conflicts of interest

1. Governance and key roles

ICEBLOCK has put in place a dedicated structure to manage conflicts of interest:

Management body

• Defines and approves the policy;
• Ensures its application;
• Reviews its relevance at least once a year.

Compliance Officer

• Implements, applies, and monitors the policy;
• Has direct access to the management body.

Staff

• Must report any conflict of interest situation, actual or potential, to their line management or to the Compliance Officer.

2. Organizational and technical measures

Separation of functions

• Restriction of access to sensitive information (commercial, strategic, financial) based on the “need-to-know” principle;
• Implementation of information barriers (“Chinese walls”) between sensitive teams or projects;
• Strict control of physical and logical access to tools and premises.

Control of information flows

• Restricted lists for sensitive operations;
• Obligation to declare access to confidential information.

Gifts, benefits, and entertainment

• Exempt: items worth less than 150€, working meals, training tools;
• To be declared: items whose estimated commercial value exceeds 150€ or benefits unrelated to ICEBLOCK's activities. A mandatory declaration and prior approval from the Compliance Officer are required.

Personal transactions in crypto-assets

• Prohibition on trading on the basis of privileged information;
• Obligation to declare personal accounts and wallets;
• Prohibition on executing a personal transaction in the same direction as a pending client order.

External activities of Staff

• Prohibition on holding a director position in another company without written approval;
• Mandatory declaration of any external role (consultant, expert, etc.);
• Prohibition on working for a competitor or business partner without approval.

3. Conflict management procedure

ICEBLOCK follows 5 key steps to manage conflicts of interest:

1. Identify the conflict (actual or potential);
2. Manage the conflict or withdraw from the relationship/activity;
3. Escalate and record the conflict in the dedicated register;
4. Disclose the conflict clearly to the client concerned, if necessary;
5. Keep the management framework up to date.

Conflicts of interest register:
ICEBLOCK maintains a formalized register, available upon request, listing all identified conflicts. This register is updated immediately and retained for 5 years.

ICEBLOCK's commitments: transparency and communication

Communication with clients

ICEBLOCK undertakes to:

• Inform its clients of the existence of this policy;
• Disclose any conflict of interest that cannot be managed by other measures, before the provision of the service;
• Publish clear and accessible information on its website.

Adaptation of the Code of Ethics

ICEBLOCK makes available:

• An adapted version of its internal policy (with strictly sensitive elements redacted);
• A downloadable PDF version;
• A dedicated link from the “Regulatory Information” or “Conflicts of Interest” page.

FAQ: your most frequently asked questions

1. Why a page dedicated to conflicts of interest?

ICEBLOCK considers that transparency and proactive communication strengthen clients' trust and regulatory compliance. This page makes it possible to:

• Clarify legal and internal obligations;
• Present potential risks, even in the absence of proven conflicts;
• Guarantee access to information for all.

2. What are the major risks identified by ICEBLOCK?

• For ICEBLOCK: legal, operational, or reputational risks;
• For clients: unfair treatment, financial loss, loss of trust;
• For Staff: disciplinary, criminal, or administrative sanctions.

3. Has ICEBLOCK identified any conflicts requiring disclosure?

ICEBLOCK declares:
“As of the date of publication of this communication, ICEBLOCK has not identified any actual or potential conflict of interest situation requiring specific disclosure.”

4. How to report a potential conflict of interest?

• Clients: Address your concern to the Compliance team via contact@iceblockinvestments.com;
• Staff: Report any situation to your line management or to the Compliance Officer.

5. What are the consequences of failing to comply with this policy?

• For ICEBLOCK: Civil, criminal, or administrative sanctions (AMF, ACPR);
• For Staff: Disciplinary liability, up to and including termination of the employment contract.

Access to the policy and resources

• Web version: www.iceblockinvestments.com/gestion-des-conflits-dinterets
• PDF version: Download the policy (PDF)
• Conflicts register: Available upon request from the Compliance team
• Contact: contact@iceblockinvestments.com

Updates and monitoring

This communication is updated:

• At least once a year, under the responsibility of the Compliance Officer and the management body;
• Immediately in the event of a significant change (changes to services, procedures, or the regulatory framework).

Last updated: March 31, 2026.
ICEBLOCK reminds you that any question relating to this policy must be addressed to the Compliance Officer.

Need assistance or clarification?

For any question or request for additional information:

• Contact the Compliance team: contact@iceblockinvestments.com;
• Consult the regulatory documentation available upon request.

Regulatory documentation: adapted version updated in March 2026.
Any use, reproduction, or distribution of this document must be expressly au