Conflicts of Interest
Information on how BIT Capital GmbH handles conflicts of interest
BIT Capital GmbH is a BaFin-regulatedinvestment firm and subject to various regulatory requirements regarding theavoidance of conflicts of interest.
We are obliged to act in the best interests of our investors, the investment funds we manage, and the investors in these investment funds, by always conducting our business with the necessary honesty, diligence, integrity, and while upholding market integrity.
Nevertheless, conflicts of interest cannot always be completely excluded when providing investment services or ancillary investment services. They may affect, among other things, areas such as employee transactions, execution principles, remuneration structures, inducements, complaints handling, and whistleblowing systems.
At BIT Capital GmbH, conflicts of interest can arise particularly between investors and BIT Capital GmbH (including its employees) or persons directly or indirectly connected with BIT Capital GmbH, as well as between the outsourcing fund management companies and BIT Capital GmbH. The relationship between investors and the fund management companies does not fall within the scope of BIT Capital GmbH.
Identification and Assessment of Conflicts of Interest
BIT Capital GmbH will regularly identify and document in writing potential conflicts of interest that may arise in the provision of investment services. When identifying potential conflicts of interest, the interests of other parties, such as the fund management companies, the managed investment funds, and the investors, must be considered in addition to the interests of BIT Capital GmbH (including its employees).
A conflict of interest exists when BIT Capital GmbH, one of its employees, or a person or company directly or indirectly connected to BIT Capital GmbH through a control relationship, due to the provision of investment services:
- could achieve a financial gain or avoid a loss to the detriment of a third party, including the managed investment undertakings,
- has an interest in the outcome of a service provided or a transaction that does not align with the third party's interest in that outcome,
- has a financial or other incentive to place the interests of one third party above those of another third party,
- performs the same activities for different parties, or
- receives or could receive in the future, in connection with the provision of a service, an inducement (monetary or non-monetary) from a third party that goes beyond the usual commission or fee for such a service.
BIT Capital GmbH acknowledges that even the appearance of a conflict of interest can be sufficient to assume its existence.
Measures for the Prevention, Management, and Monitoring of these Potential Conflicts of Interest
BIT Capital GmbH has organizational and administrative arrangements for identifying, preventing, resolving, managing, and monitoring potential conflicts of interest, to prevent them from causing significant harm to investment funds and investors.
BIT Capital GmbH has established a compliance function which independently monitors these arrangements and trains all employees on regulatory requirements and internal policies. BIT Capital GmbH applies high ethical standards in its dealings with investors, clients, and business partners, and expects equally high ethical standards from its business partners.
BIT Capital GmbH and its employees are obliged to avoid conflicts of interest as far as possible. Unavoidable conflicts must be resolved by BIT Capital GmbH while safeguarding the interests of all relevant parties. To this end, BIT Capital has implemented the following measures:
- Obligation of employees to disclose certain securities transactions to BIT Capital GmbH,
- Employee training,
- Establishment of a complaints management system,
- Establishment of a whistleblowing system,
- where necessary, creation of confidential areas through information barriers, segregation of duties, and/or organizational separation of business units or relevant persons who may represent conflicting interests,
- Prevention of undue influence by third parties on persons involved in portfolio management,
- Introduction of a remuneration structure that avoids misaligned incentives in the provision of services,
- Regulations on the acceptance and granting of inducements, as well as their disclosure, and
- Disclosure and documentation of conflicts of interest that cannot be avoided.
Should conflicts of interest not be able to be avoided or resolved by the aforementioned measures in exceptional cases, BIT Capital will inform the affected third party and provide them with sufficient information so that they can make a fully informed decision. In such cases, BIT Capital GmbH will, if necessary, refrain from investing in the financial instruments concerned.
As of May 2026