Last updated: December 2025.

1. Introduction and Regulatory Framework

Aplo SAS (“Aplo”, “the Firm”, “we”) is registered as a Digital Asset Service Provider (DASP) with the Autorité des Marchés Financiers (AMF) and is applying for authorization as a Crypto-Asset Service Provider (CASP).

This Disclosure is established in accordance with Article 72 of Regulation (EU) 2023/1114 (MiCAR) and the relevant ESMA Regulatory Technical Standards (RTS). Aplo is required to maintain and operate effective organizational and administrative arrangements to identify, prevent, manage, and monitor conflicts of interest.

The purpose of this Disclosure is to inform our clients of these arrangements and to ensure transparency regarding how we act honestly, fairly, and professionally in accordance with their best interests. This document summarizes the key elements of our internal Conflict of Interest Policy.

The internal policy applies to “Relevant Persons,” defined as:

• Directors, managers, and employees of Aplo;
• Any natural person directly involved in the provision of services to the Firm under an outsourcing arrangement;
• Any person directly or indirectly linked to the Firm by control.

2. Governance and Oversight

Our governance framework is designed to ensure independence and effective management of conflicts:

• The Executive Committee (Comité de Direction) is the ultimate governing body responsible for approving the Conflict of Interest Policy. It ensures that the Firm’s organizational structure allows for the effective segregation of duties and management of conflicts.
• The Regulatory Compliance Manager is responsible for:
  • Establishing and maintaining operational procedures to detect and manage conflicts.
  • Maintaining the Conflict of Interest Register, which logs all potential and confirmed conflicts.
  • Handling specific cases of confirmed conflicts to decide on the appropriate mitigation or disclosure.
  • Reporting directly to the Executive Committee on conflict matters.
• All employees and staff members are required to:
  • Report any potential conflict immediately to Compliance.
  • Adhere to the Firm’s Code of Conduct (link) and internal policies.
  • Complete mandatory annual training on conflicts of interest, market abuse prevention, and ethics.

3. Identification and Management of Conflicts

Aplo has identified specific areas where conflicts may arise and has implemented the following mitigation measures.

3.1. Conflicts within the Corporate Group

Risk: Aplo is part of a larger corporate group which includes other digital asset entities. A conflict exists if Aplo favors group entities over Client interests (e.g. routing orders to an affiliated venue despite poor terms).

Mitigation Measures:

• No Specific Intra-Group Routing: Aplo does not exclusively route client orders to its group subsidiaries or affiliates. Order routing is determined strictly by our Best Execution Policy, connecting only to external, third-party liquidity venues vetted for their performance.
• Arm’s Length Principle: Commercial interactions with group entities are conducted at arm’s length. We do not provide preferential fee structures or operational treatment to group entities compared to third parties.

3.2. Employee Personal Interest in Client Business (Order Management)

Risk: Employees could prioritize their own financial gain or the Firm’s revenue over the Client’s interest, potentially leading to poor execution.

Mitigation Measures:

• Remuneration Policy: Aplo’s remuneration policies are designed to ensure that staff incentives do not create any conflict of interest. Specifically, variable remuneration is not directly linked to outcomes that could incentivize behaviors detrimental to clients’ interest or order execution choices.
• No Proprietary Trading: Aplo strictly operates on a matched-principal basis. We do not engage in proprietary trading activities based on our own strategies, nor do we take speculative positions on our own account.
• Best Execution & Fairness: All orders are handled according to our Best Execution Policy, using objective criteria and compliance-monitored reviews, to ensure consistent order treatment. Automated systems and traders are mandated to execute orders solely based on the best possible result for the Client (price, cost, speed, likelihood of execution, security).
• High-Touch Desk Controls: We implement a “Four-Eyes” principle on the high-touch desk. Significant trades and execution decisions follow a standardized rulebook and are subject to oversight by a supervisor to prevent inappropriate behavior.

3.3. Preferential Treatment and Inducements

Risk: Aplo could be incentivized to treat certain Clients (e.g. personal relationships, friends of management, …) more favorably than others, or to select service providers/venues based on personal relationships or inducements rather than merit.

Mitigation Measures:

• Fair Treatment: Order handling procedures require that comparable orders be executed sequentially and promptly. We do not prioritize orders based on personal relationships.
• Fee Transparency: Our fee schedules are transparent. Any deviations or special commercial terms are documented and approved by senior management to ensure they do not disadvantage other clients.
• Gifts and Inducements Policy: Aplo maintains a strict policy regarding gifts and entertainment. Employees may not accept or provide gifts that are more than nominal in value or that could be perceived as impairing their judgment or duty to the Client. All gifts are logged in a register maintained by Compliance.

3.4. Insider Knowledge and Personal Trading

Risk: Employees may have access to Material Non-Public Information regarding client activity (e.g., large orders) and might use this information to trade for their personal accounts.

Mitigation Measures:

• Information Barriers: We maintain strict separation between departments. Client order information is restricted to a “need-to-know” basis.
• Personal Account Dealing: Employees must declare personal trading accounts, including their general trading strategy and holdings. Active trading strategies are not permitted. Trading in tokens for which they possess inside information is strictly prohibited.

4. Disclosure and Declining Services

Where the organizational arrangements described above are not sufficient to ensure, with reasonable confidence, that the risk of damage to a Client’s interests will be prevented, Aplo will:

1. Disclose the general nature and sources of the specific conflict to the Client before undertaking business on their behalf. This disclosure will be made on a durable medium (email, or other communication channel defined with the Client) and will include sufficient detail to enable the Client to take an informed decision.
2. Decline to act for the Client in the specific transaction if the conflict cannot be effectively managed or disclosed appropriately.

5. Review and Record Keeping

The Compliance Manager maintains an up-to-date register of all identified conflicts and the measures taken to mitigate them.

This Disclosure and the internal Conflict of Interest Policy are reviewed at least annually by the Executive Committee to ensure they remain aligned with the regulations and the evolving nature of Aplo’s business.