The Company is committed to maintaining the highest standards of integrity, fairness, and transparency in its business activities. This Conflict of Interest Policy is designed to identify, prevent, and manage any potential or actual conflicts of interest that may arise in the course of providing services to clients. The policy applies to all employees, board members, shareholders, and any other Connected Persons involved in the Company’s operations.
A conflict of interest occurs when the interests of the Company, its employees, or Connected Persons may be inconsistent with or have the potential to interfere with the best interests of a client. Examples of conflicts of interest include:
The Company takes a proactive approach to identifying and mitigating conflicts of interest. The following measures are in place:
If a conflict of interest is identified, the Company takes one or more of the following steps to resolve it:
Clients have the right to receive fair treatment and transparent service. The Company is committed to resolving any concerns related to conflicts of interest. If you suspect a conflict of interest in your interactions with the Company, you may report it to our compliance team.
Group structure & ownership:
The Company is a part of GreenMerc Group, meaning that GreenMerc AB (publ) owns 100% of the Company’s shares. The GreenMerc Group also fully owns Ijort Invest AB, which operates the Trijo trading platform, and GreenMerc Finance, which provides payment services in the NorthCrypto service. The Company has implemented the following internal controls to protect client interests, manage potential conflict of interest and ensure full adherence to the requirements of MiCA.
Personnel involved in governance and strategic decisions are required to declare any potential conflicts, and they are expected to recuse themselves from any deliberations where competing group interests could arise. Internal audits and compliance checks are conducted periodically to monitor the effectiveness of these controls. Through these efforts, the Company maintains its commitment to impartiality, transparency, and the highest standards of regulatory integrity.
Group structure & shared leadership resources:
Several individuals hold simultaneous leadership or board positions across the Company, Trijo, GreenMerc Finance and GreenMerc, potentially compromising independent decision-making. This overlapping governance can compromise independence in strategic, financial, or operational decision-making, especially when the interests of the entities diverge. For example, a board member involved in both the Company and Trijo may face difficulty remaining impartial when decisions involve execution venue selection or pricing strategy between the two.
To mitigate these risks, the company has implemented several measures. All relevant individuals are required to submit formal declarations of their external positions and potential conflicts. In cases where a decision may involve competing group interests, the individual is expected to recuse themselves to preserve impartiality. In addition, the Company has strengthened internal documentation and approval workflows to ensure transparency when decisions could be influenced by overlapping roles. Furthermore, the Company provides targeted training to senior staff on identifying and managing structural conflicts of interest within a group context. These steps help reinforce accountability and ensure that all decisions are made in the best interests of the Company and its clients.
Group structure & shared operational resources:
The Company and Trijo share certain key personnel, particularly in compliance and IT functions. While this shared resourcing can enhance efficiency and knowledge transfer, it also creates the potential for conflicts in prioritization and delays in regulatory or operational obligations, especially during periods of high workload or incident response. For example, when both entities require immediate compliance support -such as for transaction monitoring, reporting deadlines, or system alerts. The shared staff may face pressure in determining which entity to assist first.
To manage these risks, the Company has implemented a number of targeted measures. First, all shared personnel operate under clearly defined role descriptions, which distinguish their responsibilities for each entity. This ensures that expectations are aligned and accountabilities are traceable. Additionally, workload distribution and time allocation are structured in advance, so that essential regulatory functions receive appropriate attention from dedicated resources. Access to internal systems and sensitive data is also carefully controlled through entity-specific permissions and logging, helping to prevent misuse or unintentional cross-entity exposure. Together, these actions help safeguard the integrity of compliance and operational processes, even in a shared resource environment.
Conflicting roles in the Company:
Within the Company, certain individuals may hold multiple roles that combine commercial, operational, and control responsibilities. This role overlap can create inherent conflicts of interest -particularly where one role is tasked with driving business growth, while another is responsible for managing risks or ensuring compliance. For example, a team member who participates in both product development and risk evaluation may be incentivized to downplay risk considerations in order to speed up time-to-market.
To address this risk, the Company has introduced structural safeguards. Wherever possible, functions such as compliance and growth activities are separated, both in reporting lines and in day-to-day responsibilities. Employees with dual responsibilities are required to document key decisions and involve second reviewers in matters that may present a conflict of interest. These measures ensure balanced decision-making and protect the integrity of both business outcomes and regulatory compliance.
This policy is reviewed regularly to ensure it remains effective and in line with regulatory requirements. The latest version of the Conflicts of Interest Policy is always available on our website.
For more information or to raise a concern, please contact us at compliance@northcrypto.com