Northcrypto is committed to maintaining the highest standards of integrity, fairness, and transparency in its business activities. This Conflicts 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 Northcrypto’s operations.
A conflict of interest occurs when the interests of the Northcrypto, 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:
Northcrypto takes a proactive approach to identifying and mitigating conflicts of interest. The following measures are in place:
If a conflict of interest is identified, Northcrypto takes one or more of the following steps to resolve it:
Clients have the right to receive fair treatment and transparent service. Northcrypto is committed to resolving any concerns related to conflicts of interest. If you suspect a conflict of interest in your interactions with the Northcrypto, you may report it to our compliance team.
Group structure & ownership:
Northcrypto is a part of GreenMerc Group, meaning that GreenMerc AB (publ) owns 100% of Northcrypto's shares. The GreenMerc Group also fully owns Ijort Invest AB, which operates the Trijo trading platform, and Finture Ab, which provides payment services in the NorthCrypto service. While Northcrypto operates independently, when the client places an order under the Transmission Service, Northcrypto transmits such client orders to the Trijo’s trading platform as agreed in Terms of Service. Although Northcrypto does not receive any financial incentives for this routing, the shared ownership within the Group may give rise to a potential conflict of interest. Northcrypto has implemented the following internal controls to protect client interests, manage this potential conflict of interest and ensure full adherence to the requirements of MiCA.
Internally, decision-making processes related to order handling are designed to prioritize the client’s best interest, with strengthened oversight mechanisms that limit undue influence stemming from ownership ties. The order routing logic is clearly defined and formally documented in internal procedures, ensuring that all decisions related to order transmission are based on objective, pre-established criteria. 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, Northcrypto 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 Northcrypto, Trijo, Finture 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 Northcrypto and Trijo may face difficulty remaining impartial when decisions involve execution venue selection or pricing strategy between the two.
To mitigate these risks, Northcrypto 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, Northcrypto has strengthened internal documentation and approval workflows to ensure transparency when decisions could be influenced by overlapping roles. Furthermore, Northcrypto 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 Northcrypto and its clients.
Group structure & shared operational resources:
Northcrypto 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, Northcrypto 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 Northcrypto:
Within the Northcrypto, 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, Northcrypto 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