ETHICS · TRANSPARENCY · ACCOUNTABILITY

Conflict of Interest Policy

Our commitment to identifying, disclosing, and managing conflicts of interest fairly and transparently.
All employees, directors, and contractors must adhere to this policy.

100%Disclosure compliance
24Hours to report
3Annual reviews
0Tolerance for non‑disclosure

Policy Statement

QuantumX Vault is committed to conducting its business in accordance with the highest ethical standards. We recognize that conflicts of interest may arise in the ordinary course of business. This policy outlines our approach to identifying, disclosing, and managing such conflicts to ensure fair treatment of all clients and stakeholders.

Transparency

All potential conflicts must be disclosed promptly.

Fairness

Clients’ interests come before our own.

Accountability

Breaches will be investigated and remediated.

COMMON SCENARIOS

Types of Conflicts

01

Personal Trading

Employees trading assets ahead of client orders or based on non‑public information.

02

Related Parties

Transactions involving family members, friends, or entities with shared ownership.

03

Outside Employment

Working for a competitor, supplier, or client without prior approval.

04

Gifts & Hospitality

Accepting gifts or favors that could influence business decisions.

05

Board Memberships

Serving on boards of companies that do business with QuantumX Vault.

MANAGEMENT FRAMEWORK

Disclosure & Mitigation

Conflict Type
Disclosure Required
Mitigation Measure
Personal Trading
Pre‑clearance for certain assets
Blackout periods, restricted list
Related Party Transactions
Written disclosure + independent review
Approval by Compliance Officer
Outside Employment
Annual declaration
Prohibition on competitor roles
Gifts & Hospitality
Reporting if value > $100
Decline or return excessive gifts
Board Memberships
Prior written authorization
Chinese wall, recusal from relevant decisions
WHO DOES WHAT

Roles & Responsibilities

Employees
  • Complete annual conflict disclosure form
  • Report any potential conflict immediately
  • Recuse from decisions where conflicted
Managers
  • Review team disclosures
  • Escalate unresolved conflicts
  • Model ethical behavior
Compliance Officer
  • Maintain conflict register
  • Investigate reported conflicts
  • Recommend remedial actions
Board of Directors
  • Oversee policy effectiveness
  • Review high‑risk conflicts
  • Approve policy amendments
REPORTING CHANNELS

How to Report a Conflict

1
Identify potential conflict (self or observed)
2
Immediately notify your manager or Compliance Officer (within 24 hours)
3
Complete Conflict Disclosure Form (available on internal portal)
4
Compliance investigates and determines mitigation (recusal, restricted duties, divestment)
5
Outcome documented in conflict register; annual review
*Anonymous reporting is available via our whistleblower hotline at whistleblower@quantumxvault.com.
TRAINING & AUDIT

Compliance Metrics

100%Employees trained annually
98%Disclosure completion rate
0Unresolved material conflicts
All new hires receive conflict of interest training within 30 days of onboarding. Refresher courses are conducted every 12 months.
98%
Disclosure compliance
FREQUENTLY ASKED

Conflict of Interest
FAQ

What should I do if I suspect a colleague has a conflict?
Report it to your manager or the Compliance Officer immediately. You may also use the anonymous whistleblower channel. Do not investigate yourself.
Can I invest in a crypto project that QuantumX Vault is considering for listing?
No. Employees are prohibited from trading assets that are under review for listing or that could be influenced by their role. Pre‑clearance is required for all personal trading.
How are conflicts documented?
All disclosed conflicts are recorded in a central Conflict Register, which is reviewed by the Compliance Officer and Audit Committee quarterly.
What happens if I fail to disclose a conflict?
Failure to disclose a material conflict may result in disciplinary action up to and including termination of employment or contract, and potential referral to regulators.

Start investing in crypto & access instant loans today — join 20k+ clients.

Jake M. — Instructor, Oliver Driving Institute.
QUANTUMXVAULT
Get started
Crypto investing & loans — the future of money starts with you
John from United States just invested $5,000 in Crypto Mining