Conflicts of Interest policy
Introduction
This document provides a summary of the Conflicts of Interest Disclosure for Ramp Swaps (Ireland) Limited (“Ramp Ireland”), pursuant to Regulation (EU) 2023/1114 on Markets in Crypto-Assets (“MiCAR”). In compliance with Article 72 MiCAR and the ESMA Regulatory Technical Standards (RTS), this disclosure outlines our approach to identifying, preventing, and managing conflicts of interest to ensure the fair treatment of our clients.
Where Conflicts Can Arise
Conflicts may arise between Ramp Ireland and our clients, between different clients, between group companies/shareholders, or internally regarding staff incentives and personal interests. These situations occur where the financial or personal interests of the firm or its employees may compromise the integrity of decisions made in the best interests of our clients.
Management of Conflicts of Interest
Ramp Ireland operates a layered control framework, including organisational segregation, information barriers to prevent inappropriate sharing of inside information, and strict staff conduct rules. Our Head of Compliance maintains a formal Conflicts Register, and all significant risks are subject to Board oversight and regular monitoring.
Conflict Risks and Mitigations
1. Group Structure and Operational Independence: As we outsource certain operations to group entities, a risk exists that group-level priorities could compromise our local regulatory obligations. We mitigate this through legally binding Intra-Group Agreements that prioritise Irish regulatory requirements and by ensuring the Ramp Ireland Board maintains a majority of independent members.
2. Transaction Pricing: When settling transactions against our proprietary assets, a conflict of interest regarding price may arise. This is managed through our Commercial Policy and a transparent Pricing Policy published on our website.
3. Asset Selection: To prevent the firm from being incentivised to offer assets based on profitability rather than quality, we employ a formal Token Due Diligence Procedure. This ensures assets are selected based on objective criteria, including security, liquidity, and reputational checks.
4. Execution and Slippage: During volatile market movements, the firm could be incentivised to pass negative slippage to clients while retaining positive movements. We mitigate this by defining exact order finality points in our Pricing Policy and monitoring execution prices against quoted prices.
5. Client Order Sequencing: To prevent unfair treatment when multiple orders are received simultaneously, we utilise an automated, time-prioritised First-In, First-Out (FIFO) system. This eliminates human discretion in the sequencing of client orders.
6. Liquidity Provider Selection: To ensure our choice of Liquidity Providers is not influenced by rebates or inducements, we follow an objective vendor selection process and conduct annual due diligence to ensure pricing remains competitive with the wider market.
7. Payment Processor Selection: We select banking and payment partners based on service quality and fee levels rather than ancillary commercial benefits to the firm. This is managed through a formal vendor selection process and a strict prohibition on inducements.
8. Management Body External Interests: Board members may hold external directorships that create divided loyalties. We require annual declarations of interest and enforce a strict policy where conflicted directors must recuse themselves from relevant discussions and voting.
9. Remuneration and Incentives: To ensure our commercial team acts in your best interests, our Remuneration Policy prohibits variable pay from being directly linked to the profitability of a single transaction or narrow portfolio of transactions.
10. Gifts and Inducements: To prevent objectivity from being compromised by third-party benefits, we enforce a zero-tolerance policy on bribery. All staff must declare gifts and hospitality above a de minimis threshold in a centralised register managed by Compliance.
Disclosure Approach Where it is not possible to fully eliminate a conflict, Ramp Ireland will provide clear and timely disclosure on our website and applications to ensure you can make an informed decision before proceeding.