Conflict of Interest Policy

Updated August 13, 2024

At Figure Markets, we are committed to conducting business in a fair, ethical, and transparent manner. As part of this commitment, we provide this Conflicts of Interest Disclosure to inform our users about potential conflicts that may arise and how we manage them. This disclosure is provided to ensure that our users are aware of any circumstances that could influence our services or decision-making processes.

Proprietary Trading:

• Summary: Our exchange and/or affiliates may engage in proprietary trading activities. This means that we, or our affiliates, may trade digital assets for our own account, which could include buying, selling, or holding positions in the same digital assets that are available for trading on our platform.
• Management: We have implemented policies and procedures to separate our proprietary trading activities from user trading activities. Our proprietary trading desk operates independently of the teams responsible for user account management and order execution. Any affiliate account(s) engaging in proprietary trading is subject to the same fees, rules, and restrictions as other user accounts accessing our exchange. Additionally, we do not use non-public information about user trades for our own trading purposes.

Market Making:

• Summary: We may act as a market maker for certain digital assets listed on our platform. As a market maker, we may provide liquidity by continuously offering to buy and sell certain digital assets at publicly quoted prices.
• Management: To mitigate potential conflicts, our market-making activities are conducted in accordance with established regulatory standards and internal policies. We maintain transparent and fair market practices, and our market-making operations are monitored to ensure compliance with these standards.

Listings and Delistings:

• Summary: The decision to list or delist a digital asset on our exchange may create a potential conflict of interest, especially if we have a financial interest in the digital asset or a business relationship with a certain project and/or issuer.
• Management: We have a detailed process for evaluating digital assets for listing and delisting. This process involves a thorough review of the asset’s technology, market demand, regulatory compliance, and other relevant factors. Decisions are made by a dedicated committee that operates independently of any financial interests or business relationships.

Fees and Incentives:

• Summary: Our exchange may generate revenue through transaction fees, listing fees, and other charges. Additionally, we may offer incentives or discounts to certain users, which may create a potential conflict of interest.
• Management: We disclose our fee structure transparently on our website, and any incentives or discounts are offered based on clear and objective criteria. Our goal is to ensure that all users are treated fairly and that our fee practices do not unduly influence our decision-making processes.

Relationships with Third Parties:

• Summary: We may have business relationships with third-party service providers, including liquidity providers, wallet providers, payment processors, or other partners, which may create potential conflicts of interest.
• Management: We conduct due diligence on all third-party service providers and maintain clear and transparent agreements that prioritize the interests of our users. We regularly review these relationships to ensure they align with our commitment to fairness and transparency.

Employee Trading:

• Summary: Employees of our exchange may have access to non-public information and may also trade digital assets for their own accounts, creating a potential conflict of interest.
• Management: We have implemented strict policies to prevent misuse of non-public information. Employees are prohibited from trading based on any non-public information they may have access to as part of their employment.

Advisory Roles:

• Summary: Members of our team or advisory board and affiliates may hold positions or advisory roles in digital asset projects, which may create potential conflicts of interest.
• Management: We require full disclosure of any such roles and implement measures to manage potential conflicts. Decisions related to the exchange’s operations and listings are made independently of any personal interests held by any team members and/or advisors.