Conflicts of interest

Zodia Custody Limited is committed to maintaining high standards of integrity, transparency, and governance. As part of this commitment, we have established a comprehensive framework to identify, assess, manage, and where necessary disclose conflicts of interest.

Conflicts of interest may be actual, potential, or perceived, and can arise across a range of activities, including staff decision making, relationships with clients, counterparties, service providers, and other external parties. If not appropriately managed, conflicts could impact fair client outcomes or market integrity. Zodia Custody therefore takes a proactive and structured approach to conflict management.

Our Conflicts of Interest framework includes:

• A firm wide Conflicts of Interest Policy and Code of Conduct applicable to all staff
• Clear accountability for identifying and managing conflicts at staff, management, and senior leadership level
• Processes to record and assess conflicts through a central Conflicts of Interest Register
• Risk based controls designed to prevent, mitigate, or manage conflicts before they crystallise
• Escalation and governance oversight through Compliance and senior risk committees
• Ongoing monitoring, review, and periodic assurance of conflict controls
• Disclosure to clients where a conflict cannot be fully mitigated through organisational or administrative arrangements

All staff are required to act in the best interests of clients, to avoid conflicts where possible, and to promptly declare any situation that could give rise to an actual or perceived conflict. Senior management is responsible for ensuring appropriate controls are in place within their areas of responsibility and for promoting a strong culture of ethical conduct.

Zodia Custody’s approach to conflicts of interest is embedded within its broader risk management and compliance framework and is reviewed regularly to reflect changes in business activities, regulatory expectations, and market structure.

If you would like a copy of our full Conflicts of Interest Policy or have any questions, please get in touch.