Conflict of Interest Disclosure Gemini Intergalactic EU Artemis, Ltd

Última actualización: 1 October 2025

Conflict of Interest Disclosure - GIEAL

Gemini Intergalactic EU Artemis, Ltd (the “Company”) is required to establish, implement and maintain effective policies and procedures, taking into account the nature, scale and range of its investment services, to appropriately identify, prevent, manage and disclose any real, potential or perceived conflicts of interest.
The Company has established a Conflicts of Interest Policy (the “Policy”) which sets out the effective organizational and administrative arrangements implemented by the Company to identify, prevent, manage and disclose any real, potential or perceived conflicts of interest entailing a material actual or potential risk of damage to the interests of the Company and/or its clients (the “Clients”). 
Identification of Conflicts
Conflicts of interest may arise between:
  1. the Company (including any director, manager, employee, officer, member of any committee of the Company, tied agent, or any person or entity directly or indirectly linked to the Company by control, or any person or entity directly involved in the provision of services placed at the disposal of the Company or under the control of the Company or through an outsourcing agreement (collectively, the “Relevant Persons”)) and their Clients;
  2. different Clients of the Company;
  3. the Company and any Relevant Person;
  4. different teams/ functions of the Company; and
  5. different companies and associates within the Gemini Group (the “Group”).
The Company maintains a Conflicts of Interest Register which records conflicts of interests arising from time to time, and the manner in which the risks relating to those conflicts of interests are mitigated.
Conflicts of Interest potentially detrimental to Clients
A conflict of interest is a situation where either the Company or any of its Relevant Persons is in a position to exploit the proceedings of a transaction or the services or activities in a professional or official capacity in some way either for corporate or personal benefit or interest.
For the purposes of identifying the conflicts of interest that may arise in the course of providing investment services and whose existence may damage the interests of one or more Clients, the Company shall consider, as a minimum, whether the Company or any of its Relevant Persons, is in any one of the following scenarios:
a) it is likely to make a financial gain, avoid a financial loss, or receive another kind of benefit, at the expense of a Client;
b) it has an interest in the outcome of a service provided to a Client, or of a transaction carried out on behalf of a Client, which is distinct from the Client’s interest in that outcome;
c) it has a financial or other incentive to favour the interest of one or more Clients over the interests of another Client;
d) it carries out the same business as a Client;
e) it receives or will receive from a person, other than a Client, an inducement in relation to a service provided to the Client, in the form of monetary or non-monetary benefits or services.
Conflicts of Interest due to the Nature of the Investment Services
The Company may face a variety of “standard” conflicts similar to those faced by most investment firms in a similar business to the Company. These include conflicts associated with, inter alia:
a) personal account trading by staff in securities traded for the Clients;
b) allocation of transactions amongst different Clients;
c) favouring certain entities or counterparties over others; and
d) entertainment or other forms of inducement.
The Company may also face a variety of other conflicts as a result of the nature of the activities which the Company provides. Where there are any conflicting activities, the Company will have conflicts of interest which need to be managed appropriately.
The Company may combine a transaction for a Client with orders of another Client. The Company will only aggregate orders when it considers that the aggregation of orders will work to the advantage of the Clients. The effect of aggregation may in certain instances work to the disadvantage of a Client in relation to any particular order.
Conflicts of Interest due to other Entities within the Group
The Company shall take into account any circumstances which may give rise to a conflict of interest due to the structure and business activities of other entities within the group.
Prevention and Management of Conflicts of Interest
The Company has robust governance arrangements and oversight by senior management. Key decisions are taken by the Board of Directors and the head of departments, who understand the Company’s obligations under applicable law to identify, prevent, manage and disclose conflicts of interest.
The procedures and measures to prevent and/or manage conflicts of interest include:
  1. Reporting Lines
  2. Separate Supervision
  3. Segregation of Functions
  4. Board of Directors responsibilities
  5. Risk Management and Compliance Function oversight
  6. Access to Information restrictions
  7. Remuneration policy
  8. Best Execution policy
  9. Personal Transactions restrictions
  10. Payments, Gifts or other Forms of Inducements policy
  11. Awareness of this Policy and Appropriate Internal Reporting Channels within the Company
  12. Disclosure to Clients
  13. Outside Business & Directorships oversight
  14. Oversight of Services by Group Entities

La plataforma financiera criptonativa de confianza

Crea una cuenta gratis de Gemini en minutos