OKX Middle East Conflict of Interest Policy

Published: 21 February 2025

1. Purpose and Scope
This Policy applies to all individuals associated with OKX Middle East Fintech FZE ("OKX Dubai"), including employees, Board members, contractors, and anyone associated with the company. It ensures that conflicts of interest between OKX Dubai and its clients are identified, disclosed, and managed ethically and transparently. The goal is to protect the company's integrity and uphold regulatory compliance.

2. Identification of Conflicts
Conflicts of interest can arise at any point in our relationships with clients, vendors, or internal operations. OKX Dubai Staff must remain vigilant and report any potential or actual conflicts. Common conflicts may involve personal financial interests, business relationships, or incentives that prioritize one client over another, or business relationships that may lead to competing interests.

3. Managing Conflicts
When conflicts cannot be avoided, OKX Dubai will implement appropriate measures such as information barriers, staff reassignment, or role segregation. The company maintains a zero-tolerance stance on bribery and corruption, Insider Trading, outside business activities, Intellectual Property (IP) Misuse, Competitive Practices and enforces strict policies to prevent undue influence.

4. Reporting Conflicts
OKX Dubai Staff must promptly report any potential or actual conflicts using the Conflict of Interest Declaration Form. The Head of Compliance, in collaboration with the Managing Director, will assess each situation and determine necessary actions. All conflicts are documented and monitored to ensure transparency. The Board of Directors holds ultimate accountability for conflict resolution. All OKX Dubai Staff must comply with this Policy and escalate conflicts as necessary.

5. Confidentiality and Data Protection
Disclosures related to conflicts of interest are handled confidentially, in compliance with data protection laws, and shared only with relevant personnel for resolution.

6. Training and Compliance
All OKX Dubai staff must acknowledge that they have read, understand, and agree to abide by this Policy. Training is provided to ensure that staff are equipped to identify, report, and resolve conflicts of interest effectively.

7. Violations
Violations of this Policy will be investigated, and failure to comply may result in disciplinary actions, including termination, may be taken for non-compliance.

8. Effective Date and Review
This Policy  along with its documented procedures, becomes effective with approval by the OKX Middle East Fintech FZE board and will be reviewed periodically to ensure compliance with evolving regulations.

This Policy ensures the fair and transparent management of conflicts of interest, safeguarding the best interests of OKX Dubai's clients, employees, and the company's integrity.