Conflicts of Interest Disclosure

Breinrock s.r.o. · Version 1.0 · Effective 12 November 2026

1. Purpose

This disclosure explains where conflicts of interest may arise when we provide our services to you, and what we do to manage them. It applies to all services Breinrock s.r.o. provides to its clients, including payment services.

A conflict of interest arises when our interests, or those of our staff or group companies, could differ from yours. It can also arise when the interests of one client could differ from those of another.

2. Our approach

We aim to prevent conflicts of interest. Where we cannot prevent one, we manage it so it does not harm your interests. Where a conflict remains despite these steps, we tell you about it before we provide the service. This disclosure does not replace those steps.

3. Where conflicts may arise

• Group companies. Breinrock s.r.o. is part of the Breinrock group. Other group companies provide other financial services and share some systems and staff with us.
• Our staff. Staff may hold their own investments or have outside interests that could influence their work.
• Pay and incentives. Pay linked to sales or volume could encourage staff to act in our interest rather than yours.
• Gifts and payments from third parties. Gifts, hospitality or fees from partners or providers could influence our choices.
• Our service providers. We use third parties for some services. Our choice of provider could be influenced by our own commercial interests.
• Between clients. We may serve clients whose interests differ, for example when handling orders or allocating resources.

4. How we manage them

• We keep a written conflicts of interest policy, approved by our management, and review it at least once a year.
• We identify and record conflicts of interest in a conflicts register.
• We separate roles and information where needed, so that staff with a conflict are not involved in the decision.
• Staff must declare outside interests and follow rules on personal transactions.
• Our pay structures do not reward staff for acting against clients’ interests.
• Staff may not accept gifts or payments that could affect their judgement. Permitted gifts are recorded.
• We choose service providers on objective criteria and review them regularly.
• We treat all clients fairly and handle orders in the order received.
• Our compliance function monitors these measures and reports to management.

5. Updates

We keep this disclosure up to date. We review it at least once a year and whenever our services or the conflicts we identify change. The current version is always available on our website.

6. Questions

If you have questions about this disclosure, contact us at complaints.cz@breinrock.com or at Breinrock s.r.o., Lazarská 1718/3, Nové Město, 110 00 Prague 1, Czech Republic.