Conflicts of Interest Disclosure

Overview

This Disclosure explains the conflicts of interest that may arise when you use the services provided by Baysart MMC ("we", "the provider").

We identify, disclose and manage conflicts of interest so that your interests are treated fairly in the transactions we conduct with you.

This document is for general information and should be read together with our Service Agreement, Execution Policy and other legal documents.

Our counterparty / market-maker role

On buy, sell and convert transactions we do not act as a broker; we act as your counterparty and market-maker. This means we stand on the other side of the trade.

We source liquidity and price through a Settlement/Liquidity Partner, and then apply a disclosed spread: 100 basis points (1.00%) on buy and sell, and 50 basis points (0.50%) on swaps between USDC and USDT.

This spread is our revenue. As a result, there is an inherent conflict between your interests and ours arising from the counterparty relationship, and it is disclosed to you up front before each transaction.

• Buy/sell: 100 basis points (1.00%) spread.
• USDC ↔ USDT swap: 50 basis points (0.50%) spread.
• The spread is reflected in the price shown to you before the transaction.

Our issuer role

We also issue AZNS (the manat-pegged stablecoin). This is a separate role and an additional source of conflict of interest.

In managing the reserves backing AZNS, we may earn income on those reserves (reserve income). Holders of AZNS earn no interest or yield on the AZNS they hold.

Accordingly, as issuer our interests differ in part from your holding of AZNS, on which you earn no income, and this is disclosed.

How we manage these conflicts

We apply the following measures so that conflicts of interest are not used to your detriment.

Further detail on the fair-execution aspects of these measures is set out in our Execution Policy.

• Transparent, pre-trade pricing: the price and the applied spread are shown before you confirm.
• We do not front-run your orders.
• Fair execution: orders are executed in accordance with our Execution Policy.
• Segregation of the AZNS reserve: reserve assets are managed separately and are not commingled with our operating funds.

Your acknowledgment

By using our services to buy, sell, convert or swap, you confirm that you understand and accept the conflicts of interest set out in this Disclosure.

If you do not agree, you should not carry out the relevant transactions.