Last updated on September 1, 2025
1. INTRODUCTION
Burvix sp. z o.o., company incorporated under number 0001131882, having its registered address at ul. Żurawia 43, lok. 8a, 00-680 Warszawa, Republic of Poland (hereinafter – “Company”, “We”, “Our”, “Us”) is committed to acting honestly, fairly, and professionally in the best interests of its clients (hereinafter – “Clients”).
The Company has adopted this Conflicts of Interest Disclosure (hereinafter – “Disclosure”) to identify, prevent, and manage situations where conflicts may arise in the course of providing crypto-asset services.
The purpose of this Disclosure is to ensure transparency towards Our Clients and to maintain their trust. Where a conflict of interest cannot be fully prevented, the Company will take all reasonable steps to manage it and, if necessary, disclose it to Clients in a clear and timely manner before providing the relevant service.
This Disclosure applies to all crypto-asset services provided by the Company.
2. DEFINITION OF CONFLICTS OF INTEREST
A conflict of interest arises when personal, professional, or financial interests of the Company, its managers, employees, shareholders, or related persons may interfere (or appear to interfere) with the ability to act in the best interests of Clients.
Conflicts can be actual, potential, or perceived. Even the appearance of a conflict is treated seriously and managed with the same level of care as an actual one..
3. TYPES OF CONFLICTS THAT MAY ARISE
Conflicts of interest may arise in different ways during the course of Our business. The most common types include:
- Company vs Client – where the Company, its employees, or shareholders could gain a benefit at the expense of a Client. For instance, the Company has a financial incentive to recommend one product over another that may not be in the Client’s best interest.
- Client vs Client – where the interests of two or more Clients are in conflict. For instance, executing transactions for multiple Clients in the same asset where one Client’s position may negatively impact another’s.
- Personal interests of employees or management – where employees or managers have external business interests, investments, or relationships that could affect their impartiality. For instance, holding shares in a competing business or having close ties with a supplier or partner of the Company.
- Gifts and inducements – where offering or accepting gifts, benefits, or hospitality could improperly influence decision-making.
- Use of confidential information – where access to sensitive or non-public Client information could be misused for personal or third-party gain.
The existence of a conflict of interest does not necessarily mean that wrongdoing has occurred. What matters is that the conflict is identified, disclosed when necessary, and properly managed so that Client interests are not harmed.
4. PREVENTION AND MANAGEMENT
The Company takes a proactive approach to preventing and managing conflicts of interest. We have put in place internal procedures and controls designed to protect Clients’ interests and ensure fair treatment at all times.
Key measures include:
- clear internal policies and procedures to identify, assess, and manage conflicts of interest;
- segregation of duties so that decisions and controls are not concentrated in one individual or team;
- restrictions on personal trading and outside business activities that could create conflicts;
- rules on gifts and hospitality, ensuring that employees cannot be influenced through undue benefits;
- employee training and awareness to help staff identify and properly report potential conflicts;
- oversight by the Compliance function to monitor adherence and review conflicts on an ongoing basis.
Where a conflict cannot be fully prevented, the Company will apply additional safeguards – such as recusal from decisions, reassignment of responsibilities, or disclosure to Clients – to ensure that Clients’ interests remain protected.
In exceptional cases, if the Company determines that a conflict of interest cannot be effectively managed or mitigated, We may decide not to proceed with providing the relevant service to the Client.
5. DISCLOSURE TO CLIENTS
The Company’s priority is to prevent and properly manage conflicts of interest. However, if a conflict cannot be fully avoided, We will provide Clients with clear, timely and prominent disclosure before delivering the relevant crypto-asset service.
Such disclosure will include:
- a description of the nature and source of the conflict;
- an explanation of the measures taken to manage or mitigate the conflict;
- a statement of the residual risks that may remain despite these measures.
This information will be provided in sufficient detail to enable the Client to make an informed decision about whether to proceed with the service under the disclosed circumstances.
6. CLIENT RIGHTS
Clients have the right to:
- receive clear and timely information about any conflict of interest that may affect them;
- make an informed decision on whether to proceed with a service in circumstances where a conflict exists;
- refuse to continue with a service if they do not feel comfortable with the disclosed conflict;
- raise questions or concerns about conflicts of interest at any time.
If a Client believes that their interests have been negatively affected by a conflict of interest, they may contact the Company through the channels listed below.
7. CONTACTS
If you have any questions about this Disclosure, or if you wish to notify Us of a potential or actual conflict of interest, please contact Us at: legal@burvix.io.
We will review your concern promptly and provide a response in line with Our internal procedures.
8. REVIEW
This Disclosure is reviewed at least once a year and updated whenever necessary to reflect changes in the Company’s business model, products and services, or applicable regulatory requirements.
The latest version of this Disclosure is always available on Our website.