Last Updated: 10.10.2025
We, the Odin Pay s.r.o., a company registered in the Czech Republic, registration number 223 56 312 and having its official registered address at Olšanská 54/3 Prague 3 Žižkov 130 00, Czech Republic (the “Company”), in accordance with Article 72 of the Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets (MiCA), are committed to ensuring transparency and integrity in our operations. This notice aims to inform our clients and prospective clients of the general nature and sources of conflicts of interest that may arise in connection with our services, and the steps taken to mitigate them.
1. Nature of Conflicts of Interest
1.1 Conflicts of interest may arise in various situations, including but not limited to:
1.1.1 Situations where our financial or other interests may conflict with those of our clients.
1.1.2 Scenarios where our personnel or management may have interests that could interfere with their duties to clients.
1.1.3 Instances where we may receive benefits from third parties that could potentially affect our objectivity.
1.1.4 Conflicts arising from providing preferential treatment to certain clients or affiliated parties.
1.1.5 Potential conflicts resulting from personal relationships or financial interests of our personnel that could influence decision-making.
2. Measures for Prevention and Mitigation:
2.1 To address conflicts of interest, we have implemented Conflicts of Interest Policy, taking into account the scale, nature, and range of our crypto-asset services. These measures include:
2.1.1 Regular assessment and review of conflicts of interest cases
2.1.2 Measures on prevention of conflicts of interest
2.1.3 Prohibition of certain activities that may lead to conflicts of interest
2.1.4 Segregation of duties and separation of conflicting roles
2.1.5 Whistleblowing practice
2.1.6 Confidential reporting channels for personnel to disclose conflicts of interest
2.1.7 Training programs to raise awareness and promote conflicts of interest measurements
2.1.8 Monitoring and supervision mechanisms to ensure compliance with our Conflicts of Interest Policy
3. Reporting and Handling of Conflicts of Interest
3.1 Clients are encouraged to report any potential or actual conflicts of interest directly to the Compliance Officer via email: [email protected]. We commit to investigating all reports thoroughly and addressing them in a timely and transparent manner, under the oversight of the Management (CEO and CBO).
3.2 If you have any questions or require further information, please do not hesitate to contact us.