Last updated: 27/09/2025
Scintilla Network FZE (“Scintilla”) is committed to identifying, managing, and disclosing conflicts of interest that may arise in the course of our business. This ensures fairness, transparency, and alignment with the Dubai Virtual Assets Regulatory Authority (VARA) Rulebooks.
A conflict of interest occurs when Scintilla’s interests, or those of our employees, could interfere with the best interests of our clients or investors.
Examples (where applicable) include:
• Preferential allocation of tokens in an issuance.
• Scintilla acting as both issuer and distributor.
• Pricing or routing decisions influenced by commercial arrangements.
• Staff personal trading in Virtual Assets linked to client activity.
Scintilla applies the following measures:
• Separation of Functions – staff with conflicting responsibilities are segregated.
• Disclosure – material conflicts are disclosed to clients before transactions.
• No Undisclosed Benefits – we do not accept hidden commissions or retrocessions.
• Governance Oversight – all conflicts are reviewed by the Compliance Officer and
reported to the Audit, Risk and Compliance Committee.
Where applicable:
• Whitepapers disclose any relationship between Scintilla and token issuers.
• Allocation processes are documented and free from preferential treatment.
• Any cross-ownership or financial interest in issuances is disclosed to VARA and investors.
For details on Scintilla’s Conflicts of Interest Policy, please email: contactus@scintillanetwork.com.
