Conflicts of Interest Policy

1. Purpose and scope

This policy governs conflicts of interest at Aethon Digital FZCO, operating as Aethon Credit Intelligence (ACI). It applies to ACI's directors, employees and contractors, and to any person who contributes to the production, review or approval of an ACI Risk Indicator. In this policy, “ACI personnel” means those persons collectively.

The policy covers the production of ACI analytical outputs. It does not govern commercial activities unrelated to scoring.

2. Ownership and financial interests of the firm

ACI does not hold, and will not hold, a financial interest in any entity it scores. This covers equity, debt, token holdings, derivative positions and any economic interest whose value depends on the performance of a scored entity or product.

ACI holds no ownership interest in any provider, issuer, custodian or venue covered by any scoring module. No scored entity holds an ownership interest in Aethon Digital FZCO.

3. Personal holdings

As a condition of engagement, ACI personnel must not hold a financial interest in any covered entity or covered product, except direct personal ownership of native bitcoin (BTC), which is permitted subject to the disclosure, conflict assessment and recusal requirements set out in this policy.

This covers equity, debt, token holdings and derivative exposure whose value depends on the performance of a scored entity.

This exception applies only to BTC itself. All other restrictions and exclusions set out in this policy remain unchanged.

Broad-market instruments that give no material exposure to a single scored entity — diversified index funds, pension arrangements and life insurance, for instance — fall outside this prohibition.

Holding digital or traditional assets in custody at a regulated institution, on that institution's standard commercial terms, is a customer relationship rather than a financial interest in the institution, and is permitted. Any such relationship with a scored entity must be disclosed under section 11 and assessed against section 6.

Anyone who becomes aware of a prohibited holding must disclose it to the Chief Risk Officer and dispose of it, and may not participate in scoring that entity until they have.

4. Revenue and the issuer-pays question

ACI is not paid by the entities it scores to produce, modify, delay, withhold or publish a score. ACI has no issuer-pays arrangement and does not offer one.

Covered entities may purchase ordinary subscriptions on the published terms available to other subscribers. Subscription purchases do not influence methodology, evidence assessment, Risk Indicator results, certification or publication timing.

ACI does not accept payment for favourable coverage, does not sell placement in any ranking or board, and does not offer paid score reviews or rating advisory services.

5. Indirect interests and related parties

The restrictions in sections 2 and 3 extend to interests held through an intermediary, including holdings by an entity that an ACI person controls, and holdings by an immediate family member in the same household where the ACI person has a material economic interest in them.

ACI personnel must disclose any commercial relationship, directorship, advisory role or family connection with a scored entity to the Chief Risk Officer before contributing to a score for that entity.

6. Recusal

Where a person holds a disclosed interest or relationship that could reasonably be seen to affect their judgement on a specific provider, they are recused from that provider's scoring and certification. A recusal is recorded in the audit log against the affected provider, with the date and reason.

An ordinary customer relationship of the kind described in section 3 does not by itself trigger recusal. Recusal follows from an interest in the performance of a scored entity, from a commercial arrangement with it, or from any relationship that could reasonably be seen to affect judgement.

ACI currently operates with a single Chief Risk Officer. Where the Chief Risk Officer is recused, ACI does not publish a score for that provider. ACI does not substitute a less independent reviewer to keep a score in production.

7. Governance and evidence integrity

ACI Risk Indicators are computed from validated, classified inputs under the published methodology. Risk Indicator calculations are deterministic when the approved inputs, methodology version, engine version and configuration are held constant. Evidence is drawn from public sources; selection and classification follow documented procedures.

Scored entities do not review, approve or receive advance sight of a score before publication, and hold no right to require a change to a published score.

A provider may submit factual corrections with supporting evidence. A correction enters the same deterministic pipeline, is recorded in the audit log, and produces a new snapshot. Earlier snapshots are not overwritten.

8. Gifts and inducements

ACI personnel must not accept gifts, entertainment, travel or any other benefit from a scored entity, or from a person acting on its behalf, other than hospitality of nominal value in an ordinary business setting. Anything beyond that is declined or returned.

9. Breaches

A suspected breach is reported to the Chief Risk Officer, who records it and determines what action is required, including recusal, withdrawal of an affected score, or ending an engagement.

Where a breach may have affected a published score, that score is reviewed and, where necessary, recomputed and republished with the correction recorded.

10. Relationship to prevailing standards

Conflicts standards for rating and analytical firms, including those applied under the United States and European regimes, restrict ownership of an assessed entity's securities and financial instruments and require the separation of commercial and analytical functions. They do not treat an ordinary customer relationship — a deposit, custody or insurance account on standard terms — as a disqualifying interest.

ACI applies the same distinction. Where such a relationship exists with a scored entity, ACI discloses it under section 11 rather than relying on that distinction silently.

11. Current disclosures

The following relationships are disclosed as at the effective date of this policy.

ACI personnel hold personal digital assets in custody with Sygnum Bank AG on standard commercial terms. Sygnum appears in ACI's provider universe as a custodian. The relationship is that of an ordinary custody customer: it confers no equity, debt, token or derivative interest in Sygnum Bank AG and no preferential terms. There is no commercial arrangement between Sygnum and ACI, ACI receives no payment from Sygnum, and Sygnum holds no interest in Aethon Digital FZCO, the operator of Aethon Credit Intelligence.

This relationship does not trigger recusal under section 6. Sygnum Bank AG is assessed under the same published methodology, evidence standards and hard rules as every other entity in scope. The score is computed deterministically from published evidence. This disclosure is carried with any ACI output whose result is materially determined by an assessment of Sygnum.

ACI personnel hold BTC in a personal capacity, as disclosed in the Conflicts of Interest Policy.

Last updated: 2 October 2026.

ACI holds no relationship of the kinds described in sections 2, 3 or 5 other than those disclosed above. This section is updated whenever a disclosable relationship arises.

12. Review and contact

This policy is reviewed annually, and on any material change to ACI's ownership, personnel or revenue model.

Questions and reports: help@aethoncredit.com