Noah LV SIA

1. GENERAL PROVISIONS

1.1. This Policy describes the conflicts of interest which may arise in the services of the Company, the risks to the Customer, and the measures by which the Company prevents those risks.

1.2. It is the conflicts of interest policy in section 7.10 of the Terms of Service, addressed to Customers and prospective Customers. The Company is NOAH LV SIA, registration number 40203762919, with its registered office at Antonijas iela 21, Rīga, LV-1010, Latvia.

1.3. The Company identifies, prevents and manages conflicts of interest. Disclosure does not relieve the Company of that duty. Where its arrangements are not sufficient to prevent the risk of damage to the Customer, the Company discloses the conflict before it acts, as set out in Section 5.

1.4. This Policy does not amend the Terms of Service. It is not investment advice and it is not a recommendation to enter into a transaction.

2. SERVICES COVERED BY THIS POLICY AND THE CAPACITY IN WHICH THE COMPANY ACTS

2.1. This Policy applies to the services which Latvijas Banka has authorised the Company to provide from 30 September 2026, whether the Customer uses them directly or through a Partner.

2.2. Crypto-asset services, licence No. 27-55/2026/24: custody and administration of crypto-assets on behalf of clients; exchange of crypto-assets for funds; execution of orders for crypto-assets on behalf of clients; and transfer services for crypto-assets on behalf of clients.

2.3. Payment services, licence No. 27-55/2026/28: execution of payment transactions, including credit transfers and standing orders.

2.4. In custody, the Company holds crypto-assets for the Customer and does not treat them as its own assets. On an exchange of crypto-assets for funds, the Company acts as counterparty and may earn a spread or a fee. The Company executes orders for the Customer and may use a liquidity provider, transfers crypto-assets on the Customer's instruction, and executes payments for the Customer.

2.5. Before the Customer confirms a transaction, the Company presents the service, the capacity in which it acts, and the price, spread, fee or other charge.

3. NATURE AND SOURCES OF CONFLICTS OF INTEREST

3.1. A conflict of interest arises where an interest of the Company, or of a Related Person, competes with an interest of a Customer, or the interests of Customers compete, in a way that may damage a Customer if the conflict is not prevented or managed. A Related Person is a shareholder, a person holding a qualifying holding, an employee or a member of the Board, and the spouse, registered partner or relative up to the third degree of any of them, a company which any of them controls or manages, and a person acting jointly with them. The Board is the Management Board of the Company.

3.2. A conflict of interest may arise where the Company or a Related Person:

3.2.1. may obtain a financial gain, or avoid a loss, at the expense of the Customer. On an exchange, the Company acts as counterparty and may earn a spread or a fee, so the price or the route may favour the Company.

3.2.2. has an interest in the outcome which differs from the interest of the Customer, including through a liquidity provider, a sub-custodian or a Partner, such as the quoted price, filling an order, a custody appointment, or the Partner's relationship with the Customer.

3.2.3. has an incentive to favour another Customer, a Partner, a liquidity provider or another third party, where a fee, commission, rebate or other inducement may influence the choice of provider, crypto-asset or execution path.

3.2.4. acts in more than one capacity in one journey, by holding crypto-assets for the Customer, exchanging them as counterparty, and transferring them or executing a payment. A group company may supply the technology, and a Partner may introduce the Customer.

3.2.5. carries out a personal transaction, or uses non-public information about an order of the Customer or about the pricing of the Company.

3.3. Customers may have competing interests, including where a Customer is also a Partner, a shareholder, an employee or a group company. Different fees or terms are those set out in the agreement applicable to the relevant Customer.

4. MEASURES TO IDENTIFY, PREVENT AND MANAGE CONFLICTS OF INTEREST

4.1. The Company limits access to information about a Customer, and to pricing and order flow, to the persons who need it for their functions. A Related Person does not use that non-public information for a personal transaction.

4.2. Where activities may conflict, the Company entrusts them to different persons. A Related Person with a personal, family or business connection with a Customer does not take part in onboarding, risk assessment, service conditions or approval for that Customer. Where the connection may affect the Customer's treatment, the Company does not provide the service until the Customer confirms in writing that the Customer is aware of the connection and accepts it.

4.3. Remuneration does not reward employees, members of the Board or persons performing outsourced tasks for favouring themselves, the Company, or one Customer or Partner, at the expense of a Customer. A Related Person does not accept a gift that could influence professional judgement.

4.4. The Company assesses a fee or other inducement from or to a Partner, liquidity provider, sub-custodian, technology provider or group company, and does not enter into an inducement that would impair fair treatment of the Customer. A conflicted transaction with a Related Person or a group company is documented and carried out on terms equivalent to those between independent parties.

4.5. The Company does not favour a Customer because the Customer is connected with a shareholder, a member of the Board, an employee or another Related Person. Crypto-assets held for a Customer are dealt with only as the Terms of Service and the law permit.

4.6. A Related Person declares outside interests at least once a year and when they change, and informs the Chief Compliance Officer promptly of a conflict of interest. The Company keeps a register of conflicts, measures and disclosures for at least five years after the relevant relationship ends.

4.7. A personal crypto-asset transaction of a Related Person, outside that person's duties, is notified to the Chief Compliance Officer before it is agreed, documented, and carried out on terms equivalent to those between independent parties. Above a set threshold, the Board approves it first. The Company may prohibit or restrict it. A member of the Board does not vote where that member has a conflict of interest.

4.8. The Chief Compliance Officer assesses a reported conflict promptly and sets the measures, which may include removing a person from the function. Where the conflict cannot be avoided, the Company manages it fairly and, where Section 5 applies, discloses it before acting. A material conflict is escalated to the Board.

5. DISCLOSURE OF CONFLICTS OF INTEREST TO CUSTOMERS

5.1. The Company publishes this Policy in English, in a prominent place on its website and in the channel through which the service is provided, with a link to the website version.

5.2. Where the arrangements are not sufficient to prevent the risk of damage to the Customer, the Company discloses, before it acts, the nature and sources of the conflict, its capacity, the risks, the measures and any risk that remains. The Customer may decide not to use the service.

5.3. The Company updates a disclosure where the conflict, the persons involved, the risks or the measures change materially.

6. FINAL PROVISIONS

6.1. A Customer may request a copy of this Policy by email to support@noah.com or by post to the registered office of the Company.