Conflict of Interest Statement
Dream Finance OÜ is committed to acting honestly, fairly, and professionally in the best interests of our clients. We maintain robust internal standards to identify, prevent, and manage conflicts of interest that may arise during the course of our business activities.
This page summarises the key principles of our Conflicts of Interest Policy.
1. What Is a Conflict of Interest?
A conflict of interest occurs when the personal, professional, or financial interests of Dream Finance OÜ, its employees, or related parties may diverge from the interests of our clients or impair the objectivity and independence of decision-making.
Conflicts may be:
- Actual – a direct and existing conflict;
- Potential – a situation that could develop into a conflict;
- Perceived – circumstances that may appear to compromise impartiality, even if no real conflict exists.
Our objective is to ensure such situations are recognised early, assessed properly, and managed effectively to maintain trust and integrity.
2. General Principles We Follow
Dream Finance OÜ applies the following fundamental principles in managing conflicts of interest:
Fair treatment
We always act in the best interests of our clients and ensure our actions do not unfairly advantage one client over another.
Integrity and independence of judgement
Our employees and management must make decisions independently and avoid situations that could impair objectivity.
Transparency
Where unavoidable conflicts arise, we provide transparent disclosures to clients, explaining the nature of the conflict and the measures used to address it.
Confidentiality
Sensitive information obtained during business activities – including crypto-asset-related and commercial information – is handled strictly in accordance with confidentiality and applicable regulations.
Proportionality
Measures to prevent or manage conflicts are applied in a manner proportionate to the nature, scale, and risks of our business.
3. Types of Conflicts of Interest
A. Institutional Conflicts of Interest
Institutional conflicts may arise from the Company’s organisational structure, business lines, or interactions with external stakeholders. Examples include:
- Different business units whose objectives may diverge;
- Situations where multiple functions overlap or could influence one another;
- Relationships with vendors, partners, or group-related entities.
To mitigate such risks, we implement clear separation of responsibilities, information barriers (“Chinese walls”), and robust governance arrangements.
B. Personal Conflicts of Interest
Personal conflicts may arise when an individual’s private interests diverge from their professional duties. Examples include:
- Financial interests in external companies or clients;
- Close personal or professional relationships that may impact independent judgement;
- Gifts, benefits, or inducements that could influence decisions;
- External employment or business activity that could affect impartiality.
Employees and management are required to disclose such interests and refrain from participating in decisions where their independence may be compromised.
4. How We Identify and Assess Conflicts
Dream Finance OÜ maintains internal procedures to identify and assess potential or actual conflicts of interest. These include:
- Regular declarations of interest by employees and management;
- Review of new products, business lines, and organisational changes;
- Ongoing monitoring by Compliance in accordance with applicable regulations.
Identified conflicts are evaluated based on:
- Their nature and sources;
- The persons or units involved;
- The potential impact on clients and the Company (material vs non-material).
5. How We Manage Conflicts of Interest
Where conflicts are identified, the Company applies measures such as:
Preventive measures
- Segregation of duties and responsibilities;
- Separation of structural units and sensitive functions;
- Ensuring related-party transactions occur on market terms;
- Restrictions on access to sensitive information.
Mitigating measures
If a conflict cannot be fully prevented, we take additional steps such as:
- Reassigning responsibilities;
- Enhanced monitoring of decisions or transactions;
- Withholding certain persons from participating in decision-making (e.g., abstaining from votes).
Material conflicts of interest are never accepted and must always be prevented or effectively mitigated.
6. Disclosure to Clients
In the limited cases where a conflict cannot be fully avoided, we may provide clear and fair disclosure to affected clients.
Such disclosure includes:
- The nature and source of the conflict;
- Associated risks;
- The measures taken to manage or mitigate the conflict.
Disclosure is used only as a last resort – never as a substitute for proper internal controls.
7. Record-Keeping and Monitoring
Dream Finance OÜ maintains a Conflicts of Interest Register, where identified conflicts and relevant mitigation measures are documented.
Compliance regularly monitors the effectiveness of applied measures and provides periodic reports to senior management and the Regulatory body, if required.
We also conduct ongoing employee training to ensure awareness and adherence to our standards.
8. Commitment to Continuous Improvement
Our Conflicts of Interest Policy is reviewed regularly to ensure continued alignment with:
- applicable regulations;
- expectations of the Regulatory body;
- best practices in transparency, governance, and client protection.
Dream Finance OÜ is committed to maintaining strong internal controls to protect the interests of all clients and stakeholders.