Satispay Invest S.A.
Compliance Function
This summary of our Conflicts of Interest Policy (the “Summary”) applies to Satispay Invest SA (“Satispay Invest” and, the “firm”) which is an investment firm authorised and regulated by the Commission de Surveillance du Secteur Financier (“CSSF”) with register number P00000555.
This Summary sets out the circumstances and activities that have been identified by Satispay Invest as potentially giving rise to conflicts of interest entailing a risk of damage to client interests. It further outlines the organizational and administrative controls established to identify, prevent, manage, and, where necessary, disclose such conflicts. These arrangements are subject to ongoing monitoring and review by Satispay Invest’s Compliance function to ensure the firm continuously adheres to its statutory obligation to act honestly, fairly, and professionally in the best interests of its clients.
A conflict of interest arises where the duty of Satispay Invest to act in the best interests of a client is, or may be, compromised by competing interests. Such situations may arise between:
Satispay Invest (including its group entities) and a client;
Satispay Invest employee or director and a client;
Two or more clients of Satispay Invest;
Third-party service provider and a client.
Satispay Invest provides investment services and, where applicable, ancillary services in accordance with its regulatory authorization. In providing these services,, Satispay Invest acknowledges that conflicts of interest may arise across its business operations presenting a risk of disadvantage to clients, including:
Strategic arrangements with external partners, including product issuers, execution and settlement brokers, or data and research providers, where institutional ties could influence service selection over the client’s best interest.
Receipt of monetary or non-monetary benefits from third parties, such as distribution fees, commissions, marketing contributions, or corporate gifts, that could introduce commercial bias.
Business targets, promotional initiatives, or volume-based goals that could incentivize prioritizing Satispay Invest revenue or platform turnover above client outcomes.
Personal investment activity of Satispay Invest employees, outside business activities, that present risks of front-running or unauthorized use of confidential client data.
Personal connections of Satispay Invest employees and market counterparties or clients that could compromise impartiality.
The list above is not exhaustive. It just provides a summary of the some prevalent conflicts of interest that may arise, in accordance with Satispay Invest business operations.
Satispay Invest operates a defined hierarchy of controls to address conflicts of interest.
Prevention: Satispay Invest seeks first to design its operational model to avoid conflicts entirely.
Mitigation and Management: Where a conflict cannot be prevented, robust organisational and administrative arrangements are deployed to manage and monitor it.
Disclosure (Measure of Last Resort): Where organisational arrangements are insufficient to prevent, with reasonable confidence, the risk of damage to client interests, Satispay Invest will disclose the specific nature and source of the conflict to the client prior to undertaking business.
Satispay Invest implements a number of mechanisms to ensure conflict of interest prevention:
Policies and Procedures implemented to support the conflict of interest identification and prevention.
Mandatory employee training upon joining and on a periodic basis thereafter to ensure potential conflicts are systematically recognized, recorded, and escalated.
Employee remuneration designed and reviewed to avoid incentives that may harm clients.
Rigorous governance frameworks and prior-approval protocols governing all fees, commissions, or non-monetary benefits paid to, or received from, third parties in connection with investment services.
Where potential conflicts exist, Satispay Invest actively manages and monitors them through:
Regular compliance reviews and the maintenance of a formal Conflicts of Interest Register.
Structured oversight and monitoring protocols governing third-party execution and service partners.
Regular monitoring of the accuracy and timeliness of order transmission.
Restrictions, where applicable, on certain types of employee activity such as their personal investment activity.
Internal policies governing gifts and entertainment, and outside of business interests.
Disclosure is an exceptional measure and is not used as an alternative to appropriate operational controls. If Satispay Invest’s internal arrangements are insufficient to prevent the risk of damage to a client’s interests with reasonable confidence, the firm will provide the client with a clear description - provided in a durable medium - of the general nature and source of the conflict, the associated risks, and the mitigating steps taken, prior to delivering the relevant service. Where the risk to the client cannot be mitigated to an acceptable standard, Satispay Invest will decline to act.
This Summary is published for informational purposes pursuant to regulatory disclosure obligations under MiFID II and applicable CSSF regulations.
