At Gap 3 Partners FZCO (“G3P”), we are committed to maintaining the highest standards ofethics, transparency, and professionalism in all our activities. As a licensed Virtual AssetAdvisory Service Provider regulated by the Dubai Virtual Assets Regulatory Authority(VARA), we recognize the importance of identifying and managing actual, potential, orperceived conflicts of interest to preserve the trust of our clients, stakeholders, and regulators.
What Is a Conflict of Interest?
A conflict of interest arises when an individual’s personal interests — such as financial interests,family connections, or other external relationships — may interfere with their ability to act in thebest interest of G3P or its clients. Conflicts can also occur at the firm level, where G3P’sbusiness interests may not align with client interests.
Conflicts may be:
- Actual (present and occurring);
- Potential (reasonably foreseeable); or
- Perceived (could appear to an external party as compromising).
All forms of conflicts are taken seriously and treated with equal importance.
Scope and Applicability
This policy applies to:
- All G3P employees, board members, consultants, contractors, and service providers;
- All activities conducted under the G3P brand, whether internal or client-facing;
- Any scenario where professional judgment or objectivity may be compromised.
How We Manage Conflicts of Interest
1. Identification and Disclosure
G3P requires that all employees and representatives promptly disclose any situation that couldgive rise to a conflict. Disclosures must be made to the Compliance Officer, who maintains aConflict Register and investigates reported concerns.
2. Prevention
To minimize the risk of conflicts:
- G3P implements internal controls, such as Chinese Walls and operational segregation;
- Clear rules govern gifts, hospitality, and external engagements;
- Employees are trained regularly on identifying and avoiding conflicts.
3. Mitigation and Resolution
If a conflict cannot be avoided, G3P adopts measures such as:
- Recusal of individuals from certain decisions or activities;
- Independent review of decisions where impartiality could be questioned;
- In rare cases, restructuring or terminating roles or engagements.
4. Client Transparency
When a conflict of interest may affect a client, G3P commits to full disclosure and, wherenecessary, obtaining the client’s consent before proceeding. This helps preserve trust and protectthe client’s interests.
5. Monitoring and Enforcement
G3P regularly reviews its operations and policies to detect emerging risks and ensurecompliance. Breaches of this policy may result in disciplinary action, including termination ofemployment or contracts.
Our Independence
As a virtual asset advisory service provider, Gap 3 Partners FZCO maintains full independence in the delivery of its services. We do not:
- Accept any undisclosed monetary or non-monetary benefits (such as tokens, allocations,or preferential treatment) from virtual asset projects or protocols in exchange for advisory support;
- Refer or introduce clients to virtual asset exchanges, custodians, or service providers inreturn for commissions or kickbacks;
- Operate or have financial interests in any affiliated broker-dealer, trading platform, orvirtual asset exchange that may create a conflict of interest with our advisory duties.
All strategic, regulatory, and technical advice provided by Gap 3 Partners FZCO is rooted inindependent, objective analysis and guided solely by what serves the best interests of our clients.
Referral Arrangements and Associated Benefits
Gap 3 Partners FZCO does not refer or introduce clients to other entities (including Virtual Asset Service Providers, custodians, or trading platforms) in return for monetary or non-monetary compensation, whether directly or indirectly. Should any such arrangement be entered into in the future, G3P commits to:
- Full disclosure of the existence and terms of such arrangements;
- Transparency regarding any fees, commissions, or non-cash benefits received;
- A documented assessment that such referrals do not impair the objectivity orindependence of our advice.
Third-Party Account Relationships
Gap 3 Partners FZCO does not hold or maintain client funds or virtual assets. If, in the course ofa particular engagement, third-party custodians or service providers are required to facilitate advisory or compliance processes, G3P will:
- Clearly disclose the identity of such third parties;
- Outline their role and responsibilities;
- Ensure that clients retain full visibility and control over their accounts and assets.
As of the date of this policy, G3P has no standing custodial, wallet, or exchange accounts maintained with third parties.
Monitoring, Review, and Enforcement
This policy is subject to ongoing monitoring and periodic review by G3P’s Compliance team.Violations of this policy may lead to disciplinary action, up to and including termination ofemployment or business relationship. We encourage internal and external stakeholders to reportany suspected conflicts via our secure compliance channel.
Contact
If you have any concerns regarding conflicts of interest or require further clarification, pleasecontact our Compliance Officer at:
compliance@g3p.io