1. Purpose and Legal Status

This Conflicts of Interest Policy (the "Policy") sets out the principles and measures adopted across the Polar Tensor™ group to identify, prevent, manage, and disclose conflicts of interest that may arise in connection with the services provided.

This Policy is published as a public summary for transparency purposes and must be read together with the applicable customer agreements, risk disclosures, and entity-specific policies.

Where required by law, more detailed internal conflicts policies apply and are maintained within the group.

2. Scope of Application

This Policy applies to all group entities, including but not limited to:

• Polar Tensor™ Corporation (holding and governance)
• Polar Tensor™ Corp. (technology and execution)
• Polar Tensor™ US LLC (U.S. and non-EU clients)
• Polar Tensor™ Europe SP ZOO (EU clients)
• Polar MSB Inc. (payments and fiat services)
• Polar Tensor™ LAB Limited (research and development)

3. Identification of Potential Conflicts

Conflicts of interest may arise, without limitation, where:

• different group entities perform separate but complementary roles (custody, execution technology, payments, R&D);
• technology providers and custodial entities operate within the same corporate group;
• fees are charged for technology access and performance-linked software use; or
• independent marketers or introducers are remunerated for referral activity.

The group acknowledges that such structural relationships may give rise to potential conflicts if not appropriately managed.

4. Structural Mitigation Measures

The group has implemented the following structural safeguards:

4.1 Functional Separation

• Custody, execution technology, payments, and R&D are performed by separate legal entities.
• No single entity combines custody of client assets with discretionary trading or advisory functions.

4.2 Licensing Alignment

• Regulated activities are conducted exclusively by entities holding the relevant registrations or licences in their respective jurisdictions.
• Non-regulated entities do not perform regulated services.

4.3 Asset Control & Safeguarding

• Legal custody and withdrawal authority remain solely with licensed custodial entities.
• Execution-layer entities do not control client withdrawals or client onboarding.

5. Fee-Related Conflicts

Fees charged to clients may include technology access fees and performance-linked software fees.

To mitigate related conflicts:

• fees are clearly disclosed in advance;
• performance-linked fees apply only to realised results, as contractually defined;
• no guarantees of performance are provided; and
• fee structures do not grant discretionary authority over client assets.

6. Technology & Execution Considerations

Automated execution technology operates on a predefined, non-customisable basis.

As a result:

• execution decisions are system-driven, not influenced by individual client profiles;
• no preferential treatment is given to specific clients; and
• no cross-client profit or loss sharing occurs.

This limits conflicts arising from execution prioritisation or discretionary decision-making.

7. Independent Marketers and Introducers

Where independent marketers or introducers are used:

• they do not receive, hold, or control client assets;
• they do not provide investment advice or recommendations;
• they do not onboard clients or perform compliance checks; and
• their role is limited to general marketing and client referral.

Their remuneration structure does not grant influence over execution, custody, or client decision-making.

8. Governance and Oversight

The group maintains internal governance measures designed to identify and address conflicts, including:

• internal reporting and escalation procedures;
• separation of duties between entities and functions;
• compliance oversight appropriate to each jurisdiction; and
• periodic review of business practices and fee structures.

9. Disclosure to Clients

Where a conflict of interest cannot be fully prevented, it is disclosed to clients in a clear and transparent manner through:

• customer agreements;
• fee disclosures;
• risk disclosures; or
• this Policy.

Clients are encouraged to review all disclosures carefully before using the services.

10. No Client Detriment Principle

The group is committed to ensuring that conflicts of interest are managed so as to avoid detriment to clients.

No conflict is permitted to materially impair the fair treatment of clients or the integrity of the services provided.

11. Amendments

This Policy may be updated from time to time to reflect changes in law, regulation, or business operations.

The most current version will be made available on the relevant websites.