We have established policies and procedures designed to identify, disclose, manage and, where necessary, avoid material conflicts of interest in relation to our company, our clients and third parties. This includes actual, potential and perceived material conflicts of interest.
This Conflicts of Interest section explains in greater detail potential material conflicts of interest that may arise as a normal part of doing business with us, how they may affect your interests as our client, and, where possible, how we intend to address them in your best interest. We are required to avoid any material conflict of interest between you and us where the conflict cannot otherwise be addressed in your best interest. We will strive to keep you informed in a timely fashion should we identify any other material conflicts that would adversely affect your interests in the future.
Uphold does not operate a marketplace nor does it engage in market making. Uphold’s role is to buy or sell crypto assets for clients from various liquidity providers. Pursuant to certain intercompany arrangements with its affiliates, Uphold sources its liquidity for the Uphold Platform from multiple leading global crypto asset trading platforms and OTC counterparties. These platforms and counterparties are not affiliated with Uphold. Uphold adds a spread to the price offered to the client for any buy or sell trade on the Uphold Platform to compensate Uphold.
Uphold takes reasonable measures to provide fair and reasonable pricing to its clients. We may enter into transactions or arrangements with other entities within the Uphold group of companies. This could give rise to the perception that, when providing products or services to you, we will favour the business interests of these related entities. Uphold only enters into transactions and arrangements within Uphold group where they are permitted under applicable securities laws. Uphold puts in place services agreements to contractually bind the affiliated entities to pursue their obligations. When engaging an affiliated entity to perform a service, Uphold treats it like an arms-length third-party service provider.
Our employees may have access to confidential information regarding the trading activities of our clients. This may give rise to the perception that an employee may use the information of one client for the benefit of another client, or for themselves. Access to such confidential information regarding the trading activities of our clients is limited by us to employees on a need-to-know basis. Furthermore, access to such information by employees is tracked and monitored internally on an ongoing basis. We maintain policies and procedures which prohibit employees from making use of confidential client trading information for their own benefit or for the benefit of Uphold or another client of Uphold.
Our employees may engage in approved outside business activities, such as pursuing personal outside business interests, for which they may receive compensation. This may give rise to the perception that these activities influence an employee’s professional dealings with a client. We have established internal policies and procedures reasonably designed to ensure that employees disclose any outside business activities that reasonably would be expected to give rise to a conflict of interest. Potential conflicts of interest are identified and addressed via an established approval process. Outside business activities that give rise to a material conflict of interest are generally not approved.
Our employees may give or receive gifts or entertainment from clients, third parties or other employees. This may give rise to the perception that these inappropriately influence an employee’s professional dealings with a client. We have established policies and procedures reasonably designed to ensure gifts or entertainment received or given are limited, are in accordance with applicable law and regulation, and are conducted in the spirit of the business to foster and maintain the business relationship.
We select vendors for the purposes of outsourcing certain services. We may be perceived as favouring vendors that provide us with certain benefits or rebates. We have established policies that are reasonably designed to ensure Uphold controls costs while mitigating risks associated with vendors including performance and security related risks.
We may make information about you available to our related entities within the Uphold group. This may give rise to the perception that, when providing products to you, we will favour the business interests of these related entities. We have established policies that are reasonably designed to ensure Uphold complies with applicable privacy laws and regulations with respect to handling of client information, including our Privacy Policy. A copy of our Privacy Policy can be found here.
Uphold earns compensation when you buy and sell Crypto Assets on our platform. Generally, the more money you invest with us and the more products and services you use, the more compensation we earn. This may give rise to the perception that, when providing products to you, we will favour our own business interests. Uphold does not have any authority to act on a discretionary basis on behalf of clients. We endeavour to be fully transparent on fees and inform you of any increases in advance so that you know what you will be paying. Information about our fees can be found on the Uphold website and in your account opening documentation.
Uphold may buy, hold and sell Crypto Assets in its inventory for operational purposes, such as in order to facilitate deposits and withdrawals. Uphold will not take any long or short positions on Crypto Assets for speculative or investment purposes. Uphold does not operate a marketplace nor does it engage in proprietary trading or market making.
