Cure Holdings Limited Conflict of Interest Management Policy


This policy applies to all management, prospective or current employees of Cure Holdings Limited (CURE), as well as contractors and persons acting on behalf of the company and sets out CURE arrangements in connection with the identification, documentation, escalation and management of conflicts of interest. A “Conflict of Interest” is a situation where one or more persons have competing interests and the serving of one interest may involve detriment to another; any professional situation in which the discretionary powers of a person or enterprise may be influenced or altered by personal considerations or the influence or pressure exerted by a third party.

This policy seeks to ensure that a Conflict of Interest does not adversely affect the interests of COT Holders, CURE, its shareholders or other stakeholders through the identification, prevention or management of the Conflict of Interest.


Where a person has a material interest in a transaction with or for a client or a relationship which gives rise to an actual or potential conflict of interest in relation to the transaction, it should neither advise, nor deal in relation to the transaction unless it has disclosed that material interest or conflict to the client and has taken all reasonable steps to ensure fair treatment of the client.


All Employees and others acting on behalf of CURE are responsible for identifying and managing Conflicts of Interest on an ongoing basis and are required to:

  • Comply with this policy relating to the identification, documentation, escalation and management of Conflicts of Interest;
  • Act with integrity and the requisite degree of independence and objectivity
  • Avoid, where possible, situations giving rise to Conflicts of Interest due to possible personal financial interest, dealing with family members or close relationships, previous, current or potential future involvement in an activity or endeavour;
  • Immediately notify their supervisor of the existence and general nature of a Conflict of Interest;
  • Immediately disclose Conflicts of Interest to the chairperson when participating in decision making and, if the chairperson so determines, remove themselves from the decision making process and not seek to influence such decisions;
  • Avoid supervisory or control relationship with closely related persons;
  • Not misuse sensitive information that could lead to a Conflict of Interest;
  • •Manage sensitive information on “Need to Know” basis;
  • Challenge and escalate promptly issues of concern to their supervisors so that Conflicts of Interest may be appropriately reviewed, managed and resolved;
  • Comply with applicable rules which require transactions and arrangements between CURE and a related party to be carried out on an independent, arms-length basis. Special duties for members of senior management (staff who are responsible for, or have significant influence over, the direction and day-to-day management) :
  • sponsor and encourage an appropriate culture and the fair handling of Conflicts of Interest;
  • Be engaged in the implementation of policies, procedures and arrangements for the identification, documentation, escalation, management and monitoring of Conflicts of Interest;
  • Raise awareness and promote adherence of staff;
  • Sponsor systems and controls to document, track, manage and mitigate Conflicts of Interest risk
  • Regulate incentives or performance measures that can give rise to Conflict of Interest.


Segregation of duties

CURE implements a framework that requires the independence of control functions, including compliance, risk, and audit.

Conflict of interest record

CURE maintains a register that records the types of Conflicts of Interest that have arisen in the course of its operations and the resolution applied to such conflicts.


CURE has enough staff dedicated to compliance role to maintain an efficient and effective management and resolution of conflict of interests.


Data walls

CURE maintains information barriers that are designed to restrict data flows betweendifferent areas of the company. These restrictions enable CURE and its employees to carry out duties without being influenced by other information which may give rise to a Conflict of Interest. Where a staff member is required by any other policy or procedure to share information with other staff, data is shared in accordance with “need to know” policy or procedure provided that such sharing of information does not breach this Conflicts of Interest Policy.


CURE operates internal escalation processes for Conflicts of Interest. The escalation processes are required to enable the Conflict of Interest to be escalated on a timely basis and considered at an appropriate level of seniority and by the correct stakeholders to arrive at the most appropriate resolution.


CURE provides appropriate channels for the safe reporting of Conflicts of Interest within the company where a staff member considers this to be the appropriate channel to draw the matter to the attention of the company.


In certain circumstances, CURE may determine that its arrangements to prevent ormanage Conflicts of Interest may not be sufficient to protect a user or holder of Cosplay Tokens (COT) interest from material damage and the user or holder of COT must be made aware of this. Alternatively, CURE may decide in particular circumstances that a user or holder of COT should be made aware of the potential for a Conflict of Interest and the arrangements that will be put place to manage the conflict. Where appropriate, disclosure to an affected user or holder of COT may be made to inform the user or holder of COT of the arrangements and/or to specifically seek its consent to act.


Analysis independence

A conflict of interest may arise where the content of reports or other public statements by a staff at CURE on users of the platform or their personal tokens do not represent the analyst’s genuinely held beliefs.


A conflict of interest may arise where CURE has received an inducement from a third party that might conflict with the interests of COT holders. Any inducement must be assessed for appropriateness and managed in context of any conflict of interest that may arise.

Purchase of COT

A Conflict of Interest may arise if a staff member receives, transmits, executes or otherwise handles a sale of COT. CURE has an automated system to protect buyer/seller from such conflict of interest furthermore it requires staff to act honestly, fairly and professionally in accordance with the best interests of a customer prohibiting improper conduct such as front-running client orders.

Outside business interests

A conflict of interest may arise where staff members have business interests that may conflict with CURE or the COT holders. CURE imposes disclosure and approval requirements, enabling the identification, management and, if necessary, prohibition of outside business interests that may give rise to a conflict of interest.

Employee trading

A conflict of interest may arise where staff members have trading interests that may conflict with CURE or some COT holders. Particularly in conflicting tokens whether inside of outside the CURE platform.CURE requires disclosure and approval for personal trading accounts and pre-clearance for specific trading activity.

Remuneration of staff

A conflict of interest may arise where CURE remuneration practice could incentivise a staff member to act contrary to their responsibilities or the best interests of COT holders. Remuneration is assessed by CURE for appropriateness and managed in context of any conflict of interest that may arise.


A conflict of interest may arise where a staff member receives or offers a gift or entertainment to or from third party representative, clients or vendors that constitutes an inappropriate incentive for a staff member to act in a certain way. CURE does not permit the offering or acceptance of gifts or entertainment by a Staff Member unless it is reasonable, proportionate and for a legitimate business purpose.


Client related conflicts

Conflicts of Interest relating to clients can be described as scenarios where the CURE staff member is likely to make an inappropriate financial gain or avoid financial loss at the expense of a client or has an interest in the outcome of a service or transaction provided to a client.

Conflicts of Interest relating to clients can also arise when staff has a financial or other incentive to favour the interest of a client over the interests of another client or receives an inducement in relation to a service provided to the client other than a standard commission or fee for that service

CURE related conflicts

Those conflicts relate to situations where staff member’s interest in the outcome of a particular activity or endeavour differs from the CURE’s interest or a staff member has the opportunity to influence CURE’s granting business or making administrative and other material decisions in a manner that leads to personal gain or advantage for the staff member or a family member or close relationship

Conflicts of Interest can also arise in respect to existing financial or other interest or previous engagement in an endeavour or activity or relationship with another person, impairs or could impair their judgment or objectivity in carrying out their duties and responsibilities wards CURE.