of REGULAR FINANCE SAS, the company dedicated to the Regular account
version effective April 29, 2025
In accordance with MiFID II, Article L. 54-10-5 I 4° of the French Monetary and Financial Code, and Article 721-9 of the General Regulations of the French Financial Markets Authority, Regular Finance (hereinafter “Regular” or the “Company”) has established this policy on conflicts of interest (the “Policy”). This Policy is available for consultation by clients and prospects, as well as by other partners of Regular.
This document details how Regular minimizes and handles conflicts of interest. It provides details on the various means implemented to ensure the effective implementation of procedures for identifying, preventing, and managing conflicts of interest.
Purpose and scope of the Policy
The Policy defines the Company's procedures and clearly identifies circumstances that may give rise to conflicts of interest, where the Company cannot reasonably ensure that the risk of harm to the client's interests will be avoided.
The Policy identifies the types of potential conflicts of interest that may arise on the technological interface operated by Regular via the portal www.regular.eu The Policy describes the procedure for such identification and the measures taken by the Company.
The Policy is set out in writing and is appropriate to the size and organization of the Company, as well as the nature, scale, and complexity of our activities.
The Policy applies to the Company and its officers, employees, and any other person directly or indirectly controlled by the Company (the “Relevant Persons”).
As minimum criteria, the Company takes into account the following situations:
the Company and/or a Relevant Person has an interest in the outcome of a service provided to the client that conflicts with the client's interest;
the Company and/or the Relevant Persons have a financial or other incentive to favor the interests of a particular client or group of clients to the detriment of its other clients;
the Company and/or Relevant Persons receive, or will receive, from a person other than the client, an incentive in connection with a service provided to the client, in the form of money, goods, or services, other than the standard commission or fee for that service;
-
The Policy identifies the procedures and measures taken by the Company that are designed to ensure that Relevant Persons engaged in different business activities involving a conflict of interest (as specified above) carry out those activities at a level of independence appropriate to the size and activities of the Company.
The procedures in the Policy are designed to:
prevent and control the exchange of information between Relevant Persons engaged in activities involving a risk of conflict of interest where the exchange of such information may harm the interests of one or more clients;
separate the supervision of Relevant Persons whose primary functions involve performing activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including with those of the Company;
eliminate any direct link between the compensation of Relevant Persons primarily engaged in one activity and the compensation or income generated by other Relevant Persons primarily engaged in another activity, where a conflict of interest may arise in relation to these different activities;
take measures to prevent or limit the possibility of any person exerting inappropriate influence over the way in which a Relevant Person renders its services.
Identification of potential sources of conflicts of interest
Taking into account the services offered by the Company, potential sources of conflicts of interest may arise in the following cases:
as the Company's remuneration on its “Regular Account” product is based on the return generated by the sums invested by its clients, the Company may have an interest in promoting high-yield but high-risk products;
the Company may provide services to clients who may have interests in digital assets that conflict or compete with the interests of other clients of the Company;
commissions, remuneration, gifts, etc. granted or paid to the Company's employees by the Company on the basis of their performance may adversely affect the Client and encourage more or less aggressive marketing tactics;
Remuneration and/or incentives granted or paid to third parties (affiliates or business introducers) based on recommendations, referrals, and/or the integration of new clients, which may adversely affect the Client and encourage aggressive marketing tactics.
remuneration and/or incentives granted or paid to third parties who provide services under an outsourcing agreement, if such remuneration encourages practices that are contrary to the interests of the Company's clients.
It should be noted that the above scenarios do not necessarily give rise to a “conflict of interest” or any material damage to the client, but are disclosed in the interests of full transparency. The above scenarios should be considered in conjunction with the procedures and measures implemented by the Company to manage or limit their impact.
Management of conflicts of interest
The Company applies organizational and administrative procedures to manage and prevent any conflicts of interest that may arise and could constitute or lead to a risk of harm to its clients.
This section of the Policy describes the measures taken by the Company in general, as well as those taken in relation to the above list of identified potential conflicts of interest:
1. General measures
the Company has procedures in place for the employment of persons considered to be knowledgeable and competent, as well as for the training of such employees;
the Company implements procedures for monitoring third parties/outsourced service providers to ensure that they are competent to perform the services assigned to them;
The Company implements procedures governing access to electronic data so that individuals working in one department do not have direct (i.e., unauthorized) access to information relating to matters handled by other departments, unless such data is necessary for the performance of their duties.
The Company implements a separation of departments/functions providing services to clients whose interests may conflict with those of other clients or with the interests of the Company.
The Company ensures that no single employee can have responsibilities that pursue conflicting interests.
The Company respects the confidentiality of information it receives from and about its customers and applies a “need-to-know” approach. Access to confidential information is limited to those whose duties require access to it, in a proportionate and limited manner;
the Company may erect “Chinese walls” to physically separate key departments of the Company in order to restrict the flow of confidential information within the Company;
The Company may establish an internal compliance function whose responsibilities include monitoring and communicating KYC-LCBFT procedures and the Policy, as well as identifying potential conflicts of interest and making recommendations for their management/mitigation. The compliance function is also responsible for legal monitoring to ensure that the Company complies with applicable legislation.
The Company applies the “four-eyes” principle in the supervision of its activities, which consists of assigning the various verification steps to different individuals.
2. Measures relating to the Company's digital asset investment services
The Company makes available the return recorded on this product over the past two years and its risk on a three-level scale (low, medium, high).
When the return on the Regular account was variable (from September 4. 2023 to March 11. 2024) and fluctuated daily, the average return recorded was 7.83%/year.
From March 11. 2024 to April 2. 2025, the return was fixed at a rate of 7.20%/year.
From April 2. 2025 to March 9. 2026, the return has been fixed at 6.40%/year.
Since March 9. 2026, the return has been fixed at 5.50%/year.
The risk is measured as low, as the investment strategy is based solely on the use of collateralized stablecoins to build the digital assets in the portfolio. In addition, the portfolio is diversified, consisting of more than 10 different assets.
The Company does not grant preferential treatment to any of its clients or groups of clients and guarantees fair treatment to all its clients and their transactions. However, benefits may be granted to certain groups of clients solely on the basis of transparent and objective criteria (e.g., regular clients or those wishing to acquire large amounts of digital assets).
3. Measures relating to incentives, commissions, remuneration, gifts...
Employee remuneration policy: in accordance with the legislation in force, the Company does not base the variable remuneration of its employees on factors that could create a conflict of interest with the clients with whom they are in contact. For employees who receive variable compensation, this is therefore based on objective performance indicators within their departments.
In addition, employee employment contracts include clauses on loyalty, non-competition, and confidentiality.
Disclosure of conflicts of interest
When the Company is aware of a conflict of interest that may arise and when the organizational and administrative arrangements established by the Company to prevent or manage this conflict are not sufficient to ensure, with reasonable confidence, that the risks of harm to the client's interests will be avoided, the Company will disclose this risk to its clients.
When disclosure of such a conflict is not sufficient to manage the conflict, the Company may choose, at its sole discretion, not to proceed with the transaction or business relationship giving rise to the conflict.
The Company reserves the right to amend this Policy whenever it deems appropriate.