Conflict of Interest

2023-10-23

Selection of Destination Digital Asset Exchange for Digital Asset Brokerage Service

We, Gulf Binance Co., Ltd., have carefully considered and selected the digital asset exchange of BN KZ Technologies Ltd. as the sole destination exchange for our digital asset brokerage service. It is primarily because the digital asset exchange of BN KZ Technologies Ltd. can access to the Binance Global Liquidity Pool which we believe it can provide the Duty of Best Execution (with respect to volume, time, and price) to our customers. 

Who is BN KZ Technologies Ltd.?

BN KZ Technologies Ltd. was incorporated in Kazakhstan and has been granted with a license to operate the Digital Asset Trading Facility (license no. AFSA-G-LA-2022-0009) issued by The Astana Financial Services Authority (AFSA). BN KZ Technologies Ltd. is 100% owned by Binance (AP) Holdings Limited, and Binance (AP) Holdings Limited is 100% owned by Mr. Changpeng Zhao. 

Duty of Best Execution

BN KZ Technologies Ltd. has access to the Binance Global Liquidity Pool which we believe it can provide the duty of best execution to our customers in all volume, time, and price aspect as follows:

  1. Volume – With the most numbers of digital asset transactions in the world of the Binance Global Liquidity Pool, we are confident that there is a best chance for our customer’s buy or sell orders to be matched and executed at the most requested volume;

  2. Time – With the most numbers of digital asset transactions in the world of the Binance Global Liquidity Pool, we are confident that there is a best chance for our customer’s buy or sell orders to be matched and executed with the fastest matching time;

Price – With the most numbers of digital asset transactions in the world of the Binance Global Liquidity Pool, we are confident that there is a best chance for our customer’s buy or sell orders to be matched and executed at the price which is least varied from the true market price.

Conflict of Interest Management

Although we and BN KZ Technologies Ltd. are the affiliates of Binance group, however, we hereby represent that:

  1. We and BN KZ Technologies Ltd. do not have any relationship as a shareholder of each other;

  2. Our management team (i.e. Board of Directors and senior management) and the management team of BN KZ Technologies Ltd. are not the same, and they are working independently without any conflict.

Conclusion

We confirm that our ultimate goal is to provide the best services to our customers, and hence, we believe that the selected destination digital asset exchange can service that objective. Nevertheless, we shall establish the appropriate processes to monitor and audit the services provided by BN KZ Technologies Ltd. on regular basis, in order to ensure that such service will be provided in accordance with the agreed standard and expectation.

In addition, if in the future, we decide to engage with additional destination digital asset exchange, we will apply the same selection consideration and criteria to ensure the best services to our customers.