# ETP Foundry: conflicts of interest policy **Draft v0.3, pending counsel review, 19 October 2026.** Under Methodology v1.1, which governs wherever this policy differs. This policy covers the conflicts of ETP Foundry itself and its staff. Seat holders' conflicts are covered by the Committee terms (v1.4, §5). > **In short.** ETP Foundry calculates and proposes each fund's NAV; the fund's own parties sign it. We never sign, the ledger refuses us as a committee member, and no seat we run counts. We do not trade the funds' assets. We have conflicts we cannot remove: a fee in basis points rises with the fund value we calculate, we run creation and redemption, and today we operate every seat on DevNet. They are disclosed, and the controls below limit them. > **What changed from v0.2.** v0.2 (28 September 2026) was written for the retired price-fixing product, where ETP Foundry was the "benchmark administrator" of an official token price and the fee was linked to funds referencing that price. v0.3 restates it for the fund model: we calculate a fund's NAV from existing price providers and the fund's parties sign. The staff dealing window now runs around a fund's valuation point instead of a strike. The test holdings disclosure is unchanged (as at 28 September 2026). ## 1. We calculate; we never sign - ETP Foundry's engine calculates and proposes every NAV and fund action and publishes the record. **It is never a committee member.** The ledger refuses a committee that lists it. - A seat ETP Foundry runs or hosts may sign on the record for testing, but **never counts** toward K. The ledger enforces this. - There is no independent oversight function yet (Methodology v1.1 §9.1). Until there is, ETP Foundry performs the reviews, publishes them and says so. ## 2. Seats we operate Today every seat on the DevNet test funds is operated by ETP Foundry for testing, or open. **These are test seats.** Nothing they sign is presented as signed by an outside party. - A register of seats we operate (party, fund, role, key level, dates created and retired) is kept and shown to committee members and sponsors. - Every act ETP Foundry performs as another party is logged and disclosed. - Our seats are retired as outside parties take their seats. ## 3. We do not trade what we value - ETP Foundry does not trade, make markets in, or take positions for profit in any asset held by a fund it runs, or in any fund's shares. - **Disclosure (as at 28 September 2026):** ETP Foundry holds 1.0 BitSafe cBTC and about 1,017 Canton Coin on Canton **DevNet** (no money value), used only to test creation and redemption. The founder holds an exchange account used for treasury. Any position in an asset a fund holds is entered in the register (§5). ## 4. Staff personal dealing Anyone working for ETP Foundry: - may not trade an asset a fund holds, or a fund's shares, from 24 hours before to 1 hour after that fund's valuation point; - must pre-clear any such trade with the conflicts officer (today the founder; a second reviewer will be named when there is a second person); - must never use unsigned proposals, seat submissions or sponsor information for trading; - declares their holdings on joining, and every year after. ## 5. Register and review - The **conflicts register** records every declared interest of ETP Foundry and its staff: holdings, commercial relationships with seat holders or sponsors, and seats we operate. - It is reviewed at every quarterly committee meeting, and the review is minuted. - Each person re-declares every year, and within five business days of any change. ## 6. Commercial relationships Only the fund sponsor pays ETP Foundry. Seats are never paid and never charged. A firm may hold a seat on one fund and sponsor another; the two are papered separately so that neither is leverage over the other. ## 7. Conflicts we cannot remove, disclosed - **Fee linked to fund value.** If a fund pays a fee in basis points of its assets, our fee rises with the NAV, which we calculate. Controls: we never sign; the ledger refuses us as a member; the administrator recomputes the NAV from its own reads within its declared tolerance; each price comes from a provider named in the fund's terms, with its source and time on the record; we do not trade the fund's assets. - **We run creation and redemption.** Each is one atomic transaction against a signed NAV, recorded on the ledger. - **We operate every seat on DevNet today.** Disclosed on every value, which is labelled indicative. These conflicts are mitigated, not removed. ETP Foundry does not accept payment contingent on a NAV's level. A knowingly false or manipulated input is reportable under the Committee terms. --- Lucilla, Inc., federal corporation no. 16699448, Toronto, trading as ETP Foundry. Contact: hello@etpfoundry.com.