Satstreet Inc. Conflicts of Interest - Client Focused Reforms (CFRs)

Satstreet Inc.
Last Updated: Aug 1, 2025
(Note: This Policy Is Being Drafted for Internal Review)

‍Understanding Client-Focused Reforms and Conflicts of Interest Disclosures

Canadian securities regulators have introduced new rules to better protect investors like you. These rules are based on a simple principle: your interests must always come first. At Satstreet Inc. (“Satstreet”), we fully support this approach. We’ve put policies in place to identify and address situations where a conflict of interest could arise, and we’re committed to being transparent with you about them. These disclosures are meant to help you better understand how we work and the steps we take to always put your best interests first.

About Satstreet Inc. 

Satstreet Inc. is a digital asset trading firm offering over-the-counter (OTC) liquidity to high-net-worth individuals, family offices, and institutional clients. We provide access to a range of cryptoassets, combining deep market liquidity, secure custody solutions, personalized service, and a strong commitment to regulatory compliance. Discretion, privacy, and security are paramount in every aspect of our client relationships and operations. We are committed to disclosing any material relationships or potential conflicts of interest, so that you are fully informed when evaluating our services.

What is a conflict of interest?

A conflict of interest arises when there is a factor that could influence the decisions we make in managing your account. It could also affect the decisions you make about your account with us. Our goal is to recognize and deal with these situations so that your interests always come first.

How We Manage of Conflicts of Interest

We manage relevant conflicts of interest through the following approaches:

Avoidance:
We avoid conflicts that are prohibited by law or that cannot be effectively managed in a way that protects client interests.

Control:
We implement internal controls, including robust policies, procedures, and supervisory practices, to manage conflicts that are permissible but require oversight.

Disclosure:
Where appropriate, we provide clear and timely information about conflicts, enabling clients to make informed decisions about the services we offer and the potential impact of those conflicts.

At Satstreet, we have established policies and procedures to help identify and manage conflicts of interest. Where a conflict is determined to be too significant to address through controls or disclosure, it will be avoided entirely. If avoidance is not possible, we will manage the conflict through appropriate controls, including internal policies and oversight mechanisms. Where disclosure can assist in managing the conflict, we will provide you with clear information outlining the nature of the conflict and the steps we are taking to address it in your best interest. This disclosure is intended to help you better understand the nature of your relationship with Satstreet.

Specific Conflicts of Interest You Should Know About

Below, we outline the key conflicts of interest that currently exist or that we reasonably expect could arise in the future. We also share certain conflicts that we actively avoid, so you can better understand the steps we take to prioritize your best interests at all times.
                                                               
Conflicts Involving Proprietary Offerings         
Why It Matters 
It is an inherent conflict of interest for Satstreet to recommend or facilitate transactions involving digital assets or products that are developed or otherwise connected to Satstreet. If we ever offer or distribute proprietary products, such as Satstreet-branded digital assets or structured investment vehicles, there is a potential risk that our interests could be placed ahead of yours, particularly when those products are included in a recommendation or made available for direct purchase. Satstreet is committed to identifying, managing, and disclosing such conflicts to ensure that your best interests remain our priority at all times.
Our Approach
Control/Disclosure 
Steps Taken
Satstreet does not currently offer any proprietary digital assets. If we do so in the future, we will ensure that any recommendations are made with your best interests in mind, and that all risks, fees, and potential conflicts are clearly disclosed. We will also assess the suitability of any proprietary product before it is offered and compare it to similar third-party alternatives to ensure fairness and transparency.

                                                                     
Potential Conflicts in Oversight Roles
Why It Matters 
If the compensation of Satstreet’s compliance or supervisory staff were tied to sales performance or firm-wide revenue generation, or if their compensation were not independent from the activities they oversee, this could create a conflict of interest. Such a structure might impair their ability to provide objective oversight and could risk placing personal or firm interests ahead of those of our clients.
Our Approach  
Avoid
Steps Taken
Satstreet avoids this conflict by prohibiting compensation structures that are directly tied to revenue generation. No employee, including compliance or supervisory staff, is compensated based on individual sales or client assets under administration. While discretionary bonuses may be awarded, they are based on the overall performance of the firm and are not linked solely to trading volume, investment performance, or revenue from client accounts.

                                                                     
Clients may be subject to varying fee schedules, which can result in differences in profitability to the firm.
Why It Matters 
Charging a client more than others for the same or substantially similar products or services may raise concerns about fairness and could constitute a breach of the registrant’s obligation to treat clients fairly, honestly, and in good faith.
Our Approach  
Control/Disclosure
Steps Taken
Satstreet manages this conflict through a transparent model based solely on transaction spreads. We do not charge account fees, management fees, or service fees. Clients are subject to the same standardized spread structures based on transaction sizes and or account trade volume, which is applied consistently across transactions. In limited cases, spread adjustments may be made due to legacy arrangements, client volume, or institutional relationships, but these are governed by internal policy and disclosed as part of Satstreet’s Conflicts of Interest Disclosure.

                                                                 
Equal Opportunity in Digital Asset Execution
Why It Matters 
Conflicts may arise when multiple client accounts compete for the same trading opportunities, particularly during periods of limited liquidity. In such situations, it can be challenging for a registrant to allocate trades in a way that serves the best interests of all clients equally and simultaneously.
Our Approach  
Control/Disclosure
Steps Taken
Satstreet does not offer pooled investment vehicles or proprietary funds, and clients do not compete for limited investment allocations. Our services are provided on a transaction-by-transaction basis, primarily through over-the-counter (OTC) execution of digital asset trades. In rare situations where multiple clients may seek to execute trades at the same time and available liquidity is limited, Satstreet follows a fair and transparent first-come-first-served process. Orders are executed based on timing, client instructions, and available pricing from third-party liquidity providers. Satstreet does not prioritize any client or internal account over another and does not offer exclusive access to digital asset opportunities. Our internal policies ensure that all clients are treated equitably and that execution practices comply with our regulatory obligation to act in the best interest of each client.

                                                                 
Managing or Directing a Client’s Financial Affairs
Why It Matters 
Having full control or authority over a client’s financial affairs may create a significant conflict of interest, particularly if it compromises the client’s ability to make independent financial decisions.
Our Approach  
Avoid
Steps Taken
Satstreet avoids this conflict by ensuring that no employee or representative has full control or authority over a client’s financial affairs. Satstreet does not permit such arrangements under any circumstance.

                                                                       
Registered Individuals with Outside Activities
Why It Matters 
An outside activity may impair the employee’s ability to fulfill their responsibilities at Satstreet, create confusion about whom the individual is representing, or place the employee in a position of influence that conflicts with their duties to clients.
Our Approach  
Avoid/Control/Disclose
Steps Taken
Employees who engage in activities outside of their role at Satstreet must receive prior written approval to ensure there are no conflicts with their responsibilities to clients.

                                                                         
Cross-Trades
Why It Matters 
In the context of over-the-counter (OTC) digital asset trading, a cross-trade occurs when Satstreet facilitates a transaction directly between two clients, rather than sourcing liquidity from an external counterparty. While cross-trades may offer pricing or execution benefits, they can give rise to conflicts of interest, particularly regarding fair pricing, order priority, and client confidentiality.
Our Approach  
Control
Steps Taken
Satstreet manages this conflict by prohibiting cross-trades between clients. Satstreet does not act as a market maker or take market risk on trades, and personnel are never in a position to act on both sides of a trade. All OTC trades are executed on a client-by-client basis, with clear segregation of interests and strict adherence to fair execution standards.

                                                                       
Using inside information for personal gain
Why It Matters 
Individuals may encounter situations where their personal interests conflict with those of a client. The use of confidential information obtained through the course of one’s duties at Satstreet for personal gain constitutes an inherent conflict of interest and is strictly prohibited under applicable securities laws and firm policy.
Our Approach  
Control
Steps Taken
Satstreet manages this conflict through strict internal policies and procedures governing the handling of confidential and potentially material non-public information. Employees are prohibited from using such information for personal gain or disclosing it to unauthorized parties.

                                                                       
Other offerings that may include insurance or financial planning support
Why It Matters 
Offering related services to clients may create a potential conflict of interest if clients feel pressured or obligated to use those services due to their existing relationship with Satstreet. This could impair their ability to make independent decisions that are in their best interest.
Our Approach  
Avoid
Steps Taken
Satstreet avoids this conflict by not offering related services such as financial planning, insurance, or other ancillary products. We focus solely on providing digital asset and OTC trading services, ensuring there is no overlap that could influence a client’s decision-making.
               
                                                         
The giving or receiving of gifts or entertainment by employees 
Why It Matters 
There may be instances where Satstreet employees give or receive gifts or business entertainment of more than nominal value in connection with the firm’s activities. In such cases, a perceived or potential conflict of interest may arise, particularly if the gesture could be seen as influencing business decisions or client referrals.
Our Approach  
Control
Steps Taken
Satstreet has policies in place that establish clear limits and guidelines around the giving and receiving of gifts. The value of any gift offered or accepted must not exceed $500 per year. Any gift above this threshold must be disclosed to and approved by the Chief Compliance Officer to ensure it does not create a real or perceived conflict of interest.

                                                       
Complaints
Why It Matters 
A potential conflict of interest may arise if a complaint is not properly addressed, particularly where doing so could negatively impact an individual employee or the firm. This could undermine the fair treatment of clients and the integrity of the firm’s complaint handling process.
Our Approach  
Control
Steps Taken
Satstreet manages this conflict through established policies and procedures that ensure all client complaints are handled promptly, fairly, and independently. These controls are designed to protect client interests and maintain objectivity throughout the complaint resolution process.