Conflict of Interest Policy

Published on Mar 29, 202520 min read

Last Update: 27 June 2025

1.PURPOSE AND SCOPE

OKX TR was registered with the Istanbul Trade Registry Office under trade registry number 457610-5 and the Company headquarters is located at Maslak Mah., AOS 55. Sok. 42 Maslak B Blok Sitesi No: 4 Interior Door No: 542, Sarıyer/ Istanbul. The Company operates under the brand name "OKX TR".

OKX TR is obliged to establish, implement and maintain effective policies and procedures to appropriately identify, prevent, manage and disclose conflicts of interest, taking into account its organizational structure, the number of customers, the number and variety of listed crypto assets, and the nature, scope, scale and diversity of the crypto asset services and activities it offers.

This Conflict of Interest Policy ("Policy") has been prepared in accordance with the relevant capital markets legislation, in particular the Communiqué on the Establishment and Operating Principles of Crypto Asset Service Providers numbered III-35/B.1 ("Communiqué on Operating Principles") and the Communiqué on Operating Procedures and Principles and Capital Adequacy of Crypto Asset Service Providers numbered III-35/B.2 ("Working Principles Communiqué ") and sets out the effective organizational and administrative arrangements that OKX TR has in place to identify, prevent, manage in an ethical and transparent manner and disclose conflicts of interest and address situations that pose an actual or potential risk of significant harm to the interests of OKX TR and/or its clients ("Clients").

This Policy covers all individuals associated with OKX TR who may potentially create a conflict of interest, including OKX TR’s employees, members of the Board of Directors, executives, suppliers, and Clients.

Various articles of the Communiqué on Operating Principles and the Communiqué on Operating Procedures will enter into force at a later date and therefore, the relevant obligations in this Policy shall become applicable as of the date the relevant legislation provisions enter into force. 


The Policy has been reviewed and approved by OKX TR Board of Directors ("Board") and has entered into force pursuant to a resolution of the Board. The Policy will be reviewed and renewed periodically in order to comply with changing regulations or in cases deemed necessary. Amendments to this Policy shall enter into force upon a resolution of the Board and shall be communicated to OKX TR’s employees, and also shared with Clients through the relevant section of OKX TR’s website.


An individual designated by the Board to conduct assessments regarding conflicts of interest within OKX TR (“Officer”) is responsible for implementing this Policy and monitoring its compliance with the relevant legal and regulatory framework. Such a framework includes, in particular, the following:

  • Capital Markets Law No. 6362,

  • Communiqué on Operating Principles,

  • Communiqué on Operating Procedures,

  • and other applicable laws, regulations, rules and guidelines relating to OKX TR

(collectively referred to as "Applicable Law").

In accordance with Applicable Law, as required, OKX TR is obliged to disclose in a prominent place on its website the general nature and sources of conflicts of interest, as well as the measures taken to mitigate them. Such disclosures must contain sufficient detail for Clients to understand in what context a conflict of interest may arise and to make an informed decision accordingly. For this purpose, this Policy has been made accessible to Clients through the relevant section of OKX TR’s website.

The principles set forth and stipulated in this Policy shall not be interpreted in a manner that would result in any act or transaction being carried out in violation of Applicable Law.

This Policy guarantees fair, honest and transparent management of conflicts of interest of OKX TR's Clients, employees and company integrity with due regard to the interests of the Clients and the integrity of the crypto asset markets.

1.IDENTIFICATION OF CONFLICTS

a.General Principles


Conflicts of interest may arise, among other situations, between the following parties:


OKX TR’s Clients and:

  • OKX TR,

  • OKX TR’s shareholders,

  • the member companies of the corporate group to which OKX TR belongs,

  • any domestic or foreign person directly or indirectly connected to OKX TR (or its shareholders, employees or executives) through control or any other form of relationship,

  • OKX TR’s members of the Board of Directors,

  • OKX TR’s other executives, including the General Manager and Deputy General Managers (if any),

  • OKX TR’s employees, 

or between OKX TR and the persons listed above, or two or more Clients with conflicting interests.

For the purposes of this Policy, the following definitions shall apply:

  • "connected person" means any of the persons listed above who may have a conflict of interest with OKX TR or OKX TR’s Clients;

  • "remuneration" means any payment, or other financial or non-financial benefit provided directly or indirectly by OKX TR to its Clients for the provision of crypto asset services;

  • "group" means a group of companies within the scope of Article 195 of the Turkish Commercial Code No. 6102.

OKX TR may maintain certain records regarding conflicts of interest that arise, their consequences, and how the risks associated with such conflicts are mitigated from time to time. Such records are maintained for the purpose of assessing potential conflicts of interest and developing proposed solutions in this regard. If the Officer designated to review conflicts of interest identifies any actual or potential conflict of interest, he or she must immediately report the matter to the Board of Directors and act expeditiously to address the conflict of interest and/or remedy the violation of this Policy.

b.Conflicts of Interest with the Potential to Harm Customers

In order to identify conflicts of interest that may arise when providing crypto asset services and that may be against he interests of one or more Clients, OKX TR will at a minimum assess whether OKX TR or any connected person is in one of the following situations:

  • It is probable that OKX TR or any connected person will realize a financial gain or be relieved from a financial loss to the detriment of the Client;

  • OKX TR or any connected person obtains a benefit from the outcome of a crypto asset service, or any activity provided to a Client even if the Client does not derive any benefit in relation to these matters;

  • These persons have a financial or other interest to promote the interests of one or more Clients to the detriment of the interests of another Client or Clients;

  • These persons receive or will receive monetary benefits other than standard fees and commissions from a person, an institution or an application other than the Client in connection with a service or activity provided to a Client;

  • In the event that the use of a distributed ledger network belonging to relevant connected persons or their affiliates is made mandatory in relation to the crypto assets to be listed, and as a result, these connected persons are to derive any financial gain.

c.Conflicts of Interest with the Potential to Harm OKX TR

In order to identify situations that may create a conflict of interest in relation to the performance of a connected person's duties and responsibilities, OKX TR takes into account at least the following situations and/or relationships:

  • These connected persons have an economic interest in a person, institution or organization that has interests that conflict with the interests of OKX TR;

  • These persons, at least in the last three (3) years, have had a personal, professional and/or political relationship with a person, institution or organization that has conflicting interests with the interests of OKX TR;

  • These persons carry out conflicting tasks or activities, have conflicting responsibilities, or are under the hierarchical control of a person responsible for conflicting functions or tasks.

For the above purposes, the following are considered "economic benefits":

  • Ownership of shares, crypto assets (including management tokens), other property rights or membership interests in the person, institution or organization in question;

  • The person, entity or organization holds debt instruments or has another debt arrangement with that person, entity or organization;

  • Has any contractual relationship with the person, institution or organization in question, such as management contracts, service contracts, transfer or outsourcing agreements, or intellectual property licenses.

When identifying persons, institutions or organizations whose interests conflict with OKX TR, OKX TR also takes into account whether they are in one of the following situations, for example:

  • If it is likely to realize a financial gain or avoid a financial loss to the detriment of OKX TR;

  • has an interest in the outcome of a crypto asset service, activity or a decision taken by OKX TR that is different from OKX TR's own interest;

  • is engaged in the same business as OKX TR or is a client, consultant, attorney, agent, representative, outsourcer, service provider or other supplier (including subcontractors) of OKX TR and as a result of that, is likely to have a conflict of interest with OKX TR as reasonably inferred from objective circumstances.

d.Conflicts of Interest Arising from Other Organizations within the Group

OKX TR also takes into account the possibility of any conflict of interest that may arise due to the structure and business activities of other entities within the group. In this regard, in particular, measures are taken to prevent abuse of concentrated control, and ensure management of related party transactions (including subsidiaries) and transparency of these transactions.

2.PREVENTION AND MANAGEMENT OF CONFLICTS OF INTEREST

Given OKX TR's business activities, some decisions may be made in order to maximize OKX TR's profits. Separate oversight of persons acting on behalf of Clients or providing services to Clients whose interests may conflict with OKX TR's interests is critical to ensure that OKX TR acts in accordance with Applicable Law.

OKX TR has robust governance arrangements and effective oversight by senior management. Key decisions are made by the Board and OKX TR’s department heads who understand OKX TR's obligations under the Applicable Law to identify, prevent, manage and disclose conflicts of interest.

Officer is tasked with identifying conflicts of interest and reports them directly to the Board of Directors. The Officer adopts a holistic approach to identify potential conflicts that may arise or develop in the different business lines of OKX TR and ensures that necessary actions in this regard are taken. The Board of Directors must provide all the information necessary for the Officer to identify conflicts of interest. As a senior officer of OKX TR, the Officer has the necessary authority to carry out his/her responsibilities independently and appropriately and has the right to report directly to the Board of Directors.

The Officer shall carry out the necessary reporting and documentation regarding all actual or potential conflicts of interest identified, and shall transparently monitor such conflicts of interest as required. In cases where the effective management and prevention of potential damage risks arising from conflicts of interest cannot be ensured, the ultimate responsibility for making the necessary decisions lies with the Board of Directors.

Procedures and measures in place to prevent or manage conflicts of interest include at a minimum:

a.Reporting Lines

OKX TR has clear and specific reporting lines. An organizational chart is maintained by OKX TR and updated as necessary in accordance with OKX TR's operational structure taking into account potential conflicts of interest.

b.Separate Audit

OKX TR prevents or controls any person or department from influencing the way another person or department performs its duties. Clearly segregated functions with separate reporting lines have been established in this regard to ensure that there is no undue influence on any person or department. If a person (especially employees) believes that there is an inappropriate influence, they should inform the Officer without delay. The Officer may consult with the Board of Directors as appropriate. To prevent potential conflicts of interest within this scope, the Officer may take necessary organizational measures, such as the reassignment of relevant employees' duties, and may implement additional measures to ensure the effective supervision of employees.

c.Determination of Employee Remuneration

The remuneration of all employees serving in OKX TR’s departments and units is determined in consideration of OKX TR’s corporate principles, ethical values, strategic objectives, and structural balances. 

In order to prevent potential or actual conflicts of interest between employees, or between employees and OKX TR, and to mitigate any negative consequences thereof, necessary procedures and policies may be established, implemented, and enforced in accordance with Applicable Law regarding the principles and methods for determining remuneration and other payments provided to employees in return for their services. Any measures deemed necessary in this context may be taken by senior management upon the recommendation of the Officer.

d.Supervision of Employees

In the event that any relevant unit or department of OKX TR is subject to a conflict of interest, the necessary supervisory mechanisms are determined and implemented by OKX TR’s senior management to ensure that employees within such a unit or department comply with the orders and instructions given for the resolution and management of the said conflict.

e.Decomposition of Functions

OKX TR has appropriately segregated duties and functions to be independent from each other. All functions operate under the separate and direct supervision of the Board of Directors. In this way, conflicts of interest are tried to be prevented. Furthermore, in the execution of processes such as the appointment and promotion of employees, OKX TR’s senior management exercises the necessary care and diligence to prevent the emergence of potential conflicts of interest.

f.Board of Directors

The members of the Board of Directors are tasked with making objective and impartial decisions in the best interests of the Clients and, depending on the circumstances, OKX TR. Board members may not serve as a board member of another crypto asset service provider outside the group that competes with OKX TR. Furthermore, a Board member is obliged to inform the other Board members and abstain from voting on any matter in which he or she (or a person related to him or her) has or may have a conflict of interest or in which his or her objectivity or ability to properly perform his or her duties to OKX TR may be compromised.

g.Risk Management

The risk management function operates independently from all other business units of OKX TR.

h.Harmony Function

The Officer reports directly to the OKX TR Board of Directors on the performance of his/her duties. 

i.Restricting the Flow of Information

OKX TR takes necessary measures to prevent or control the sharing of information between persons (including group companies) engaged in activities that may harm the interests of one or more Clients. 

j.Access to Knowledge

Important information is only accessible to those who need it to fulfill their duties and responsibilities. OKX TR has procedures in place to ensure that access to material information is restricted to the specific categories of personnel who need it.

k.Pricing

To mitigate and manage conflicts of interest that may arise, OKX TR has adopted the following remuneration principles:

  • Remuneration is determined and paid in accordance with Applicable Law.

  • Remuneration (including incentives) is not based solely or predominantly on quantitative commercial criteria, but also takes into account qualitative criteria such as compliance with Applicable Law, fair treatment of Clients and quality of service provided to Clients.

  • There is always a balance between fixed and variable wage components.

  • Variable remuneration is based on the realization of objectives linked to the respective functions.

  • Any person who may have an interest in the determination of remuneration shall refrain from participating in discussions and decision-making processes.

l.Best Practice Exemplification

OKX TR's Order Fulfillment Policy sets out the adequate steps OKX TR takes to achieve the best possible result for its Clients, taking into account price, cost, speed, likelihood of execution and settlement, size, nature or other relevant considerations for the execution of the order. In this context, the Order Execution Policy regulates the circumstances under which OKX TR may enter orders into its own trading environment, in a manner that does not create a conflict of interest between OKX TR and its Clients, and with due consideration of the potential interests of the Clients.

m.Awareness of this Policy and Appropriate Internal Reporting Channels within OKX TR

The Officer ensures that relevant individuals are aware of their responsibilities under this Policy and Applicable Law. In particular, directors, employees, senior managers and officers of OKX TR are required to report any potential conflict of interest related to a proposed activity or transaction to their immediate supervisor or to the individuals responsible for supervising them. Clear disclosure of policies, procedures and expectations will be made so that in the event of a potential conflict of interest, necessary disclosures are made, and the conflict is appropriately addressed.

n.Explanation for Customers

Where it is not possible to effectively manage the potential risk with reasonable assurance, OKX TR shall disclose the conflict of interest in accordance with Section 5 of this Policy. The Officer is responsible for ensuring that such disclosures are fair, clear and not misleading.

o.External Business Activities and Managerial Duties

If any relevant person has other business activities that may conflict with the interests of OKX TR, such person shall notify the relevant situation to the Officer (or, if the Officer has a conflict of interest or potential conflict of interest in this regard, to the Board of Directors). The Board of Directors shall determine the appropriate action to be taken accordingly with respect to this issue. The written declaration to be obtained from the relevant persons in this regard shall be kept on file by OKX TR and updated if deemed necessary.

p.Oversight of Services Provided by Group Companies

Officer will supervise the services provided by any group company and be responsible for monitoring the performance of these group companies under the relevant contract and maintaining regular communication with the service provider which is a group company. This includes establishing a direct reporting line with the service provider, receiving feedback from service providers through regular reports and meetings, and being physically present at the service provider's offices when necessary.

If any person is concerned about an actual or potential conflict of interest, they are encouraged to discuss the matter with the Officer. If the Officer has an actual or potential conflict of interest in this matter, the Officer should report it to the Board of Directors, depending on the circumstances.

The Board of Directors shall receive a written report ("Report") on a regular basis from the Officer and at least annually on the implementation, maintenance and review of the principles contained in this Policy and the general arrangements for identifying, avoiding and mitigating conflicts of interest. This Report shall, at a minimum, state:

  • Steps taken to avoid and mitigate actual or potential conflicts of interest;

  • Disclosure of any general or specific conflict of interest;

  • Deficiencies (if any) identified in this Policy and other procedures and regulations (including OKX TR's remuneration policies, procedures and regulations) and measures taken to address them.

3.REPORTING CONFLICTS OF INTEREST

OKX TR employees must take the necessary measures and perform adequate controls to identify actual or potential conflicts of interest, and must act in accordance with the principles set forth in this Policy. Where a potential conflict of interest is identified, relevant employees  should first disclose it to their direct line manager to assist in assessing the risk of material harm. In this regard, relevant employees should make the required disclosure with full information to allow for a thorough investigation, including

  • corrective and preventive actions;

  • why these actions were deemed appropriate;

  • the conditions applied; and

  • if there is still an ongoing conflict, how it is managed and how the Clients involved will be informed.

The Board of Directors will receive written reports from the relevant departments and units at regular intervals and at least once a year on all the above-mentioned situations.

4.DISCLOSURE OF CONFLICTS OF INTEREST

a.General Nature and Source of Conflicts of Interest

OKX TR will disclose the general nature and sources of conflicts of interest on its website. This disclosure shall be made available through appropriate links that Clients can access at any time and from any device. 

b.Specific Conflicts of Interest

Where there is a specific conflict of interest in relation to a Client, the conflict shall be disclosed to the Client in writing so that the Client can make an informed decision as to whether to do any business or transaction with OKX TR under the circumstances. 

c.Provision of General Advice

In the event that general advice of a guiding nature regarding the trading of crypto assets is provided, as defined under Article 50/1 of the Communiqué on Working Procedures, the principles set forth in this Policy regarding the disclosure of conflicts of interest shall be followed.

5.CONNECTED PERSONS 

A connected person is required to confirm in writing that they have received and read this Policy.

Each year, the connected person will complete a declaration form indicating any relationship, position or situation that may contribute to any conflict of interest. This information will be kept confidential and will generally only be shared with the Board of Directors and any committee established to address conflicts of interest, or the Officer (unless additional disclosure is required in the context of implementing this Policy).

6.EDUCATION AND AWARENESS

This Policy has been made available to all relevant personnel and employees of OKX TR. A general summary of this Policy is also included in OKX TR's recruitment and annual training programs.

Regular training sessions and continuous awareness raising are conducted to ensure that conflicts of interest are recognized, are detected effectively, are reported and procedures for their management are understood.

7.COMPLIANCE WITH AND BREACHES OF THIS POLICY

OKX TR employees and managers are required to declare that they have read, understood, and agreed to comply with this Policy. Such declarations shall be retained as specified in this Policy.

In the event of a breach of this Policy, an internal investigation shall be initiated concerning the relevant employee, and as a result of said investigation, appropriate sanctions may be imposed, including disciplinary action or termination of employment.

8.REGULAR REVIEW AND APPROVAL

This Policy will be reviewed annually, or more frequently if necessary, by the Officer, the Document Owner or the Document Author to ensure it remains up-to-date with regulatory changes and business practices. If deemed necessary (e.g., for the purpose of aligning with current industry practices or complying with new legislative requirements), it will be updated accordingly.

The Document Approver's approval is required at least once every year or when major and significant revisions are made, whichever precedes. Minor and limited revisions may be approved by the Document Owner or Officer, unless the Document Owner is also the Author.

9.RECORD KEEPING 

The storage of this document and Customer information and ensuring the security of such information is carried out in accordance with Personal Data Protection Law No. 6698 and the Data Retention Policy. The relevant information shall be disclosed only to the units and personnel responsible for resolving the said conflict of interest, in accordance with the applicable policy and legislation.

OKX TR will keep all documents relating to employees and their transfer instructions for at least 10 (ten) years after the termination of the employment contract.

A copy of this Policy will be retained for a minimum of ten (10) years or longer, in accordance with applicable legislation.