Purpose
Prevent manipulation, insider dealing, front running, misuse of confidential information and unmanaged conflicts arising from market-facing and employee activity, consistent with the approved Market Conduct & Trading Compliance Manual v1.1 sections 3, 4.3, 4.4 and 11.2.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Prohibit wash trading, spoofing, layering, pump-and-dump activity, false market signals, rumor dissemination and other manipulative conduct | Such practices undermine market integrity, erode client trust and may constitute criminal offenses under financial market regulations; employees must report any suspected manipulative activity to the Compliance team for investigation | MCT 3.1 |
| 2 | Identify material non-public information (MNPI), restrict access and apply information barrier (“Chinese Wall”) protocols to listings, partnerships, regulatory approvals, client orders and other sensitive matters | Employees must not buy, sell or recommend virtual assets where they possess MNPI; confidential client or company data must never be exploited for personal benefit or to benefit third parties | MCT 3.2 |
| 3 | Prohibit trading, recommendations or disclosure based on MNPI, client data, advance order knowledge or non-public sanctions and compliance information | Employees must not use knowledge of sanctions alerts, internal compliance escalations, onboarding restrictions, unusual activity reviews, pending approvals or other non-public control information for personal benefit or to benefit another person; any such use is strictly prohibited and may constitute serious misconduct | MCT 4.4 |
| 4 | Require all employees to obtain Compliance approval before trading digital assets | MCT 4.4 Pre-Approval | |
| 5 | Maintain restricted-asset and sensitive-event information and refuse or condition personal-trading requests where conflicts or MNPI risk exists | Employees may be restricted from trading in assets under consideration for listing, partnership or other strategic activity by Bitkaya | MCT 4.4 Restricted Assets |
| 6 | Record personal-trading requests, approvals, refusals and relevant disclosures | Personal trades are subject to periodic review to ensure compliance with disclosure and conflict of interest requirements | MCT 4.4 Monitoring |
| 7 | Review personal trading periodically for approval compliance, restricted assets, timing, client-order proximity and conflict indicators | MCT 4.4 | |
| 8 | Require prompt disclosure of personal, financial, outside-business and third-party conflicts and document avoidance, restriction, disclosure or mitigation | Employees and management must promptly disclose any personal or financial interests that may conflict with Bitkaya’s business activities; acceptance of gifts, entertainment or favors that could improperly influence decision-making is prohibited; all partnerships, vendor arrangements and service agreements must be reviewed for potential conflicts with mitigation steps documented | MCT 11.2 |
| 9 | Enforce zero-tolerance against front running: employees, officers or affiliates must not use advance knowledge of client orders to execute trades in their own accounts or on behalf of others before the client order is executed | Front running is a serious breach of trust and may result in termination, regulatory reporting and potential criminal liability; surveillance systems are in place to detect patterns that may suggest front running or related misconduct | MCT 4.3 |
| 10 | Escalate suspected manipulation, insider trading, front running or misuse for investigation, discipline and external reporting assessment | Where conflicts cannot be avoided, Bitkaya will adopt measures to manage, disclose and resolve them in a manner that prioritizes client interests | MCT 11.2 Client First Principle |
Exceptions and Escalation
No exception permits use of MNPI or advance client-order knowledge. Unclear information status or conflict shall result in no trading until Compliance decides.
Records
- MNPI and restricted-asset records
- Personal-trading request and decision
- Conflict disclosure and treatment
- Periodic review results
- Alert, investigation and escalation evidence
Relationships
- Policy: POL-MCT-001 Market Conduct and Trading Compliance Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-MCT-002 Ensure Market Abuse and Personal Trading Controls Operate
- Related ABC policy: POL-ABC-001 Anti-Bribery and Corruption Manual
Assurance
Runtime effectiveness results are maintained in Odoo and assessed through the Hermes workflow tracked in ISS-HERMES-001. This note defines design, ownership, evidence expectations and testing method; it does not contain a manually maintained operation, evidence or overall effectiveness rating.
- Frequency: per request, continuous prohibition and periodic review
History
- 2026-07-26: Created from sections 3, 4.3, 4.4 and 11.2 of the approved MCT Manual.