Legal document \u00b7 Version 1.0
Conflict of Interest
Effective date
2026-01-01
Last updated
2026-04-21
Document ID
WS-LEG-COI-001
Supersedes
None
Notice. This policy is a public summary. The full Code of Ethics and supporting procedures are internal and made available to regulators and auditors on request.
\u00a7 1. Scope
This policy applies to all directors, officers, employees, contractors, interns, and consultants of Wavestar Holdings LLC and its subsidiaries (“Covered Persons”), and, where indicated, to members of their immediate household.
\u00a7 2. Principles
- 01
Member interests first
Covered Persons must act in the best interests of Members and of the market as a whole, not their personal interests or the interests of a third party. - 02
Disclose before you act
If a conflict exists or could reasonably be perceived to exist, disclose it to Compliance before taking the action. Disclosure is a protection, not an accusation. - 03
Information walls
Market-sensitive information is walled off from commercial, sales, and marketing functions. Crossings require Compliance approval. - 04
Document the management plan
Where a conflict cannot be eliminated, the management plan — recusal, information barriers, independent review — is documented and monitored.
\u00a7 3. Employee personal trading
Covered Persons may not trade, directly or indirectly through a household member, in any cleared contract, derivative, or underlying asset where:
- the Covered Person has material non-public information obtained through their role;
- the trade would take advantage of Wavestar’s pending or contemplated actions;
- the trade involves a Member or counterparty with which the Covered Person has a direct commercial relationship on behalf of Wavestar.
Pre-clearance is required for trades in cleared contracts, in Members, and in any security listed on the quarterly restricted list. Pre-clearance requests are submitted through the compliance portal and are valid for three business days.
\u00a7 4. Related-party transactions
A related-party transaction is any transaction between Wavestar and a director, officer, employee, beneficial owner above the five-percent threshold, or a household member of any of the foregoing. All related-party transactions require:
- advance disclosure to the Chief Compliance Officer;
- Audit Committee approval for transactions above USD 120,000 in any calendar year; and
- disclosure in our annual Transparency Report.
\u00a7 5. Gifts and hospitality
Thresholds
- Gifts received — single item
- USD 100
Above the threshold requires written Compliance approval before acceptance.
- Gifts received — annual aggregate per giver
- USD 300
- Hospitality received
- USD 250 per event
Reportable above USD 100; prohibited if the giver has a pending material regulatory, commercial, or disciplinary matter.
- Gifts given
- USD 100 per recipient per year
Higher thresholds require approval and must be consistent with the recipient's own gift policy.
- Hospitality given
- USD 250 per recipient per event
- Cash and cash equivalents
- Prohibited in all circumstances
- Gifts to public officials
- Require General Counsel approval
Regardless of value. We apply U.S. FCPA and UK Bribery Act standards globally.
\u00a7 6. Outside business activities
Covered Persons must disclose outside employment, board positions, investment advisory roles, and material personal investments (including investments in Members or counterparties) in writing to Compliance. Approval is required before accepting new outside positions. Political candidacy and public office are subject to separate disclosure and approval rules.
\u00a7 7. Confidentiality and insider trading
Material non-public information learned through a role at Wavestar — Member positions, pending defaults, regulator engagements, pending product launches — is confidential. Tipping others, trading on the information, or using it for personal advantage is a serious breach of this policy and, depending on circumstances, a violation of law.
\u00a7 8. Reporting and investigation
Suspected conflicts of interest, policy breaches, or ethical concerns should be reported to the Chief Compliance Officer or through the anonymous Speak-Up channel described at /compliance/whistleblower. Good-faith reports are protected against retaliation.
\u00a7 9. Breach and discipline
Breaches of this policy may result in disciplinary action up to and including termination, disgorgement of gains, and referral to regulators or law enforcement. The Board Audit Committee oversees material-breach investigations.
Disclose
When in doubt, disclose.
Compliance reviews disclosures within three business days. Disclosing a potential conflict protects you and protects the market.