Conflicts of Interest

Overview

ARTE One recognises that conflicts of interest may arise in connection with the operation of its digital wealth platform and the provision of access to investment-related products and services.

This Conflicts of Interest statement provides a high-level description of potential conflicts and the general principles applied to identify, manage, and disclose them. More specific disclosures may be provided at the product, provider, or onboarding level.

Sources of Potential Conflicts

Platform-Related Conflicts

ARTE One operates as a technology-enabled wealth platform that provides access to information, tools, and connectivity to products and services offered by ARTE group entities and independent third-party providers.

Conflicts may arise where:

  • certain products or services are made available, featured, ranked, or prioritised on the platform; or
  • platform design, functionality, eligibility criteria, or presentation influences user engagement with specific products or providers.

The availability, ordering, or visibility of products or services may reflect a range of considerations, including legal and regulatory restrictions, compliance requirements, risk controls, operational feasibility, and commercial arrangements. ARTE One does not guarantee platform neutrality or equal visibility for all products or providers.

Group-Related Conflicts

ARTE One forms part of a broader group of affiliated entities.

Conflicts may arise where ARTE group entities:

  • provide products or services accessible through the platform (including, without limitation, investment management, technology, analytics, structuring, or operational services); and/or
  • derive economic benefit from user access to, or use of, certain products or services.

Remuneration and Economic Interests

ARTE One or affiliated entities may receive fees, commissions, revenue-sharing arrangements, referral payments, or other economic benefits in connection with products or services accessible through the platform.

Remuneration structures may differ between products or providers and may include benefits paid by users and/or benefits paid by product providers. ARTE One or affiliated entities may also receive non-monetary benefits (such as access to information, research, tools, events, or services) in connection with certain arrangements.

Third-Party Relationships

Conflicts may arise from relationships with independent third-party providers, including:

  • commercial partnerships;
  • distribution, referral, or connectivity arrangements; and
  • arrangements where third-party providers have their own incentives, conflicts, or business interests.

Third-party providers operate under their own governance, terms, and policies. ARTE One does not control third-party practices and does not assume responsibility for third-party conflicts, except as required by applicable law.

Management of Conflicts

ARTE One maintains policies, procedures, and controls designed to identify and manage conflicts of interest. Depending on the nature of the activity and associated risk, these may include, where appropriate:

  • governance and oversight arrangements and clear allocation of responsibilities;
  • separation of roles and responsibilities and segregation of duties;
  • maintenance of internal documentation and, where appropriate, a conflicts register;
  • controls over remuneration structures and commercial arrangements;
  • disclosure of relevant conflicts at the platform or product level;
  • training and awareness practices for relevant personnel; and
  • escalation processes where a conflict cannot be adequately mitigated.

Not all conflicts can be eliminated. Where conflicts cannot be effectively managed, ARTE One may limit, restrict, or decline access to certain products or services.

Product-Level Disclosure

Specific conflicts relating to a particular product or service are disclosed, where applicable, in the relevant product documentation, contractual agreements, and/or onboarding materials. Users should review such disclosures carefully before engaging with any product or service.

Product-level disclosures shall prevail in the event of any inconsistency with this general statement.

User Acknowledgement

By accessing or using the ARTE One platform, users acknowledge that:

  • conflicts of interest may arise in connection with the platform, group relationships, remuneration arrangements, or third-party providers; and
  • ARTE One does not act as a fiduciary and does not provide personalised investment advice unless expressly agreed in writing under a separate contract.

Relationship with Other Legal Documents

This Conflicts of Interest statement should be read in conjunction with the Terms of Service, Risk Disclosure, and Legal & Regulatory Information made available on the ARTE One platform.

Updates

This Conflicts of Interest statement may be updated from time to time to reflect changes in the platform, group structure, commercial arrangements, or regulatory expectations. The most recent version will always be available on the ARTE One website.