1. Introduction
AZIVON is committed to transparency, integrity and the adoption of practices intended to identify and manage potential conflicts of interest related to its activities. This Conflict of Interest Policy establishes principles and procedures to identify, prevent, manage and, when necessary, disclose situations in which the interests of AZIVON, its traders, employees, partners or other related parties may conflict with the interests of users.
The existence of a potential conflict of interest does not necessarily mean that the investor will suffer harm. The purpose of this Policy is to establish mechanisms so that such situations are identified and handled appropriately.
2. What is a conflict of interest?
A conflict of interest may occur when the financial, commercial, professional or personal interests of a particular party may influence, or appear to influence, a decision or activity related to the services made available by AZIVON. Such conflicts may involve, among others:
· AZIVON and its users;
· Traders and investors;
· Employees and users;
· Commercial partners and users;
· Different groups of users;
· Service providers and other parties related to AZIVON’s operations.
3. Principles adopted by AZIVON
When managing potential conflicts of interest, AZIVON seeks to observe principles of:
· Transparency;
· Integrity;
· Appropriate treatment of users;
· Independence in operational decisions;
· Protection of confidential information;
· Identification and management of potential conflicts;
· Clarity in the disclosure of fees, compensation and relevant commercial relationships.
4. Management of trades
Decisions related to trades in AZIVON’s PAMM account are made manually by the traders responsible for management, based on their analyses, experience, risk criteria and conditions observed in the financial markets.
Decisions to buy, sell, maintain, reduce or close positions should not be made with the objective of individually favoring a specific participant in the PAMM structure to the detriment of others. AZIVON seeks to keep trade management separate from individual interests related to users, partners or participants in the Rewards Program.
5. AZIVON compensation
AZIVON receives compensation related to the services provided, including the 30% performance fee on eligible profits and the applicable administrative fee according to the investor’s capital tier. The existence of a fee linked to performance may represent a potential conflict of interest because AZIVON’s compensation may increase when higher eligible profits are generated.
To help align the fee with investor results, the performance fee uses the High-Water Mark (HWM) methodology and is applied only to eligible profits according to the structure’s rules. The existence of performance-based compensation does not eliminate the risks associated with trading.
6. Rewards Program
AZIVON maintains a Rewards Program related to referrals made by participants. Of the 30% performance fee charged by AZIVON, 10% is allocated to the Rewards Program and may be distributed according to the referral levels established by the program.
Rewards come from eligible performance fees generated by accounts linked to the network and are not calculated on deposits or on the capital invested by participants. The existence of a referral relationship should not influence management decisions made by the traders. No participant should receive different operational treatment in the PAMM account because of their position or participation in the referral network.
7. Relationship with the partner broker
AZIVON uses BlackBull Markets’ infrastructure for the PAMM structure and execution of trades. BlackBull Markets is a company independent of AZIVON and has its own terms, policies, procedures and responsibilities.
If commercial relationships, partnership programs, commissions or other forms of compensation exist between AZIVON and the broker or other partners, such relationships may represent potential conflicts of interest and should be managed appropriately.
The existence of a commercial relationship should not replace the assessment of the operational factors considered by AZIVON when using a particular infrastructure or partner.
8. Selection of partners and service providers
AZIVON may work with different suppliers, service providers and commercial partners. Whenever possible, selection of these partners should consider factors related to quality, security, infrastructure, commercial conditions, technical capability and suitability to the needs of AZIVON and its users.
Personal relationships or individual benefits should not be used as the predominant criterion for decisions that may affect users.
9. Personal trading and traders’ interests
Traders, employees or other persons related to AZIVON may hold investments or carry out financial transactions in a personal capacity. When such activities may create a material conflict with trades executed within the PAMM structure, AZIVON may establish controls, restrictions or internal procedures intended to manage that conflict.
Information related to AZIVON’s trades should not be improperly used to obtain personal advantage.
10. Use of confidential information
Confidential information related to users, trades, positions, internal procedures or AZIVON activities should be used only for legitimate purposes related to the functions and responsibilities of authorized persons.
Improper use of confidential information to obtain personal benefit or favor third parties is prohibited.
11. Gifts, benefits and incentives
Employees, traders and other persons related to AZIVON should not accept gifts, payments, benefits or incentives that may compromise, or appear to compromise, the independence of their professional decisions.
Legitimate commercial benefits may be permitted when they are reasonable, transparent and do not interfere with responsibilities toward users.
12. Identification of conflicts
AZIVON may review its activities, commercial relationships and internal procedures with the objective of identifying situations that may represent conflicts of interest. Factors that may be considered include:
· Compensation structures;
· Relationships with partners;
· Participation in commercial programs;
· Financial interests of related persons;
· Personal activities of traders or employees;
· Use of confidential information;
· Relationships between users and participants in the Rewards Program.
13. Management of conflicts
When a potential conflict of interest is identified, AZIVON may adopt measures proportionate to the nature of the situation. Such measures may include:
· Separation of certain functions or responsibilities;
· Restriction of access to information;
· Implementation of internal controls;
· Monitoring of certain activities;
· Review of commercial relationships;
· Restriction of certain practices;
· Disclosure of the conflict to users when appropriate;
· Other measures considered necessary to properly manage the situation.
14. Disclosure of conflicts
When internal measures are not sufficient to adequately manage a material conflict of interest, AZIVON may disclose to affected users information regarding the nature and possible consequences of the conflict.
Disclosure should be sufficiently clear to allow the user to understand the situation and make their own decisions.
15. Treatment of users
AZIVON seeks to treat its users fairly and consistently within the conditions applicable to the services used. Participation in the Rewards Program, the volume of referrals, commercial relationships or other external interests should not determine privileged operating conditions in the management of the PAMM account.
Differences arising from previously established rules, such as administrative-fee tiers, do not in themselves constitute improper treatment when applied according to the disclosed criteria.
16. Internal responsibilities
Persons acting on behalf of AZIVON should report situations that may represent material conflicts of interest whenever they become aware of them.
AZIVON may analyze the situation and determine the measures necessary to prevent, reduce, manage or disclose the identified conflict.
17. Monitoring and review
This Policy may be reviewed periodically to reflect changes in AZIVON’s structure, the services offered, relationships with partners or applicable legal and regulatory requirements.
New potential conflicts may be identified as products, services or features are added to the platform.
18. Changes to this Policy
AZIVON may update this Conflict of Interest Policy whenever necessary. The updated version will be made available on AZIVON’s website or platform.
Where applicable, material changes may be communicated to users through official channels.
19. Contact
For questions related to this Conflict of Interest Policy, contact AZIVON:
Email: contact@azivon.com
Last updated: 20/09/2025
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