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Conflicts of Interest Statement

Trek Labs Ltd FZE d/b/a Backpack Exchange | Licence No. VL/23/07/001

Our commitment.

Trek Labs Ltd FZE dba Backpack Exchange (“TLL” or the “Company”) is committed to integrity, fairness, and transparency. We recognise that conflicts of interest can arise in the normal course of business. This notice explains, in plain terms, how we identify, manage, and reduce those risks.

Where conflicts may arise.

• Dealings with related or affiliated parties.

• Fees, commissions, rebates, or other incentives.

• Allocation of opportunities, resources, or client attention.

• Access to and use of confidential or client-order information.

• Staff personal account dealing, gifts, or outside interests.

• Preferential access to order flow or execution information by affiliated entities or market participants.

How we manage conflicts.

• Policies & governance: Documented Conflicts Policy, Code of Conduct, and a maintained Conflicts Register overseen by Compliance and senior management.

• Disclosure & transparency: Clear public disclosures of material relationships, fees, and practices; updates when they change.

• Information handling: Confidentiality rules, least-privilege access, information barriers, restricted lists, and monitoring to prevent misuse.

• Decision independence: Client-first decision-making; controls so fees or incentives do not determine outcomes.

• Monitoring & remediation: Ongoing surveillance/QA, escalation workflows, and timely remediation with audit trails retained per regulatory requirements.

• Order flow protection: No affiliated entity receives preferential access to order flow or execution information. All participants access the shared order book under the same Price-Time Priority with no prioritised access. Market Data available to all participants is limited to resting Limit Orders and executed Fills; Stop Orders, cancelled orders, and user identity are excluded.

Related-party dealings.

Market making, liquidity and proprietary trading.

• An affiliated entity within the Backpack Exchange group provides market making services and liquidity on the platform. The arrangement is conducted on an arm’s-length basis; the affiliated entity participates in the shared order book on the same Price-Time Priority basis as all other users with no preferential treatment. Third-party market makers also provide liquidity on the platform.

• No affiliated entity engages in proprietary trading on the Backpack Exchange platform. The platform operates solely as an intermediary enabling users to interact with each other to execute trades.

• All market making and liquidity arrangements involving affiliated entities are monitored internally by an independent function to ensure compliance with applicable market integrity requirements.

• Conducted on an arm’s-length basis with fair and competitive terms.

• Documented, reviewable, and where appropriate — subject to independent review or consent.

• No preferential treatment for affiliates over comparable third parties.