1. Organizational policies#
Obsidiam Ltda. maintains formal policies for Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT), Corporate Governance, Risk Management and Cybersecurity, prepared in accordance with Brazilian Law No. 9,613/1998 and other applicable regulations.
The full versions of the policies may be requested by clients and regulatory authorities at compliance@obsidiam.com.
2. Conflicts of interest#
Obsidiam Ltda. identifies, assesses and discloses any conflicts of interest arising from corporate, commercial or operational relationships with partners, suppliers and other entities of the Obsidiam Group, as well as the measures adopted to mitigate them, including segregation of duties and the submission of potential conflicts for assessment and approval by an independent Compliance function, in accordance with its Conflicts of Interest Policy.
Identified conflict: Volcanic Glass AG, the institutional liquidity provider for transactions intermediated by Obsidiam Ltda., is an entity under common control with Obsidiam Ltda. Because it acts as a liquidity counterparty in transactions involving clients of Obsidiam Ltda., this relationship is treated as a potential conflict of interest and is subject to the mitigation measures described above.
The information disclosed may be adjusted based on its sensitivity in order to comply with applicable business-secrecy provisions governing the agreements entered into by Obsidiam Ltda.
3. Contact#
Policy requests and compliance questions: compliance@obsidiam.com.