# ETP Foundry — Administrator conflicts of interest policy

> **SUPERSEDED — not in force.** This document is superseded by [ETP Foundry Methodology v1.0](/documents/methodology-v1.0.md) (28 Sep 2026) and by [Conflicts policy v0.2](/documents/conflicts-policy-v0.2.md). It is kept for the record only. Where it differs from Methodology v1.0, Methodology v1.0 governs.

**Draft v0.1 — pending counsel review · 28 September 2026**

This policy covers the conflicts of ETP Foundry itself, as benchmark administrator, and of its staff.
Committee members' conflicts are covered by the committee terms of reference (§5).

## 1. The administrator proposes; it never attests

- The administrator computes and proposes every fixing and publishes the result. **It is never a
  committee member.** The ledger enforces this: a committee cannot list the administrator among its
  own members.
- A value becomes attested only when K of N independent seats confirm it.

## 2. Desk-operated seats

Today every seat on the only committee on the ledger is a party ETP Foundry hosts and signs for
(trust level L1). These are **test seats**. No value they sign is published as an attestation.

- A **register of desk-operated seats** (party, instrument, trust level, date created and date
  retired) is kept and shown to committee members and licensees.
- Every act the administrator performs as another party is logged and disclosed (rulebook §6.7).
- Desk-operated seats are retired as third-party seats are filled. They never count toward K for an
  OFFICIAL value.

## 3. The administrator does not trade what it prices

- ETP Foundry does not trade, make markets in, or take positions for profit in any asset or product
  it prices.
- **Current disclosure (28 Sep 2026):** ETP Foundry holds 1.0 BitSafe CBTC and about 1,017 Canton Coin
  on Canton **DevNet**, used only to test creation and redemption. The founder holds an exchange
  account used for treasury. Any position in an asset in a priced basket is entered in the register
  (§5).
- Where a holding is material to a benchmark, it is disclosed on that benchmark's page, and the
  administrator takes no part in any decision about that benchmark's inputs beyond the published
  methodology.

## 4. Staff personal dealing

Anyone working for ETP Foundry:

- may not trade an asset in a priced basket from 24 hours before to 1 hour after its strike;
- must pre-clear any trade in such an asset with the conflicts officer (today the founder; a second
  reviewer will be named when there is a second person);
- must never use unpublished proposals, committee evidence or licensee information for trading;
- declares their holdings on joining, and every year after.

## 5. Register and review

- The **conflicts register** records every declared interest of the administrator and its staff:
  holdings, commercial relationships with committee members or licensees, and desk-operated seats.
- It is reviewed at every quarterly committee meeting (rulebook §10), and the review is minuted.
- **Annual declaration**: each person re-declares every year, and on any change within five business
  days.

## 6. Commercial relationships

A party may both hold a committee seat and take a licence. The two are papered separately, so neither
can be used as leverage over the other. Seats are never paid and never charged.

Lucilla, Inc., federal corporation no. 16699448, Toronto, trading as ETP Foundry.
Contact: hello@etpfoundry.com.