# ETP Foundry — Administrator conflicts of interest policy

**Draft v0.2 — pending counsel review · 28 September 2026** (v0.1, 28 September 2026; v0.2 aligns the
policy with ETP Foundry Methodology v1.0 §9.2 and adds §7, the administrator's commercial and
operational conflicts). Methodology v1.0 is the sole governing methodology; the Rulebook v0.2 describes process only where it is consistent with it, and where any text differs, Methodology v1.0 governs.

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.
- The administrator computes the determination from the venues' submissions under the published
  methodology. A value becomes attested only when K of N seats confirm it and every gate passes.
- There is no independent oversight function yet (Methodology v1.0 §9.1). The committee of seats is not
  one. Until it is constituted, the administrator performs the reviews, publishes them and says so.

## 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.

## 7. The administrator's commercial and operational conflicts

The fund and ETP issuer licence includes a component linked to the assets under management of funds that reference ETP Foundry fixings. AUM rises with the fixing level, so this is a conflict of interest for the administrator. It is disclosed; the controls are that the administrator computes but never attests, cannot sign (the ledger refuses it as a member), and does not trade the instruments. Those controls do not address a fee that rises with the level; the mitigation for that is Methodology v1.0 §6.4: no value above tier 0 without an independent oversight function, K signatures by third parties with their own keys, and no administrator seats. The administrator also operates the settlement desk and creation/redemption, and today operates every committee seat on DevNet; both are disclosed conflicts.

These conflicts are mitigated, not removed. The administrator also does not accept payment contingent
on a fixing's level, and a knowingly false or manipulated input is reportable under the committee terms.

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