Our Commitment
At Nova Digital FZE ("Nova Digital"), we are committed to upholding the highest levels of integrity, independence, and regulatory compliance in all aspects of our investment management activities. As an entity regulated by the Virtual Assets Regulatory Authority (VARA) in Dubai to provide Virtual Asset Management and Investment Services, we recognise that conflicts of interest whether actual, potential, or perceived can undermine client trust and decision-making integrity. Nova Digital's governance framework is designed to identify, manage, and mitigate such conflicts to ensure that all actions are taken in the best interests of our clients and investors.
Conflicts of Interest Framework
Nova Digital has implemented a comprehensive Conflicts of Interest Framework that establishes clear principles and controls to:
- Detect and assess circumstances that could give rise to conflicts between Nova Digital, its personnel, and clients or among different clients and funds under management;
- Manage and reduce identified conflicts through structured internal controls, segregation of duties, and independent oversight; and
- Disclose any material conflicts transparently where they cannot be fully mitigated, allowing clients and fund governing bodies to make informed decisions.
Nova Digital acts honestly, fairly, and professionally, ensuring that the interests of the funds we manage and their investors always take priority.
Core Controls and Safeguards
1. Independent Oversight
Decisions related to investment management, valuation, and execution are subject to oversight by Nova Digital's governance committees, ensuring objectivity, accountability, and independence from commercial or personal influence.
2. Segregation of Functions
Operational, risk, and compliance functions are separated from investment decision-making to prevent conflicts between fiduciary responsibilities and business objectives.
3. Fair Client and Fund Treatment
All funds and investors are treated equitably under consistent standards. Nova Digital does not favour any client, shareholder, or related entity when executing investment decisions or allocating opportunities.
4. No Custody or Proprietary Trading
Nova Digital does not hold client or fund assets in custody and does not engage in proprietary trading of Virtual Assets. All assets remain under the control and title of the relevant fund's appointed custodian, ensuring a neutral and conflict-free structure.
5. Employee Conduct and Ethical Standards
All employees are bound by Nova Digital's Code of Conduct, which requires disclosure of any external interests, prohibits personal trading or activities that may create conflicts, and mandates immediate escalation of potential conflicts to Compliance.
6. Ongoing Training and Awareness
Regular training reinforces staff awareness of conflicts of interest, ethical conduct, and regulatory expectations to maintain a strong culture of compliance and fiduciary care.
Management and Disclosure of Material Conflicts
In rare circumstances where a conflict cannot be entirely eliminated, Nova Digital will:
- Disclose the nature of the conflict promptly and clearly to the relevant fund or client;
- Outline the steps taken to mitigate the conflict; and
- Implement appropriate measures to ensure that clients' interests are protected at all times.
All material conflicts are recorded, monitored, and periodically reviewed as part of Nova Digital's compliance oversight process.
Declaration
As of the date of this disclosure, Nova Digital FZE confirms that there are no known material conflicts of interest arising from its investment management activities. Nova Digital remains committed to transparency, integrity, and the highest standards of fiduciary conduct in the management of virtual asset investment portfolios and regulated funds.