Conflicts Of Interest
Last updated: 13. September 2026
Internal Review Passed
1. Policy Statement and Objective
Sentens is committed to acting honestly, fairly, and professionally in accordance with the best interests of its clients. This Conflicts of Interest Policy outlines how we identify, prevent, manage, and disclose conflicts of interest that may arise during the provision of our algorithmic trading and infrastructure services, ensuring that client interests are never compromised for corporate gain.
2. Identifying Potential Conflicts
We proactively monitor operations to identify situations where a conflict may arise. Potential conflicts include, but are not limited to, scenarios where Sentens or its employees:
- Are likely to make a financial gain, or avoid a financial loss, at the direct expense of a client.
- Have an interest in the outcome of a service provided to the client which is distinct from the client's interest in that outcome.
- Receive an inducement from a third party (such as a liquidity provider) in relation to a service provided to the client, other than standard commission or fees.
- Trade on their own personal accounts (PA dealing) using proprietary information regarding client algorithmic flows.
3. Management and Mitigation Strategies
To mitigate these risks, Sentens implements strict "Information Barriers" (Chinese Walls) between different departments. We strictly prohibit "front-running" client algorithmic orders. Furthermore, we maintain a stringent Personal Account Dealing Policy that restricts employees from trading specific digital assets when they possess material non-public information regarding institutional client flows or platform updates.