Conflicts of Interest Disclosure

1. The house market maker

Tufdog runs on the Victoi platform. Victoi operates the order book and a market maker that trades on it for its own account, so there is usually a price to trade at. The market maker:

• sets the opening price of each contract and quotes buy and sell prices using models and data feeds;
• trades on the same order book as members and may be the other party to your trade;
• profits when members it trades against lose, and loses when they win;
• quotes during live games without the short delay that applies to members' orders;
• may widen its prices, reduce what it offers, or stop quoting at any time.

2. The operator and the platform provider

• Our platform provider operates the ledger, the order book, the market maker and the deposit payment page, and earns from the fees and from the market maker's trading.
• We decide how markets settle and when they are voided. A settlement decision can favour the market maker's position or the members'.
• Relationship: Victoi, Inc. owns Tufdog and provides the platform the Service runs on, acting on Tufdog's behalf. Your agreement is with Tufdog. When Victoi keeps your balance and positions, matches your orders or takes your deposits, it does so for Tufdog as our platform provider.

3. How these conflicts are managed

• Every matched trade is fully paid for when it is made, so a winning contract always pays whoever was on the other side.
• The market maker's exposure is capped per market and in total.
• Markets settle on the official result named in each market's rules, published before you trade, and voids follow published reasons (see our Market Rules).
• Staff accounts cannot trade, and staff must not pass non-public information to anyone who trades.
• Fees are the same for every member and shown before you confirm (see our Fee Schedule).

Oversight: surveillance alerts are reviewed by people acting for Tufdog (including our platform provider's staff acting on our behalf). Where we suspect insider trading, match-fixing or manipulation, we may share information with the league, governing body or sports-integrity organisation concerned and report it to the police or other competent authorities.