Virtual Asset Standards

The Company has adopted the following Virtual Asset Standards ("VAS") in accordance with regulatory requirements. The Company has established a comprehensive framework of standards for all Virtual Assets for which it provides VA activities. Before and during the delivery of any VA activities, the Company takes all necessary measures to ensure that all VAs adhere to these standards. This includes performing required due diligence on an ongoing basis to ensure continued compliance. The Company's disclosures and reviews of VAs will be made available on this website.

Scope

This Policy applies to all Virtual Assets, including cryptocurrencies, tokens, and any digital representations of value handled in connection with the Company's activities. This Policy does not extend to non-digital assets or securities.

Criteria for listing

The Company evaluates each VA using a thorough set of criteria, which encompasses but is not limited to the following:

Market metrics

Assessment of market capitalisation, fully diluted value, and liquidity, including consideration of whether these metrics have trended downwards over time.

Design & use cases

Examination of the VA's design, features, and use cases, whether or not intended by the issuer or relevant developers.

Compliance with laws & regulations

Features which may materially affect compliance with applicable laws, regulations, rules, or directives, including AML/CFT, sanctions, securities, and intellectual property.

Regulatory treatment

Consideration of the regulatory treatment by VARA and other Regulatory Authorities, including whether the issuance of the VA has received any regulatory approvals.

Prohibitions

Investigation of whether VARA or other appropriate authorities prohibit a VA in jurisdictions where the VASP provides VA activities.

Security of DLT protocol

Assessment of the security and immutability of the underlying Distributed Ledger Technology (DLT) protocol.

Future development

Evaluation of the VA's future development roadmap as communicated by the issuer and/or relevant developers.

Price manipulation

Assessment of susceptibility to price manipulation and the mitigations to be implemented.

Conflict of interest

Assessment of potential or actual conflicts of interest that may arise from the Company providing VA activities in relation to the VA and the relevant mitigations.

Issuer background

Evaluation of the issuer's background, including relevant experience in the VA sector and whether they have been subject to investigations or claims relating to fraud or deceit.

Asset rights

If the VA represents rights to any other assets, the enforceability of such rights is evaluated.

Asset availability

Confirmation that sufficient assets are available to satisfy any obligations with respect to any VA activities.

Terms & conditions alignment

Ensuring that VA terms and conditions reflect the operation of any existing underlying physical market, avoiding adverse impacts to such a market where applicable.

Risk analysis

A comprehensive evaluation of the risks associated with the VA, including market volatility, cybersecurity threats, investor protection, and technological vulnerabilities.

Governance

Assessment of the governance framework and mechanisms in place to ensure transparency, accountability, and compliance with legal and regulatory requirements within the VA ecosystem.

Ratings framework

The Company has established a Ratings Framework to evaluate and rank VAs considered for listing and other activities, ensuring consistent, transparent, and objective assessment. The following elements are taken into account:

Empowerment

Whether the VA focuses on poverty alleviation, healthcare, education, or other areas that empower individuals or communities.

Equitability

Whether equitable outcomes, fair resource distribution, or equal access to opportunities are promoted.

Sustainability

Whether there is a focus on practices that promote sustainability, environmental responsibility, or alignment with the Sustainable Development Goals.

Eco-friendliness

Whether the VA minimises environmental harm, reduces carbon footprint, or promotes eco-friendly practices.

Linked to the real economy

The connection between the VA and the real economy, referring to the production, consumption, and distribution of goods and services.

Opportunity creation

Whether the VA facilitates creation of economic opportunities and job growth, or enables individuals to engage in productive activities.

Use of smart & emerging technologies

The extent to which the VA utilises advanced technologies such as AI, blockchain, or other emerging technologies to innovate or improve operations.

Transparency & disclosures

The level of openness, accountability, and provision of relevant information, including financial disclosures and operational practices.

Governance

The systems, structures, and processes in place to ensure effective oversight, accountability, and responsible management.

Charitability

Whether the VA incorporates philanthropic or charitable elements, such as donating to causes, supporting community initiatives, or engaging in social impact activities.

Listing process

The following departments are involved in the analysis of VAs before listing: Legal and Compliance, and Product Development.

Product team ideation: The product team identifies a potential VA for listing and gathers all necessary information and documents for screening.
Ethical review: The Ethics and Impact department reviews the VA from an ethical perspective, ensuring it is equitable, ethical, and in line with the Company's values.
Legal and compliance review: The legal and compliance team reviews the application against the listing criteria, regulatory and legal criteria. This review may include technical analysis, market analysis, legal review, and risk assessment.
Management review: If the review is successful, the VA is escalated to management for review.
Approval: The VA will be listed with Regulatory Authorities if necessary for approval.
Final review: After listing, the VA will be continuously monitored to ensure it continues to meet all regulatory, legal, and internal requirements.

Ongoing due diligence

The Company takes proactive steps to ensure that every VA remains in compliance with the VAS throughout its lifecycle. Ongoing due diligence involves:

Monitoring VA performance: Regularly monitoring listed VAs to assess alignment with the Company's standards for risk, liquidity, and market stability, including compliance with any new or updated VARA requirements.
Regulatory changes: Continuously assessing the impact of any regulatory changes on the VA.
Issuers' background: Regular checks on the issuer's legal status, any ongoing investigations or litigation, and any material changes in the issuer's business practices.
Security and technological integrity: Monitoring for any security vulnerabilities or technological updates that could affect the VA's operational stability.
Periodic re-evaluation: Periodic reassessments of the VA at least annually, or as needed based on the nature of the asset and any material changes.
Ongoing monitoring: Implementing a continuous monitoring system to detect any signs of market manipulation, cybersecurity risks, or other irregularities.
Annual review of T&Cs: Conducting an annual review of the VA's terms and conditions to ensure alignment with relevant physical market standards and incorporating any regulatory changes.

VA activity suspension protocols

The Company shall establish clear conditions under which VA activities may be suspended. These include:

Non-compliance with VAS: If a VA fails to maintain compliance with the VAS, activities may be suspended.
Regulatory changes: Changes in the regulatory environment affecting a VA's legal standing or compliance ability.
Operational issues: Significant operational issues affecting the VA's underlying technology, blockchain, or network.
Market manipulation or unfair practices: Evidence of market manipulation, misleading conduct, insider trading, or other unfair practices.
Security breach: In the event of a security breach or cyberattack associated with a particular VA.
Asset volatility: Extreme and abnormal price volatility may lead to temporary suspension to protect investors.

When any such conditions are met, the Company will: activate a formal cross-departmental review; inform all relevant teams immediately; issue transparent and timely communication to clients; document all decisions and actions for eight (8) years; and notify VARA as soon as possible.

VARA shall have the right to require the suspension of VA activities in respect of any VA upon reasonable grounds it deems appropriate. The Company shall act promptly to comply with VARA's directive.

Notification & mitigation

Upon recognition that a VA fails to meet the VAS, the Company shall promptly notify VARA and undertake all necessary steps as directed by VARA to minimise any adverse impact on clients resulting from the non-compliance.

Record keeping & inspection compliance

The Company is committed to maintaining all records pertinent to VA assessments for a duration of eight (8) years, in compliance with the Company's Records Management Policy. These records include VA vetting processes, monitoring reports, and activity suspension records. Such records will be readily provided for VARA inspection upon request.

This Policy will be reviewed and updated regularly to reflect the evolving VA landscape and regulatory standards. Any changes will be communicated promptly to all relevant stakeholders.