Last Updated: March 2, 2026

1. Scope of Custody Services

The Company provides custody and administration of crypto-assets on behalf of clients within the meaning of Article 3(1)(11) of the MiCA Regulation.

The custody service applies exclusively to stablecoins (e.g., USDC, EURC). The following mechanisms are not applicable and are not provided by the Company:

• on-chain governance voting rights,

• staking or delegation of validation rights,

• third-party airdrops.

The Company does not support or facilitate these features.

2. Type of Custody

The Company uses two custody models:

a) Segregated Client Wallet

• Each client is assigned a dedicated vault upon onboarding.

• Assets are technically segregated from other clients and from the Company.

b) Omnibus Wallet

• Multiple clients’ assets may be held in a pooled wallet.

• The Company maintains precise internal ledger records allocating each client’s share.

• Client assets are always segregated at accounting and system levels from the Company’s own assets.

The Company strictly separates client assets from proprietary assets.

3. Technical Safeguards

Custody is provided through the Fireblocks platform using:

• MPC (Multi-Party Computation) technology (no single complete private key exists),

• encryption of data at rest and in transit,

• role-based access control (RBAC),

• multi-factor authentication (MFA),

• real-time transaction monitoring.

No individual employee has unilateral authority to transfer client assets.

4. Transaction Authorisation

Transfers of crypto-assets:

• are executed solely upon client instruction,

• are subject to multi-level authorisation,

• are logged with transaction ID, timestamp, and blockchain hash.

The Company implements a Fireblocks Transaction Authorisation Policy (TAP), which:

• technically prevents unilateral transaction initiation by staff,

• requires cryptographic validation.

5. Prevention of Commingling

The Company and its employees may not:

• use client assets for proprietary purposes,

• pledge client assets as collateral,

• transfer assets between clients without explicit instruction.

Daily automated reconciliations are performed.

6. Return of Crypto-Assets

a) Ordinary Termination

Crypto-assets are transferred without undue delay to the address designated by the client.

b) Insolvency of the Company

• Client assets are held separately.

• Records are made available to the insolvency administrator.

• Client assets do not form part of the Company’s insolvency estate.

7. Hard Fork Handling

In the event of a hard fork:

• The Company assesses the dominant blockchain branch.

• Only the dominant chain is supported.

• Minority fork tokens are not credited to clients.

• Clients are informed within five (5) business days.

8. Risk Mitigation Measures

• MPC technology

• Four-eyes principle

• Continuous blockchain monitoring

• Disaster recovery testing at least twice annually

• Incident Response Policy aligned with DORA

• Periodic internal audits of custody processes

9. Complaints and Communication

Contact details for complaints are provided in the contractual documentation and published on the Company’s website.