ANNEX 1 - STATEMENT ON CRYPTOCURRENCY LISTING AND GOVERNANCE POLICIES
This Statement on Cryptocurrency Listing and Governance Policies (this “Statement") is made available to provide greater clarity and transparency regarding the policies and procedures that are established by us to evaluate the cryptocurrencies that are supported by us. You should evaluate this Statement to make an informed assessment as to such policies and procedures before engaging in any of the digital payment token services that we provide. Unless otherwise defined in this Statement, all capitalised terms used in this Statement shall have the meanings ascribed to them in the XREX General Terms and Conditions.
EVALUATING PROSPECTIVE CRYPTOCURRENCIES
(1) Cryptocurrencies Listing Committee. To evaluate prospective cryptocurrencies that we intend to support, we have established a committee comprising certain members of senior management (“Committee”), which would oversee the process of evaluating such cryptocurrencies. This is conducted through a rigorous review process that evaluates assets against legal, compliance, risk, and technical security standards.
(2) Cryptocurrencies Listing Assessment. We have established a cryptocurrency listing assessment (“Listing Assessment”) to evaluate a cryptocurrency’s suitability for inclusion on our platform. The Committee is responsible for administering the cryptocurrency assessment framework in accordance with our policies and procedures. This Listing Assessment covers various criteria (such as an evaluation of commercial, governance, technical, and legal criteria), including but not limited to:
(a) the founding team and developers of the cryptocurrency;
(b) the governance model and token allocation plan (if any) of the cryptocurrency;
(c) the supported token protocol for the cryptocurrency;
(d) the business use case of the cryptocurrency;
(e) the track record, history and reputation of the cryptocurrency;
(f) the legal characterisation of the cryptocurrency;
(g) the cybersecurity certifications and measures implemented in connection with the cryptocurrency;
(h) assessment of the cryptocurrency's features that could heighten money laundering or terrorism financing risks;
(i) the supported blockchains and any monitoring or screening of the cryptocurrency;
(j) the market capitalisation of the cryptocurrency; and
(k) the liquidity and volatility of the cryptocurrency.
ONGOING MONITORING
(1) We monitor the cryptocurrencies on our platform on an ongoing basis to ensure they continue to comply with our listing standards. When a cryptocurrency no longer complies with the standards, we may conduct a review and suspend trading, delist or cease support on the cryptocurrency.
(2) The following factors may be taken into consideration in our review:
(a) Cryptocurrency no longer meets our legal, compliance and technical security standards;
(b) Responsiveness of the developers to our ongoing due diligence question and request for information;
(c) No visible product development or commitment from the project team;
(d) Trading volume and liquidity on the markets on the platform;
(e) Significant events such as security breach or compromise of DPT’s network; and
(f) Sanction and adverse media, including money laundering or terrorism financing risks, on the founders or issuer or parties associated with the cryptocurrency.
(3) The decision to suspend or delist will be made by the Committee. We will provide customers with timely and clear communication regarding the suspension or delisting process and the implications for their holdings.
Processes for Suspending, Delisting, and/or Ceasing to Support a Cryptocurrency.
(4) If we decide to cease support for a cryptocurrency, we will take the following steps where appropriate:
(a) notifying you and the regulatory authority of the decision and, if appropriate, the reasons for doing so;
(b) notifying you of the date and time by which we intend to cease support;
(c) notifying you of your rights and options in relation to the cryptocurrency before support is ceased; and/or
(d) notifying you of the consequences if you do not take any action in relation to the cryptocurrency (including unilaterally selling and/or converting your cryptocurrency) before support is ceased.
(5) Generally, we endeavour to use commercially reasonable efforts to provide you with prior written notice of any decision to cease support for a cryptocurrency. If we provide you with such prior written notice, you may sell, convert, and/or (if supported by us) transfer the cryptocurrency before support is ceased. However, if you do not take any action by the specified time notified to you, we may unilaterally sell and/or convert the cryptocurrency in your account. In addition, you should also be aware that you may not always be given each of the rights to sell, convert, and/or transfer the cryptocurrency, especially cryptocurrency transfers are not supported by us for the cryptocurrency.
(6) You should also be aware that it may not always be practicable to provide you with prior written notice of ceasing support for any cryptocurrency (for example, in the case of a significant market dislocation and/or absence of liquidity over a short period), although we endeavour to use commercially reasonable efforts to notify you as soon as practicable. In such circumstances where we cease support of any cryptocurrency without giving you prior written notice, we may unilaterally sell and/or convert the cryptocurrencies at the time we cease support for such cryptocurrency and we shall not be liable for any Losses that you may suffer in respect of such sale and/or conversion.
CONFLICT OF INTERESTS IN SUPPORTING CERTAIN CRYPTOCURRENCIES
(1) Potential or actual conflicts of interests may arise under certain circumstances when we are assessing whether to support any cryptocurrency. We are committed to mitigating such risks by implementing appropriate and effective policies and procedures, which should include but is not limited to:
(a) a segregation of compliance and commercial functions to provide a degree of independence in the Listing Assessment; and
(b) regarding supporting any cryptocurrency whereby (i) we are given any incentive to do so by the issuer and/or any other person and/or (ii) the issuer is a related or affiliated company of us, to declare such conflicts of interest to the Committee for consideration and thereafter implement appropriate steps to mitigate such risks including disclosure to customers on a case-by-case basis. For more information, please refer to our Terms for further information.
ADDITIONAL DISCLAIMERS
(1) No Guarantees Regarding Cryptocurrencies Listed on the Site. You acknowledge and agree that:
(a) our decision to support any cryptocurrency on our platform does not indicate our approval or disapproval of the cryptocurrency or the integrity, security or operation of the cryptocurrency or its underlying technology, and the risks associated with cryptocurrencies and trading of cryptocurrencies still apply notwithstanding our decision to support a particular cryptocurrency on our platform;
(b) we may be reliant on public information and representations made by third parties that are not controlled by us, and we are unable to warrant or guarantee that such information are accurate, complete, updated, not misleading, and/or authentic;
(c) our opinions on the legal characterisation of any cryptocurrency is confined under the financial services law and regulations in Singapore and such cryptocurrencies may be characterised differently under the laws of any other jurisdiction; and
(d) under no circumstances shall any of the Indemnified Parties be responsible or liable to you or any other person or entity for any Losses by reason of, or arising from, or as a consequence of any reliance by us on such third party information in our evaluation of cryptocurrencies.
(2) No Guarantees of Full Support for All Cryptocurrency Services. If we decide to support a cryptocurrency, you acknowledge and agree that we may not support all cryptocurrency services for such cryptocurrency. For example: (a) we may support only trading of a cryptocurrency and not deposits/withdrawals of the cryptocurrencies on any blockchain network; and (b) we may support only limited deposits/withdrawals of a cryptocurrency on a specific blockchain network, and not all blockchain networks that the cryptocurrency may be supported. It is your sole responsibility to review the extent to which any cryptocurrency is supported before using any of the Services.
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