5. Conflicts of interest

Confirmo FZE maintains internal policies and controls to identify, prevent, and manage conflicts of interest between client orders, employee interests, and company operations. Staff are subject to Personal Account Dealing restrictions that prohibit front-running, insider dealing, or any personal trading that conflicts with client order execution, and receive training on these and related conduct standards.

6. Order execution, pricing, and routing

In line with VARA's Broker-Dealer Services Rulebook, Confirmo FZE takes all reasonable steps to get the best possible execution result for client orders, weighing price, total cost, speed, likelihood of execution and settlement, size, and market impact. Confirmo FZE acts either as agent, routing client orders to vetted third-party liquidity providers and venues, or as principal, filling orders directly against its own liquidity inventory, and it discloses which capacity applies before execution and on trade receipts.

Prices are derived from rates quoted by Confirmo FZE's liquidity providers and updated continuously; where a single liquidity provider accounts for 20% or more of order flow in a given period, that provider will be named here.

All broker commissions, platform service fees, and conversion spreads are shown before trade confirmation and itemized on post-trade execution receipts. Confirmo FZE does not pay or receive third-party inducements, rebates, or other monetary benefits that would create a conflict of interest or compromise its duty of best execution.

7. Custody and safeguarding of client assets

In compliance with VARA's Asset Safeguarding standards, all client fiat funds and virtual assets held with Confirmo FZE are kept strictly separate from the company's own operational capital, in designated omnibus client accounts and segregated wallet structures. Confirmo FZE does not lend, pledge, re-hypothecate, or otherwise use client virtual assets or funds for its own account, operations, or investments without the client's explicit prior written consent.

Confirmo FZE does not hold client virtual assets directly. Client virtual assets are held by a third-party custodian.

8. Data privacy and whistleblowing

Confirmo FZE processes personal data in line with applicable UAE data protection requirements, as set out in Annexure D – Confidentiality and Data Protection Policy.

Confirmo FZE maintains a whistleblowing mechanism that lets employees report concerns about misconduct or breaches confidentially, without fear of retaliation. This is a group-wide reporting channel; concerns can be reported to [email protected].

9. Client referrals and third-party arrangements

Confirmo FZE does not currently operate any referral or introducer arrangements for UAE clients.

10. Risk warnings

Virtual assets are subject to high market risks, extreme price volatility, and potential complete loss of capital. Virtual asset transactions are final and irreversible.

Before transacting with Confirmo FZE, clients should understand the core risks involved. Virtual assets exhibit extreme price volatility driven by sentiment, global market dynamics, liquidity changes, and regulatory shifts, and past performance doesn't indicate future results. Transactions executed on distributed ledgers are permanent and irreversible once confirmed on-chain, so an erroneous or accidental transfer cannot be reversed by Confirmo FZE or by VARA. Virtual assets are not legal tender in the UAE, unless specifically designated as fiat-backed stablecoins under UAE regulatory standards, and they are not covered by central bank or investor compensation schemes. The underlying networks are also exposed to cyberattacks, software bugs, smart contract vulnerabilities, network forks, and outages beyond Confirmo FZE's control, and during periods of extreme volatility or network congestion, market illiquidity can affect execution speed, pricing, or the platform's ability to process transactions promptly.

11. Senior management and board disclosure

Neither Confirmo FZE nor any member of its Board of Directors or Senior Management has been subject to any criminal convictions, regulatory enforcement actions, or disqualification proceedings in the United Arab Emirates or any international regulatory jurisdiction.

12. Complaints and contact information

Clients can submit formal complaints to [email protected]. Confirmo FZE acknowledges complaints within 48 hours and provides a formal written resolution within 15 business days. Unresolved complaints can be escalated directly to VARA.