Asset Segregation Policy

Objective and scope

The policy establishes principles, guidelines, responsibilities and procedures to ensure the absolute legal, accounting, operational and asset separation between Swapo's own assets and funds and the assets, funds and amounts of clients, users or third parties that are under Swapo's safekeeping, administration or operational control, where applicable.

The purpose is to protect clients' interests, preserve asset integrity, mitigate operational and legal risks, prevent commingling of assets and ensure compliance with the regulatory framework for virtual asset service providers.

The policy covers financial assets, virtual assets, securities, balances, rights and receivables held in those conditions, as well as employees, administrators, service providers and partners involved in operational, financial, accounting and technology activities. Compliance with it is mandatory and an essential condition for carrying out Swapo's activities.

Principles

• Absolute separation between own assets and client assets.
• Client assets are unavailable to satisfy Swapo's obligations.
• Traceability and individualized identification of assets.
• Accounting and operational transparency.
• Protection of assets against the risks of insolvency, bankruptcy or enforcement.
• Compatibility with the operational and technological model adopted.

Funds in fiat currency

Client funds must be held in segregated bank accounts, separate from Swapo's operating and asset accounts, identified as third-party funds and periodically reconciled with internal records and bank statements.

It is prohibited to use client funds to:

• pay Swapo's operating expenses;
• secure its own obligations;
• make its own investments;
• grant credit or advances.

Virtual assets

Where applicable, clients' virtual assets must be held on a segregated basis, with:

• logical and/or physical separation between client wallets and Swapo's own wallets;
• individualized identification or identification by segregated groups, according to the operational model;
• a prohibition on using client assets for its own purposes;
• on-chain traceability of movements.

The policy requires technical and operational controls that make it possible to identify, at any time, the ownership and availability of each client's virtual assets.

Accounting records and access control

Swapo must maintain accounting records segregated between its own assets and those of clients, individualized records of client assets, periodic reconciliations among internal records, bank statements and on-chain records, and auditable documentation. Client assets are not part of Swapo's assets or liabilities for accounting purposes, unless a specific rule expressly requires it, without prejudice to legal segregation.

The policy provides for segregation of duties and access controls: restricted access to the systems that control client assets, least-privilege profiles, logs and audit trails, and multiple approvals for sensitive movements.

Insolvency, judicial reorganization or bankruptcy

In the event of Swapo's insolvency, judicial reorganization or bankruptcy, the policy establishes that:

• client assets remain legally segregated;
• those assets are not commingled with Swapo's assets;
• those assets may not be used to satisfy Swapo's creditors;
• Swapo must take measures for the return or transfer of the assets to clients, as applicable.

Monitoring and audit

The effectiveness of the segregation must be monitored continuously by the responsible area, subjected to internal audits and, where applicable, independent audits, and assessed within the risk and internal controls governance. Failures or deviations must be corrected immediately and reported to Senior Management.

Governance and training

Senior Management approves the policy, ensures its implementation, provides resources and oversees compliance with it. The Finance, Accounting, Operations, Technology and Compliance areas perform the controls, within their responsibilities.

Employees involved in moving or controlling assets receive periodic training on asset segregation, associated risks and regulatory obligations.

Review and effective date

The policy is reviewed at least once a year and whenever there are relevant changes to the business model, regulatory changes or relevant incidents. It takes effect on the date of its approval by Senior Management and must be complied with by administrators, employees and third parties involved in Swapo's activities.

Regulatory basis

• Law No. 14,478/2022;
• BCB Resolutions No. 519, 520 and 521;
• BCB Circular No. 3,978/2020;
• applicable rules of the National Monetary Council;
• COAF (Brazil's Financial Intelligence Unit) rules related to AML/CFT;
• prudential principles adopted by the Central Bank of Brazil for supervised institutions.

About this version

Public version of the document “Asset Segregation Policy”, dated September 21, 2026, which is part of the authorization request filed with the Central Bank of Brazil. Authorization has not been granted yet.

This text summarizes the internal document. Personal data (LGPD), monitoring parameters and technical details whose disclosure would undermine security, fraud prevention and anti-money laundering efforts have been omitted, as have terms subject to business confidentiality (BCB Resolution No. 520/2025, art. 52, § 2). This version does not replace the service agreement or the applicable regulations.

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