Commercial and Client Relationship Policy

Purpose

This policy sets principles, guidelines and procedures for Swapo's relationship with its clients. The goal is to ensure ethical, transparent and responsible commercial practices that are consistent with the nature, size and complexity of the virtual asset services provided.

The policy also seeks to protect clients' interests, mitigate conduct risks, prevent conflicts of interest and ensure adherence to applicable law and regulation, in particular the rules of the Central Bank of Brazil.

Principles

Swapo's commercial conduct must follow these principles:

• Transparency in the information given to clients.
• Good faith and loyalty in the commercial relationship.
• Suitability of the services to the client's profile.
• Clarity about the risks inherent to virtual assets.
• Equitable, non-discriminatory treatment.
• Compliance with anti-money laundering and counter-terrorist financing rules.
• Respect for personal data protection law.

Audience and eligibility

The services are intended for individuals and legal entities, according to Swapo's business strategy, who are previously registered and approved under the internal client identification (KYC) and, when applicable, company identification (KYB) procedures.

Only clients who meet the following conditions may be served:

• They have satisfactorily completed the identification and registration verification process.
• They expressly accept the contractual terms and conditions of the services.
• They are not subject to legal, regulatory or internal restrictions.
• They do not appear on restricted or sanctions lists, as applicable.

Swapo may restrict service to certain client profiles, products or jurisdictions, based on an assessment of regulatory, operational or reputational risk.

Client information

The policy requires that clients have clear, advance access to relevant information about:

• The nature and characteristics of the services provided.
• The rights and duties of the parties.
• The fees and any applicable charges.
• The risks associated with virtual asset transactions.
• Swapo's limitations and responsibilities.

This information must be understandable, suited to the client's profile and must not be misleading.

Promising, guaranteeing or suggesting future returns, publicizing expectations of gains, and promotional language that may mislead the client about risks are prohibited. The policy requires Swapo to act in an informational and operational capacity, without investment advice.

Pricing and compensation

The policy establishes that Swapo:

• Does not set its own prices for virtual assets.
• Informs the client in advance of the intermediation or service fees charged.
• Ensures that costs are transparent and properly itemized.

The policy also establishes that Swapo's compensation is not tied to the performance of the assets traded.

Service and complaints

The policy provides for service channels consistent with the size and nature of the operations, which may include electronic service through the digital platform, service by e-mail or other electronic means, and specific operational support channels.

Service must observe courtesy and professionalism, recording and tracking of requests, reasonable response times and internal escalation of complex requests.

For complaints, the policy provides for formal procedures for intake and recording, analysis and response, identification of recurring causes and adoption of corrective measures, when necessary. Whenever possible, complaints must be handled independently of the commercial areas.

Conflicts of interest and confidentiality

To identify, prevent and mitigate conflicts of interest in client relationships, the policy provides for:

• Segregation of duties between commercial and operational areas.
• A ban on the use of inside information.
• A specific conflict of interest policy, when applicable.

No employee is authorized to prioritize their own interests or those of third parties to the detriment of clients' interests.

In its relationship with clients, Swapo must comply with the LGPD (Brazil's General Data Protection Law), the internal privacy and information security policies, and the duty of confidentiality of client information. Data must be used only for legitimate purposes related to the provision of the services.

Communication and advertising

All commercial or institutional communication must:

• Be truthful, clear and not misleading.
• Respect the applicable regulatory limits.
• Not suggest guarantees, absolute safety or financial return.

Advertising materials must be reviewed in advance, when applicable, to ensure regulatory compliance.

Training, monitoring and review

Employees involved in client relationships must receive training on this policy, know the limits of commercial conduct and observe ethical standards and professional conduct. Non-compliance with the policy may result in internal disciplinary measures.

Swapo must periodically monitor its commercial and client relationship practices and may review procedures, update training and adjust controls, as necessary.

The policy must be reviewed periodically, in accordance with internal governance, whenever there is a relevant change in the business model and as a result of applicable regulatory changes.

The policy takes effect on the date of its approval by Senior Management and must be observed by all employees, officers and third parties involved in Swapo's activities.

Legal basis

• Law No. 14,478/2022.
• Central Bank of Brazil regulation applicable to virtual asset service provider companies.
• Law No. 13,709/2018 (LGPD).

About this version

Public version of the document “Commercial and Client Relationship 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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