Liquidity Management Policy

Purpose

The policy establishes principles, guidelines, responsibilities and procedures so that Swapo maintains adequate liquidity to meet its operational and financial obligations in a timely and orderly manner, including in adverse scenarios.

It seeks to mitigate liquidity risks arising from the volatility of virtual assets, operational failures, dependence on third parties and market stress events.

Scope

The policy applies to:

• liquidity management in fiat currency;
• liquidity management in virtual assets, where applicable;
• Swapo's proprietary operations;
• financial and operational flows related to clients;
• relationships with liquidity providers, partners and critical third parties.

The policy was designed for the intermediary category and in proportion to Swapo's non-bank nature. It is not to be confused with bank asset and liability management policies.

Principles and references

• Sufficiency and availability of funds.
• Prudence and conservatism.
• Segregation between proprietary and client funds.
• Transparency and traceability.
• Proportionality to size and operating volume.
• Integration with risk management and business continuity.

As technical guidance, without altering the Brazilian regulatory framework, the policy draws on the principles of the BIS and the Basel Committee (BCBS) on liquidity and operational resilience, on IOSCO and CPMI-IOSCO recommendations, to the extent applicable, and on the practices of virtual asset service providers in the European Union, the United Kingdom and Switzerland.

Governance

Senior Management is responsible for approving the policy and its revisions, setting general liquidity guidelines, overseeing its management and deciding on extraordinary measures in stress scenarios.

Liquidity management is carried out by the Risk and Capital Officer, who monitors liquidity positions, manages cash flows and liquid assets, tracks internal limits and reports risk situations to Senior Management.

Sources and uses of liquidity

The main sources of liquidity are share capital, recurring operating revenue, balances at financial institutions and, where applicable, highly liquid assets. Swapo does not depend on raising funds from the public.

The main uses are payment of operational obligations, administrative and technology expenses, settlement of intermediated transactions, and tax and regulatory obligations.

Liquidity in reais, in virtual assets and with providers

In fiat currency, Swapo must maintain controls for minimum cash availability, daily tracking of inflows and outflows, segregation between proprietary and client funds, and adequate operating accounts. Internal minimum liquidity limits are set in a manner consistent with operating volume.

In virtual assets, where applicable, the policy provides for procedures to ensure sufficient liquidity to execute intermediated orders, avoid excessive concentration in certain assets, monitor dependence on liquidity providers and limit exposure to low-liquidity assets.

Liquidity providers must be selected on technical and reputational criteria, with formal contracts and defined service levels, monitoring of the quality and availability of liquidity, and diversification of providers whenever possible.

Monitoring, stress and contingency

Liquidity is tracked through internal indicators, such as available cash position, concentration by asset, dependence on critical third parties and significant changes in operating volume, which are analyzed periodically and reported to Senior Management.

In proportion to its size, Swapo conducts stress exercises on demand peaks, liquidity provider failures, adverse market events and temporary restrictions on access to financial systems. The results guide preventive adjustments.

Liquidity contingency plans may include a temporary cash reinforcement, adjustment of operating limits, temporary suspension or restriction of certain services and preventive communication to clients and authorities, where applicable.

Integration and training

Liquidity management is integrated with the Risk Management Policy, the Business Continuity Plan and the Internal Controls Policy. Personnel involved in financial and operational management receive training on the policy and its procedures.

Review and effective date

The policy is reviewed periodically and whenever there is a relevant change in the operating model, regulatory changes or relevant liquidity events. It takes effect on the date of its approval by Senior Management, must be observed by personnel, administrators and third parties involved in Swapo's activities, and must be kept up to date and available for supervision and inspection by the Central Bank of Brazil.

Legal basis

Law No. 14,478/2022, Central Bank of Brazil regulations and international best practices.

About this version

Public version of the document “Liquidity Management 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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