Description of virtual asset services

Purpose and scope

This document describes the virtual asset services provided by Swapo and sets out their operational scope, Swapo's responsibilities, the limits of its activity and the activities it does not provide.

Swapo operates in the intermediary category and offers exclusively the services described here. The services are intended for individuals and legal entities and are subject to eligibility criteria, the internal policies on preventing money laundering and terrorist financing, and the applicable rules of conduct and client protection.

Providing any service not covered by this document is prohibited without prior review of this description and compliance with the applicable regulatory duties, including prior notice to or prior authorization from the Central Bank of Brazil, as the case may be.

Intermediation of purchases and sales

Swapo intermediates the purchase and sale of virtual assets between its clients and partner liquidity providers or trading platforms, domestic or foreign, as applicable. The flow of an order is as follows:

• The client, previously registered and approved in the identification procedures (KYC), submits the purchase or sale order through the channels Swapo makes available.
• Swapo checks that the order complies with operational, regulatory and risk limits.
• The order is forwarded to the partner liquidity provider or platform for execution.
• After execution, the virtual asset is transferred according to the client's instructions, subject to the operating model adopted.

Responsibilities of Swapo and the client

Swapo is responsible for:

• Receiving, validating and forwarding client orders.
• Performing registration, regulatory compliance and anti-money laundering checks.
• Recording transactions and keeping the information required by the applicable regulations.
• Making the notices and reports to the competent authorities, when required.

The client is responsible for:

• Defining the terms of the purchase or sale order.
• Correctly indicating the destination or source wallet for the virtual assets.
• Providing truthful, complete and up-to-date information.

Service limits and risks

• Swapo does not guarantee liquidity or the full execution of orders.
• Swapo does not assume market risk on behalf of the client.
• No credit, financing or leverage is granted.

Virtual asset services involve inherent risks, including market, technological, operational, regulatory and third-party risks. The document provides for internal policies and procedures to mitigate them, without removing the client's responsibility for making decisions and for assuming the risks of the transactions the client carries out.

Price formation

Swapo does not set its own prices for virtual assets. The document provides that it only passes on to clients the quotes supplied by third-party liquidity providers or trading platforms, transparently and without discretionary interference.

No custody

Swapo declares that it does not provide virtual asset custody services and that it does not, under any circumstances, hold exclusive or unilateral control of the private keys associated with its clients' virtual assets.

Virtual assets are transferred directly to the wallets indicated by the client or held in the custody of independent third parties, according to the client's express instructions.

Virtual asset transfers

Swapo enables the transfer of virtual assets between wallets, according to the client's instructions and subject to the applicable operational, regulatory and anti-money laundering limits.

Swapo does not guarantee confirmation of the transaction on the underlying network and is not liable for delays or failures arising from the operation of the distributed networks used.

Activities Swapo does not provide

Swapo declares that it does not provide, directly or indirectly, the following services:

• Granting of credit, financing or loans, in fiat currency or in virtual assets.
• Discretionary management of clients' virtual assets or funds.
• Offering of products or services with a promise, guarantee or expectation of returns.
• Issuance of virtual assets, its own or third parties'.
• Intermediation of securities, within the meaning of the applicable law.
• Activities not provided for or not authorized by the regulations in force.

Review

This description must be reviewed whenever there is a relevant change in the scope of Swapo's activities, subject to the duty to give prior notice to or obtain authorization from the Central Bank of Brazil, as required by the applicable regulations.

Legal basis

• Law No. 14,478 of December 21, 2022.
• BCB Resolution No. 519/2025 and other applicable rules of the Central Bank of Brazil.

About this version

Public version of the document “Detailed Description of Virtual Asset Services”, 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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