Disclosures

Additional Disclosures 2023

(i) Conflict of Interest 

There are no identified conflict of interest arising out of WadzPay’s business  activities. 

(ii) Whistleblowing 

The Board of the Company is committed to maintaining the highest standards of  honesty, openness and accountability and recognise that all Directors and other  members of staff have an important role to play in achieving this goal. It is impossible to give an exhaustive list of the activities that constitute malpractice  but, broadly speaking, the Company would expect the staff to report the following: (i) Criminal offences; 

(ii) Failure to comply with legal obligations; 

(iii) Actions which endanger the health or safety of staff;  

(iv) Actions which are intended to conceal any of the above. 

It will not always be clear that a particular action falls within one of these categories,  and Directors and other employees must use their own judgement in this regard.  However, the Company would prefer staff to report their concerns rather than keep  them to themselves. If a report is made in good faith, then even if it is not confirmed  by an investigation, the initial concern will be valued and appreciated and staff will not  be liable to disciplinary action. If a false report is made, maliciously or for personal  gain, then disciplinary action may result. 

All reports can be submitted to: [email protected]

(iii) Referral Activities 

The Company does not refer or introduces its clients to other entities including, but not  limited, to other VASPs. 

(iv) Custody 

The Company uses BitGo to provide custody services and make sure all clients’  assets are segregated from the Company’s own assets. 

(v) Past Convictions or Prosecutions 

There were no past convictions or prosecutions of any members of the Company’s  senior management or Board in any jurisdiction. 

(vi) Virtual Assets Offering 

The Company currently offers BTC, ETH, USDC and USDT. Please refer to publicly  available data source such as CoinMarketCap for the information pertaining to each  Virtual Assets such as date of issuance, market captalisation and fully diluted value,  circulating 

supply, smart contract audit, and price changes. 

(vii) Pricing 

The Company’s system sends the rate enquiry to up to three (3) pre-identified virtual  asset exchanges simultaneously in real-time. The rates received from these three  exchanges are compared and shown to the customer to select, with the most  favourable conversion option marked as ‘recommended’. The order for the  transaction is placed with the exchange whose rate is opted by the customer.

(viii) Execution 

To be further Disclosed. [VARA requires a description of the Company's routing  practices, including if twenty percent [20%] or more of client orders are routed to any  liquidity source and if so, the identity of such source(S)]. 

(ix) The Company does not hold or maintain funds or Virtual Assets or provide  clearing services for other VASPs providing Broker-Dealer Services. 

(x) The Company will not hold assets on behalf of clients

Disclaimer: *WadzPay is a B2B technology provider. All regulated activities featured in WadzPay are conducted by licensed entities in applicable jurisdictions.