Market Conduct Statement

1. COMMITMENT TO INTEGRITY AND MARKET ETHICS

At World Golden Gate Virtual Assets Broker & Dealer Services L.L.C (WGG), market integrity is not just a regulatory obligation — it is a foundational principle. As a broker-dealer regulated by the Dubai Virtual Assets Regulatory Authority (VARA), we uphold the highest standards of fair dealing, regulatory compliance, and ethical conduct in all our trading operations.

Our Market Conduct Statement outlines how we ensure transparent and lawful virtual asset trading, promote confidence in the ecosystem, and protect the interests of all participants.

2. WHAT IS MARKET CONDUCT?

Market conduct covers the principles and practices that govern how market participants, including broker-dealers like WGG, interact with clients, counterparties, and the broader virtual asset ecosystem. It includes rules on fair trading, abuse prevention, client protection, and the proper handling of material information.

3. FAIR, TRANSPARENT, AND LAWFUL TRADING

WGG facilitates spot and over-the-counter (OTC) trading only. We do not offer custody, portfolio management, or financial advisory services.

All transactions executed through WGG are:

• Self-directed by the client,

• Transparent in pricing, and

• Executed fairly with no preferential treatment or discrimination.

We ensure:

• Full clarity on trading terms,

• Honest communication with clients, and

• Strong internal systems to prevent misconduct.

4. PROHIBITED MARKET PRACTICES

WGG maintains a strict zero-tolerance policy for unethical, manipulative, or unlawful conduct. The following practices are strictly forbidden:

• Market Manipulation: Including spoofing, wash trading, quote stuffing, or pump-and-dump schemes.

• Insider Trading: The use or misuse of confidential or material non-public information.

• Abusive Trading: Such as churning, layering, or front-running client orders.

• Fraud or Misrepresentation: Deliberate misinformation, unauthorized access, or unethical inducements.

Violations result in internal disciplinary measures and, where necessary, reporting to VARA or other competent authorities.

5. EMPLOYEE CONDUCT AND TRADING RESTRICTIONS

WGG personnel are subject to:

• Personal trading restrictions, including blackouts and approval requirements;

• Prohibitions on misuse of insider information; and

• Annual training on ethical behavior and market conduct.

These controls are designed to prevent personal benefit from client transactions and ensure impartiality in all dealings.

6. BEST EXECUTION STANDARDS

WGG follows robust procedures to achieve best execution on all trades by considering:

• Price competitiveness,

• Speed and likelihood of execution, and

• Order type and venue selection.

We do not operate a public order book. For OTC transactions, WGG:

• Provides pre-trade price quotations,

• Discloses spreads and fees transparently, and

• Ensures post-trade execution summaries are available to clients upon request.

7. MARKET SURVEILLANCE AND MONITORING

We employ real-time surveillance systems supported by blockchain analytics tools (such as Elliptic) to detect and prevent:

• Irregular trading patterns,

• Suspicious counterparties, and

• Transactions linked to financial crime.

All trading activity is logged and retained for a minimum of eight (8) years, in line with regulatory retention obligations.

8. LIQUIDITY AND RISK MANAGEMENT

WGG maintains operational resilience through:

• Liquidity reserves covering at least 50% of client-related positions,

• Counterparty diversification, and

• Regular stress testing of market conditions and system vulnerabilities.

We employ structured OTC risk protocols to manage large trade exposures and reduce execution slippage.

9. CYBERSECURITY AND DATA PROTECTION

To protect client data and operational integrity, WGG enforces:

• Military-grade encryption,

• Multi-factor authentication (MFA) for internal and client systems,

• Ongoing vulnerability assessments and penetration testing, and

• A comprehensive incident response plan with breach notification protocols.

10. GOVERNANCE AND REGULATORY ALIGNMENT

Our governance practices include:

• Annual third-party audits of compliance and technology (e.g., by PwC, Elliptic),

• Full AML/CFT compliance (KYC, KYT, travel rule adherence),

• Internal logs of all orders, client interactions, and trading exceptions, and

• Continuous alignment of internal policies with evolving VARA and UAE regulatory expectations.

11. WHISTLEBLOWING AND ETHICS REPORTING

WGG supports a culture of transparency. Staff and partners can report concerns via secure, confidential whistleblowing channels. We:

• Protect whistleblower identities to the extent permissible by law,

• Investigate all concerns promptly, and

• Cooperate fully with regulators when misconduct is suspected.

12. CLIENT CLASSIFICATION AND PROTECTION

We categorize clients (e.g., retail, qualified, institutional) based on regulatory standards and apply tailored protections and disclosures accordingly. All clients receive:

• Clear communication of trading risks,

• Access to support teams for clarification, and

• Encouragement to seek independent advice before engaging in high-risk trading.

13. COMPLAINTS AND DISPUTE RESOLUTION

Clients can raise complaints through our secure portal or via designated email channels. We ensure:

• Timely acknowledgment and resolution of issues,

• Fair escalation procedures, and

• Full cooperation with VARA or other authorities in any regulatory inquiry or dispute.

OUR COMMITMENT

WGG is built on a foundation of trust, ethical conduct, and regulatory alignment. Our market conduct is not merely policy — it is our promise to clients, counterparties, and the broader ecosystem.

We remain committed to fair dealing, transparent trading, and upholding market confidence across all our activities.

DISCLAIMER

This Market Conduct Statement is a summary for transparency purposes only and does not represent WGG’s complete internal policy documentation. Clients and regulatory parties seeking additional details may contact our Compliance Department at compliance@worldgoldengate.com