Code of Conduct Policy

1. Introduction

2. Scope

3. Ethical and Legal Compliance

4. Professional Conduct

5. Accountability and Reporting

6. Enforcement of VARA Regulations

7. Employee, Partner and Customer Acknowledgment

8. User Responsibilities

1.1 Commitment to Ethical Business Practices: At Fastex, we are committed to conducting our business operations in full compliance with the Virtual Assets Regulatory Authority (VARA)regulations and ethical business practices. Our core principles ensure the protection of clients, fair market behavior, and compliance with all relevant laws.

1.2 Scope and Objective: This Code of Conduct outlines Fastex’s expectations for ethical behavior and compliance with VARA’s standards for all employees, contractors, vendors, business partners interacting with our platform and all participants on their trading venue. It sets the standard for behavior and practices to maintain the highest levels of integrity and accountability in the virtual assets space.

1.3 Core Values: Fastex promotes

· Integrity in all dealings with clients, regulators, and stakeholders.

· Transparency in all business practices and communications.

· Security of client data and virtual assets.

· Compliance with all applicable laws, including AML, CTF, and KYC regulations.

2.1 Applies to All Participants: This Code applies to all employees, third-party vendors, contractors, affiliates, clients, business partners and all participants on the trading venue involved, including digital asset trading, custodianship, and related services.

2.2 Compliance with VARA Regulations: All employees, partners and customers are required to understand and adhere to VARA’s regulations, including, but not limited to, licensing, reporting, anti-money laundering (AML), counter-terrorism financing (CTF), and client protection standards.

3.1 Compliance with VARA and Applicable Laws: Fastex will comply with all VARA regulations regarding licensing, customer identification (KYC), transaction monitoring, and reporting. Failure to adhere to these regulations can result in disciplinary actions, including termination and legal repercussions.

3.2 Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF): Fastex implements comprehensive AML and CTF policies in line with VARA’s requirements:

· Customer Due Diligence (CDD): All clients must undergo thorough identification processes.

· Suspicious Activity Reporting: Employees must report any suspicious transactions or activities to the compliance department.

· Ongoing Monitoring: All transactions will be continuously monitored to detect any potentially illicit activities.

3.3 Data Protection and Privacy: Fastex is committed to ensuring the confidentiality of client information. Personal data must be processed in compliance with data protection laws and VARA’s requirements.

4.1 Market Integrity: Employees and partners must act in good faith and integrity at all times:

· Insider Trading: Employees with access to confidential or price-sensitive information may not engage in trading based on that information.

· Market Manipulation: Any attempt to manipulate or influence market conditions for personal gain is strictly prohibited

4.2 Client Treatment and Transparency: Fastex is committed to fair treatment of clients:

· Clear Communication: We will provide clear and honest information regarding fees, services, and potential risks.

· No Conflicts of Interest: Employees must avoid situations where personal interests could conflict with company interests or the interests of our clients.

4.3Anti-Bribery and Corruption: Fastex adheres to a strict anti-bribery policy. Offering or accepting bribes, gifts, or other forms of undue influence is prohibited.

5.1 Whistleblowing: Fastex has a whistleblower program where employees, partners and customers can report unethical behavior, breaches of the Code, or any potential violations of law without fear of retaliation. All reports will be taken seriously and investigated promptly.

· Fastex has a whistleblower program that allows employees and partners to report unethical behavior, breaches of the Code, or legal violations without fear of retaliation.

· All reports are taken seriously, investigated promptly, and handled with confidentiality.

· Employees are encouraged to follow the escalation process outlined in the Fastex Code of Conduct.

· No one can force actions that violate company policies, and concerns should be raised immediately if in doubt.

· Fastex commits to providing regular updates to whistleblowers on the status of their reports, ensuring transparency and demonstrating the company’s commitment to addressing all concerns thoroughly

· Fastex ensures that the whistleblower program is accessible to everyone, including employees, partners, and customers, facilitating easy reporting of any concerns or misconduct

5.2 Disciplinary Actions: Any violation of this Code may result in disciplinary actions, including but not limited to:

· Verbal and written warnings

· Suspension of privileges

· Termination of employment or partnerships

· Referral to regulatory authorities for legal violations

5.3 Compliance Audits: Fastex will conduct regular internal audits to ensure compliance with VARA and the company’s policies. Employees must cooperate fully with any audit procedures.

6.1 VARA License Compliance: Fastex is licensed and regulated under VARA and will take all steps to ensure that our business practices align with VARA’s ongoing requirements for virtual asset service providers.

6.2 Reportable Events and Breaches: All significant breaches of this Code or VARA’s regulations must be reported to the relevant authorities immediately. This includes activities such as:

· Non-compliance with AML/KYC regulations

· Breaches of data protection laws

· Fraudulent or unethical business practices

Fastex Acknowledges that:

VARA holds the authority to implement further remedies or disciplinary actions against participants on Fastex’s trading platform offering Exchange Services, as it deems necessary. It may also, at its sole discretion, authorize Fastex to enforce these additional measures, provided there is written consent.

Furthermore, VARA can mandate the suspension of trading any Virtual Asset if there are reasonable suspicions of non-compliance with Part III of the Exchange Services Rulebook. When such a suspension is enforced, VARA may set specific conditions for how and when the suspension can be lifted.

7.1 Acknowledgment of the Code: All employees, contractors, partners, customers must read, understand, and acknowledge their commitment to adhere to this Code. A formal acknowledgment will be required during onboarding and annually thereafter.

7.2 Ongoing Training: Fastex will provide mandatory training on VARA regulations, compliance, and ethics for all employees. Employees will be required to complete training upon hiring and periodically throughout their tenure.

At Fastex, we are committed to providing a safe, secure, and ethical environment for all users engaging in digital asset trading and related services. Our Code of Conduct for users ensures that all individuals using our platform act in accordance with our core values, fostering a trusted and compliant ecosystem. As a user of Fastex, you agree to the following principles and standards of behavior:

8.1 Compliance with Laws and Regulations: Users must comply with all applicable local and international laws, including those set by the Virtual Asset Regulatory Authority (VARA)and other relevant regulators. Users are responsible for understanding and adhering to VARA’s rules governing the trading and exchange of virtual assets, including rules on anti-money laundering (AML) and know your customer (KYC).

8.2 Honesty and Integrity: Users are expected to act honestly and ethically in all their interactions on the Fastex platform. This includes refraining from activities such as market manipulation, fraud, insider trading, or misrepresentation. Users must not engage in pump-and-dump schemes, spread false information, or engage in any activities that may harm the platform's integrity or other users' rights. This Code of Conduct grants Fastex the authority to implement or enforce various actions as necessary for each situation, including:

a. issuing warnings;

b. delivering reprimands;

c. providing training;

d. setting qualification minimums;

e. establishing remediation plans;

f. conducting compliance audits;

g. demanding restitution;

h. imposing contractually agreed penalties;

i. setting trading conditions;

j. enforcing trading prohibitions;

k. implementing trading suspensions and restrictions;

l. expelling participants;

 - canceling client orders and any pending instructions;

 - reporting breaches to VARA; and

 - making criminal referrals.

Clients agree to the Code of Conduct by utilizing Fastex's services and acknowledging the company's Terms of Use.

I acknowledge that I have read and been informed of the content, requirements, and expectations of the Fastex Code of Conduct Policy.

I understand that the Policy outlines Fastex’s commitment to ethical business practices, compliance with VARA regulations, and professional conduct standards. I agree to adhere to these principles, including integrity, transparency, security, and compliance with AML, CTF, and KYC requirements.

Please ensure you have thoroughly reviewed the Code of Conduct Policy before signing below

Employee Name:

_________________________________________________________________

Employee Signature:

____________________________________________________________________

Supervisor Signature:

____________________________________________________________________

Date: ________________________