Policy Document: Segregation of Company and Client Funds

1. Purpose

The purpose of this policy is to ensure the proper segregation of company funds and client funds at CoinPort Pty Ltd (hereinafter referred to as “the Company”). This policy aims to protect client assets, maintain trust, and comply with relevant regulatory requirements.

2. Scope

This policy applies to all employees, officers, and agents of the Company, and covers all financial transactions involving company and client funds.

3. Definitions

Company Funds: Financial assets owned by CoinPort Pty Ltd, including operational capital, profits, and any other monetary resources belonging to the Company.

Client Funds: Financial assets deposited by clients into their accounts with CoinPort Pty Ltd, including cryptocurrency holdings and fiat currency deposits.

Segregated Accounts: Separate bank or digital wallets maintained to hold company funds and client funds, ensuring that there is no commingling of assets.

4. Policy Statements

4.1 Segregation of Funds The Company shall maintain segregated accounts for company funds and client funds. These accounts shall be distinct and separate to ensure that there is no commingling of assets.

Client funds shall be deposited into and withdrawn from client accounts only. Under no circumstances shall client funds be used for company expenses or any other purposes unrelated to the clients’ transactions.

4.2 Account Management The Company shall open and maintain distinct bank accounts and digital wallets for company funds and client funds.

Client funds shall be held in trust accounts or equivalent accounts that provide legal protection for client assets. Regular audits and reconciliations shall be conducted to ensure the accuracy and integrity of the segregated accounts.

4.3 Access and Authorization Access to segregated accounts shall be restricted to authorized personnel only. The Company shall implement stringent internal controls to prevent unauthorized access or misuse of funds.

All transactions involving segregated accounts shall require dual authorization to enhance security and reduce the risk of fraud.

4.4 Reporting and Transparency The Company shall provide clients with regular statements detailing the balance and activity in their accounts.

The Company shall maintain transparent records of all transactions involving segregated accounts and make these records available for audit and regulatory review.

4.5 Compliance and Monitoring The Company shall comply with all relevant legal and regulatory requirements related to the segregation of funds.

Regular internal audits and third-party audits shall be conducted to ensure compliance with this policy.

Any discrepancies or violations of this policy shall be reported immediately to the senior management and rectified promptly.

4.6 Contingency Planning The Company shall establish a contingency plan to protect client funds in the event of insolvency, bankruptcy, or any other financial distress.

The contingency plan shall include measures to ensure the prompt return of client funds and minimize disruption to clients.

5. Responsibilities

Chief Financial Officer (CFO): Responsible for overseeing the implementation and compliance of this policy, including the management of segregated accounts and ensuring regular audits.

Compliance Officer: Responsible for monitoring adherence to legal and regulatory requirements and reporting any compliance issues. Internal Audit Team: Responsible for conducting regular audits of segregated accounts and reporting findings to senior management.

6. Review and Amendments

This policy shall be reviewed annually or more frequently if necessary to ensure its continued relevance and effectiveness. Any amendments to this policy shall be approved by the Board of Directors.

7. Approval

This policy has been approved by the Board of Directors of CoinPort Pty Ltd and is effective as of 1st July 2022.

Approved by: Peter Cooney Director 1st July 2022

For any questions or clarifications regarding this policy, please contact the Compliance Officer.

CoinPort Pty Ltd Level 2, 696 Bourke St, Melbourne VIC 3000 Phone 1300 902 595 https://www.coinport.com.au