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: whistleblower@wadzpay.com.
(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)].