Chapter 22 Information Disclosure Policies and Procedures
The purpose of this Information Disclosure Policies and Procedures ("the Disclosure Policy") is to ensure that the Company discloses all necessary information to its shareholders and relevant stakeholders clearly, correctly, and in an orderly manner. This will enable them to obtain a comprehensive view of the overall performance and financial position of the Company. The Disclosure Policy aims to comply with all applicable laws, regulations, rules, and directives, including the Market Conduct Rulebook and other Rulebooks applicable to the VASP.
I. Scope
This Disclosure Policy applies to all employees, directors, officers, and any other representatives of the VASP.
II. Disclosure Principles
a. The Company shall ensure that all disclosed information is accurate, clear, timely, and relevant.
b. The Company shall disclose information in accordance with all applicable laws, regulations, rules, and directives.
c. The Company shall maintain an updated website containing all required information for public disclosure.
III. Website Disclosures
a. The VASP's website shall include all information required to be disclosed to the public in accordance with all applicable laws, regulations, rules, and directives, including but not limited to:
i. Licence details and authorised VA activities whereas the Company shall publish the licence number issued by VARA and also VA activities the Company is licenced by VARA to carry out in the Emirate (including any restrictions stated by VARA as a condition of the licence and the validity period of the licences.
ii. The Company shall publish the names of all responsible individuals iii. The Company shall publish a detailed description of all material risks associated with the virtual assets including but not limited to a specific statement that virtual assets:
1. may lose their value in part or in full and are subject to extreme
volatility at times;
2. may not always be transferable and some transfers may be
irreversible;
3. may not be liquid;
4. some transactions are not private and may be recorded on
public DLTs; and
5. may be subject to fraud, manipulation, theft, including through
hacks and other targeted schemes and may not benefit from
legal protections.
iv. Virtual Assets standard when applicable.
v. Complaints handling channels and procedures.
vi. And additional public and client disclosure requirements pursuant to VARA’s Rulebooks when applicable.
b. The VASP's website shall be regularly updated to ensure the accuracy and relevance of the disclosed information.
IV. Board Responsibilities
a. The Board has established and will maintain effective Disclosure Policy. b. The Board shall periodically review the Disclosure Policy to ensure and procure its compliance with the best practices in the Virtual Asset industry.
c. The Board shall designate a responsible person to oversee the implementation and adherence to the Disclosure Policy.
V. Monitoring and Review
a. The designated responsible person or team shall monitor the implementation of the Policy and report any non-compliance to the Board.
b. The Board shall take appropriate action to address any identified non compliance with the Policy.
VI. Policy Updates
This Policy shall be reviewed and updated periodically, or as required by changes in applicable laws, regulations, rules, and directives. Any updates to the Policy shall be communicated to all relevant stakeholders.