Statement On Digital Payment Token (DPT) Listing Policies

STATEMENT ON DIGITAL PAYMENT TOKEN (DPT) LISTING POLICIES

This Statement on Digital Payment Token (DPT) Listing Policies (this “Statement”) is intended to provide greater clarity and transparency regarding the listing policies and procedures established by Moomoo Financial Singapore Pte. Ltd. (“we”) for evaluating Digital Payment Tokens (DPT) supported on our platform.

To make a more informed assessment, this Statement should be reviewed prior to engaging in any Digital Payment Token (DPT) Services we provide.

1. EVALUATING PROSPECTIVE DIGITAL PAYMENT TOKENS (DPT)

1.1 Digital Payment Token (DPT) Admission and Review Committee

To evaluate prospective Digital Payment Tokens (DPT) that we intend to support, our policies and procedures establish a Digital Payment Token (DPT) Admission and Review Committee comprising certain members of senior management (the “Committee”) to oversee the listing process.

1.2 Digital Payment Token (DPT) Listing Assessment

We have established a set of criteria to evaluate the suitability of any Digital Payment Token (DPT) for inclusion on our Platform. The Committee has primary responsibility for administering the Digital Payment Token (DPT) evaluation framework in accordance with our policies and procedures. The assessment covers various categories (such as commercial, governance, technical, and legal), including:

(a) the background of management, developers, or known key members of the Digital Payment Token (DPT);
(b) the regulatory status of the Digital Payment Token (DPT) in Singapore and its associated impact;
(c) the market conditions of the Digital Payment Token (DPT) (e.g., market capitalization, supply, demand, liquidity, volatility);
(d) the token configuration of the Digital Payment Token (DPT) (e.g., underlying technology, token allocation plan);
(e) the governance risks of the Digital Payment Token (DPT) (e.g., governance framework, consensus mechanism);
(f) the legal and compliance risks associated with the Digital Payment Token (DPT) and its issuer (e.g., regulatory compliance, legal opinions, litigation history);
(g) the enforceability of any rights extrinsic to the Digital Payment Token (DPT) (e.g., rights to any underlying asset, contracts and agreements);
(h) the reputational status of the Digital Payment Token (DPT);
(i) cybersecurity and the technical aspects of the underlying network (e.g., network security, security protocols, incident response); and
(j) the purpose and utility of the Digital Payment Token (DPT) (e.g., token use case, development roadmap).

2. PERIODIC REVIEWS OF SUPPORTED DIGITAL PAYMENT TOKENS (DPT)

2.1 Periodic Review of Supported Digital Payment Tokens (DPT)

Supported Digital Payment Tokens (DPT) are reviewed periodically in accordance with our policies and procedures. The general timeline for such reviews is biannual, but ad hoc reviews may be conducted if we become aware of any material changes that could affect the prevailing assessment of the Digital Payment Token (DPT).

2.2 Periodic Review Assessment

The periodic review assessment primarily determines whether there have been material changes since the previous evaluation that may impact the decision to continue making the Digital Payment Token (DPT) available on our platform. The assessment may consider, without limitation, the following factors:

(a) whether the Digital Payment Token (DPT) continues to meet the token admission criteria set out in this Policy;
(b) any material changes to the Digital Payment Token (DPT) (e.g., hard fork events);
(c) any specific events or circumstances involving the issuer or the Digital Payment Token (DPT) that may affect its eligibility;
(d) any legal or regulatory action, or any change in the legal or regulatory status of the Digital Payment Token (DPT);
(e) any adverse news concerning the Digital Payment Token (DPT);
(f) any complaints received from users;
(g) the trading performance of the Digital Payment Token (DPT) on our platform and on other service providers
(h) any hacking or security incidents involving the Digital Payment Token (DPT).

3. SUSPENDING, DELISTING, AND/OR CEASING SUPPORT FOR DIGITAL PAYMENT TOKENS (DPT)

3.1 Suspension, Delisting, or Cessation of Support

(a) Unless otherwise stated, if we support a Digital Payment Token (DPT) in connection with any Digital Payment Token (DPT) services, we will generally seek to continue such support. However, you should be aware that we retain sole and absolute discretion to modify, suspend, delist, or cease support for any Digital Payment Token (DPT) at any time, with or without notice. Such decisions may arise from our periodic assessments and be made in accordance with our internal policies and procedures. We may, without limitation, continue to offer limited services or cease all related support entirely.

(b) The following non-exhaustive list sets out factors that may influence our decision to cease support for a Digital Payment Token (DPT):

(i) whether the Digital Payment Token (DPT) falls within the definition of a “Digital Payment Token” under the Payment Services Act 2019 of Singapore;
(ii) unusual price movements or high spreads observed on our platform or other reputable trading platforms;
(iii) compromise or defects in the Digital Payment Token (DPT) ’s blockchain or underlying technology;
(iv) discontinuation of support or maintenance by upstream providers;
(v) complaints received from users or other parties;
(vi) allegations of fraud;
(vii) involvement in illegal activities in any jurisdiction;
(viii) suspected price manipulation by the issuer;
(ix) changes to the development team that materially affect the Digital Payment Token (DPT) or related products;
(x) prolonged illiquidity;
(xi) prolonged inactivity (i.e., no orders recorded);
(xii) hard forks that render continued support infeasible;
(xiii) decline in market capitalization below an acceptable threshold;
(xiv) daily average transaction volume below USD 1,000,000 for more than 30 calendar days;
(xv) issuer’s failure to promptly and adequately respond to material crises, such as security breaches or misinformation;
(xvi) activities by the issuer that harm our reputation or adversely affect users;
(xvii) unresolved breaches of our listing rules within 14 calendar days; and/or
(xviii) failure to continue satisfying our token admission criteria.

3.2 Process for Suspending, Delisting, or Ceasing Support

(a) If we determine to cease or provide limited support for a Digital Payment Token (DPT), we may, where appropriate and practicable, take the following steps:

(i) notify you and the relevant regulatory authorities of our decision and, where appropriate, the reasons;
(ii) inform you of the effective date and time for cessation;
(iii) notify you of your rights and available options regarding the affected Digital Payment Token (DPT) prior to the cessation of support;
(iv) inform you of the potential consequences of inaction, including possible unilateral sale or conversion of the Digital Payment Token (DPT) by us or possible cost associated with safeguarding Digital Payment Token (DPT); and
(v) provide you with updates as the situation evolves, where applicable.

(b) We will generally use commercially reasonable efforts to provide you with prior written notice before ceasing or providing limited support for a Digital Payment Token (DPT). Where such notice is provided, a specified window may be granted to sell, convert, or transfer your Digital Payment Token (DPT) (where supported). If you do not act within the specified period, we reserve the right to take appropriate action at our sole discretion, which may include the unilateral sale or conversion of the Digital Payment Token (DPT) at the prevailing market rate and subject to any applicable fees, or the safekeeping Digital Payment Token(s) at your own risks and costs.

You should be aware that we shall not liable for any loss (including indirect or consequential loss), cost or damage of any kind incurred or suffered by you or any other person due to the Digital Payment Token(s) not being liquidated before the Delist Date unless such loss, cost or damage is caused by our fraud, wilful misconduct or gross negligence.

You should be aware that not all rights (i.e., to sell, convert, or transfer) may be made available in every case—particularly where transfer functionality is not supported.

(c) You should also be aware that it may not always be practicable to provide prior written notice. In such cases, we will use commercially reasonable efforts to notify you as soon as practicable. Where notice is not possible, we may still take actions deemed necessary or appropriate in our sole discretion, including the unilateral sale or conversion of the affected Digital Payment Token (DPT)at the time support is ceased or the safekeeping of Digital Payment Token (DPT) at your own risks and costs at the time we cease support for such Digital Payment Token (DPT).

4. HOW WE ADDRESS THE RISK OF UNFAIR OR DISORDERLY TRADING

4.1 Management of Risks of Unfair or Disorderly Trading

We endeavour to maintain a fair, orderly, and transparent Platform. To address the risk of unfair or disorderly trading, we have implemented policies and procedures that include the following:

(a) We may, in our sole discretion, reverse, cancel, modify, or disregard any Order or Transaction if:

(i) we believe it was placed by a User engaged in abusive or improper conduct (e.g., market manipulation, fraud, exploitation of platform vulnerabilities); or
(ii) the Transaction is an Erroneous Transaction;

(b) All Users are granted equal access to the Platform and Services. We do not provide or permit preferential or prioritised access to any User.

(c) In the event of technical issues preventing or impairing the Order placement/cancellation or Platform access, we may, in our sole discretion:

(i) disable or suspend any Digital Payment Token (DPT) services;
(ii) reverse, cancel, modify, or disregard Orders and/or Transactions;
(iii) suspend new Order placement;
(iv) suspend Transaction settlement;
(v) suspend Account access; and/or
(vi) suspend access to the Platform, Services, or related systems.

(d) We have implemented and enforce rules strictly prohibiting:

• false trading
• market manipulation
• dissemination of false or misleading information
• fraudulent, deceptive, or manipulative conduct

(e) We may, at any time and in our sole discretion, freeze and/or liquidate funds or Digital Payment Token (DPT) in a User’s Account if we suspect that the Account or Services are being used in a fraudulent, unlawful, or unauthorised manner.

Please refer to our Client Agreement for further details on measures implemented to address such risks.

5. HOW WE EFFECT SETTLEMENT OF DIGITAL PAYMENT TOKEN (DPT) TRANSACTIONS

5.1 Finality of Transactions

Generally, once we issue confirmation that a transaction has been entered into, such Transaction shall be deemed final. However, you acknowledge that we retain the right to reverse, cancel, modify, or disregard Transactions under certain circumstances, including those set out in this Statement and the Client Agreement.

5.2 Settlement

If you have transferred to us the full Settlement Amount under a Transaction, we will use reasonable efforts to promptly credit your Account with the corresponding funds or Digital Payment Token (DPT) (as applicable).

If we fail to effect settlement, we will generally re-attempt to do so as soon as reasonably practicable. Where such settlement is not possible due to circumstances beyond our control, we may, in our sole discretion, take such steps as we deem appropriate, including delaying settlement until the relevant circumstances are resolved.

For more information, please refer to our Client Agreement.

6. CONFLICTS OF INTEREST IN SUPPORTING CERTAIN DIGITAL PAYMENT TOKENS (DPT)

6.1 Management of Conflicts of Interest

Conflicts of interest may arise during our evaluation of whether to support a Digital Payment Token (DPT). We are committed to identifying, managing, and mitigating such risks through effective policies and procedures, including:

(a) segregation of risk and commercial functions to ensure appropriate independence in the listing assessment process; and

(b) in situations where:

(i) we receive any incentive from the issuer of a Digital Payment Token (DPT) or any third party; and/or
(ii) the issuer is a related or affiliated entity,

such conflicts will be reviewed and assessed by the Committee in accordance with our internal policies and procedures. Following review, appropriate mitigation measures may be implemented.

7. ADDITIONAL DISCLAIMERS

7.1 No Guarantees Regarding Digital Payment Token (DPT)s Listed

While we have established internal policies and criteria for evaluating Digital Payment Token (DPT), you acknowledge and agree that:

(a) our decision to support any Digital Payment Token (DPT) does not constitute or imply any form of endorsement, approval, or disapproval of the Digital Payment Token (DPT), including but not limited to its integrity, security, functionality, or underlying technology. All risks associated with Digital Payment Tokens (DPT) and the trading thereof continue to apply notwithstanding our decision to support a particular Digital Payment Token (DPT);

(b) we may rely, in whole or in part, on publicly available information or representations made by third parties not under our control. We do not make any representation or warranty, express or implied, as to the accuracy, completeness, timeliness, authenticity, or reliability of such information

(c) any views or assessments we express regarding the legal characterisation of a Digital Payment Token (DPT) are limited to applicable financial services laws and regulations under Singapore law, and such characterisations may differ under the laws or regulations of other jurisdictions; and

(d) under no circumstances shall we be responsible or liable to you for any direct, indirect, incidental, special, consequential loss or damage (including without limitation any loss of profits, business, revenue, or opportunities) arising out of or in connection with any reliance on third-party information used by us in the evaluation or ongoing support of any Digital Payment Token (DPT).

7.2 No Guarantee of Full Service Support

If we decide to support a Digital Payment Token (DPT), you should be aware that support may be limited in scope, and not all Digital Payment Token (DPT) services may be available. It is your sole responsibility to determine the extent of support before using our services.

For example:

(a) we may support only trading, but not deposits/withdrawals;
(b) we may support deposits/withdrawals only for specific networks;
(c) we may support only certain network versions or configurations.