This Risk Disclosure Statement (“Statement”), provides you with information about some of the risks associated with Virtual Assets (VAs), access and use of the Services offered by Fuze. The information presented in this Statement is not comprehensive and you must make your own independent decision and should seek any advice that you consider necessary or desirable (including financial and/or legal advice) from independent advisers before you use any Services offered by Fuze. You use the Services at your own risk. Fuze may amend any portion of this Statement, at any time, without prior consent or notification by posting the revised version of the Statement with an updated revision date. Terms not otherwise defined in this Statement shall bear the same meanings attributed to them in the Terms of Service.

A. General Risks
Virtual Assets (referred to as VA or VAs), more commonly also known as Digital Assets or Cryptocurrency is a digital representation of value that functions as a medium of exchange, a unit of account, or a store of value, but it does not have legal tender status. VA are sometimes exchanged for U.S. dollars or other currencies around the world, but they are not generally backed or supported by any government or central bank. VA's represent a speculative investment and involve a high degree of risk. You should have the financial ability, sophistication/experience and willingness to bear the risks of an investment. Their value is completely derived by market forces of supply and demand, and they are more volatile than traditional currencies. The value of a VA may be derived from the continued willingness of market participants to exchange fiat currency for VA, which may result in the potential for permanent and total loss of value of a particular VA should the market for that VA disappear. The volatility and unpredictability of the price of VA and the risk of marker manipulation relative to fiat currency may result in significant loss over a short period of time. VA trading is extremely risky and You should not deal in VAs unless you understand their nature and the extent of your exposure to risk.
B. Regulatory Risk
The regulatory environment concerning VAs continues to develop. Legislative and regulatory changes or actions at the state, federal, or international level may adversely affect the use, transfer, exchange, and value of VAs or the Services. In addition, the VA markets and exchanges are not regulated with the same controls or customer protections available in other traditional forms of investment such as equity, option, futures, or foreign exchange investments.
You understand that ultimately it is your responsibility to make sure that you comply with any and all local regulations, directives, restrictions and laws in your place(s) of residence before using our Services. We do not permit the use of our Services by Users from a jurisdiction in which the use of our Services is not permitted (Restricted Jurisdictions). We are not offering or soliciting the use of our Services to any person located in any Restricted Jurisdiction or any other jurisdiction in which the specific use of our Services is prohibited by applicable laws.
C. Operational Risk
Transactions relating to VA's may not be private and may be recorded on public Distributed Ledger Technology. There can be no assurance that use of the Services will provide a positive return or profit, that significant losses will not be incurred, or that your objectives will be achieved. It is possible that you may lose a substantial proportion or all of your capital.
We strongly request and recommend our clients to conduct extensive research into the legitimacy of each individual VA before investing. The features, functions, characteristics, operation, use and other properties of the specific VA may be complex, technical, or difficult to understand or evaluate. The VA may be vulnerable to attacks on the security, integrity or operation. Some VA transactions will be deemed to be made when recorded on a public ledger, which is not necessarily the date or time that a transaction may have been initiated.
Any client money account maintained by Fuze may not be sufficient to cover all losses incurred by You. Any insurance maintained by Fuze for the benefit of its clients may not be sufficient to cover all losses incurred by clients. The nature of VA means that any technological difficulties experienced by Fuze may prevent the access of your VA.
Fuze engages third party service providers to enable custody of virtual assets and fiat. These third parties are not our affiliates or under our control. These third parties are Fireblocks and Tungsten Custody Solutions (for VA custody) & Zand Bank and Wio Bank (for fiat).
D. Cyber Risk
VA's may not always be transferable or transactions in VAs may be irreversible, and, accordingly, losses due to theft, fraudulent or accidental transactions may not be recoverable. The nature of digital currency may lead to an increased risk of fraud or cyber-attack. Any individual VA may change or otherwise cease to operate as expected due to changes made to its underlying technology, changes made using its underlying technology, or changes resulting from an attack. Malicious individuals, groups or organisations may attempt to interfere with the Platform in a variety of ways, including, but not limited to, malware attacks, denial of service attacks, coordinated attacks, account takeovers and submitting fake transactions (including spoofing) which could negatively affect the Services.
You can take the following measures to protect your keys and/or seed phrases from misuse or unauthorised access:
- Enable Two-Factor Authentication (2FA): This adds an extra layer of security by requiring a second verification step, such as a unique code sent to their mobile device.
- Secure Storage of Keys and Seed Phrases: Clients should use offline or hardware wallets designed specifically for storing virtual assets. Additionally, keys should be saved offline and never revealed in plaintext to anyone, ideally keys should be stored in lockers.
- Backup and Recovery: Keys and seed phrases should be regularly backed up. Clients should store backups in multiple secure locations, preferably encrypted and offline, to protect against physical loss or damage.
- Monitor Account Activity: Encourage clients to monitor their account activity regularly and report any suspicious transactions or unauthorized access to the VASP immediately.
E. Liquidity Risk
Virtual Assets may be riskier, less liquid, more volatile and more vulnerable to economic, political, market, industry, regulatory and other changes than other traditional asset and investment types. Under certain market conditions, you may find it difficult or impossible to liquidate a VA quickly at a reasonable price or you may be unable to liquidate at all.
F. No Insurance on Deposit
There are no deposit protection schemes that are applicable to the Services and your Account balances are uninsured unless you specifically obtain third party private insurance with respect to them. Your Account balance is at risk of total loss, from, among others things, security breaches (whether in respect of your Account(s) specifically or the Services generally), electronic, technological or systems failures (including book- or record keeping errors), and insolvency or bankruptcy, or equivalent formal proceedings, in respect of the Company. It is your responsibility to ensure that you use the correct address for any deposit, withdrawal, or transfer, and that the address you use is a valid address for the VA that you intend to transfer and that the Company accepts to provide its Services. Any inaccuracy in a specified address, or in the VAs that you attempt to transfer between addresses, may result in total loss of the VAs concerned.
We hold your assets in designated "client money accounts". These client money accounts are segregated from operational accounts and balances are maintained and reconciled against client liabilities at all times.

Cyber Risk

If you share your private keys, you run the risk of losing all your Virtual Assets. Transactions in VAs may be irreversible, and, accordingly, losses due to theft, fraudulent or accidental transactions may not be recoverable and the consequences could be irreversible. The nature of digital currency may lead to an increased risk of fraud or cyber-attack. Any individual VA may change or otherwise cease to operate as expected due to changes made to its underlying technology, changes made using its underlying technology, or changes resulting from an attack. Malicious individuals, groups or organisations may attempt to interfere with the Platform in a variety of ways, including, but not limited to, malware attacks, denial of service attacks, coordinated attacks, account takeovers and submitting fake transactions (including spoofing) which could negatively affect the Services.

You can take the following measures to protect your keys and/or seed phrases from misuse or unauthorised access:

Enable Two-Factor Authentication (2FA): This adds an extra layer of security by requiring a second verification step, such as a unique code sent to their mobile device.
Secure Storage of Keys and Seed Phrases: Clients should use offline or hardware wallets designed specifically for storing virtual assets. Additionally, keys should be saved offline and never revealed in plaintext to anyone, ideally keys should be stored in lockers.
Backup and Recovery: Keys and seed phrases should be regularly backed up. Clients should store backups in multiple secure locations, preferably encrypted and offline, to protect against physical loss or damage.
Monitor Account Activity: Encourage clients to monitor their account activity regularly and report any suspicious transactions or unauthorized access to the VASP immediately.

Fuze Ethics and Conduct Policy

1. Code of Conduct

As a company, we aim to operate with integrity and live by the Fuze values.

The Importance of Doing the Right Things
1. We are honest: We are honest and truthful in all of our professional and business relationships. We do not deliberately mislead or deceive others by misrepresentations, overstatements, partial truths, selective omissions, or any other means. We are honest about the services we provide; and the knowledge and experience we possess.
2. We have integrity: We demonstrate personal and professional integrity by always doing what is right. We do not sacrifice our integrity for expediency or unscrupulous practices. We are committed to acting for the absolute good in the interest of all we are engaged with.
3. We value loyalty: We are loyal to the company, our work colleagues, our clients, and our business partners. We safeguard our ability to make sound professional judgments by identifying and avoiding undue influences and conflicts of interest. We do not use or disclose information learned in confidence for personal advantage.
4. We are accountable: We have a strong sense of personal accountability for all of our decisions and undertakings. We are accountable for the risks we assess and take, ensuring they are carried out in a disciplined way, within our authority, and appropriate to our business area and activities. We take ownership of our work, mistakes, and behavior.
5. We are always fair: We are fair and just in all of our dealings. We treat all our colleagues with respect, courtesy, and fairness. We value actions, processes, and outcomes that are morally right and honorable and achieve equality.
6. We respect others: We understand the impact that our individual behaviors can have on other people and always want to take responsible action. We encourage and value the diverse mix of people, talents, and experiences in our company. We are caring, compassionate, and kind. We respect the intrinsic dignity of all people and the decisions made by others.
7. We are supportive and collaborative: We are inspired and driven by working with openness, trust, and collaboration. We support each other to achieve business and professional objectives. We manage and resolve conflicts by understanding the needs of others, engaging in a professional, respectful way, and working together to achieve core priorities.
8. We are proud of our reputation: We are always aware that our reputation and the morale of our people are dependent on our commitment to always doing the right thing. We are committed to building and protecting our company’s good reputation and the morale of our people. We take steps to correct and prevent inappropriate conduct.
9. We are ethical leaders: We are always aware that our reputation and the morale of our people are dependent on our commitment to always doing the right thing. We are committed to building and protecting our company’s good reputation and the morale of our people. We take steps to correct and prevent inappropriate conduct.
10. We are committed to excellence: We pursue excellence in all of our undertakings. We are committed to innovation, efficiency, and working collaboratively to achieve the best results for the company. We constantly endeavor to increase our proficiency and develop our expertise in all areas of our responsibility.
11. We are compliant with Laws, Regulations, and Standards: We ensure we understand and comply with all relevant laws and regulations in all of our business activities and concerned jurisdictions. We give full cooperation to our regulators and engage with them in a responsive, open, and honest way. We accept and comply with the company’s standards, policies, and procedures as well as the spirit in which they are intended. We are Compliant with Laws, Regulations, and Standards in the way we conduct our business.
Avoiding and Managing Conflicts of Interest
Conflicts of interest can arise in various business and personal situations. Early and effective management of conflicts of interest enables us to avoid legal and regulatory risks; and protect our integrity, our brand, and our reputation. Conflicts of interest can be avoided by:
1. Ensuring you are aware of what conflicts of interest are. Please reach out to your manager and/or the People and Compliance team if you have any queries.
2. Acting with integrity in all of your undertakings.
3. Incorporating considerations about conflicts of interest in all of your business activities.
4. Avoiding activities, situations, or relationships that may impair or appear to impair your professional judgment.
5. Seeking approval before you engage in outside business/ financial/personal relationships where there may be a risk of conflict of interest.
In assessing whether you have an actual, reasonably perceived or potential conflict of interest, you may ask yourself the following questions:
1. Could there be benefits for me now or in the future that may cast doubt on my objectivity?
2. Do I hold any personal or professional views or biases that may lead others to reasonably conclude that I am not the appropriate person to deal with a particular matter?
3. Have I received a benefit, gift, or hospitality from someone who stands to gain or lose from my proposed decision or action?
4. Is there a current personal, professional, or financial relationship or association of significance?
5. Would I, or anyone associated with me, benefit from or be detrimentally affected by my proposed decision or action?
6. Would our company’s reputation be enhanced or damaged as a result of the proposed decision or action?
Protecting Confidential Information
It is our responsibility to protect the security of all confidential or personal information entrusted to us by the company or our colleagues. The responsible use of confidential information fosters an environment of trust and confidence which we all value working in. Confidential information includes:
1. All company information that is not publicly available.
2. Any information that, if disclosed, might be useful to our competitors and harmful to the company, our customers, partners, or employees.
3. Any commercial or personal information entrusted to us by our partners, employees, and/or any other third party.
Confidential information must only be accessed and used when absolutely necessary for the purposes of your role and should not be shared with colleagues who do not need to access it for their roles.
When handling and using confidential information, you must exercise care and diligence by accessing and storing confidential information in line with our security and privacy policies. In particular, you must ensure that confidential information is communicated and transferred securely on proper platforms provided by the company.
Please be aware that as an employee of the company, you are subject to confidentiality obligations in relation to all company information you have access to. These obligations are contained in your employment contract and the employee non-disclosure agreement. We take any breach of these obligations very seriously, and appropriate action will be taken against those employees in breach. Where there is a need to share information with a third party, our standard form mutual non-disclosure agreement (“NDA”) must be signed by both the company and the third-party recipient of the information prior to any information being shared.
Data Protection
Data is valuable for innovation, solutions development, and as a driver for business excellence. As our activities entail large-scale processing of personal data, along with systematic monitoring of data subjects, any information related to an identified or identifiable person must be collected and processed in compliance with applicable data privacy laws.
You are required to be familiar with and adhere to our company’s internal guidelines relating to data protection.
Anti-Bribery and Corruption
We do not tolerate bribery, any form of corrupt business behaviour, or fraud. Our company’s Anti-Bribery and Corruption Policy elaborate on our commitment to combating bribery and other forms of corruption. We are all required to be familiar with and comply with the policy, which provides guidance on Bribery and Corruption, Bribery of Government Officials, Facilitation Payments, Gifts, Meals & Entertainment, Political & Charitable Donations, Business Partnerships, Misuse of Assets, Reporting, and Investigations, Training and Communication and Record Keeping. Fuze will respond to all incidents of bribery, corruption, and fraud, seeking to recover the loss, taking action against those who perpetrate fraud, and reporting incidents to the authorities as appropriate. This may lead to prosecution and/or disciplinary sanctions, including dismissal. We expect our business partners and suppliers to uphold similar principles to us for bribery, corruption, and fraud risk management.
Reporting – Anti-bribery & corruption and Violations of Laws and Regulations
All cases of anti-bribery / corruption / violation of laws and regulations are to be reported to the Compliance Officer. Please raise your concerns via email to [email protected] or directly call +971-502787818.
Preventing and Detecting Financial Crimes
Financial crime harms society and governments and can adversely affect our business and reputation. We are committed to playing a strong role in the global fight against financial crime. We do this by adhering to the following:
1. Applicable anti-money laundering and counter-terrorism financing (AML/CTF) laws and regulations
2. Applicable economic and trade sanctions regulations and boycott rules
3. Our Anti-Corruption and Bribery policies
You are required to:
1. Read, be familiar with, and adhere to all of our internal standards, controls, and procedures designed to prevent any form of financial crime;
2. Report all instances of financial crime, suspicious activity, and concerns to the Head of Compliance;
3. Complete all mandatory compliance training, and speak to your manager about further training and guidance if required.
Our AML/CTF, Economic and Trade Sanctions, Boycott rules and ABC policies set out our governance and appetite to identify, manage and mitigate the risk of opportunities for financial crime within our company. These are available here or by contacting the Compliance Team for information and guidance.
Promoting a Safe and Healthy Workplace
It is important that we all work in a fair, safe, and inclusive environment that empowers us to pursue our values and achieve our goals.
This includes:
1. Always treat each other with fairness and respect.
2. Promoting equal opportunity in recruitment and employment.
3. Basing appointments, training, development, rewards, and promotions on merit and ability.
4. Ensuring all of our tools and systems are used appropriately, and all communications are respectful and constructive.
A safe and healthy workplace is free from discrimination, exploitation, bullying, and harassment.
Respect at Work
At Fuze, we celebrate diversity. Promoting an inclusive culture for everyone represents our commitment to equal opportunities for all. It’s vital that respect and inclusion exist within our physical workspaces, including our offices, at company events, and at offsites.
This extends to our virtual workspaces such as Zoom meetings, Slack conversations and channels, email, and more. We are curating a culture where we amplify and strengthen our people’s voices, a culture where diversity, impact, transparency, and collaboration are expected and celebrated.
Zero Tolerance Policy
At Fuze, we have a zero-tolerance policy towards:
1. Discrimination: Comments or behavior that discriminates against, stereotypes, or harms members of the community.
2. Sexual Harassment: Examples of sexual harassment include but are not limited to:
  1. Suggestive or overly personal comments about an individual’s body or physical appearance
  2. Sexually suggestive comments or gestures toward an individual
  3. Invading personal space in a sexual way
  4. Unwelcome physical contact of a sexual nature
  5. Persistent unwelcome questions about someone’s marital or relationship status, sexual preferences, or sexual conduct
  6. Treating someone unfavorably (or suggesting that someone will be treated unfavorably) if they do not submit to conduct of a sexual nature

2. POLICY GUIDELINES

Training and Awareness

All Fuze employees will receive training on ethics and conduct policy. This training will be provided upon hiring and refreshed periodically.

Reporting Procedures

Any employee who becomes aware of a potential violation of ethics and conduct policy must promptly report it to their immediate supervisor or the Human Resources department.

Management of Conflicts

Reported violations and misconduct will be reviewed promptly and carefully. Actions will be taken to manage the conflict, such as reallocation of duties, creating a management plan, or even disciplinary action if needed.

Transparency and Record-Keeping

Fuze will maintain a register of reported violations and the measures taken to manage them. This register will be managed by the Human Resources department and will be subject to review as needed.

3. IMPLEMENTATION AND REVIEW

This policy will be reviewed regularly to ensure it remains relevant, effective, and consistent with current legislation. All employees have a responsibility to uphold the principles outlined in this policy.

4. REPORTING AND NON-RETALIATION

Covered Persons shall report in a timely fashion any conduct which is believed in good faith to be a violation or potential violation of the Ethics and Conduct Policy. By reporting misconduct, you are contributing to the Company’s ethical culture and upholding the Company’s values. All such reports shall be treated confidentially to the extent permitted by law. Covered Persons have a duty to cooperate with any investigation into known or suspected violations of this Policy or the law. The Company prohibits retaliation in any form against any person for making a good faith report under this Policy or for cooperating with an investigation into an alleged violation of this Policy or the law – even if the report is not substantiated. Anyone found to have retaliated against someone for making such a report will be subject to corrective action, up to and including termination of employment.

Client Assets Safeguarding

Fuze undertakes multiple overlapping measures to ensure the safety and sanctity for its clients’ assets. This ranges from the underlying blockchain technology being used to custody assets, to security and privacy measures over and above that. Some of the salient points of our approach are:

Segregation of Assets: Fuze maintains all customer assets 1:1 - the details of which are frequently shared with regulatory authorities. Further more, client assets are held separately from Fuze’s own funds.
Custody Model: Digital assets are held in a combination of hot, warm and cold wallets. Hot and warm wallets are secured by MPC (multi-party computation) - which ensures that there’s no single point of failure. Cold wallets are completely air-gapped - all transactions are therefore manual.
Security Infrastructure: Fuze’s security infrastructure has been audited and certified (SOC2 Type II and ISO27001). This ranges from data encryption of all data and communication between servers through TLS 1.2 or higher with a minimum 256 bit key cipher. Any additional service communication within Fuze happens over an E2E encrypted mesh VPN.
Insurance Coverage: Fuze has insurance coverage over assets held in case an incident still occurs, providing an additional measure of protection.

Order Routing Practices

Fuze works with multiple liquidity providers and get the quote for its customers based on several factors including but not limited to price, latency, previous data for fills, tokens, volatility. Fuze has partnerships with Cumberland and FalconX, besides other liquidity providers.

Virtual Asset Pricing

Fuze requests for quotes from liquidity providers. Once it receives quotes, it chooses a liquidity provider to which the order is routed. This automated choice is based on factors like latency, time for expiry of quotes, previous data for fills, tokens, volatility, and more. Fuze charges a markup on the quote received from the liquidity provider.

Whistleblower Policy

Fuze has comprehensive policies in place and establishes a framework to encourage employees and stakeholders to report any wrongdoing or unethical behaviour. Fuze ensures that whistleblowers are protected and that appropriate action is taken against any misconduct.

The policy is applicable to all employees, contractors, vendors, clients, and any person who becomes aware of any activity or behaviour that goes against the company's code of conduct, policies, or legal requirements. Fuze acknowledges that whistleblowers play a vital role in maintaining integrity and ethical standards. It encourages the reporting of concerns in good faith and assures protection from retaliation. Fuze has established secure channels that ensure confidentiality of the relevant parties. If you have any concerns relating to the activities of the company, please reach out to [email protected] or [email protected] or you can also directly call +971-502787818.

Fair Treatment of Client

Fuze's comprehensive internal controls and policies highlight its commitment to trust, integrity, and respect among its employees, customers, and stakeholders. In furtherance of its commitment to uphold fair treatment of all the stakeholders involved, including our customers, Fuze has policies around fair treatment of all stakeholders, including its clients, directors, officers, contractors, and employees (Covered Persons).

Fuze's Ethics and Conduct Policy (Policy) is a comprehensive document that outlines the guidelines and principles to be followed by all Covered Persons. The policy aims to establish and maintain high standards of ethical conduct in all business dealings and provides guidance on appropriate behavior in various situations.

The Code of Conduct section outlines the following key values that all Covered Persons should abide by:

Honesty: Fuze expects honesty and truthfulness in all professional and business relationships. There should be no deliberate misleading or deceiving of others.
Integrity: Personal and professional integrity must be demonstrated at all times, and individuals are expected to act for the absolute good in the interest of all stakeholders.
Loyalty: Covered Persons should be loyal to Fuze, colleagues, its clients, and business partners. They must avoid conflicts of interest and not use confidential information for personal gain.
Accountability: All individuals are responsible for their decisions and actions, and they should take ownership of their work, mistakes, and behavior.
Fairness: Dealing with others in a fair and just manner is essential, and everyone should respect the rights and dignity of others.
Respect: Covered Persons should treat all colleagues with respect, courtesy, and fairness, promoting a diverse and inclusive working environment.
Support and Collaboration: Openness, trust, and collaboration should be encouraged, and conflicts should be resolved in a professional and respectful manner.
Reputation: Upholding the company's reputation and morale is vital, and inappropriate conduct should be corrected and prevented.
Ethical Leadership: All individuals are expected to lead by example and consistently apply the values and principles outlined in the policy.
Commitment to Excellence: Pursuit of excellence, innovation, and efficiency is encouraged to achieve the best results for the company.
Compliance with Laws and Regulations: Adherence to all relevant laws, regulations, and company policies is essential.

The policy also addresses specific areas, such as conflicts of interest, protection of confidential information, data protection, anti-bribery and corruption, and prevention of financial crimes. Covered Persons are required to avoid situations that could impair their professional judgment and seek approval for any outside relationships that may pose a conflict of interest.

Regarding confidentiality, Covered Persons must protect and use confidential information responsibly, following the company's security and privacy policies. Any breach of confidentiality obligations is taken seriously and may result in appropriate action.

Fuze maintains, at all times, a Zero-Tolerance approach to Bribery and Corruption. The policy emphasizes the prevention of bribery, corruption, and fraud and requires compliance with anti-money laundering, counter-terrorism financing laws, economic and trade sanctions regulations, and the company's anti-corruption and bribery policies.

The company promotes a safe, healthy, and inclusive workplace, free from discrimination, harassment, bullying, and exploitation. The policy highlights the importance of respecting diversity and inclusion in both physical and virtual workspaces.

The document includes guidelines for reporting violations of the policy and outlines procedures for managing conflicts and handling reported misconduct. It stresses the importance of cooperation in investigations and ensures confidentiality for whistleblowers.

Employees are required to undergo training on the policy, and all reports of potential violations are treated confidentially, without fear of retaliation.

Overall, the Policy serves as a guide to maintain the company's ethical culture and uphold its values in all aspects of its operations.

Complaints

You can contact Fuze by filling out this Complaint Form or by emailing [email protected].

Fuze will acknowledge all complaints within 24 hours of it being made.
Fuze will try to resolve as many complaints as possible immediately, via the respective channel through which contact was established.
In all cases, Fuze will provide you an update on the status of the complaint, and explain any extraordinary circumstances that are delaying the resolution within four(4) weeks of the complaint being made. Fuze will resolve all complaints no later than eight(8) weeks from when the complaint was made.
There is no extra cost for raising a complaint. In case certain resolutions require a change in the scope of the product/service being offered to you, you will be made aware of it and, should you opt for it, your explicit consent will be sought and documented.
Irrespective of the channel, please try and give Fuze as much context as possible about the nature of your complaint. This will help us effectively come up with both short and long term solutions for you.

Please keep in mind that Fuze also operates as a B2B2C - so if you have been exposed to a product powered by Fuze on a banking or finance app, you can receive faster resolution by contacting the respective bank or finance company. In any case, Fuze shall ultimately remain responsible for the resolution of those complaints as well.

Disclaimers

Risk Disclosure Statement

A. General Risks

B. Regulatory Risk

C. Operational Risk

D. Cyber Risk

E. Liquidity Risk

F. No Insurance on Deposit