Kriptomat Compliance and Integrity

Kriptomat is committed to fair and transparent business practices. We care about the safety of our clients. We strive to run the business within the framework of legal regulations, including the Markets in Crypto-Assets Regulation (MiCA), and in accordance with best practices and personal integrity. For this reason, we implemented numerous technical measures and obtained an Operating license: License and Registrations and the international information security certificate ISO 27001:2022, which confirms that we follow the best practices in the field of information security.

Our strategy does not include any shortcuts that would lead to goals faster at the expense of integrity. We do not believe in the idea of quick earnings, so we lead a long-term story that we believe in and that is of a solid structure.

Our business partners, shareholders, investors, employees, and the wider community deserve honesty and integrity in every step we take. Compliance is not just a requirement—it is embedded in our daily behaviour. We are honest, fair, and transparent. And we genuinely care.

Code of Conduct:

Living & Communicating Integrity and Setting Clear Rules

As a licensed cryptocurrency exchange service, we have implemented a set of regulatory requirements in relation to anti-money laundering and counter-terrorist financing (AML/CFT). We established clear internal rules that enable us to work efficiently while minimising business risks. Adherence to legal regulations, our internal rules, Code of Conduct, and internal guidelines is the foundation of our daily operations and an indispensable tool in achieving our goals and vision.

On a company level, we adopted a set of rules and values that represent our Code of Conduct. However, we recognise that not all situations can be governed by written rules. For this reason, we complement the rules with something that transcends them—Integrity. Integrity is our lens for action and decision-making, particularly in ambiguous situations. It is a question of our corporate culture.

It matters what and how we do things; achieving goals without integrity is not acceptable. We operate based on ethical standards and evaluate every decision in light of integrity.

Given that we can only monitor and supervise our internal environment, we remain vigilant regarding external factors such as fraudulent conduct by third parties that may harm our clients. We have allocated significant resources to fraud prevention and established an internal section dedicated to it. Even if we can only partially influence external threats, we are committed to ongoing vigilance and prevention.

We further ensure market integrity and prohibit any form of market manipulation, insider dealing, or dissemination of false or misleading information, in line with MiCA Title VI. Our systems are equipped to detect and escalate suspicious activity, and our staff are trained to identify risks of market abuse.

MiCA Compliance Framework

Kriptomat acknowledges and fully aligns with the Markets in Crypto-Assets Regulation (MiCA) (Regulation (EU) 2023/1114). As a Crypto-Asset Service Provider (CASP), Kriptomat ensures compliance with the regulation’s core obligations including white paper disclosures, organizational governance, crypto-asset custody, conflict of interest management, and investor protection.

We maintain robust internal procedures to ensure:

• Proper registration and licensing under relevant competent authorities.
• Safeguarding of clients’ crypto-assets in segregated accounts.
• Ongoing disclosures to users as per MiCA Titles II and III.
• Timely reporting of serious operational or security incidents (Article 75).
• Adherence to governance standards and internal controls.

Client Asset Safeguarding

In accordance with MiCA and industry best practices, Kriptomat maintains strict segregation of client assets from company assets and employs licensed custodians when appropriate. Our wallet infrastructure includes internal access controls and encryption mechanisms to ensure security and transparency.

Conflict of Interest Policy

Kriptomat has implemented a conflict-of-interest framework in accordance with MiCA Article 89. We systematically identify, manage, and monitor potential conflicts. Measures include insider trading prohibitions, impartial client service treatment, and transparency in crypto-asset listings and advisory practices.

Compliance Management

As a provider of crypto-asset services, we are committed to compliance and ethical standards. We carefully oversee legal and internal rule adherence and manage money laundering and terrorist financing risks.

Compliance is part of our corporate culture and is greatly influenced by the conduct of top management. All Kriptomat employees and business partners must uphold high ethical standards and take full responsibility for their conduct and decisions.

Our guideline principle is “Making the right way with the right attitude,” fully embodied in the Kriptomat Compliance Management System.

We ensure that outsourced activities are compliant with MiCA Article 83. Kriptomat retains full responsibility for outsourced services and implements oversight mechanisms, including audits, SLAs, and vendor risk assessments.

Anti-bribery Commitments

Kriptomat complies with all anti-bribery regulations and standards by:

• Promoting a bribery-free business culture and achieving defined anti-bribery objectives.
• Complying with anti-bribery laws in all jurisdictions where we operate.
• Upholding anti-bribery principles in all business interactions.
• Continuously improving our anti-bribery management system.
• Maintaining an independent body for anti-bribery compliance.
• Enforce disciplinary measures for violations of the anti-bribery policy.

Kriptomat Internal Fraud Prevention

Kriptomat is committed to fair and transparent business practices. We believe all crypto market players have a duty to act prudently and foster industry best practices. While providing services, we balance speed with client security.

To manage fraud risks, we launched our Internal Fraud Prevention Program in February 2020 under the leadership of our Chief Operating & Integrity Officer. We collect and analyse fraud data, implement enhanced safety measures, and monitor their effectiveness.

Our risk assessments are compliant with applicable regulations and enriched by both internal insights and client feedback. We use this information to inform our continuous improvement processes and client protection measures.

Contact

For inquiries or suggestions related to compliance, please email us at [email protected].