Ethics Policy – Tungsten Custody Solutions FZE

Date: 20th February 2025

Version: 2.0

Whistleblowing Policy

At Tungsten Custody Solutions, we are committed to upholding the highest standards of integrity, transparency, and ethical conduct across all our operations. We foster a culture of accountability and compliance, ensuring that all employees, stakeholders, and business partners adhere to the ethical principles that define our organization.

Encouraging Transparency & Reporting Misconduct

To safeguard these values, Tungsten has implemented a comprehensive Whistleblower Policy that encourages employees, contractors, vendors, clients, and other stakeholders to report any wrongdoing, unethical behaviour, or regulatory violations. We recognize that a strong compliance culture is built on the ability of individuals to speak up without fear of retaliation, ensuring that concerns are raised in good faith and appropriately addressed.

Protection & Confidentiality for Whistleblowers

We assure strict confidentiality and protection for whistleblowers who report concerns relating to:

Fraud, financial misconduct, or regulatory breaches
Conflicts of interest or corruption
Harassment, discrimination, or unethical workplace practices
Non-compliance with company policies, internal controls, or legal requirements

Tungsten has a zero-tolerance policy against retaliation. Employees or stakeholders who report misconduct in good faith will be fully protected from any form of adverse action, discrimination, or retribution. All concerns are investigated thoroughly, fairly, and impartially, with appropriate actions taken to address misconduct and enhance compliance measures.

How to Report Concerns

We provide secure, confidential reporting channels for whistleblowers, ensuring that concerns are escalated appropriately and remain protected throughout the investigation process. If you suspect wrongdoing, unethical behaviour, or compliance violations, we encourage you to report your concerns securely and directly through:

Email: support@tungsten.ae

At Tungsten, we value and appreciate the role of whistleblowers in strengthening our compliance culture and ensuring that our operations remain ethical, transparent, and aligned with global best practices.

Complaints

You can contact Tungsten by emailing support@tungsten.ae or submit the complaint through our complaint form

Tungsten will try to resolve as many complaints as possible immediately via the respective channel through which contact was established.

We shall acknowledge all complaints within one week of a complaint being made.

In all cases, we will provide you an update on the status of the complaint, and explain any extraordinary circumstances that are delaying the resolution within four weeks of the complaint being made. Moreover, will resolve all complaints no later than eight 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 us 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.

Anti-Bribery and Corruption

At Tungsten, we are committed to conducting business with the highest standards of integrity, transparency, and ethical conduct. We recognise the importance of maintaining trust and confidence with our clients, partners, employees, and stakeholders. As part of this commitment, we have implemented a robust Anti-Bribery and Corruption Policy that reflects our zero-tolerance approach to any form of bribery or corruption.

Conflicts of Interest

Tungsten adheres to a Conflicts of Interest Policy designed to identify and manage any conflicts that may arise between the firm and its clients, as well as among different clients. In line with this policy, we have implemented robust procedures and controls to mitigate potential conflicts. When acting on your behalf, there may be instances where Tungsten or an affiliated entity has a material interest, relationship, or arrangement related to the transaction or service. If a material conflict is identified, we are committed to addressing and resolving it in a timely and appropriate manner. Should it not be possible to fully eliminate the conflict, we will inform you accordingly and outline the available options. To minimize potential risks, Tungsten enforces strict segregation of duties, comprehensive management oversight, professional training, and a strong compliance framework to ensure transparency and fairness in all client interactions.

At Tungsten, we are committed to maintaining the highest standards of integrity, transparency, and regulatory compliance. As a regulated Virtual Asset Service Provider (VASP) under the Dubai Virtual Assets Regulatory Authority (VARA), we recognize the importance of identifying, managing, and mitigating any actual, perceived or potential conflicts of interest that may arise in the course of our operations.

Identification and Management of Conflicts of Interest

Tungsten has implemented a Conflicts of Interest Policy designed to:

Identify and assess conflicts that may arise between Tungsten and its clients, or among different clients.
Mitigate and manage conflicts through strict segregation of duties, independent decision-making, and governance controls.
Disclose and communicate any material conflicts to affected parties and, where necessary, take appropriate steps to remove or neutralize such conflicts.

Key Measures to Prevent Conflicts of Interest

Client Asset Segregation: We ensure that client assets are held separately from Tungsten’s own assets, preventing any undue influence or misuse.
Independent Governance & Oversight: Our compliance and risk management frameworks include independent oversight by senior management and regulatory reporting mechanisms.
Fair & Transparent Client Treatment: We do not provide preferential treatment to any client, ensuring that all services are delivered fairly and equitably.
No Proprietary Trading: Tungsten does not engage in proprietary trading of virtual assets, ensuring our role remains strictly as a neutral custodian.
Strict Employee Conduct & Ethics: Our employees adhere to a code of conduct that prohibits any activity leading to conflicts of interest, including personal trading restrictions and mandatory disclosure of external interests.

In the event that an unavoidable conflict of interest arises, Tungsten undertakes to disclose the conflict to affected clients and provide options to ensure their interests remain protected. Our approach is designed to align with VARA’s regulatory framework, ensuring that our clients receive secure, transparent, and conflict-free custodial services.

Tungsten Custody Solutions FZE confirms that it has no actual or potential conflicts of interest arising out of its activities.

Third Parties

Tungsten confirms that it does not have any accounts, funds, or Virtual Assets maintained by a third party. All client assets are held directly under Tungsten’s custody in accordance with our regulatory obligations and security protocols, ensuring full control, transparency, and compliance.

Our Commitment

Zero Tolerance: We do not tolerate bribery or corruption in any form. This includes offering, giving, receiving, or soliciting anything of value to influence the actions of an individual or organization improperly.

Compliance with Laws: We strictly adhere to all applicable anti-bribery and corruption laws and regulations, including but not limited to the Virtual Assets Regulatory Authority (VARA) regulations, the anti-bribery provisions under the UAE Federal Penal Code, the UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combatting the Financing of Terrorism, as well as relevant international standards. Our commitment extends to ensuring full compliance with these laws within the Emirate of Dubai and any other jurisdictions where we operate.

Employee Responsibility: All employees, officers, and directors of Tungsten Custody Solutions FZE are required to understand and comply with our Anti-Bribery and Corruption Policy. Regular training and resources are provided to ensure our team is well-equipped to identify and avoid any unethical practices.

Third-Party Due Diligence: We carefully select our partners, suppliers, and other third parties, ensuring they share our commitment to ethical business practices. We conduct thorough due diligence and require all third parties to comply with our Anti-Bribery and Corruption Policy.

Reporting and Accountability: We encourage all employees, partners, and stakeholders to report any concerns or suspicions of bribery or corruption. Reports can be made confidentially and without fear of retaliation. We are committed to investigating all reported incidents promptly and taking appropriate action.

Continuous Improvement: We regularly review and update our Anti-Bribery and Corruption Policy to ensure it remains effective and relevant. We are dedicated to continuous improvement in our efforts to prevent bribery and corruption in all aspects of our business.

By upholding these principles, Tungsten Custody Solutions FZE strives to create a fair, transparent, and ethical environment that benefits everyone involved. We believe that integrity is the foundation of long-term success, and we are dedicated to maintaining the highest ethical standards in everything we do.

For more information or to report any concerns, please contact us at support@tungsten.ae

Fair Treatment of Clients

At Tungsten, we are dedicated to maintaining the highest standards of ethical and professional conduct. Our Code of Business Conduct outlines the expectations we have for all employees, contractors, and third parties who work with or on behalf of our company. This policy serves as a comprehensive guide to ensure that all business activities are conducted with integrity, transparency, and in full compliance with applicable laws and regulations.

Key Principles

Ethical Conduct: We expect everyone involved with our company to act ethically and responsibly in all business dealings, ensuring fairness, integrity, and respect for all stakeholders.

Compliance with Laws: Adherence to local and international laws, including anti-bribery, anti-corruption, and anti-money laundering regulations, is mandatory. We cooperate fully with regulators and ensure that all actions are in line with the legal requirements.

Customer Relations: We are committed to treating customers fairly, protecting their confidential information, and addressing any concerns or complaints promptly and transparently.

Conflict of Interest: All employees must avoid situations where personal interests conflict with the interests of the company. This includes managing relationships with suppliers and other third parties to maintain impartiality and fairness.

Whistleblowing: We encourage a culture where employees and partners can report unethical behavior without fear of retaliation. Our zero-tolerance policy ensures that all reports are taken seriously and investigated thoroughly.

Safeguarding Assets: Protecting company assets, including intellectual property, financial resources, and information, is a shared responsibility. We ensure that all assets are used efficiently and protected against loss or misuse.

This policy forms the foundation of how we conduct our business, emphasising our commitment to ethical practices and legal compliance. It is essential for building trust with our clients, partners, and the wider community.