HashKey Global Token Management Rules

Preamble

Objectives. The HashKey Global Token Management Rules (these “Rules”) are developed in order to foster the sustainable development of the HashKey Global platform, safeguard the rights and interests of trading participants, and offer guidance on the rights and obligations of Project Teams.

Definitions. Unless otherwise expressly provided, the following terms in these Rules shall have the meanings as specified:

(1) “Exchange Rules”: shall refer to the HashKey Global - Exchange Rules and any rules (including but not limited to these Rules)

in relation to any token offerings or trading which HashKey Global may implement and publicize on its website from time to time.

(2) “HashKey Global”: shall refer to the virtual asset trading platform branded “HashKey Global” which is operated by HashKey MENA FZE Limited.

(3) “Project”: shall refer to the underlying project, assets, or business that the Token is designed to represent or support .

(4) “Project Team”: shall refer to any entity responsible for the issuance, development or operation of the Token Project, i.e., the legal entity, team, natural person or beneficial owner of the Token listed or to be listed on HashKey Global, or the representative

willing to take responsibility for a community-based decentralized Token without a recognized Project Team.

(5) “Token”: shall refer to the cryptographic digital proof of interest traded on HashKey Global, including digital assets that represent ownership, utility, or other rights within a blockchain or decentralized network.

(6) “Monitoring Tag”: Tokens with Monitoring Tags exhibit notably higher volatility and risks compared to other listed tokens.

These tokens are closely monitored by the platform. These tokens are at risk of no longer meeting our listing criteria and being

suspended from trading or delisted from the platform.

Chapter I General Provisions

Article 1 General Requirements. To allow HashKey Global to perform due diligence on the Project and the Token, set out below is a non-exhaustive list of general requirements and information which a Project Team shall provide to HashKey Global before its Token may be approved to be listed on HashKey Global for trading:

(1) background of management, development team, and any of its known key members;

(2) regulatory status of the Token in major jurisdictions;

(3) supply, demand, maturity and liquidity of the Token;

(4) technical aspects of the Token;

(5) development of the Token;

(6) market and governance risks of the Token;

(7) legal risks associated with the Token;

(8) utility offered, novel use cases facilitated, technical structural or cryptoeconomic innovation, or administrative control exhibited by the Token and supporting information on viability of the Project not dependent on continuous inflow into the Token;

(9) enforceability of any rights extrinsic to the Token (for example, rights to any underlying assets) and the potential impact of the Token’s trading activity on the underlying markets; and

(10) assessment on the money laundering and terrorist financing risks associated with the Token.

The Project Team shall comply with all Exchange Rules, policies and procedures that apply to the Project, the Project Team and the Token in effect or as amended from time to time, and any conditions attached to a listing which HashKey Global considers appropriate at its sole discretion.

HashKey Global may attach to a listing any conditions that it considers appropriate, and vary or revoke the condition(s) when deemed necessary upon listing or at any time the Token is listed on HashKey Global.

(11) VA Standards: The Standards below are some of the factors considered for Virtual Asset listings. Virtual Assets are assessed for listing on a holistic basis, rather than on a single factor basis.

a. its market capitalisation, fully diluted value and liquidity, and whether such metrics have trended downwards over time;

b. its design, features and use cases, whether or not intended by the Issuer or relevant developers;

c. whether there are features which may materially affect a VASP’s compliance with applicable laws, Regulations, Rules or Directives, including but not limited to those relating to AML/CFT, sanctions, securities, intellectual property;

d. regulatory treatment by VARA and other appropriate authorities [including those outside of the Emirate], in particular whether the issuance of the Virtual Asset has received any regulatory approvals;

e. whether a Virtual Asset is prohibited by VARA or any other appropriate authorities [both inside or outside the UAE] in jurisdictions in which the VASP will provide VA Activities, or equivalent activities, in relation to such Virtual Asset;

f. the security and immutability of the underlying DLT protocol;

g. its future development [e.g. “roadmap”] as communicated by the Issuer and/or relevant developers;

h. whether it may be susceptible to price manipulation for any reason and relevant mitigations that will be implemented by the VASP;

i. whether potential or actual conflicts of interest may arise should a VASP provide any VA Activities in relation to the Virtual Asset and relevant mitigations;

j. the background of its issuer including, but not limited to, relevant experience in the Virtual Asset sector and whether it has been subject to any investigations or claims in relation to fraud or deceit;

k. if the Virtual Asset represents rights to any other assets, the enforceability of such rights;

l. sufficient assets are available to satisfy any obligation with respect to any VA Activities;

m. VASPs shall ensure that Virtual Asset terms and conditions reflect, to the extent possible, the operation of any existing underlying physical market and avoid adverse impacts to such market [if applicable]; and

n. VASPs should review Virtual Asset terms and conditions on a periodic basis for appropriate correlation with any physical market to ensure such terms and conditions conform to standards and practices in that physical market [if applicable].

 

Article 2 Non-security. The Token shall not be a security token and will not become a security token unless with the prior written consent of HashKey Global. The Project Team is responsible for maintaining the non-security status of the Token and will not make any changes that could cause the Token to be classified as a security. HashKey Global reserves the right to delist the Token upon any change in the non-security status of the Token at its sole discretion.

Chapter II Information Disclosure Article 3 Information Disclosure Obligations.

The Project Team shall disclose all information that may have a material impact on the Token, market activity

of the Token or the Project Team in a timely and transparent manner, and ensure that all the information

disclosed are true, accurate and complete, not deceptive or misleading, and does not omit any material facts or considerations.

Article 4 Forms of Information Disclosure.

From the date of publication of these Rules, the Project Team shall make regular and ad-hoc disclosures available promptly on its official website. The information disclosed shall include, but not be limited to, the progress of code updates, market activities, institutional investment, community development, regulatory action and any other important aspects of information.

Article 5 Ad-Hoc Disclosures.

An ad-hoc disclosure refers to the disclosure that shall be made by a Project Team in addition to the regular disclosure in the event of any special incidents occurring. All such incidents shall be disclosed and HashKey Global shall be notified in writing within twenty-four (24) hours of such occurrence. The special incidents

herein provided include, but are not limited to, change or loss of contact of core team members, major technical incidents, changes in the direction of product and technical development, major legal risks involving the core team, significant negative news or public opinions, and any other incidents that may have a significant impact on or could reasonably be expected to cause the fluctuations on the price of the Token (including the unlocking and the buyback of a locked Token).

The content of an ad-hoc disclosure shall include, but not be limited to, the reasons for the occurrence, the process,

the basic facts, and the results of the incident.

Article 6 Exceptions to Information Disclosure.

If the information to be disclosed by the Project Team involves any state secrets or if the disclosure may have conflict with public interests, such information may be withheld with HashKey Global's consent.

Chapter III Inquiry and Review Article 7 Inquiries and Responses.

HashKey Global shall have the right to inquire to the Project Team about the Token and/or the Project from time to time.

The Project Team shall actively cooperate with and respond to the inquiries within twenty-four (24) hours.

Article 8 Forms of Inquires.

HashKey Global may make an inquiry to a Project Team by contacting: (1) the official email address provided by the Project Team;

(2) the phone number provided by the Project Team; or (3) the instant messaging application accounts provided by the Project Team, such as via Telegram.

Article 9 Content of Inquires.

The content of an inquiry may include, but not be limited to, the fulfillment of the commitments made in the whitepaper or on the official website, the employment and Token holdings of core team members, the progress of the product and technical development, and other factors that may have a significant impact on or could reasonably be expected to cause the fluctuations on the price of the Token (including the unlocking and the buyback of a locked Token).

Article 10 Results of Inquiries.

HashKey Global may at its sole discretion, determine whether a Project Team has violated these Rules based on the factors such as whether the Project Team has cooperated with the inquiries, the level of cooperation, and the content of the responses.

HashKey Global may take relevant actions to deal with the violations in accordance with the procedures set forth in Chapter IV.

The actions may be notified to the Project Team or the users through the means specified in Article 8 or through an announcement.

Article 11 Routine Reviews.

HashKey Global shall have the right to conduct regular or ad-hoc reviews of the Project and the Project Team, for the following circumstances: (1) significant aspects of whitepaper commitments; (2) security reviews of the code; (3) other factors that may have impact on or could reasonably be expected to cause the fluctuations on the price of the Token, such as changes of positions held by the Project Team or other major Token holders, and the fulfillment of the commitment to lock the Token; (4) changes in core team members; or (5) any other aspects considered necessary to be reviewed at HashKey Global’s discretion, including

but not limited for purposes of risk management, corporate governance, internal controls and compliance with laws and regulations

. Article 12 Special Reviews.

HashKey Global may initiate a special review if: (1) the Project Team is reported by the users or is revealed by the news media to be involved in the circumstances specified in Article 11, and the Project Team has not made any response to such report or revelation, or the response is not sufficient to disprove such involvement of the circumstances specified thereof; (2) significant risk is identified in a routine review, or (3) any other circumstances that HashKey Global may deem necessary to initiate a special review at its discretion, including but not limited for purposes of risk management, corporate governance, internal controls and compliance with laws and regulations.

Article 13 On-Site Investigations.

HashKey Global may visit and supervise the Project Team and conduct on-site investigations on a regular or ad-hoc basis according to actual needs (consent from the Project Team not to be unreasonably withheld). The Project Team shall actively cooperate with HashKey Global’s on-site investigation. The content of the investigation may include, but not be limited to, those specified in Article 9.

If the Project Team refuses to, intentionally obstructs or otherwise fails to cooperate with HashKey Global's investigation, HashKey Global may decide to take relevant actions against the Project team in accordance with these Rules at its sole discretion, including but not limited to the delisting of the Token from HashKey Global.

Article 14 Cooperative Obligations of the Project Team.

The Project Team is obliged to actively cooperate with HashKey Global for routine and special reviews. The Project Team shall also actively respond to or rectify the related issues reported from the users, the inquiries raised from the news media, and the risk notices addressed from relevant regulatory authorities. HashKey Global may take relevant actions against the Project Team in accordance with these Rules in the event that the Project Team fails to fulfill the cooperative obligations herein. Such actions may be notified through the means specified in Article 8 or through an announcement.

Chapter IV Handling of Violations Article 15 Implementations of Monitoring Tag Warnings.

HashKey Global shall have the right to, at its sole discretion, implement a Monitoring Tag warning on a Token according to the risk associated and severity of a violation of the Exchange Rules and place a “Monitoring Tag” on the relevant trading pairs to alert the users of the risk of trading such Token.

15.1 Trigger Events of Monitoring Tag Warnings.

The Monitoring Tag warnings will be triggered if any of the following events are identified, present or occur from the Project, the Project Team or the Token (the “Trigger Events”):

(1) the Project Team fails to update or disclose information about the Project or the Token, including but not limited to,
the Project Team’s official website, whitepaper, and ad-hoc disclosure incidents set forth in Article 5; (2) the average daily
transaction volume of any trading pairs of the Token is less than USDT30,000 or other equivalent tokens for more than 30
consecutive days; (3) the Project has poor liquidity,

i.e., the spread exceeds 2% for three consecutive days, fewer than 15 price tiers of orders are placed on either side of the market, the top 10% bid/ask market depth is worth less than USDT10,000 or other equivalent Tokens, or the price of the Project has been found to be manipulated (the price deviates from the market price by 10% or more); (4) any considerations as HashKey Global may, at its discretion, deem it necessary to place a Monitoring Tag upon a comprehensive assessment by means of inquiry, routine review, special review, on-site investigation, etc.; or (5) any other circumstance arises that can be assessed as a serious violation at HashKey Global’s discretion, including but not limited for purposes of risk management, corporate governance, internal controls and compliance with laws and regulations.

15.2 Lifting of Monitoring Tag Warnings.

HashKey Global shall have the right to lift the Monitoring Tag warning on a case-by-case basis if such Project Team have taken appropriate rectifications and the Project, the Project Team or the Token have been reviewed as no longer meeting any of the Trigger Events.,

Article 16 Trading Suspension, and Token Delisting.

HashKey Global shall have the right to, at its sole discretion, suspend the trading or delist the Token, according to the severity of the following

circumstances:

(1) the Monitoring Tag warning is not lifted within thirty (30) calendar days from the date of its implementation;

(2) implementation of new regulatory standards and other compliance issues that, as determined by HashKey Global, requires the suspension of trading or delisting of the Token;

(3) the Project, the Project Team or the Token posed significant regulatory risks, including but not limited to, that the Token constitutes a “security” in a jurisdiction and HashKey Global is unable to and/or unwilling to prevent its users from that jurisdiction from holding and/or trading the Token;

(4) blockchain or related technology becomes compromised or defective;

(5) the Project or the Token is no longer supported or maintained by the Project Team or others;

(6) complaints or material allegations by users or other third parties, which are related to significant issues such as gross negligence, wilful misconduct or fraud;

(7) the Project Team or any of its memebers conducts or is involved in any illegal activity(ies) within any jurisdiction(s), such as money laundering, fraud or pyramid selling;

(8) any threatened, pending or active legal proceeding or claim (whether civil, criminal, or administrative, formal or informal, or direct or indirect) against the Project Team;

(9) the Project Team is suspected of manipulating the market and the circumstances are serious;

(10) the Project Team is unreachable within a specified period indicated to it;

(11) any changes to Project Team members which HashKey Global considers to have material adverse impact on the Project or the Token;

(12) any core member of the Project Team has been found of significant fraud or deception, including but not limited to, misappropriation of the raised Tokens, unknown whereabouts of the Project development team, cease to support the Project technology, intentionally concealment of material facts of the Project, disclosure or creation of materially fraudulent, false or misleading information;

(13) the dissolution of the Project development team or resignation of core team members without the consent of the Project community, resulting in the inability to continue development;

(14) there is a lack of liquidity in the Token’s market over a time period to be determined as appropriate by HashKey Global;

(15) no order of the Token is recorded over a time period to be determined as appropriate by HashKey Global after initial listing;

(16) the Project Team changes supply of the Token without giving prior notice to HashKey Global;

(17) the Project Team unlocks the Tokens without fulfilling the commitment made in the whitepaper or in other forms;

(18) the Project Team conducts a hard fork, token migration, token split, token merge, and rebranding of the Token without giving prior notice to HashKey Global;

(19) the Project Team has caused significant losses to HashKey Global and/or users due to security issues in the main net or the contract, and the Project Team fails to reimburse HashKey Global for the losses and/or compensating its users for the losses that they suffer;

(20) other risks and hazards exist in the Project or the Token, such as hacking, coins stealing, concealment of additional issuance, and double spend attack;

(21) the average daily transaction volume of any trading pairs of the Token is less than USDT10,000 or other equivalent tokens for more than 30 consecutive days;

(22) there is no immediate action taken or solution given by the Project Team in the event of any crisis, as deemed by HashKey Global, that is causing detrimental impact to HashKey Global, the HashKey Group generally and/or any trading participant, including but not limited to, discovery of inaccurate information, technical issues on the Token, security breach, etc.;

(23) the Project Team conducts any activity(ies) that damages the reputation of HashKey Global or the HashKey Group generally, and adversely affecting any trading participant’s interest;

(24) the Project develops close association with prohibited categories of business;

(25) the Project Team has materially breached the Listing Agreement entered into between Hashkey Global and the Project Team;

(26) the Project Team has materially breached the Exchange Rules and the breach cannot be or has not been cured within fourteen (14) days;

(27) any such circumstances as agreed between HashKey Global and the Project Team, including but not limited to, any circumstances specified in a Listing Agreement; or

(28) other circumstance(s) that, at the sole discretion of HashKey Global, is/are sufficient for removal of the Token from HashKey Global, including any circumstances which causes the Token to be no longer eligible or appropriate to continue to be listed.

In the case of trading suspension, the trading and deposit of the Token shall be suspended, but the users will be able to continue to hold a position of the Token. The Project Team is obliged to address all violations and ensure compliance with the Exchange Rules to HashKey Global’s satisfaction before the suspension can be lifted. HashKey Global reserves the right to delist the Token, provided that the trading of the Token has been continuously suspended for a prolonged time, or if any violations have not been or cannot be remedied, as determined by HashKey Global.

Article 17 Liquidation and Termination of Trading.

The liquidation process shall be determined by HashKey Global on a case-by-case basis. In the case of delisting, liquidation process shall commence on the date the

delisting decision is made. Upon completion of the liquidation process, trading of such liquidated Token will

cease and the Token will be officially delisted. The termination of trading will be notified to the Project Team or the users through the means specified in Article 8 or through an announcement on HashKey Global.

 

Article 18 Liability.

The Project Team shall be liable for any losses caused to HashKey Global, the users or any other third parties resulting from or by reason of any breach of these Rules.

Chapter V Supplementary Provisions

 

Article 19 Some Projects may have privileged roles that possess the authority to unilaterally perform administrative actions, such as modifying network functionality or seizing user funds, which, if misused, can pose a threat to the secure custody of customers' assets by HashKey Global. It is strongly recommended that Project Teams adhere to the principle of "least privilege”, whereby privileged roles should have narrow scopes limited to essential functionalities.

Project Teams are encouraged to renounce unnecessary privileges and, if unavoidable, to establish comprehensive policies and procedures for quorum-based key management and usage, particularly for actions affecting balances of trading participants.

Article 20 In the event of any discrepancy between these Rules and any other rules or

announcements previously published by HashKey Global, these Rules shall prevail. In the event of any discrepancy between the English language version of these Rules and any translation of these Rules in a foreign language, the respective English version shall prevail.

Article 21 HashKey Global reserves the right to amend these Rules from time to time and the right of final interpretation. Such amendments shall take immediate effective upon being published on HashKey Global’s website. Project Teams and trading participants are responsible for referring to the latest Rules as uploaded on HashKey Global’s website.

Article 22 Project Teams are forbidden from disclosing any information in relation to the listing until HashKey Global (or its affiliates) issues our listing announcement.

 

Article 23 These Rules shall take effect from the date of publication.

Disclaimer: The analysis regarding the suitability of a Token for listing may change over time as digital assets, regulatory statements, and interpretations evolve. It is recommended that each Project Team consults with their own legal advisors to obtain legal guidance on these matters. HashKey Bermuda Limited and its affiliates, directors, officers, employees, agents, and attorneys do not provide legal advice or act as attorneys for any specific Project Team.