Company Disclosures

1. Company Information

1.1 Corporate Details

1.2 Business Activities

Sirius Digital provides digital asset consulting and investment services, including:

• Digital asset investment consulting services
• Portfolio management and strategy
• Blockchain technology consulting
• DeFi research and education

2. Compliance Framework

2.1 Anti-Money Laundering (AML) and Know Your Customer (KYC)

Sirius Digital maintains a comprehensive AML/KYC compliance program in accordance with applicable laws and industry best practices:

• Customer due diligence (CDD) and enhanced due diligence (EDD) procedures
• Beneficial ownership identification and verification
• Ongoing transaction monitoring and suspicious activity detection
• Sanctions screening and politically exposed persons (PEP) checks
• Staff training and awareness programs
• Independent audit and review

For detailed information, please refer to our AML/KYC Policies.

2.2 Data Protection and Privacy

We comply with the Personal Data Protection Act 2012 (PDPA) and maintain robust data protection policies and practices to safeguard your personal information.

Our data protection framework includes:

• Consent-based data collection with clear purpose notification
• Secure storage and processing of personal data
• Access controls and encryption measures
• Data breach notification procedures
• Individual rights management (access, correction, withdrawal of consent)
• Cross-border data transfer safeguards

For complete details, see our Privacy Policy.

2.3 Cybersecurity and Technology Risk Management

Sirius Digital implements comprehensive cybersecurity controls aligned with industry best practices:

• Multi-layered security architecture and defense-in-depth approach
• Encryption of data in transit and at rest
• Regular security assessments, vulnerability scanning, and penetration testing
• 24/7 security monitoring and incident response capabilities
• Business continuity and disaster recovery planning
• Third-party security due diligence and vendor risk management

3. Capital and Financial Standing

Sirius Digital maintains adequate capital to ensure financial soundness and operational resilience.

4. Client Asset Protection

4.1 Segregation of Client Assets

Client funds and assets are segregated from Sirius Digital's proprietary assets:

• Client funds are held in designated accounts with approved financial institutions
• Client digital assets are held in segregated wallets with institutional-grade custody solutions
• Regular reconciliation of client balances and holdings
• Independent verification and audit of client asset segregation

4.2 Custody Arrangements

Digital assets are secured using:

• Multi-signature cold storage wallets for the majority of holdings
• Hot wallets with limited balances for operational liquidity
• Institutional-grade custody partners where applicable
• Regular security audits of custody infrastructure

5. Conflicts of Interest

Sirius Digital is committed to identifying, managing, and disclosing conflicts of interest that may arise in the course of our business.

5.1 Types of Potential Conflicts

Conflicts of interest may arise from:

• Compensation arrangements: We may receive fees, commissions, or other compensation from product issuers, liquidity providers, or other third parties
• Proprietary interests: Sirius Digital or its affiliates may hold positions in products available to clients
• Multiple roles: We may act in various capacities (e.g., as agent, principal, or consultant) in relation to different transactions or clients
• Related party transactions: We may transact with affiliated entities or introduce clients to related service providers

5.2 Conflicts Management

We manage conflicts of interest through:

• Disclosure: Transparent disclosure of material conflicts to clients
• Information barriers: Separation of functions and restriction of information flows where appropriate
• Fair allocation: Objective criteria for allocation of investment opportunities
• Oversight: Compliance monitoring and review of potential conflict situations
• Independence: Decision-making processes designed to protect client interests

5.3 Specific Disclosures

6. Advertising and Marketing Standards

Sirius Digital adheres to responsible advertising practices, ensuring:

• Clear and balanced communication: Marketing materials present a fair and balanced view, including disclosure of risks
• No misleading statements: All claims are substantiated and not designed to mislead
• Appropriate risk warnings: Material risks are prominently disclosed
• Board and management oversight: Senior management is responsible for advertising compliance

7. Corporate Governance

7.1 Board and Management

Sirius Digital is governed by a Board of Directors with appropriate expertise in financial services, technology, risk management, and compliance.

• Independent oversight of key functions (risk, compliance, internal audit)
• Regular board meetings and committee reviews
• Clear accountability and escalation frameworks

7.2 Three Lines of Defense

We operate a three lines of defense model:

1. First Line (Business Operations): Business units own and manage risks
2. Second Line (Risk & Compliance): Independent oversight and policy setting
3. Third Line (Internal Audit): Independent assurance and validation

8. Fair Dealing and Conduct of Business

Sirius Digital is committed to treating all clients fairly and conducting business with integrity:

• Best execution: We take reasonable steps to obtain the best available outcome for client transactions
• Transparent pricing: Fees, charges, and costs are clearly disclosed
• Clear communication: Terms, risks, and key information are presented in plain language
• Suitable advice: When providing consulting services, we assess suitability based on client circumstances
• Complaint handling: Effective procedures for addressing client concerns

9. Complaints and Dispute Resolution

9.1 Internal Complaint Process

If you have a complaint or concern about our services, please contact us:

We will:

• Acknowledge your complaint within 3 business days
• Investigate thoroughly and fairly
• Provide a substantive response within 30 days (or notify you if more time is needed)
• Keep you informed of progress throughout the process

9.2 External Dispute Resolution

If you are not satisfied with our resolution of your complaint, you may refer the matter to an appropriate external dispute resolution body based on your jurisdiction.

10. Outsourcing and Third-Party Service Providers

We may engage third-party service providers for certain functions, including:

• Technology infrastructure and cloud services
• KYC and identity verification services
• Digital asset custody and wallet services
• Payment processing and banking services
• Data analytics and monitoring tools

All material outsourcing arrangements are subject to:

• Due diligence on service provider capabilities and controls
• Contractual safeguards to protect client data and interests
• Ongoing monitoring and performance review
• Business continuity arrangements

Sirius Digital remains fully responsible for all outsourced functions.

11. Updates and Notifications

We are committed to keeping you informed of material changes to our corporate status, policies, or operations. We will notify you of:

• Material changes to terms of service or fee structures (30 days advance notice)
• Significant corporate events (mergers, acquisitions, ownership changes)
• Updates to legal and compliance policies

Notifications will be provided via email, account notifications, or prominent website notices.

12. Contact and Further Information

For questions about our company disclosures or compliance framework: