Compliance Disclosure

Tribe Tokenisation FZE applies defined standards when approving Asset-Referenced Virtual Assets ('ARVAs') for distribution on the platform. These standards ensure ARVAs are offered fairly, transparently, and without misleading features, and that every asset meets mandatory regulatory, legal, and technical benchmarks.

• Direct linkage to clearly identifiable, verifiable underlying real-world assets (such as DLD-registered property).
• Legal structure providing enforceable token-holder rights consistent with the asset reference and UAE law.
• Clearly defined issuance terms, supply mechanics, exit rights (if applicable), and asset linkage, fully disclosed in offering documents.

• Values derived from independent, objective valuations (such as by DLD-approved valuers).
• Transparent disclosure of methodology, revaluation frequency and limitations (including liquidity/basis risks).
• No reliance on speculative metrics like market capitalisation or trading liquidity.

• Issuer appropriately licensed/authorised with strong governance and oversight.
• Comprehensive background checks, KYC and due diligence on issuers, key personnel and material counterparties for integrity, competence, and regulatory standing.

• Full compliance with VARA classifications, virtual asset regulations, securities laws, and other applicable UAE financial services requirements.
• Robust AML/CFT and sanctions arrangements for ARVAs, associated transactions, issuers, and counterparties, including screening against global lists (e.g., UN, OFAC, EU, UAE).
• Ongoing due diligence, monitoring, and risk assessments of issuers, third parties, and key personnel in line with VARA/FATF standards.

• Blockchain infrastructure and smart contracts meeting high security/reliability standards.
• Mandatory independent third-party smart contract audits prior to approval.

• Assessment for fraud, misrepresentation, manipulation, or other risks specific to ARVAs.
• High disclosure standards ensuring users understand the ARVA's nature, underlying asset backing, valuation basis and limitations (including liquidity constraints).

This framework is reviewed annually (or upon material changes) to ensure continued alignment with regulatory requirements and industry best practice.

A conflict of interest may arise in a number of areas including in relation to clients, partners, suppliers, staff members, and directors. Tribe Tokenisation FZE ("Tribe") has a strict governance framework to monitor for and record actual or potential conflicts of interest. If a conflict of interest is identified, Tribe will implement mitigation measures and controls depending on the nature of the conflict to ensure that it is managed appropriately. To date, Tribe has not identified any actual or potential conflicts of interest in relation to its activities.

This section provides an overview of how Tribe manages potential conflicts of interest to ensure all business decisions are made objectively and in the best interests of our clients and stakeholders.

A conflict of interest occurs when a personal, financial, or other interest of an individual (or Tribe itself) compromises, or appears to compromise, objective decision-making or the ability to act in the best interests of clients and stakeholders.

Tribe maintains a zero-tolerance approach to unmanaged conflicts and operates with the highest standards of integrity, fairness, and ethical conduct. All business decisions must prioritise client interests and market fairness.

• Personal holdings or positions by staff/directors in Virtual Assets tokenised or listed on Tribe's platform.
• Outside directorships, significant shareholdings, or financial interests in issuers, property owners, or entities involved in tokenisation projects.
• Relationships with third-party vendors, valuers, or service providers that could influence pricing, admission, or valuation decisions.
• Acceptance of gifts, hospitality, or benefits that may unduly influence business judgments.
• Related-party transactions involving token issuance, placement, or distribution.

Tribe proactively identifies and manages conflicts through:

• Mandatory Disclosure: All staff and Board members must promptly disclose (in writing) any actual or potential conflict to the Compliance Officer upon identification or change in circumstances.
• Periodic Risk Assessments: Formal conflict of interest risk assessments are conducted at least annually (and ad hoc following material business changes) to identify heightened risk areas and inform mitigation updates.
• Conflict Register: All disclosures are recorded in a centralised, auditable register, reviewed by the Board at least every six months.
• Independent Oversight: The Compliance Officer investigates disclosures, recommends mitigation, and ensures compliance with this policy.

Tribe applies proportionate controls based on the conflict's nature and severity:

• Prior Approval: Board members and Staff must obtain written approval from Tribe before opening, modifying, or closing Virtual Asset positions or taking external director roles.
• Chinese Walls: Information barriers separate business development and compliance functions to prevent conflicts.
• Independent Valuations: All property valuations are conducted by independent, DLD-approved valuers (not influenced by Tribe or issuer relationships).
• Arm's Length Pricing: All pricing for initial placement and distribution is conducted at arm's length and subject to Compliance Officer review.
• Board Approval: Material related-party transactions require Board of Directors approval.
• Exclusion and Divestment: Individuals with conflicts are excluded from relevant discussions, decisions, or voting. If a conflict cannot be adequately mitigated, divestment of the conflicting interest or resignation from the role is required.
• Ongoing Monitoring: Continuous oversight of disclosed positions, transactions and external interests.

The following are strictly prohibited and may result in disciplinary action, up to termination:

• Trading or holding interests in Virtual Assets or entities where an unmanageable conflict exists.
• Using inside or confidential information for personal gain (insider dealing).
• Facilitation payments, kickbacks, bribery, or any corrupt practices (refer to Tribe's Anti-Bribery & Corruption Policy).

Tribe Tokenisation FZE makes available Asset-Referenced Virtual Assets ("ARVAs") representing fractional, asset-referenced interests linked to specific real estate properties.

The following general standards apply to all ARVAs offered on the platform.

• ARVAs are issued by VARA-licensed issuers and distributed by Tribe in its capacity as a broker-dealer.
• Each ARVA is linked to a specific underlying real estate property registered with the Dubai Land Department.
• ARVAs are not cryptocurrencies, stablecoins or deposit-like instruments and should not be compared to unbacked digital assets.

• ARVA values are derived from independent property valuations conducted by Dubai Land Department-approved valuers.
• Initial valuations are established at issuance, with periodic revaluations thereafter.
• Unit values are valuation-derived and do not represent traded market prices or guaranteed exit values.

• The total number of ARVA units issued for each property is fixed and disclosed at the property level.
• ARVA supply mechanics, including whether all units are issued at launch or subject to specific conditions, are disclosed per property.
• ARVAs do not operate on a free-floating supply model comparable to cryptocurrencies.

• ARVAs are issued and transferred using smart contracts deployed on approved blockchain infrastructure.
• Smart contracts are subject to independent audits prior to issuance.
• Audit status and relevant audit information are disclosed at the property level.

• Where available, historical valuation information is disclosed to provide context on how the value of the underlying asset has changed since issuance.
• Valuation movements reflect property market conditions and appraisal updates, not speculative trading activity.

Important Note: This General Standards document provides a framework overview applicable to all ARVAs. Complete, asset-specific disclosures are provided on each individual property disclosure page.

ARVA unit values displayed on the platform are derived from independent valuations of the underlying real estate assets conducted by third-party, Dubai Land Department-approved valuers.

Unit values are calculated by reference to the most recent property valuation relative to the total issued ARVA units.

ARVA values do not reflect real-time market trading prices and are not determined through continuous secondary market activity.

Tribe operates as a private marketplace and does not route client orders to external liquidity sources or third-party exchanges. All transactions are executed internally within the Tribe platform. As such, 0% of client orders are routed to any external liquidity source.

Tribe does not provide clearing services for other Virtual Asset Service Providers (VASPs). Tribe is responsible solely for the settlement of transactions occurring on its own platform for its own clients.

How your assets are protected:

Client Funds

• Held in segregated client money accounts at Zand Bank (a UAE-regulated bank)
• Fully separated from Tribe's own operational funds
• Subject to regular reconciliation and independent audits
• Used exclusively for client transactions, never for Tribe's business operations

Virtual Assets (ARVAs)

• Held in third-party custody with Ripple Custody
• Each client has a dedicated wallet
• ARVAs remain the client's property at all times

Tribe does not refer or introduce clients to other VASPs or third-party entities, nor does it receive any monetary or non-monetary benefits, commissions, or reciprocal business for such arrangements.

Tribe works with the following third-party providers: