Compliance Disclosure

Direct linkage to clearly identifiable, verifiable underlying real-world assets (such as DLD-registered property).

• Values derived from independent, objective valuations (such as by DLD-approved valuers).
• Tribe assesses the relevant value reference and liquidity characteristics of each Virtual Asset and monitors whether these metrics have trended adversely over time.
• ARVA values are not assessed by reference to speculative market capitalisation or secondary market trading activity.
• No reliance on speculative metrics like market capitalisation or trading liquidity.

• Transparent disclosure of methodology, revaluation frequency and limitations (including liquidity/basis risks).
• High disclosure standards ensuring users understand the asset's nature, underlying backing, valuation basis and limitations (including liquidity constraints).

• Legal structure providing enforceable token-holder rights consistent with the asset reference and UAE law.
• Where a Virtual Asset represents rights to any underlying assets, Tribe conducts a specific assessment of the enforceability of those rights under applicable law, prior to distribution and on an ongoing basis.

Clearly defined issuance terms, supply mechanics, exit rights (if applicable), and asset linkage, fully disclosed in offering documents.

• Issuer appropriately licensed and 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.
• Assessment of whether any features of the Virtual Asset may materially affect Tribe's compliance with applicable laws, Regulations, Rules or Directives, including those relating to AML/CFT, sanctions, securities, and intellectual property.

• Assessment of the regulatory treatment of each Virtual Asset by VARA and other appropriate authorities, including whether the issuance has received the requisite regulatory approvals.
• Verification that each Virtual Asset is not prohibited by VARA or any other appropriate authority in jurisdictions where Tribe provides VA Activities.

• Robust AML/CFT and sanctions arrangements for Virtual Assets, 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, and immutability standards.
• Mandatory independent third-party smart contract audits prior to approval.

Assessment for fraud, misrepresentation, manipulation, or other risks specific to the Virtual Asset.

Assessment of each issuer's communicated plans for the development or modification of the Virtual Asset, and the potential impact of any anticipated changes on the asset's risk profile and suitability for continued distribution.

Identification and mitigation of potential or actual conflicts of interest that may arise as a result of Tribe providing VA Activities in relation to any given Virtual Asset. Identified conflicts are documented and managed in accordance with Tribe's conflicts of interest framework.

Assessment of whether sufficient assets are available to satisfy any obligation arising in connection with the VA Activities Tribe provides in relation to each Virtual Asset.

Where a Virtual Asset references an underlying physical market, Tribe assesses whether the Virtual Asset's terms and conditions reflect, to the extent possible, the operation of that market and avoid adverse impacts on it. Tribe reviews this alignment periodically to ensure conformity with applicable standards and practices in the relevant physical market, including the Dubai real estate market.

Tribe has established conditions under which VA Activities in relation to a Virtual Asset may be suspended, including where a Virtual Asset no longer meets these VA Standards. Where such conditions are met, Tribe will implement the necessary operational procedures and controls, notify VARA as soon as possible, and take appropriate steps to minimise any adverse impact on clients.

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).

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.
• 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.

• 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.

Tribe conducts comprehensive background checks, KYC and due diligence on all issuers, their key personnel and material counterparties, covering integrity, competence, regulatory standing, and AML/CFT compliance.

Robust AML/CFT and sanctions arrangements apply to all ARVAs, associated transactions, issuers, and counterparties, including screening against global sanctions lists (e.g., UN, OFAC, EU, UAE). Ongoing monitoring is conducted in line with VARA/FATF standards.

The legal structure of each ARVA provides token holders with enforceable rights consistent with the nature of the asset reference and applicable UAE law. Tribe assesses the enforceability of such rights prior to distribution and on an ongoing basis.

Each ARVA is assessed for indicators of fraud, misrepresentation, or potential value manipulation, including the integrity of the underlying property valuation and the accuracy of offering documentation.

Each ARVA is accompanied by comprehensive disclosure covering:

• the nature and description of the underlying asset;
• the legal basis and structure of the asset reference;
• the valuation methodology and basis of unit values;
• supply mechanics;
• exit rights (if applicable); and
• known risks including illiquidity.

Important Note: This document provides a general standards framework 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.

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.

Client funds are held in a segregated client money account at Zand Bank P.J.S.C, a UAE-regulated bank. This account is held in Tribe's name on behalf of clients and is fully separated from Tribe's own business funds.

Client Virtual Assets are held in custody by Ripple Custody. Each client has a dedicated wallet. Client Virtual Assets remain the property of the client at all times and are never mixed with Tribe's own assets.

Payment processing is handled by Tap Payments, which processes payment transactions on behalf of Tribe. Tap Payments does not hold client funds on an ongoing basis.

Tribe Tokenisation FZE takes a strict zero-tolerance approach to bribery and corruption in all its forms. No director, employee, contractor, or business partner of Tribe is ever permitted to offer, give, request, or accept any bribe or corrupt payment in connection with Tribe's business. This applies everywhere Tribe operates, with no exceptions.

Tribe's full Anti-Bribery and Corruption Policy is available here.

Anyone — including people outside of Tribe — can report a suspected case of bribery or corruption confidentially using the channels below. Your identity will be kept private and you will face no negative consequences for making a genuine report.

• Email: compliance@mytribe.ae
• Phone: +971 4 594 3839

All reports are investigated carefully and kept confidential. Any confirmed unlawful conduct will be reported to VARA immediately.

None of the directors or members of the senior management team of Tribe Tokenisation FZE has any criminal convictions or ongoing criminal proceedings in the UAE or in any other country.

Tribe Tokenisation FZE is committed to maintaining an open and transparent environment where any concerns about misconduct, unethical behaviour, or regulatory breaches can be raised safely and confidentially. Tribe's Whistleblowing Policy sets out how concerns can be reported, how they will be investigated, and the protections available to anyone who raises a concern in good faith. Retaliation against whistleblowers is strictly prohibited.

Tribe's full Whistleblowing Policy is available here.