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LEXIM TRADING DMCC
PUBLIC DISCLOSURES

Updated on: 26 October 2024

Conflicts of Interest Policy Statement

At Lexim Trading DMCC, we are committed to maintaining the highest standards of integrity, transparency, and fairness in all operations. We recognise that conflicts of interest can arise while providing our services. As part of our dedication to fostering trust and accountability with our clients and stakeholders, we have implemented a comprehensive Conflicts of Interest Policy.

Please refer to our Conflicts of Interest Policy here.

Privacy Policy Statement

At Lexim Trading DMCC, we are committed to safeguarding personal data in compliance with applicable laws and regulations. Our Privacy Policy explains how we collect, use, share, and protect our clients' information and our clients' rights regarding their data. This applies to all interactions with our website and services, including data processed by third parties on our behalf.

For more details, please refer to our Privacy Policy here.

Anti-Bribery and Corruption Policy

Lexim Trading DMCC is committed to the highest ethical standards and compliance with all applicable anti-bribery and anti-corruption laws and regulations. We maintain a zero-tolerance approach toward bribery and corruption in any form. The Anti-Bribery and Corruption Policy outlines our dedication to preventing such practices, sets expectations for employee conduct, and mandates reporting any suspected violations to uphold the integrity of our business operations.

Reporting Channels:

Lexim has established, maintained, and published on its website, methods of contact, including but not limited to a telephone line, email address, or mailing address, for receiving reports of any violation or possible violation of any applicable laws and regulations relevant to anti-bribery and corruption by Lexim, its Board, or staff on its behalf.

This may be done either in person or anonymously:

Concerned Individuals:

(a) Line Manager; and/or

(b) Head of Human Resources

Lexim's Email Address for Reporting: compliance@lexim.gold or hr@lexim.gold.

Lexim's Mailing Address for Reporting: Lexim Trading DMCC, Mazaya Business Avenue 2201, Tower AA1, First Al Khail St Jumeirah Lake Towers, Dubai, United Arab Emirates.

Lexim's Contact Number for Reporting: +971 (0)4 375 1987.

For more details, please refer to our Anti-Bribery and Corruption Policy here.

Complaint Handling Policy

At Lexim Trading DMCC, we are committed to handling all customer complaints related to trading virtual assets on our platform fairly and efficiently. The Complaints Handling Policy outlines our procedures to manage concerns efficiently and transparently. We strive to investigate all issues thoroughly, provide clear communication throughout the process, and implement appropriate solutions to maintain the highest standards of service and client satisfaction.

For more details, please refer to our Complaint Handling Policy here.

Virtual Asset Standards/ Listing Policy

At Lexim Trading DMCC, we ensure that all virtual assets listed on our platform adhere to stringent criteria designed to protect clients and uphold the integrity of our trading environment. Our Virtual Assets Listing Standards Policy outlines the evaluation process, focusing on legal compliance, market demand, technology standards, and risk management. We assess factors such as the underlying technology, the team's track record, the asset's market performance, and adherence to relevant regulatory requirements and industry best practices.

Please refer to our Virtual Asset Standards/ Listing Policy here.

Responsible Individuals

Lexim Trading DMCC is regulated by the Dubai Virtual Assets Regulatory Authority. As per the regulatory requirements under Rule V.A.3 of VARA’s Market Conduct Rulebook and Rule I.B.2 of VARA’s Broker-Dealer Services Rulebook, Lexim Trading DMCC is required to make certain disclosures regarding its leadership.

The responsible individuals of Lexim Trading DMCC are as follows:

Zhou Fan Zhang, Chief Executive Officer
Timothy Sawyer, Chairman of the Board of Directors

Furthermore, Lexim Trading DMCC confirms that as of October 2024, no members of the company's Board of Directors or Senior Management have been prosecuted or convicted before the courts of the United Arab Emirates or any other jurisdiction. Lexim Trading DMCC believes in upholding high standards of integrity, and this commitment is reflected in the pristine record of our leadership.

Pricing of Virtual Assets

Lexim Trading DMCC determines the prices of the virtual assets it quotes to clients based on current and prevailing prices of the underlying commodities, that is, gold. Additional factors include the supply and demand for the commodity, market volatility and liquidity, available inventory, order quantity and trader discretion. Additionally, any applicable fees are transparently disclosed to clients at the time of the transaction

Execution Practices

Lexim Trading DMCC does not engage in order routing as part of its business operations. Lexim Trading DMCC strives to ensure that orders are executed at the best available price and in accordance with the best standards. Lexim adheres to all relevant regulatory requirements in this regard.

For more details, please refer to our Execution Practices here.

Clearing Services and Custody for Other VASPs

Lexim Trading DMCC does not hold or maintain funds or virtual assets, nor does it provide clearing services for other virtual asset service providers offering broker-dealer services.

Client Asset Protection

Lexim Trading DMCC employs robust measures to protect the ownership of client assets held by our firm. All virtual assets are stored using institutional grade and independently certified custody technology to ensure maximum security. Additionally, Lexim Trading DMCC complies with relevant legal or regulatory frameworks governing the safeguarding of client assets against loss or theft and performs regular audits to verify the integrity of all holdings.

Referral and Introduction Arrangements

Lexim Trading DMCC does not, in the ordinary course of business, refer or introduce clients to other entities or virtual asset service providers. Should any such arrangement occur, it would be entirely ad hoc, with no formalised monetary or non-monetary benefit schemes in place.

Third-Party Custody and Maintenance of Virtual Assets

Lexim Trading DMCC does not use a third-party custodian for the safekeeping of client virtual assets. Instead, Lexim directly manages and safeguards client virtual assets through its own secure custody infrastructure.

To ensure the highest standards of asset protection, Lexim:

Implements robust security measures, including multi-signature wallets, cold storage solutions, and advanced encryption protocols.
Maintains full regulatory compliance with all applicable VARA requirements regarding the custody and safeguarding of virtual assets.

Conducts regular security audits and risk assessments to uphold the integrity and safety of client assets.

Material Risks of Virtual Assets

Lexim Trading DMCC advises all users to be aware of the following material risks associated with Virtual Assets (VAs):

Loss of Value & Volatility: VAs may experience extreme price fluctuations and could lose their value partially or entirely.
Transferability & Irreversibility: Some VAs may not always be transferable, and transactions may be irreversible, leading to potential loss if errors occur.
Liquidity Risks: VAs may not always be easily sold or converted into fiat or other assets due to market conditions.
Privacy & Public Ledger Risks: Certain VA transactions are recorded on public DLTs, making them visible and traceable.
Fraud & Security Risks: VAs are vulnerable to fraud, manipulation, hacking, and other cyber threats and may not benefit from legal protections.
Technology Risks: Loss of private keys or technical failures may result in permanent loss of assets.

Virtual Assets Offered

Symbol

DAU