Last updated: 27/09/2025

1. Overview

Scintilla Network FZE (“Scintilla”) upholds fair, transparent, and orderly markets in compliance with the VARA Market Conduct Rulebook.

2. Commitment to Fair Markets

Scintilla prohibits and actively monitors against:

• Market Manipulation – including wash trading, spoofing, or price distortion.

• Insider Trading – misuse of material non-public information.

• Unfair Dealing – preferential treatment or misleading practices.

3. Issuance Integrity

For token issuances (where applicable):

• Whitepapers are accurate, fair, and approved by VARA.

• Disclosures cover risks, rights, restrictions, and lock-ups.

• Allocations are conducted transparently, without manipulation or unfair advantage.

4. Monitoring & Enforcement

• Market conduct is monitored by Compliance using surveillance and analytics tools.

• Suspicious transactions are reported to VARA and relevant AML authorities.

• Staff receive regular training on market conduct obligations.

5. Our Commitment

Scintilla will take immediate action, including suspension of activity, termination of accounts, and regulatory reporting, where breaches are identified.

6. Contact Us

For more details on Scintilla’s Market Conduct Policy, please email: contactus@scintillanetwork.com.

Market Conduct Statement

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