Last updated: 27/09/2025

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1. Overview

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

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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.

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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.

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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.

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5. Our Commitment

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

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6. Contact Us

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

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