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Microtrade Anti-Fraud Policy

1. Introduction

The Anti-Fraud Policy (the “AF Policy”) of MicroAlgoTrading Inc LTD as World Trust Tower, 50 Stanley St,

Central, Hong Kong, registration number 2843392 (“we”, “our”, “us” or “Microtrade”) is stablished

to prevent and mitigate possible risks of Microtrade being involved in illegal or illicit activities and to

enable Microtrade to meet its legal and regulatory obligations in this area (if any, where applicable).

This AF Policy is subject to changes and updates by Microtrade from time to time to ensure compliance

with any applicable legislation and global AF practices.

2. Policy Statement

2.1. Microtrade will comply with applicable laws of Hong Kong. In line with applicable laws
Microtrade has a ‘zero tolerance’ policy towards fraud, collusion, money laundering, financing of
terrorism and other criminal conduct and will thoroughly investigate and seek to take legal action
against those who perpetrate, are involved in, or assist with fraudulent or other improper actions in
all Microtrade activity and related transactions.
2.2. Microtrade will provide adequate and appropriate resources to implement the Anti-Fraud Policy and
will ensure it is communicated and understood.

3. Purpose&Scope

3.1. The purpose of this document is to outline the responsibilities of all the involved parties with respect
to fraud prevention, the actions to be taken if fraud is suspected and the mechanism of verifying
suspicion of fraud, the reporting process and the recovery action plan.

4. Legislation Compliance

4.1. The Anti-Fraud Policy has been drafted to comply with the current applicable law, including, but not
limited to applicable laws of Hong Kong.
4.2. Adherence to the Anti-Fraud Policy Microtrade will ensure compliance with all relevant legislation
and internal policies.

5. The User verification (over 50.000 USD deposit)

5.1. The User undertakes to provide Microtrade with correct and relevant personal information and
documents contained therein. In case the User provides counterfeit documents and false personal
information, such behavior will be interpreted as a fraudulent activity.
5.2. The User hereby authorizes Microtrade, directly or indirectly (through third parties), make any
inquiries as we consider it necessary to check the relevance and accuracy of the information provided
for verification purposes. Personal Data transferred will be limited to strictly the necessary and with
security measures in use to protect the data and is specifies in our Privacy Policy

6. Account security

6.1. The User is responsible for maintaining the confidentiality of their Account’s credentials, including,
but not limited to a password, email, wallet address, balance and of all activity including transactions
made through the Account.
6.2. If the User has any security concerns about his/her Account, login details, password or other security
feature being lost, stolen, misappropriated, used without authorization or otherwise compromised,
the User is advised to change the password. The User must contact us via [email protected]
without undue delay on becoming aware of any loss, theft, misappropriation or unauthorized use of

the Account, login details, password or other security features. Any undue delay in notifying
Microtrade may not only affect the security of the Account but may result in the User being liable
for any losses as a result.
6.3.Any loss or compromise of User’s electronic device or User’s security details may result in
unauthorized access to User’s Account by third parties and the loss or theft of any digital currency
held in User’s Account. User must always keep his/her security details safe. For example, User
should not write them down or otherwise make them visible to others.
6.4. User should never allow remote access or share his/her computer screen with someone else when
User is logged on to Account. Microtrade will never under any circumstances ask User for IDs,
passwords, or 2-factor authentication codes or to screen share or otherwise seek to access to
computer or Account. User should not provide details to any third party for the purposes of remotely
accessing User’s Account unless specifically authorized.
6.5. Microtrade assume no responsibility for any loss that User may sustain due to compromise of
Account login credentials due to no fault of Microtrade.

7. Key Responsibilities

7.1.In view of the Anti-Fraud Policy Microtrade is responsible for:
• Undertaking a regular review of the fraud risks associated with each of the key organizational
• Establishing an effective anti-fraud response plan, in proportion to the level of fraud risk identified;
• The design of an effective control environment to prevent fraud;
• Establishing appropriate mechanisms for:
o reporting fraud risk issues.
• Making sure that all staff are aware of Microtrade Anti-Fraud Policy and know what their
responsibilities are in relation to combating fraud; and
• Ensuring that appropriate action is taken to minimize the risk of previous frauds occurring in future.

8. Fraud detection and investigation

8.1. Microtrade’s Operational Anti-Fraud Department, in particular, the Head of Anti-Fraud Services, is
the first line of detection, investigation and protection in preventing Prohibited Activities through the
Users and transactions appraisal process. The Head of Anti-Fraud Services will be responsible for
the proper fulfillment of the Anti-Fraud Policy.

9. Miscellaneous

9.1. Microtrade will review the Anti-Fraud Policy to reflect new legal and regulatory developments and
ensure good practice.