Hex Trust MENA FZE

License no.

VL/23/08/002

Licensed Activity:

Virtual Assets Custody Services - Authorised to serve Institutional Investors and Qualified Investors.

Address:

Office 426, Level 4, Convention Tower, Dubai World Trade Centre, Dubai, UAE.

Names of all Responsible Individuals

Responsible Individuals: Alessio Quaglini, Filippo Buzzi
Compliance Officer and Money Laundering Officer: Miles Corney

VA Standards

View our Knowledge Base here.
View Our VA Standards here.

Virtual Asset Risk Disclosure Statement

Introduction

This Risk Disclosure Statement provides Clients with critical information regarding the risks associated with Virtual Assets. Clients are strongly encouraged to carefully read and fully understand this statement before engaging in any products or services offered by Hex Trust.

This statement does not purport to disclose all risks associated with Virtual Assets but offers a high-level overview of material risks to assist Clients in making informed decisions. Clients should conduct their own due diligence, seek independent professional advice where appropriate, and carefully consider their financial situation, objectives, experience, and risk tolerance before engaging in Virtual Asset activities.

Overview of Key Risks Associated with Virtual Assets

Engaging in Virtual Asset activities involves significant risks, including but not limited to the following:

Loss of Value and Extreme Volatility

Virtual Assets are subject to high levels of price volatility and market uncertainty. Unlike traditional fiat currencies or regulated financial instruments, Virtual Assets often lack intrinsic value foundations, making their valuations susceptible to speculation, sentiment, and market dynamics.

Historically, Virtual Assets have demonstrated extreme price fluctuations over short periods, sometimes driven by limited liquidity, speculative trading, regulatory announcements, technological developments, or broader economic factors. As a result, Clients should be prepared to sustain substantial losses, including the possibility of a total loss of value.

Transferability and Irreversibility of Transactions

Virtual Asset transfers may not always be possible or may encounter restrictions. Some Virtual Assets may have compatibility issues between different blockchain protocols, wallet formats, or platform requirements. Additionally, once a transaction is broadcast and confirmed on a blockchain network, it is typically irreversible.

Errors in inputting wallet addresses, incorrect transfer details, or fraud by malicious actors may result in a permanent loss of Virtual Assets without recourse or recovery options.

Liquidity Risk

Liquidity risk refers to the difficulty in selling, exchanging, or realizing value for Virtual Assets at desirable prices. Not all Virtual Assets have active or deep secondary markets. In times of market stress or for niche or emerging Virtual Assets, liquidity may evaporate quickly, resulting in difficulty executing trades or converting assets to cash.

Limited liquidity can exacerbate price volatility, widen bid-ask spreads, and delay trade execution.

Privacy Considerations

Transactions involving Virtual Assets are typically recorded on public Distributed Ledger Technologies (DLTs), such as blockchains, which are transparent and immutable. While public blockchains often do not record personal identifying information directly, wallet addresses and transaction histories are publicly visible and may be linked to individuals or organizations through blockchain analytics or regulatory reporting measures.

This transparency may conflict with Clients’ expectations of privacy and could expose transactional histories to regulatory authorities, cyber attackers, competitors, or other third parties.

Fraud, Manipulation, Theft, and Limited Legal Protections

The digital and decentralized nature of Virtual Assets exposes them to heightened risks of fraud, market manipulation, theft, hacking, and cybercrime. Unlike traditional financial systems, the Virtual Asset ecosystem often lacks the robust consumer protections and regulatory safeguards that protect investors in fiat or securities markets.

Holders of Virtual Assets rely heavily on the security of private keys and wallet integrity. Loss of private keys due to negligence, theft, hacking, or fraud can result in permanent loss of access to Virtual Assets. Moreover, in many cases, there are no legal mechanisms for reversing unauthorized transactions or recovering stolen Virtual Assets.

No Deposit Protection

Client Virtual Assets ("Client VAs") held by Hex Trust MENA FZE benefit from any form of deposit protection or guarantee scheme offered by the Virtual Assets Regulatory Authority or any other component authority in the United Arab Emirates.  

Important Disclosures

• Virtual Assets are not legal tender and are not backed or guaranteed by any government.
• Past performance of Virtual Assets does not guarantee future outcomes.
• Hex Trust MENA FZE provides Virtual Asset Custody Services on an execution-only basis and does not offer financial, investment, legal, or tax advice.
• Clients are responsible for understanding all associated risks and determining the suitability of Virtual Asset transactions for their own circumstances.
• Clients should only participate in Virtual Asset activities using funds they can afford to lose entirely.

Contact Us

If you have any questions regarding this Risk Disclosure Statement or wish to seek further clarification about Virtual Asset risks, please contact us at hello@hextrust.com.

Complaint Management

At Hex Trust MENA FZE, we are committed to ensuring a fair, transparent, and responsive process for addressing client complaints in accordance with regulatory requirements. We value client feedback and view it as an essential part of maintaining trust and continuously improving our services.

Our Commitments to You

• We will acknowledge receipt of your complaint within one (1) week of receiving it.
• We aim to resolve all complaints within four (4) weeks. In the event of extraordinary circumstances that prevent resolution within this period, we will provide you with an update explaining the circumstances and will resolve the complaint no later than eight (8) weeks from the date the complaint was made.

How to Submit a Complaint

We have made it easy for you to submit a complaint. You may:

• Complete our Complaint Submission Form,
• Email us at complaints.mena@hextrust.com 

We accept complaints through multiple channels and formats to ensure accessibility. You are not required to use a specific form for your complaint to be recognized.

Complaints Involving Third Parties

If your complaint involves a third-party service provider linked to our Virtual Asset Activities, we will work directly with the third party to address your concerns. However, we will remain responsible for ensuring your complaint is fully resolved.

No Fees or Charges

We do not impose any fees or charges for submitting or handling complaints.

At Hex Trust MENA FZE, client satisfaction and regulatory compliance are of utmost importance. We are committed to addressing all concerns promptly, fairly, and professionally.

For any queries regarding our complaints handling process, please contact us at complaints.mena@hextrust.com.

Anti-Bribery and Corruption

At Hex Trust MENA FZE, we are committed to conducting our business with the highest standards of integrity, transparency, and ethical conduct. We recognise that maintaining the trust and confidence of our clients, partners, employees, and stakeholders is critical to our success. As part of this commitment, we have implemented a robust Anti-Bribery and Corruption Policy that reflects our strict zero-tolerance approach to any form of bribery or corruption.

The Company, its Board of Directors, and all Staff must act professionally, fairly, and with integrity in all business dealings and relationships, both internally and externally. We expect the same high standards from all third parties acting on our behalf.

Failure to comply with our Anti-Bribery and Corruption Policy will result in immediate disciplinary action, including the potential termination of employment without notice. In addition, any instances of non-compliance must be immediately reported to the Virtual Asset Regulatory Authority (VARA) for evaluation, in line with our regulatory obligations.

We remain fully committed to upholding a culture of integrity and ensuring that bribery and corruption have no place in any aspect of our operations.

Whistleblower Policy

Commitment to Integrity and Transparency

At Hex Trust MENA FZE, we are committed to upholding the highest standards of integrity, transparency, and ethical conduct across all areas of our operations. We foster a culture of accountability and compliance, encouraging all employees, stakeholders, and business partners to adhere to the principles that define our organization.

Maintaining an open and ethical environment is vital to our success and to maintaining the trust of our clients, employees, regulators, and partners. To support this, we have implemented a comprehensive Whistleblowing Policy that enables the reporting of any suspected misconduct, unethical behaviour, or regulatory violations.

Encouraging Transparency and Reporting Misconduct

Hex Trust MENA FZE actively encourages all employees, contractors, vendors, clients, and other stakeholders to report concerns or suspected wrongdoing, including but not limited to:

• Fraud, financial misconduct, or breaches of regulatory obligations
• Bribery, corruption, or conflicts of interest
• Harassment, discrimination, or other unethical workplace behaviour
• Non-compliance with internal policies, procedures, or legal requirements

Reports may be made openly, confidentially, or anonymously. While we encourage open or confidential reporting to facilitate effective investigation and remediation, we also recognize that some individuals may prefer to report anonymously. In such cases, whistleblowers are asked to provide sufficient detail or supporting evidence to allow a responsible investigation to proceed.

Protection and Confidentiality for Whistleblowers

Hex Trust MENA FZE has a strict zero-tolerance policy against retaliation. Any individual who reports a concern in good faith will be fully protected from any form of adverse action, discrimination, harassment, or retribution. Protection extends not only to the identity of the whistleblower but also to any identifying information that could indirectly reveal their identity, recognising that certain facts may act as a "signature."

All concerns reported will be treated with the highest degree of confidentiality and sensitivity. Investigations will be conducted thoroughly, fairly, and impartially, and where misconduct is substantiated, appropriate corrective and disciplinary actions will be taken.

No final finding of misconduct will be made solely based on anonymous allegations unless they are independently corroborated through investigation.

Reporting Channels

Hex Trust MENA FZE provides secure and confidential channels for whistleblowers to raise concerns safely.
If you suspect wrongdoing, unethical behaviour, or regulatory non-compliance, you can report your concerns securely via:

Email: whistleblowing@hextrust.com 

All concerns will be escalated appropriately and handled by designated Compliance and Risk Officers to ensure a professional and impartial review.

Closing Statement

At Hex Trust MENA FZE, we value and appreciate the essential role whistleblowers play in safeguarding our organisation’s ethical foundation. Your voice helps protect our integrity, ensure regulatory compliance, and build a stronger, more transparent future.

Conflicts of Interest

Our Commitment

At Hex Trust MENA FZE ("Hex Trust MENA"), we are committed to maintaining the highest standards of integrity, transparency, and regulatory compliance. As a regulated entity authorised by the Virtual Assets Regulatory Authority (VARA) in the Emirates of Dubai to provide Custody Services, we recognise the critical importance of identifying, managing, and mitigating any actual, potential, or perceived conflicts of interest that may arise in the course of our operations.

Conflicts of Interest Policy

Hex Trust MENA has established a comprehensive Conflicts of Interest Policy designed to:

• Identify and assess conflicts that may arise between Hex Trust MENA and its clients, or among different clients;
• Implement robust controls and procedures to manage and mitigate such conflicts;
• Disclose material conflicts to clients where they cannot be fully mitigated and provide appropriate options to protect client interests.

We are committed to acting honestly, fairly, and professionally in accordance with the best interests of our clients at all times.

Key Measures to Prevent and Manage Conflicts of Interest

We have implemented the following key measures to ensure transparency, fairness, and client protection:

Client Asset Segregation

Client assets are held in segregated custody accounts, separate from the firm's own assets, ensuring clear asset ownership and eliminating risk of misuse.

Independent Governance and Oversight

Our risk and compliance frameworks provide for independent oversight by senior management and committees, ensuring objective decision-making and escalation procedures.

Fair and Transparent Client Treatment

Hex Trust MENA does not provide preferential treatment to any client. All clients are treated fairly and equitably under consistent operational standards.

No Proprietary Trading

Hex Trust MENA does not engage in proprietary trading of Virtual Assets. Our sole focus is on safeguarding client assets in a neutral and conflict-free manner.

Strict Employee Conduct and Ethics

Employees are required to comply with a Code of Conduct that mandates disclosure of external interests, prohibits personal trading that could give rise to conflicts, and requires immediate reporting of any potential conflict situations.

Training and Awareness

Staff undergo regular training on conflicts of interest, ethical behaviour, and regulatory obligations to reinforce a culture of compliance and client-first responsibility.

Management of Material Conflicts

Where an unavoidable conflict of interest is identified that cannot be fully eliminated, Hex Trust MENA will:

• Disclose the conflict to the affected client(s) clearly and promptly;
• Outline the nature of the conflict and the options available to the client;
• Take all reasonable steps to manage the conflict to ensure that the client’s interests are not adversely affected.

In all cases, we prioritise client protection, fairness, and regulatory compliance in line with VARA expectations and principles.

Declaration

At the time of this statement, Hex Trust MENA FZE confirms that it has no known actual or material conflicts of interest arising from its custodial activities.

We remain committed to operating with full transparency and integrity, upholding the trust placed in us by our clients, regulators, and stakeholders.

Custody of Client Assets Statement

Hex Trust MENA FZE ("Hex Trust MENA") confirms that it does not maintain any client accounts, funds, or Virtual Assets with third parties.

All client assets are held directly under Hex Trust MENA’s custody, fully segregated from the firm's own assets, and maintained in accordance with our regulatory obligations.

We ensure full control, transparency, and protection of client assets through robust custody operations, comprehensive internal controls, and adherence to the highest standards of security, governance, and regulatory compliance.

‍