Public Disclosure

LBK Exchange FZE (“LBank” or the “Company”) provides exchange services for virtual assets

(“Exchange Services”) and is licensed by the Virtual Assets Regulatory Authority (“VARA”) in Dubai.

These public disclosures (“Public Disclosures”) have been developed for LBank. These Public

Disclosures are reviewed annually unless there is a change in regulation or LBank’s business that requires

to implement an earlier update.

LBank has been granted a Virtual Asset Service Provider (“VASP”) license by VARA to provide

Exchange Services in the emirate of Dubai, United Arab Emirates. LBank’s license number is as follows:

[to be inserted once license is issued] and is valid for the period starting from [insert start date] to [insert

end date].

1. CONFLICT OF INTEREST

1.1. LBank is committed to conducting its business according to the principle that it must manage conflicts of

interest appropriately. At present there are no actual, identified conflicts of interest arising out of

LBank’s Exchange Services. LBank has and will continue to identify potential conflicts of interest

arising out of its outsourcing arrangements with group entities. LBank has put in place internal

mechanisms and guardrails to ensure that no actual conflicts arise, or are adequately managed should

they arise, including the Company’s Conflict of Interests Policy. We recognise that conflicts may occur

between:

(a) LBank and its clients;

(b) one client and another;

(d) LBank and its group entities or vendors.

1.2. To address this, we have put in place:

(a) Identification processes to detect conflicts (including financial interests, personal relationships,

inducements, proprietary trading, and related-party transactions).

(b) Preventive measures such as separation of duties, “Chinese Walls” between client and proprietary

trading, mandatory disclosure of employee outside business interests, and strict controls on

gifts/benefits.

require staff declarations, and monitor related-party transactions.

(d) Disclosure obligations ensure that, where conflicts cannot be avoided, affected clients are informed

in writing in sufficient detail to make an informed decision.

1.3. Our approach ensures that any conflict is either avoided, effectively managed, or disclosed transparently

to protect clients and uphold market integrity.

1.4. This has further been detailed in the Conflict-of-Interest Policy of LBank available at:

https://uae.lbank.com/support/articles/2027274822207143936

2. PRIVACY

2.1. LBank appreciates you trusting the Company with your personal data. LBank is committed to protecting

your privacy.2.2. Our Privacy Policy is designed to comply with the UAE’s Federal Data Protection Law and VARA

requirements. We collect and process personal data such as:

(a) Identifiers (name, ID details, contact information, login credentials).

(b) Sensitive data (biometric, religious beliefs, criminal records) only where required by AML/CFT or

other legal obligations.

(d) Financial data (bank account, card, and tax details).

(e) Marketing and usage data (preferences, communication history, interactions with our platform).

2.3. We use this data for purposes including onboarding, providing services, verifying identity, fraud

prevention, legal compliance, customer support, analytics, and marketing (with consent).

2.4. Your data may be shared with regulators (including VARA, CBUAE, and law enforcement), our

affiliates, payment providers, technology partners, and other authorised third parties under strict

contractual safeguards. International transfers are permitted only where adequate protections exist or

through binding safeguards such as contractual clauses.

2.5. You have the right to: access, rectify, erase, restrict, and port your data; object to processing; withdraw

consent; and file complaints with the UAE Data Office or CBUAE. We retain personal data for at least

five years, as required under CBUAE regulations.

2.6. To protect your data, LBank applies strong encryption, access restrictions, security testing, breach

notification procedures, and ongoing monitoring of risks.

2.7. For more details on how LBank collects and processes your personal data, you can access the

Company’s Privacy Policy: https://uae.lbank.com/support/articles/1958056230861668352, and the

Client Agreement https://uae.lbank.com/support/articles/2027304962794455040.

3. COMPLAINTS AND WHISTLEBLOWING

3.1. LBank is committed to promptly, fairly, consistently and efficiently resolving all complaints received

from its clients and/or other stakeholders. LBank views complaints as an opportunity to continually

improve the quality of its offerings. To that end, LBank has formulated and implemented comprehensive

complaint-handling procedures. If you seek to make any complaints, you can write to the Company at

uaesupport@lbank.com. While LBank may, at its discretion, outsource the handling of complaints to its

group companies or a third party, all responsibility for handling complaints shall remain with LBank as

if LBank is handling such complaints in-house. Further, all such arrangements shall be made by way of

written agreements that are in compliance with all applicable laws, including those in relation to

outsourcing, as may be prescribed by VARA and the Central Bank of the UAE from time to time. For

further details on the LBank’s complaints handling procedure and policy, you can read the Company’s

Complaints Handling Policy on the LBank’s website.

3.2. As further detailed in the Compliant Handling Policy, LBank. is committed to resolving client

complaints promptly, fairly, and transparently. Complaints will be acknowledged within one (1) week

and resolved within four (4) weeks, or, in exceptional cases, within eight (8) weeks with status updates

provided. Clients may submit complaints through multiple accessible channels, and no fees shall be

charged for lodging or processing complaints.The Complaints Handling Policy available at:

https://uae.lbank.com/support/articles/20272714511317729283.3. We maintain clear procedures for investigating complaints, including those involving third-party service providers, and take appropriate action to remedy any recurring or systemic issues. A record of all

complaints, actions taken, and outcomes is maintained in accordance with regulatory obligations. Our

procedures are available on our website and designed to ensure fairness and accountability in every

client interaction.

3.4. Whistleblowing: LBank is committed to the highest standards of integrity, accountability, and

transparency. LBank seeks to be responsive to all employees and stakeholders, be seen as a trusted

organization that treats its employees with respect, demonstrate commitment to its own policies and

applicable laws and regulations, and strengthen the “speak up” culture. An important aspect of this

mechanism is to enable the voicing of concerns in a responsible and effective manner.

(a) Reporting Mechanism: Employees and other stakeholders are encouraged to report concerns

through the whistleblowing channels outlined in the LBank’s Whistleblowing Policy. Reports

may be submitted anonymously; however, providing contact information is encouraged to

facilitate follow-up and a more effective investigation process. Apart from this, you can write to

LBank at uaesupport@lbank.com anonymously.

(b) Protection for Whistleblowers: LBank strictly prohibits any form of retaliation against individuals

who report concerns in good faith. Disciplinary action, up to and including termination, will be

taken against any employee who retaliates against a whistleblower. The identity of the

whistleblower will be kept confidential to the extent permitted by applicable laws and disclosed

only on a need-to-know basis for the purpose of investigation.

whistleblowing team or appointed personnel. LBank is committed to ensuring that investigations

are conducted impartially, objectively, and in a timely manner. Where appropriate, the outcome

of the investigation will be communicated to the whistleblower within a reasonable timeframe,

depending on the complexity of the matter.

(d) Non-retaliation assurance: We reaffirm our commitment to maintaining an environment in which

concerns can be raised without fear of adverse consequences. Any instance of retaliation will be

addressed seriously and may result in disciplinary measures, including termination of

employment. We encourage employees, clients, and partners to report any concerns that may

affect the integrity or reputation of LBank.

(e) Whistleblowing policy is available at:

https://uae.lbank.com/support/articles/2027273991755923456

4. RISK

4.1. Virtual assets transactions are subject to several risks, including but not limited to market risks, credit

risks, liquidity risks, and technology risks. Please read the Company’s detailed Risk Disclosure

Statement at https://uae.lbank.com/support/articles/1958065714497585152 for more information on the

risks associated with virtual assets including the types and nature of such risks, and a statement on the

likelihood and severity of any losses which may be suffered.

4.2. LBank advises all users to be aware of the following material risks associated with virtual assets:

(a) Loss of Value & Volatility: Virtual assets may experience extreme price fluctuations and could

lose their value partially or entirely.(b)

Transferability & Irreversibility: Some virtual assets may not always be transferable, and

transactions may be irreversible, leading to potential loss if errors occur.

due to market conditions.

(d) Privacy & Public Ledger Risks: Certain virtual assets may transactions are recorded on public

DLTs, making them visible and traceable.

(e) Fraud & Security Risks: Virtual Assets are vulnerable to fraud, manipulation, hacking, and other

cyber threats and may not benefit from legal protections.

(f) Technology Risks: Loss of private keys or technical failures may result in permanent loss of

assets.

5. SERVICES

5.1. LBank conducts:

(a) an exchange, trade or conversion between Virtual Assets and fiat currency;

(b) exchange, trade or conversion between one or more Virtual Assets;

between (i) Virtual Assets and fiat (i) Virtual Assets and fiat currency or (ii) one or more Virtual Assets; or

(d) maintenance of an order book in furtherance of (a), (b) and (c).

5.2. LBank’s list of virtual assets and products is continually expanding, and updates will be reflected on

LBank’s website as new virtual assets are added. Currently, LBank supports trading in the following virtual assets:

No.	Token Name	Symbol	CoinMarketCap/CoinGeko Link
1	Bitcoin	BTC	https://coinmarketcap.com/currencies/bitcoin/
2	Ethereum	ETH	https://coinmarketcap.com/currencies/ethereum/
3	Tether	USDT	https://coinmarketcap.com/currencies/tether/
4	XRP	XRP	https://coinmarketcap.com/currencies/xrp/
5	Binance Coin	BNB	https://coinmarketcap.com/currencies/bnb/
6	Solana	SOL	https://coinmarketcap.com/currencies/solana/
7	USD Coin	USDC	https://coinmarketcap.com/currencies/usd-coin/
8	Dogecoin	DOGE	https://coinmarketcap.com/currencies/dogecoin/
9	Cardano	ADA	https://coinmarketcap.com/currencies/cardano/
10	TRON	TRX	https://coinmarketcap.com/currencies/tron/
11	Lido Staked ETH	STETH	https://www.coingecko.com/en/coins/lido-staked-ether
12	Wrapped Bitcoin	WBTC	https://www.coingecko.com/en/coins/wrapped-bitcoin
13	Chainlink	LINK	https://coinmarketcap.com/currencies/chainlink/
14	Hedera	HBAR	https://coinmarketcap.com/currencies/hedera/
15	UNUS SED LEO	LEO	https://coinmarketcap.com/currencies/unus-sed-leo/
16	Stellar	XLM	https://coinmarketcap.com/currencies/stellar/
17	Avalanche	AVAX	https://coinmarketcap.com/currencies/avalanche/
18	Sui	SUI	https://coinmarketcap.com/currencies/sui/
19	Litecoin	LTC	https://coinmarketcap.com/currencies/litecoin/
20	Shiba Inu	SHIB	https://coinmarketcap.com/currencies/shiba-inu/
21	Bitcoin Cash	BCH	https://coinmarketcap.com/currencies/bitcoin-cash/
22	Toncoin	TON	https://coinmarketcap.com/currencies/toncoin/
23	Polkadot	DOT	https://coinmarketcap.com/currencies/polkadot-new/
24	Mantra	OM	https://www.coingecko.com/en/coins/mantra
25	Ethena USDe	USDE	https://coinmarketcap.com/currencies/ethena-usde/
26	Dai	DAI	https://coinmarketcap.com/currencies/multi-collateral-dai/
27	Hyperliquid	HYPE	https://coinmarketcap.com/currencies/hyperliquid/
28	Uniswap	UNI	https://coinmarketcap.com/currencies/uniswap/
29	Aptos	APT	https://coinmarketcap.com/currencies/aptos/
30	Near Protocol	NEAR	https://coinmarketcap.com/currencies/near-protocol/
31	Ondo	ONDO	https://coinmarketcap.com/currencies/ondo-finance/
32	Ethereum Classic	ETC	https://coinmarketcap.com/currencies/ethereum-classic/
33	Pepe	PEPE	https://coinmarketcap.com/currencies/pepe/
34	Aave	AAVE	https://coinmarketcap.com/currencies/aave/
35	Internet Computer	ICP	https://coinmarketcap.com/currencies/internet-computer/
36	OKB	OKB	https://coinmarketcap.com/currencies/okb/
37	Trump Official	TRUMP	https://coinmarketcap.com/currencies/official-trump/
38	VeChain	VET	https://coinmarketcap.com/currencies/vechain/
39	Bittensor	TAO	https://coinmarketcap.com/currencies/bittensor/
40	Cronos	CRO	https://coinmarketcap.com/currencies/cronos/
41	Polygon	POL	https://coinmarketcap.com/currencies/polygon-ecosystem-token/
42	Filecoin	FIL	https://coinmarketcap.com/currencies/filecoin/
43	Algorand	ALGO	https://coinmarketcap.com/currencies/algorand/
44	GateToken	GT	https://coinmarketcap.com/currencies/gatetoken/
45	Celestia	TIA	https://coinmarketcap.com/currencies/celestia/
46	Kaspa	KAS	https://coinmarketcap.com/currencies/kaspa/
47	Arbitrum	ARB	https://coinmarketcap.com/currencies/arbitrum/
48	Cosmos	ATOM	https://coinmarketcap.com/currencies/cosmos/
49	Starknet	STRK	https://coinmarketcap.com/currencies/starknet-token/
50	DeXe	DEXE	https://www.coingecko.com/en/coins/dexe

5.3. Please note that the following information, as mentioned herein below, for the tokens provided under point 5.2 of this document, can be accessed through publicly available data sources, including CoinMarketCap and CoinGecko. For the convenience of users, links to the sources are provided for each token in the table under point 5.2 of this document.

i. Date of issuance;

ii. Market capitalisation and fully diluted value;

iii. Circulating supply, including as a percentage of maximum total supply (if applicable);

iv. Whether the virtual asset has been subject to an independent smart contract audit, and the date of the most recent audit; and

v. Largest reduction in price from high to low stated as both an absolute amount and a percentage change, including when it occurred.

6. RESPONSIBLE INDIVIDUALS

6.1. In accordance with applicable laws and regulations, LBank has appointed the following two (2)

individuals who are senior officials at LBank as responsible parties to ensure LBank’s compliance with

all legal and regulatory obligations:

Sr. no.	Name	Designation	E-mail
1.	Mr. Qiang Chen	Director	xiangzhang@lbk.one
2.	Mr. Wei He	Director and UBO	eric.he@lbank.com

7. EXECUTION

7.1. Trading Venue: Please note that all client orders will be settled on the LBank platform. LBank matches

the orders between the clients and maintains the order books accordingly.

7.2. Deposit process: Please note that all client deposits through their personal external wallet are made to a

unique deposit address managed by LBank, generated with Fireblocks. This is a temporary address

through which compliance verification of the transactions and the client is conducted per the regulatory

requirements and LBank's internal policies. Once the compliance verification is complete, the client

deposits are swept into the Client Hot Wallet. The Client Hot Wallet is exclusively for client virtual

assets (“VAs”) and is segregated in accordance with VARA's client asset segregation requirements.

LBank’s own VAs are held in different and segregated hot and cold wallets in compliance with

applicable regulations.

7.3. Protection of client VAs: As mentioned above, the Client Hot Wallet is exclusively for client VAs and

is segregated in accordance with VARA's client asset segregation requirements. LBank’s own VAs are

held in different and segregated hot and cold wallets in compliance with applicable regulations.

Furthermore, to ensure the protection of client VAs, all transactions are only executed once all three key

shards have authorised the transaction. LBank has also engaged the services of CoinCover for the

disaster recovery of the keys. This has been further outlined in the internal Key and Wallet management

Policy.

7.4. Ownership of Client VAs: Client Assets are pooled together in Client Hot and Cold Wallets (omnibus), which are separate from the wallet holding Lbank’s proprietary assets. All Client VAs are tracked and attributed to a client through internal ledgers linking the client’s account on the LBank platform to the specified amount of VAs deposited by them.

7.5. Price Quote: Exchange trading policy: LBank uses a transparent pricing methodology supported by

independent external market sources. Prices are derived from tier-1 exchanges (e.g., Binance, Coinbase)

through publicly accessible APIs, and are cross-validated with data from independent aggregators such

as CoinMarketCap. Internal systems compare multiple market feeds to detect anomalies or manipulation,

ensuring that valuations remain fair, accurate, and consistent. This has been further outlined in LBank's

internal Exchange Trading Policy.

7.6. LBank does not introduce its clients to any other entities. LBank does not refer or introduce clients to

other entities, including but not limit to, other VASPs.

8. HOLDING AND CONTROLLING CLIENT MONEY

8.1. In the process of providing Exchange Services, LBank does not hold or control Client Money (as defined

in the VARA Compliance and Risk Management Rulebook). This Client Money will be held in dedicated

Client Money Accounts (as defined in the VARA Compliance and Risk Management Rulebook) in

accordance with applicable laws and regulations. Client Money is held with Zand Bank (designated

licensed financial institution). LBank shall ensure that Client Money is always identifiable and secure.

LBank shall ensure compliance with all applicable law and regulations in handling and controlling Client

Money, including formulating and implementing the necessary policies, systems and controls,

appropriate to the nature and scale of LBank’s operations. LBank’s own operational funds accounts will

not be commingled with the Client Money.

9. STATEMENTS BY LBANK

9.1. LBank does not hold or maintain funds or virtual assets or provide clearing services for other VASPs.

9.2. Clients must appreciate the complexities of the crypto market dynamics, including the potential for high

volatility and/or low liquidity, and ensure that they are covered by risk management strategy. Virtual

asset prices are affected by factors such as global economic and non-economic events, demand and

supply, interest rates and currency exchange rates, cyber theft from digital wallets, market regulation

measures, and the popularity of businesses offering virtual asset-related services. Overall, negative

sentiment fueled by influences, news, allegations, or events pertaining to the blockchain space can also

have an adverse effect on the virtual assets market at large and the value of certain virtual assets in

particular.

9.3. Liquidity risk is a critical concern for any virtual assets institution, including Lbank. This risk is

characterised by the possibility that LBank may not be able to efficiently meet its expected and

unexpected current and future financial obligations without impacting its regular operations, incurring

significant losses, or being unable to convert virtual assets into fiat currency at the time of a client's

request. In scenarios of a heightened liquidity shortage, clients may not be able to withdraw their

holdings at their convenience in some particular assets that are under liquidity constraints at a particular

moment. Furthermore, there may be limitations on the clients' ability to receive their holdings in the

same virtual assets or in the desired fiat equivalent. Such temporary restrictions are to be expected solely

under conditions of severe market distress.

9.4. LBank shall also publish on its website or by other publicly accessible means, any such additionalinformation relating to its business or activities as may be reasonably required by VARA, to the extent

permissible under applicable laws.

10. PAST CONVICTIONS

10.1. No members of Lbank’s senior management or board of directors have faced any past convictions or

prosecutions, whether before the courts of the UAE or the courts of another jurisdiction.

11. VA STANDARDS

11.1. LBank ensures that all virtual assets listed on its platform adhere to stringent criteria designed to protect clients and

uphold the integrity of our trading environment. The Virtual Assets Listing Standards outline the evaluation process,

focusing on legal compliance, market demand, technology standards, and risk management.

11.2. LBank assesses 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.

11.3. The VA Standards are available at: https://uae.lbank.com/support/articles/1958068338718408704