Compliance Declaration – SCANDIC COIN

Introduction

SCANDIC COIN is part of the SCANDIC GROUP brand portfolio and functions as a utility token within the SCANDIC ecosystem. The token grants access to goods and services without conferring any profit participation, interest, or repayment rights. As the issuer of SCANDIC COIN, we are fully aware of the extensive legal and regulatory requirements imposed on providers of crypto-assets. This compliance declaration documents how SCANDIC COIN has established internal regulations, risk management processes, and control mechanisms to ensure legal conformity, ethics, and responsible conduct.

SCANDIC ASSETS FZCO
Dubai Silicon Oasis DDP
Building A1/A2
Dubai — 342001, United Arab Emirates
Phone: +97 14 3465-949
Email: Info@ScandicAssets.dev
Commercial Register: Verify certificate

Represented by:
SCANDIC TRUST GROUP LLC
(hereinafter referred to as “SCANDIC GROUP”)
IQ Business Centre, Bolsunovska Street 13–15
Kyiv — 01014, Ukraine
Phone: +38 09 71 880-110
Email: Info@ScandicTrust.com
Commercial Register: View extract

In cooperation with:
LEGIER Beteiligungs mbH
Kurfürstendamm 14
10719 Berlin, Federal Republic of Germany
Commercial Register: HRB 57837
Register Court: Berlin-Charlottenburg
VAT ID: DE 413445833
Phone: +49 (0) 30 99211-3469
Email: Office@LegierGroup.com
German Commercial Register: View entry

Legal Notice:
SCANDIC ASSETS FZCO and LEGIER Beteiligungs mbH act as non-operational service providers. All operational activities of SCANDIC DATA are carried out by SCANDIC TRUST GROUP LLC. SCANDIC ASSETS FZCO serves as the holding company and brand owner, while all operational and managerial responsibilities are assumed by SCANDIC TRUST GROUP LLC.

1. Compliance Organization

SCANDIC COIN maintains an independent compliance management system seamlessly integrated into the structures of the SCANDIC GROUP. The management board is supported by an internal compliance department responsible for legal affairs, data protection, information security, risk management, and internal audits. A comprehensive policy stack combines regulations on corporate governance, data protection, supply-chain and human-rights policies, modern slavery declarations, cookie policies, and specific provisions for token operations. Responsibilities and escalation procedures are clearly defined; risk management coordinates legal, operational, technological, and reputational risks. Regular reports to executive management ensure transparency and consistent implementation of compliance objectives.

3. Data Processing and Due Diligence

Prior to establishing a business relationship, SCANDIC COIN conducts comprehensive risk assessments. For corporate clients, we verify company names, addresses, and beneficial owners based on commercial register extracts. Potential users must confirm that they will not use the utility token for illegal activities and that they comply with all applicable export and data protection laws. Technical and organizational measures (TOMs) for data classification and encryption are implemented. Transactions and user activity may be monitored for irregularities; in cases of suspected misuse (e.g., money laundering, terrorism financing), access may be restricted, and authorities notified if necessary.

4. Marketing and Communication

Our marketing communication follows principles of transparency and fairness. We clearly state that SCANDIC COIN is a utility token issued by the SCANDIC GROUP and identify the contracting entity. Product descriptions concerning availability, performance, and security features are based on verifiable data. We refrain from misleading claims and disclose actual conditions. Marketing is directed exclusively at businesses and institutions; no targeted advertising is directed at vulnerable groups. Supplementary services from other brands within the group (e.g., payment services from SCANDIC PAY or media services from LEGIER MEDIA) are clearly identified as separate offerings.

5. Sanctions Screening and Prohibited Content

SCANDIC COIN screens all clients and transactions against national and international sanctions lists. We reject business inquiries if companies, owners, or end users appear on sanctions lists or if providing token access would risk violating export control or embargo regulations. The use of the utility token for illegal purposes (e.g., terrorism financing, money laundering, or fraud) is strictly prohibited. We reserve the right to immediately suspend such activities and notify law enforcement authorities.

6. Whistleblowing System

The SCANDIC GROUP operates a confidential whistleblowing system, which is also used by SCANDIC COIN. Employees, clients, or business partners can report violations of laws, internal regulations, or human rights through a secure platform without fear of reprisal. Reports are treated confidentially, investigated, and documented. External bodies or authorities may be involved where necessary. Results and actions are published in anonymized form to ensure transparency.

7. Training and Awareness

All employees of SCANDIC COIN undergo regular training on data protection, information security, anti-money laundering (AML), human rights, and compliance. Specific training related to token operations addresses risks such as cyberattacks, manipulation, fraud, data protection, and emergency procedures. Training sessions are documented and updated at least annually.

8. Monitoring and Continuous Improvement

Our compliance program is subject to a process of continuous improvement. Internal audits, risk assessments, external certifications, and client feedback contribute to the ongoing enhancement of our policies. Technical measures such as zero-trust architectures, SIEM/SOAR systems, network segmentation, and signed supply-chain artifacts ensure high standards of security and data protection. SCANDIC COIN publishes regular reports on progress, challenges, and new regulatory developments. Our goal is to assume a leading role as a responsible utility-token provider while maintaining the highest levels of safety and quality for our clients.