Code of Ethics

As an entity engaged in the crypto asset exchange business, we fully recognise our social responsibilities. Each and every officer and employee shall consistently maintain sound social common sense and ethical awareness to earn the trust of the public, while striving for continuous improvement to meet the required level of expertise.

Furthermore, as responsible members of society, we shall respect one another and eliminate and prevent discriminatory remarks or any form of harassment based on nationality, race, gender, age, beliefs, religion, social status, or disability.

To this end, as the fundamental mindset for our officers and employees in performing their duties, we declare our commitment to comply with the Nomura Group Code of Conduct and establish our Ethics Code as follows.

1.　Compliance with Laws, Regulations and Social Norms

We shall correctly understand and strictly comply with all relevant laws, regulations, rules, and other norms pertaining to the crypto asset exchange business. Furthermore, we shall adhere to general social norms, maintain common sense and ethical awareness to supplement areas not explicitly covered by laws or regulations, and strive to act with sincerity, guided by morality and reason.

2.　Appropriate Management of Conflicts of Interest

We shall appropriately manage conflicts of interest arising from our business activities to prevent any undue detriment to our customers' interests. Furthermore, we shall not use our position or authority as a crypto asset exchange operator, nor information obtained through our business activities, to gain improper benefits.

3.　Compliance with Confidentiality Obligations and Information Management

We shall strictly manage and protect as confidential any information obtained in the course of our business, except for information permitted to be disclosed under statutory disclosure requirements or other provisions governing information disclosure. Furthermore, we shall appropriately manage undisclosed information relating to crypto assets, such as information expected to have a significant impact on the value derived from crypto asset transactions, in accordance with relevant laws, regulations, and rules.

4.　Maintaining Social Order and Practising Social Contribution

As a corporate citizen, we shall actively participate in societal activities and contribute to the stability and maintenance of social order. We shall respond resolutely to forces, organisations, and their members engaged in antisocial activities, and shall not engage in any transactions with them whatsoever.

5.　Actions Prioritising Customer Interests

We shall fully ascertain our customers' knowledge, experience, financial circumstances, and purposes regarding crypto assets and crypto asset transactions. Based on this understanding, we shall always act with the consideration of maximising our customers' interests.

6.　Execution of business with sincerity and fairness from the customer's perspective

We shall consistently prioritise our clients' needs and interests, conducting business with sincerity and fairness from their perspective. We shall not favour specific clients by leveraging our authority, position within the company, or access to comparative advantage information. Furthermore, we shall strive to establish the principle of self-responsibility by adhering to appropriate solicitation practices and ensuring transactions are based on our clients' independent judgement.

7.　Advisory Services to Clients

When advising clients on crypto asset transactions, we shall provide guidance from a neutral standpoint, clearly distinguishing facts from opinions, and utilising our professional expertise. We shall not advise clients based on undisclosed information relating to crypto assets, such as information expected to influence the value derived from crypto asset transactions, under relevant laws, regulations, or rules.

8.　Establishing Appropriate Management Systems and Exercising Effective Governance Functions

To ensure financial soundness and the appropriateness of operations, we shall strive to establish an efficient management control system and exercise effective governance functions. This will be achieved through the appropriate staffing of officers and employees, compliance with laws, regulations, and other rules, and sound and appropriate business operations.

9.　Development of Risk Management Systems and Maintenance of a Sound Financial Foundation

By establishing an appropriate risk management framework based on the scale and characteristics of our operations and risk assessments, we will comprehensively identify various risks that could impact assets, liabilities, and profit or loss. We will appropriately control these risks, thereby striving to maintain a sound financial foundation through the establishment of a sustainable profit structure and the securing of capital commensurate with the risks.

10.　Timely and Appropriate Disclosure of Information

Recognising the importance of enhancing management transparency, we shall endeavour to fulfil our accountability by providing timely and appropriate information disclosure to our customers and society.

11.　Awareness of Social Mission and Maintenance/Enhancement of the Soundness and Reliability of the Crypto Asset Trading Market

We shall correctly understand the fairness and soundness of the crypto asset trading market and refrain from any actions that hinder its healthy development. Furthermore, we shall endeavour to act with an awareness of our social mission through maintaining the soundness of the crypto asset trading market. We shall not engage in inappropriate conduct that could undermine trust in our company or damage the soundness of the crypto asset trading market, such as involvement in activities that distort fair price formation.

12.　Judging Actions Raising Doubts

Even where not explicitly stipulated by laws, regulations, or rules, we shall assess the appropriateness of any conduct that may raise doubts when measured against social norms or the standards expected of a crypto asset exchange operator, in accordance with this Code of Ethics.

Established 17 October 2025

Laser Digital Japan Co., Ltd.