CODE OF CONDUCT

This Code sets out the minimum standards of conduct, integrity, and user treatment that every Listed Exchanger must meet as a condition of its listing on the Platform. It applies to every company or entity whose exchange services are displayed on the Platform and to all persons acting on its behalf.

The standards in this Code are binding requirements. Where this Code uses the word "must" or "must not", compliance is mandatory. This Code governs standards of conduct only — commercial terms, financial obligations, and technical listing conditions are addressed in the other Exchanger Framework Documents.

A Listed Exchanger must conduct its business honestly and in good faith at all times. The following are prohibited without exception:

• engaging in fraudulent, deceptive, or dishonest conduct towards users or the Company;
• misappropriating, withholding, or failing to deliver to a user any funds/cryptoassets/other property or valuables, including gold, silver, telegram stars or other assets of material value that are exchangeable;
• manipulating the outcome of any exchange transaction to the detriment of a user;
• advertising or representing exchange rates, fees, or conditions that the exchanger has no genuine intention or ability to honour;
• providing the Company or any user with false or materially misleading information about the exchanger's services, rates, regulatory status, or identity.

The foregoing constitutes Dishonest Conduct and/or material misrepresentation for the purposes of clauses 8.3 and 9.1 of the Exchanger Participation Agreement, giving rise to Blocked status and/or termination, independently of whether a Qualifying Breach has also occurred, and does not entitle any user to compensation from the Reserve Deposit.

A Listed Exchanger must treat all users with courtesy, respect, and professionalism at every stage of the exchange process — including during initial enquiries, identity verification, transaction execution, and post-transaction support.

All communications with users, whether conducted by written message, email, live chat, telephone, or any other channel, must be professional, clear, and constructive. The following are prohibited in any communication with a user:

• the use of profanity or offensive language, or any expression of contempt directed at the user;
• threats of physical harm of any nature directed at the user;
• any language or conduct intended to coerce a user into taking or refraining from any action that is prohibited by law;
• any act, statement, or omission made in bad faith with the intention of inducing a user to withdraw, abandon, or refrain from submitting a complaint or claim;
• language that demeans or stereotypes users on the basis of nationality, gender, age, religion, or any other personal characteristic.

These standards apply equally to the exchanger's employees, agents, support staff, and any other person communicating on the exchanger's behalf.

The following response standards apply to user communications:

A response that merely acknowledges receipt without addressing the substance of the user's concern does not satisfy this obligation. Every response must engage with the user's specific issue and either provide a resolution or state a clear and realistic timeline for one.

A Listed Exchanger must not treat any user less favourably on the basis of nationality, language, gender, age, religion, or any other characteristic unconnected to legitimate compliance requirements. Where an exchanger declines to serve a user on compliance or regulatory grounds, it must inform the user promptly and courteously of its inability to provide the service.

A Listed Exchanger must execute every confirmed transaction on the terms agreed with the user, including the amount to be delivered, the applicable rate, all fees, and the processing timeframe. All fees and commissions must be disclosed in full before the user commits funds — they must not be concealed within the exchange rate.

Where a delay or problem arises that prevents or materially affects execution of a confirmed transaction, the exchanger must notify the affected user within 2 hours of becoming aware of the issue, provide a reason and revised timeline, and inform the user of their right to a refund where applicable.

Each Listed Exchanger is independently responsible for compliance with all laws applicable to it, including AML/CFT, KYC, licensing, data protection, and consumer protection requirements. This responsibility rests entirely with the exchanger and cannot be transferred to the Company.

As a minimum, every Listed Exchanger must:

• apply customer due diligence (CDD) to all users, including identity verification and source of funds checks where required by law;
• apply enhanced due diligence (EDD) to higher-risk users and transactions, including those connected to FATF Blacklist or Grey List jurisdictions where required by law;
• not process any transaction it knows or suspects to be connected to money laundering, terrorist financing, proliferation financing, or any other financial crime;
• not provide services — directly or indirectly — to any person or entity listed on UK (OFSI), UN, EU, or OFAC sanctions lists, or to any person acting on their behalf where required by law;
• not provide services in connection with any Restricted Jurisdiction, including the Russian Federation, DPRK, Iran, Belarus, Syria, Cuba, Myanmar;
• where required by law hold all required licences and registrations in good standing and not misrepresent its regulatory status to users or to the Company;
• not, directly or indirectly, engage in, facilitate, or knowingly process any transaction involving, or provide any service to or on behalf of:
  • (a) Designated and Sanctioned Platforms.

    Any virtual asset service provider, exchange, or entity that is the subject of a designation, blocking order, or primary money laundering concern determination by any applicable sanctions authority or financial intelligence unit, including (without limitation): Garantex Europe OU and its successor entity Grinex; Bitzlato Limited;

  • (b) Transaction Obfuscation and Anonymisation Services.

    Any platform, protocol, tool, or service the primary function or effect of which is to obscure, anonymise, or conceal the origin, destination, or ownership of virtual assets, including (without limitation): Blender.io; ChipMixer; and any functionally equivalent mixing, tumbling, or chain-hopping service, whether operated through smart contracts, peer-to-peer infrastructure, or any other technical means;

  • (c) Illicit Marketplaces and High-Risk Unregulated Exchanges.

    Any darknet marketplace or platform known to facilitate the sale of illegal goods, narcotics, stolen financial instruments, or other unlawful products or services, including (without limitation): Hydra Market; Black Sprut; and any successor or functionally equivalent marketplace;

  • (d) Sanctioned State-Sponsored Actors.

    Any entity, group, or individual operating under the direction or control of, or for the benefit of, a state-designated cyber threat actor or sanctioned state-sponsored organisation, including (without limitation) the Lazarus Group.

A Listed Exchanger is responsible for ensuring that all information displayed about it on the Platform — including exchange rates, currency pairs, fees, processing times, and transaction limits — accurately reflects its actual current offering at all times. The exchanger must update this information whenever any material change occurs.

A Listed Exchanger must not display a rate it does not intend to honour, nor communicate to a user a rate that is artificially inflated relative to prevailing market rates with the intention of applying a different rate at execution. A deviation between the displayed rate and the execution rate of more than 0.5% of the mid-market rate at the time of execution, where not attributable to disclosed market movement, constitutes a presumptive breach of this Code.

A Listed Exchanger must not, directly or indirectly:

• submit or procure the submission of any review or rating that is not based on a genuine personal experience of its services;
• offer any benefit — financial or otherwise — to any person in exchange for submitting, amending, or withholding a review or rating, except in the case of giveaways and prizes awarded to real users;
• use automated tools, bots, or coordinated campaigns to inflate its own ratings or deflate those of another exchanger;
• threaten or take adverse action against any user in response to a genuine negative review.

A Listed Exchanger must respond to all requests submitted by the Company within the following timeframes:

A Listed Exchanger must cooperate fully and in good faith with the Company's complaint-handling procedures, providing relevant transaction records and correspondence upon request, subject to applicable data protection and confidentiality obligations.

A Listed Exchanger must notify the Company in writing of the following events within the timeframes specified:

• Within 30 minutes — default, insolvency, confirmed fraud or misappropriation of user funds, or any event rendering the exchanger immediately unable to execute confirmed transactions;
• Within 24 hours — revocation or suspension of any required licence or authorisation; change of jurisdiction of incorporation; material change of ownership or control; commencement of regulatory investigation or criminal proceedings against the exchanger or its senior officers; material deterioration in financial position affecting ability to perform.

Notifications must be sent to the Company's contact address in Section 12, marked "URGENT NOTIFICATION — MATERIAL EVENT" or "NOTIFICATION — MATERIAL EVENT" as applicable.

The Company reserves the right to suspend, block or permanently remove a Listed Exchanger from the Platform where the Company reasonably determines that the exchanger has breached this Code, engaged in fraudulent or unlawful conduct, failed to meet AML/CFT or sanctions obligations, been subject to regulatory enforcement action, or received a significant volume of substantiated user complaints.

Suspension, block or removal may take effect immediately and without prior notice where delay would expose users to risk of harm. As an interim measure, the Company may flag the exchanger's listing as under review pending investigation.

Where a Listed Exchanger has committed a Qualifying Breach, the Company may apply the Reserve Deposit and compensation mechanism set out in Section 9.6 of the Platform Terms of Use. Users affected by a Qualifying Breach should refer to the Platform's Dispute Resolution Policy.

Nothing in this Code creates any liability on the part of the Company for the conduct of any Listed Exchanger.

Any user, third party, or member of the public who believes that a Listed Exchanger has breached this Code may report the concern to the Company:

• By email: contact@bettertomorrowgroupltd.com
• By form: User Complaint and Claim Form, available at obmify.com/en/complaint-form

Reports should include the name of the exchanger, a description of the alleged breach with relevant dates, and any supporting evidence. The Company will review all reports in accordance with its Dispute Resolution Policy and may investigate, contact the relevant exchanger, and take such action as it considers appropriate. Submitting a report does not affect a user's right to pursue any claim directly against the exchanger or to seek legal redress.

The Company reserves the right to amend this Code at any time. The current version is published on the Platform at obmify.com/en/complaint-form and is dated at the head of this document. Continued listing on the Platform following publication of an amended version constitutes the exchanger's acceptance of the amended Code.