Policy on prohibited use (applicable to the SCANDIC brand ecosystem)

This Prohibited Use Policy (hereinafter referred to as the "Policy") applies to all products, services, platforms, interfaces and other offerings of:

SCANDIC FINANCE GROUP LIMITED

Room 10, Unit A, 7/F, Harbour Sky, 28 Sze Shan Street

Yau Tong, Hong Kong / SAR - PRC

Phone HQ – Switzerland, Zurich: +41 44 7979 99 – 85

Email: Office@ScandicFinance.Global

Commercial register: Link

In cooperation with:

SCANDIC ASSETS FZCO

Dubai Silicon Oasis DDP Building A1/A2

Dubai, 342001 / United Arab Emirates

Telephone: +971 56 929 86 – 90

Email: Info@ScandicAssets.dev

Commercial register: Verify Link

in cooperation with:

SCANDIC TRUST GROUP LLC

IQ Business Centre, Bolsunovska Street 13 – 15

Kyiv — 01014 / Ukraine

Telephone HQ – United Kingdom, London: +44 7470 86 92 – 60

Email: Info@ScandicTrust.com

Commercial register extract: View PDF

in cooperation with:

LEGIER BETEILIGUNGS GMBH

Kurfürstendamm 14, 10719 Berlin / Federal Republic of Germany

HR Berlin: HRB 57837

Telephone: +49 (0) 30 9921134 – 69

Email: Office@LegierGroup.com

Commercial register: Handelsregister.de

Legal notice: SCANDIC ASSETS FZCO, LEGIER Beteiligungs GmbH and SCANDIC TRUST GROUP LLC operate as non-operational service providers. All operational and responsible activities relating to financial, fiduciary, payment and investment services are carried out by SCANDIC FINANCE GROUP LIMITED, Hong Kong, Special Administrative Region of the People's Republic of China.

This policy incorporates European Union standards, international compliance requirements (including due diligence obligations to prevent money laundering and terrorist financing) and relevant elements of the Supply Chain Due Diligence Act (LkSG), where applicable, and applies to the SCANDIC BRAND ECO-SYSTEM, in particular the brands and services:

- LEGIER GROUP
- SCANDIC SEC
- SCANDIC FLY
- SCANDIC PAY
- SCANDIC COIN
- SCANDIC CARS
- SCANDIC DATA
- SCANDIC SETUP
- SCANDIC TRUST
- SCANDIC CARDS
- SCANDIC ESTATE
- SCANDIC YACHTS
- SCANDIC HEALTH
- SCANDIC FINANCE

as well as for all structures held or supported by LEGIER Beteiligungs Gesellschaft mit beschränkter Haftung in the media and investment sector, insofar as they support financial, fiduciary, payment or investment services.

The policy applies worldwide, insofar as this is permitted under the applicable laws of the relevant jurisdictions.

1. Interpretation and relationship to other documents

1.1. Terms used in this policy and defined in the terms of use of SCANDIC FINANCE GROUP LIMITED (hereinafter "terms of use") have the same meaning as in the terms of use.

1.2. This prohibited use policy applies in addition to:

  • the Terms of Use,
  • the Privacy Policy,
  • the Cookie Policy,
  • the Compliance Framework,
  • the Code of Ethics for Artificial Intelligence,
  • the Sustainability Strategy,
  • the Human Rights Policy, and
  • other contractual agreements between you and SCANDIC FINANCE GROUP LIMITED or the aforementioned cooperation partners.

In the event of any contradictions, mandatory legal provisions shall take precedence over the provisions of this policy. In the relationship between this policy and the terms of use, the terms of use shall generally take precedence, unless expressly stated otherwise.

1.3. By using the services of SCANDIC FINANCE GROUP LIMITED, you acknowledge this policy and agree to comply with its provisions.

2. General prohibition of misuse

2.1. Your user account with SCANDIC FINANCE GROUP LIMITED (hereinafter referred to as "user account") and all associated services may not be used in any way that:

  • violates applicable law, official regulations or court orders,
  • impairs public interests, public order or public safety,
  • violates public morality,
  • impairs or infringes the rights or legitimate interests of third parties (including other users),
  • disrupts the proper functioning, security, availability or integrity of the systems, platforms or infrastructures operated by SCANDIC FINANCE GROUP LIMITED.

2.2. Any use that disrupts, impairs, negatively affects or prevents other users from using the services is prohibited.

3. Misuse of the Services

3.1. It is strictly prohibited to use the Services in any way that results in a reduction in value, impairment, overload or disruption of the quality of the Services or that affects the experience of other users.

3.2. This includes, in particular, but is not limited to:

  • the creation, distribution or promotion of content that
    • is unlawful, harmful, threatening, defamatory, libellous, insulting, obscene or pornographic,
    • infringes the property rights of third parties (e.g. copyrights, trademark rights, personal rights),
    • incites or glorifies criminal offences;
  • the promotion, facilitation, creation or distribution of spam, chain letters or other unsolicited mass communications;
  • the creation and distribution of content for fraudulent or misleading activities, including but not limited to:
    • fraud,
    • phishing,
    • identity theft,
    • distribution of malware (malware, ransomware, spyware, viruses, Trojans);
  • Market abuse or market manipulation in connection with financial instruments, crypto assets, securities or other products, in particular:
    • Spoofing,
    • Layering,
    • Wash trading,
    • Matched trading,
    • other coordinated trading strategies designed to artificially influence prices;
  • Disseminating false or misleading information with the intention of influencing or distorting prices, market sentiment or market conditions;
  • Using multiple user accounts or technical aids to circumvent risk controls, limits, trading restrictions or compliance measures;
  • Any other fraudulent or dishonest behaviour, in particular:
    • providing false, misleading or incomplete information to SCANDIC FINANCE GROUP LIMITED or its cooperation partners;
    • the use of forged or stolen identity documents;
    • concealing the beneficial owners contrary to legal requirements.

4. Financial misconduct

4.1. It is strictly prohibited to use the services of SCANDIC FINANCE GROUP LIMITED for:

  • carrying out fraudulent transactions,
  • trading in prohibited, illegal or unauthorised goods and services, in particular:
    • narcotics or certain controlled substances,
    • products that pose a significant risk to consumer safety,
    • items or content that encourage, promote, facilitate or instruct others to engage in illegal activities,
    • goods and services that have been illegally imported or exported,
    • stolen goods, including digital and virtual goods;
  • The trade or brokering of regulated products without the appropriate licence or authorisation, in particular:
    • Weapons, ammunition, explosives,
    • tobacco products, electronic cigarettes,
    • other age-restricted goods and services;
  • any form of money laundering, terrorist financing or support for the financing of the proliferation of weapons of mass destruction;
  • circumvention of economic sanctions, export control regulations or embargo regulations.

4.2. Any form of significant misuse of the services of SCANDIC FINANCE GROUP LIMITED is also prohibited, in particular:

  • exploiting system vulnerabilities, pricing errors or technical malfunctions for one's own benefit or to the detriment of other users,
  • coordinated trading or transaction strategies that are intended to disadvantage other users or market participants with fraudulent intent or to circumvent regulatory requirements,
  • concealing the origin of funds or assets, in particular through complex, convoluted or unusual transaction structures without any economically comprehensible purpose.

5. Misrepresentation and identity theft

5.1. Any actions that:

  • impersonate a natural or legal person, an organisation or an authority,
  • falsely claim affiliations, functions or powers,
  • gain or facilitate unauthorised access to user accounts, systems or third-party data,
  • unauthorised use, sharing, sale or disclosure of access data, private keys, passwords or other authentication features.

5.2. The use of services under a false name, with forged documents or by concealing one's own identity is not permitted, unless this is expressly permitted by law (e.g. whistleblower protection in accordance with relevant legal provisions, in channels provided for by law).

6. Restricted persons and prohibited countries

6.1. The services may not be used in a manner that violates sanctions or export control laws or other foreign trade regulations.

6.2. In particular, the following is prohibited:

  • the use of the services by persons, companies or organisations that
    • are included on national or international sanctions lists (e.g. by the United Nations, European Union, United States of America or other competent authorities),
    • are owned or controlled by sanctioned persons;
  • the execution of transactions involving sanctioned countries, territories or regions, if this is prohibited under applicable law;
  • the deliberate circumvention of sanctions or embargo regulations by concealing the origin, recipient, beneficial owner or transaction route.

6.3. SCANDIC FINANCE GROUP LIMITED reserves the right, at its sole discretion, to:

  • block or close user accounts,
  • block or reject transactions,
  • request additional proof of identity and origin if there are indications of sanction-relevant circumstances or restricted persons.

7. Violations of the public interest

7.1. The use of the services to carry out activities that harm the public interest or social cohesion is not permitted.

7.2. This includes, in particular, activities that:

  • systematically spread disinformation, fake news or manipulative content,
  • are intended to undermine democratic processes or constitutional structures,
  • incite or glorify violence, riots, acts of terrorism or serious violations of the law,
  • deliberately contribute to the destabilisation of states, institutions or infrastructures.

8. Violations of public morality

8.1. Activities that violate public morality are prohibited, in particular:

  • the creation, distribution or possession of materials that are considered obscene or inappropriately sexually explicit, insofar as this violates applicable law;
  • the provision or promotion of adult services, insofar as they violate laws, regulations or youth protection regulations;
  • any form of content related to child sexual abuse or the sexual exploitation of minors, including:
    • image, audio or text materials,
    • instructions or assistance for the exploitation of minors,
    • offers or requests for such content or services.

8.2. SCANDIC FINANCE GROUP LIMITED will take immediate action upon receiving relevant information and, if required or necessary by law, inform the competent authorities.

9. Promotion of hatred, discrimination and violence

9.1. Any use of the services to promote the following is prohibited:

  • hatred,
  • discrimination,
  • violence,

in particular on the basis of:

  • race or ethnic origin,
  • skin colour,
  • gender or gender identity,
  • religion or belief,
  • sexual orientation,
  • Disability,
  • national or social origin,
  • age or other characteristics protected by applicable law.

9.2. This includes in particular:

  • hate speech, incitement to violence or dehumanisation of certain groups of people,
  • glorification of extremist or terrorist organisations,
  • the dissemination of symbols, slogans or propaganda material, insofar as this is prohibited by applicable law.

10. Technical and security-related prohibitions

10.1. Any actions aimed at impairing, manipulating or unauthorised use of the technical systems of SCANDIC FINANCE GROUP LIMITED or its cooperation partners are prohibited, in particular:

  • Denial-of-service or distributed denial-of-service attacks,
  • Hacking, intrusion into networks or systems (with or without successful access),
  • circumvention of security mechanisms, firewalls or access controls,
  • Reverse engineering, decompilation or other unauthorised analysis of system components,
  • unauthorised use of programming interfaces, in particular to circumvent usage limits or for mass data collection,
  • Introduction of malware, scripts or automated tools that may damage or disrupt systems, networks or other users.

10.2. The unauthorised collection, reading or scraping of data (e.g. using bots, crawlers or similar tools) is prohibited unless expressly authorised by contract or in writing.

11. Automated use, bots and scraping

11.1. Automated use of the Services (e.g. through bots, scripts or algorithmic trading systems) is only permitted if and to the extent that:

  • this is expressly permitted in the Terms of Use, Programming Interface Guidelines or separate agreements, and
  • all technical, regulatory and security requirements are complied with.

11.2. The following is expressly prohibited:

  • the use of bots to circumvent restrictions, limits or security measures,
  • mass retrieval or copying of content, data or price information without express consent,
  • the replication or simulation of the platform for the purpose of deceiving users or redirecting them to malicious websites.

12. Measures in the event of violations

12.1. Violations of this policy are considered a serious breach of contract. SCANDIC FINANCE GROUP LIMITED is entitled, at its sole discretion and in compliance with applicable laws, to take the following measures in particular:

  • immediate, temporary or permanent suspension of users or user accounts,
  • restriction or termination of access to individual or all services,
  • blocking, cancelling or reversing transactions, to the extent permitted by law,
  • freezing of credit balances or assets, to the extent permitted by law and/or ordered by the authorities,
  • obtaining additional information, documents or evidence (e.g. in the context of identity checks or due diligence),
  • Reporting suspicious activities to the competent authorities, supervisory bodies or financial investigation agencies,
  • Assertion of civil law claims, for example, compensation for damages,
  • Initiation of criminal proceedings by reporting the matter to the competent law enforcement authorities.

12.2. The exercise of these measures shall not affect any further rights, claims or legal remedies of SCANDIC FINANCE GROUP LIMITED and its cooperation partners.

13. Reporting of violations

13.1. Users, employees, business partners and other third parties are expressly encouraged to report actual or suspected violations of this policy.

13.2. Reports can be made via the following contact channels in particular:

13.3. To the extent legally possible, reports will be treated confidentially. Whistleblowers shall be protected from reprisals in accordance with the applicable whistleblower regulations.

14. Amendments to this policy

14.1. SCANDIC FINANCE GROUP LIMITED reserves the right to amend, supplement or update this policy at any time, in particular:

  • to take account of new legal or regulatory requirements,
  • to adapt to changed market conditions,
  • to improve the protection of users, systems and the general integrity of the services.

14.2. Changes will be announced in an appropriate manner, in particular by publishing an updated version with a new "Last updated" date on the relevant platforms.

14.3. Continued use of the services after the changes have come into effect shall be deemed to constitute acceptance of the current version of this policy, unless the user objects within the specified period, insofar as a right of objection is provided for by law.

15. Final provisions

15.1. Should any provision of this policy be or become invalid or unenforceable in whole or in part, the validity of the remaining provisions shall remain unaffected. The invalid or unenforceable provision shall be replaced by a provision that comes closest to the economic purpose of the original provision and is valid.

15.2. This policy applies regardless of the user's place of residence and nationality, insofar as this is compatible with mandatory legal provisions of the applicable legal system.

15.3. Where generic male, female or diverse personal pronouns are used in this policy, they apply equally to all genders.

Drafted, signed and approved:

The Board of Directors of SCANDIC FINANCE GROUP LIMITED

Hong Kong, SAR - PRC, 1 January 2026

Legal representation: Clifford Chance, Global Law Firm

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