Disclosures for Digital Asset Services

1. Status, Scope

Orient Capital Management Ltd. (“OCM”) is an AIFC Authorised Firm regulated by the Astana Financial Services Authority under licence AFSA-A-LA-2023-0012. The proposed Digital Asset services are for Professional Clients only and will not commence until the relevant licence modification and pre-launch conditions have been completed. OCM may deal as principal or agent, manage investments and Collective Investment Schemes, advise and arrange transactions and custody within its approved scope. OCM will not operate a Digital Asset Trading Facility or carry on Providing Custody. Services will be performed manually by authorised employees through corporate communication channels and approved third-party provider systems.

Under the agency and Arranging Custody model, Client Digital Assets will remain in hosted accounts or wallets opened in each Client's own name with an approved exchange, broker or custodian. Assets will settle directly between the Client and the provider. OCM will not hold or control Client private keys, seed phrases, signing credentials or withdrawal access, including temporarily or in transit. BN KZ Technologies Limited (Binance Kazakhstan) is the planned primary, but not exclusive, AIFC provider. Other AFSA-authorised or appropriately regulated foreign providers may be used following documented due diligence. No proprietary Client platform or Binance API custody module is currently used or required for this manual model.

2. Digital Asset Risk Warning

Digital Assets are highly speculative and involve a high degree of risk. Clients must read all of the following warnings:

1. Except for a Central Bank Digital Currency, Digital Assets are not legal tender and are not backed by a government.
2. Digital Assets are subject to extreme volatility and may lose value rapidly. A Fiat stablecoin or Commodity stablecoin may lose its peg.
3. An investor may lose all or part of the value of a Digital Asset investment.
4. Digital Assets may not always be liquid or transferable.
5. Digital Asset investments may be complex and their risks may be difficult to understand.
6. Digital Assets may be stolen as a result of cyber attacks.
7. Trading in Digital Assets is susceptible to irrational market forces.
8. The nature of Digital Assets may create an increased risk of Financial Crime.
9. There may be limited or no mechanism for recovering lost or stolen Digital Assets.
10. Digital Assets involve risks relating to anonymity, irreversibility, accidental transactions, transaction recording and settlement.
11. Technological difficulties experienced by a Digital Asset Trading Facility Operator may prevent access to or use of a Client’s Digital Assets.
12. Participation in Digital Assets is not comparable to participation in traditional investments such as Securities.
13. There is no recognised compensation scheme providing an avenue of redress for aggrieved Digital Asset participants.

This warning will be displayed prominently and fixed at the top of relevant OCM website or mobile pages. Where space is insufficient, “High-risk investment” will link directly to the full warning.

3. Conflicts, Referrals and Third Parties

Conflicts may arise from OCM acting in different capacities, including as principal, agent or investment manager, and from pricing, remuneration, provider selection, order allocation, valuation or personal interests. OCM manages them through disclosure, a conflicts register, segregation of duties, information barriers, execution and allocation controls, personal-account-dealing controls, independent review and refusal to act where a conflict cannot be adequately managed. Before providing a service, OCM will disclose the identity and role of relevant brokers, custodians, wallet providers, venues and other third parties, together with any monetary or non-monetary benefit received.

4. Privacy, Whistleblowing and Complaints

OCM processes personal, KYC, wallet and transaction data only for onboarding, service delivery, AML/CFT and sanctions controls, monitoring, recordkeeping and legal or regulatory compliance, subject to access, confidentiality, retention and security controls. Suspected misconduct may be reported confidentially to info@orientcapital.kz with the subject “Whistleblowing”; good-faith reporters are protected from retaliation.

Complaints may be submitted free of charge to info@orientcapital.kz with the subject “Complaint”, or to

OCM will acknowledge, investigate and respond under its complaints procedure.

Further information is available on the AFSA complaints page.

5. Client Assets, Access, Execution and Liquidity

For agency and Arranging Custody services, Client ownership is protected through the Client's direct account with the approved provider, contractual recognition of the Client's entitlement, segregation, records and reconciliation. For principal or bilateral OTC transactions, assets transferred as consideration become the receiving party's property in accordance with the Client Agreement and Order Form and are not held for safekeeping. Accounts and wallets holding Fund Property will be opened in the relevant Fund's name and Fund Property will not pass through OCM's own accounts. OCM assesses each provider's authorisation, safeguarding, segregation, key management, cybersecurity, financial standing and resilience.

All Client orders must be recorded in a signed Order Form. Corporate email, an in-person meeting or a recorded telephone or video discussion may support the instruction process, but oral instructions alone are not accepted. OCM records receipt and provides an execution report. In principal or OTC transactions, OCM will complete its corresponding delivery on the same Business Day where practicable and no later than the next Business Day unless another period is agreed in writing or completion is delayed by the Client, a provider, legal or compliance controls, or Force Majeure. Derivatives, margin products, staking, lending or borrowing may be accessed only through authorised third-party providers and where permitted by the relevant mandate or Fund Offering Materials; OCM does not itself provide those infrastructures.

OCM will consider price, total cost, speed, likelihood of execution and settlement, size, Client instructions, liquidity and counterparty risk. OCM may delay, decline or suspend execution where the written instruction is incomplete, funds or assets are insufficient, required AML/CFT or sanctions checks are unresolved, the provider is unavailable, or acceptable execution terms are not available. Transfers and trading may resume through the same or another approved provider only where permitted and, where required, agreed with the Client. Market, liquidity, slippage, counterparty, custody, settlement, cyber, protocol, network, legal and regulatory losses may be substantial or total and recovery may be limited.