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This Code of conduct is the property of TOKO FZE. TOKO FZE may modify, enhance, delete from or add to these policies, procedures, and guidelines at any time.

TOKO is a virtual asset tokenisation engine (TOKO Token Engine), broker dealer (TOKO Primary Market Platform) and exchange (TOKO Secondary Market) platform designed to facilitate the issuance, listing and trading of asset-backed virtual assets.

As such, TOKO is committed to ensuring that the virtual assets (tokens) listed on our platform meet our high standards for security, legality, and compliance, under the regulatory framework of the Dubai Virtual Assets Regulatory Authority (VARA).

TOKO values transparency, integrity, and respect for all its users. We believe that creating a safe and welcoming environment is crucial for achieving our mission, and we expect everyone who interacts with our platform to adhere to the following Code of conduct.

Code of conduct

Ethical behavior

TOKO is committed to maintaining high ethical standards in all aspects of its business. All employees and users must act with honesty, integrity, and professionalism at all times.

We expect all employees and users to treat each other with respect and courtesy, regardless of their background or beliefs. We do not tolerate any form of harassment, discrimination, or hate speech.

We value honesty and transparency in all of our dealings. Employees and users must provide accurate and truthful information when registering for an account or participating in transactions on our platform.

Compliance with laws and regulations

All employees and users of TOKO must comply with all applicable laws and regulations, including those set forth by the Virtual Assets Regulatory Authority (VARA) in Dubai.

As a token issuance platform and token broker dealer for primary issuance, we adhere to all applicable regulations and laws. Users are expected to comply with these regulations as well.

Anti-money laundering (AML) and counter-terrorism financing (CTF): TOKO is committed to preventing the use of its platform for illegal purposes, such as money laundering or terrorism financing. All employees and users must adhere to strict AML and CTF policies and procedures, as outlined by VARA.

Confidentiality and data protection

TOKO takes the confidentiality and data protection of its users seriously. All employees and users must respect the privacy of others and comply with all relevant data protection laws and regulations.

Protection of user data

We take the security and privacy of user data seriously. Users must also take responsibility for protecting their own personal and financial information and not share it with unauthorized parties.

Prevention of conflict of interest

All employees and users of TOKO must avoid conflicts of interest, or any situation that may give rise to a conflict of interest. This includes not engaging in any activities that may compromise the integrity or reputation of TOKO. Please refer to TOKO FZE Conflicts of Interest Policy.

Prevention of market manipulation

As a virtual asset secondary market exchange, we do not tolerate any form of market manipulation, including insider trading or pump-and-dump schemes.

Transparency and disclosure

TOKO values transparency and disclosure in all aspects of its business. All employees and users must be open and honest in their dealings with others and must disclose any relevant information in a timely and accurate manner.

Report of suspicious activity

Users are encouraged to report any suspicious activity, such as potential fraud or money laundering, to our support team. Employees are subject to AML-CFT obligations as per TOKO FZE Compliance Manual and AML-CFT policies.

Fair treatment of users

TOKO is committed to providing fair and transparent services to all of its users. All employees and users must treat others with respect and fairness and avoid any form of discrimination or harassment.

Resolve disputes fairly

We strive to resolve any disputes between users fairly and impartially. Users are encouraged to reach out to our support team if they need assistance.

Continuous improvement

TOKO is committed to continuous improvement and innovation. All employees and users are encouraged to provide feedback and suggestions for improvement, and to actively participate in the ongoing development of the platform.

Users are expected to stay up to date with any changes or updates to our platform, including our policies and procedures.

Disciplinary action, suspension, termination, and VARA rights and powers

TOKO reserves the right to suspend or terminate the accounts of users who violate this Code of conduct or any applicable laws or regulations. Any such actions will be taken in accordance with the VARA guidelines and procedures. TOKO reserves the rights to implement disciplinary actions against participants on Primary and Secondary Market platforms in case of breach of any Regulations, Rules or Directives.

To this end, TOKO necessary rights to issue, impose, require or collect, the following to all employees and users of its platform:

  1. warnings;
  2. reprimands;
  3. training;
  4. qualification minimums;
  5. remediation plans;
  6. compliance audits;
  7. restitution;
  8. contractually agreed penalties;
  9. conditions on trading;
  10. trading prohibitions;
  11. suspensions and restrictions to trading;
  12. expulsions;
  13. cancellation of a client’s orders and any outstanding instructions from that client;
  14. report any breaches to VARA; and
  15. criminal referrals.

VARA have authority to pursue such additional remedies or disciplinary measures against users of the TOKO services, especially the Secondary Market Platform providing Exchange Services as it determines and may, in its sole and absolute discretion, delegate to TOKO providing Exchange Services the ability to enforce such additional remedies or disciplinary measures upon its written consent.

In addition to the above, VARA may require the suspension of trading of any Virtual Asset with effect from such time as it may determine if there are reasonable grounds to suspect non-compliance with Part III of the VARA Exchange Services Rulebook. If VARA has required the suspension of trading of any Virtual Asset, it may impose such conditions on the procedure for lifting the suspension as it considers appropriate.

Further Information

TOKO is committed to providing a secure, compliant, and transparent platform for the issuance and trading of virtual assets.

TOKO Code of conduct is disclosed on TOKO Website and has to be accepted by Employees and Users as per TOKO Client agreements Term and Conditions.

We believe that the virtual assets listed on our platform should meet the highest standards of quality and integrity, and we will work closely with virtual asset issuers to ensure that they meet the standards of the VARA.

By using TOKO’s platform, all users agree to abide by this Code of conduct and any applicable laws or regulations.

Questions regarding this Code of conduct should be directed to James Holding, TOKO FZE Compliance Officer at