Hex Trust Singapore Consumer Protection Disclosures

1. Consumer Protection - Regulatory Disclosures

The Monetary Authority of Singapore requires Hex Technologies Pte. Ltd. (“Hex Trust Singapore”) to provide specific disclosures to customers engaging with Digital Payment Token (“DPT”) services. Please review the following information carefully before using Hex Trust Singapore’s DPT services.

These disclosures apply exclusively to the DPT services provided by Hex Trust Singapore under the terms set out in your Master Trading Agreement or Custodian Agreement (an “Agreement”). Any capitalised terms used but not defined herein shall carry the meanings assigned to them in the relevant Agreement.

Please note that these disclosures do not apply to services provided by other entities within the Hex Trust Group under separate terms and conditions. 

2. Risk Warning On Digital Payment Token Services

In accordance with the MAS Notice PSN08, the Monetary Authority of Singapore (MAS) requires us to provide this risk warning to you as a customer of a digital payment token (DPT) service provider.

Before you:

(a) pay Hex Trust Singapore any money or DPT; or

(b) pay a third party any money or DPT under an arrangement by Hex Trust Singapore,

You should be aware of the following.

1. Hex Trust Singapore is licensed by MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to Hex Trust Singapore or any other third party referred to above, if Hex Trust Singapore’s or the third party’s business fails.

1A. You should be aware that MAS does not supervise or regulate Hex Trust Singapore for the provision of unregulated services. This includes any service of trading digital payment token derivatives such as futures.

2. You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact is transferred or held by Hex Trust Singapore.

3. You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens.

4. You should be aware that Hex Trust Singapore, as part of its licence to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “stablecoin”.

3. Asset Safeguarding Disclosures

3.1. Asset Storage Arrangements

Hex Trust’s asset storage arrangement utilizes advanced hardware and software infrastructure with strong security controls. The central component is the Hardware Security Module (HSM), which securely stores and manages cryptographic keys, ensuring they are always wrapped (encrypted) and never exposed in clear text. Both Safe Plus and Safe Vaults operate in an air-gapped environment, isolated from the internet, with data diodes ensuring one-way communication to prevent unauthorized access.

Key generation occurs within the HSM using a True Random Generator, and physical security is enhanced by storing encrypted keys in multiple vaults across different locations, requiring multiple approvals for access. Transaction signing involves client-initiated transactions that go through several approval stages before being securely signed within the HSM through the Key Management System (KMS).

Singaporean clients are onboarded under the Singapore custodian entity, with the Hardware Security Module (HSM) in Singapore serving as their primary operational HSM. To ensure resilience, a secondary HSM located in Hong Kong acts as a geographically redundant backup, ready to take over in the event of hardware failure or disruption to the primary instance. This architecture provides operational continuity and robust disaster recovery for cryptographic asset management.

3.2. Rights and Claims of Customers

Clients of Hex Trust Singapore retain beneficial ownership of digital assets safeguarded on their behalf. However, clients may hold rights only to the financial value of the DPTs and do not automatically receive rights to protocol derived features such as governance participation, airdrops or new tokens created from hard forks.

Clients may be entitled to new tokens resulting from hard forks or airdrops subject to certain conditions as set out in the Custodian Agreement. Hex Trust Singapore may, at its sole discretion, decide whether to support any fork or airdrop, and clients have no such entitlement to such benefits unless explicitly provided. Additional fees may apply for the processing or distribution of such assets.

3.3. Addressing Asset Losses from Fraud or Gross Negligence

If you suspect any loss of assets due to fraud or negligence by Hex Trust Singapore, please contact our client service team immediately. You may escalate unresolved matters through our Complaints Handling and Resolution process, in accordance with the timelines and procedures as described in this disclosure and your agreement.

Any compensation offered will be capped at your direct losses and may be adjusted based on contributory negligence, if applicable.

Hex Trust Singapore will not be liable for losses resulting from client fraud, gross negligence or wilful misconduct (among other things).

3.4. Customer Instructions and Authorization 

Clients may provide instructions through Hex Trust Singapore’s official channels as outlined in your Agreement. 

The client shall provide a list of all persons authorised to act on its behalf in giving such instructions, clearly specifying the scope, limitations, or role of each individual’s authority. Hex Trust Singapore will only act on clients assets in accordance with the instructions received from the client’s duly authorized representatives.

All authorisations are subject to our verification and risk assessment procedures. It is the client’s responsibility to ensure the list of authorised persons remains accurate and up to date, and to ensure security and confidentiality of all access credentials. Hex Trust Singapore may refuse any instruction from a person who is not duly authorised or has not satisfied our verification process.

Hex Trust Singapore does not use client assets as collateral and will not sell, loan, or otherwise encumber assets without explicit client instruction or legal requirement. Where required, we may debit your account to complete transactions in accordance with agreed payment terms.

For further details, please contact our Client Services team or refer to the applicable service agreement.

3.5. Fees Associated with Safeguarding of Assets

All fees associated with the safeguarding of clients’ assets are fully disclosed in the Fee Schedule attached to the Custodian Agreement and are communicated during relevant service interactions. 

By using Hex Trust Singapore’s services, clients acknowledge and consent to these fees, which are necessary to maintain secure and compliant asset safeguarding procedures.

3.6. Delivery Of Information

Clients will have ongoing access to account-related information, including digital asset balances and transaction history through a secure and dedicated client portal provided by  Hex Trust Singapore.  Additionally, periodic reports and/or monthly statements of accounts relating to the assets of the clients shall be delivered via email or other agreed communication channels. The frequency, timing, and level of details of these reports will be expressly agreed between Hex Trust Singapore and the client from time to time.

4. Supported Asset Disclosures

Hex Trust Singapore conducts a comprehensive evaluation of digital assets through a multi-layered review framework that includes both global due diligence and localised legal and compliance assessment to ensure alignment with applicable regulatory standards and internal risk policies.

4.1. DPT Support Evaluation Process

The evaluation process for supporting new DPT involves a comprehensive assessment based on several key criteria including but not limited to: 

Technology and Security Assessment:

Assessment of the asset’s underlying infrastructure, including whether it operates on a proprietary blockchain or leverages an existing blockchain. This also includes review of the asset’s security measures and evaluation of the infrastructure required to support the asset.

Risk Assessment:

Assessment of the issuer and its development team’s technological experience, track record, and reputation to identify potential operational and reputational risks. This also includes a review of the asset’s tokenomics (supply and release schedule), funding status and key investors, and market presence through its exchange listings, trading pairs, and liquidity profile.

Compliance Assessment:

Assessment focusing on AML/CFT name screening to ensure the asset and associated parties are not on sanctions watchlists, alongside negative news searches to identify any adverse media or controversies related to the project.

Upon successful completion of the fundamentals assessment, the DPT will be integrated and supported on Hex Trust Singapore’s platform for deposit and transfer. Only DPTs that comply with internal standards and relevant regulatory requirements will be supported.

4.2. DPT Support Discontinuation Process

To ensure asset integrity, the platform will maintain ongoing oversight of the performance, security, and regulatory compliance of every supported asset. The platform may suspend or discontinue support for a DPT if it determines that the asset no longer meets requirements, poses substantial risk, or if any concerns arise from ongoing monitoring.

4.3. What Happens When Support for an Asset is Suspended or Discontinued?

In most cases, clients will receive advance notice of approximately two weeks prior to a suspension or discontinuation of asset support. During this period, clients will be able to trade or withdraw the affected asset. On the date support is discontinued, trading will be suspended, but withdrawals will remain available unless otherwise specified.

In exceptional circumstances (e.g., immediate legal or regulatory concerns, smart contract vulnerabilities), Hex Trust Singapore may suspend all support without advance notice. In such cases, the Hex Trust team will notify affected clients and outline the next steps, which may include enforced liquidation or a pre-defined conversion to a supported asset such as USDC.

4.4. Does Hex Trust Singapore Receive Incentives for Asset Support?

Hex Trust Singapore does not accept fees or incentives in exchange for supporting digital assets.

However, other entities within the Hex Trust Group may, from time to time, engage in commercial arrangements with asset issuers, node providers, other parties or affiliates. Where such relationships exist, potential conflicts of interest are managed under Hex Trust’s Group-wide Conflicts of Interest Policy. More information can be made available upon request.

5. Complaints Handling and Resolution

Hex Trust Singapore is committed to providing fair, timely, and transparent resolution of customer complaints. Hex Trust Singapore recognises that client feedback is essential for improving its services and enhancing the overall customer experience.

All complaints are properly assessed and documented, including relevant details and correspondence, by a dedicated team. Staff handling complaints operate independently and are not involved in the subject of the complaint.

Complaints may be raised by clients or members of the public through various channels such as in person, writing, phone, or via Hex Trust Singapore’s Helpdesk:

Email: clients@hextrust.com  | WhatsApp: +852 6460 8565

Hex Trust Singapore aims to resolve complaints promptly upon receipt. Where immediate resolution is not possible, complainants are advised to submit their complaint in writing (e.g., via email or WhatsApp) for proper review and documentation. Complaints are assessed fairly to determine whether they should be upheld. Should the complaint be dismissed, written reasons will be provided. If the matter cannot be resolved promptly or it involves significant issues, it will be escalated to senior management within 24 hours, followed by an official acknowledgement to the complainant.

The outcome of the assessment will be clearly communicated. All complaints will be resolved within 10 calendar days from the date of receipt. If additional time is required due to complexity, an interim update will be issued with the status and, where possible, the expected resolution date. 

6. Conflict of Interest Disclosures

A conflict of interest arises when competing obligations or interests may impair the ability of Hex Trust Singapore to act solely in the best interests of its clients. This can occur when Hex Trust Singapore or its affiliates have commercial, financial, or strategic incentives that may diverge from those of the client, potentially resulting in an advantage to Hex Trust Singapore or the Hex Trust Group, while disadvantageing the client.

Hex Trust Singapore is committed to the highest standards of ethical conduct and transparency. We believe it is important for clients to understand where actual or potential conflicts of interest may exist, so they can make informed decisions when engaging our services.

Outlined below are key areas of actual or potential conflicts of interest and how we mitigate them.

6.1. Affiliate or Related-Party Services

Hex Trust Singapore is part of the wider Hex Trust Group, which provides a range of digital asset services and products (e.g. custody, staking, tokenisation, and trading solutions). Certain related party services may be accessible through the same platform or interface that hosts services offered by Hex Trust Singapore. In such cases, there may be a perception that Hex Trust Singapore could be motivated to prioritise the broader commercial interests of the Hex Trust Group over those of its clients, particularly if clients are not clearly informed that the service is being provided by an affiliate or related entity.

To mitigate such perceived conflicts of interest, Hex Trust Singapore maintains an independent governance and management structure.

While we believe potential conflicts of interest arising from affiliate or related party services are adequately managed, we acknowledge that residual risks, such as user perceptions of bias or unconscious internal bias may remain. To maintain transparency and safeguard client trust, Hex Trust Singapore will inform clients of the identity of the Hex Trust Group entity providing such related party services, thereby enabling clients to make an informed decision on whether to engage with those services.

6.2. Commitment to Transparency and Governance

Hex Trust Singapore is committed to proactively identifying, managing, and disclosing conflicts of interest, ensuring these are appropriately governed and resolved in a fair and transparent manner.

Clients are encouraged to contact us should they have any questions or concerns regarding potential conflicts of interest or wish to receive further information about how these matters are addressed.

7. General Information

7.1. Operating Hours and Service Availability

Hex Trust Singapore’s standard business days are Monday to Friday, from 9:00 AM to 5:00 PM (local time). Our customer support team is available 24/7/365 to help with any service support or inquiries. Please note that our business hours may be subject to change due to operational adjustments. Any changes will be communicated promptly through our website and other official channels.

7.2. Help & Support

For any inquiries or assistance, please contact our Hex Trust Singapore’s support team 24/7/365:

Email: clients@hextrust.com

WhatsApp: +852 6460 8565

Our support team is available to assist you with general questions, service support, and guidance. For complaints or disputes, please refer to our dedicated Complaints Handling and Resolution section.

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