Code of Conduct for Members and Industry Practitioners
A pledge to abide by these rules and by the industry self-regulations and the associated rules as stipulated by the supervisory/ regulatory authorities.
This Code of Conduct for Members and Industry Practitioners is aimed at protecting the interests of the participating members of OBTU, investors, and users, as well as encouraging the healthy development of the Blockchain industry and guiding the development of crypto-currencies in a positive direction. In order to promote the spirit of self-regulation, abide by supervisory stipulations, enhance business ethics and establish market disciplines and investor-confidence, we hereby solemnly swear to abide by the following fundamental principles:
Principle 1: Regulatory Abidance
We undertake to follow these regulations, along with any associated rules and regulations promulgated by supervisory and regulatory authorities, and should not take actions in violation, or the aiding and abetting of others in the violation of, any of the regulations.
A. We understand that if we engage in advising on or dealing in regulated financial instruments, we may need to obtain government approvals. Therefore, we will ensure that we either:
- Obtain the requisite government approvals before engaging in such activities; or
- Refrain from making available for trading, dealing in or advising on any illegal financial instruments.
B. We understand that we remain subject to other laws, including the Consumer Protection Act, Personal Information Protection Act, Data Privacy Act, Nigeria Cyber Crime Act, etc. We agree to make the self-regulatory principles as additional guidance and abide by them.
Principle 2: Information Transparency
We undertake to provide sufficient, transparent and up to date information in a timely manner in order to enable investors to make investment decisions. We will provide any necessary information to relevant authorities to meet applicable legal or regulatory requirements. We also undertake to make available any additional information to help investors make better decisions.
A. We will disclose relevant company information, including but not limited to:
- Name, address and contact details of the company;
- The experience of responsible persons, directors, general manager and chief executive officer; and
- If government approval is required, the company should disclose relevant information.
B. We will provide objective criteria for participation in operating crypto- exchanges to promote fair and just experience to users. We will provide users with sufficient information to form an accurate understanding of the risks, fees, and costs they incur from trading on the platform.
Principle 3: Prudent Administration
We will exercise the due care of a prudent administrator and meet any expected accountabilities in strengthening system robustness, maintaining personal data security and providing the best services. We will be efficient and effective in meeting our obligations with respect to the services we provide.
A. We will put in place governance structures that are clear and transparent in order to promote the safety and efficiency of the platform, prevent market misconduct, assist the stability of the broader crypto-asset system and support the objectives of relevant stakeholders.
B. We will design our systems in a manner to ensure a high degree of security and operational reliability, and future scalability.
C. We recognize that any rights attached to tokens held on behalf of users belong to the users. Unless receiving approval from users or otherwise required by law, we will not exercise the voting rights (if any) of the users without their approval. We will not withhold user account distributions in the absence of any delay or outstanding platform fees.
Principle 4: Operational Risk Management
We will aim to identify and mitigate any possible sources of risk, both internal and external, through the use of appropriate systems, policies, procedures, and controls.
A. We will separate and safeguard our own and our users’ assets (including holding a sufficiently high proportion of crypto-assets in appropriate cold storage) and minimize the risk of loss and delay in access to assets.
B. We will implement technical methods to monitor and to prevent the risk of money-laundering or terrorist financing.
C. We will implement a real-name authentication mechanism for users if the transactions involve legal currencies.
D. To reduce the risk of fraud, we will implement multi-factor authentication for the withdrawal of digital assets from the trading platforms and other transactions above certain thresholds.
E. In the event of a wide-scale or major disruption, we will aim to timely recover the operations and fulfill trading platform obligations through business continuity management.
Principle 5: Market, Liquidity and Credit Risk Management
We will effectively measure, monitor and manage market, liquidity and counterparty risks. （if any）
A. We will hold sufficient liquid assets to cover potential general business losses so that we can continue operations and services if such losses occur.
B. If we extend leverage to our users, we will effectively measure, monitor, and manage credit risks, such as by accepting only high quality, liquid collateral and by setting appropriate conservative valuation discounts and concentration limits.
C. We will not engage in wanton destruction of competitors’ reputations or interests or engage in any other type of unfair competition. We will refrain from engaging in behaviors that mislead, falsify, defraud, or cause distrust among other market participants.