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Market Abuse Policy

Market Abuse Policy

Geloro Pay Ltd (trading as Octapex) Registered Money Services Business with FINTRAC

1. Purpose

Geloro Pay Ltd (“the Company”) is committed to maintaining fair, orderly, and transparent markets across all digital asset and payment services it facilitates.

The purpose of this Market Abuse Policy is to define the principles, controls, and expectations that prevent and detect abusive or manipulative behaviour. Market integrity is fundamental to maintaining trust with users, partners, and financial institutions, and the Company applies a zero-tolerance approach to any activity that undermines it.

2. Scope

This Policy applies to:

  • All users of the Octapex platform
  • Employees, directors, and contractors
  • Business partners and service providers interacting with the platform

It covers all transactions and activities conducted through the Company’s infrastructure, including:

  • Crypto-to-fiat and fiat-to-crypto transactions
  • Digital asset trading and exchange activity
  • Payment flows and related financial operations

3. Regulatory Framework

The Company operates as a Canadian Money Services Business and complies with obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and guidance issued by FINTRAC.

In addition, the Company considers:

  • Canadian securities law principles relating to market integrity
  • Regulatory expectations for digital asset service providers
  • Broader financial crime obligations where market abuse overlaps with fraud or money laundering

Where required, the Company cooperates with regulators and law enforcement authorities.

4. Operating Model (Non-Custodial Structure)

Geloro Pay Ltd operates on a non-custodial basis.

This means:

  • The Company does not hold or store client digital assets
  • The Company does not control private keys
  • Users retain full ownership and control of their funds

All transactions are executed through external wallets or payment rails, reducing custody-related risks and limiting exposure to misuse of client assets.

5. Definition of Market Abuse

Market abuse refers to any activity that distorts or is likely to distort the fair functioning of markets or provides an unfair advantage.

This includes, but is not limited to:

  • Insider trading – trading based on material non-public information
  • Market manipulation – creating false or misleading signals about price or demand
  • Wash trading – trading between related accounts to simulate activity
  • Spoofing and layering – placing orders without intent to execute
  • Pump-and-dump schemes – coordinated price manipulation

All such activities are strictly prohibited.

6. Insider Information and Confidentiality

The Company may have access to sensitive information such as:

  • Asset listings
  • Strategic partnerships
  • Technical or security developments

This information is treated as strictly confidential.

Employees and associated persons are prohibited from:

  • Trading based on non-public information
  • Sharing such information externally
  • Encouraging others to act on it

Internal controls are implemented to restrict access and monitor behaviour where necessary.

7. Monitoring and Surveillance

The Company maintains systems designed to detect unusual or suspicious activity, including:

  • Transaction pattern monitoring
  • Order behaviour analysis
  • Detection of abnormal trading volumes or pricing

Where activity appears inconsistent with normal behaviour, the Company may:

  • Investigate the activity
  • Restrict or suspend accounts
  • Apply preventative controls

8. User Responsibilities

Users are required to:

  • Act in good faith and in compliance with applicable laws
  • Avoid any behaviour that could distort market conditions
  • Refrain from using the platform for manipulative or abusive purposes

By using the platform, users agree to comply with this Policy and acknowledge that violations may result in enforcement action.

9. Transparency and Fees

The Company applies a transparent fee structure of up to 2.5% per transaction, depending on:

  • Asset type
  • Transaction size
  • Payment method

All fees are clearly disclosed prior to execution.

The Company does not apply hidden charges. Any pricing adjustments or spreads are presented transparently within the platform interface.

10. Reporting Suspicious Activity

Users and partners are encouraged to report any suspected market abuse or irregular behaviour.

Reports are:

  • Treated confidentially
  • Assessed by the Compliance function
  • Investigated where appropriate

Where required, the Company may escalate matters to relevant authorities.

11. Regulatory Cooperation

The Company maintains a cooperative relationship with FINTRAC and other authorities.

Where appropriate, it will:

  • Submit reports
  • Provide information
  • Support investigations into financial crime or market abuse

12. Enforcement

Breaches of this Policy may result in:

  • Account suspension or termination
  • Restriction of access to services
  • Reporting to regulators or law enforcement

The Company applies a strict enforcement approach, particularly where intentional misconduct is identified.

13. Policy Updates

This Policy may be updated periodically to reflect:

  • Regulatory developments
  • Changes in market conditions
  • Enhancements to internal controls

The latest version will always be available on the Company’s website.