Terms and Conditions

TREASURY GENERAL TERMS AND CONDITION

A. Introduction

Effective since March 1, 2025

1. The following are the Treasury General Terms and Conditions under which Treasury provides services to users of the Treasury App.

2. For simplicity, Treasury has separate terms and conditions for separate products, which compliments this Treasury General Terms and Conditions. Users who transact in precious metals on the Treasury App must read this Treasury General Terms and Conditions in conjunction with the Treasury Precious Metals Terms and Conditions.

3. To protect the interests of users, users are to carefully read applicable terms and conditions before conducting any transactions on the Treasury App. By registering and conducting transactions in the Treasury App, users are deemed to have acknowledged, understood, and agreed to all Terms and Conditions, Privacy Policies, and other provisions contained in the Treasury App. Violations of any or all of these provisions grant Treasury the authority to take actions, including but not limited to blocking the user’s account.

4. All Terms and Conditions, any Treasury accounts, and the relationship between Treasury and the users, shall be subject to, governed by and construed in accordance with the laws of the Republic of Singapore and such other laws which are applicable to the services. Treasury and users submit to the non-exclusive jurisdiction of the courts of the Republic of Singapore.

5. Every gold and/or silver purchase made by the User through the Treasury app is guaranteed to have a corresponding physical gold reserve, stored in accordance with the recorded balance in the User’s gold and/or silver ownership. Treasury collaborates with ICDX Logam Berikat (ILB), the designated storage facility, to securely store the User’s physical gold.

6. Treasury ensures that the amount of physical gold stored matches the amount of gold and/or silver purchased by the User, guaranteeing that the User’s gold and/or silver balance is always backed by an equivalent asset.

B. Registration

1. After downloading the Treasury App available on the Play Store, App Store or through the treasury.sg website, users are required to fill in their personal data in a digital form, which includes full name (as per National Identification Registration Card (“NRIC“) or passport), mobile phone number, NRIC or passport number, gender, date of birth, email, mobile phone number, address, password, and PIN, as well as required documents, such as NRIC or passport photo, and bank account data to be used in the Treasury App.

2. All provided data must be consistent with each other (e.g., bank account data must match the data on the NRIC or passport; any discrepancy may result in failed withdrawals from the proceeds of Gold and/or Silver sales to the user’s account, which Treasury is not liable for).

3. To ensure security and convenience for users in conducting transactions, Treasury will require users to undergo various data and information verification processes during registration, which include but are not limited to submitting a photo of their ID and a selfie, which will be verified by Treasury within two (2) business days.

4. Treasury will send an email to verify the user’s data, and the user is then asked to follow the instructions in the email.

5. Treasury will send a confidential OTP code to the user’s registered mobile phone number, and the user is asked to enter the OTP code as instructed to complete the registration process.

6. Each email, ID, mobile phone number, and bank account can only be used for one Treasury account. Treasury reserves the right to block any accounts found to be using duplicate personal data.

7. Users can log in using the mobile phone number or email used for Treasury account registration after verification has been completed, and may add or change security questions, modify their password and/or PIN in the settings submenu under the Profile menu.

8. Users may complete their ID details (NRIC or passport) in the KYC submenu under the Profile menu for further verification by Treasury within two (2) business days.

9. In conducting various transactions in the Treasury App, users may only conduct transactions using a single device. Switching devices will render the previous device unusable for concurrent transactions with the new device. The use of two or more devices for transactions in close or simultaneous timing is classified as a violation of the Terms and Conditions of the Treasury App, and Treasury reserves the right to reject or cancel such transactions and to include the user on the Treasury blacklist.

10. Failure to conduct transactions in the Treasury App due to errors and/or discrepancies in user data, including but not limited to NRIC data, passport data, or bank account data, is not the responsibility of Treasury.

11. Treasury reserves the right to reject user registrations and/or block and/or terminate registered user accounts if deemed suspicious or not in compliance with the laws and regulations of the Republic of Singapore, the regulations of the relevant authorities, and the applicable Terms and Conditions, such other laws which are applicable to the services, or if the user has been blacklisted by Treasury.

12. These Terms and Conditions serve as a binding agreement between the Treasury user and Treasury.

13. Users can access profit/loss information from total assets held in Singapore dollar or percentage units. Users acknowledge that such profit/loss information is not absolute and/or entirely accurate and may change over time in line with the market fluctuations of the commodities displayed in the Treasury App.

14. If there are any promotions related to user registration in the Treasury App, the Terms and Conditions of such promotions also bind the user.

15. Users who have been blacklisted by Treasury are not permitted to participate in promotions organized by Treasury or other third parties in collaboration with Treasury. The promotions as referred to in these provisions also include vouchers, Gold and/or Silver bonuses, or other benefits provided by Treasury. Treasury reserves the right to cancel transactions and/or nullify vouchers, Gold and/or Silver bonuses, or other benefits provided by Treasury that are held by users who have been blacklisted or those not entitled to receive them and/or acquired them in violation of these Terms and Conditions.

16. The Terms and Conditions for Treasury App registration may change at any time without prior notice to users.

17. The provisions regarding the submission of user information are subject to the Treasury App’s privacy policy, which is binding on users.

18. Users are advised to carefully read all Terms and Conditions, Privacy Policies, and other provisions contained in the Treasury App before conducting any transactions through the Treasury App.

19. By registering and conducting transactions (including but not limited to Gold and/or Silver purchases, sales, and gifts) in the Treasury App, users are deemed to have acknowledged, understood, and agreed to all Terms and Conditions, Privacy Policies, and other provisions contained in the Treasury App. Violations of any or all of these provisions grant Treasury the authority to take actions, including but not limited to blocking the user’s account.

20. Users acknowledge and agree not to use the Treasury App for money laundering and/or terrorism financing and/or the proliferation of weapons of mass destruction and/or other illegal activities. Treasury will not be liable if users use the Treasury App for such prohibited activities as described in this provision. If Treasury finds indications of illegal use of the Treasury App, Treasury will follow up by reporting it to the relevant law enforcement agencies.

21. Any form of fraud and/or criminal activity committed by users and/or other parties in operating and/or transacting in the Treasury App will be reported to the relevant law enforcement authorities.

22. Each Treasury user is not permitted to transfer or grant power of attorney to others to operate their Treasury account. Treasury will not be responsible for any fraudulent and/or criminal acts and/or losses arising from such transfer or granting of power of attorney, and all losses will be fully borne by the Treasury user.

23. Treasury is not responsible for errors arising from the negligence of Treasury users.

24. Any malware attacks, data theft, and other security breaches caused by the use of devices that have been jailbroken or rooted are not the responsibility of Treasury.

25. Treasury does not permit users to use the Treasury App for activities and/or transactions that are not activities and/or features and/or transactions provided and/or promoted by Treasury.

26. Treasury is not responsible for activities and/or transactions conducted by users that are not activities and/or features and/or transactions provided by Treasury on the Treasury App. Users hereby understand and agree to release Treasury along with its entire management, employees, and consultants from liability, including but not limited to legal and financial responsibility, for misuse of activities and/or features and/or transactions conducted by users.

27. Treasury is a commodity trading platform that includes but is not limited to digital physical Gold and Silver trading, having obtained approval from Ministry of Law of Singapore (Singapore’s Precious Stones and Precious Metals Act: PS20220002641). This ensures that the transactions conducted by users on our platform are secure.

C. Wallet

1. “Wallet” is a balance owned by the Treasury App user, which amount is self-funded by the user within the Treasury App. The Wallet balance can be topped up through the “Top Up Wallet” feature and withdrawn through the “Withdraw Wallet” feature in the form of Singapore Dollars and can be used for transaction payments within the Treasury App including but not limited to Gold and/or Silver purchases.

2. Wallet balance top-up can be made using credit card (Visa/Mastercard), debit card (Visa/Mastercard), paynow QR code (only applicable when bank account and/or ewallet platform is connected to paynow payment system) , as well as other payment options that have been or will be implemented by Treasury for User convenience, both currently available or in the future, as displayed in the Treasury App which include but are not limited to the provisions regarding the maximum transactions that can be made by the user.

3. Payments for transactions using the Wallet balance will directly reduce the Wallet balance when the transaction status is successful.

4. The result of Gold and/or Silver sales transactions aimed at the Wallet in the Treasury App will be processed within up to two (2) business days.

5. The withdrawal proceeds will be transferred to the bank account registered by the User in the Treasury App within up to two (2) business days, subject to and following the operational banking time regulations.

6. The maximum Wallet balance for users who have verified their NRIC or passport, is SGD 200,000

7. Users will be charged an administrative fee for Wallet balance top-up according to the deposit method chosen.

8. The minimum Wallet balance withdrawal will be displayed in the Treasury App, excluding administrative fees.

9. An administrative fee for Wallet balance withdrawal will be charged for disbursement destination accounts and the amount will be set out in the Treasury App.

10. Failure in conducting various transactions in the Treasury App caused by errors and/or discrepancies in user data, including but not limited to NRIC data, passport data or bank account, is not the responsibility of Treasury.

11. Treasury has the right to reject user transactions and/or block and/or terminate registered User accounts that are indicated by Treasury as suspicious and not in compliance with the laws and regulations of the Republic of Singapore, the regulations of the relevant authorities, as well as the applicable Terms and Conditions, such other laws which are applicable to the services, and users who have been blacklisted by Treasury.

12. Users can access profit/loss information from the total assets owned in Singapore Dollars or percentage units. Users acknowledge that such profit/loss information is not absolute and/or completely accurate and will change from time to time following the price fluctuations of the commodity assets displayed in the Treasury App.

13. In the event of a promotion related to Wallet balance top-up in the Treasury App, the Terms and Conditions regarding the promotion will also apply to the user.

14. Users who have been blacklisted by Treasury are not allowed to participate in promotions conducted by Treasury or other third parties working with Treasury. The promotions referred to in these terms include vouchers, Gold and Silver bonuses, or other forms and benefits provided by Treasury. Treasury has the right to cancel transactions and/or void vouchers, Gold and Silver bonuses, or other forms and benefits provided by Treasury owned by users who have been blacklisted or who are not entitled to receive such benefits and/or obtained by users but not in accordance with these Terms and Conditions.

15. These Terms and Conditions may change at any time without prior notice to the user.

16. The provision regarding the submission of user information is subject to the privacy policy of the Treasury App, which is binding on the user.

17. Users are advised to read carefully all Terms and Conditions, Privacy Policies, and various other terms and conditions available in the Treasury App before conducting any transactions through the Treasury App.

18. These Terms and Conditions apply as a binding agreement between the Treasury user and Treasury.

19. By performing Wallet balance top-up and transactions (including but not limited to purchase, sale, and gifting ) in the Treasury App, the user is deemed to have acknowledged, understood, and agreed to all Terms and Conditions, Privacy Policies, and various other terms and conditions available in the Treasury App. Violation of any or all of these provisions grants Treasury the authority to take actions including but not limited to blocking the User’s account.

20. The User states that they understand and agree not to use the Treasury App for money laundering activities and/or terrorism financing and/or the proliferation of weapons of mass destruction and/or other illegal activities. Treasury will not be responsible if the user uses the Treasury App for the prohibited activities as referred to in this provision. If Treasury finds any indication of the illegal use of the Treasury App, Treasury will follow up on this by reporting it to the relevant law enforcement authorities.

21. All forms of fraud and/or criminal acts committed by users and/or other parties in operating and/or transacting in the Treasury App will be followed up with the relevant law enforcement agencies.

22. Each Treasury user is not allowed to transfer or grant authority to others to operate the Treasury user’s account. Treasury will not be responsible for any forms of fraud and/or criminal acts and/or losses arising from such transfer or granting of authority to operate the account, and all losses will be fully borne by the Treasury user.

23. Treasury will not be responsible for errors arising from the negligence of Treasury users.

24. All types of malware attacks, data theft, and other security breaches caused by the use of devices that have undergone jailbreak or root are not the responsibility of Treasury.

25. Treasury does not allow users to use the Treasury App for activities and/or transactions that are not activities and/or features and/or transactions provided and/or promoted by Treasury.

26. Treasury is not responsible for activities and/or transactions conducted by users that are not activities and/or features and/or transactions provided by Treasury on the Treasury App. Users hereby understand and agree to release Treasury along with all its management, employees, and consultants from responsibility, including but not limited to legal and financial liability, for misuse of activities and/or features and/or transactions conducted by Users.

27. Treasury is a commodity trading platform that includes but is not limited to the first digital physical Gold and Silver trading platform that has obtained approval Ministry of Law of Singapore (Singapore’s Precious Stones and Precious Metals Act: PS20220002641. This ensures that transactions conducted by users on our platform are securely guaranteed.

D. Account Deactivation

1. Users may deactivate their Treasury account at any time directly through the Treasury App, and this action is permanent.

2. In the event that there is a remaining Gold and/or Silver balance belonging to the user in the Treasury App, the user is required to sell and/or convert and/or withdraw the Gold and/or Silver and/or piggy bank balance held in the Treasury account, and complete all ongoing transactions in the Treasury App before closing the account. If these actions have not been completed, the user will not be able to deactivate their Treasury account.

3. Users who have successfully deactivated their Treasury account cannot re-register with the Treasury App using the same email and phone number as the deactivated Treasury account.

4. Any form of fraud and/or criminal activity conducted by the user and/or other parties in operating and/or transacting in the Treasury App will be followed up with the relevant law enforcement agencies.

5. Each Treasury user is not permitted to transfer and/or grant power of attorney to others to operate the Treasury user’s account. Treasury will not be responsible for any fraud and/or criminal acts and/or losses arising from the transfer and/or granting of power to operate the account, and all losses will be fully borne by the Treasury user.

6. Treasury will not be responsible for errors arising from the negligence of Treasury users.

7. Users acknowledge and agree not to use the Treasury App for money laundering activities and/or terrorist financing and/or the proliferation of weapons of mass destruction and/or other illegal activities.

8. The Terms and Conditions for closing a user’s account may change at any time without prior notice to the user.

9. Users are advised to carefully read all Terms and Conditions, Privacy Policies, and other provisions contained in the Treasury App before conducting any transactions through the Treasury App.

10. These Terms and Conditions serve as a binding agreement between Treasury users and Treasury.

11. Any type of malware attack, data theft, and other security disturbances caused by the use of devices that have been jailbroken or rooted are not the responsibility of Treasury.

12. Treasury does not permit users to use the Treasury App for activities and/or transactions that are not part of the activities and/or features and/or transactions provided and/or promoted by Treasury.

13. Treasury is not responsible for activities and/or transactions conducted by users that are not part of the activities and/or features and/or transactions provided by Treasury in the Treasury App. Users hereby understand and agree to release Treasury, along with all its management, employees, and consultants, from responsibility, including but not limited to legal and financial accountability, for the misuse of activities and/or features and/or transactions conducted by the user.

14. Treasury is a commodity trading platform that includes but is not limited to digital physical Gold and Silver trading, the first of which has obtained a license from Ministry of Law of Singapore (Singapore’s Precious Stones and Precious Metals Act: PS20220002641. This ensures the security of transactions carried out by Users on our platform.

E. Blocked / Terminate Account

1. Treasury reserves the right to block and/or terminate the accounts of Treasury users who violate the laws of the Republic of Singapore, regulations of the relevant authorities, such other laws which are applicable to the services, and all applicable Terms and Conditions, including but not limited to the Treasury General Terms and Conditions and the Treasury Precious Metals Terms and Conditions.

2. The Treasury team will deactivate various features accessible by users who will be blocked due to violations as referred to in clause 1 above.

3. Blocked user accounts will receive an email from the Treasury team informing them of the violation and providing details of the follow-up actions related to the account blocking.

4. In the event that the user’s remaining Gold and/or Silver balance in the Treasury App is blocked by Treasury, the Treasury team will conduct an internal investigation to verify the legitimacy of the ownership of the Gold and/or Silver. If the owned Gold and/or Silver is valid and complies with all Terms and Conditions, the Treasury team will convert the remaining Gold and/or Silver into money, in accordance with the selling price listed in the Treasury App as of the date of the blocking, as communicated by the Treasury team to the user’s account.

5. Treasury reserves the right to forfeit transaction benefits in the form of Gold, Silver, money, and/or other forms owned by the user, who, after investigation by the Treasury team, is found to have violated provisions referred to in all applicable Terms and Conditions, including but not limited to the Treasury General Terms and Conditions and the Treasury Precious Metals Terms and Conditions.

6. The conversion terms of the remaining Gold and/or Silver belonging to users blocked by Treasury will be subject to the Gold and/or Silver sale terms as referred to in the Treasury General Terms and Conditions, including but not limited to the terms of money transfer resulting from the Gold and/or Silver conversion.

7. If the money resulting from the Gold and/or Silver conversion of a blocked Treasury user does not meet the minimum bank transfer requirements according to the regulations of the banking authorities, including but not limited to the regulations of each bank registered by the user as the bank used for transactions in the Treasury App, the user may withdraw the money at a location determined by the Treasury team.

8. Blocked users cannot re-register on the Treasury App, including with the same data and information held by the blocked user, including but not limited to email data, NRIC data, passport data and bank account numbers.

9. In the event of a dispute related to the blocking and/or termination of Treasury users who violate the laws of the Republic of Singapore, regulations of the relevant authorities, and all applicable Terms and Conditions, such other laws which are applicable to the services, including but not limited to the Treasury App General Terms and Conditions and the Treasury Precious Metals Terms and Condition, Treasury and Treasury users irrevocably submit to the non-exclusive jurisdiction of Singapore courts.

10. Any form of fraud and/or criminal activity conducted by the user and/or other parties in operating and/or transacting in the Treasury App will be followed up with the relevant law enforcement agencies.

11. Each Treasury user is not permitted to transfer and/or grant power of attorney to others to operate the Treasury user’s account. Treasury will not be responsible for any fraud and/or criminal acts and/or losses arising from the transfer and/or granting of power to operate the account, and all losses will be fully borne by the Treasury user.

12. Treasury will not be responsible for errors arising from the negligence of Treasury users.

13. Users acknowledge and agree not to use the Treasury App for money laundering activities and/or terrorist financing and/or the proliferation of weapons of mass destruction and/or other illegal activities.

14. The Terms and Conditions for blocking users may change at any time without prior notice to the user.

15. Users are advised to carefully read all Terms and Conditions, Privacy Policies, and other provisions contained in the Treasury App before conducting any transactions through the Treasury App.

16. These Terms and Conditions serve as a binding agreement between Treasury users and Treasury.

17. Any type of malware attack, data theft, and other security disturbances caused by the use of devices that have been jailbroken or rooted are not the responsibility of Treasury.

18. Treasury does not permit users to use the Treasury App for activities and/or transactions that are not part of the activities and/or features and/or transactions provided and/or promoted by Treasury.

19. Treasury is not responsible for activities and/or transactions conducted by users that are not part of the activities and/or features and/or transactions provided by Treasury in the Treasury App. Users hereby understand and agree to release Treasury, along with all its management, employees, and consultants, from responsibility, including but not limited to legal and financial accountability, for the misuse of activities and/or features and/or transactions conducted by the User.

20. Treasury is a commodity trading platform that includes but is not limited to digital physical Gold and Silver trading, the first of which has obtained a license from Ministry of Law of Singapore (Singapore’s Precious Stones and Precious Metals Act: PS20220002641. This ensures the security of transactions carried out by Users on our platform.

F. Refund

1. The Refund facility is a service provided by Treasury to return funds to Users in case of transaction issues within the Treasury app.

2. Transactions on the Treasury app that qualify for a Refund, as mentioned in point 1, must meet the following criteria (“Problematic Transactions”):

   1. • Transactions where the User has made a payment exceeding the required transaction amount; and/or
      • Transactions deemed invalid or non-compliant with Treasury’s applicable Terms and Conditions.

3. Treasury will only accept Refund requests for Problematic Transactions submitted by Users through WhatsApp : +6588362319 or email at [email protected], accompanied by the following supporting documents:

   1. • Proof of transaction payment, such as a transfer receipt or other payment confirmation;
      • Invoice or billing statement from the Treasury app for the transaction; and
      • A scanned copy of the savings book or registered bank account details linked to the Treasury app.

   Regardless of the above requirements, Treasury reserves the right to request additional documents from the User for verification purposes if necessary.

4. The maximum period for submitting a Refund request is 90-120 calendar days from the transaction date. Treasury reserves the right to reject Refund requests submitted beyond this period and/or those that do not meet the Problematic Transactions criteria as outlined in these Terms and Conditions.

5. If the documents provided by the User are incomplete or if Treasury requires additional documents, Treasury’s Customer Service team will contact the User via email and/or WhatsApp based on the channel used to submit the Refund request. Once all documents are complete and verified by Treasury, the Refund process will be completed within 1-2 business days after verification, except in cases of force majeure, which Treasury will notify the User about accordingly.

6. Funds will be refunded under the following conditions:

   1. • Refunds for Problematic Transactions made using Visa/Mastercard will be processed through a chargeback mechanism, where the User submits a refund request to their card-issuing bank for transactions deemed unauthorized or disputed. In this case, the User must apply for a Refund directly through their card issuer, acknowledging that the refund process will be subject to the chargeback policies of their issuing bank.
      • If the User’s Refund request requires processing via the chargeback mechanism, the User must follow the procedures set by their card-issuing bank, including but not limited to providing supporting evidence if required.
      • During the chargeback process, Treasury reserves the right to review and respond to the chargeback request, including accepting or rejecting the request, in accordance with Treasury’s policies and the terms set by the payment network (Visa/Mastercard). Treasury may reject a chargeback request if sufficient evidence confirms that the disputed transaction does not qualify as a Problematic Transaction.
      • If the chargeback is approved by Treasury, the issuing bank, and the payment network (Visa/Mastercard), Treasury will process the refund to the card used for the original transaction within the timeframe specified by the issuing bank.

7. If a Refund request is made for a Problematic Transaction that results in an unintended balance increase in the Treasury app (such as an increase in the User’s Gold balance or Savings balance), Treasury will deduct and/or remove the balance in the Treasury app equivalent to the refunded transaction amount.

8. Any fraudulent activities and/or illegal actions committed by the User and/or other parties in operating and/or conducting transactions within the Treasury app will be reported to the relevant law enforcement authorities.

9. Users of Treasury are strictly prohibited from transferring or granting access to their accounts to others. Treasury will not be responsible for any fraud, criminal activities, or losses resulting from account transfers or unauthorized access, and all losses will be fully borne by the User.

10. Treasury is not responsible for any losses resulting from errors due to the User’s negligence or intentional actions, including:

    1. • Errors in entering transaction data or submitting a Refund request that does not comply with applicable terms and conditions; and
       • Delays or failures in processing Refunds, unless such delays or failures are directly caused by Treasury’s negligence.

11. Treasury is not liable for any delays in Refund processing due to force majeure.

12. Users acknowledge and agree not to use the Treasury app for money laundering, terrorism financing, the proliferation of weapons of mass destruction, or any other illegal activities.

13. These Refund Terms and Conditions are subject to change at any time without prior notice to Users.

14. Users are advised to carefully read the Terms and Conditions, Privacy Policy, and other applicable policies available in the Treasury app before conducting any transactions.

15. These Terms and Conditions constitute a legally binding agreement between the User and Treasury.

16. Treasury is not responsible for any malware attacks, data theft, or security breaches caused by the use of jailbroken or rooted devices.

17. Treasury does not allow Users to use the Treasury app for activities and/or transactions that are not provided, supported, or promoted by Treasury.

18. Treasury is not liable for any activities and/or transactions conducted by Users that are outside the scope of Treasury’s services and features within the Treasury app. By using the app, Users acknowledge and agree to release Treasury, including its management, employees, and consultants, from any liability—including but not limited to legal and financial responsibility—resulting from the misuse of services and/or transactions conducted by the User.

19. Treasury is a commodity trading platform that includes, but is not limited to, the digital trading of physical Gold and Silver. It was among the first to obtain a license from the Singapore Ministry of Law under the Precious Stones and Precious Metals Act (PS20220002641). This ensures the security of transactions conducted by users on our platform.

G. Limitation of Liability

1. Subject to applicable laws, customers acknowledge the risks related to price volatility, liquidity, and operational issues before transacting.

2. Where a loss is suffered by customers for which Treasury would otherwise be jointly and severally or jointly liable with any third party or third parties, the extent to which such loss shall be recoverable by customers from Treasury (as opposed to any third parties) shall be limited so as to be in proportion to the aggregate of our contribution to the overall fault for such loss, as agreed between all of the relevant parties or, in the absence of agreement, as determined by a court of competent jurisdiction. For the purposes of assessing the contribution to the loss in question of any third party for the purposes of this clause, no account shall be taken of any limit imposed or agreed on the amount of liability of such third party by any agreement (including any settlement agreement) made before or after such Loss occurred or was otherwise incurred.

3. Nothing in these Terms and Conditions limits or excludes Treasury’s liability for death or personal injury caused by Treasury’s negligence or for any damage or liability incurred by the customer due to fraud or fraudulent misrepresentation by Treasury, or to the extent that liability cannot be excluded or limited under applicable law.

4. To the fullest extent permitted by applicable law, the customer agree to be responsible for and hold Treasury (along with its officers, directors, employees, suppliers, agents, and related entities) harmless from any and all loss, damage, liabilities, claims, costs, and expenses arising out of or in connection with:

   • The customers breach of these Terms and Conditions or any applicable law or regulation;
   • The customers use of our services; and/or
   • Any fraud committed by the customer.

   This provision shall remain in effect even after you cease using our services.

5. To the extent permitted by applicable law, Treasury is not liable, and the customer agrees not to hold Treasury responsible, for any damages or losses (including, but not limited to, loss of money, goodwill, reputation, profits, or other intangible losses, as well as any special, indirect, or consequential damages) resulting directly or indirectly from:

   • The customers inability to use our services for any reason;
   • Delays or disruptions in our services;
   • Viruses or other malicious software obtained from accessing our website or any associated site or service;
   • Glitches, bugs, errors, technological attacks, harmful material affecting your phone or computer hardware, software, or data, or inaccuracies of any kind in our services;
   • The content, actions, or inactions of third parties;
   • Suspension or other actions taken with respect to your Treasury account;
   • The customers need to modify practices, content, or behavior, or your loss of or inability to do business, due to changes in these Terms and Conditions; and/or
   • Illegal actions and operations of third parties conducted using counterfeit or illegal documents or data obtained unlawfully.

6. Treasury (including its officers, directors, employees, suppliers, agents, and related entities) shall not be liable for any failure to perform, or delay in performing, any of Treasury’s obligations due to events beyond our control. An event beyond our control includes, but is not limited to, strikes, lock-outs, industrial actions by third parties, civil commotion, riots, invasion, terrorist attacks or threats, wars (whether declared or not), fires, explosions, storms, floods, earthquakes, subsidence, epidemics, or other natural disasters, or failures in public or private telecommunications networks or the impossibility of using transport systems, including railways, shipping, aircraft, or other means of public or private transport.

7. Treasury shall have no liability to the customer under these Terms and Conditions or in any other way if we are prevented from or delayed in performing our obligations under these Terms and Conditions or carrying on our business due to acts, events, omissions, or accidents beyond our reasonable control. These events may include, but are not limited to, strikes, lock-outs, industrial disputes (whether involving us or others), failure of utility services, transport, or telecommunications networks, acts of God, war, riots, civil commotion, malicious damage, compliance with laws, government orders, rules, regulations, accidents, breakdowns in plant or machinery, fires, floods, storms, or default by subcontractors, provided that the customers are notified of such events and their expected duration.

TREASURY PRECIOUS METALS TERMS AND CONDITION

A. General

1. The following are the Treasury Precious Metals Terms and Conditions of providing services for the acquisition, storage, transportation, and sale of precious metals between Treasury App and Users.

2. For users who transact in precious metals on the Treasury App, this Treasury Precious Metals Terms and Conditions must be read in conjunction with the Treasury App General terms and Conditions.

3. Unless otherwise defined herein, capitalised terms used here shall have the meanings ascribed to them in the Treasury App General Terms and Conditions.

4. Treasury App agrees to offer the following services to you. When Users execute a transaction within the Treasury App, Users are deemed to have acknowledged, understood and agreed the terms and conditions of this Agreement.

5. Precious Metals refer to physical Gold and Silver transacted via the Treasury App.

6. All Terms and Conditions, any Treasury accounts, and the relationship between Treasury and Users, shall be subject to, governed by and construed in accordance with the laws of the Republic of Singapore and such other laws which are applicable to the services. Treasury and Users submit to the non-exclusive jurisdiction of the courts of the Republic of Singapore.

B. Gold and Silver Buy

1. Gold and/or Silver purchases can be made using payment options, including: credit card (Visa/Mastercard), debit card (Visa/Mastercard), paynow QR code (only applicable when bank account and/or ewallet platform is connected to paynow payment system) , as well as other payment options that have been or will be implemented by Treasury for User convenience, both currently available or in the future, as displayed in the Treasury App including but not limited to provisions on the maximum transaction amount that can be conducted by the User.

2. The minimum Gold purchase amount via the Treasury App is 0.0001 gram.

3. The minimum Silver purchase amount via the Treasury App is 0.01 gram.

4. The maximum total amount of Gold and/or Silver purchases via the Treasury App in a single transaction is SGD 9,999. For purchases above 9,999 SGD up to 20,000 SGD, they are categorized as Big Orders and will be directed to Treasury customer service to proceed the transaction.

5. Gold obtained by the User through purchasing Gold on the Treasury App is categorized as organic Gold.

6. Silver obtained by the User through purchasing Silver on the Treasury App is categorized as organic Silver.

7. Gold purchased by the User using the Wallet Voucher Balance and/or obtained free of charge through promotions conducted by Treasury and/or e-commerce partners and/or the Treasury marketplace is not categorized as organic Gold.

8. Silver purchased by the User using the Wallet Voucher Balance and/or obtained free of charge through promotions conducted by Treasury and/or e-commerce partners and/or the Treasury marketplace is not categorized as organic Silver.

9. The maximum transfer amount for each transaction within the Treasury App are or will be available on the Treasury App.

10. The notification of the amount to be paid by the User will include the total price of the Gold and/or Silver plus administrative fees and taxes.

11. Gold and/or Silver purchases must be completed by entering a confidential Transaction PIN known only to the respective User of the Treasury App.

12. The Gold and/or Silver purchase price changes continuously over time (by the minute), following global Gold and/or Silver price fluctuations, which can be monitored by the User through the Treasury App.

13. Users can only make Gold and/or Silver purchases and/or other transactions using one device, with a maximum of three (3) transactions within one (1) minute. Treasury reserves the right to cancel transactions made by Users who do not comply with these terms. Cancellations will be applied to all transactions made within the close timeframe.

14. Gold and/or Silver purchased will automatically be entrusted to Treasury without any fees and time limits as per the User’s preference and will be recorded in the User’s Treasury account.

15. Gold and/or Silver entrusted can be sold based on the selling price at the time the User decides to sell or gift to other Treasury Users in accordance with the applicable Terms and Conditions.

16. Users are limited to a maximum of ten (10) transactions per day on the Treasury App for Gold and/or Silver purchases. Failures in conducting various transactions on the Treasury App due to errors and/or data discrepancies from the User, including but not limited to data such as NRIC, bank accounts, are not the responsibility of Treasury.

17. Treasury reserves the right to cancel a User’s Gold and/or Silver purchase and/or block and/or terminate the registered User’s account that Treasury deems suspicious and not in compliance with the laws of the Republic of Singapore, regulations of the relevant authorities, as well as the applicable Terms and Conditions, Users who have been blacklisted by Treasury, and such other laws which are applicable to the services.

18. Users can access profit/loss information from the Total Assets they own, displayed in Singapore Dollars or percentages. Users acknowledge that the profit/loss information is not absolute and/or fully accurate and may change at any time in line with the market price fluctuations of the Commodity Assets displayed on the Treasury App.

19. In case of promotions related to Gold and/or Silver purchases, the Terms and Conditions regarding the promotions also apply to the User.

20. Users who have been blacklisted by Treasury are not allowed to participate in promotions conducted by Treasury or any third parties working in collaboration with Treasury. The promotions referred to in this provision include vouchers, Gold and/or Silver bonuses, or other forms and benefits provided by Treasury. Treasury reserves the right to cancel transactions and/or revoke vouchers, Gold and/or Silver bonuses, or other forms and benefits granted to blacklisted Users or those who are not entitled to them and/or obtained by Users but in violation of these Terms and Conditions.

21. The Terms and Conditions for Gold and/or Silver purchases may change at any time without prior notice to the User.

22. The provisions regarding the submission of User data are subject to the privacy policy of the Treasury App, which is binding on the User.

23. Users are advised to carefully read all Terms and Conditions, Privacy Policy, and other provisions available on the Treasury App before conducting any transactions through the Treasury App.

24. These Terms and Conditions serve as a binding agreement between the Treasury Users and Treasury.

25. By conducting transactions (including but not limited to Gold and/or Silver purchases, sales, and gifts) on the Treasury App, the User is deemed to have understood, acknowledged, and agreed to all the Terms and Conditions, Privacy Policy, and other provisions available on the Treasury App. Violation of any or all of these provisions grants Treasury the authority to take actions, including but not limited to blocking the User’s account.

26. Users acknowledge and agree not to use the Treasury App for money laundering activities and/or terrorism financing and/or the proliferation of weapons of mass destruction and/or other unlawful acts. Treasury shall not be held liable if the User uses the Treasury App for activities prohibited as mentioned in this provision. If Treasury detects any indication of unlawful use of the Treasury App, Treasury will follow up by reporting it to the relevant law enforcement authorities.

27. Any form of fraud and/or criminal acts committed by Users and/or other parties in operating and/or transacting on the Treasury App will be followed up with the relevant law enforcement authorities.

28. Each Treasury User is not allowed to transfer and/or grant authorization to others to operate the User’s Treasury account. Treasury will not be responsible for any fraud and/or criminal acts and/or losses arising from the transfer and/or granting of authorization to operate the account, and all losses will be fully borne by the Treasury User.

29. Treasury will not be liable for errors arising from the negligence of Treasury Users.

30. Any malware attacks, data theft, and other security breaches caused by the use of devices that have been jailbroken or rooted are not Treasury’s responsibility.

31. Treasury does not allow Users to use the Treasury App for activities and/or transactions that are not provided and/or promoted by Treasury.

32. Treasury is not responsible for activities and/or transactions conducted by Users that are not activities and/or features and/or transactions provided by Treasury on the Treasury App. The User hereby understands and agrees to release Treasury, along with all its management, employees, and consultants, from any liability, including but not limited to legal and financial responsibility, for the misuse of activities and/or features and/or transactions conducted by the User.

33. Treasury is a commodity trading platform, including but not limited to being the first digital physical Gold and Silver trading platform that has been licensed by Ministry of Law of Singapore (Singapore’s Precious Stones and Precious Metals Act: PS20220002641. This ensures that transactions conducted by Users on our platform are secure.

C. Gold and Silver Sell

1. The minimum Gold and/or Silver sale amount via the Treasury App is SGD 6.

2. The maximum Gold and/or Silver sale amount via the Treasury App is SGD 20,000.

3. The proceeds from the Gold and/or Silver sale will be transferred to the bank account registered by the User in the Treasury App within two (2) business days, subject to and in accordance with banking operational hours. Ensure that the data entered is accurate. User bear full responsibility for ensuring the accuracy of the bank account information provided for disbursement. Treasury will not be held liable for any disbursement errors resulting from incorrect information submitted by the User.

4. Proceeds from Gold and/or Silver sales directed to the Wallet in the Treasury App will be added to the Wallet balance within a maximum of two (2) business days.

5. In the case of Gold and/or Silver sales involving Gold and/or Silver is still undergoing verification, the proceeds will be transferred to the bank account registered by the User in the Treasury App within three (3) calendar days, subject to and in accordance with banking operational hours. Ensure that the data entered is accurate. User bear full responsibility for ensuring the accuracy of the bank account information provided for disbursement. Treasury will not be held liable for any disbursement errors resulting from incorrect information submitted by the User.

6. The Gold and/or Silver sales must be conducted by entering a Transaction PIN, which is confidential and only known to the respective Treasury App User.

7. The Gold and/or Silver selling price is constantly changing (every minute), following fluctuations in global gold prices, which can be monitored by the User through the Treasury App.

8. The User can only sell Gold and/or Silver and/or conduct other transactions using a single device, with a maximum of three (3) transactions allowed within one (1) minute. Treasury reserves the right to cancel transactions conducted by the User that do not comply with this provision. Cancellation of transactions will result in the cancellation of all transactions conducted within a close time frame.

9. The Gold and/or Silver selling price will be locked for one (1) minute when the User initiates the sale.

10. Failures in conducting Gold and/or Silver sales and/or withdrawing the proceeds from Gold and/or Silver sales in the Treasury App due to errors and/or discrepancies in the User’s data, including but not limited to NRIC data, passport data, or bank account data, will not be the responsibility of Treasury.

11. If there is a promotion related to Gold and/or Silver sales, the terms and conditions of the promotion will also apply to the User.

12. Users are limited to a maximum of ten (10) transactions per day on the Treasury App for Gold and/or Silver purchases and/or sales.

13. Treasury reserves the right to cancel the User’s Gold and/or Silver sales and/or block and/or terminate the User’s registered account if Treasury detects suspicious activity or if the activity is deemed non-compliant with the laws and regulations of the Republic of Singapore, the regulations of the relevant authorities, or these Terms and Conditions, or if the User is blacklisted by Treasury or such other laws which are applicable to the services. Users can access profit/loss information from their Total Assets in Singapore Dollar or percentage. The User understands that this profit/loss information is not absolute and/or fully accurate and may change at any time, following fluctuations in commodity market prices displayed in the Treasury App.

14. If there is a promotion related to the User’s Gold and/or Silver sales in the Treasury App, the terms and conditions of the promotion will also apply to the User.

15. Users who are blacklisted by Treasury are not permitted to participate in promotions conducted by Treasury or other third parties in cooperation with Treasury. Promotions referred to in this provision include vouchers, Gold and/or Silver bonuses, or other forms of benefits provided by Treasury. Treasury reserves the right to cancel transactions and/or revoke vouchers, Gold and/or Silver bonuses, or other benefits provided to Users who are blacklisted or are not eligible to receive them and/or have acquired them in violation of these Terms and Conditions.

16. These Gold and/or Silver sale terms and conditions are subject to change at any time without prior notice to the User.

17. Provisions regarding the submission of User data are subject to the privacy policy of the Treasury App, which binds the User.

18. Users are advised to carefully read all Terms and Conditions, Privacy Policy, and other terms contained in the Treasury App before conducting any transaction through the Treasury App.

19. These Terms and Conditions serve as a binding agreement between Treasury Users and Treasury.

20. By conducting transactions (including but not limited to the purchase, sale, and gift of Gold and/or Silver) on the Treasury App, the User is deemed to have acknowledged, understood, and agreed to all the Terms and Conditions, Privacy Policy, and other terms contained in the Treasury App. Violations of any or all of these terms authorize Treasury to take actions, including but not limited to blocking the User’s account.

21. The User acknowledges and agrees not to use the Treasury App for money laundering and/or terrorist financing and/or the proliferation of weapons of mass destruction and/or other illegal activities. Treasury will not be responsible if the User uses the Treasury App for activities prohibited under this provision. If Treasury detects any indication of illegal use of the Treasury App, Treasury will take appropriate action, including reporting the matter to the relevant law enforcement authorities.

22. Any fraud and/or criminal acts committed by the User and/or other parties in operating and/or conducting transactions in the Treasury App will be followed up with the relevant law enforcement authorities.

23. Each Treasury User is prohibited from transferring and/or granting power to another person to operate the User’s Treasury account. Treasury will not be responsible for any fraud and/or crimes and/or losses arising from the transfer and/or granting of power to operate the account, and all losses will be fully borne by the Treasury User.

24. Treasury will not be responsible for any errors arising from the negligence of Treasury Users.

25. Any malware attacks, data theft, and other security breaches caused by the use of devices that have been jailbroken or rooted will not be the responsibility of Treasury.

26. Treasury does not permit Users to use the Treasury App for activities and/or transactions that are not part of the activities and/or features and/or transactions provided and/or promoted by Treasury.

27. Treasury will not be responsible for activities and/or transactions conducted by Users that are not part of the activities and/or features and/or transactions provided by Treasury on the Treasury App. Users hereby understand and agree to release Treasury, along with its management, employees, and consultants, from all liabilities, including but not limited to legal and financial liabilities, for the misuse of activities and/or features and/or transactions conducted by Users.

28. Treasury is a commodity trading platform that includes but is not limited to digital physical Gold and/or Silver trading. Treasury has been licensed by Ministry of Law of Singapore (Singapore’s Precious Stones and Precious Metals Act: PS20220002641. This ensures that transactions conducted by Users on our platform are secure.

D. Gold and Silver Send Gift

1. The minimum amount of Gold and/or Silver that can be Gifted through the Treasury App is SGD 1.

2. The maximum amount of Gold and/or Silver that can be Gifted through the Treasury App is SGD 20,000.

3. Users can gift (Gift) Gold and/or Silver after completing the NRIC verification process.

4. Gold and/or Silver that can be gifted by Users is Gold and/or Silver purchased based on the Gold and/or Silver purchasing method as stipulated in these Terms and Conditions. Gold and/or Silver obtained by Users from bonuses and/or vouchers and/or promotions conducted by Treasury or other third parties cannot be gifted using the Gold and/or Silver gifts method as referred to in these Terms and Conditions.

5. Gold and/or Silver gifts can only be made by entering a Transaction PIN, which is confidential and only known to the respective Treasury App User.

6. Gold and/or Silver gifts and/or receiving Gold and/or Silver from gifts can only be conducted for a total maximum of fifty (50) grams of Gold and/or Silver per day.

7. The User gifting Gold and/or Silver to another User will receive a notification through the User’s App and email.

8. Treasury is not responsible for any disputes that may arise between Users regarding Gold and/or Silver gifts.

9. Users may only conduct a maximum of two (2) Gold and/or Silver gift transactions in one (1) day. Treasury reserves the right to cancel transactions made by Users that do not comply with this provision.

10. Users can only receive Gold and/or Silver through gifts a maximum of two (2) times in one (1) day. Treasury reserves the right to cancel transactions made by Users that do not comply with this provision.

11. The limits on Gold and/or Silver gifts (Gift), as well as the frequency of Gold and/or Silver gifts and receipts per day, are parameterized.

12. Treasury reserves the right to disable Gold and/or Silver gifts (Gift) and/or cancel transactions deemed suspicious and inconsistent with the laws of the Republic of Singapore, regulations of relevant authorities, the applicable Terms and Conditions and such other laws which are applicable to the services.

13. In the event of more than two (2) Gold and/or Silver gift or Gold and/or receipt activities within the same minute (race condition), only the first Gold and/or gift or receipt will be processed. Treasury reserves the right to cancel transactions made by Users that do not comply with this provision.

14. Users who have been blacklisted by Treasury cannot use the Gold and/or Silver gift (Gift) feature and/or other features within the Treasury App.

15. In the case of promotions related to Gold and/or Silver gift and/or other promotions, the Terms and Conditions regarding the promotion will also apply to Users.

16. Failure to conduct various transactions on the Treasury App due to errors and/or mismatches in the User’s data, including but not limited to NRIC, bank account, is not the responsibility of Treasury.

17. Treasury reserves the right to refuse a User’s transaction and/or block and/or terminate a User’s registered account if Treasury indicates and considers it suspicious and inconsistent with the laws of the Republic of Singapore, the regulations of relevant authorities, the applicable Terms and Conditions, Users who have been blacklisted by Treasury, and such other laws which are applicable to the services.

18. Users can access profit/loss information from the total assets they own, in both Singapore Dollar and percentage. Users acknowledge that the profit/loss information is not absolute and/or entirely accurate and will change from time to time, following fluctuations in the market price of commodities assets displayed in the Treasury App.

19. In the case of promotions related to Gold and/or Silver gifts, the Terms and Conditions regarding the promotion will also apply to Users.

20. Users who have been blacklisted by Treasury are not allowed to participate in promotions conducted by Treasury or other third parties cooperating with Treasury. The promotions referred to in this provision also include vouchers, Gold and/or Silver bonuses, or other forms and benefits provided by Treasury. Treasury reserves the right to cancel transactions and/or revoke vouchers, Gold and/or Silver bonuses, or other forms and benefits provided by Treasury that belong to Users who have been blacklisted or that are obtained by Users without the right to do so, and/or obtained by Users not in compliance with these Terms and Conditions.

21. The Terms and Conditions of Gold and/or Silver gifts can be changed at any time without prior notice to Users.

22. The provision regarding the submission of User data information is subject to the Treasury App privacy policy that binds Users.

23. Users are advised to read carefully all Terms and Conditions, the Privacy Policy, and other provisions in the Treasury App before conducting any transactions through the Treasury App.

24. These Terms and Conditions serve as a binding agreement between Treasury Users and Treasury.

25. By conducting transactions (which include but are not limited to the purchase, sale, and gift) on the Treasury App, Users are deemed to have understood, acknowledged, and agreed to all Terms and Conditions, Privacy Policy, and other provisions in the Treasury App. Violation of any or all of these provisions grants Treasury the authority to take actions, including but not limited to blocking the User’s account.

26. Users acknowledge and agree not to use the Treasury App for money laundering activities and/or terrorist financing and/or the proliferation of weapons of mass destruction and/or other unlawful acts. Treasury is not responsible if Users use the Treasury App for prohibited activities as referred to in this clause. Should Treasury find any indication of the unlawful use of the Treasury App, Treasury will follow up on the matter by reporting it to the relevant law enforcement authorities.

27. Any form of fraud and/or criminal activity committed by Users and/or other parties while operating and/or conducting transactions on the Treasury App will be followed up with the relevant law enforcement authorities.

28. Each Treasury User is not permitted to transfer or grant power to another party to operate the Treasury User account. Treasury is not responsible for any fraud and/or criminal activity and/or losses arising from such transfers or granting of power to operate the account, and all losses will be fully borne by the Treasury User.

29. Treasury is not responsible for errors arising from the negligence of Treasury Users.

30. Any type of malware attack, data theft, and other security disruptions caused by using devices that have undergone jailbreak or root modifications are not the responsibility of Treasury.

31. Treasury does not permit Users to use the Treasury App for activities and/or transactions that are not activities and/or features and/or transactions provided and/or promoted by Treasury.

32. Treasury is not responsible for activities and/or transactions conducted by Users that are not activities and/or features and/or transactions provided by Treasury on the Treasury App. Users hereby understand and agree to release Treasury and all its management, employees, and consultants from any responsibility, including but not limited to legal and financial liabilities, for the misuse of activities and/or features and/or transactions conducted by Users.

33. Treasury is a commodity trading platform, including but not limited to the trade of physical digital gold and/or silver, which is the first to have obtained permission from Ministry of Law of Singapore (Singapore’s Precious Stones and Precious Metals Act: PS20220002641. This ensures that the transactions conducted by Users on our platform are secure.

E. Gold and Silver Save+

1. Gold/Silver Save+ is a feature available to all Treasury Users, allowing them to earn additional Gold and/or Silver grams (“Gold / Silver Bonus”) by storing Gold and/or Silver for a specific period (“Certain Period”) in the Treasury App. The period and the corresponding bonus will be displayed in the Treasury App.

2. The term “day” in the Treasury Gold/Silver Save+ feature refers to a calendar day;

3. The Gold / Silver Bonus is an annual percentage of the Gold and/or Silver grams stored during the Certain Period in the Treasury Gold / Silver Save+ feature;

4. The Gold / Silver Bonus depends on the grams of Gold and/or Silver stored and the duration of each Certain Period of Gold and/or Silver storage;

5. The payment method for purchasing Gold and/or Silver to be stored in the Treasury Gold/Silver Save+ feature can be made through the Wallet Balance or other payment methods listed in the Treasury Gold/Silver Save+ feature;

6. The Gold and/or Silver balance stored at the beginning of the Certain Period will be sent to the Treasury User’s Gold and/or Silver balance when the Certain Period ends;

7. Specifically for Treasury Users who store Gold and/or Silver for a Certain Period other than 14 (fourteen) days, the Gold / Silver Bonus will be sent to the Treasury User’s Gold balance every 30 (thirty) days;

8. The Gold / Silver Bonus in the Treasury Gold/Silver Save+ program already includes taxes and other fees (if any);

9. In the event that a Treasury User withdraws Gold and/or Silver that is being stored before the selected Certain Period ends, the Treasury User will be subject to an early withdrawal fee of zero point five percent (0.5%) of the stored Gold and/or Silver grams. By withdrawing Gold and/or Silver before the selected Certain Period ends, the Gold / Silver Bonus as referred to in points 1, 3, and 7 becomes invalid;

10. The maximum number of ongoing Gold/Silver Save+ processes at one time is ten (10);

11. Treasury Users who have previously been blacklisted by Treasury cannot participate in this Treasury Gold/Silver Save+ feature;

12. Treasury reserves the right to cancel this Treasury Gold/Silver Save+ feature if suspicious transactions are detected and/or have the potential to harm Treasury/other third parties and/or do not comply with the laws and regulations of the Republic of Singapore, the regulations of the competent authorities, the Treasury User Agreement, the applicable Terms and Conditions of Treasury, such other laws which are applicable to the services, as well as Treasury Users who have been blacklisted as mentioned in clause 11 above;

13. By participating in this Treasury Gold/Silver Save+ feature, Treasury Users are considered to have acknowledged and agreed not to use the Treasury App as a means for money laundering activities and/or terrorist financing and/or proliferation of weapons of mass destruction and/or other illegal activities;

14. By participating in the Treasury Gold/Silver Save+ feature, Treasury Users are deemed to have acknowledged, read, understood, and agreed to all existing provisions;

15. In addition to the Terms and Conditions of the Treasury Gold/Silver Save+ feature, Treasury Users are also subject to and required to comply with all Terms and Conditions and/or other binding provisions contained in the Treasury App and/or website, unless expressly stated by Treasury that such Terms and Conditions do not apply in the implementation of this Treasury Gold/Silver Save+ feature;

16. These terms and conditions may change at any time without prior notice to Treasury Users;

17. Treasury Users are advised to carefully read all the Terms and Conditions before conducting any transactions through the Treasury App. For more information, Treasury Users can contact Treasury Customer Service via email at [email protected]

18. Any actions deemed as fraud and/or criminal acts will be followed up by Treasury through legal proceedings in accordance with the laws and regulations of the Republic of Singapore.

19. Each Treasury User is not permitted to transfer and/or grant power of attorney to others to operate the Treasury User’s account. Treasury will not be responsible for any fraud and/or criminal acts and/or losses arising from the transfer and/or granting of power to operate the account, and all losses will be fully borne by the Treasury User;

20. Treasury will not be responsible for errors arising from the negligence of Treasury Users;

21. These Terms and Conditions serve as a binding agreement between Treasury Users and Treasury;

22. Any type of malware attack, data theft, and other security disturbances caused by the use of devices that have been jailbroken or rooted are not the responsibility of Treasury;

23. Treasury does not permit Users to use the Treasury App to conduct activities and/or transactions that are not part of the activities and/or features and/or transactions provided and/or promoted by Treasury;

24. Treasury is not responsible for activities and/or transactions conducted by Users that are not part of the activities and/or features and/or transactions provided by Treasury in the Treasury App. Users hereby understand and agree to release Treasury, along with all its management, employees, and consultants, from responsibility, including but not limited to legal and financial accountability, for the misuse of activities and/or features and/or transactions conducted by the User;

25. Treasury is a commodity trading platform that includes but is not limited to digital physical gold and silver trading, the first of which has obtained a license from Ministry of Law of Singapore (Singapore’s Precious Stones and Precious Metals Act: PS20220002641. This ensures the security of transactions carried out by Users on our platform.

F. Advance Cash

1. “Advance Cash” is a feature that can be used by all Treasury Users to temporarily sell a certain amount of their digital Gold balance to Treasury (“Gold Balance”) at a value of ninety-three percent (95%) of the Gold Selling Price at the time the transaction occurs, and then the Treasury User is obligated to repurchase the Gold Balance sold periodically with a selectable period and the Advance Cash fee that will be charged to the User (“Advance Cash Fee“);

2. The Advance Cash Fee will be charged every fifteen (15) days to Treasury Users participating in Advance Cash. Treasury Users can periodically repurchase the Gold Balance, and the period will be displayed in the Treasury App. The calculation of the period will be based on calendar days.

3. “Repurchase Value” refers to the repurchase value of the temporarily sold Gold Balance by the User when participating in Advance Cash along with the Advance Cash Fee;

4. Treasury Users have the right to repurchase all the Gold Balance used in Advance Cash at one time by paying the remaining Repurchase Value according to the selected Period;

5. The minimum amount that can be temporarily sold in the Advance Cash program SGD 5;

6. The maximum amount that can be temporarily sold in the Advance Cash program is SGD 20,000;

7. Treasury Users will be charged a Disbursement Fee of SGD 0.25 when conducting a Advance Cash transaction, which will be deducted from the Treasury User’s Gold Balance above;

8. Treasury Users participating in Advance Cash are required to repurchase a certain amount or the entire Repurchase Value, which will be calculated based on the selected Period every thirty (30) days (“Period Expiry Date”) starting from the initial Advance Cash transaction date. Specifically, for the fifteen (15) day Period option, the Period Expiry Date is fifteen (15) days from the initial Advance Cash transaction date;

9. The payment method for the Repurchase Value can be made using credit card (Visa/Mastercard), debit card (Visa/Mastercard), paynow QR code (only applicable when bank account and/or ewallet platform is connected to paynow payment system) as well as other payment options that have been or will be implemented by Treasury for User convenience, both currently available or in the future, as displayed in the Treasury App. Terms and conditions regarding offline transactions will depend on the mechanisms established by each respective payment provider, including but not limited to provisions on the maximum transaction amount that can be conducted by the User;

10. If Treasury Users have not made the Repurchase Value payment by the Period Expiry Date, they will enter a “Grace Period” for a maximum of fourteen (14) days and will be charged a “Late Fee” of SGD 0.50 for each day capped at SGD 7.50 during the Grace Period until the Treasury User has made the Repurchase Value payment;

11. If the Treasury User has not made the Repurchase Value payment by the end of the Grace Period, the Treasury User’s participation in Advance Cash will be declared terminated;

12. The previously paid Repurchase Value will be accumulated and reduced by the total Late Fee, then used to purchase Gold based on the Gold purchase price at that time and afterward sent to the Treasury User in the form of Gold Balance. The Gold Balance temporarily sold to Treasury will become a permanent sale that cannot be repurchased;

13. If the Treasury User has fulfilled the Advance Cash Terms and Conditions as outlined above, the repurchase is deemed successful, and Treasury will provide the Gold Balance used in Advance Cash to the Treasury User no later than twenty-four (24) hours from the end of the Advance Cash Period;

14. Treasury Users who have previously been blacklisted by Treasury cannot participate in Advance Cash;

15. Treasury reserves the right to cancel ongoing Advance Cash if any suspicious transactions are found and/or have the potential to harm Treasury/other third parties and/or do not comply with the laws and regulations of the Republic of Singapore, the regulations of competent authorities, the Treasury User Agreement, the applicable Treasury Terms and Conditions, such other laws which are applicable to the services, as well as Treasury Users who have been blacklisted as mentioned in clause 13 above;

16. By participating in Advance Cash, Treasury Users are considered to have acknowledged and agreed not to use the Treasury App as a means for money laundering activities and/or terrorist financing and/or the proliferation of weapons of mass destruction and/or other illegal activities;

17. By participating in Advance Cash, Treasury Users are deemed to have acknowledged, read, understood, and agreed to all the applicable provisions;

18. In addition to the Terms and Conditions of Advance Cash, Treasury Users are also subject to and required to comply with all Terms and Conditions and/or other binding provisions contained in the Treasury App and/or website, unless expressly stated by Treasury that these Terms and Conditions do not apply in the implementation of the Advance Cash feature;

19. These terms and conditions are subject to change at any time with or without prior notice to Treasury Users;

20. Treasury Users are advised to carefully read all the Terms and Conditions before conducting any transactions through the Treasury App. For more information, Treasury Users can contact Treasury Customer Service via email at [email protected];

21. Any actions deemed as fraud and/or criminal acts will be followed up by Treasury through legal proceedings in accordance with the laws and regulations of the Republic of Singapore;

22. Each Treasury User is not permitted to transfer and/or grant power of attorney to others to operate the Treasury User’s account. Treasury will not be responsible for any fraud and/or criminal acts and/or losses arising from the transfer and/or granting of power to operate the account, and all losses will be fully borne by the Treasury User;

23. Treasury will not be responsible for errors arising from the negligence of Treasury Users;

24. These Terms and Conditions serve as a binding agreement between Treasury Users and Treasury;

25. Unless expressly stated otherwise in these Terms and Conditions, Treasury Users participating in Advance Cash are also bound by all terms and conditions contained within the Treasury App;

26. Any type of malware attack, data theft, and other security disturbances caused by the use of devices that have been jailbroken or rooted are not the responsibility of Treasury.

27. Treasury does not permit Users to use the Treasury App to conduct activities and/or transactions that are not part of the activities and/or features and/or transactions provided and/or promoted by Treasury.

28. Treasury is not responsible for activities and/or transactions conducted by Users that are not part of the activities and/or features and/or transactions provided by Treasury in the Treasury App. Users hereby understand and agree to release Treasury, along with all its management, employees, and consultants, from responsibility, including but not limited to legal and financial accountability, for the misuse of activities and/or features and/or transactions conducted by the User;

29. Treasury is a commodity trading platform that includes but is not limited to digital physical gold and silver trading, the first of which has obtained a license from Ministry of Law of Singapore (Singapore’s Precious Stones and Precious Metals Act: PS20220002641. This ensures the security of transactions carried out by Users on our platform.

TREASURY ANTI-MONEY LAUNDERING (AML) AND COUNTER-TERRORISM FINANCING (CTF) POLICY

A. Policy Overview

1. Objective

   This AML/CTF policy aims to safeguard Treasury’s operations, ensure compliance with Singapore’s regulatory framework, and combat money laundering and terrorism financing in accordance with:

   • The Monetary Authority of Singapore (MAS) Payment Services Act (PSA).
   • The Precious Stones and Precious Metals (PSPM) Act.
   • The Financial Action Task Force (FATF) standards.

2. Scope

   This policy applies to all employees, officers, contractors, and agents of Treasury, as well as all transactions conducted on Treasury’s platform, including buy, sell, or trade operations of precious metals or commodities.

B. Risk Assessment Framework

1. Risk-Based Approach (RBA)

   Treasury adopts a Risk-Based Approach to:

   • Identify and assess risks related to money laundering and terrorism financing.
   • Prioritize resources on higher-risk areas, such as transactions involving politically exposed persons (PEPs), high-risk jurisdictions, or high-value commodities.

2. Risk Categories

   Treasury identifies risks under three categories:

   • Customer Risk: High-risk customers include PEPs, non-residents, or clients from high-risk jurisdictions.
   • Transaction Risk: Transactions that are unusually large, complex, or inconsistent with customer profiles.
   • Geographic Risk: Jurisdictions with weak AML/CTF regulations or listed on international watchlists.

C. Customer Due Diligence (CDD)

1. CDD Process

   Treasury ensures effective customer verification by collecting:

   • Individual Clients: Full name, date of birth, residential address, ID number (e.g., NRIC or passport), and nationality.
   • Corporate Clients: Name of the entity, registration number (e.g. Singapore Unique Entity Number (UEN)), constitutional documents (e.g. memorandum and articles of association or partnership agreement), registered address, and identification of beneficial owners (>25%).

2. Enhanced Due Diligence (EDD)

   For high-risk customers (e.g., PEPs or transactions in any one year period cumulatively exceeds SGD 20,000):

   • Obtain additional information, such as source of funds and intended transaction purpose.
   • Conduct ongoing monitoring of transactions.

3. Ongoing Monitoring

   • Regularly review customer transactions to ensure consistency with the customer profile.
   • Flag unusual or suspicious activity (e.g. complex, unusually large or unusual patterns of transactions) for further investigation.

D. Record Keeping

1. Retention Requirements

   • Retain all records related to customer identification, transactions, and risk assessments for a minimum of 5 years after the relationship ends.
   • Ensure accessibility of records for regulatory review upon request.

2. Records to Be Maintained

   • • Copies of customer identification documents.
     • Records of transactions, including amounts, dates, and methods.
     • Results of risk assessments and internal investigations.

    

E. Reporting Obligations

1. Suspicious Transaction Reporting (STR)

   • Treasury will file an STR with the Suspicious Transaction Reporting Office (STRO) for any activity that is suspected of involving money laundering or terrorism financing.
   • STRs must be submitted promptly, within the legal timeframe.

2. Large Value Transactions Reporting

   • Report any cross-border transactions exceeding SGD 20,000 to the relevant authorities, as required under Singapore law.

F. Employee Training and Awareness

1. Training Programs

   Treasury provides annual AML/CTF training to employees, covering:

   • Identification of suspicious activities.
   • Reporting obligations and procedures.
   • Updates on AML/CTF regulations.

2. New Employee Onboarding

   All new employees must complete an AML/CTF orientation as part of their onboarding process.

G. Internal Controls and Independent Audit

1. Internal Controls

   Treasury has established internal procedures to:

   • Implement the Risk-Based Approach.
   • Ensure compliance with CDD, monitoring, and reporting obligations.

2. Independent Audit

   An external auditor will conduct periodic reviews of Treasury’s AML/CTF framework to:

   • Evaluate its effectiveness.
   • Identify gaps and recommend improvements.

H. Specific Requirements for Commodities Transactions

1. Trade-Based Money Laundering (TBML)

   Treasury recognizes that the commodities industry is vulnerable to TBML and will implement additional measures, including:

   • Verifying the authenticity of trade documents.
   • Monitoring the value of commodities to identify under- or over-invoicing.

2. Sanctions Screening

   All clients and transactions will be screened against international sanctions lists and the MAS Targeted Financial Sanctions requirements.

I. Compliance with MAS Notice PSN01

Treasury adheres to MAS Notice PSN01 by:

• Ensuring compliance with AML/CTF guidelines specific to payment services providers.
• Performing enhanced customer due diligence for transactions in any one year period cumulatively exceeds SGD 20,000.
• Conducting regular screenings of clients against terrorist watchlists.

J. Penalties for Non-Compliance

Non-compliance with this policy may result in:

• Regulatory fines or sanctions.
• Legal consequences for Treasury or its employees.
• Reputational damage to Treasury.

K. Policy Review and Updates

This policy will be reviewed annually or as required to reflect:

• Changes in AML/CTF laws or regulations.
• Updates in Treasury’s business operations.
• Findings from internal audits or risk assessments.