Summary of Custody and Administration Policy

Date of issuance: 31.05.2025
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Table of Content

1. Introduction and purposes of the Policy
2. Segregation of assets and safekeeping
3. Clients Rights and Asset Management through the Register of positions
4. Transaction management
5. Compliance and risk mitigation
6. Reporting and transparency: clients communication and support

1. Introduction and purposes of the Policy

At YouHodler Italy S.r.l. (the “Company” or “YHIT”), we are committed to delivering secure, state-of-the-art custody and administration services for Crypto assets *1 and related funds.

Our priority is to protect our clients’ assets from unauthorized access and to safeguard their ability to always access and exercise their rights over those assets. To achieve this, YHIT implements the most advanced and cutting-edge security technologies and protocols, ensuring the integrity, confidentiality, and availability of our clients’ holdings.

The Company understands the importance of maintaining trust in the crypto asset custody industry and is dedicated to upholding the highest standards of integrity and security and ensuring compliance with all applicable compliance obligations. For this reason YHIT drafted a YHIT Custody Policy that outlines the rules and procedures the Company has in place to ensure the safeguarding of Client assets and funds and to prevent any unauthorized use of client’s assets for personal gain.

Adding to what written above, this summary of the Custody Policy (the "Summary") provides an overview of the key aspects of the Custody Policy, ensuring that clients have a clear understanding of
how their assets are managed and protected: it contains a description of the services offered by YHIT to customers, outlines the processes and controls in place to ensure that client assets are protected from unauthorised use, accurately tracked, and operationally and legally segregated from YHIT’s own assets. It also details the rights of clients with respect to their assets and the procedures YHIT follows to manage, transfer, and report on these holdings. Customers of YHIT’s custody services are also referred to the terms and conditions governing YHIT’s provision of the custody services. YHIT recognises the critical role it plays as a custodian and is dedicated to maintaining a transparent relationship with clients.

2. Segregation of assets and safekeeping

YHIT adheres to stringent asset segregation practices to ensure that client crypto-assets are securely held and operationally separated from YHIT’s own assets. This segregation is fundamental to protecting client assets and maintaining transparency in custodial operations, ensuring transparency and effectively preventing any risk of misappropriation, confusion, unauthorized access, or misuse.

The Company generates both individual wallet addresses (“Hot Wallets”) and collective (omnibus) accounts (“Cold Storage”), depending on the type and purpose of the custody. Each client’s assets are managed within an omnibus account tied to the respective blockchain protocol but are tracked individually through YHIT’s internal ledger system. This system ensures that the integrity of each client’s holdings is preserved. In addition to operational segregation, YHIT employs advanced security measures, including multi-signature wallets, encryption, and regular audits, to safeguard assets. These measures are complemented by a robust operational framework that includes strict access controls, regular reconciliations, and continuous monitoring of all custodial activities.

In order to protect the blockchain infrastructure from cyber attacks, clients are not permitted to directly deposit assets to the omnibus accounts since a significant part of clients assets can be held there.

For further security reasons only the Company omnibus accounts are whitelisted on exchange accounts and within external custody providers operational systems: for these reasons YHIT implemented a specific system to standard access controls, and, adding to this, an employment of a multisignature (multisig) system as a critical layer of protection for its crypto-asset storage infrastructure. Additionally, strong password policies are enforced throughout the organization. All these combined measures (multisignature controls, multi-factor authentication, strict role-based access, and rigorous password enforcement) form a resilient security framework to safeguard the integrity, confidentiality, and availability of client assets.

3. Clients Rights and Asset Management through the Register of positions

The Custody Policy ensures that the recognition and protection of each client’s rights to their crypto-assets are prioritized.

Each client’s rights to their assets are reflected in a detailed register of positions maintained by YHIT.

This register records the specific holdings of each client, tracking all movements, including deposits, withdrawals, and transfers. The register is continuously updated to ensure it accurately represents the client’s holdings at any given time, providing a clear and transparent view of their asset positions.

This tool ensures that any movement affecting a client’s assets is promptly recorded and that each client’s ownership is clearly defined and respected: clients have full visibility into their asset holdings through the secure client portal, where they can view detailed reports of their positions, transaction history, and any relevant updates. The Company shall provide the client with their transactional history once a quarter and the statement shall include the assets held, the value of the assets and the balance, as well as the movements made during the period concerned.

4. Transaction management

YHIT developed and built a secure and efficient transaction management of its custody services.

All asset movements, including deposits, withdrawals, and transfers, are conducted with the highest levels of security and accuracy to ensure the integrity of client holdings. When a client initiates a transaction, whether it involves moving assets into or out of their custody account, the process is governed by strict internal controls: these controls include multi-level authorisation procedures, thorough verification of client instructions, and the use of secure communication channels to prevent unauthorised access or fraudulent activities.

Asset movements are recorded in real-time within YHIT’s internal ledger system, ensuring that the register of positions remains up-to-date and accurately reflects each client’s current holdings. This real-time tracking allows for prompt reconciliation and minimises the risk of discrepancies between client instructions and the actual movement of assets. All transactions are subject to ongoing monitoring and review to ensure compliance with regulatory requirements and internal policies.

5. Compliance and risk mitigation

YHIT operates within a robust compliance framework that aligns with the latest regulatory standards, including the MiCA. Compliance is central to all custody operations, ensuring that client assets are managed in accordance with both legal requirements and best industry practices.

YHIT’s risk management procedures are designed to identify, assess, and mitigate risks associated with the custody and administration of crypto-assets: the Company continuously monitors and assesses risks associated with custody services, particularly crypto asset custody.

Appropriate risk mitigation strategies are in place to address potential threats and vulnerabilities, and regular training and awareness programs focusing on cybersecurity and fraud are conducted for employees to enhance their knowledge of security practices.

To maintain high standards of compliance, YHIT implements regular audits to review and verify that all custody activities meet regulatory and policy requirements.

6. Reporting and transparency: clients communication and support

YHIT is committed to maintaining transparency in its custody operations by providing clients with comprehensive and timely reports on their crypto-asset holdings. These reports are designed to give clients clear insights into the status of their assets, including detailed information on account balances, transaction history, and any movements within their portfolios.

There is a secure online portal through which clients have access to view and download reports at any time. The portal provides real-time updates on asset positions, allowing clients to monitor their holdings and review past transactions with ease: this level of transparency ensures that clients are always informed about the state of their assets, fostering trust and confidence in the custodial services provided.

Reports are generated using secure systems that protect client data and maintain the confidentiality of all information.

To ensure that clients are well-informed and supported in all aspects of their crypto-asset custody experience, YHIT provides multiple channels for clients to reach out, including email (and the secure online portal described above in this Summary) ensuring that assistance is always readily available.

In addition to routine communications, YHIT offers dedicated support for any queries or issues that may arise: the customer support team is trained to handle a wide range of inquiries, from basic account management to more complex questions about custody operations and asset movements. For more specialised concerns, clients have access to expert support staff who can provide detailed explanations and guidance.

In any case the Company will not make any claims or exercise ownership rights over client assets without explicit authorization, and protects clients assets against any third party claims.

*1 Crypto-assets as defined by article 3.1.5 of the Regulation (EU) 2023/114, of the European Parliament and of the Council of 31
May 2023 on markets in crypto-assets and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives
2013/36/EU and (EU) 2019/1937.