Wallet Address & Whitelisting Change Policy

1. Policy Title: Wallet Address & Whitelisting Change Policy

2. Version: 1.0

3. Effective Date: 03/09/2025

4. Review Date: 03/09/2026

5. Policy Owner: Head of Procurement

6. Policy Sponsor: Director of Operations

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Please note, following a receipt of change request all subsequent transactions and smart contract payments will be paused, until such time as the change request is verified, proven legitimate and processed.

7. Purpose:

• To ensure the secure and verified update of wallet addresses, and whitelists were used, listed in vendor contracts after contract execution. This policy protects against unauthorized changes and potential fraud by enforcing a standardized identity verification process prior to approving any modification.

8. Scope:

• This policy applies to all vendors with active contracts who request to change the wallet address or withdrawal whitelists specified in their contract after it has been signed.

• Exclusions: This policy does not apply to the initial submission of wallet addresses during the contracting phase or to vendors whose contracts do not involve cryptocurrency payments.

9. Principles:

This policy is grounded in the principles of:

• Security – preventing unauthorized or fraudulent wallet address changes.

• Verification – ensuring only authorized representatives of the vendor can initiate and approve changes.

• Accountability – maintaining clear audit trails for all wallet address changes.

• Transparency – consistent communication and documentation of all changes.

10. Definitions:

• Wallet Address: Represents a blockchain wallet used for receiving payments.

• Vendor Whitelist: A list or approved addresses a vendor can withdraw funds to.

• KYC (Know Your Customer): A process of identity verification to confirm the legitimacy of the requestor. For more information, you can read the Intersect Due Diligence Policy.

• Authorized Representative: A person identified in the contract or via KYC who has legal authority to act on behalf of the vendor.

• Verification Call: A phone call conducted to confirm the identity and intent of the individual requesting the wallet address change.

11. Policy Statements:

• Vendors may request a wallet address or whitelist address change after contract execution through the defined process.

• Any request to update a wallet address or whitelist address must come directly from the authorised contract signatory or a representative with documented delegated authority.

• All wallet address change requests must be accompanied by a completed KYC via Sumsub.

• The KYC form must include a valid phone number of an authorized representative.

• A member of the Operational Services team will conduct a verification call to confirm the requestor’s identity and the change request.

• No wallet address changes or whitelist addresses will be accepted via email or messaging platforms without full verification.

• Changes will only be processed after successful verification and documentation.

• It is at Intersects discretion to process wallet address and whitelist address change requests, circumstances exist where this may not be operationally or technically possible.

• All wallet address and whitelist address change requests and confirmations will be logged and retained for audit purposes.

12. Roles and Responsibilities:

Vendor:

• Authorised contract signatory or a representative with documented delegated authority Initiates the wallet address or whitelist address change request via sending an email cc’ing in [email protected] and [email protected].

• Submits the completed KYC form including the authorized phone contact.

• Ensures availability for the verification call.

• Submits new wallet address using Intersects wallet request form.

Operations / Payments Team:

• Procurement sends the KYC form to the vendor upon request.

• Conducts the verification call.

• Confirms the identity of the authorized representative.

• Checks the new wallet address and/or whitelist addresses have been submitted via the google form and checked internally.

• Updates the wallet address and/or whitelist address in internal systems post-verification and relays to the operational services team for the vendor smart contract.

• Logs all communications and updates for audit records.

• If the call fails or the requestor cannot be verified:

• The change is rejected, and the vendors KYC/KYB contact(s) are notified.

• All records are stored securely for auditing.

13. Monitoring and Compliance:

• All wallet address changes will be monitored and logged.

• Periodic internal audits will verify adherence to this policy.

• Fraudulent or unverified requests will be reported and may lead to contract termination or legal action.

14. Review and Amendment:

• This policy will be reviewed annually or upon significant changes to vendor engagement processes, risk management protocols, or applicable regulations.

• Amendments require approval from the Policy Owner and the Policy Sponsor

15. Related Documents/References:

• Intersect Due Diligence Policy.