Market Integrity

MEDRE is committed to upholding the highest standards of market integrity, ensuring fair and transparent trading of its tokens. In line with the Markets in Crypto-Assets Regulation (MiCA), we will implement measures to prevent market abuse and manipulation.

Key Measures to Ensure Market Integrity:

Prevention of Insider Dealing: We have established a clear policy prohibiting employees and associated persons from using confidential information to gain an unfair advantage in trading MEDRE tokens. This policy is included in the employment contracts of all employees in key positions, including executives, finance personnel, and members of the technology development team. These individuals have access to sensitive information, such as upcoming acquisitions, financial results, or technological developments, which could potentially be used for insider trading. Any violation of this policy will result in contract termination and may lead to legal action, financial penalties, and reporting to the relevant authorities.

Information Barriers: MEDRE maintains strict procedures to prevent the dissemination of inside information to unauthorized individuals. This includes physical security measures like storing sensitive documents in restricted access locations, as well as robust digital security protocols such as strong passwords, encryption, and data loss prevention tools. Clear communication guidelines prohibit discussing confidential matters in public or on non-secure channels. Access to confidential information is granted only on a “need-to-know” basis, and regular training reinforces the importance of information security for all employees. These measures create a secure environment where confidential information is protected and only accessible to authorized individuals, preventing insider trading and upholding market integrity.

Monitoring of Trading Activity: While MEDRE is not a Crypto-asset Service Provider (CASP) and does not directly handle trading activity, we are committed to maintaining market integrity and preventing market manipulation. We encourage responsible disclosure of any suspicious trading activity that could indicate market abuse.

MEDRE provides a confidential whistleblowing mechanism for reporting suspicious trading activity or potential market manipulation. Individuals can submit reports through a dedicated channel on our website or by contacting our compliance team directly, providing as much detail as possible. All reports are investigated confidentially, and if deemed credible, MEDRE may blacklist individuals involved, report the activity to authorities, or pursue legal action. More information about this can be found on page 5.2 under Security Measures within the Smart Contract.

Cooperation with Authorities: MEDRE recognizes the importance of collaborating with regulatory authorities to maintain the integrity of the crypto-asset market. We are committed to full cooperation with national competent authorities (NCAs) in their market abuse investigations. This includes:

• Prompt Response to Information Requests: We will respond promptly and comprehensively to any information requests from NCAs regarding MEDRE tokens, trading activity, or any suspected market abuse.
• Provision of Documentation: We will provide all necessary documentation, including trade records, order books, and know-your-customer (KYC) information, to assist NCAs in their investigations.
• Reporting of Suspicious Activity: We will proactively report any suspicious trading activity or potential market manipulation to the relevant authorities. This includes instances of suspected insider trading, wash trading, or other manipulative practices.
• Collaboration in Investigations: We will actively collaborate with NCAs in their investigations, providing access to relevant personnel and information as required.
• Compliance with Regulatory Directives: We will adhere to all directives and guidance issued by NCAs regarding market integrity and the prevention of market abuse.

MEDRE believes that a collaborative approach with regulatory authorities is essential for fostering a healthy and trustworthy crypto-asset market. We are dedicated to working with NCAs to ensure compliance with MiCA and uphold the highest standards of market integrity.