Holyheld Non-discriminatory Commercial Policy

Last Update: 19.12.2025

1. This Summary provides a clear and comprehensive overview of the Non-discriminatory Commercial Policy of UAB Holyheld Financial (the “Company”). The Company is dedicated to delivering services and products of exceptional quality. The company's goal is to ensure that every Client understands how the Company ensures fair, equal, and transparent access to its services, pricing, and commercial terms.

2. Purpose and Regulatory Alignment

2.1. The Company is committed to treating all Clients fairly and without discrimination. The purpose of the Non-Discriminatory Commercial Policy is to ensure that:

  • 2.1.1. access to the Company’s services is provided on objective, transparent, and proportionate criteria;
  • 2.1.2. Clients in comparable situations are treated equally;
  • 2.1.3. pricing, fees, and commercial terms are applied consistently;
  • 2.1.4. any differentiation between Clients is objectively justified and documented;
  • 2.1.5. the Company complies with applicable EU and Lithuanian legal and regulatory requirements, including MiCA and consumer protection rules.

3. Scope of Application

3.1. The Policy applies to:

  • 3.1.1. all natural and legal persons using or seeking to use the Company’s crypto-asset services;
  • 3.1.2. all commercial interactions, including onboarding, access to services, pricing, fees, incentives, and commercial conditions;
  • 3.1.3. all employees and decision-makers involved in commercial, pricing, marketing, and client-facing activities.

4. Principle of Equal Treatment

4.1. The Company applies a principle of equal treatment to all Clients.

4.2. This means that:

  • 4.2.1. Clients in similar circumstances are offered the same services on the same terms;
  • 4.2.2. no Client is favoured or disadvantaged without an objective and legitimate reason;
  • 4.2.3. decisions are based on predefined criteria rather than subjective judgment.

5. Permissible Differentiation

5.1. Differences in treatment may occur only where they are objectively justified. Such differentiation may be based on, for example:

  • 5.1.1. the type of service requested;
  • 5.1.2. transaction volumes or usage levels;
  • 5.1.3. risk-based considerations (including AML/CTF, fraud prevention, or sanctions compliance);
  • 5.1.4. regulatory or legal requirements;
  • 5.1.5. operational or technical constraints.

5.2. Any differentiated treatment must be:

  • 5.2.1. proportionate;
  • 5.2.2. documented;
  • 5.2.3. consistent with internal policies and Applicable Legal Regulations.

6. Prohibited Discrimination

6.1. The Company does not tolerate discrimination based on personal or arbitrary characteristics.

6.2. In particular, the Company does not discriminate on the basis of:

  • 6.2.1. nationality, ethnicity, race, or origin;
  • 6.2.2. gender, age, disability, or health status;
  • 6.2.3. political opinions, religious or philosophical beliefs;
  • 6.2.4. any other protected characteristic under applicable law.

7. Pricing and Commercial Terms

7.1. Pricing, fees, and other commercial conditions:

  • 7.1.1. are defined in advance using transparent methodologies;
  • 7.1.2. are applied consistently to Clients in comparable situations;
  • 7.1.3. are disclosed clearly to Clients prior to the provision of services;
  • 7.1.4. may vary only where objective criteria justify such variation.

7.2. Any promotional offers, discounts, or incentives are applied according to predefined and documented rules. Applicable fees are available at Holyheld Fees, Holyheld Rewards, and Holyheld Cashback Rewards.

8. Governance and Oversight

8.1. The Company ensures effective oversight of non-discriminatory commercial practices through:

  • 8.1.1. Management Board approval of the Non-Discriminatory Commercial Policy;
  • 8.1.2. ongoing monitoring by Compliance and Risk functions;
  • 8.1.3. internal controls and reviews of pricing and commercial decisions;
  • 8.1.4. escalation and remediation mechanisms where deviations are identified.

9. Transparency and Client Communication

9.1. The Company is committed to clear and transparent communication with Clients.

9.2. Clients are informed about:

  • 9.2.1. applicable fees and charges;
  • 9.2.2. key commercial terms and conditions;
  • 9.2.3. reasons for any material decisions affecting access to services, where permitted by law.

9.3. Information is provided in clear and understandable language.

10. Complaints and Escalation

10.1. Clients who believe they have been treated unfairly or in a discriminatory manner may submit a complaint under the Company’s Complaints Handling framework.

10.2. Complaints:

  • 10.2.1. are handled free of charge;
  • 10.2.2. are investigated impartially;
  • 10.2.3. are resolved within defined regulatory timelines;
  • 10.2.4. may be escalated to supervisory or consumer protection authorities where applicable.

10.3. Details on how to submit a complaint are available in the Complaints Handling Policy.

11. Continuous Improvement

11.1. The Company regularly reviews its commercial practices to:

  • 11.1.1. identify potential inconsistencies or risks of discriminatory treatment;
  • 11.1.2. improve transparency and fairness;
  • 11.1.3. ensure ongoing compliance with evolving regulatory expectations.

12. Further Information

12.1. For further information, Clients may contact the Company via official support channels in Holyheld web or mobile application, or via email support@holyheld.com.