1. PURPOSE

1.1 This document sets out how Digital Capital Ltd safeguards customer funds in accordance with applicable laws and regulatory requirements.

1.2 It explains:

• how funds are protected

• how safeguarding operates in practice

• how risks are managed

• how safeguarding is governed

2. REGULATORY FRAMEWORK

2.1 Digital Capital Ltd safeguards customer funds in accordance with:

• Electronic Money Regulations 2011

• applicable FCA requirements

2.2 Safeguarding is a core regulatory obligation.

3. NATURE OF CUSTOMER FUNDS

3.1 Funds held by Digital Capital:

• are electronic money

• represent a claim on Digital Capital

3.2 These funds:

• are not deposits

• are not covered by FSCS

4. SAFEGUARDING PRINCIPLE

4.1 Customer funds must:

• be segregated from corporate funds

• be protected in insolvency

5. SAFEGUARDING METHOD

5.1 Digital Capital safeguards funds by:

• holding funds in segregated safeguarding accounts

6. SEGREGATION OF FUNDS

6.1 Customer funds are:

• separated from company funds

• not used for operational purposes

7. SAFEGUARDING ACCOUNTS

7.1 Safeguarding accounts are:

• held with authorised credit institutions

8. OWNERSHIP AND RESPONSIBILITY

8.1 Digital Capital retains full responsibility for safeguarding.

9. GOVERNANCE

9.1 Safeguarding is overseen by:

• senior management

• finance / safeguarding function

10. RISK MANAGEMENT

10.1 Safeguarding risks include:

• reconciliation errors

• operational failures

• banking dependency

11. INTERNAL CONTROLS

11.1 Controls include:

• segregation

• reconciliation

• monitoring

12. PARTNER MODEL

12.1 Partners do not:

• hold funds

• control safeguarding

13. TRANSPARENCY

13.1 Customers are informed that:

• funds are safeguarded

• not insured

14. LIMITATIONS

14.1 Safeguarding:

• is not equivalent to deposit protection

15. CONTACT

15.1 For safeguarding queries:

info@digi-capital.co.uk

16. OPERATIONAL SAFEGUARDING FRAMEWORK

16.1 Digital Capital operates a structured safeguarding framework designed to ensure that customer funds are identified, segregated, reconciled, monitored and protected on an ongoing basis.

16.2 The operational safeguarding framework is intended to ensure that:

• the amount of funds that should be safeguarded is accurately determined

• safeguarded funds are held in the correct accounts

• discrepancies are identified promptly

• exceptions are escalated and resolved without undue delay

• records remain sufficiently accurate to support customer fund protection

• management has visibility over safeguarding effectiveness and exceptions

16.3 Safeguarding is treated as a live operational control environment and not as a static legal concept.

17. SAFEGUARDING OPERATING MODEL

17.1 Digital Capital maintains an operating model under which:

• customer funds received in exchange for electronic money or otherwise subject to safeguarding requirements are identified through the firm’s systems and records

• those funds are held in designated safeguarding accounts

• safeguarding balances are compared against internal records through reconciliation processes

• any safeguarding discrepancies are escalated, investigated and resolved

• governance and management information support regular oversight of safeguarding effectiveness

17.2 The safeguarding operating model must be documented and kept under review.

17.3 The safeguarding model must remain consistent with:

• the firm’s product set

• payment flows

• card arrangements

• account structures

• banking arrangements

• geographic footprint

• operational dependencies

18. IDENTIFICATION OF RELEVANT FUNDS

18.1 Digital Capital identifies funds that are subject to safeguarding requirements through its internal books, records and transaction systems.

18.2 This includes funds which:

• have been received from or for a customer in connection with the issuance of electronic money

• remain owed to customers in connection with regulated services

• must be protected pending redemption, payment execution or other lawful disposition

18.3 The identification logic must be sufficiently robust to ensure that:

• customer liabilities are not understated

• corporate funds are not incorrectly treated as safeguarded funds

• relevant pending and settled flows are properly captured

• timing differences are understood and controlled

18.4 The firm must ensure that the basis on which relevant funds are identified is documented and consistently applied.

19. CUSTOMER FUND RECORDS

19.1 Digital Capital maintains books and records sufficient to determine:

• the amount owed to customers

• the balance that should be safeguarded

• the relationship between customer liabilities and safeguarded balances

19.2 Customer fund records must be:

• accurate

• complete

• current

• capable of supporting reconciliation and exception investigation

19.3 Record integrity is a critical component of safeguarding.

19.4 If record accuracy is in doubt, the matter must be treated as a safeguarding risk and escalated appropriately.

20. SAFEGUARDING ACCOUNTS — OPERATIONAL EXPECTATIONS

20.1 Safeguarding accounts must be clearly designated and distinguishable from Digital Capital’s own corporate or operating accounts.

20.2 The firm must maintain a clear internal record of:

• each safeguarding account

• the institution with which it is held

• its intended purpose

• associated operational dependencies

• authorised internal users and approval controls

20.3 Access to safeguarding accounts and associated banking operations must be appropriately restricted.

20.4 Any change to safeguarding account arrangements must be subject to governance review and controlled implementation.

21. SEGREGATION IN PRACTICE

21.1 Segregation is not satisfied solely by legal description; it must also be reflected in operational reality.

21.2 Digital Capital therefore operates controls intended to ensure that:

• customer funds are not mixed with general operating funds other than to the limited extent permitted by the safeguarding framework and timing mechanics of payments operations

• transfers into and out of safeguarding accounts are controlled and traceable

• operational personnel understand the distinction between safeguarded funds and firm funds

• finance, operations and compliance are aligned on the treatment of balances and exceptions

21.3 Any actual or suspected failure of segregation must be treated as a serious safeguarding incident.

22. RECONCILIATION OBJECTIVE

22.1 The objective of safeguarding reconciliation is to verify that the amount held in safeguarding accounts appropriately matches the amount that ought to be safeguarded for customers.

22.2 Reconciliation exists to:

• detect under-safeguarding

• detect over-safeguarding

• identify timing mismatches and record errors

• support prompt remediation

• provide management assurance that safeguarding is functioning effectively

22.3 Reconciliation is one of the most important operational safeguards within the safeguarding framework.

23. RECONCILIATION FREQUENCY

23.1 Digital Capital performs safeguarding reconciliations on a regular basis consistent with regulatory requirements, the scale of the business, volume of customer funds and operational risk profile.

23.2 As a minimum expectation for a mature control environment, safeguarding should be treated as a daily operational control where relevant balances and flows justify it.

23.3 The reconciliation cycle must be sufficiently frequent to ensure that:

• discrepancies are identified promptly

• management does not rely on stale information

• operational issues do not remain undetected for prolonged periods

24. RECONCILIATION DATA SOURCES

24.1 Safeguarding reconciliation may involve comparison between:

• internal customer liability records

• ledger balances

• safeguarding account balances

• pending movement records

• settlement or timing adjustment records

24.2 The firm must understand the origin, quality and timing of each data source used in reconciliation.

24.3 Where reconciliation depends on extracts, uploads, interfaces or reports, those dependencies must be controlled and monitored.

25. RECONCILIATION METHODOLOGY

25.1 The reconciliation methodology must be documented in sufficient detail to explain:

• what balances are included

• what balances are excluded

• how timing differences are treated

• how exceptions are identified

• who performs the reconciliation

• who reviews it

• how it is evidenced

25.2 The methodology must be consistent with the firm’s actual product and transaction flows.

25.3 If the product set or payment flow logic changes, the reconciliation methodology must be reviewed accordingly.

26. RECONCILIATION PREPARATION

26.1 Before each reconciliation, the relevant data inputs should be checked for reasonableness and completeness.

26.2 This may include:

• confirming ledger integrity

• confirming availability of banking balances

• confirming completion of relevant processing cycles

• identifying known system issues that may affect the comparison

26.3 Material uncertainty affecting reconciliation accuracy must be escalated.

27. PERFORMANCE OF RECONCILIATION

27.1 The reconciliation must be performed by appropriately trained personnel using the approved methodology.

27.2 The reconciliation process must produce a clear comparison between:

• the required safeguarded amount

• the actual safeguarded amount

• any difference or break identified

27.3 The output must be recorded in a manner that is auditable and retrievable.

28. REVIEW OF RECONCILIATION

28.1 Reconciliations must be subject to review by an appropriately authorised reviewer.

28.2 The reviewer should assess:

• whether the reconciliation appears complete

• whether unusual movements or unexplained items exist

• whether any differences have been identified

• whether the explanation of differences is reasonable

• whether escalation is required

28.3 Review evidence must be retained.

29. SAFEGUARDING BREAKS

29.1 A safeguarding break is any discrepancy between the amount that should be safeguarded and the amount actually safeguarded, or any other material failure in the safeguarding control process.

29.2 Safeguarding breaks may arise from:

• reconciliation error

• ledger error

• delayed transfer

• banking issue

• operational process failure

• system issue

• data integrity weakness

• misclassification of balances

• manual error

29.3 A safeguarding break may indicate:

• under-safeguarding

• over-safeguarding

• uncertainty in records

• unresolved timing mismatch

• process weakness requiring remediation

30. UNDER-SAFEGUARDING

30.1 Under-safeguarding arises where the amount held in safeguarding accounts is less than the amount that should be safeguarded.

30.2 Under-safeguarding is treated as a serious matter because it may indicate that customer funds are not fully protected in the manner required.

30.3 Any under-safeguarding position must be escalated promptly and addressed with urgency.

30.4 The firm must document:

• the amount of the break

• the cause or suspected cause

• when it arose or was identified

• interim actions taken

• final resolution steps

31. OVER-SAFEGUARDING

31.1 Over-safeguarding arises where the amount held in safeguarding accounts exceeds the amount that should be safeguarded.

31.2 While generally less severe than under-safeguarding from a customer protection perspective, over-safeguarding may still indicate:

• record inaccuracy

• process weakness

• misclassification

• inefficient liquidity management

• unresolved operational error

31.3 Over-safeguarding must therefore also be investigated and resolved.

32. TIMING DIFFERENCES

32.1 Some reconciliation differences may arise due to timing differences between systems, settlement cycles, banking movements or payment processing cut-offs.

32.2 Timing differences must not be assumed to be acceptable merely because they are common.

32.3 The firm must maintain a documented basis for distinguishing:

• acceptable and understood timing differences

• unexplained or suspicious discrepancies

• breaks requiring escalation or remediation

32.4 Ageing of timing differences must be monitored.

33. BREAK LOG

33.1 Digital Capital maintains a safeguarding break log or equivalent exception register.

33.2 The break log should record, at minimum:

• date identified

• reference ID

• amount

• type of break

• root cause category

• owner

• current status

• escalation status

• target resolution date

• actual resolution date

• control remediation required, if any

33.3 The break log must support management oversight and auditability.

34. BREAK INVESTIGATION

34.1 Each safeguarding break must be investigated to determine:

• what happened

• how material it is

• whether customer funds were or may have been exposed

• whether the issue is isolated or systemic

• whether an interim control is required

• whether a regulatory or governance escalation is required

34.2 Investigations must be documented.

34.3 Repeated similar breaks must trigger root cause analysis and control review.

35. ESCALATION OF SAFEGUARDING BREAKS

35.1 Safeguarding breaks must be escalated according to severity and nature.

35.2 Escalation criteria should take into account:

• amount of the discrepancy

• duration of the discrepancy

• whether the break indicates under-safeguarding

• whether customer protection may have been compromised

• whether the cause is unknown

• whether the issue is recurring

• whether a system or third-party dependency is implicated

35.3 Escalation may include:

• finance / safeguarding operations

• compliance

• risk

• senior management

• legal or regulatory engagement where required

36. INTERIM ACTIONS

36.1 Where a safeguarding discrepancy or control failure is identified, Digital Capital may take interim actions to reduce risk.

36.2 Interim actions may include:

• immediate funding or transfer action

• additional reconciliations

• temporary manual controls

• increased review frequency

• transaction or process restrictions

• system workarounds pending permanent remediation

36.3 Interim actions must be documented and reviewed.

37. RESOLUTION OF BREAKS

37.1 A safeguarding break should only be treated as resolved when:

• the discrepancy is corrected

• the cause is understood to an appropriate level

• any required remediation has been identified

• evidence of resolution is retained

• any necessary escalation or reporting has been completed

37.2 Closure of a break without adequate explanation is not acceptable.

38.ROOT CAUSE ANALYSIS

38.1 Significant or recurring safeguarding breaks must undergo root cause analysis.

38.2 Root cause analysis should assess whether the break arose from:

• system design weakness

• process gap

• human error

• inadequate review

• incomplete records

• third-party dependency

• training deficiency

• poor change implementation

38.3 Root cause analysis must result in:

• specific remediation actions

• assigned owners

• timelines

• follow-up validation where appropriate

39. SAFEGUARDING MANAGEMENT INFORMATION (MI)

39.1 Digital Capital maintains safeguarding MI to support governance and oversight.

39.2 Safeguarding MI may include:

• total safeguarded balances

• reconciliation completion status

• number and value of breaks

• ageing of unresolved breaks

• under-safeguarding incidents

• repeat issues by cause

• time to resolve safeguarding discrepancies

• unresolved control actions

• dependency or banking issues affecting safeguarding

39.3 MI should be sufficiently clear to support challenge by management and, where relevant, the Board or equivalent governance body.

40. DAILY AND PERIODIC REPORTING

40.1 Daily or frequent operational reporting may be required for safeguarding teams or control owners.

40.2 Periodic management reporting should summarise:

• current safeguarding position

• open issues

• trend analysis

• remediation progress

• material incidents or near misses

40.3 Reporting should be proportionate to the scale and complexity of operations but sufficiently robust to support governance.

41. EVIDENCE AND RECORD RETENTION

41.1 Digital Capital retains records sufficient to evidence the operation of the safeguarding framework.

41.2 This includes, where relevant:

• reconciliation outputs

• review sign-offs

• break logs

• investigation records

• funding adjustments

• management reports

• escalation records

• remediation actions

• governance minutes or issue papers

41.3 Safeguarding evidence must be retrievable in a form suitable for:

• internal review

• audit

• bank diligence

• FCA requests

42. ACCESS CONTROLS AND SEGREGATION OF DUTIES

42.1 Safeguarding operations must be supported by appropriate segregation of duties.

42.2 This includes, where practicable:

• separation between preparation and review of reconciliations

• controlled access to safeguarding bank account operations

• restricted approval rights for funding movements

• controlled exception handling

42.3 Access permissions should be reviewed periodically.

43. SYSTEM AND THIRD-PARTY DEPENDENCIES

43.1 The safeguarding operating model may depend on systems, banks or service providers.

43.2 Digital Capital must understand and monitor such dependencies.

43.3 Where a third-party issue affects safeguarding, the matter must be treated with urgency and tracked as a safeguarding-related risk or incident where appropriate.

44. TRAINING AND COMPETENCE

44.1 Staff involved in safeguarding operations must be appropriately trained.

44.2 Training should cover:

• safeguarding principles

• reconciliation methodology

• identification of breaks

• escalation requirements

• documentation standards

• the distinction between customer funds and firm funds

44.3 Competence should be refreshed periodically and when material process changes occur.

45. REVIEW OF SAFEGUARDING OPERATIONS

45.1 The safeguarding operating model must be reviewed periodically to confirm that it remains appropriate.

45.2 Review triggers may include:

• product changes

• new payment flows

• new banking arrangements

• incidents or repeated breaks

• regulatory developments

• audit or compliance findings

45.3 Any material change to safeguarding operations must be subject to change governance and documented update.

46. INSOLVENCY PROTECTION — GENERAL POSITION

46.1 The purpose of safeguarding is to improve protection of customer funds if Digital Capital Ltd were to become insolvent.

46.2 Safeguarding is intended to ensure that relevant customer funds are protected from claims by the firm’s general creditors and are available to be returned to customers in accordance with applicable law and insolvency processes.

46.3 Safeguarding is a regulatory protection mechanism. It is not a guarantee that funds will be returned immediately, without process, delay, cost or legal complexity in every circumstance.

46.4 The firm must therefore ensure that its public and internal safeguarding descriptions are accurate, balanced and do not overstate the protection afforded by safeguarding.

47. INSOLVENCY SCENARIO — OPERATIONAL EXPECTATION

47.1 If Digital Capital were to fail or enter an insolvency-related process, customer funds that have been safeguarded should be distinguishable from the firm’s own funds through the safeguarding structure, books and records, and associated reconciliations.

47.2 In such a scenario, the return of safeguarded funds would ordinarily depend on matters including:

• the accuracy and completeness of the firm’s books and records

• the quality of segregation and reconciliation controls

• the availability of safeguarding account balances

• the speed and effectiveness of insolvency administration processes

• the ability to identify customer entitlements

• any legal, practical or operational issues arising at the point of failure

47.3 Digital Capital must not assume that insolvency protection is purely a legal drafting issue. It is heavily dependent on operational readiness and record integrity.

48. ROLE OF BOOKS AND RECORDS IN INSOLVENCY

48.1 The quality of the firm’s books and records is a critical safeguarding control because, in an insolvency scenario, those records may be relied upon to determine:

• which funds are customer funds

• how much is owed to each customer

• whether a safeguarding shortfall or surplus exists

• whether customer liabilities can be matched to safeguarded balances

48.2 Poor records, unresolved breaks, inconsistent classifications or weak data lineage may materially increase the complexity, delay and cost of returning funds.

48.3 For this reason, Digital Capital treats books and records as a core safeguarding issue rather than merely an accounting or operational matter.

49. INSOLVENCY PRACTITIONER AND DISTRIBUTION PROCESS

49.1 In an insolvency or administration scenario, an insolvency practitioner or similar officeholder may be appointed.

49.2 That person may be involved in:

• identifying safeguarded funds

• reconciling entitlements

• managing distribution of available safeguarded amounts

• dealing with operational issues, claims and records

49.3 The insolvency process may therefore involve administrative work, forensic review, legal interpretation and customer balance verification.

49.4 Digital Capital must ensure that its public disclosure accurately reflects that safeguarding improves customer protection but does not eliminate the practical realities of insolvency administration.

50. COSTS AND DEDUCTIONS

50.1 In certain circumstances, costs associated with the return of safeguarded funds may be incurred in connection with the insolvency process or the operation of the safeguarding framework.

50.2 Where permitted by law, such costs may affect the funds ultimately returned or the speed at which they are returned.

50.3 Digital Capital must ensure that customer-facing safeguarding disclosure does not imply that no costs, deductions, delays or process frictions could ever arise.

50.4 This point is particularly important because inaccurate statements about “full protection” or “guaranteed immediate return” may create regulatory and conduct risk.

51. LIMITATIONS OF SAFEGUARDING

51.1 Safeguarding does not provide the same protection as a bank deposit protection regime.

51.2 In particular, safeguarded funds:

• are not deposits

• are not protected by the Financial Services Compensation Scheme (FSCS) solely by reason of being safeguarded e-money or payment funds

• may still be affected by insolvency process delays, records issues or related costs

51.3 Safeguarding also does not remove all operational risks. Its effectiveness depends on:

• correct identification of relevant funds

• robust segregation

• accurate reconciliation

• timely issue escalation

• effective governance and oversight

51.4 Digital Capital must therefore present safeguarding as a strong regulatory protection mechanism, but not as an absolute or insurance-like promise.

52. CUSTOMER DISCLOSURE PRINCIPLES

52.1 Customer-facing safeguarding disclosure must be:

• clear

• accurate

• balanced

• not misleading

• consistent across all public materials

52.2 Customer disclosure should explain, at a minimum:

• that relevant funds are safeguarded in accordance with applicable rules

• that safeguarded funds are not deposits

• that safeguarded funds are not protected by the FSCS solely because they are safeguarded

• that safeguarding is intended to protect customer funds if the firm fails

• that insolvency processes may still involve administrative delay or costs

52.3 Customer-facing disclosure must avoid:

• overstating protection

• implying a guarantee of immediate access

• using language that suggests safeguarding is equivalent to deposit insurance

• using vague promotional language that weakens legal accuracy

53. CONSISTENCY OF PUBLIC DISCLOSURE

53.1 Safeguarding-related statements must be consistent across:

• the safeguarding information page

• account terms

• website disclosures

• FAQs

• onboarding flows

• customer support scripts, where relevant

• complaint responses, where relevant

53.2 Inconsistency between documents may create:

• customer confusion

• conduct risk

• FCA scrutiny

• bank diligence concerns

• legal interpretation risk

53.3 Digital Capital must therefore periodically review safeguarding language across all external materials.

54. GOVERNANCE OF SAFEGUARDING

54.1 Safeguarding must be subject to formal governance and oversight.

54.2 Governance should ensure that safeguarding is not treated as a narrow finance process only, but as a cross-functional control environment involving:

• finance / safeguarding operations

• compliance

• risk

• senior management

• operations and systems stakeholders where relevant

54.3 Governance must be sufficiently robust to ensure that material safeguarding risks, issues and trends are visible to the appropriate management level.

55. SENIOR MANAGEMENT OVERSIGHT

55.1 Senior management is responsible for ensuring that the firm maintains an effective safeguarding framework.

55.2 Senior management responsibilities include:

• ensuring adequate resourcing and capability

• reviewing material safeguarding MI

• ensuring that significant breaks or weaknesses are escalated

• ensuring remediation is tracked and completed

• ensuring that growth, product changes or new Partner arrangements do not undermine safeguarding integrity

55.3 Senior management must also ensure that safeguarding is properly reflected in the firm’s wider governance, risk and supervisory readiness model.

56. MANAGEMENT INFORMATION AND REPORTING

56.1 Safeguarding MI must be reported periodically to the appropriate governance level.

56.2 Reporting should include, where relevant:

• current safeguarded balance

• reconciliation completion status

• open breaks and ageing

• under-safeguarding incidents

• over-safeguarding trends

• repeat issues and root causes

• unresolved remediation actions

• banking or dependency issues affecting safeguarding

• any incidents requiring heightened attention

56.3 MI should support meaningful challenge, not merely summary reporting.

56.4 If safeguarding MI is incomplete, delayed or unreliable, that itself should be treated as a control concern.

57. ESCALATION TO GOVERNANCE FORUMS

57.1 Material safeguarding issues must be escalated to the appropriate governance forum or senior management channel.

57.2 Escalation should occur where there is, for example:

• under-safeguarding

• a significant unresolved discrepancy

• repeated or systemic reconciliation issues

• unresolved dependency failure affecting safeguarding

• uncertainty over records or entitlement calculations

• a material governance, process or systems weakness

• any safeguarding issue with potential regulatory significance

57.3 Escalation records must be retained.

58. INTERACTION WITH RISK, INCIDENT AND AUDIT FRAMEWORKS

58.1 Safeguarding does not operate in isolation.

58.2 Safeguarding issues may also fall within the scope of:

• the Risk Management Framework

• the Incident & Breach Management Policy

• the Compliance Monitoring Plan

• the Internal Audit Framework

• the Board MI and governance reporting framework

58.3 Material safeguarding matters should therefore be reflected consistently across those frameworks where relevant.

58.4 This is important to ensure that safeguarding is treated as an enterprise control issue and not siloed within one function.

59. INTERACTION WITH PARTNER MODEL

59.1 In Digital Capital’s business model, Partners do not hold or control safeguarded funds.

59.2 Partners do not control safeguarding account arrangements, safeguarding reconciliations, or safeguarding governance decisions.

59.3 However, the business model, customer volumes, onboarding patterns and segmentation associated with Partners may affect the scale and operational profile of safeguarding.

59.4 For this reason, changes in Partner arrangements, customer cohorts, transaction patterns or product usage should be assessed for potential safeguarding impact.

60. BANKING AND DEPENDENCY RISK

60.1 Safeguarding depends in part on the operational reliability of banking and related infrastructure arrangements.

60.2 Digital Capital must therefore monitor and manage risks relating to:

• banking dependencies

• account availability

• operational restrictions

• delays in account operations

• concentration risk where relevant

• changes in banking arrangements

60.3 Material dependency issues affecting safeguarding must be escalated and reflected in management reporting where appropriate.

61. CHANGE MANAGEMENT

61.1 Material changes to products, payment flows, banking structure, ledger logic, reconciliation logic, system architecture or Partner operating model must be assessed for safeguarding impact before implementation.

61.2 Change approval should consider:

• whether customer funds are identified correctly

• whether reconciliation logic remains accurate

• whether new timing differences are introduced

• whether reporting or evidence outputs are affected

• whether governance or review controls require adjustment

61.3 A material change should not be treated as complete until safeguarding impact has been considered and documented.

62. INTERNAL REVIEW, MONITORING AND ASSURANCE

62.1 Safeguarding must be subject to periodic internal review.

62.2 Such review may occur through:

• first-line control review

• compliance monitoring

• risk review

• internal audit

• thematic or issue-based review

62.3 Review activity should assess not only whether safeguarding documentation exists, but whether:

• reconciliations are occurring as required

• breaks are being managed appropriately

• MI is reliable

• records are accurate

• remediation actions are effective

62.4 Findings should be documented and tracked.

63. TRAINING, AWARENESS AND CONTROL CULTURE

63.1 Safeguarding effectiveness depends not only on process, but also on understanding and control culture.

63.2 Staff relevant to safeguarding must understand:

• why safeguarding matters

• how customer funds differ from firm funds

• how reconciliation works

• when discrepancies must be escalated

• what constitutes a serious safeguarding issue

• how customer-facing descriptions must remain accurate and balanced

63.3 The firm should promote a control culture in which safeguarding issues are raised early and not minimised.

64. CUSTOMER COMMUNICATION IN THE EVENT OF ISSUES

64.1 Where a safeguarding-related issue has actual or potential customer impact, Digital Capital must consider whether customer communication is required, taking into account:

• legal obligations

• regulatory expectations

• customer fairness

• the need for accuracy and consistency

• the need not to mislead or overstate the issue

64.2 Communications should be coordinated with compliance, legal and senior management where appropriate.

64.3 The firm must avoid speculative or incomplete customer messaging that could create further confusion or conduct risk.

65. DOCUMENTATION AND RETENTION

65.1 Digital Capital retains safeguarding-related documentation and evidence in accordance with legal, regulatory and operational requirements.

65.2 Retained documentation may include:

• safeguarding methodology documents

• reconciliation procedures

• reconciliation outputs

• break logs

• review and sign-off records

• MI packs

• incident or issue records

• remediation records

• governance papers

• change assessments affecting safeguarding

65.3 Such records must be sufficiently organised to support:

• internal assurance

• regulatory requests

• bank diligence

• audit review

• insolvency-readiness considerations

66. REVIEW OF THIS DOCUMENT

66.1 This safeguarding document must be reviewed periodically and whenever a material change occurs in:

• regulation

• safeguarding methodology

• products or services

• payment flows

• banking arrangements

• Partner model

• internal systems or records

• control incidents or audit findings

66.2 Updates must be version controlled and approved through appropriate governance channels.

67. FINAL POSITIONING

67.1 Digital Capital Ltd safeguards relevant customer funds in accordance with applicable legal and regulatory requirements.

67.2 Safeguarding is supported not only by legal structure, but by:

• operational segregation

• reconciliation

• issue escalation

• governance oversight

• management information

• evidence and record integrity

67.3 The effectiveness of safeguarding depends on the strength of the firm’s full operating model, and Digital Capital therefore treats safeguarding as a core control priority across legal, operational, governance and supervisory dimensions.