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A. Application

1. VASPs shall satisfy ESG disclosure requirements as set out in this Part V of this Company Rulebook.
2. During the licensing process, VARA will determine the ESG disclosure level required of each VASP, which shall be communicated to the VASP by VARA and required as a condition of the VASP’s Licence.
3. In making such determination, VARA may consider, but shall not be limited to, the following factors with respect to the VASP and its Group—
  a. the number of Staff members or other personnel engaged by the VASP;
  b. turnover and/or other financial information; and
  c. business models and VA Activities.
4. VASPs may choose at any time to comply with a higher ESG disclosure level than that set by VARA as a condition of its Licence.
5. To the extent possible, VASPs should maintain the same ESG standard across its Group. Notwithstanding the preceding provisions of this Rule V.A of this Company Rulebook, such standards should be set and maintained at the highest level of any jurisdiction which is applicable to a VASP’s Group, including in respect of the VASP’s activities in the Emirate.