Disclosure Statements
1. Introduction
1.1. Welcome to Bondi Technology Inc. (“Bondi”, “we”, “us”, or “our”). We are a technology company providing a platform that enables the tokenization of existing, publicly traded bonds into digital assets known as "Bond Tokens."
1.2. Bondi is a company domiciled in the Republic of Panama and operates the software platform (frontend, backend, and smart contracts). Bond Tokens are issued by Ensuro Re Ltd. acting in respect of its segregated account designated "Bondi Finance" established under Bermuda law (the "Cell"). Ensuro Re Ltd. holds a Class F Digital Asset Business (DAB) license and a Class IIGB (Innovative Insurer General Business) insurance license, both issued by the Bermuda Monetary Authority. The legal framework for digital assets continues to evolve. Platform access and use are governed by our Terms of Service and applicable laws of Panama, while matters relating to the issuance, custody, and administration of Bond Tokens by Ensuro Re Ltd. acting in respect of the Cell are subject to applicable Bermuda law and regulation.
1.3. This Disclosure Statement provides essential information about Bondi Finance and our platform for all users and participants (“you” or “your”).
1.4. Please read this Statement carefully. A glossary of defined terms is provided at the end of this Statement.
2. Our Platform
2.1. Bondi Finance operates a smart-contract-based platform on the Ethereum, Base, Plume, and Mantle blockchains. The platform facilitates the creation (minting) and management of Bond Tokens, which represent a fractional economic interest in real-world, underlying corporate bonds.
2.2. Capital Providers deposit funds (typically stablecoins like USD stablecoin) to mint Bond Tokens corresponding to a specific underlying bond.
2.3. Holders of Bond Tokens are entitled to receive periodic payments equivalent to the coupon payments of the underlying bond and the principal upon its maturity, subject to the fees and risks outlined in our legal documentation. Such payments flow from the Cell through Ensuro Re Ltd. into Bondi's non-custodial distribution smart contracts, which disburse amounts to verified token holder wallets on a pro-rata basis, net of applicable fees. Bondi does not hold or custody funds at any point in this process.
2.4. The underlying bond assets are acquired and held to the credit of the Cell and identified in the Issuer’s records by Bond Token Line. Each Bond Token Line is intended to be a separate class of limited-recourse obligations of Ensuro Re Ltd. acting in respect of the Cell, with recourse limited to the Line Assets linked to that Bond Token Line. A single Bond Token Line may be offered in more than one Series, successive funding rounds of the same Bond Token, each with its own target raise amount and funding deadline. All Series of a Line share the same Bond Token, the same Line Assets, and the same pool of recourse; Series are not segregated from one another.
2.5. Bondi Technology Inc. does not issue Bond Tokens or hold underlying assets. Bondi provides and maintains the technology through which Users interact with the smart contracts administered under authorization from the Issuer. To mint or hold Bond Tokens, you may be required to review and accept the Issuer's Governing Instrument, which governs your rights as a holder and includes dispute-resolution procedures under Bermuda law. You also accept the Bond Token Terms Acceptance together with Bondi's other published legal documents when completing KYC.
3. Disclaimer
3.1. Except as expressly provided in a written agreement between you and Bondi, we disclaim and exclude, to the fullest extent permitted by applicable law, all liability for any losses or damages arising from your use of the Platform.
3.2. Bondi does not provide investment, legal, or tax advice. We make no recommendation as to the suitability, legality, or appropriateness of any Bond Token or transaction. You should seek independent advice from qualified professionals before participating in our platform.
4. Material Risks
The Bondi Finance platform involves significant risks. By participating, you confirm that you understand and accept the following material risks, which may result in partial or total loss of capital.
A. Capital and Financial Risks
4.1. Market Risk: The value of Bond Tokens can fluctuate due to changes in interest rates, market sentiment, inflation, and general economic conditions that affect the price of the underlying bonds.
4.2. Credit & Issuer Risk: The value and performance of Bond Tokens are directly linked to the creditworthiness of the issuer of the underlying bond. In the event of an issuer default, you could lose your entire principal and any accrued interest. Bondi is not responsible for the solvency or performance of any bond issuer.
4.16. Default, Passive Holdership, and Absence of Bondholder Rights: Upon a default, restructuring, distressed exchange, refinancing, or analogous event affecting an underlying Bond, the Issuer's policy in respect of the Cell is one of passive holdership. The Issuer will not exercise, and you should not expect the exercise of, any bondholder rights, including rights to vote on or consent to restructurings, to accelerate, to join or form creditor or bondholder committees, to accede to workout or refinancing arrangements, or to direct any trustee or agent in respect of the Bond. Collective decision-making mechanisms that exist at the level of the underlying Bond (for example, a bond trustee acting on the direction of a specified majority of holders of record) operate at the level of the holder of record, which is the custody arrangement holding the Bond for the Cell, and not at the level of Token Holders. You will have no direct say in any such process and may be bound by its outcome. The Issuer will distribute to you, pro rata and net of fees, only amounts actually received to the credit of the Cell in respect of the Bond, if and when received. You acknowledge that (i) your entitlement is solely to amounts actually received to the credit of the Cell; (ii) you hold a contractual economic entitlement and not direct title to, or the rights of a holder of, the underlying Bond; (iii) a defaulted Bond may have limited or no secondary market liquidity, such that early-redemption requests through the Redemption Vault may fail to execute in a timely manner or at all; and (iv) recovery on a defaulted Bond may be partial, may be delayed for an extended period, or may not occur, and may result in total loss.
4.3. Bond Token-Specific Risks: Bond Tokens:
- May lose all value due to issuer default, protocol failure, or adverse market events.
- Are not legal tender and are not insured by any government authority.
- Are not protected by deposit insurance.
- Do not confer any equity or voting rights in Bondi Technology Inc.
- May be subject to taxation, depending on your jurisdiction.
- Constitute limited-recourse obligations of Ensuro Re Ltd. acting in respect of the Cell. Your recourse is limited exclusively to the Line Assets linked to your Bond Token Line, and not to any other Line Assets. Although the segregated-accounts regime and Line-specific accounting records are designed to support bankruptcy remoteness and asset linkage, their effectiveness may be impacted by applicable law, court orders, regulatory actions, fraud, misappropriation, operational error, commingling, or extraordinary intervention, and courts in all jurisdictions may not give effect to segregation or contractual limited-recourse provisions in all circumstances.
4.3A. Inter-Line and Basket Risk: Multiple Bond Token Lines are issued through the same segregated account (the Cell). The assets of each Bond Token Line are intended, by contract and by the Cell's books and records, to be available only to the holders of that Line. This inter-Line segregation is established through the Issuer's Governing Instrument and Ensuro's books and records; it is not separate statutory segregation for each Bond Token Line. While the Segregated Accounts Companies Act 2000 segregates the Cell as a whole from the general account and other segregated accounts of the Issuer, it may not, of its own force, segregate one Bond Token Line from another within the same Cell. You acknowledge that Lines are contractual divisions within one statutory segregated account, not separate statutory accounts. In the event of insolvency of the Cell, third-party claims against the Cell, fraud, operational error, or commingling, a court may not give effect to inter-Line segregation, and the assets attributable to your Bond Token Line could be exposed to the liabilities of another Bond Token Line. Line-specific limited recourse remains subject to valid security interests, preferential claims, receivership costs and other mandatory rights arising under applicable law. Where a Line has been offered in more than one Series, all Series of that Line are backed by the same pool of underlying assets and share a single pool of recourse; there is no segregation between Series of the same Line. Where Bond Tokens are backed by a Basket, holders have a pro rata interest in the pooled Basket as a whole and not in any individual bond; a default, loss, or restructuring affecting any single bond in the Basket will affect all holders of that Bond Token Line pro rata.
4.3B. Vault Share and Third-Party Protocol Risk: The Platform offers optional vaults (the Reinvestment Vault and the Redemption Vault) into which you may deposit Bond Tokens in exchange for Vault Shares. Using a vault is never required in order to hold a Bond Token or to receive distributions on it. Where you choose to use one, you accept risks in addition to those of holding the Bond Token directly:
- A Vault Share is not a Bond Token. It is a claim on the assets held by the relevant vault contract, and it is subject to that contract's own share-price accounting, entry and exit conditions, and any period during which deposits or exits are closed or suspended (including around maturity and issuer calls).
- Vault contracts carry the smart contract risks described in section 4.6 in addition to those of the Bond Token itself.
- A vault exit may settle in a different form, or at a different time, than you expect. Stablecoin proceeds are paid only to wallets that have completed KYC verification. A wallet that has not been verified may exit only in Bond Token form, or may have amounts recorded for later claim, until verification is completed.
- The Reinvestment Vault reinvests coupon proceeds through onchain swaps that are subject to price and slippage checks. Where those checks are not satisfied, reinvestment may be delayed for an extended period and the proceeds may remain held in the vault as stablecoin rather than compounded into Bond Tokens.
- The Redemption Vault does not guarantee an early exit; see sections 4.4 and 4.16.
- If you supply Vault Shares to a Lending Market or any other third-party protocol, you do so entirely at your own risk. Such protocols are not developed, operated, or controlled by Bondi, and their price oracles, collateral parameters, and liquidation mechanics are outside Bondi's control. Your position may be liquidated, including as a result of oracle error or unavailability, movements in the price of the Underlying Bond, or a Bond Token lifecycle event such as an issuer call. Bondi is not responsible for any loss arising from your use of any third-party protocol.
4.4. Liquidity Risk: The ability to buy or sell Bond Tokens on secondary markets may be limited. There is no guarantee of a liquid secondary market, which could prevent you from selling your tokens on demand.
4.5. Forced Transfers, Freezing & Token Burns: Bond Token smart contracts may include controls that can freeze, forcibly transfer, and/or burn Bond Tokens in limited circumstances, including:
- Compliance actions required to comply with binding legal or regulatory obligations (including sanctions programmes and court orders) or authenticated instructions of competent authorities; and/or
- Bond Token lifecycle and issuer-directed operational events consistent with the Bond Tokens’ governing documents (for example, maturity redemptions, issuer calls/partial calls that require burning all or a pro‑rata portion of Bond Tokens and distributing the related proceeds to Bond Token holders, or other required settlement mechanics).
These controls are not intended to be used for unilateral commercial reasons unrelated to the above.
B. Operational, Technical, and Cyber Risks
4.6. Smart Contract and Platform Risks: Despite rigorous testing and audits, smart contracts may contain unknown bugs or vulnerabilities that could be exploited, potentially resulting in a loss of funds. For third-party smart contract audit results, see our Security Audit Report. Bondi has adopted the SEAL Safe Harbor Agreement for Whitehats (Base mainnet, March 22, 2026); adoption, onchain references, and documentation aligned with the SEAL self-adoption guide appear in our Cybersecurity Guide, and user consent in our Terms of Service. Participation remains subject to the risks described in those materials, including risks connected with attempted fund rescues by eligible whitehats where applicable.
4.7. Cybersecurity Threats: Bondi applies advanced security protocols, but risks persist, including phishing, malware, and other attacks that could compromise the platform or user wallets.
4.8. Loss of Private Keys: You are solely responsible for securing your wallet credentials (private keys or seed phrases). If they are lost or compromised, your Bond Tokens cannot be recovered by Bondi. This risk also applies to the security of social accounts used for in-app wallets.
4.9. System Failures and Accounting Risks: Due to the platform's complexity, there may be:
- Misstatements in financial reporting or token valuations
- Operational errors due to technology or human oversight
- Delays in coupon distributions or redemptions due to smart contract execution failures, network congestion, or disruption to the payment flow between the Cell, Ensuro Re Ltd., and Bondi's non-custodial distribution contracts
4.10. Data Handling and Privacy Risk: KYC/AML data is stored securely and may be shared with the Issuer and its service providers as necessary to satisfy regulatory and compliance obligations, but remains vulnerable to data breaches despite best practices.
C. Regulatory and Legal Risks
4.11. Legal Uncertainty: The legal landscape governing blockchain and tokenized assets is rapidly evolving and varies across jurisdictions. Abrupt regulatory changes could restrict or alter Bondi's services.
4.12. Jurisdictional and Sanction Risks: Services are restricted in certain jurisdictions (e.g., the U.S., sanctioned countries). You must ensure your participation does not violate any local laws.
4.13. Regulatory Change Impact: Changes in Bermuda, Panama, or other jurisdictions may:
- Force Bondi to restrict, suspend, or cease services (including Bond Token issuance or redemptions)
- Alter Bondi's business model, investment strategy, or compliance obligations
- Cause financial losses due to asset lock-up, token devaluation, or forced shutdown, without recourse or compensation
D. Force Majeure and Service Availability Risks
4.14. Platform Disruption or Shutdown Risk: In cases of regulatory intervention, technical failure, insolvency, or force majeure events, Bondi's platform and related services may become temporarily or permanently inaccessible, and funds may be delayed or inaccessible.
E. User Responsibility
4.15. Independent Evaluation Required:
- Bondi provides no financial, legal, or tax advice
- You must evaluate all aspects of participation independently and consult your own advisors as needed
- Past performance of underlying bonds is not indicative of future results
5. Matters Applicable to Our Services
Regulatory Status
5.1. Bondi Technology Inc. is a corporation registered in the Republic of Panama and operates as a technology platform provider. Bond Tokens are issued by Ensuro Re Ltd. (Bermuda registration number 202100534) acting in respect of its segregated account designated "Bondi Finance" established under Bermuda law (the "Cell"). Ensuro Re Ltd. holds a Class F Digital Asset Business (DAB) license and a Class IIGB (Innovative Insurer General Business) insurance license, both issued by the Bermuda Monetary Authority. Disputes regarding issuance, custody, and token-holder rights are subject to the Issuer's dispute-resolution terms and Bermuda law.
Schedule of Fees
- Minting Fee: 1% (0.5% service fee + 0.5% Bondi platform fee) of the total value of the tokens minted, charged upon the issuance of new Bond Tokens.
- Maturity Redemption Fee: 0.5% of the redemption value, charged upon the redemption of Bond Tokens at maturity. The same rate and parameter apply to a redemption resulting from an issuer call of an Underlying Bond.
- Early Redemption Fee: 0.5% of the redemption value, charged upon the early redemption of Bond Tokens before maturity.
- Coupon Fee: 0.5% of the gross coupon payment, charged on each coupon payment processed by the Platform.
- Blockchain Transaction (Gas) Fees: Variable fees paid by the user for interacting with smart contracts, dependent on network congestion on the respective blockchain (Ethereum, Base, Plume, or Mantle).
Any material changes to our fee structure will be communicated via the Platform in advance.
Eligibility
5.2. All participants must complete Know Your Customer (KYC) and Anti-Money Laundering (AML) onboarding prior to engaging in any platform activity. KYC/AML verification is conducted by Ensuro Re Ltd. as Class F Digital Asset Business (DAB) licence holder and regulatory principal, using its verification infrastructure (implemented via idenfy or a substantially similar service), which includes document verification, an investor knowledge assessment, PEP screening, AML screening, and blockchain address scanning. Bondi presents Ensuro's verification flow on its frontend; upon Ensuro's backend confirmation of approval, Bondi whitelists your wallet address on its KYC smart contracts. You authorize Ensuro Re Ltd. and its service providers to collect, process, verify, and retain your identification information, and to share verification results with Bondi for wallet whitelisting and access control purposes. Wallets that have not been whitelisted cannot interact with gated platform functions regardless of any other status.
Irrevocability of Blockchain Transactions
5.3. Once confirmed on the blockchain, all Bond Token transactions are final and cannot be reversed by Bondi or any third party.
Governance and Voting
5.4. Bond Token holders do not receive any governance or voting rights in Bondi Technology Inc.
General Rights and Obligations
5.5. Bondi disclaims all liability to the extent permitted by law for any mistaken, unauthorized, or unintended token transfers. While we may, at our sole discretion, attempt to recover such assets, there is no obligation to do so.
5.6. You are responsible for ensuring that your contact and compliance details remain accurate and up to date for regulatory and operational communications.
5.7. A submitted transaction may only be cancelled if the instruction has not yet been processed onchain.
5.8. Bondi may decline to execute a transaction if doing so would violate applicable laws, AML rules, sanctions restrictions, or regulatory orders.
5.9. You may request a formal receipt of any on-platform transaction, which will be provided within 14 business days via email.
5.10. Where required by applicable law or where a change is material, Bondi will endeavour to provide reasonable advance notice of changes to service terms or policies via email or the platform interface.
Information Rights
5.11. At the conclusion of any transaction, you will have access to the following information through the Bondi Platform or upon written request:
- Bondi Technology Inc.'s name and contact details
- Contact information to access and manage your account, inquire about our operations, or submit a complaint through our formal complaint-handling procedures
- A record of each transaction, including type, value, date, time, and the on‑chain transaction hash (which serves as your immutable receipt) or a reference ID
- A breakdown of any fees or commissions associated with the transaction
Our Structure
5.12. Bondi Technology Inc. operates the technology platform (frontend, backend, and smart contracts). Bond Tokens are issued by Ensuro Re Ltd. acting in respect of its segregated account designated "Bondi Finance" (the "Cell"). Coupon and principal payments flow from the Cell through Ensuro Re Ltd. into Bondi's non-custodial distribution smart contracts, which disburse amounts to verified Bond Token holder wallets. Bondi does not hold or custody funds at any point in the distribution process. The non-custodial architecture of Bondi's distribution contracts means that funds flowing to Bond Token holders are not subject to claims by Bondi's creditors, as such funds never pass through Bondi-controlled accounts. In the event of Bondi's insolvency or operational failure, this design eliminates Bondi-level custodial risk on the payment leg.
5.13. The underlying bond assets are acquired and held to the credit of the Cell, custodied through a licensed investment broker. Holders of Bond Tokens and other creditors in respect of a Bond Token Line have recourse solely to that Line's Line Assets and have no interest in or recourse to other Line Assets, the assets of the Issuer's general account, any other segregated account, or Bondi Technology Inc. Distributions from the Cell (coupon payments and redemption proceeds) flow through Ensuro Re Ltd. into Bondi's non-custodial distribution smart contracts, which disburse amounts to verified Bond Token holder wallets. Bond Token holders receive distributions directly to their wallets via smart contract execution; Bondi does not intermediate or hold funds at any stage.
5.14. Holders of Bond Tokens have no ownership interest in Bondi Technology Inc. or its affiliates. Their rights are strictly contractual and linked to the performance of the underlying bonds, the applicable Bond Token Line, and the terms governing the Cell.
5.15. As an innovative entity operating at the intersection of traditional finance and blockchain technology, Bondi has limited operating history. The rapidly evolving nature of blockchain and digital asset markets, as well as evolving regulation in Bermuda and Panama, may impact our capacity to scale operations or respond to market and regulatory shifts.
6. Cyber Reporting
Bondi shall notify affected clients without undue delay if a significant cybersecurity event occurs that involves unauthorized access to personal or transactional client data. Notifications will include a summary of the breach, remedial actions taken, and guidance for affected users. The Issuer may also provide notifications in accordance with the Bermuda Digital Asset Business Act and other applicable Bermuda regulations.
7. Privacy
For details on how Bondi Technology Inc. collects, uses, stores, and shares your personal data, please refer to our full Privacy Policy.
8. Glossary
- Basket: A pool of two or more Underlying Bonds to which a single Bond Token Line is linked. Holders of a Basket Bond Token have a pro-rata economic interest in the pooled Basket as a whole and no claim to, or in respect of, any individual bond within it. See section 4.3A.
- Blockchain: A distributed ledger technology that enables peer-to-peer electronic transactions. The Bondi Platform operates on public Blockchains, including Ethereum, Base, Plume, and Mantle.
- Bond Token: A digital token issued on the Platform representing a fractional economic interest in an underlying real-world bond.
- Bond Token Line (or Line): A distinct Bond Token, identified as such in the Issuer's records and linked to its own Underlying Bond or Basket. Each Line is a separate class of limited-recourse obligations of Ensuro Re Ltd. acting in respect of the Cell; a Line is the unit at which assets, proceeds, reserves, and recourse are identified. Different Bond Tokens are different Lines. Lines are contractual divisions within one statutory segregated account, not separate statutory accounts.
- Line Assets: The underlying bond assets, coupon proceeds, redemption proceeds, reserves, and other assets identified in the Issuer's books and records as linked to a particular Bond Token Line.
- Capital Provider: An investor who provides capital to mint Bond Tokens.
- Coupon: The periodic interest payment made by the issuer of the underlying bond, which is distributed to Bond Token holders (net of fees).
- Gas Fee: A fee required to conduct a transaction on a blockchain.
- Issuer: Ensuro Re Ltd. (Bermuda registration number 202100534), acting in respect of its segregated account established under Bermuda law designated "Bondi Finance" (the "Cell" or the "Account"), which legally issues Bond Tokens. References to "Issuer" in this Statement mean Ensuro Re Ltd. acting in respect of the Cell, not the corporate entity that originally issued the underlying bond; the latter is referred to as the "Underlying Bond Issuer" where relevant. The Cell is a segregated account and is not itself a legal person.
- Underlying Bond Issuer: The entity (e.g., a corporation) that originally issued the underlying bond to which a Bond Token's economic interest is linked.
- KYC: “Know Your Customer”; a compliance process used to verify the identity of clients.
- Lending Market: A third-party lending protocol, not developed or operated by Bondi, in which Vault Shares may be supplied as collateral to borrow other digital assets. Bondi does not control any Lending Market, and use of Vault Shares in one is at your own risk and subject to that protocol's own terms, price oracles, and liquidation mechanics.
- Minting: The process of creating new Bond Tokens on the platform.
- Platform: The smart-contract-based infrastructure developed and operated by Bondi Technology Inc.
- Redemption: The process of returning Bond Tokens at the maturity of the underlying bond to receive the principal value.
- Redemption Vault: A Platform smart contract that pools early-exit requests from multiple holders until the combined position reaches the minimum lot size required for an off-chain block sale of the Underlying Bond by the Cell's broker. Depositors receive non-transferable Vault Shares as a receipt. Depositing does not guarantee that a sale will occur; see section 4.16.
- Reinvestment Vault: A Platform smart contract that holds a Bond Token and reinvests coupon proceeds into additional Bond Tokens, so that value compounds into the Vault Shares it issues rather than being paid out.
- Series: A funding round of a Bond Token Line. A single Line may be offered in successive Series, each with its own target raise amount and funding deadline, all of which mint the same Bond Token. Series of the same Line are backed by the same assets and are not segregated from one another.
- Smart Contracts: Computer programs deployed on a blockchain that execute the terms of an agreement.
- Stablecoin: A type of cryptocurrency designed to maintain a stable value, such as USD stablecoin, which is pegged to the US Dollar.
- Underlying Bond: The real-world corporate bond that a Bond Token represents economic exposure to.
- Vault Share: A token issued by a Reinvestment Vault or Redemption Vault as a receipt for Bond Tokens deposited into it, representing the depositor's pro-rata claim on the assets held by that vault. A Vault Share is not a Bond Token and carries the additional risks of the vault contract itself.
- Profile: A user's verified account configuration on the Platform, containing permissions, wallet addresses, transactional data, and preferences.
- Force Majeure: Extraordinary circumstances beyond Bondi's control, including but not limited to natural disasters, war, terrorism, government actions, or technical failures of third-party infrastructure.