Terms of Investment Advisory Services

1. WHO WE ARE

1.1 We are Raison Securities Limited, a private limited company incorporated in Astana International Financial Centre (“AIFC”) ("we", "us", “our” or "Raison").

1.2 Raison is an Authorised Firm which is regulated and licensed by the Astana Financial Services Authority ("AFSA") to carry on Regulated Activities.

1.3 General information about Raison:

Name: Raison Securities Limited Business Identification Number: 230140900126 Registration date: 13 January 2023 Registration Authority: Astana Financial Services Authority

1.4 Raison contact details:

• Telephone: +7 717 273 47 55
• E-mail: [email protected]
• Website: raison.app (“Website”)
• Address of Raison is available at Raison's Website: raison.app

1.5 100% of Raison's shares are owned by Raison FinTechnologies, Inc., with the registered address at 8 The Green STE B, Dover, DE 19901, USA.

1.6 Raison is duly authorized by the AFSA to provide regulated investment services in the securities market.

1.7 License No.AFSA-A-LA-2023-0004 is issued by the AFSA for the provision of the following investment services:

• 1.7.1 Dealing in Investments as a Principal;
• 1.7.2 Dealing in Investments as an Agent;
• 1.7.3 Advising on Investments;
• 1.7.3 Arranging Deals in Investments with a scope authorisation restricted to the specified Financial Products such as Shares, Debentures, Structured products, Units in a Collective Investment Scheme without permission to carry on the Regulated Activities with Structured products for Retail Clients.

2. SUMMARY

2.1 This document (“Agreement”) forms the basis of the agreement between you and Raison and provides you with important information about the services relating to the provision of non- discretionary advisory services by us to you, meaning you are responsible for making final decisions on any investment recommendations provided by us. If this Agreement is translated and made available to you in your local language, the English version of this Agreement will still prevail. In case we translate and make available any document in a language other than English, all other documents and information related to our Services can still be provided to you in English and we will communicate to you in English.

2.2 In this Agreement, capitalised words and expressions have the meanings ascribed to them in Annex A (Definitions).

2.3 Please read this Agreement carefully before using the Services provided by us. By using any of our Services you agree to be bound by this Agreement. If you do not agree to this Agreement, you must not use the Services. This Agreement is available on our Website for your review at any time.

2.4 In order to access our Services you must explicitly accept these terms. Acceptance of this Agreement can be provided by: written or electronic confirmation of acceptance (such as by signing or agreeing to a separate service request form) when Services are provided. Your acceptance of these terms is legally binding and constitutes a formal agreement between you and Raison. The terms of this Agreement take effect as soon as you agree through any of the accepted methods, or upon your first use of the Services in any form, whichever occurs first.

2.5 This Agreement relates only to the provision of non-discretionary advisory services by us to you, and where we provide additional services to you, those services will be governed by our other terms as appropriate. We have disclosed Raison Risk Disclosure (“Risk Disclosure”) on our Website. The risks set out in the Risk Disclosure do not represent all the risks involved when using the Services that we provide to you under this Agreement, as there may be additional risks to you and your capital both currently and in the future and the Risk Disclosure is not intended to be a comprehensive explanation of the key risks. By accepting this Agreement, you are deemed to represent to us that you have carefully read and understood all Risk Disclosure and you accept it. You accept that we may, in our absolute discretion, amend this Agreement and the Risk Disclosure, from time to time and will notify you in a manner as set out in this Agreement. If you have any questions or concerns about any of the content of this Agreement or any of our other agreements or notices, you should seek independent professional advice before using the Services.

3. OUR SERVICES

3.1 Pursuant to valid and proper authority and in accordance with Applicable Law, you hereby appoint, entirely at your risk, Raison to render the non-discretionary investment advisory services in accordance with the terms and conditions of this Agreement for the term of your relationship with Raison and Raison agrees to such appointment on terms and conditions provided for herein.

3.2 Raison provides you with the non-discretionary investment advisory services (the “Services”). Upon completion of the onboarding checks by us, as specified in this Agreement, we provide services that include, but are not limited to:

• 3.2.1 Advising on the merits of Investments: We will provide advice to you, in your capacity as an investor or potential investor, regarding the merits of buying, selling, holding, subscribing for, or underwriting specific Investments. This advice may include analysis, reports, or recommendations intended to assist you in making informed investment decisions.

• 3.2.2 Investment-related statements, opinions, or reports: Our advice may include statements, opinions, or reports aimed at influencing your investment decisions or which could reasonably be regarded as being intended to influence your decisions related to a specific Investment.

3.3 We will provide Investment Advice without exercising any discretion over your Investments. All decisions regarding Investments remain solely yours, and we do not manage or control your Investments or make decisions on your behalf.

3.4 You and Raison may agree on specific investment parameters, which may include risk tolerance, investment horizon, and targeted asset classes in the Investment Advisory Request Form. You may provide instructions to Raison via email, by telephone or in person. Raison will acknowledge receipt of instructions through the relevant channel of communication chosen by you.

3.5 You understand and acknowledge that the Services provided by Raison are not an asset management service. You should be aware that the Services do not provide comprehensive financial planning. Please click download button to get the document.

4. ONBOARDING

4.1 To access our Services, you have to be at least 18 years old and you must complete an onboarding process, which may be done either through Raison App or in person at our office with a manager.

4.2 You acknowledge and agree that you will provide us with all information which we may reasonably request of you from time to time for the purposes of verifying your identity as part of the process of onboarding or otherwise for the purpose of complying with Applicable Law.

4.3 We have legal obligations to verify your identity and certain information in order to comply with Applicable Law, including AIFC’s Anti-Money Laundering, Counter-Terrorist and Sanctions Rules and other relevant regulations. As part of the onboarding process, we may request certain information from you so that we can perform anti-money laundering checks, screen our users against “Politically Exposed Person” and international sanctions’ lists as well as comply with Applicable Law and therefore also collect and process your information for these purposes.

4.4 You authorise Raison to, directly or through third parties, make any inquiries that we consider necessary to verify your identity and/or protect against fraud, including to query identity information contained in public domains or reports, to query account information associated with the bank, e-money or payment institution account that you link to the Account or qualifying credit/ debit cards (e.g., name or account balance), and to take any action we reasonably deem necessary based on the results of such inquiries or reports. You further authorise any and all third parties to whom such inquiries or requests may be directed to fully respond to such inquiries or requests. If in our absolute discretion, we suspect or have reason to suspect money laundering or any other illegal activities, we may cease to provide the Services to you without any explanation or notice and inform law enforcement or other relevant authorities of our suspicions and the reasons for them. This is in order for us to comply with our legal obligations.

4.5 You agree that we may exercise our rights under this section 4 both during the onboarding process and at any other time and as often as we consider necessary.

4.6 You agree that any information you submit to us about yourself, both during the onboarding process and at any other time under this Agreement, is true, accurate, current and complete.

5. SUITABILITY ASSESSMENT

5.1 For Retail Clients, we are required to assess the suitability of any Investment Advice we provide. This involves evaluating your investment objectives, financial situation, and knowledge and experience concerning the recommended Investments or services. You undertake as an ongoing obligation to provide Raison with updates of such information and to inform Raison as according to Section 13 of this Agreement. A Suitability Report will be provided, detailing the Investment Advice, and explaining why the recommendation is suitable for you.

5.2 For Professional Clients, we may assume you have the necessary knowledge, experience, and financial situation to make informed decisions. As a result, we are not required to conduct a suitability assessment unless you specifically request such a service.

5.3 Please ensure that the information you provide to us is accurate and complete, as this is critical for us to assess the appropriateness or suitability of any recommendations made. If you fail to provide adequate information or provide incorrect or incomplete information, you may be exposed to greater risks.

5.4 Raison may ask you to review and update (if needed) your suitability assessment result. Failure to provide up-to-date information may have an impact on the ability of Raison to provide the Service to you.

5.5 You are advised that in case Raison receives no request for any update, your previous profile and relevant suitability assessment result on record will continue to be used.

5.6 You will only receive a recommendation or an Investment Advice which aligns with your suitability assessment result.

5.7 The suitability assessment and the results are for your reference only and should not be construed as an offer to sell, or a solicitation for an offer to purchase any securities or services. Raison and its affiliates accept no responsibility or liability for the accuracy or completeness of the information provided in the Suitability Report and the results. The assessment is not a comprehensive financial tool and is not a substitute for independent professional advice.

6. CLIENT CLASSIFICATION

We are required to classify you as a certain type of client based on the information provided by you. We will treat you as a Retail Client unless you have requested to instead be classified as a Professional Client and we have agreed to this request in writing. It is up to you to request at any time a different client categorisation to the one we have given you, but we may, in our sole discretion, reject any such request. If you are a Professional Client and request to be treated as a Retail Client, or a Market Counterparty requesting to be treated as a Professional Client or Retail Client, we will treat you as such regarding all or certain Services, Transactions or Investments. By accepting the terms of this Agreement, you acknowledge and confirm that you have read, understood and agreed with the method of classification of the clients, information about which is provided by Raison on its Website.

7. FEES

7.1 Clients may be charged through one or more of the following compensation models:

• 7.1.1 Consultation Fees: A flat fee per advisory session or consultation, determined based on the complexity of an Investment concerned and the specific nature of the Services provided.

• 7.1.2 Portfolio-Based Fees: A percentage-based fee charged on the total value of the Investment under advisement, or a flat annual fee for ongoing support.

• 7.1.3 Project-Based Fees: For specific projects or transactions (e.g., advice on portfolio restructuring, asset sales), a negotiated fee is agreed upon before the Service is provided.

Raison’s compensation will be determined on an ad hoc basis, allowing for flexibility in negotiating fees based on the Investment complexity and scope of the Services required. Any specific fees for consultations or Investment Advice will be indicated in the Investment Advisory Request Form, specifying the scope of required Investment Advice and applicable pricing.

• 7.1.4 We reserve the right to modify the fees for the Services at any time.

8. CONFLICTS OF INTEREST

8.1 We are required to take all reasonable steps to prevent or manage conflicts of interest between us and you and between our different Clients. We operate in accordance with our conflicts of interest policy we have put in place for this purpose in which we have identified those situations where there may be a conflict of interest, and in each case, the steps we have taken to prevent or manage that conflict. A summary of Raison Securities Limited's Conflicts of Interest Policy is available on our Website. Where such arrangements would be insufficient to eliminate the risk of damage to your interests then, as a last resort, we will disclose to you the general nature and/or source of those conflicts of interest and the steps we have taken to mitigate such risks.

8.2 We are under no obligation to:

• 8.2.1 disclose to you or take into consideration any fact, matter or finding which might involve a breach of confidence to any other person, or which comes to the notice of any of our directors, officers, employees or agents, where the individual(s) dealing with you have no actual notice of such fact, matter or finding; or

• 8.2.2 account to you for any profit, commission or remuneration made or received by us from or by reasons of any transactions or circumstances in which we have a material interest or where in particular circumstances a conflict of interest may exist.

9. YOUR INFORMATION

9.1 Raison takes its data security seriously. We will only use your personal information as detailed in our Privacy Policy which is available online. You should review our Privacy Policy to ensure you understand and agree to our collection, use and disclosure of your personal information.

9.2 For certain Investment Advice in relation to a certain Investment, we may be required to obtain certain information on your investment or other objectives, financial situation and knowledge and experience in relation to the type of Service concerned, to ensure that the recommendation is suitable for you. Where we are subject to such obligations, we will inform you and request such information from you as we deem necessary in order to perform a suitability assessment. You acknowledge and agree that you will provide all such information as may be reasonably requested by us for the purposes of conducting such assessment. If you do not provide such information, we are under no obligation to provide the Services and we may refuse to do so.

9.3 You acknowledge and agree that we are entitled to disclose information about Investment Advice given to you as may be required under Applicable Law.

10. HOW TO CONTACT US

10.1 How to Contact Us and How We Will Contact You

• 10.1.1 if you need to speak to us or if we need to speak to you, in relation to any matters arising out of or in connection with this Agreement, you specifically consent that we will contact you via email. For the avoidance of doubt, such consent includes your consent to receive Suitability Reports (if we are under obligation to provide it to you) and any other reports, documents, statements or similar that we may provide to you in connection with this Agreement.

• 10.1.2 We may use the email address you provide to us during the onboarding to contact you.

10.2 If You Have a Complaint

• 10.2.1 If you feel dissatisfied with any aspect of our Service, then in the first instance please contact us by emailing [email protected]. We will immediately carry out an independent investigation of your complaint and will provide a written response. More details on the process can be found in Raison Securities Limited Complaints Management Policy which can be found on our Website.

11. ADVICE MAY DIFFER

11.1 You understand and agree that we act as an investment advisor for Clients and will continue to do so. We and our personnel may make recommendations to Clients that may differ from the recommendations we give to you.

11.2 In addition, our personnel may take actions for their own accounts based on their own investment situations that differ from the recommendations we give you.

13. RECORDING CONVERSATIONS AND ELECTRONIC COMMUNICATIONS

13.1 We may record telephone conversations we have with you and store electronic communications between you and us, and you hereby specifically consent to this. You also specifically consent to such records being used in any arbitral or legal proceedings between us.

13.2 Where we have recorded a conversation we have had with you or stored an electronic communication between you and us in accordance with our obligations, we will make a copy of such recordings and/or communications available to you on request for a period of six (6) years.

14. NOTICES

14.1 Any notice or other communication given to either party in connection with this Agreement shall be in English and, unless otherwise stated in this Agreement, shall be sent:

• 14.1.1 by email to the email address notified to the other party in accordance with this Agreement. Our email address for the service of notices is [email protected].

14.2 Any notice or other communication will be deemed to have been received if sent by email, at 9.00 am on the next business day after it is sent.

15. AMENDMENTS TO THIS AGREEMENT OR THE SERVICES

15.1 We may amend this Agreement at any time by providing you with 14 calendar days’ notice unless the amendments are required by Applicable Law.

15.2 A notice shall be provided to you by e-mail to the email address that you have provided to us. You will be deemed to accept and agree to any and all amendments to this Agreement that have been notified to you. If you object to any of our amendments to this Agreement, you have the right to terminate the Agreement with immediate effect. If you have not notified us of the wish to terminate, then the amended Agreement will take effect from the date indicated in the notice referred to in clause 14.1. Any amended version of this Agreement will supersede any previous version of the Agreement entered into between Raison and you.

15.3 Raison may discontinue or modify the Services, or any portion thereof, at any time. You release and agree to indemnify and hold harmless Raison for any loss or damages arising from or relating to such discontinuation or modification. It is important that you keep your personal contact information up to date, so please let us know if any of your details change.

16. TRANSFER RIGHTS

16.1 Raison and you are the only parties to this Agreement. You cannot transfer any rights or obligations under this Agreement to any other person without our written consent.

16.2 We may at any time assign or transfer any or all of our rights under this Agreement upon providing you with prior notice, provided that we meet our regulatory and legal obligations prior to doing so.

17. IN THE EVENT OF A BREACH OF THESE TERMS

17.1 If you believe or have reason to believe that you have or may breach this Agreement, you must notify us immediately at [email protected].

17.2 Where you have breached this Agreement you may be liable for any damage, loss or expenses that we suffer as a result of, or which a reasonable person would consider as resulting from, your breach of this Agreement. If we become aware that you have breached this Agreement, either because you have told us that you have or we otherwise become aware of such breach, we may take all or any of the following actions:

• 17.2.1 immediate, temporary or permanent withdrawal of your right to use the Services;

• 17.2.2 legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach;

• 17.2.3 further legal action against you; and

• 17.2.4 disclosure of such information to law enforcement authorities as we reasonably feel is necessary or as required by law.

17.3 We exclude our liability for all action we may take in response to breaches of this Agreement. The actions we may take are not limited to those described above, and we may take any other action we reasonably deem appropriate. Among others, we may apply any other legal remedies available to us under Applicable Law.

18. INTELLECTUAL PROPERTY

18.1 We own the Services, the documentation, specifications, written instructions or explanatory material relating to the installation, operation, use or maintenance of the Services and the Raison App and any subsequent versions thereof, available through the Raison App (“Licensed Work”), and all improvements, modifications and derivative works thereof and all intellectual property rights therein or relating thereto are and shall remain the exclusive property of Raison or its licensors as the case may be. Except as set forth in this Agreement, Raison does not grant any rights to the Services or Licensed Work to you. You further acknowledge that we retain all rights, title and interest in the Licensed Work including all rights to patent, copyright, and trade secret.

18.2 For the avoidance of doubt, all intellectual property rights which are created pursuant to the provision of the Services by us (other than those which subsist in your personal data) shall vest on creation in us and shall remain our sole property.

18.3 You acknowledge and agree that the Licensed Work constitutes and contains valuable proprietary products and trade secrets of Raison, embodying confidential information, ideas and expressions.

18.4 You agree not to challenge, directly or indirectly, any right or interest of Raison in the Services or Licensed Work nor the validity or enforceability of our rights under Applicable Law. You agree not to directly or indirectly register, apply for registration or attempt to acquire any legal protection for, or any proprietary rights in, the Services or Licensed Work or to take any other action which may adversely affect our rights or interest in the Services or Licensed Work in any jurisdiction.

19. DISCLAIMERS & NON-WARRANTY

19.1 Your use of the Website, Raison App, and the personal information you provide is at your sole discretion and risk. All our Services, content on the Website and the Raison App are provided on an “as is” and “as available” basis without warranties of any kind from Raison.

19.2 To the fullest extent permitted under Applicable Law, Raison expressly disclaims all warranties of any kind with respect to the Services and any content provided directly or indirectly through the Raison App and the Website, whether express, implied or statutory including, but not limited to, the implied warranties of title, merchantability, fitness for a particular purpose and non- infringement of proprietary rights, course of dealing or course of performance. Raison does not guarantee the accuracy, timeliness, completeness or usefulness of any content or information. You agree to use the content, the Website, the Raison App and the Services entirely at your own risk.

19.3 Raison does not warrant, endorse, guarantee, or assume responsibility for any product or service advertised or offered by a third party through the Raison App, and will not be a party to or in any way be responsible for monitoring any transaction between you and such third party providers of products or services. You are solely responsible for all of your communications and interactions with other persons with whom you communicate or interact as a result of your use of the Services.

19.4 Regarding the availability, security, accuracy, reliability, timeliness and performance of Raison App or the Website, content and/or client information; that the Website or Raison App will be error-free or that errors will be corrected; that the Website or Raison App will be free from electronic viruses, or regarding the performance of or accuracy, quality, currency, completeness, or usefulness of any information provided by Raison on its Website or Raison App including but not limited to information obtained through social media.

19.5 No advice or information, whether oral or written, obtained by you from Raison App, or the Website, shall create any warranty not expressly stated in this Agreement. If you choose to rely on such information, you do so solely at your own risk.

20. INDEMNIFICATION AND LIABILITY

20.1 You will indemnify and hold harmless Raison and the officers, directors, agents, partners, employees, licensors, distributors, and representatives of Raison (together the “Service Providers”), from and against any and all claims, demands, actions, causes of action, suits, proceedings, losses, damages, costs, and expenses, including reasonable attorneys' fees, arising from or relating to your access and/or use of, the Services, or any act, error, or omission of your use of your Account or any user of your Account, in connection therewith, including, but not limited to, matters relating to incorrect, incomplete, or misleading information; libel; invasion of privacy; infringement of copyright, trade name, trademark, service mark, or other intellectual property; any defective product or any injury or damage to person or property caused by any products sold or otherwise distributed through or in connection with the Service; or violation of any Applicable Law.

20.2 IN NO EVENT SHALL RAISON, ITS OFFICERS, DIRECTORS, EMPLOYEES, OR AGENTS BE LIABLE FOR ANY DAMAGES WHATSOEVER, INCLUDING WITHOUT LIMITATION INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE, OR CONSEQUENTIAL DAMAGES ARISING OUT OF OR IN CONNECTION WITH YOUR USE OF THE SERVICES OR RELIANCE ON THE CONTENT AND/OR THE WEBSITE INFORMATION, INCLUDING BUT NOT LIMITED TO THE QUALITY, ACCURACY, OR UTILITY OF THE INFORMATION PROVIDED THROUGH RAISON, INCLUDING BUT NOT LIMITED TO ANY INVESTMENT DECISIONS MADE BASED ON INFORMATION PROVIDED BY RAISON, WHETHER SUCH DAMAGES ARE FORESEEABLE AND WHETHER RAISON HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. THE FOREGOING LIMITATION OF LIABILITY SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY LAW IN THE APPLICABLE JURISDICTION AND IN NO EVENT SHALL RAISON'S CUMULATIVE LIABILITY EXCEED U.S. $100. THIS LIMITATION OF LIABILITY SHALL APPLY REGARDLESS OF THE LEGAL BASIS OF SUCH CLAIM, WHETHER IN CONTRACT, TORT, OR OTHERWISE.

20.3 You understand and acknowledge that the investment results you could obtain from investment information and financial insights provided by Raison cannot be guaranteed and that Raison cannot be held responsible. All investments entail a risk of loss and you may lose money.

21 TERMINATION

21.1 This Agreement is of unlimited duration and the Agreement shall remain in full force and effect unless terminated in accordance with the provisions of this section.

21.2 You may terminate your Account at any time and for any reason by giving us notice via email at [email protected].

21.3 Raison may terminate this Agreement at any time by giving you at least 30 calendar days' written notice of such termination.

21.4 Raison may also immediately terminate this Agreement if any of the following circumstances occur:

• 21.4.1 you have breached this Agreement;

• 21.4.2 you are declared or it is acknowledged that you are insolvent or upon the filing of any proceeding (whether voluntary or involuntary) for bankruptcy, insolvency or relief from your creditors).

22. RELEVANT LAWS

22.1 This Agreement and any non-contractual obligations arising out of or in connection with it will be governed by and construed in accordance with the Acting Laws of the AIFC.

22.2 Without prejudice to any rights, you may have to refer a complaint to the authorities, as set out in the “If you have a complaint“ clause above, the AIFC court has exclusive jurisdiction to settle any dispute arising in connection with this Agreement and for such purposes, we and you irrevocably submit to the jurisdiction of the AIFC Court.

23. ENTIRE AGREEMENT

23.1 This Agreement, together with any written or electronic confirmations provided by you (including service request forms or other written agreements), constitutes the entire Agreement between Raison and you with respect to the Services and supersedes all prior or contemporaneous oral or written communications, proposals, agreements and representations with respect to such subject matter.

23.2 Except as required by statute, no terms will be implied (whether by custom, usage, course of dealing or otherwise) into this Agreement.

23.3 Each of us acknowledges that in entering into this Agreement we have not relied on any express or implied representation (including any made negligently), assurance, undertaking, collateral agreement, warranty or covenant which is not set out in this Agreement.

23.4 In connection with the subject matter of this Agreement, each of us waives all rights and remedies (including any right or remedy based on negligence) which might otherwise be available to it in respect of any express or implied representation, assurance, undertaking, collateral agreement, warranty or covenant which is not set out in this Agreement.

24. GENERAL

24.1 If, at any time, any provision of this Agreement is or becomes illegal, invalid or unenforceable in any respect under the law of any jurisdiction, neither the legality, validity or enforceability of the remaining provisions of this Agreement nor the legality, validity or enforceability of such provision under the law of any other jurisdiction will in any way be affected or impaired.

24.2 No person other than you or us shall be entitled to enforce any of the provisions in this Agreement in any circumstances.

24.3 Any failure by us (whether continued or not) to insist upon strict compliance with any of the terms in this Agreement shall not constitute nor be deemed to constitute a waiver by us of any of our or their rights or remedies.

24.4 Nothing in this Agreement is intended to or will be used to establish any partnership or joint venture between the parties, nor authorise any party to make any commitments for or on behalf of any other party.

24.5 If you have breached this Agreement and we don't enforce our rights, or we delay enforcing them, this will not prevent us from enforcing those or any other rights at a later date.

Annex A To Raison Securities Limited Terms of Investment Advisory Services

In addition to the terms defined elsewhere in this Agreement, for all purposes of this Agreement, the following terms shall have the meanings assigned to them below:

Acting Law of the AIFC

Has the meaning given by Article 4 of the Constitutional Statute of the Republic of Kazakhstan dated 7 December 2015 entitled On the Astana International Financial Centre.

AFSA

Astana Financial Services Authority

AIFC

Astana International Financial Centre

Applicable Law

Any and all applicable laws, legislation, bye- laws, decisions, notices, statutes, orders, rules (including any rules or decisions of court), regulations, directives, edicts, schemes, warrants, local government rules, statutory instruments or other delegated or subordinate legislation and any directions, codes of practice issued pursuant to any legislation, voluntary codes, other instruments made or to be made under any statute and codes of conduct and mandatory guidelines (including in all cases those that relate to audit, accounting or financial reporting) and which have legal effect, whether local, national, international or otherwise existing from time to time, together with any similar instrument having a legal effect in the relevant circumstances and shall include, for the avoidance of doubt, anti-money laundering requirements.

Client

A Person to whom Raison provides the Services.

COB

AIFC Conduct of Business Rules, AIFC Rules No. FR0005 of 2017 (COB), which ensures that financial services firms operating in the AIFC meet the standards of conduct expected of such firms, particularly with regard to the treatment of their clients, but also in their dealings with counterparties and other market participants. COB also includes rules to ensure that the behaviour of firms operating in the AIFC contributes to fostering and maintaining the integrity of financial markets in the AIFC. For more detailed information about AIFC Rules, you can visit the Astana International Financial Center website at aifc.kz

Complex Investment

An Instrument, which Is not a Non-complex Investment.

Investment

Any financial product or security that is available for investment, including but not limited to Shares, Debentures, Structured Products, and Units in a Collective Investment Scheme.

Investment Advice

Any recommendation, statement, opinion, or report provided by the Raison to the Client concerning the merits of buying, selling, holding, subscribing for, or underwriting specific Investments. This advice is provided with the intention of influencing, or which could reasonably be regarded as being intended to influence, the Client's decisions regarding those Investments.

Investment Advisory Request Form

A document or digital form provided by Raison, which Clients must complete to formally request Investment Advice. This form may include, without limitation, the following information: the scope of advisory services required, specific investment objectives, risk tolerance, and any relevant personal or financial circumstances that may affect the Investment Advice. Also, this form may specify any applicable fees for consultations or Investment Advice based on the complexity of an investment in question and the scope of Services required. By submitting this form, the Client acknowledges and agrees to the terms associated with the Services as outlined in this Agreement.

Market Counterparty

A market counterparty as defined in the COB 2.7.1

Non-complex Investment

A non-complex financial instrument as defined in the COB 5.3.3

Person

A Person includes any natural person, Body Corporate or body unincorporated, including a legal person, company, Partnership, unincorporated association, government or state.

Professional Client

A professional client as defined in the COB 2.3.1.

Raison

Raison Securities Limited

Raison App

This is our mobile application through which you can undergo KYC checks and onboarding procedures.

Retail Client

A retail client as defined in the COB 2.2.1

Risk Disclosure

Raison Risk Disclosure, which is available on our Website.

Services

Non-discretionary investment advisory services provided by Raison to the Client as defined in clause 3.2

Suitability Report

A mandatory document provided by Raison to a Retail Client when offering Investment Advice.

Website

Raison’s website at raison.app or such other website as Raison may maintain from time to time.

Annex B To Raison Securities Limited Terms of Investment Advisory Services NOTICE OF CLASSIFICATION AS A RETAIL CLIENT

Raison Securities Limited (hereinafter – Raison) is subject to AIFC Conduct of Business Rules (hereinafter – regulatory requirements, COB), including obligations to protect investors. Raison also has license restrictions.

A fundamental part of this regulatory framework is the requirement to classify Clients. We are required under regulatory requirements to classify you into one of the categories (Retail Client, Professional Client or Market Counterparty) so that when carrying out business with you we can provide the level of information, services and protection that is appropriate to and consistent with your classification as well as apply licensing restrictions on the carrying out transactions with certain financial products. In accordance with regulatory requirements, the Retail Client category will be provided with the maximum level of protection.

Please read Section 6 of the CLIENT CLASSIFICATION document situated on the Website.

This Notice is to inform you that we will, on the basis of the information available to us, treat you as a Retail Client in accordance with regulatory requirements in providing our services to you.

You, as a Retail Client, can receive advice on Shares, Debentures and Units in Collective Investment Schemes.

In accordance with license restrictions, Raison is not entitled to provide advice to Retail Clients on the following financial instruments:

• Structured Financial Products,
• Futures,
• Contracts for Differences,
• Options,
• Warrants,
• Certificates,
• Rights to or interests in Investments.

In case you want to be treated as a Professional Client, you need to go through the appropriate procedure and meet certain criteria. In this case, Raison still has the right to leave you in the Retail Client category based on the assessment carried out. The criteria that will allow us to classify you as a Professional Client as well as the reclassification procedure are set out in the CLIENT CLASSIFICATION document which can also be found on Raison's Website. It is your responsibility to inform us if you want to change your classification and if any change occurs that could affect your classification as a Retail Client. In order to go through the procedure for your classification to the Professional Client category, contact your relationship manager or submit a request for reclassification at [email protected].