V 1.3 – 24.04.2017

Customer info

Customer info Customer information regarding the services of FXFlat Wertpapierhandelsbank GmbH According to the Securities Trading Act and Civil Code consumer information guidelines on agreements and distance selling contracts concluded out of the commercial premises (including revocation instructions). Content I. Overview of the services and brand names II. General information III. Service and contract-related information A) Commission order execution (brand name FXFlat Konto DE) 1) Essential features of the service a) Orders to conclude CFD transactions and foreign currency transactions (commission business) b) No investment advice / Information on the adequacy check c) No licensing or provision of the requisite hardware and software along with customer connection d) Type, frequency and timing of the customer information about transactions e) Risk indication and reference to rate fluctuations 2) Key features of the agreement 3) Special information on the omnibus trust account and compensation schemes a) omnibus trust account b) Statutory compensation schemes aa) FXFlat Wertpapierhandelsbank GmbH bb) Trust collective account bank 4) Execution policy in the commission business and execution venues 5) Special conditions for the starter package B) Support services for use of a third-party system (brands FXFlat, CapTrader, FXFlat account GB and FXFlat HKK-Invest) 1) Key features of the service a) Support service for use of a system of the customer bank b) Support service for use of an alternative third-party system c) Scope and limits of the support service d) No investment brokerage and no investment advice e) No liability for the system 2) Key features of the agreement C) Special conditions for the negotiation of an asset management contract (brand name FXFlat HKK-Invest) 1) Key features of the service 2) Key features of the contract

IV. Dealing with conflicts of interest and payment information V. Right of revocation and consequences

I. Overview of the services and brand names

The illustration below serves to classify the services of FXFlat Wertpapierhandelsbank GmbH (referred to below as: Bank) and provide the customer with an initial overview. FXFlat Wertpapierhandelsbank GmbH offers the following services, which are assigned to the various brand names: - Commission order execution with customers trading in Contracts for Difference (CFD) and Options, which relate to financial instruments, indices, other underlyings and currencies (FOREX). In the commission business, execution transactions with foreign banks acting as market makers are concluded on behalf of the customer. The customer asset is lodged on omnibus trust accounts at Wirecard AG (i.e. customer funds not separated from one another, but customer funds separated from company funds). The customer is electronically connected to the bank under the terms of a separate agreement between the customer and the connection software provider; consequently, the bank provides no connection software or hardware for the customer. The bank does not offer investment advice (Execution Only). In return for its services, the bank receives, for the commission business, payments amounting to a percentage of the margins achieved by the market makers. This business segment is called: FXFlat Konto DE - Support services for customers who places commission orders with the bank's cooperation partners and/or who use their proprietary trading (market making) in the financial instrument sector (e.g. shares, fund units, ETFs), Contracts for Difference (CFD) and options, which relate to financial instruments, indices, other underlyings and currencies (FOREX). The customer asset is lodged with the cooperation partners. The support service relates to assistance for using the electronic transmission system provided to the customer by the cooperation partner or selected third party. The customer is electronically connected to the cooperation under the terms of a separate agreement between the customer and the cooperation partner and/or third party; consequently, the bank provides no connection software or hardware for the customer. The bank offers no investment advice, no investment brokerage and no financial services, even in case of a transmission system failure. In return for its services, the bank receives payments amounting to a percentage of the margins achieved by the market makers. In the fund sector, it receives a portion of the issuing premium. The business segment is called: FXFlat Konto GB, particularly for support services with the customer's business relationship with Interactive Brokers Ltd. FXFlat CapTrader and for fund units FXFlat HKK-Invest. - Negotiation of asset management contracts between customer and third party by way of the bank demonstrating to the customer the possibility of concluding asset management contracts. No investment advice is given, the bank does not intervene in the asset management process executed by the customer. The bank receives from the third party payments amounting to a percentage of the performance fee. This business segment is called: FXFlat HKK-Invest. - Provision of asset management services for customers in accordance with the agreed investment directives and fee rates. The brand name of this business segment for asset management relating to CFDs and options is FXFlat/CapTrader Managed Accounts (provided by FXFLAT HKK-Invest) and for other financial instruments, HKK-Invest.

II. General Information

Name and loading address: FXFlat Wertpapierhandelsbank GmbH, Kokkolastraße 1, 40882 Ratingen, Germany. Public Register: Düsseldorf County Court, HRB 44445, VAT ID No: DE218683071, Legal Agents: Rafael Neustadt, Martin Krüger, Michael Heyder, Samed Yilmaz. Primary business activity: The company trades in the financial commission business, as well as in financial portfolio management and investment and acquisition brokerage in accordance with the Banking Act. At present, investment counselling, finance leasing and factoring are not offered. Type and means of communication: Telephone (02102-100494-00), Fax (02102-100494-90), email (service@fxflat.com), use of the electronic trading system, mailbox in the customer's electronic trading system. Language for communication, information and agreements: Communication and information (including in provided documents) will be in German, the contractual language is German. No participation in any dispute settlement proceedings before a consumer arbitration board: FXFlat is under no obligation and not prepared in principle to participate in any dispute settlement proceedings before a consumer arbitration board. European platform for online dispute settlement: The European Commission provides a platform for online dispute settlement (OS) at ec.europa.eu/consumers/odr/. An overview of the arbitration boards recognised in Germany is available through this link. Responsible supervisory authority: BaFin – Federal Agency for Financial Services Supervision, Bank Supervision Graurheindorfer Str. 108, 53117 Bonn, Securities Regulators/Asset Management Marie-Curie-Str. 24-28, 60439 Frankfurt. Homepage www.bafin.de. Function, identity and address of other commercially active persons: Other commercially active persons with whom the customer may engage in business activities based on contracts are not authorized or empowered by FXFlat Wertpapierhandelsbank GmbH, in particular to offer investment advice, conclude agreements and issue statements. This also applies to liable "tied agents" (§ 2 Para. 10 KWG [German Banking Act]) of FXFlat Wertpapierhandelsbank GmbH; such agents are only entitled to operate as a contract facilitator and present opportunities for concluding agreements. The initiation and conclusion of contracts is solely the responsibility of FXFlat Wertpapierhandelsbank GmbH. The identity and address of tied agents registered within Germany can be obtained from the Federal Financial Supervisory Authority (BaFin) on the BaFin website (www.bafin.de database) in the "Register der gebundenen Vermittler" [Registry of tied agents]. Compensation schemes: FXFlat Wertpapierhandelsbank GmbH belongs to the compensation scheme for securities trading firms (see www.e-d-w.de) with an office at Behrenstraße 31, Berlin-Mitte, Postfach 10865, Berlin. The trustee bank at which FXFlat Wertpapierhandelsbank GmbH has deposited customer funds in trust in the FXFlat Konto DE segment is a member of the EDB Entschädigungseinrichtung deutscher Banken GmbH (see www.edb-banken.de), Burgstraße 28, 10178 Berlin and the voluntary Einlagensicherungsfonds des privaten Bankgewerbes (Deposit Protection Fund of the Association of Private German Banks). In regard to the specific requirements and scope of the securities, to see Section III. A) 3) b) aa). Validity period of the information: The information provided to the customer remains valid until further notice (as of April 2017) and until further information is forthcoming.

III. Service and contract-related information

A) Commission order execution (brand name FXFlat Konto DE) 1) Key features of the services The commission business service is offered for concluding a CFD (contract-for-difference) transaction or a foreign currency transaction (both also referred to as contract). This means the conclusion of a transaction by FXFlat Wertpapierhandelsbank GmbH with a third-party on behalf of the customer (commission business). The customer carries the credit risk of the third party, FXFlat is not liable for fulfilling the terms of the transactions concluded by the third party. The customer places the orders via the electronic trading system provided to the customer. This requires a payment onto a an escrow account, which is maintained by FXFlat Wertpapierhandelsbank GmbH as a omnibus trust account (i.e. no separation between customer funds, although customer funds remain separate from company funds) held at Wirecard AG, 85609 Aschheim. No interest is charged. A sufficient balance must be maintained in reference to the current contractual value depending on the current market value of the underlying asset and other requirements. The customer may therefore be forced to pay in additional contributions or liquidate the contract (exception starter package, see below). The maintenance of sufficient funds is gauged against the balance of the virtual CFD or currency account reported on the electronic trading platform. The provision of the trading system to conclude transactions with third parties (commission business) are governed by the current version of the "Special conditions for contracts for differences (CFD trade) and foreign exchange spot transactions (forex trade)". A CFD transaction or forex trade involves speculation in the future development of the underlying instrument (shares, indices, currency, etc.), with partial prepayment by the customer depending on the current underlying value relative to the contractual value, which is concluded by FXFlat Wertpapierhandelsbank GmbH on behalf of and on the account of the customer with third parties, or directly with the customer. CFD transactions and forex trade are accordingly associated with a certain level of risk to the customer; this risk is not restricted to the amount paid in by the customer (see risks listed under II. 5) and "Supplementary risk information on futures transactions in CFDs and forex trade"). a) Orders to conclude CFD transactions and foreign currency transactions (commission business) A CFD contract is an open speculation on differences in the development of the price of the underlying instrument. It involves exclusively the monetary settlement of the difference between the prices listed in the CFD contract by FXFlat Wertpapierhandelsbank GmbH (hereinafter: FXFlat) at the time of opening and the time of concluding the CFD contract. By using the trade system, the customer entitles FXFlat to open or close a CFD contract with third parties, which act as market makers (see IV below). Execution principles); FXFlat will attempt to execute this order. FXFlat does not provide investment advice. Corresponding claims and entitlements between FXFlat and the customer are generated by the legal and financial position between FXFlat and the market maker. Market makers submit prices during trading times which are posted to the customer in the electronic trading system by FXFlat; the customer is then entitled to place orders to open and close contracts. To open a CFD contract, a deposit must be made to the omnibus trust account (a so-called margin). During the term of the CFD contract, the customer is obligated to maintain sufficient

funds in this account. The customer deposits are employed by FXFlat to cover the margin and fulfillment requirements of the market maker, commission fees and other charges to the customer. Since the contractual value develops relative to the trend of the underlying instrument, additional funds may have to be paid in. In particular, the customer must provide sufficient coverage for reserve liability. The maintenance of sufficient customer funds in the omnibus trust account is gauged against the balance of the virtual CFD or currency account reported on the electronic trading platform. In the electronic trade system, the customer is continuously informed of the value of the contract and the balance resulting from his transactions. Without being obligated, FXFlat will make an effort to inform the customer of any pending necessity of additional contributions; the customer is however required to continuously monitor his or her transactions and the valuation of the contracts. If no additional deposits are made by the customer or are not made within a timely manner, the CFD contract will be terminated even though it may mean a loss to the customer. The customer is bound to fully satisfy all contractual obligations even if the contract is forcibly terminated. If no activity on the part of the customer is noted within a 30 day period and no new contracts have been opened, the customer will be refunded the share of funds in the omnibus trust account stipulated by banking regulations. For any contracts to be concluded after this time, new deposits must be made. The above holds true, including cash settlements in lieu of foreign currency, equally for orders to execute foreign exchange spot transactions with the following provision: Foreign exchange spot transactions constitute the exchange of one foreign currency into another freely convertible currency. The value date, i.e. the posting to the currency account, is two days after conclusion of the foreign exchange spot transaction. Foreign exchange, FOREX or FX currencies are foreign currencies in the form of book money. The exchange rate denotes the value of one currency in another currency. It is defined as the price (offered in the domestic currency) that must be paid for a certain amount of foreign currency. The price of the local currency is expressed in the foreign currency (indirect quotation). The exchange rate for the currency pair EUR/USD expresses the value of a euro in US dollars. The calculated margin, additional contributions and forcing out of orders to close CFD positions and foreign exchange spot transactions are considered collectively. This means that when the account does not have sufficient coverage for a foreign exchange spot transaction, the transaction may be forcibly closed which can also include the CFD position and vice versa. b) No investment advice / Information on the adequacy check FXFlat executes the customer's orders (commission business) without prior investment advice. FXFlat may only offer customers investment services without prior recommendation that are appropriate for the customer. FXFlat bears the responsibility of assessing whether an investment is appropriate for the customer. Investments are considered appropriate for the customer when they satisfy the customer's investment goals, when the associated investment risks are financially supportable, and when the customer is able to discern the associated investment risk drawing upon his her experience and expertise. In order to perform this assessment in the context of the business relationship, the customer must provide FXFlat with information about its knowledge and experience with financial instruments and investment services, as well as the customer's investment goals and financial situation. Before executing orders and transactions, FXFlat is obligated to use the available information to determine whether the customer possesses sufficient theoretical

expertise and practical experience to appropriately assess the risks associated with the specific order or transaction. The assessment may lead the customer to indicate that the order or transaction may be inappropriate. The order or transaction will then only be executed upon the customer's expressed approval. The records on the customer's experience and knowledge will be based on the information provided by the customer upon initiating the business relationship and from the orders and transactions executed. To the extent that FXFlat provides the customer with rate and market information, the purpose is to exclusively provide notification of third-party information which is not subject to a review by the securities trading bank. Furthermore, the evaluation of this data is the sole responsibility of the customer. The customer is not entitled to demand the communication of any rate or market information which would be relevant for the customer. c) No licensing or provision of the requisite hardware and software along with customer connection For commission trading, the bank operates an electronic trading platform to which the customer can connect in order to transmit orders to the bank electronically and/or conclude transactions. For this purpose, the customer requires transmission and connection software (frontend software), which is to be operated on the customer's electronic devices ("hardware"), and also an Internet or proprietary online service with Internet access ("connection and network access"). The customer is responsible for obtaining the relevant hardware and software, and also for ensuring that the connection meets the specifications and minimum requirements defined by the bank. The bank does not provide the customer with any hardware. The bank does not develop any software, transmission and connection software (so-called "frontends") in particular. Nor does it provide the customer with any proprietary or third-party software. The customer is responsible for validating the software (frontends in particular), which is a prerequisite for use of the trading system, acquiring such software, concluding appropriate licence agreements with third parties, as well as operating, maintaining and updating the transmission and connection software. The same applies for the connection and network access. d) Type, frequency and timing of the customer information about transactions Through the electronic trade system, the customer is supplied with current information on the execution of orders, transactions, fees and costs of the executed orders and transactions, realized and pending profits and losses, postings and the balance of the business account (virtual CFD and currency account) as well as margin requirements. Furthermore, the customer receives on the next day via email and/or their inbox of the electronic trading system, a balanced end of day report. The report summarizes the information in the electronic trading system from the previous day, and a financial report is also prepared two weeks after the end of the month. The customer is responsible for individually monitoring his positions and margin requirements and immediately paying into the omnibus trust account whenever necessary to achieve the required balance.

e) Risk indication and reference to rate fluctuations CFD and forex transactions are associated with their own unique risks based on the nature of the transactions. The following risks in particular should be stated: • Rate fluctuation risk for contract / rate fluctuation risk for underlying • Currency fluction risk • Total loss risk (not limited to pay-in) and obligation to make additional contributions • Credit risk (risk of default and/or insolvency) of the market maker • Credit risk (risk of default and/or insolvency) of FXFlat in case of market making by FXFlat The price of a customer's position is subject to fluctuations on the financial market, over which FXFlat has no control. Contracts are therefore not subject to revocation. The exchange rate of the customer's position can experience a significant negative downward trend and require matching contributions which may far exceed the original amount paid in. This is true especially with overnight positions. Past profits and increases in value are no indicator of future profits and value. More detailed information can be obtained in the informational brochures "Basic information", and especially "Supplementary risk information on futures transactions in CFDs and forex trade".

2) Key features of the agreement

Law governing the business relationship and the agreement, legal venue: German law applies; there is no clause stipulating jurisdiction for private customers. Conclusion of the agreement: The customer submits a binding offer to FXFlat on an agreement for concluding contracts for differences (CFD trade) and foreign exchange spot transactions (forex trade) by sending in the completed and signed forms to FXFlat, whereupon FXFlat accepts the offer; acceptance of the offer is signified by accessibility to the trading system. "Special conditions for contracts for differences (CFD trade) and foreign exchange spot transactions (forex trade)" apply to the business relationship between FXFlat and the customer as well as the individual transactions and orders. Minimum term of the agreement: There is no minimum term; the notification period is one-month. If the customer wishes to cancel the business relationship, all contracts must be terminated by the expiration of the notification period. If no activity on the part of the customer is noted within a 30 day period and no new contracts have been opened, the customer will be refunded the share of funds in the omnibus trust account stipulated by banking regulations. For any contracts to be concluded after this time, new deposits must be made. Details of payment and fulfillment: • Omnibus trust account: The customer is responsible for paying into and maintaining the required balance of the omnibus trust account at the FXFlat securities trading bank through Wirecard AG. FXFlat will credit this account with any profits or deduct any associated losses and charges at least monthly. The credit on the escrow account constitutes a security (proprietary trade) provided by the customer to the benefit of FXFlat or an advance (commission business) for concluding financial contracts for differences, or orders to conclude financial contracts for differences. These securities and advances provided by the customer may be used by FXFlat to settle the charges of the market maker (commission business), as well as all associated charges. Credit balances in the omnibus trust account do not accrue interest. FXFlat shall make

payments from the omnibus trust account to the reference account designated by the customer. • CFD account and foreign exchange account: The transactions made by FXFlat for and with the customer, including unrealised profits and losses and charges, are displayed in the electronic trading system on a daily basis and are summarized on the following trading day in a daily report and monthly in a monthly financial report, and offered to the customer in the agreed manner (a mailbox of the electronic trading platform or by e-mail). The CFD and foreign exchange account are the only binding records of mutual charges. • Opening and closing contracts: Commission business by FXFlat is considered fulfilled upon conclusion of a commission transaction with the market maker. The claims and charges arising from the commission transaction (profit and loss) are credited to or charged against the CFD or foreign exchange account of the customer in equal measure, including the service charges of FXFlat. • Customer contributions: Supplementary payments by the customer, especially to avoid forced termination of a contract, Must be made to the omnibus trust account within the deadlines cited in the "Special conditions for contracts for differences (CFD trade) and foreign exchange spot transactions (forex trade)". Forcing out does not release the customer from its obligation to fulfil the terms of the contract. • Trade-related communications: The customer is provided with notifications of transactions including open contracts and their valuation, notifications regarding contributions and postings to the omnibus trust account in the form agreed with customer (to the mailbox of the trading platform, by e-mail, or posting to the CFD/foreign exchange account). Prices, costs, taxes: • The current prices for services provided by FXFlat which are charged to the omnibus trust account as fees by FXFlat can be found in the current "List of price and services". Changes to prices are made in accordance with the guideline for changes in the "Special conditions for contracts for differences (CFD trade) and foreign exchange spot transactions (forex trade)". The current "List of prices and services" can be found on the website of FXFlat and can be sent on request. • FXFlat is entitled to collect from the customer due fees by way of the surcharge on the price stated by the market maker. Consequently, the bank is entitled to communicate to the customer the total price from the execution transaction price plus the commission, to collect by debiting from the omnibus trust account, to transfer the execution transaction price to the market maker and to retain the fees. • Costs to the customer which are charged as fees by FXFlat to the CFD or foreign exchange account also include the financing amount according to the "Special conditions for contracts for differences (CFD trade) and foreign exchange spot transactions (forex trade)" for overnight positions of the customer. These costs are itemized on the website of FXFlat under "contract specifications". • The funds held in the omnibus trust account also do not accrue interest; however, 8% interest per annum is charged as damage for delay if the customer maintains a negative balance. If the currency of the omnibus trust account is different than the currency of the underlying asset of a contract, customer costs also include the cost associated with converting the underlying asset currency into the account currency based on the valid rate of the European Central Bank for the business day. • The customer is responsible for bearing its own costs such as telephone charges or

postage. FXFlat does not charge separate communication fees. • Income from business transactions are generally taxable. Depending on the applicable tax law, capital gains and/or other taxes may be charged upon payment of earnings and profits from sales. These taxes are payable to the respective tax authority and correspondingly reduce the amount payable to the customer. Additional taxes may also be due that are not deducted directly by FXFlat. According to the "Special conditions for contracts for differences (CFD trade) and foreign exchange spot transactions (forex trade)", the customer directs FXFlat to automatically deduct any church tax of which FXFlat may be aware. In case of questions, the customer should consult its tax consultant or the tax authorities. • In addition FXFlat will receive a portion of any trade revenues of the market maker for commission transactions by the market maker. Information on these contributions is found under section V.

3) Special information on the omnibus trust account and compensation schemes

a) Omnibus trust account Customer funds are held in an omnibus trust account at Wirecard Bank AG ("Depository trust company") BIC: WIREDEMMXXX in the name of FXFlat. For euros, the IBAN is DE92 5123 0800 0000 0623 05; for Swiss francs, the IBAN is DE65 5123 0800 0000 0623 06. The trustee bank has been informed that the funds are not those of FXFlat but rather customer funds held in trust by FXFlat. FXFlat does not hold any funds in these accounts, and customer and company funds are kept separate from each other. Customer funds are held collectively in these accounts, that is, a separate account is not maintained for each customer. Rather, the funds of different customers are held collectively in a single account, and the customer's funds are only separated from each other in an accounting system. The obligation to maintain trust customer funds of different customers separate from each serves to protect trust customers. Separate accounts are maintained for each customer by assigning the individual funds to each customer in our accounting system. In the event of insolvency, the enforcement of a release claim may be easier when each customer has a separate account than is the case when each customer is merely listed separately in the accounting system. The customer is nonetheless informed that funds are not maintained separately in the escrow account from the funds of other customers (omnibus trust account). The customer funds are employed by FXFlat to cover the margin and fulfillment requirements of the market maker, commission fees and other charges to the customer. FXFlat is entitled to charge the share of these fees accruing to the customer to the omnibus trust account and withdraw and deduct the due amount. The customer funds in the omnibus trust account are not considered the assets of FXFlat or the assets of the depository trust company. Should FXFlat undergo bankruptcy, the creditors of FXFlat are not entitled to use the ominous trust funds to satisfy their claims, and the funds are accordingly insolvency-proof. If the depository trust company becomes insolvent, the customer becomes a creditor of the depository trust company, and the claim to payment against to the depository trust company corresponds to the share in the omnibus trust account. The claim to payment is legally insured up to €100,000.00 by the membership of the depository trust company in EDB Entschädigungseinrichtung deutscher Banken GmbH (see www.edb-banken.de), Burgstraße 28, 10178 Berlin. The depository trust company is also a member of the

Einlagensicherungsfonds des Bankenverbands deutscher Banken e.V. (see www.bankenverband. de), Burgstraße 28, 10178 Berlin, Postfach 040307, 10062 Berlin (see the following). b) Statutory compensation schemes aa) FXFlat Wertpapierhandelsbank GmbH FXFlat Wertpapierhandelsbank GmbH belongs to the compensation scheme for securities trading firms (referred to below as: "EdW") with an office at Behrenstraße 31, Berlin-Mitte, Postfach 10865, Berlin. EdW was established by the German Deposit Guarantee and Investor Compensation Act (previously investment security and investor compensation act) to provide coverage for the claims of investors and indemnify investors as a public service in accordance with the law and protect liabilities from securities transactions up to 90% of their value or a maximum of €20,000.00 per creditor. Obligations from securities transactions pursuant to the EAEG are those obligations of an institution to repay funds that are due to or belong to investors from securities transactions and that are held on their account in conjunction with securities transactions. These include investor claims to the return of instruments owned by the investors and are held on their account in conjunction with securities transactions. The cited financial instruments include securities such as shares, certificates representing the shares, bonds, participation certificates and subscription warrants, derivatives, etc. The claim to damages is gauged against the level of obligations accruing to the creditor from securities transactions with consideration of any offsetting and retention rights of the financial institution. In calculating the level of damages, the amount of the funds and the market value of the financial instruments upon the occurrence of the claim will be used. No claim for damages exists if the funds are not held in the currency of a member state of the European Union and in euros. The claim for damages extending to the maximum limit includes the interest accruing until payment of the claim. Claims to damages from erroneous advice are not covered. Investors such as banks and financial service providers, insurance companies, medium-sized to large stock corporations, as well as public companies are not protected. bb) The bank holding the omnibus trust account Note on the scope of the investment security by the bank holding the omnibus trust account: "Investments at Wirecard Bank AG Einsteinring 35 85609 Aschheim are protected by Entschädigungseinrichtung deutscher Banken GmbH (compensation scheme of German banks) 1 Security limit €100,000 per investor per credit institute 2 If you have several investments at the same credit institute All your investments at the same credit institute "added together" and the sum total is subject to the top limit of €100,000 2 If you have a joint account with one or several persons The top limit of €100,000 applies for each and every investor 3 Reimbursement deadline if a credit institute becomes insolvent 20 working days through to 31 May 2016 and/or 7 working days from 1 June 2016 4 Reimbursement currency euro Contact data for Entschädigungseinrichtung deutscher Banken GmbH Burgstraße 28 10178 Berlin Germany Postal Address: Postfach 11 04 48 10834 Berlin Germany Tel.: +49 (0)30 59 00 11 960 E-Mail: info@edb-banken.de Further information at www.edb-banken.de 5 (1) Your investment will be covered by a statutory investment security system and a contractual investment security system. If your credit institute becomes insolvent, your investments will be reimbursed up to an amount of €100,000. (2) If an

investment is no longer available because a credit institute is unable to meet its financial commitments, the investors will be compensated by the investment security system. The maximum sum covered is €100,000 per credit institute. This means, to determine this amount, all the investments held at the same credit institute are added together. If, for example, an investor holds €90,000 on a savings account and €20,000 on a current account, he will be reimbursed only €100,000. (3) For joint accounts, the top limit of €100,000 applies for each investor. Investments on an account over which two or more people as members of a partnership or society, an association or similar merger without legal personality have the power of disposal, are, however amalgamated and treated as the investment of a single investor in the calculation of the top limit of €100,000. In case of Section 8, paras. 2 to 4 of the Investment Security Act, investments of more than €100,000 are secured. Further information can be obtained from the website of Entschädigungseinrichtung deutscher Banken GmbH, www.edb-banken.de. (4) If you do not receive the reimbursement by these deadlines, you should contact the compensation scheme, since the validity period for reimbursement claims may expire after a certain time. Further information can be obtained from the website of Entschädigungseinrichtung deutscher Banken GmbH, www.edb-banken.de. (5) Investments of private customers and companies are generally covered by investment security systems. Exceptions that apply for certain investments are announced on the website of the compensation scheme concerned. Your credit institute will inform you, on request, whether certain products are covered or not. If investments are covered, the credit institute will also confirm this on the account statement. The bank is a member of the Einlagensicherungsfonds des Bundesverbandes deutscher Banken e.V. (Deposit Protection Fund of the Association of German Banks) and the Entschädigungseinrichtung deutscher Banken GmbH (Compensation Scheme of German Banks). All obligations falling under the balance sheet item of "liabilities customer" are insured on the basis of these provisions. This includes demand, time and savings deposits as well as the savings bonds in their name. Up until 31 December 2019, the security limit per creditor is 20%, up until 31 December 2024 15% and from 1 January 2025 8.75% of the equity capital of the bank essentially liable for the investment security. For investments justified or extended after 31 December 2011, the new security limits from the aforementioned effective dates shall apply, regardless of the investment justification. For investments justified prior to 31 December 2011, the old security limits up until the investment matures or up until the next possible termination date shall apply. The bank shall announce the respective security limit to the customer on request. It can also be found online at www.bankenverband.de. Those liabilities for which the bank has issued bearer securities, such as bearer bonds and bearer certificates of deposit, as well as liabilities to banks, are not protected. Security of liabilities from securities transactions If, contrary to its obligation, the bank is incapable of returning the customer's securities, a claim to reimbursement exists from the Entschädigungseinrichtung deutscher Banken GmbH in addition to the compensation due from the bank's own liability. The claim on the compensation scheme is limited to the 90% of the value of this security, the maximum being the equivalent of €20,000. In the case of Wirecard Bank AG, the deposit guarantee ceiling is €6,403,000. The compensation claim with respect to securities remains unaffected.

4) execution policy in commission business and execution venues

The following guidelines on the execution of orders in commission business constitute internal provisions stipulated by FXFlat to achieve the best possible outcome for the customer. It does not constitute a violation of the commitment to achieve the best possible result when executing orders if FXFlat fails to achieve the best possible result in individual cases despite executing the order in line with the execution guidelines. FXFlat operates as an agent acting on commission in accordance with the relevant passages of the "Special conditions for contracts for differences (CFD trade) and foreign exchange spot transactions (forex trade)". Accordingly, FXFlat exclusively engages in execution transactions by concluding CFD and foreign exchange spot transactions with a market maker presently residing in Great Britain. Please refer to the execution policy of the market markers concerned for both the pricing strategy and business activities of the market makers leading to the conclusion of executions transactions between FXFlat and the market maker on behalf of the customer. Please observe: www.fxflat.com/de/execution-policy/. Changes and additions will be announced on the trading platform. These market makers function as the arena for the execution of the customer's orders; orders will not be executed in a regulated market (such as a stock exchange) or a multilateral trading system. The pricing and business activities of the market maker leading to the conclusion of executions transactions between FXFlat and the market maker on account of the customer are dependent on certain givens with which the market maker is confronted such as market trends and the estimation of the base value, unusual market situations, hedging options of the market maker, or the readiness and speed of the trading system of the market maker. FXFlat has no influence on these factors. FXFlat will regularly monitor the execution quality and subjected to a review at least once annually and will intervene if necessary.

5) Special conditions for the starter package

Customers with low payments onto the omnibus trust account are offered a starter package. This differs from the standard business relationship in that it involves no obligation to make additional contributions and has a lower leverage ("Starter conditions"). It applies to customers whose payment onto the omnibus trust account is less than €5,000.00 when the business relationship is started. Insofar as such customers, after entering into a business relationship, have a balance during the day or at the end of the day on the omnibus trust account of over €5,000.00, the starter conditions shall cease to apply 2 weeks after the customer gives their written consent; if the customer fails to give their consent after written request for a period of 3 weeks, the bank shall be entitled to termination without notice. The bank is entitled, on the basis of its equitable discretion, to refuse within this 3-week period customer orders, the scope of which is disproportionate to the release from the additional contribution obligation of the starter package that continues in place during this time (i.e. no advanced trading at starter package conditions, particularly if the €5,000.00 threshold is exceeded as a result of customer payments); the same applies for the closing out of customer positions. The starter conditions do not apply to customers for whom the starter conditions no longer apply but whose balance during the day or at the end of the day on the omnibus trust account is less than €5,000.00 (i.e. retrospective underrun of the €5,000.00 threshold does not lead to the waiver of

the additional contribution obligation and lower leverages). B) Support service for use of a third-party system (brand names FXFlat CapTrader, FXFlat Konto GB and FXFlat HKK_Invest) 1) Essential features of the service a) Support service for use of a system of the customer bank The customer holds an account and/or securities account at a domestic or foreign credit institute for the purposes of trading with financial instruments (customer bank). For his trading activity, his account-holding and/or custodian credit institute provides him with an electronic order transmission system, via which he can transmit to his account and/or custodian credit institute orders or requests to conclude financial instrument transactions (system). The rights and obligations of the account-holding and/or custodian credit institute and of the customer concerning the order transmission system, order execution and business activity are set out in bilateral contracts between these parties. FXFlat is granted access to the customer's business activity and offers the customer support services for the use and operation of the order transmission system of the account-holding and/or custodian credit institute. Investment brokerage services are not provided, i.e. declaration of intent by the customer for the acquisition or sale of financial instructions or for contract conclusions are not transmitted to the customer's contracting partner - even in case of system failure. b) Support service for use of an alternative third-party system Insofar as the account-holding and/or custodian credit institute permits, instead of or parallel to the order transmission system of the account-holding and/or custodian credit institute, the customer to use a third-party order transmission system and the bank includes this third-party system into the support spectrum, the bank shall offer the customer support services for use and operation of the third-party system. The rights and obligations of the account-holding and/or custodian credit institute and of the customer concerning the order transmission system, order execution and business activity are set out in bilateral contracts between these parties. the rights and obligations of the third-party system provider and of the customer concerning the third-party system are set out in bilateral contracts between these parties. Investment brokerage services are not provided, i.e. declaration of intent by the customer for the acquisition or sale of financial instructions or for contract conclusions are not transmitted to the customer's contracting partner - even in case of system failure. c) Scope and limits of the support services The bank supports the customer for use of the electronic transmission system and for executing transactions on the basis of the data and information provided by the account-holding credit institute and/or the third-party system provider. Comprising in particular: - support services for installation of the transmission software - setup of a telephone Help Desk to support operation of the transmission software - setup of a telephone Help Desk to support to support execution and settlement of the transactions - support services through forging contacts between responsible employees of the account-holding and custodial credit institute and the customer, especially by means of telephone conferences - offer of regular training for use and operation of the electronic transmission system and for any new products. The customer hereby warrants that it has verified the quality and compliance with quality descriptions of the transmission system, the

ability of the transmission system to be connected to and integrated into the account-holding and custodian credit institute and the hardware and software equipment of the customer, as well as the suitability of the transmission systemto meet the customer's requirements. The bank does not check the aforementioned circumstances. d) No liability for the system The bank accepts no liability for damage or lost profit incurred by the customer due to the complete or partial failure or such malfunction of the electronic transmission system provisioned by the account-holding and/or custodian bank or third party to the customer. e) No investment brokerage and no investment advice Investment brokerage services regarding "Support service for use of a system of the customer bank" and "Support service for use of an alternative third-party system" are not provided, i.e. declaration of intent by the customer for the acquisition or sale of financial instructions or for contract conclusions are not transmitted to the customer's contracting partner - even in case of system failure. The electronic transmission system, including any contingency and back-up systems, is operated solely by the account-holding and custodian credit institute and/or the provider of the third-party system, such operation being governed exclusively by the contractual agreements between customer and account-holding and custodian credit institute and third-party system provider. The bank has no possibility to intervene in the electronic transmission system, no proprietary system to replace the electronic transmission system in case of emergency or failure and no authority to otherwise act with effect for the customer in an order mediation capacity. Consequently, the bank will in not in particular enter any orders, requests, messages or other declarations of intent or data for the customer into the electronic transmission system or transmit, in any other way, orders, requests, messages or other declarations of intent or data for the customer or in the way proposed by the account-holding and custodian credit institute and/or the third-party system provider in case of emergency or failure. Consequently, the customer is responsible for taking precautions to cover any transmission system failure. The "Support service for use of a system of the customer bank" and the "Support service for use of an alternative third-party system" do not involve any investment advice by the bank. The bank's employees are given strict instructions not to advise the customer on buying or selling financial instruments, either as part of advertising measures, entering into the business relationship with the customer or in pursuing the business relationship. There is no active sending or active reference to information documents, either created by the account-holding or custodian credit institute of the customer or issuer of the financial instrument or provided (basic information, key investor documents, product information sheet, sales brochures). 2) Key features of the contract Law governing the business relationship and the agreement, legal venue: German law applies; there is no clause stipulating jurisdiction for private customers. Conclusion of the agreement: The customer submits a binding offer to FXFlat on an agreement for concluding a contract by sending in the completed and signed forms to FXFlat, whereupon FXFlat accepts the offer. Hence, the "Special Conditions for the support

services when using a third-party system" apply for the business relationship between FXFlat. Minimum term of the agreement: There is no minimum term; the notification period is one-month. Details on payment and fulfillment: In all divisions of this segment (i.e. FXFlat CapTrader, FXFlat Konto GB and FXFlat HKK-Invest), FXFlat receives payments. Detailed information on this is provided in the information section below entitled "Dealing with conflicts of interest and payment information". The customer does not make direct payments to to FXFlat. FXFlat essentially fulfills its support obligations maintaining a Hotline and provisioning personnel. Prices, costs, taxes: The current prices for services provided by FXFlat which are charged to the omnibus trust account as fees by FXFlat can be found in the current "List of price and services". The current "List of prices and services" can be found on the website of FXFlat and can be sent on request. The customer is responsible for bearing its own costs such as telephone charges or postage. FXFlat does not charge separate communication fees. Income from deals transacted with third parties are usually taxable. Depending on the applicable tax law, capital gains and/or other taxes may be charged upon payment of earnings and profits from sales. These taxes are payable to the respective tax authority and correspondingly reduce the amount payable to the customer. C) Negotiating an asset management contract (brand name FXFlat HKK-Invest) 1) Key features of the service The bank communications the conclusion of asset management contracts between the customer and third parties. An asset management contract is mediated by provisioning the contract documents and customer information documents of the third party for the customer, and also by obtaining the customer details and passing on such details to the third party (required for mediating an asset management contract). Insofar as the customer gives the bank power of attorney over the account and securities account, the bank will not exercise such power of attorney, even in an emergency. The mediation of an asset management contract does not involve any investment advice by the bank. No check by the bank to establish whether the specific offer meets the customer's investment goals, whether the associated investment risks are financially supportable, and whether the customer is able to discern the associated investment risk drawing upon his her experience and expertise. Release from banking secrecy, data inspection rights and data protection For the services of the bank, the customer releases the bank and the third party from the banking and data secrecy obligation, as required to provision the services and grant payments. 2) Key features of the contract Law governing the business relationship and the agreement, legal venue: German law applies; there is no clause stipulating jurisdiction for private customers. Conclusion of the agreement: The customer submits a binding offer to FXFlat on an agreement for mediating a contract by sending in the completed and signed forms to FXFlat, whereupon FXFlat accepts the offer. Hence, the "Special Conditions for the negotiation of an asset management contract" apply to the business relationship between FXFlat. Minimum term of the agreement: There is no minimum term; there is no notification period. Details on payment and fulfillment: In this segment, FXFlat receives payments. Detailed information on this is provided in the information section below entitled "Dealing with conflicts of interest and payment information". The

customer does not make direct payments to to FXFlat. Prices, costs, taxes: The current prices for services provided by FXFlat which are charged to the omnibus trust account as fees by FXFlat can be found in the current "List of price and services". The current "List of prices and services" can be found on the website of FXFlat and can be sent on request. The customer is responsible for bearing its own costs such as telephone charges or postage. FXFlat does not charge separate communication fees. Income from deals transacted with third parties are usually taxable. Depending on the applicable tax law, capital gains and/or other taxes may be charged upon payment of earnings and profits from sales. These taxes are payable to the respective tax authority and correspondingly reduce the amount payable to the customer.

IV. Dealing with conflicts of interest and payment information

A) Conflicts of interest and the receiving/granting of payments The policy of FXFlat on dealing with conflicts of interest and received and granted payments is addressed below. FXFlat seeks to identify and avoid conflicts of interest associated with its business activity which may arise between itself and the customer, and will provide notification of any unavoidable conflicts of interest. FXFlat has identified the following circumstances as significant, potential conflicts of interest: FXFlat might be inclined, by pricing as the market maker in the spread and by adding surcharges to the spread beyond the amount necessary to finance its activities, to minimise the price change risk of the contract, which would be reflected as an elevated risk to the customer. When executing the customer's orders to conclude transactions (commission business), a potential conflict of interest exists in the customer seeking to engage in trading to the benefit of colleagues for the sake of commission. Furthermore, potential conflicts of interest exist in general business activity that can arise from cooperation (in particular payments from market makers), the receipt or granting of payments. FXFlat receives the following payments: - Commission business (brand name FXFlat Konto DE): The bank receives contributions from market makers in executing customer orders on commission. Per transaction type or transaction in instruments, the bank receives a share of up to 65% of the profit obtained by the market maker from the execution transaction. Further details will be provided upon request. The customer hereby agrees that these payments will be made by the market maker to the bank and may be received by and retained at the bank. To this end, it is hereby agreed that the customer possesses no claims for surrender against the bank or the market maker. This provision is to provide a secure basis for the technical infrastructure and variety of services as well as cost-effective execution of orders. - Support services for use of a third-party system (brand names FXFlat CapTrader, FXFlat Konto GB) In return for support services, the bank receives payments from the market makers (brand names CapTrader and FXFlat Konto GB). Per transaction type or transaction in instruments, the bank receives a share of up to 65% of the profit obtained by the market maker from the execution transaction. Further details will be provided upon request. The customer hereby agrees that these payments will be made by the market maker to the bank and may be received by and retained at the bank. To this end, it is hereby agreed that the customer possesses no claims for surrender against the bank or the market maker. This provision is to provide a secure basis for the technical infrastructure and variety of services as well as cost-effective execution of orders. The bank receives payments from the account-holding and/or custodian credit institute for investment funds of the customer (brand name

FXFlat HKK-Invest) of up to 100% of the offering premiums and up to 100% of the management fee. The bank will provide further details upon request. The customer hereby agrees that these payments will be made by the market maker to the bank and may be received by and retained at the bank. To this end, it is hereby agreed that the customer possesses no claims for surrender against the bank or the payment-granting third party. This provision is to provide a secure basis for the technical infrastructure and variety of services as well as cost-effective system setup. - Mediation of an asset management contract (brand name FXFlat HKK-Invest) The bank receives payments from the asset manager of up to 100% of the performance fee. The bank will provide further details upon request. The customer hereby agrees that these payments will be made by the third party to the bank and may be received by and retained at the bank. To this end, it is hereby agreed that the customer possesses no claims for surrender against the bank or the third party. This provision is to provide a secure basis for the technical infrastructure and variety of services as well as cost-effective execution of orders. FXFlat receives the following payments: - Brand names FXFlat Konto DE, FXFlat CapTrader, FXFlat Konto GB: The customer consents to the bank making payments to cooperation partners and affiliated agents to the extent required by the German Banking Act. These payments comprise a percentage of the remuneration provided by the customer to the bank. The cooperation partners or affiliated agents will received up to 0.0025% of the volume traded in CFDs by the customer, and a payment up to 5.50 USD for foreign exchange spot transactions (sales and purchases) per lot (unit: 100,000). The precise level of the payment will be communicated to the customer upon request. The customer hereby agrees that these payments will be made by the bank and will be retained by the cooperative partners or affiliated agents. This provision is to provide a secure basis for the technical infrastructure and variety of services as well as cost-effective system setup - brand names FXFlat CapTrader and FXFlat HKK-Invest: The customer declares its consent to payments by the bank to cooperation partners and associated brokers in accordance with the German Banking Act. These payments comprise up to 100% of the payments collected. The precise level of the payment will be communicated to the customer upon request. The customer hereby agrees that these payments will be made by the bank and will be retained by the cooperative partners or affiliated agents. This provision is to provide a secure basis for the technical infrastructure and variety of services as well as cost-effective execution of orders. B) Dealing with conflicts of interest FXFlat has undertaken preventative measures to avoid conflicts of interest. These include pricing guidelines for employees involved in proprietary trade, a ban on investment counselling to avoid the inherent risk of currying favouritism in customer orders, and monitoring the pricing and quality of the market makers (commission business and support services). Furthermore, FXFlat requires its employees to carefully and honestly offer services in the interest of the customer. As an additional preventative measure, FXFlat has established an independent compliance center to ensure that the internal, statutory and contractual requirements governing interactions with customers are maintained. This also includes the disclosure and monitoring of the private business activities of all employees. Employees also undergo regular training.

V. Right of revocation and consequences

The customer is entitled to rescind the declaration of intent to conclude the agreement on concluding contracts for differences (CFD trade) and foreign exchange spot transactions (forex trade) as follows (when there are several parties, each party is entitled to rescind): Right of revocation You shall be entitled to revoke your contractual statement within 14 days, without stating reasons, by means of a clear statement. The term starts upon receipt of the statement recorded on a permanent data carrier, however not before the conclusion of the agreement, and also not before the fulfillment of our informational obligations pursuant to Article 246b, § 2, para. 1 in conjunction with Article 246b, § 1, para. 1 EGBGB, also not before the fulfillment of our informational obligations pursuant to Article 246b Section 2, para. 1 in conjunction with Section 1, para. 1, number 7 to 12, 15 and 19, as well as Article 248, Section 4, para. 1 EGBGB. The timely dispatch of the revocation shall be deemed sufficient for compliance with the term of revocation, providing that the statement is on a permanent data carrier (such as a letter, fax or e-mail). The revocation must be sent to: FXFlat Wertpapierhandelsbank GmbH, Kokkolastraße 1, 40882 Ratingen, Germany, telephone: 02102-100494-00, fax: 02102-100494-90, e-mail service@fxflat.com. • Consequences In the event of effective revocation, the services received by both parties must be returned. If your account is overdrawn without an agreed overdraft facility, or if the agreed overdraft facility is exceeded, we are not entitled to demand costs or interest beyond the repayment of the overdraft amount, or beyond the amount exceeding the agreed overdraft facility, if we have not properly informed you of the conditions and consequences of overdrawing or exceeding (such as the applicable borrowing rate and costs). You are under an obligation to pay compensation for the services rendered up to the point of revocation if you have been informed of these legal consequences before submitting your contractual statement and have given your express consent that we can start executing the consideration before the end of the revocation term. If an obligation exists to pay compensation, you may nonetheless be required to fulfil contractual payment obligations for the period until the timer of revocation. Your right of revocation shall expire prematurely if, in response to your expressed wishes, the contract is fulfilled in toto by both parties before you exercise your right of revocation. Obligations to reimburse payments must be satisfied within a period of 30 days. For you, the period for this commences when you send your declaration of revocation; for us, it commences upon receipt. • Special notes Should this agreement be rescinded, you are no longer bound to any other agreement associated with this agreement when the associated agreement relates to services rendered by us or a of third party based on an agreement between us and the third party. • End of revocation instructions No right of revocation exists for individual transactions with financial instruments whose price is subject to fluctuations on the financial market over which the bank has no influence and which may arise during the term of revocation. End of information on the agreement and associated services.