APPROVED

by Order No. 109/1-о of the

Director of Pixel Internet Closed

joint-stock company dated

01.10.2025 as amended and

approved by Order No. 32-o dated

04.03.2026, No.41-o dated

31.03.2026

Shall come into effect on 01.04.2026

AGREEMENT FOR PARTICIPATION IN TOKEN TRADING

(for legal entities and individual entrepreneurs)

This agreement for participation in token trading (hereinafter referred to as the

“Agreement”) is concluded by and between Pixel Internet Closed joint-stock company

and the Client

of the Company by accepting this Agreement in electronic form, putting

a mark of consent with the terms hereof and other documents that are an integral part

hereof. The mark of consent

(expression of the Client’s consent to conclude the

Agreement on the offered terms) is affixed by the Client at the time of creating the

Client’s Account (personal account) in the Trading System.

1. SUBJECT OF THE AGREEMENT

1.1. According to this Agreement, the Company undertakes to organize token trading,

and the Client undertakes to pay remuneration to the Company in accordance with the

rules for determining the size and procedure for collecting cryptoplatform operator’s

remuneration from the clients.

1.2. The Company shall organize token trading by providing:

(a) access to the User and/or the Client to the Company’s Trading System and

technical support when using the Trading System;

(b) the Client with an opportunity to perform actions necessary to ensure holding

token trading, including when the Client performs trading with the use of Borrowed

Tokens, including depositing Funds to eWallet, sending (placing) Applications for token

acquisition (disposition, exchange), withdrawing Funds from eWallet.

1.3. Only tokens that are admitted by the Company to token trading in the Trading

System in accordance with the rules established by Company’s internal regulations can

be traded. The list of tokens admitted to token trading is posted on the Company’s

Website and/or in the Company’s mobile Application, if such functionality is provided

by the Company.

1.4. The Company can act as a party in transactions between the Client and the

Company, and depending on the transactions, it can act as a seller, a buyer, and under

any circumstances as an organizer of token trading with corresponding responsibilities

Hereinafter, in the text of this Agreement, as well as in other documents that are an integral part hereof, Pixel Internet Closed

joint-stock company may be referred to as the Company.

Prior to successful Verification and obtaining the status of a Trading Member, the Client acts solely as a User with the

appropriate rights and obligations.

The consent note may include appendices to the Agreement, as well as other documents that, although not part of the

agreement, contain provisions on pre-contractual relations or regulate other related legal relations between the User (Client)

and the Company.

for organizing token trading, as well as an organizer of transactions (operations)

permitted by applicable law.

1.5. The Company has the right to carry out transactions on behalf of and on the

instructions of the Client or on its own behalf and on the instructions of the Client. The

relationship between the Client and the Company arising in connection with such

transactions is regulated by a separate agreement between them.

1.6. The Client trades with the receipt of Borrowed tokens in accordance with the

Rules for trading with the receipt of Borrowed tokens approved by the Company and

published on the Company’s Website and/or in the Company’s mobile Application, if

such functionality is provided by the Company. The rules for trading without receiving

Borrowed tokens are governed by the Rules for trading digital signs (tokens) approved

by the Company and published on the Company’s website and/or in the Company’s

mobile Application, if such functionality is provided by the Company.

1.7. Prior to the assignment of the status of a Trading Member, the Company provides

the User with limited functionality to familiarize himself with the technical capabilities

of the Trading System.

1.8. All third-party software products (applications, etc.) are not a product of the

Company, and the Company is not responsible for the content of software products, for

the actions of third parties or the operation of the program created by third parties. At

the same time, the Company has the right to conclude a cooperation agreement with the

owners of a particular software product and integrate the Trading System and the

software product. In this case, the Company acts as the operator of the cryptoplatform,

but other relations on access services to applications, processing of personal data of

individuals related to the Client as representatives of the clients of the corresponding

applications, the scope of rights and obligations within the framework of the applications

are established directly between the User (Client) and the owner of the software product

within the framework of product functionality.

2. RIGHTS OF THE USER AND THE CLIENT

2.1. In accordance with the terms and restrictions set forth herein,

2.1.1. The User is entitled to:

(a) create an Account (personal account) in the Company’s Trading System;

2.1.2. The Client is entitled to:

(b) deposit Funds to the eWallet;

for token exchange (acquisition, disposition) of tokens;

(d) withdraw Funds from eWallet and transfer them to their own current (settlement)

bank accounts, bank cards, e-wallets, addresses (identifiers) of virtual wallets;

(e) by agreement with the Company and subject to the technical capability of the

Company make other transactions (operations), provided that such transactions

(operations) do not contradict the legislation.

2.1.3. The User and/or the Client are entitled to:

(f) exercise other rights in accordance with the legislation of the Republic of Belarus,

this Agreement and other documents that form an integral part hereof.

2.2. The Client, among other things, has the right to request and receive clarifications

on the procedure for exercising their rights, on the procedure for using the Trading

System, on the documents (internal regulations) under consideration (to which a

reference is made) in this Agreement.

2.3. Should the Company violate the rights of the Users and/or the Clients, the latter

shall have the right to protect the violated rights in accordance with the civil legislation

of the Republic of Belarus. The Clients, among other things, have the right of

termination by the Company of the actions violating or creating a threat of violation of

the Clients’ rights; restore the situation that existed before the violation of law;

compensation of losses and/or other remedies depending on the type of violation and the

consequences of such violation, as well as the substance of the violated rights.

2.4. If the User and/or the Client believe that their rights have been violated, they are

entitled to send to the Company a corresponding claim to the e-mail address:

corporate@free2ex.com (in the mobile Application, if such functionality is provided by

the Company; redirection is performed automatically from the Help & Support →

15 days from the date following the day of receipt of the claim to the e-mail address

corporate@free2ex.com, or within 30 days if the User and/or the Client’s claim requires

additional consideration and verification. The Company makes reasonable efforts to

reduce the time for consideration and forwarding responses to Clients’ requests.

The above mentioned provisions do not limit the right of the User and/or the Client

to send to the Company an appeal in writing in accordance with the Law of the Republic

of Belarus dated 18.07.2011 No. 300-З “On Claims from Citizens and Legal Entities”,

to send a claim in accordance with clauses 17.2-17.6 hereof.

2.5. The User and/or the Client, his representatives, has the rights and obligations

provided for by the Privacy Policy approved by the Company and published on the

Company’s Website and/or in the Company’s mobile Application, including the right to

establish restrictions on the handling of personal data; the right to receive personal data

held by the Company in a structured form in the form of a typewritten text; the right to

demand the correction of errors (inaccuracies) in personal data; the right to demand the

deletion (destruction) of personal data held by the Company; the right to demand

notification of third parties to whom personal data were transferred about the correction

of errors (inaccuracies) in them and the fact of their deletion (destruction); the right to

object to the handling of personal data; the right not to be exposed to a decision made

only on the basis of automated handling of personal data; the right to receive transparent

information on the procedure for exercising the above stated rights. The Privacy Policy,

approved by the Company and published on the Company’s website and/or in the

Company’s mobile Application, if such functionality is provided by the Company,

defines the functions of persons responsible for ensuring the protection of information

in terms of personal data protection and includes the Company’s contact information.

3. OBLIGATIONS OF THE USER AND THE CLIENT

3.1. The User and/or the Client is obliged to:

(a) provide the Company with the necessary data (documents, information) to

undergo the Identification and Verification procedure in accordance with rules of

obtaining by the client the status of a Member in token trading (admitting a client to

token trading) and exclusion of the client from the number of Members in token trading

(deprivation of the status of a token trading Member), as well as throughout the term

hereof, at the request of the Company (or the identification agent with whom the

Company has a contract for the transmission of customer data), provide the necessary

information and documents within the time frame established by the Company;

(b) not use technical failures that may occur during the operation of the Trading

System in a manner that may be contrary to the interests and/or violate interests of other

Trading Members and/or the Company;

benefit for themselves or other persons, or cause any damage (harm) to other persons;

(d) not carry out wrongful (illegal) use of insider information about tokens

;

(e) independently and in a timely manner monitor changes in information published

by the Company on the Website (including types and sizes of commissions, including

swaps, and fees, trade details of the transaction (minimum lots, maximum lots and

increments), the text of this Agreement and other documents, Company’s internal

regulations);

(f) maintain in working condition the e-mail address that was communicated to the

Company when creating an Account (personal account) in order to properly receive

notifications or warnings that the Company may send to the Client;

(g) perform other obligations in accordance with this Agreement and the legislation

of the Republic of Belarus.

3.2. The Client shall:

(h) notify the Company of any changes in the data (information) specified in part (a)

of the clause 3.1. within three days from the date of occurrence of the relevant changes;

(i) pay remuneration to the Company when performing various transactions

(operations) with tokens in the Company’s Trading System, as well as for Account

maintenance for the purpose of carrying out transactions (operations) with tokens

;

(j) not manipulate the prices of tokens;

(k) maintain the required amount of Funds for automatic commission deduction in

the relevant payment currency under the Agreement in accordance with section 11.

4. RIGHTS OF THE COMPANY

4.1. The Company has the right to:

(a) grant the Client the status of a Trading Member, as well as deprive the Client of

the status of a Trading Member should the Client violate the legislation governing the

issues related to placement of tokens, their trading and other their circulation, and/or this

Agreement, and/or internal regulations of the Company, and inclusively performs

actions entailing violation of the rights and legitimate interests of other persons;

(b) request information and documents from the User and/or the Client, including for

the purpose of implementation of Identification and Verification in accordance with the

rules for obtaining the status of a token trading member by the client (admitting a client

Improper (illegal) use of insider information about tokens can be carried out by using this information for personal

purposes (including to participate in token trading on their own behalf and at their own expense), as well as

transferring it to third parties, except for cases established by regulatory acts of the Republic of Belarus.

In accordance with the rules for determining the amount and procedure for charging the remuneration of the

operator of cryptoplatforms from clients.

to token trading), and excluding the client from the number of token trading members

(revoking the status of a token trading member), legislation on the prevention of

Legalization of proceeds; request information from the User for registration (partial

Identification) in order to create an Account;

including the deposit and withdrawal of Funds from eWallet, also if the Company has

suspicions that the Client has violated the legislation governing the placement of tokens,

their trading and other circulation, legislation on the prevention of Legalization of

proceeds (hereinafter – AML/CTF), and/or this Agreement, and/or internal regulations

of the Company, and inclusively performed actions entailing violation of rights and

legitimate interests of other persons;

(d) reject the Client’s request to carry out a financial transaction

, if it meets the

criteria for identifying and signs of suspicious financial transactions, which, according

to the Company’s internal control rules, may be grounds for refusing to carry out a

financial transaction;

(e) suspend a financial transaction, but for no more than three business days,

including the day when the Client’s order to carry it out is to be executed, in order to

make a decision to carry out a financial transaction or refuse to carry it out;

(f) unilaterally refuse to execute this Agreement if there are two or more decisions

to refuse to carry out the Client’s financial transactions within six months;

(g) release application programs, versions, applications that represent the capabilities

of the Trading System and/or Trading Platform, both with limited and extended

functionality. If the ability to enter data, perform any functions in such programs and

applications is limited, the main channel of interaction with the Company is the Web

version of the Client’s Personal Account;

(h) conduct promotional events, organize loyalty programs, and other promotions. In

such a case, any Company has the right to establish the conditions of programs and

promotions, according to which any User may be unwittingly involved by other

participants of the program, and at the time of registration or transactions, he may not

be aware of the fact that he will create the basis for accrual of interest in other

participants of programs and promotions by his operations;

(i) acting unilaterally and out of court, amend the terms hereof in whole or in part,

including with respect to the Company’s remuneration and other obligations of the User

and/or the Client;

(j) in cases stipulated by AML/CFT legislation, as well as if the Company suspects

the commission (possibility of commission) of actions that may be classified as

fraudulent or are fraudulent in the subjective opinion of the Company, request

information and documents from the Client for analysis on the committed (planned)

transactions, explanations about the economic content of the transaction, the source of

funds, etc. (if necessary).

(k) block the client’s account if the Company suspects the commission (possibility

of commission) of actions that may be classified as fraudulent or are fraudulent in the

subjective opinion of the Company.

A financial operation for the purposes of subclauses (d), (e), (f) means a transaction using Funds irrespective of the form or

manner of its carrying out, including depositing and withdrawing Funds to/from the Trading System of the Company.

(l) take legal, organizational and technical measures to identify and prevent Users

from making unauthorized payment transactions and transactions with tokens using the

Company’s Information System;

(m) exercise other rights stipulated by the provisions of this Agreement and/or

internal regulations of the Company.

4.2. The Company is entitled to make transactions with the Client’s tokens on its

own behalf, in its own interests and, in the absence of the Client’s assignment (order),

if all the following conditions are observed:

(a) these transactions are aimed at obtaining liquidity by the Company, that is, to

receive Monetary Funds and tokens from Liquidity providers, in order to fulfill the

Company’s obligations to its Clients assumed or planned to be assumed by the

Company;

(b) Liquidity providers are legal entities that have a special permit (license) or any

other authorization document issued by the competent authorities (competent

organizations) of the countries in which these legal entities are established and are

actually located, and provide for the right to perform transactions (operations) with

tokens (if in the country of registration this type of activity is subject to licensing);

and tokens of trading Members who have given their consent stipulated by this

subclause;

(d) the Company reasonably believes that consummation of these transactions will

not result in non-performance (improper performance) of the obligation to withdraw the

Funds from the Company’s Trading System in respect of the trading Members with

whose Monetary Funds and/or tokens the relevant transactions are made.

4.3. In case due to circumstances beyond the reasonable control of the Company

and/or circumstances initiated by third parties, an exchange and/or further transfer of

Funds (including certain types of Funds: tokens, etc.) becomes impossible and/or

excessively expensive, including in the event of delisting of certain tokens

(tokenized assets), the Company, if it is aware of such circumstances, takes measures

to notify the Clients. If, after such notification, the Client has not taken measures to

exchange the relevant Funds (has failed to exchange Funds) by his own efforts within

the time limit recommended by the Company, the Company, in the absence of other

instructions from the Client, has the right to independently, without an application

(order) or other instruction from the Client, perform exchange operations with regard

to the relevant Client’s Funds, acting in his own interests.

It is understood that the Company is entitled, acting independently, to

unilaterally determine the final asset and the exchange rate at which the exchange

transactions are performed, to round the asset and the amount above/below which

the rounding is performed, as well as to determine other conditions for such

transactions.

4.4. Integrate the Trading System with other software products, including those

owned by third parties (owners, developers, official partners, etc.). For the purpose of

improving the service and processing requests – give orders for the processing, and

process information: Client’s requests related to the operation of the Trading System,

transaction requests received through the owner of the related software product

(applications, etc.), as well as transmit as a response information about technical errors,

the status of transactions, etc. to the owner of the software product in relation to Client

using such a product (e.g., an affiliate application); within the integration with partners

services – to provide official partners with access to information necessary for the

performance of operations and instructions of the Client, including information

containing personal data. The list of such information is specified by the Company in

the Privacy Policy approved by the Company and published on the Company’s website

and/or in the Company’s mobile Application, if such functionality is provided by the

Company.

4.5. Perform other actions provided for, among other things, by the legislation of the

Republic of Belarus and acts of the Supervisory Board of the HTP (Republic of

Belarus).

5. OBLIGATIONS OF THE COMPANY

5.1. The Company undertakes to:

(a) organize token trading, including ensuring the execution of Applications (orders)

of the Clients, if it is possible to execute such Applications (orders);

(b) take measures to prevent, detect, suppress and eliminate the consequences of

unfair (unlawful) use of insider information about tokens and/or manipulation of prices

for tokens;

Trading System by providing Trading Members with the opportunity to review the

progress of this process using software and hardware;

(d) ensure the fulfillment of other obligations in accordance with this Agreement,

internal regulations of the Company, legislation and acts of the Supervisory Board of

the HTP.

6. CLIENT’S CONSENT

6.1. By concluding this Agreement, the Client gives his consent to the

following:

6.1.1. performance by the Company of actions specified in clause 4.2 hereof;

6.1.2. provision of information and documents that the Company requests for

the purposes of Identification and subsequent Verification, exclusion of the facts of

unfair or illegal behavior in the Trading System, and allows the Company to store and

process this information. The Client also undertakes to provide the Company within 7

calendar days from the date of the relevant request evidence of existence of the Client’s

legal grounds for processing personal data provided to the Company.

6.1.3. provision of reports on the amount (balance) of funds, the amount

(balance) of electronic money, customer tokens held respectively in bank accounts, in

electronic wallets, at the addresses (identifiers) of virtual wallets of the cryptoplatform

operator, as well as on executed and unfulfilled requests of Clients for the purchase

and/or sale of tokens during the day for money or electronic money, or the exchange of

tokens of one type for tokens of another type in the information system of the

cryptoplatform operator, for storage (deposit) in the organization providing the relevant

services;

6.2. By concluding this Agreement, the Client agrees that:

6.2.1. the Company has the right to request information and documents that the

Company considers necessary for Identification and Verification of the Client or taking

measures in order to prevent fraud, Legalization of proceeds or other crime;

6.2.2. the Company may involve third-party organizations in order to carry out

the Identification procedures and/or subsequent Verification of the data (information)

obtained during the Identification and disclose to such third-party organizations the data

received from the Client for the purpose of Identification and subsequent Verification;

6.2.3. he cannot use bank cards, bank accounts and/or wallets of third parties

for depositing funds to the eWallet;

6.2.4. he is notified of the possibility of adverse consequences connected with

unfair (unlawful) use of insider information about tokens and/or manipulation of prices

for tokens;

6.2.5. the Company is not responsible for determining whether any types of

taxes and fees apply to transactions with tokens made by the Client, as well as the result

of transactions made;

6.2.6. the Client bears all risks of negative consequences if they do not comply

with clause 3.1 (f) hereof;

6.2.7. the basis for processing personal data of individuals related to the Client

(representatives, employees, etc.) is AML/CFT legislation, as well as the Agreement,

depending on the scope and objectives;

6.2.8. when implementing programs and promotions in accordance with clause

4.1. (h) in order to calculate prizes and gifts, accrual of remuneration to agents or

affiliates under loyalty programs, it is possible to disclose some information about the

time and volume of transactions of the attracted Users (pseudonymized). This

information will not be disclosed to third-party program participants (agents or

affiliates), and the data will not be personal or confidential, except if the user is the only

attracted client for the agent or affiliate and such information about the user can be

obvious under certain circumstances.

6.2.9. The Company is interested in expanding the service and improving the

quality of service performed. In this respect and when the Client uses third-party

services as primary services, the Company may give orders to its partners (owners of

these services) to process the personal data of the individuals related to the Client.

6.3. By concluding this Agreement, the User agrees to provide reliable information

that the Company requests for the purpose of registration or creation of an Account,

and/or Identification, and/or Verification, and agrees that the basis for processing

information, including his personal data, is the AML/CFT legislation, as well as the

Agreement, depending on the scope and objectives.

6.4. By concluding this Agreement, the Client represents and guarantees that:

6.4.1. current (settlement) bank account, bank card, electronic wallet, virtual wallet

address (identifier) and Monetary Funds, tokens, Cryptocurrency deposited by the

Client on the eWallet belong to the Client, or the Client has the right to use (dispose of)

them on legal grounds. At the same time, the Client understands and agrees that the

Except in cases when the Client is authorized for such use (disposal) by a third party through a power of attorney

or other equivalent document (certificate).

Company has the right to verify the accuracy and truthfulness of the guarantees

provided at any time.

6.4.2. The Funds deposited by the Client on the eWallet are obtained from legal

sources and by legal means.

6.5. By accepting this Agreement, the Client agrees that the initiation of a Long or

Short operation is at the same time the provision of an Irrevocable power of attorney

and an Irrevocable Offer to provide the Company with a possibility to make a Forced

Completion of Transactions on behalf of the Client in order to prevent the Client from

incurring obligations in the amount exceeding his Funds.

6.6. The Client is solely responsible for the knowledge and understanding of how

tokens are considered, regulated and taxed in accordance with the law of the state, of

which he is a citizen (national) / in whose territory he resides (for individual

entrepreneurs) or with the law of the state of registration / carrying out economic

activity (for individual entrepreneurs and legal entities), as well as the state (territory)

under whose law the person is a tax resident or has a representative office.

6.7. The Client is solely responsible for the timely and proper notification of any

government authorities, preparation and submission of the relevant reports, as well as

full and timely payment of any taxes and fees that arise or may arise as a result of

transactions with tokens performed by them in the Company’s Trading System.

6.8. The User, including the Client, understands and accepts that any software is

provided by the Company “as is” and the Company does not provide any guarantees of

any kind regarding its suitability for the Client’s purposes, compliance with the Client’s

expectations (including financial and investment), the Company also does not guarantee

continuous uninterrupted operation and quality of software.

6.9. When returning to the Client a payment made in electronic money (accrual of

funds), when such a refund is provided for by the legislation of the Republic of Belarus

or by agreement of the parties, the Company has the right to make a refund both in

electronic money and in the Funds other than electronic money, taking into account the

technical possibility.

6.10. The Client agrees that the Company has the right to place the money received

from him into deposits in banks of the Republic of Belarus and receive the interest from

such deposit in order to minimize commission costs for its Clients.

6.11. The Clients using third-party services (applications, software products, etc.)

to register and carry out transactions in the Company’s Trading System understand and

agree that the Company will give orders for processing and will process Client’s

requests regarding the operation of the Trading System, as well as transmit data on

technical errors or the status of Client’s transactions through the service of partners who

own software products used by the Client. The Client shall be extremely cautious while

working with third-party services and shall not share confidential information,

including personal data of individuals, unless it is required for the provision of services

hereunder.

7. ACCOUNT (PERSONAL ACCOUNT) CREATION, IDENTIFICATION

AND VERIFICATION

7.1. To obtain the status of a User, an individual entrepreneur or a legal entity

concludes this Agreement and assumes other mandatory terms and conditions of the

Company by putting a mark of consent to conclude this Agreement on the terms

proposed in it, creates an Account (Personal Account) and eWallet. Users have the right

to interact with the Company in the Company’s mobile Application, if such

functionality is provided by the Company.

7.2. To obtain the status of a token Trading Member, the User must go through the

following procedures of complete Identification and Verification in the Personal

Account, and receive confirmation of their successful passage from the Company. The

assignment of the status of a Trading Member is made subject to successful Verification

of the data.

7.3. When concluding this Agreement and throughout the entire period of using the

Trading System the User and/or the Client represents and warrants that he:

− is a person over 18 years of age and is a person who is able to participate in token

trading, with due regard for the terms hereof and the laws of the state of which he is a

citizen (for individual entrepreneurs) or a legal entity duly registered and operating in

accordance with the laws of the jurisdiction of its registration (for legal entities);

− acts on his own behalf and not in the name of another person (except for duly

authorized representatives of the Client that is a legal entity), or in the name of an

individual based on the relevant power of attorney;

− is not an individual entrepreneur who permanently resides (has a permanent

location, including for tax purposes) in the states (territories) included in the list of states

(jurisdictions, territories) for which the provision of services by the Company is limited

(https://files.free2ex.com/download/legal/doc/jurisdictions_en.pdf);

− is not an individual entrepreneur or a legal entity included in the List of

organizations and individuals involved in terrorist activities approved by the Committee

for State Security of the Republic of Belarus, as well as a legal entity whose beneficial

owner is included in this list;

− will not carry out criminal or other illegal activities through the Trading System,

including but not limited to Legalization of proceeds, fraud or any other crime;

− will not use any inside information about tokens in an unfair (unlawful) way and

will not manipulate token prices as part of the Client’s use of the Trading System;

− will not allow other persons to use his Account (Personal Account) (except for

his duly authorized representatives who have passed the Identification and Verification

in the Trading System).

− will not carry out any activity that violates this Agreement and/or causes (may

cause) damage to other Trading Members and/or to the Company, including using

malicious software, carrying out hacker attacks, spreading spam, etc.

7.4. To pass the Identification and Verification procedure, the User and/or the Client

is invited to provide information, the request for which is provided by the Personal

Account

questionnaire. At the same time, the Company reserves the right to request

additional documents and information in a larger volume than can be provided by the

Personal Account questionnaire, to check the documents and information provided by

The Personal Account stipulates assigning the “Verified” status to the Client. Till the date of acquisition of this status, the

functionality available to the User, is not a confirmation of successful Identification and Verification results, but affects the

User’s access to the resources and functions of the Trading System.

the User and/or the Client (to verify them) both during the Identification and

Verification process and at any time after creating an Account (personal account) and

assigning the status of a Trading Member.

If the User and/or the Client have already provided or started to provide information

for Identification and Verification in the Web version of the Client’s personal account,

such information may be reflected automatically in the Company’s mobile Application,

if such functionality is provided by the Company, if the User and/or the Client has

already provided or started to provide information for Identification and Verification in

the Company’s mobile Application, if such functionality is provided by the Company,

such information can be reflected automatically in the Web version of the Client’s

personal account. If this information was not automatically reflected, the Client has the

right to send a notification with clarification to the following e-mail address of the

technical support service: corporate@free2ex.com (in the mobile Application,

redirection is performed automatically from the Help & Support → Contact Us section),

or write to the chat on the Company’s Website, and/or in the Company’s mobile

Application, if such functionality is provided by the Company. It is understood that the

Company also reserves the right to request additional documents and information, to

check the documents and information provided by the Client (to verify them) both

during Identification and Verification, and at any time after assigning the status of a

Trading Member.

7.5. If the User and/or the Client is an individual entrepreneur that is a citizen of the

Republic of Belarus, during the Identification procedure he will be offered to pass a

survey on understanding the blockchain technology, and when passing the full Data

Identification and Verification procedure confirm the data entered during registration,

with the relevant documents.

7.6. The Company reserves the right to verify any assurances and guarantees

provided by the Client, incl. those specified in clause 6.4., clause 7.3 above, and

received by the Company before providing the Client with services for the

implementation of trading with the receipt of Borrowed tokens, at any time of the

validity of this Agreement. The Company has the right, at its sole discretion, to carry

out checks of the Client’s qualification level to assess whether the Client possesses

sufficient skills and knowledge necessary to trade tokens on the Trading Platform,

including trading with obtaining Borrowed tokens. If the Company decides that the

Client does not possess sufficient and necessary skills and knowledge, the Company

has the right to reject the Client’s further use of the Account (Personal Account).

7.7. Information and data necessary for the passage and completion of Identification

and Verification procedures can be provided by attaching (downloading) static and/or

dynamic graphic images (images created by scanning, photographing, including in the

required cases – frame-by-frame, video shooting) of the relevant documents and/or

images when filling out the Personal Account questionnaire, including the ability to

automatically attach (download) documents from systems representing providers of

electronic services, including the state ones, with digital documents, the possibility of

digital identification and verification, as well as portals with public services, and if for

any reason there is no technical opportunity for this – by sending from the e-mail

address specified during the creation and registration of the Account (Personal Account)

and eWallet to the Company’s e-mail address corporate@free2ex.com. Information and

data sent from another e-mail address not specified when creating and registering an

Account (Personal Account) and eWallet may not be considered by the Company,

which may lead to an unsatisfactory result of Identification and Verification and refusal

to assign the status of Trading Members.

7.8. The Company has the right to make, depending on the information and data

received from the Client, demands for the provision of information and data that allow

to properly identify the Client’s beneficiary and verify the information received about

them.

7.9. The information and data, provided by a Client, shall meet the following

requirements:

- an extract from the commercial register of the country of incorporation or other

equivalent proof of the status of a legal entity in accordance with the legislation of the

country of its incorporation with the date of issue not earlier than 6 months before the

date of submission of their graphics, while the extract should contain the following

mandatory set of data for legal entities: name, registration number, location of the legal

entity, as well as the last name, first name, patronymic (if any) of its manager

; for

individual entrepreneurs: surname, given name, patronymic (if any), registration

number, place of residence (stay);

- documents and information provided in a language other than Russian, Belarusian

or English are provided with the attachment of a translation into Russian, Belarusian or

English, while the Company reserves the right to verify the accuracy of the translation,

the identity of the translator, or to make the translation independently at its own

expense.

At the request of the Company, documents issued by the authorities of foreign states,

electronic copies of which are provided to the Company by the Client, are subject to

consular legalization or affixing an apostille, unless an international agreement between

a foreign state and the Republic of Belarus establishes that there is no need to legalize

official documents.

7.10. Legal entities are Clients of the Company (Users in the course of

Identification and Verification procedure), regardless of whether they are residents of

the Republic of Belarus or not, shall provide information about the ultimate beneficial

owners

, to the e-mail corporate@free2ex.com to the following extent:

1. a document confirming the identity of the final beneficiary (passport or residence

permit, other equivalent document; for citizens of the Republic of Belarus – passport

only);

2. information on permanent residence and a graphic image of the document

confirming the fact of residence at the address indicated as permanent residence;

3. the source of the ultimate beneficial owner’s funds;

Legal entities that are not residents of the Republic of Belarus, instead of graphics of an extract from the trade register of the

country of establishment or other equivalent proof of the status of a legal entity, can provide a screenshot of a page and/or a

link to the electronic register of legal entities, which is publicly available on the Internet, where the information contained in

the extract from the trade register of the country of establishment or other equivalent proof is reflected.

For the purposes of this paragraph, beneficial owners shall mean all final participants who are individuals.

4. information about the taxpayer’s account number, as well as information about

whether the ultimate beneficial owner is a public figure (official) and about the status of

the US taxpayer (FATCA);

5. at the Company’s request, a graphic image of the structure, including all

intermediate links (legal entities, or public associations, or other entities), as well as

additional data (information and documents) confirming the source of the funds of the

ultimate beneficial owners may also be provided.

7.11. At the request of the Company, the Client, who is an individual

entrepreneur, as well as the head and/or legal representative of the Client being a legal

entity, undergoes web identification (Web-ID) via video communication with an

authorized employee of the Company or through a video message analyzed by

specialized software used by the Company.

7.12. The Company is entitled, at any time during the Client’s use of the

Trading System, ask for information and documents in addition to those provided by

the Client in the process of Identification and Verification, in particular in case illegal

activity through the Account (Personal Account) and/or activities that do not comply

with the terms hereof are suspected.

7.13. The Company may periodically send to the Client a request to update the

information and/or documents provided by the User and/or the Client as part of

registration or Identification process for further Verification. The User and/or the Client

shall update the information and/or data within the period specified in such request. In

case the Client has not updated the information and/or documents within the specified

period, the Company has the right to make a restriction for the Client to use the Account

(Personal Account) for token trading in the Trading System or to block the Account till

the moment of provision of the information.

7.14. The User or/and the Client does not have the right to create more than one

Account (Personal Account) in the Trading System.

7.15. The Client receives the right to participate in trading (acquires the status

of a Trading Member) from the moment and in accordance with the procedure

established by the Rules for obtaining the status of a token trading member by the client

(allowing the client to trade tokens) and excluding the client from the number of trading

members (depriving the status of a trading member). The status of the User and/or

Client is displayed in the Personal Account in the Trading System (for example, the

Client sees the status of his Account (Personal Account) as “Verified”). Grades

(Verification levels) determining the functions of the Trading System available to the

Client may be displayed for legal entities.

7.16. The Company may, at its sole discretion, refuse to create an Account

(Personal Account) for the User without any explanation of the reasons.

8. DEPOSITING FUNDS

8.1. The Client has the right to deposit the Funds (the Funds can be credited) to be

accounted for them on their Account (Personal Account) by replenishing the eWallet

using the Client’s current (settlement) bank account, bank card issued in the name of

the Client, electronic wallet, virtual wallet address (identifier) belonging to the Client

with due regard for the peculiarities set out in clause 6.2.3. Only those Funds can be

deposited on the eWallet, the deposit of which is supported in the Trading System, and

information about which is posted on the Company’s Website and/or in the Company’s

mobile Application, if such functionality is provided by the Company.

8.2. The Company has the right not to accept the Funds from the Client (including if

the Company has a reliable reason to believe that the Client does not meet the

requirements of this Agreement, as well as to unilaterally change the list of methods by

which the Funds can be deposited at any time.

8.3. The Client has the right to deposit the Funds to the eWallet by bank transfer, by

electronic money transfer, or by token transfer in accordance with the list of deposit

methods established by the Company, which is available on the Company’s website

and/or in the Company’s mobile Application, if such functionality is provided by the

Company. Some deposit methods may not be available to the Client. The availability

of a particular deposit method depends on several factors, including the location of the

Client, the identification information provided by the Client, and restrictions imposed

by the payment system operators, the functionality of the Company’s application

programs (applications) (Telegram bot, mobile Application, its versions, etc.).

8.4. To carry out Leverage operations when the Client deposits Monetary Funds or

Cryptocurrency on the eWallet, after choosing the Trade coin token and its volume that

the Client intends to purchase, the Client purchases Trade coin tokens from the

Company in the procedure of a Borrowing operation. The implementation of Leverage

operations is possible only in the Web version of the Client’s personal account.

8.5. In the Company’s mobile Application, if such functionality is provided by the

Company, the Approximate Balance is reflected both for the estimated total number of

tokens (Monetary Funds) of the Client available on the Client’s eWallet, and for the

estimated total number of specific tokens (Monetary Funds) of the Client, and is

expressed estimated in the currency chosen by the Client. This estimated amount may

differ from the result of actual exchange operations.

8.6. The Client is entitled to convert small balances in the Company’s mobile

Application, if such functionality is provided by the Company (a small balance is the

number of specific tokens or other assets whose estimated value does not exceed 10

USDT), only into a USDT token. At the time of conversion of small balances, the

estimated amount of USDT that the Client can receive during the corresponding

operation according to the rules of clause 9.3 is reflected in the Company’s mobile

Application.

8.7. The period during which the Funds sent by the Client will be reflected on his

eWallet depends on the work of third parties responsible for maintaining the current

(settlement) bank account used by the Client, the electronic wallet, the address

(identifier) of the virtual wallet. In case of making a payment using a bank payment

card, the term for crediting (reflecting) the Monetary Funds is up to 14 business days.

8.8. The Company reserves the right to check the Client’s compliance with sub-

clauses 6.4.1 and 6.4.2 at any time in terms of use of the Trading System, in particular,

in the following ways:

(a) by requesting documentary confirmation of the source of origin of the funds,

ownership rights to them, rights to the current (bank) account, bank card, e-wallet,

virtual wallet address (identifier);

(b) by using software in particular to analyze the history of using the Client’s

account

, its relation to other accounts and operations, and to determine the risk of

using such accounts for illegal activities;

providers, banks, and non-bank credit organizations.

8.9. In case the Client is unable to provide the necessary documentary evidence, or

in the event the Company has other reasons to suspect that the Client does not comply

with clause 6.4., the Company may take any of the following actions:

(1) to refuse to the Client to deposit or withdraw the Funds to or from eWallet, or

(2) to suspend the financial operation of depositing or withdrawing the Funds, or

(3) to apply a ban on disposal, use of the Funds credited to the Client’s Account

(Personal Account), or

(4) to refuse to carry out a financial transaction in which the Client is a member, or

(5) to suspend the operation of the Client’s Account (Personal Account), including

temporarily or permanently change down the level of the limit of operations, or

(6) to refuse to transfer (credit) tokens to the address (identifier) of the Client’s

virtual wallet that are subject to such transfer (such crediting), or

(7) to assign the Account (Personal Account) the status of a deactivated Account

(Personal Account)

This clause 8.9 is an essential condition of the Agreement.

9. TOKEN PRICE. APPLICATIONS (ORDERS). EXECUTION OF

APPLICATIONS (ORDERS) AND WITHDRAWAL OF FUNDS

9.1. The price of cryptocurrencies, tokens created by third parties admitted to trading

in the Company’s Trading System, with the exception of tokens specified in clause 9.2,

is determined by the Company based on information on quotes received from Liquidity

providers, as well as supply and demand for this Cryptocurrency in the Trading System.

9.2. The procedure for determining the price (value) of the Company’s own tokens,

as well as tokens created and placed by the Company at the request of the Customers

(third parties), is established in the corresponding “White paper” declarations. These

“White paper” declarations also reflect information about material facts (events, actions)

that may affect the value of tokens.

9.3. Information on the prices of tokens sold in the Company’s Trading System is

posted in the Trading System, on the Company’s website and/or in the Company’s

mobile Application, if such functionality is provided by the Company. The displayed

price of tokens sold in the Trading System is indicative and may change immediately at

the time of the transaction, which is associated with the time interval of the moment of

viewing, the moment of the formation of the Application (order) and the execution of

the transaction.

As well as the address (identifier) of the virtual wallet

According to the rules established by Appendix No. 3 to this Agreement.

9.4. The trading platform allows the Trading Members to place orders for the

exchange (acquisition, disposition) of tokens. The placement of Applications (orders) is

carried out using the funds held on the corresponding Trading Account.

9.5. The price and the volume of the Funds for which the trading member’s tokens

will be offered to be exchanged (disposed, acquired), is determined by the Trading

Member at his sole discretion and taking into account the technical capabilities and

limitations of the Trading System and/or the Application, if such functionality is

provided by the Company.

9.6. Transactions shall be concluded on the basis of Applications (Orders)

, placed

by Clients with the use of the Company’s Trading Platform.

9.7. If the Client makes a Transaction in the course of token trading, the Company

deducts the amount of execution under this Transaction from the amount of the Funds

accounted for by the Client in the Account (Personal Account), and adds the amount

(number) of such execution to the amount of Funds recorded for the counterparty of the

specified Client, under the corresponding transaction.

9.8. The actual receipt by the Client of the Funds acquired by him as a result of token

trading is carried out by means of transfer of the Funds to him by the Company.

9.9. The Client has the right to withdraw the Funds (both in the form of Monetary

Funds, electronic money, and in the form of Cryptocurrency) from eWallet to the current

(settlement) bank account, bank card, electronic wallet, address (identifier) of the virtual

wallet (if funds and currency withdrawal method chosen by the Client for withdrawal

are supported in the Trading System) at any time by sending the Company a

corresponding request.

9.10. Transfer of the Monetary funds

, transfer of electronic funds, transfer of

tokens and Cryptocurrency assigned to the Client to the current (settlement) bank

account, bank card, to an electronic wallet, to the address (identifier) of the Client’s

virtual wallet is initiated by the Company within 5 (five) business days from the date of

receipt from the Client of a request for such operations as transfer, conversion or

virement. The moment of actual receipt of funds (tokens) by the Client depends on the

work of third parties responsible for maintaining the current (settlement) bank account,

electronic wallet, virtual wallet address (identifier) used by the Client. In case of

withdrawal of funds using a bank payment card, the term for receiving the Funds is up

to 14 (fourteen) business days.

9.11. The Company is entitled to reject, limit or suspend the withdrawal of the Funds

from the Client’s eWallet for the purpose of applying extended internal control measures

in the event that the Company has the right or is obliged to apply them in accordance

with AML/CFT legislation, fraud or any other criminal activity, in particular, if the

Company has suspicions that the Client is involved in Legalization of proceeds, fraud

or any other financial crime. The Funds withdrawal restriction may also be unilaterally

applied by the Company in the event that the Client fails to fulfill its obligations to pay

fees or does not provide the required level of the Funds in the payment currency for

automatic write-offs.

The types of orders available in the Trading System are indicated in Appendix No. 2 to this Agreement.

Including by means of SWIFT, SEPA system.

9.12. The Company also has the right to reject the withdrawal of the Funds from the

Client’s eWallet if the Client has not passed the Identification and Verification, which

makes it possible to withdraw funds in the amount corresponding to the request of the

Client.

10. REMUNERATION OF THE COMPANY

10.1. The Client is obliged to pay remuneration (fees and charges) to the

Company for the services in organizing token trading, as well as for Account

maintenance

in order to organize token trading and/or conduct transactions

(operations) with tokens, in accordance with this Agreement and the rules for

determining the amount and procedure for collecting remuneration of the cryptoplatform

operator from clients, approved by the Company.

10.2. Fees and charges may be collected by means of:

- inclusion in the token price;

- deduction from the available Funds on the Client’s Trading Account and/or eWallet.

10.3. The Company shall notify the Client of the types, size and procedure for

collecting fees and charges, of any changes related to Company’s remuneration, on the

Company’s Website and/or in the Company’s mobile Application, if such functionality

is provided by the Company, or by notifying the Client with the use of means of

communication (Personal Account, mailing, etc.). Information available in the asset

specification in the trading terminal (a pop-up window which appears when you hover

over a particular asset) is equivalent to data posted on the Website.

10.4. Changes in the types and size of commissions, the procedure for their

collection come into force from the moment such changes are published on the Website

and/or in the Company’s mobile Application, if such functionality is provided by the

Company, or from the moment specified in the published material, or in the notice

provided to the Client.

The Company shall be entitled to deduct the amount of compensation for the

Company’s expenses for payment of the services provided by banks and other payment

intermediaries when Clients make deposits and withdrawals of the Funds, electronic

money

10.5. As a result of fulfilling obligations under the Agreement, the Client may

incur debt to the Company (accounts receivable of the Company), for example, in the

case of negative trading results, write-off of commissions, or other cases. As a general

rule, the Trading commission in the Trading System is charged at the time of execution

of the transaction. Commission can also be debited after the transaction is completed

(executed). If the subsequent write-off of commissions (other debts) leads to a negative

Balance of the Client, such negative Balance will be reflected in the Client’s Account

until the Client replenishes the Account. The Client’s funds aimed at replenishing his

Account are sent as a matter of priority to repay the negative Balance.

The Account maintenance fee for the purpose of organizing token trading and/or transactions (operations) with tokens

payable in accordance with the provisions of Section 11, shall apply only to legal entities

Commissions for the conversion carried out by the Client’s bank at its respective purchase/sale rate when

depositing and withdrawing funds by the Client are not included in the compensation amounts and are paid by the

Client independently.

10.6. If the Client’s Personal Account (Account) remains unused for more than

180 days, the Company may charge a fee for inactive management of the account. This

fee is charged on a monthly basis, starting from the month following the one in which

the Account has been recognized as unused.

10.7. The Company is not responsible for the payment of third-party fees that

may be charged to the Client. Third-party fees will not be indicated on transaction

screens containing information in relation to Client’s transactions in the Account

(Personal Account). The Client is solely responsible for the payment of any third-party

fees.

10.8. When depositing, withdrawing or returning the Funds, the Client may be

charged certain fees imposed by third parties (“Third-Party Fees”):

(a) fees from the current (settlement) bank account, bank card, e-wallet, virtual

wallet address (identifier) that the Client uses to deposit the Funds;

(b) all expenses for reflection (confirmation) of transactions (operations) in the

blockchain network, including expenses for payment of remuneration to miners, as well

as expenses for the payment of fees to banks and other payment service providers (unless

otherwise expressly provided for in the Agreement and/or on the Company’s website).

Also, the Client pays to the Company the amounts of the corresponding expenses when

they arise in connection with the deposit, withdrawal or refund of the Funds. The

Company has the right to independently deduct the corresponding amounts from the

Monetary Funds, and/or electronic money, and/or tokens (at the discretion of the

Company) accounted for by the Client in his Account (Personal Account) or directly

from the transaction amount.

10.9. In case of an error (failure) in the operation of the Trading System, which

led to excessive write-off or excessive accrual of Funds to the Client, the Company has

the unilateral right to transfer the Funds or to write off the excess of the accrued Funds

from the Client’s Account (Personal Account). The consequences of a possible negative

Balance for the Client are similar to the consequences specified in clause 10.5 of the

Agreement.

10.10. When the payment made in electronic money (accrual of funds) is returned

to the Client, when such a refund is provided for by the legislation of the Republic of

Belarus or by agreement of the parties, the Company is entitled to make a refund both

in electronic money and in the Monetary Funds other than electronic money, taking into

account the technical capability of the Company.

11. ACCOUNT MAINTENANCE FEE. ACCOUNTING.

11.1. The services are provided by the Company in electronic form using software

tools. Transaction records (transaction history) are stored in the Company’s information

system.

11.2. The Company is entitled to provide information about Clients and client

transactions to third parties in cases and in accordance with the procedure stipulated by

applicable law.

11.3. The Company is not obliged to duplicate the information contained in the

Trading System and the Personal Account on paper or convert it into another form of

document

Clauses 11.1 -11.3 apply to any type of services provided by the Company.

11.4. The parties draw up primary accounting documents confirming the provision of

services, solely on the basis of data from the transaction history contained in the Personal

Account

11.5. The form of the invoice is provided in Appendix 5 hereto. The invoice is formed

after the service is deemed to have been rendered and shall be uploaded to the Personal

Account or sent to the Client via the e-mail specified during registration.

11.6. Full maintenance of the Account of the legal entity or individual entrepreneur

starts upon payment of 100% of the corresponding commission amount. The specified

commission is debited at a time in the Funds attributed to the payment currency. The

specified Commission is charged on the 1

(first) day of each month for the current

month, provided that the Client has the status “Verified”. The Funds may be written off

by the Company at a later date, taking into account the availability of funds in the

payment currency, provided that the condition of one-time write-off is fulfilled.

11.7. The payment currency for the Account maintenance fee in order to carry out

transactions (operations) with tokens for legal entities and individual entrepreneurs that

are residents of the Republic of Belarus is Belarusian rubles, for residents of the Russian

Federation – Russian rubles, and for residents of other countries – USD.

11.8. Information on payment of the Account maintenance fee for the Client being a

legal entity or individual entrepreneur is available in his Personal Account.

11.9. The amount of the Account maintenance fee for the purpose of making

transactions (operations) with tokens and other specifics of paying such a fee may be

determined solely by the Company and shall be brought to the attention of Customers

in accordance with the procedure stipulated by clauses 10.3, 10.4. The fee amount for

the service period is not reduced if the Company applies a ban on the withdrawal of

funds or other functional limitations.

11.10. The fee specified in this section is applicable to legal entities and individual

entrepreneurs.

12. INTELLECTUAL PROPERTY

12.1. In order to perform this Agreement and use the Company’s Trading System,

the Company grants its Clients a license to use the Company’s Trading System and for

the Users and/or Clients – Website and/or mobile Application, if such functionality is

provided by the Company, during the term of this Agreement, without limiting the

territory. The license is simple, revocable, non-exclusive, limited and is gratuitous in

connection with the requirement of the copyright holder.

12.2. For the avoidance of doubt, the use of the Trading System in compliance with

the terms and restrictions of this license by the Clients being legal entities, both

commercial and non-commercial, is not considered to be used for commercial purposes.

The use of the Trading System on the terms and in the manner not provided for by this

license is possible only on the basis of a separate agreement with the copyright holder.

12.3. The User or/and the Client is not entitled to use the intellectual property items

of the Company (Trading System, applications, versions, logotypes, etc.) without the

prior written permission of the Company, including copying, modifying, creating

Clause 11.4 applies from the moment of verification of the Client and applies to any type of services provided

by the Company.

derivative objects, distributing and publicly displaying, broadcasting, selling,

transferring, granting a license, assigning rights to the Trading System or any of it parts,

as well as remove, modify or hide any mention of the ownership of intellectual property

rights to the Trading System or its individual parts.

12.4. By creating a Personal Account, the User accepts the Agreement on the terms

of use of the service.

13. LIABILITY

13.1. The Company (including company officials, employees, affiliates or contracting

parties who provide services to the Company, perform work at its request, create

intellectual property objects) and the User, including the User acting as a Client, are

liable for the non-performance (improper performance) of the Agreement in accordance

with the terms of this Agreement and the legislation of the Republic of Belarus.

13.2. In case of non-performance (improper performance) of the Agreement or other

internal regulations of the Company by the User, including the User acting as a Client,

he is obliged to compensate the Company for the losses in full (including to reimburse

the Company the amount of the sanctions imposed on it in a foreign country in

connection with the conclusion and/or execution of the Agreement should the User

(Client) provide false data), as well as to pay to the Company a forfeit if it is stipulated

by the legislation of the Republic of Belarus (unless otherwise expressly provided for

by the legislation of the Republic of Belarus or by the Agreement, this forfeit is penal in

nature and is collected in excess of the amount of damages). The Company shall be

entitled to fully or partially deduct the amount of losses suffered and/or the amount of

the specified penalty from the Client’s Monetary Funds deposited by him to the Account

(Personal Account) or acquired in the process of trading in the Trading System. In case

the Company itself withholds a penalty from the Client’s tokens held by the Company,

the Parties have agreed for the purposes of this Agreement that the term “withholding a

penalty” shall mean a way of ensuring performance of the obligations not provided for

by the legislation which stipulates appropriation by the Company of the Client’s

monetary funds in the amount corresponding to the amount of the penalty.

13.3. The Client and the Company may be released from liability for the non-

performance (improper performance) of the Agreement in the event of existence of force

majeure circumstances which are understood as extraordinary circumstances

unavoidable under the given conditions, including natural, legal or technical causes,

namely: war, natural disaster, fire, flood, earthquake, epidemics, strikes, riots and other

social unrest, as well as actions of the authorities that affect the fulfillment of obligations

under the Agreement (including recommendations and other letters (acts) from

authorities and regulators to the Parties, compliance with legal and internal regulations

binding upon the Company, upon the Company’s partners or any of the participants in

the process that is necessary for the Company to fulfill its obligations), international

sanctions and prohibitions implemented after the approval of the current version of the

agreement, including as part of implementation of international sanctions - sanctions

imposed on/by partners, banks, acquirers, owners of payment systems, etc., which

considerably worsen and/or exclude the possibility of proper performance of obligations

under the Agreement.

Force majeure circumstances also include malfunctions on power transmission

lines, technical failures at transit nodes of the Internet and other violations of the

functioning of data networks transmission, beyond the parties control, failures of third-

party software, used by the Company, illegal actions of third parties towards the

equipment or software used by the Company, other actions of intruders, distributed

equipment attacks (DDOS attacks), failures in the work of the acquirer’s processing

center.

13.4. The User (including the User who acts as a Client) agrees that the Company

does not bear responsibility for the non-performance (improper performance) of this

Agreement if it was caused by or resulted from the non-performance of obligations by

a third party to the Company due to force majeure. For the purpose of this Agreement,

force majeure circumstances shall mean the circumstances which are classified as such

in accordance with the terms of this Agreement or the agreement with such third party.

13.5. The Company is not liable to the User (including if the User acts as a Client) for

the use of the Account (Personal Account) by third parties without the User’s and/or

Client’s permission, if such use occurs not through the Company’s fault.

13.6. The Client is solely responsible for conducting his own independent assessment

and research of the risks of any transaction (operation) performed by the Client in the

Trading System. The Company is not responsible for any actions, direct or indirect

damages, loss of profit, loss of income, any costs, Client’s expenses arising as a result

of incorrect assessment by the Client of the transaction (operation), including the

assessment of the associated risks of loss of the invested funds. The Company neither

recommends the Client to make any specific transactions using tokens, nor does it advise

the Client about the tax consequences of such transactions. The Company provides data

about tokens and the token market solely for informational purposes.

13.7. The Company cannot guarantee continuous access to the Trading System,

including ensuring continuous performance of trading operations in the event of force

majeure which shall be understood as extraordinary circumstances unavoidable under

the given conditions. The Company does not bear responsibility for proper conducting

of trading operations, for the occurrence of any errors, delays, node malfunctions,

failures, including technical ones, during transactions, both on the Company’s platform

and in partners’ systems caused by an obstacle beyond the Company’s control, as well

as in the event that the transaction cannot be performed or completed in cases where

access to the Company’s Trading System was interrupted under force majeure

circumstances, including under circumstances of legal or technical force majeure. In the

event of force majeure, the Company is released from any liability for the performance

of its obligations, including under the Token Trading Participation Agreement, for the

duration of such force majeure circumstances.

13.8. The Company is not responsible for the complete safety of personal and/or other

data provided by the Users and/or the Clients, if the Users (Clients) themselves grant

access to the specified data of Users (Clients) or their representatives to third parties, or

as a result of improper disclosure of such data by third parties, or third parties obtain

access as a result of improper measures taken by the Users and/or the Clients to keep

their data safe.

13.9. The Company cannot guarantee the reliability of any external websites or

applications (web-, mobile-, etc.), including of the information posted on them (among

other things, it does not provide any guarantees as to the safety of funds when purchasing

tokens created and posted by third parties outside the Trading System; guarantees of

sufficient protection of personal data by external websites; accuracy or completeness of

the information about the token market or about individual tokens on external websites),

the access to which the Client may obtain through the use of the Trading System. By

going to external and third-party websites the links to which have been received via the

Trading System, the Client independently bears all risks associated with the use of such

websites or applications.

13.10. For manipulating token prices and/or for unfair (illegal) use of insider

information, the Client shall pay the Company a penalty in the form of a fine at the rate

of 20,000 Belarusian rubles for each case of detected manipulation of token prices and

for each case of unfair (illegal) use of insider information.

13.11. For violation of the terms of this Agreement aimed at fulfilling the obligations

of the Client, as well as the rights and obligations of the Company established by clauses

3.1 (a), 3.1 (h), 4.1 (b), 4.1 (d), 7.6, 7.7 , 7.9, 7.10, 7.11, 7.12, 7.13, 7.15, 8.8, as well as

any clause from Section 6 of this Agreement, the Company has the right to impose a

fine on the Client, that complies with the terms of clause 1.2 of Appendix 3 hereto, of at

least 20% of the Funds accounted for by the Client. The Client shall pay to the Company

the fine established by this clause for each detected violation. The Company has the

right to fully or partially withhold the amount (size) of the fine from the Client’s Funds

held by the Company.

13.12. If the performance of the agreement becomes impossible for the Company due

to the circumstances specified in clauses 13.3 – 13.9, for which neither party is

responsible, the Company in any case is entitled to satisfaction from the Client under

the agreement or may terminate performance of its obligations due to the impossibility

of their fulfillment.

14. MEASURES AIMED AT PERFORMANCE OF THE COMPANY’S

OBLIGATIONS

14.1. Within the limits established by applicable law, as well as to the extent

reasonably necessary for the Company as a cryptoplatform operator to fulfill obligations

in the field of prevention of Legalization of proceeds, countering the manipulation of

token prices, countering the unlawful (unfair) use of insider information about tokens,

the Company has the right to take any or several of the following actions:

(1) refuse unilaterally and out of court to perform the Agreement, and/or

(2) suspend the Client’s Account (Personal Account);

(3) restrict or stop providing the Client with access to the Trading System as a whole

or to some of its parts and functions, including the disposal and use of the Funds assigned

to the Client in the Account (Personal Account) on his eWallet and/or Accounts,

performing trading and/or other operations;

(4) refuse to execute, cancel, suspend (resume) or otherwise change the execution of

a trading operation, as well as other operations initiated by the Client by sending an

Application (order);

(5) deactivate the Account;

(6) apply other reasonable measures not covered by this Agreement.

14.2. The Company may accept the actions specified in clause 14.1 of this Agreement,

including if:

(a) the Company is entrusted with the relevant obligations, including in the field of

preventing Legalization of proceeds, countering manipulation of prices for tokens,

counteracting unlawful (unfair) use of insider information about tokens in accordance

with the law or pursuant an order of the court or state body authorized to issue such an

order in relation to the Company;

(b) the Company has reasonable suspicions or information about the violation by the

Client of the provisions of this Agreement;

or related to a breach of the security of the Client’s Account (Personal Account);

(d) the Company has reasonable suspicions that the Client is using insider

information about tokens for the purpose of trading tokens and profiting from such use

or manipulating the token prices by performing trading operations;

(e) the Company has reasonable suspicions that the Client is carrying out financial

or any other crime;

(f) the Client repeatedly makes suspicious financial transactions;

(g) in relation to the Client or his use of the Client’s Account (Personal Account)

administrative, criminal or judicial proceedings have been initiated;

(h) the Client intends to make a transaction with tokens, which are based on the

principle of complete anonymization of transactions (operations) made with them;

(i) the Client intends to execute settlements of one transaction with tokens in the

amount exceeding 2,000 base units, not by bank transfer or electronic money transfer;

(j) if, as a result of the use of software that summarizes and analyzes the use by the

Client of addresses (identifiers) of virtual wallets, as well as evaluates the risk of using

addresses (identifiers) of virtual wallets to carry out or participate in illegal activities, or

services of other persons (performers) according to the specified generalization, analysis

and assessment when making a transaction with tokens, a high degree of risk of

Legalization of proceeds by the Client has been established;

(k) the Client refused to provide the Company with additional information and/or

data requested by the Company in the process of Identification and Verification.

14.3. The Company is obliged to apply a ban on the disposal, use of tokens and/or a

ban on transactions (operations) with tokens, which are not financial transactions, in

relation to Clients:

14.3.1. that were included in the list of organizations, individuals and individual

entrepreneurs, involved in terrorist activities;

14.3.2. in respect of whom the Company has reason to believe that in the process of

interaction with the Company they carry out Legalization of proceeds.

14.4. When the Company takes actions in accordance with this section of the

Agreement, the Company will send a notification to the Client about these actions,

unless otherwise established by the internal regulations of the Company or legislation.

14.5. In order to prevent Legalization of proceeds, the Company is obliged:

(1) to freeze funds, the holder or owner of which (their beneficial owner) is a person

included in the list of organizations, individuals and individual entrepreneurs, involved

in terrorist activities;

(2) to block a financial transaction, if a participant in this financial transaction or

beneficiary of it (its beneficial owner) is a person included in the list of organizations,

individuals and individual entrepreneurs, involved in terrorist activities.

14.6. In order to implement the provisions of clause 14.5, the Company has the right

to 1) block a financial transaction with funds in respect of which freezing measures have

been taken; 2) block a financial transaction if during the Identification process it is

established that its participant or beneficiary (its beneficial owner) is a person included

in the list of organizations, individuals, including individual entrepreneurs, involved in

terrorist activities; 3) refuse to conclude and/or execute this Agreement to a person

included in organizations, individuals, including individual entrepreneurs involved in

terrorist activities, or an organization whose beneficial owner is an individual included

in the list of organizations, individuals and individual entrepreneurs involved in terrorist

activities.

14.7. The provisions of this chapter constitute the essential terms of the Agreement.

14.8. In the event of the Company’s unilateral refusal to execute this Agreement, the

Company ensures the withdrawal of the Client’s Funds from the eWallet, taking into

account the specifics provided for by this Agreement.

15. SPECIAL ASPECTS OF PERFORMANCE OF OBLIGATIONS

15.1. The Company does not guarantee the uninterrupted operation of the blockchain

used for trading tokens. In the event of failures or other technical malfunctions related

to blockchain operation, the Company is not responsible for the losses incurred by the

Client, including for the inability to complete transactions, delays in transactions or any

other consequences.

15.2. The Company does not guarantee the uninterrupted and error-free operation of

the services provided by third parties, including, without limitation, integration with

partner services. The Company is not responsible for the actions (or inaction) of third

parties, as well as for errors, failures or defects in their software products or services.

In the event of any disputes or claims of the Client related to the operation of third-

party software products, the Client undertakes to contact directly the relevant third

parties. The Company is not a party to such disputes and is not responsible for settlement

of disputes between the Client and third parties.

15.3. When interacting with software products owned by third parties, including as

part of integration with partner services, the Client’s obligations to the Company to

deposit funds in accordance with Section 8 hereof shall be deemed performed upon

receipt by the Company of a notification of funds withdrawal from the Client’s account,

if such interaction is stipulated by agreement between the Company and the relevant

partner. The Company is entitled to request confirmation of the fact of withdrawal or

other status of money transfers in accordance with the protocol approved by the partner

bank or by the payment service.

16. AGREEMENT TERMINATION

16.1. This Agreement is terminated:

(a) at the initiative of the User who may act as the Client by sending to the Company

a notice of termination of obligations to the e-mail: corporate@free2ex.com;

(b) at the initiative of the Company, when it terminates the User’s and/or the Client’s

access to the Trading System, deactivates or terminates the Client’s access to the

Account (Personal Account) irrevocably.

16.2. The Company has the right to unilaterally refuse to perform the Agreement in

case of

16.2.1. detection by the Company of the fact of systematic performance of suspicious

financial transactions by the Client;

16.2.2. two or more decisions within six months on refusal for the Client to perform

financial transactions;

16.2.3. application of measures aimed at freezing funds and/or blocking financial

transactions in accordance with the legislation;

16.2.4. in other cases, to the extent permitted by applicable law, as well as to the

extent necessary to fulfill the obligations imposed on the Company in the field of

prevention of Legalization of proceeds, counteracting manipulation of price for tokens,

counteracting unlawful (improper) use of insider information about tokens;

16.2.5. violation by the Client of any of the conditions of section 6 hereof;

16.2.6. violation by the client of clause 3.2(h) hereof;

16.2.7. the occurrence of events provided for in paragraph 4 of clause 7.3 hereof.

16.2.8. For other reasons that the Company unilaterally deems justified for

termination of the Agreement.

16.3. After the termination of the legal relations governed by this Agreement for any

reason, unless otherwise provided for by applicable law, any rights, obligations and/or

duties that arose prior to termination continue to be in force until their full completion.

16.4. After termination of the Agreement, the Company retains the information and

documents of the User and/or the Client that are required in accordance with the

provisions of the legislation or in the interests of the User and/or the Client, including,

but not limited to:

- sound recordings (video recordings) and correspondence between the User

and/or the Client and the Company for at least 5 years from the date of

implementation (occurrence) of such sound recordings (video recordings) and

correspondence;

- information about each fact of violation of the Client’s legislation within 5 years

from the date of detection of this fact;

- reports on the Client’s transactions carried out for at least 3 years after the tax

authorities conducted an audit of compliance with tax legislation or at least 5

years from the date of closing the Client’s account when checking the Company’s

compliance with tax legislation after closing the account (the longest retention

period applies). If the tax authorities have not checked compliance with tax

legislation – 10 years from the date of financial transactions;

- documents and other materials obtained during the determination of the level of

knowledge (competence) for at least 5 years from the date of receipt of such

documents and other materials;

This clause (16.2) constitutes an essential condition of this Agreement.

- other information and documents in accordance with applicable law. The

Company does not have the right to unilaterally, out of court, refuse to fulfill

obligations under the Company’s own tokens created by it or on its instructions

by another person and placed by the Company, as well as unilaterally terminate

out of court the effect of the corresponding “White paper” declaration approved

by the Director of the Company, if these tokens are in circulation.

16.5. In the event of termination of the Agreement, the withdrawal of Funds

accounted for by the Client in the Account (Personal Account) on his eWallet and/or

Accounts is carried out by the Company in the manner and with consideration of

restrictions established by this Agreement.

16.6. The Company has the right at any time, unilaterally and out of court, to amend

the Agreement or its individual components, also in terms that describe types and

amounts of remuneration to the Company.

16.7. Amendments to the Agreement for participation in trading or its individual

components in a unilateral out of court procedure shall be made by their posting

(publishing) on the Company’s website and/or in the Company’s mobile Application, if

such functionality is provided by the Company, in the form of a new version of the

document, or changes and/or additions to the current version of the document and

becomes binding upon the Company and the Client at the time of their posting

(publishing) on the Website and/or in the Company’s mobile Application, if such

functionality is provided by the Company, unless a different date for the entry into force

of amendments and/or additions is expressly stipulated.

17. APPLICABLE LAW AND DISPUTE RESOLUTION PROCEDURE

17.1. The relations of the Parties arising out of this Agreement and other documents,

that make an integral part hereof, shall be governed by the substantive law of the

Republic of Belarus.

17.2. Compliance with the claim procedure in relation to the settlement of disputes

arising in connection with this Agreement is mandatory.

17.3. Claims shall be sent in the following ways:

− in electronic form from an e-mail address

with an attachment to the letter of an

electronic copy of the signed claim drawn up on paper (if the claim is signed by a

representative – with an attachment of an electronic copy of an image of the document

confirming the authority of the representative);

− on paper by registered mail with acknowledgment of receipt or by mail delivery

services to the addresses of the place of residence (location) (with the attachment of

copies of documents confirming the representative’s powers, if the claim is signed by

the representative).

17.4. The claim indicates:

− last name, name, patronymic (name) of the applicant of the claim and the

person(s) to whom the claim is presented (recipient of the claim), their place of residence

(place of temporary residence) or location;

− date of the claim;

− the circumstances on the basis of which the claim was made;

Taking into account the requirements for the e-mail address of the Client, established by clause 7.7. hereof.

− evidence confirming these circumstances, as well as copies of documents

substantiating and confirming the presented claims, or extracts from them;

− requirements of the applicant of the claim with reference to legislation, provisions

of this Agreement or internal regulations of the Company;

− claim amount and its calculation, if the claim is subject to monetary value;

− bank details of the claimant (if any);

− a list of documents attached to the claim;

− other information required to resolve the dispute.

17.5. Upon the receipt of a claim, the relevant party shall respond to it within 30

calendar days from the date of its receipt. The response to the claim shall be sent in the

same way as the claim was received.

17.6. The claim is not subject to consideration if the claim has been submitted not in

accordance with clause 17.3 of this section; or the content of the claim does not

correspond to clause 17.4 of this section.

17.7. If the dispute that has arisen has not been settled through a complaint procedure,

and the Parties have not agreed to appeal to extrajudicial authorities to resolve the

dispute, it is submitted to the court at the location of the Company, determined in

accordance with the legislation of the Republic of Belarus. If the Client is a foreign legal

entity or a foreign organization that is not a legal entity, the dispute shall be resolved by

the International Arbitration Court at the Belarusian Chamber of Commerce and

Industry in accordance with its Rules. This reservation applies to all disputes,

disagreements or claims that may arise from or in connection with this Agreement and

the terms and conditions, including those related to its modification, termination,

performance, invalidity or interpretation.

17.8. The Client has the right to send to the Company an offer to use other out-of-

court dispute settlement methods in accordance with clause 17.7 hereof. The use other

out-of-court dispute settlement methods, in addition to the claim procedure, is allowed

only with the consent of the Client and the Company.

18. DISCLOSURE OF RISK RELATED INFORMATION

18.1. Tokens are not considered legal means of payment and are not secured by the

government, no administrative-territorial units or state bodies are liable to the owners of

tokens for the consequences that may arise in connection with the ownership and/or

disposal of tokens.

18.2. Transactions with tokens may lead to a complete loss of the monetary funds or

tokens transferred in exchange for tokens, including, but not limited to, situations that

result from volatility in the value of tokens; technical failures (errors); committing

illegal actions, including theft.

18.3. Transactions with tokens may not meet the expectations of the financial

(investment) result.

18.4. Among other things, the implementation of transactions (operations) with

tokens is associated, in particular, with the following risks:

18.4.1. The token market is unstable. The value of tokens can be subject to significant

fluctuations, and a person making transactions (operations) with tokens can either

increase or completely lose their assets (investments);

18.4.2. Any transactions (operations) with tokens are carried out by individuals at

their own risk and are irreversible;

18.4.3. The Company’s Trading System, like any other information and trading

system, is subject to the risks of malfunctioning caused by technical failures (errors),

although the likelihood of such risks being realized is minimized due to a wide range of

technical, software and organizational measures taken by the Company;

18.4.4. Some tokens sold by the Company can have value only if the Company’s

Trading System is used;

18.4.5. The lack of unified approaches to the legal regulation of the circulation of

tokens can lead to the fact that the consequences of operations (transactions) with tokens

may have a different legal assessment in different states.

19. FINAL PROVISIONS

19.1. If any provision of this Agreement or other documents, which make an integral

part of this Agreement

, is or becomes illegal, invalid, or unenforceable in any

jurisdiction, this shall not affect the validity or enforceability in that jurisdiction of any

other provision of this Agreement or other documents, which make an integral part of

this Agreement, or the validity or enforceability in other jurisdictions of this or any other

provision of this Agreement or other documents, which make an integral part of this

Agreement.

19.2. All provisions of this Agreement that by their nature shall survive expiration or

termination of this Document, including, without limitation, the provisions relating to

restrictions as to the use, prohibited activities, dispute resolution, will remain binding

and will continue to stay in force after the termination or expiration of this Agreement.

19.3. The headings in this Agreement are for reference only and do not affect the

drafting or interpretation of any provision.

19.4. Nothing in this Agreement creates representation relationships.

19.5. This Agreement supersedes any preliminary agreement or prior arrangement

between the Company and the User and/or the Client.

19.6. Minsk (Republic of Belarus) is recognized as the place of conclusion and

execution of this Agreement.

19.7. This Agreement shall enter into force as follows:

19.7.1. With regard to the registration procedure of the Account (Personal Account),

access to part of the functionality of the Trading System (without establishing relations

in terms of trading tokens, without the right to perform financial transactions and trading

and related obligations), Identification and Verification procedures – from the moment

of acceptance of the Agreement by the User on the Company’s Website and/or in the

Company’s mobile Application, if such functionality is provided by the Company;

Including, but not limited to, the rules for determining the size and procedure for collecting remuneration of the

cryptoplatform operator from clients, the rules for trading with the receipt of Borrowed tokens, the rules for trading digital

signs (tokens), the rules for obtaining the status of a token trading Member by a client (admitting a client to token trading), and

exclusion of the client from the number of token trading Members (deprivation of the status of a token trading Member) and

other internal regulations of the Company as posted (published) on the Company’s Website in full and/or in the form of separate

parts (extracts) as well as those not subject to mandatory publication.

19.7.2. Relations with the Client regarding token trading are established, and the

rights and obligations of the Client as a Trading Member arise from the moment of

successful Verification of his data and assignment of the “Verified” status.

19.8. The Agreement is valid until the Parties fulfill their obligations in full.

19.9. The circulation of tokens placed as part of the ICO through the Company’s

Trading Platform is carried out on the terms and in the manner prescribed in the White

paper declaration corresponding to a specific ICO located on the ICO Organizer’s

website.

19.10. When interpreting and applying this Agreement, its text in Russian takes

precedence over the version of this Agreement in any other language.

19.11. This Agreement is an accession agreement, has a mixed form, contains

elements of various agreements, with the restrictions and conditions set forth in the

Agreement, regardless of whether the Agreement contains a signature (electronic digital

signature).

20. DETAILS OF THE COMPANY

Pixel Internet Closed joint-stock company

Payer’s Identification Number 590995582. Legal address: 220004, Republic of

Belarus, Minsk, 4B Amuratorskaya St., premises 22, office 17. E-mail:

corporate@free2ex.com.

Appendix No.1 to the Agreement for

participation in token trading (for legal

entities and individual entrepreneurs) (as

amended on 01.10.2025)

TERMS USED IN THE AGREEMENT FOR PARTICIPATION IN TOKEN

TRADING (FOR LEGAL ENTITIES AND INDIVIDUAL ENTREPRENEURS)

AND OTHER DOCUMENTS OF THE COMPANY

Account (personal account), Cabinet is a unique record in the Trading System,

created on the basis of a set of data reported (provided) by an individual entrepreneur or

a legal entity on the webpage of the Company https://my.free2ex.com/Login and/or in

the Company’s Mobile Application, if such functionality is provided by the Company,

which provides a unique eWallet number and access to the Client’s Personal Account.

The data provided by an individual entrepreneur or a legal entity are reflected (stored)

in the Client’s Personal Account.

Balance is the total number of the Client’s tokens (Monetary Funds) on a separate

account (Trading Account) which is reflected on the account in the result of all

Operations, including operations of replenishing the Account and withdrawing Funds

from it, and, in terms of trading with obtaining borrowed tokens – the total number of

Client’s tokens on the Leverage Account, which is reflected based on the results of all

Leverage operations, including operations of replenishment of the Leverage account and

withdrawing Funds from it.

Irrevocable power of attorney is an irreversible power of attorney that is issued by

the Client to the Company when initiating a Long transaction or a Short transaction to

provide Company with a possibility of a Compulsory completion of transactions on

behalf of the Client in order to prevent the Client from incurring obligations in the

amount exceeding the amount of the Funds.

Irrevocable power of attorney at a Long Transaction authorizes the Company to

dispose on behalf of the Client of Token assets, previously acquired by the Client from

another Trading Member within the framework of the corresponding Long Transaction.

The disposition is carried out at the current price of a Token Asset at the time of such

disposition by the Company on behalf of the Client in exchange for the required number

of Trade coin tokens.

Irrevocable power of attorney at a Short Transaction authorizes the Company to

purchase Token Assets from another Trading Member in the same amount and of the

same type as Token Assets that were previously disposed by the Client to other Trading

Members within the framework of the corresponding Short Transaction on behalf of the

Client. The purchase is carried out at the current price of a Token Asset at the time of

purchase in exchange for the required number of Trade coin tokens.

Irrevocable offer is an irreversible offer that is provided by the Client when initiating

a Long or Short Transaction to ensure a possibility for the Company to perform a

Compulsory completion of transactions, which can be accepted by the Company in

specified cases.

Irrevocable offer at a Long Transaction authorizes the Company to acquire into

ownership from a Client the number of Token Assets previously acquired by the Client

from the Company within the framework of a corresponding Long Transaction. The

purchase is carried out at the current price of a Token Asset at the time of acceptance of

the offer in exchange for the required number of Trade coin tokens.

Irrevocable offer at a Short Transaction authorizes the Company to dispose to a

Client all the Token Assets that were acquired by the Company from a Client within the

framework of this Short Transaction. The sale is carried out at the current price of a

Token Asset at the time of the acceptance of the offer by the Company.

Verification is a set of measures to confirm the authenticity of the data of the User

and/or the Client obtained in the course of Identification.

White Paper Declaration is a document that includes information about the

activities for which investments are attracted by means of placing tokens, and a person

who is about to do it.

Monetary funds is money (US dollar, euro, Swiss franc, Chinese yuan, Russian

ruble, Belarusian ruble), electronic money of the Client, including money held by the

Company and assigned to the Client in his Account (personal account).

eWallet is an integral part of the Account (Personal Account), which is used for

accounting and storing the Funds transferred by the Client to the Company and reflected

by the Company on the Client’s eWallet in the Personal Account, allowing the Client to

perform operations of acquisition (disposition, exchange) of tokens in the Company’s

Trading System, including replenishment (transfer of Funds) to Accounts within the

Trading Platform, withdrawal of Funds from the Trading System.

Application (order) is an offer to perform an operation for acquisition (disposition,

exchange) of tokens, which also serves as an acceptance for such an operation, sent by

the Client to the Company through the Trading Platform and/or Trading System.

Borrowed tokens are tokens received by a Client into ownership from the Company

as part of a Borrowing transaction.

Borrowing transaction is a transaction for exchanging tokens, during which the

Company transfers a number of certain tokens requested by the Client into the ownership

of the Client, taking into account the ratio of the Borrowed tokens and the Deposit that

are confirmed for the Client by the Company (provision of the Borrowed tokens), and

the Client undertakes to transfer (return) the ownership of the same number of equivalent

tokens for Remuneration (Return on the Borrowing operation) to the Company.

Determination of the number of tokens transferred in exchange is carried out based on

the current value (price) of the corresponding tokens in the Trading System. To ensure

the Return on the Borrowing operation, a part of the Client’s tokens is unavailable for

use as a Deposit. For a Return on the Borrowing operation, the Company can unilaterally

withdraw from the Client’s account a number of tokens identical in type and quantity to

the Borrowed tokens.

Money Laundering Law is the Law of the Republic of Belarus No. 165-З “On

measures to prevent laundering of the proceeds of crime, terrorist financing and

financing of proliferation of weapons of mass destruction” dated 30 June 2014.

Identification is a set of activities for the establishment of customer data, which is

determined by the Law on prevention of laundering and internal regulations of the

Company. When registering a User before the conclusion of the Agreement, an

incomplete identification procedure is allowed, which is necessary to create an account,

and allows the user to test the functionality of the Trading System without performing

financial transactions and to make a decision on the need to establish relations with the

Company in terms of trading tokens.

An Investment Account is an account type that relates to the Trading account,

represents a unique record of the Client within the account, intended for recording the

Client's Funds, expressed in the account currency determined by the Company, and

performing transactions with the Funds on the Trading platform based on the Leverage

operations model with a leverage of x1 and with other features established by the

Company (account currency, asset type, size and procedure for determining

commissions, swaps, etc.). This type of account assumes the ability to open several

accounts, one for each type (depending on the assets and their analogues, a separate type

of Investment account is used: US Stocks and ETF, others - as the Company’s proposals

are received).

The Investment Account is opened in the name of the Client at his request, subject to

confirmation by the Client of the required representations.

Client is a legal entity or an individual entrepreneur (a Hi-Tech-Park resident) who

has entered into an agreement with the Company for participation in token trading,

created an account in the Trading System, who has duly passed Identification and

Verification, has been admitted to token trading and who commits (intends to commit,

has committed) an acquisition (alienation, exchange) operation with regard to tokens

with the Company or other Trading Members.

Cryptocurrency is tokens that represent cryptocurrencies and are admitted for

trading in the Trading System.

Leverage transaction is a Long or Short operation performed by a Client, where the

Client uses Borrowed Tokens.

Leverage Account is a unique record created by a Client in the Client’s Personal

Account, intended for the use by the Client when performing token exchange

transactions with the receipt of Borrowed tokens on the Company’s Trading Platform.

Legalization is laundering of the proceeds of crime, terrorist financing and financing

proliferation of weapons of mass destruction.

Personal Account is a part of the Trading System used for registration,

Identification, Verification, opening and closing of Accounts, access to eWallet and

Accounts, deposit and withdrawal of the Funds, exchange of the Cryptocurrency at the

current rate set by the Company, and performance of other actions within the Trading

System.

Long Transaction is a sequence of token exchange operations performed in the

following order:

Step 1: The Company, upon request of a Client, provides the Client with Trade coin

tokens by way of Borrowed tokens.

Step 2: The Client purchases Token Assets from another Trading Member or the

Company by exchanging their own Trade coin tokens (including Borrowed Tokens) for

Token Assets.

Step 3: The Client sells Token Assets to another Trading Member or the Company

by exchanging Token Assets for Trade coin tokens.

Step 4: The Client makes a Return on the Borrowing operation.

When making a Long operation, a Client makes investments based on his own

forecast of an increase in the price of the purchased Token asset.

By initiating a Long Transaction, a Client provides the Company with an Irrevocable

Offer and an Irrevocable power of attorney to provide the Company with an ability of a

Compulsory completion of transactions.

Deposit is a number of Trade coin tokens on the Client’s Leverage Account, which

can be used only for the Return on the Borrowing operation and payment of

remuneration to the Company for a Leverage transaction. The procedure for calculating

the amount of the Deposit is determined by the Company.

Company is Pixel Internet Closed joint-stock company, UNP 590995582, legal

address: 220004, Republic of Belarus, Minsk, 4B Amuratorskaya St., premises 22,

office 17. In the text of the internal regulations issued by Pixel Internet CJSC, it may be

referred to as “Company” or “FREE2EX”.

HTP is the High-Tech park of the Republic of Belarus.

User is a person who uses the Trading System, both being and not being a Client of

the Company. The User may be a person who has started the process of registration,

and/or Identification, and/or Verification of data, but has not completed Verification and

has not received the status of confirmed Verification. The User’s functionality is limited

to viewing the capabilities of the Trading System without the possibility of performing

transactions in it.

Liquidity provider is a legal entity that provides the Company, if necessary and at

the discretion of the Company, with an opportunity to ensure the fulfilment of

Company’s obligations to the Clients on performance of transactions for acquisition

(disposal, exchange) of tokens in the Trading System.

Notification on a Compulsory completion of transactions is a notification of the

Client by the Company about the need to provide additional Deposit and a Compulsory

Completion of Transactions in the event that additional Deposit is not provided within

the time limit and in the manner established by the Rules for Trading with the Use of

Borrowed Funds.

Compulsory completion of transactions is implementation of acceptance of the

Client’s Irrevocable offer by the Company, which is provided by the Client as part of a

Long Transaction or Short Transaction, in case the Token Assets Exchange Transaction

was made with the Company, or if the Token Assets exchange Transaction was executed

by another Trading Member, the Company’s actions to alienate or acquire Token Assets

(depending on the type of Leverage Transaction) on behalf of the Client under an

Irrevocable Power of Attorney issued by the Client as part of a Long Transaction or

Short Transaction. Compulsory completion of operations may be carried out by the

Company if, as a result of the completion of the Leverage transaction, the ratio between

the Funds on the Leverage Account and the Deposit is 100% or less. In order to avoid

contradictions, the ratio at which Compulsory Completion of operations is carried out is

calculated using the following formula:

Funds/Deposit*100% ≤ 100%

where,

Funds are Client’s Funds on the Leverage account,

Deposit has the meaning established by this Appendix and the Rules for trading using

borrowed funds.

Slippage is the difference between the token exchange price reflected in the Trading

System at the time the Client places an Order (for Market Orders) or the token exchange

price specified by the Client in the Order (for Pending Orders) and the actual price at

which the Order was executed. It may occur even in the event of a Compulsory

completion of transactions.

Approximate Balance is an estimated total amount of the Client’s Funds, reflected

in the Company’s mobile Application, if such functionality is provided by the Company

(or in the Web version of the Client’s Personal Account) by the results of all

Transactions, available on the Client’s eWallet, all types of currencies (tokens) on the

Client’s Accounts. The approximate balance is reflected in a conventional unit

(currency), for example, USD

Company’s application is a software application specially designed for installation

and use on mobile or other devices, used by the Company as a cryptoplatform operator

for interaction with the Client and integrated operation of the Company’s Trading

System.

Suspension of operations on a Leverage Account is an action performed by the

Company, as a result of which operation of the Client’s Leverage Account is suspended,

the Client can “enter” it, but is deprived of the opportunity to make (carry out) any

Transactions (operations) using it, and is also deprived of the opportunity to transfer the

Funds (money, electronic money, tokens) from the corresponding Leverage account to

another account.

Close-only mode is the mode of an operation of the Trading platform in relation to a

certain market or type of tokens, which is established by the Company on its own

decision in the following cases: a) exclusion of tokens from trading on the Trading

Platform (delisting); b) performance of Corporate actions; c) negative price for a Token

asset, and is characterized by the following:

• the Client is not entitled to purchase tokens in the market in respect of which the

Close-Only mode is set and to start Trading or Leverage Transactions in relation to such

tokens;

• the Client can dispose of tokens of this market (such tokens) at trading tokens or

in any other way determined by the Company, and complete (terminate) Trading and

Leverage operations in relation to such tokens.

Company’s website means any website addresses used by the Company as an

operator of the cryptoplatform, including the website of the Company

https://www.free2ex.com/, website of the Trading Platform https://live.free2ex.com,

website(s) of the Personal Account: https://my.free2ex.com /Login/, trading terminals of

the Trading Platform allowing the User or the Client to interact with the Company in the

Web version of the Personal Account (the Web version of the Personal Account).

Solely for the convenience of the Client, the approximate balance is reflected in the reference amount and in a

certain conventional unit (currency, token, etc.). The Company has the right to unilaterally change the settings for

displaying the Approximate Balance.

Transaction is an operation for acquisition (disposal, exchange) of tokens between

Trading Members, which means execution of two counter Applications (orders), or

between a Trading Member and the Company.

Funds means money, electronic money, digital signs (tokens), including the Client’s

cryptocurrencies and Trade coin tokens the title to which was received by the Client

from the Company.

Order book is a list of unexecuted pending Applications (orders) on the Trading

Platform. Each pending Application (order) contains the price and the quantity of tokens

of the Funds necessary to perform a Trading operation.

Parties are participants of the Agreement for taking part in token trading (Client

and Company).

Account is any type of the account classified as a Trading Account.

Terminals means specialized software available for downloading on Android, iOS,

Windows platforms or through a web browser, by means of which the Client gains

access to the Trading Platform (web terminal, mobile terminal, win terminal, etc.).

Token Asset is a digital sign (token) admitted to trading in the Trading System, which

certifies the owner’s right to require the person who placed it to purchase this token at

the cost of a certain asset (currency, security, precious metal, index, exchange asset),

which this asset has at the time of satisfaction of such a requirement.

Trade coin tokens are tokens of the Company that certify that their owner has the

rights specified in a corresponding White Paper Declaration posted on the Company’s

website.

Trading Transaction is a transaction related to purchase (disposal, exchange) of

tokens on the Trading Platform, which is not a Leverage operation.

Trading platform is a software package of the Company designed to perform

transactions of acquisition (disposition, exchange) of tokens, including transactions with

the receipt of Borrowed tokens.

Trading Accounts shall mean Crypto accounts, Leverage Accounts, Investment

Accounts, and other accounts, which, depending on the administrative and technical

settings of the Trading System, may be offered for opening and maintenance by the

Company for trading tokens on the Trading Platform.

Crypto account is a unique record of the Client within the framework of the account,

intended for accounting the Client’s Funds used to perform Trading operations (without

receiving Borrowed Tokens). One Crypto account is created for the Client (depending

on the settings of the Trading System and by the decision of the Company, creation of

several Crypto accounts may be proposed). A Crypto account is opened automatically

in the name of the Client upon assignment of the status of a Trading Member and

admission to trading.

Trading system is a term used by the Company to combine such parts of the software

complex as an Account (Personal Account), Terminal, Trading platform, Client’s

Personal Account into a single concept, as well as other options that may be added by

the Company from time to time, functionally related to each other, which are subject to

And prior to receiving the status of a Trading Member – the User

all internal regulations adopted by the Company from time to time (or amended by it

from time to time).

Required Balance is a number of Trade coin tokens that must be present on a Client’s

Leverage Account by way of a Deposit.

Trading Member is a Client admitted by the Company to token trading.

Price gapping (gap) is the difference between the closing price of the previous

timeframe (chart component) and the opening price of the next one. As part of working

on the Trading Platform, Price Gapping visually corresponds to the “gap” between

neighboring components on the price chart.

Short Transaction is a sequence of token exchange operations performed in the

following order:

Step 1: The Company, upon request of the Client, provides the Client with a Token

Asset by way of Borrowed Tokens.

Step 2: The Client sells Token Assets (including Token Assets received by way of

Borrowed Tokens) to another Trading Member or the Company by exchanging Token

Assets for Trade coin tokens.

Step 3: The Client purchases from another Trading Member or the Company the same

number of Token Assets by exchanging their own Trade coin tokens for Token Assets.

Step 4: The Client makes a Return on the Borrowing operation.

In the process of making a Short Transaction, the Client makes investments based on

his own forecast of a decrease in the price of Token Assets received by the Client by

way of Borrowed Tokens.

By initiating a Short Transaction, the Client provides the Company with an

Irrevocable Offer and an Irrevocable Power of Attorney to provide the Company with

an opportunity for a Compulsory completion of transaction.

Appendix No.2 to the Agreement for

participation in token trading (for legal

entities and individual entrepreneurs)

(as amended on 01.10.2025)

1. The following types of Applications (orders) can be used in the Trading Platform.

For the purpose of this Appendix, an Application (order) shall mean only an offer to

perform an acquisition (disposal, exchange) operation with regard to tokens, which also

serves as an acceptance under such an operation, sent by the Client to the Company

through the Trading Platform:

Market orders:

⎯ Market Sell order is an order for token disposal in exchange for another token at

the best price as at the time of order execution;

⎯ Market Buy order is an order to purchase a token in exchange for another token

at the best price as at the time of order execution.

Pending orders:

⎯ Buy Stop pending order is an order for the purchase of a token in exchange for

another token at a price higher than the current best price for the purchase of a token.

⎯ Buy Limit pending order is an order for the purchase of a token asset in exchange

for another token at a price lower than the current best price for the purchase of a token.

⎯ Sell Stop pending order is an order for the disposal of a token in exchange for

another token at a price higher than the current best price for the sale of a token.

⎯ Sell Limit pending order is an order for the disposal of a token in exchange for

another token at a price lower than the current best price for the sale of a token.

⎯ Buy Stop Limit pending order is an Order to place a Buy Limit pending Order

when the token reaches the specified Buy Stop price level.

⎯ Sell Stop Limit pending order is an Order to place a Sell Limit pending order

when the token price reaches the Sell Stop price level.

⎯ Stop Loss pending order (available when trading with the receipt of Borrowed

tokens);

⎯ Take Profit pending order (available when trading with the receipt of Borrowed

tokens);

⎯ Hidden order (Iceberg order) is an order for the acquisition or disposal of tokens,

which is automatically divided into a number of orders for the acquisition or disposition

of fewer tokens and, as a result, is not partially reflected in order (application) book.

Some types of Applications (Orders) may not be available for a certain period of time

due to the lack of necessary functionality in the Trading System.

2. For the placement of a Market Order the trading Member shall specify the amount

of the token for acquisition or disposal at the best available price. If a Trading Member

wants to purchase or dispose of a token at a specified price in a larger volume than the

available one, the Member can specify the desired volume before placing a Market

Order. In this case the available Volume will be purchased (disposed), and the missing

Volume will be purchased (disposed) at the next best price.

3. For the placement of a Pending Order, including the relevant Hidden Order, the

Trading Member shall specify the amount of the token for acquisition or disposal and

the desired acquisition (disposal) price. The Pending Order for disposal will be executed

when the price of the placed Order becomes equal or the best price for disposal in the

Order book and a counter Order is placed from another Trading Member.

For the placement of a Pending Stop Limit Order (Buy Stop Limit, or Sell Stop Limit,

or the corresponding Hidden Order), the limit price for order execution (Buy Limit or

Sell Limit) is additionally indicated.

4. An Order placed by a Trading Member is both an offer and an acceptance of the

transaction for acquisition (disposal, exchange) of tokens.

5. Orders, depending on the volume and price specified in them, can be executed by

the Company in parts, excluding Market Orders and Sell Stop and Buy Stop Orders. In

case of partial execution of an Order, the price at which this Order is executed may differ

from the price for tokens that the Client has seen in the Trading System and/or when

sending the Order.

6. A mandatory requirement is that the Trading Member has the Funds to execute

the placed Order. Orders are placed after instant automatic verification of the availability

of a sufficient number of tokens (Monetary Funds) on the relevant trading account of

the Trading Member in his Personal Account. A Trading Member’s order is not placed

if the number of tokens (Monetary Funds) on the trading Account of the Trading

Member in the User Account is insufficient for the transaction.

7. When performing transactions, the market price, based on which transactions are

performed between Trading Members for all traded tokens, is determined by demand

and supply among Trading Members and is available at the address on the Company’s

website (https://live.free2ex.com/). It is understood that the Trading Platform first of all

automatically offers to the Trading Member who has placed the Order a counter Order

of another Member, taking into account the best price. If several token trading Members

send Orders with identical or similar characteristics (the volume and/or the price), the

Orders shall be executed in succession taking into account the time of their sending, i.e.

the Order which has been placed earlier shall be executed prior to the Order placed later

by the relevant Trading Member.

8. Orders are executed by reflecting the tokens owed to the token trading Members

on the Crypto accounts. This reflection is made by the Company automatically at the

time of Order execution, after which the obligations of the Trading Members to each

other are considered fulfilled. The procedure for the execution of Orders while dealing

with Investment Accounts and Leverage Accounts is determined in accordance with the

principles of application of the Rules for trading tokens with receipt of Borrowed

Tokens.

9. An order placed by a Trading Member may be partially executed. In this case,

based on the preprogrammed algorithm, the Trading Platform, on behalf of the Trading

Member who originally placed the Order, issues a new Order in the amount of an

unexecuted volume of the Order, while maintaining the conditions of the original Order.

10. The Order is considered to be executed from the moment when the acquisition

(disposal) of the corresponding number of tokens is reflected on the Crypto accounts of

the Trading Members.

11. A Trading Member has the option to withdraw (cancel) his Order. Cancellation

of an Order by the Trading Member may be performed only till the moment when the

Order is considered to be executed.

12. The Trading Member has the right to edit the previously placed Order, which is

located in the Order Book specifying a new price level and/or Order volume. After

setting the new Order parameters, the Trading System checks the availability of the

sufficient number of tokens (Monetary Funds) on the Trading Member’s account to

ensure that the Order has the new parameters. If there are not enough tokens on the

Trading Member’s Trading Account and/or Leverage account to secure an Order with

new parameters, the Order is not edited. A Market order can be edited only until the

moment when the Order is considered to be executed. A Limit order can be edited until

the moment of complete execution of such an Order to the extent in which the Limit

order has not been executed.

13. The whole history of the Trading Member’s Operations is saved and available for

viewing in their Account (Personal Account).

14. An order received by the Company is accepted by the Company’s Trading

System only if the following circumstances are present in the aggregate:

− the Order meets the requirements for its content stipulated for the Order form

(including the type and the number of tokens (amount of the Monetary Funds) that

constitute the provision for the execution of the Order by the Client);

− the Company has an opportunity to execute the Order. Such an opportunity may

not be available, in particular, because of the lack of liquidity (including the situation

when it is the result of its non-submission by the Liquidity Provider), as well as for

technical and other reasons;

− the number of the Client’s tokens (Monetary Funds) assigned to the Client on his

Trading Account is sufficient for the execution of the Order (unless otherwise is

provided for by the Order form or determined by the Company in any other way).

15. The result of the transaction may not be in favour of the Client, including due to

Slippage or a Price gap. In this case, the Client may potentially not only lose all funds

on the trading account, as well as receive a negative balance if the amount of the loss

under the transaction was higher than the Client’s balance on the Account.

The Client accepts the risks: even with a Compulsory completion of transactions

(closing of positions), it may be impossible to completely prevent losses.

The Company does not provide guarantees for writing off (zeroing, covering) the

debt if, in the case of a Compulsory completion of transactions, the Client has a negative

Balance.

Appendix No.3 to the Agreement for

participation in token trading (for

legal entities and individual

entrepreneurs) (as amended on

01.10.2025)

Unused accounts

1. The Company has the right (according to the decision made by the Company) to

assign the Account (Personal Account) the status of an unused Account (Personal

Account) in the following cases:

1.1. The Account (Personal Account) has not been used by the Client for performing

trading operations, depositing and withdrawing Funds, purchasing (disposal,

exchanging) in the Trading System for more than 180 days.

1.2. The Client lives without consideration the requests of the Company (namely,

does not respond orally, in writing, in messengers, or provides information that does not

correspond to the sent request, creates the appearance of responses, unreasonably delays

the response time, or ignores the requests of the Company) aimed at fulfilling the

obligations of the Client, as well as the rights and obligations of the Company

established by clauses 3.1 (a), 3.1 (h), 4.1 (b), 4.1 (d), 7.6, 7.7, 7.9, 7.10, 7.11, 7.12,

7.13, 7.15, 8.8 and any clause from section 6 of the agreement for participation in token

trading.

1.3. On the basis of another violation by the Client of the terms of the agreement for

participation in token trading, or by a reasoned decision of the Company.

2. The unused Accounts (Personal Accounts) are assigned the status of a

“deactivated Account” (deactivated Personal Account).

3. The Company notifies the Client about the upcoming deactivation 15 (fifteen)

calendar days before the expected date of deactivation of the Account (Personal

Account).

4. In the event that the Client received a notification of deactivation of the Account

(Personal Account), and the Funds were accounted on the eWallet and/or the Trading

Account(s) for the Client, as well as incomplete Leverage operations have been opened,

the Client undertakes to complete Leverage Operations using Leverage Accounts, to

withdraw the remaining Funds, having previously made an internal transfer of the Funds

from the Accounts, within 15 (fifteen) calendar days, taking into account the withdrawal

requirements imposed by the Company under the terms of the contract for participation

in token trading.

5. If the Client does not withdraw the Funds within 15 (fifteen) calendar days, the

Company has the right to withdraw the Funds to the Client’s current (settlement) bank

account, bank card, electronic wallet, address (identifier) of the virtual wallet.

6. The unused Accounts (Personal Accounts) may be subject to a fee for

maintaining unused (inactive) Accounts. If such fees are applied, the Company informs

the Client about this by sending him a corresponding notification.

The fee may be applied in a fixed amount, or at the rate equivalent to the

remaining balance of the Funds, or in any other amount set by the Company at its

discretion.

Such a fee may be set both on a permanent basis (for an indefinite period till the date

of its abolition) or for a certain period of time.

7. In the event that the Client did not take measures to withdraw the Funds (did not

make a withdrawal of the Funds) from the eWallet within the specified period and the

Company does not have the opportunity to withdraw the Client’s Funds to their current

(settlement) bank account, bank card, electronic wallet, address (identifier) of the virtual

wallet, including because of the blocking or closing of such a current (settlement) bank

account, bank card, electronic wallet, virtual wallet address (identifier), the Company

has the right to keep the Client’s Funds until the Client takes measures to withdraw the

Funds or the Company will be able to withdraw the Client’s Funds to their current

(settlement) bank account, bank card, electronic wallet, address (identifier) of the virtual

wallet. In the event of the occurrence of the circumstances described in this clause and

from the moment the Account (Personal Account) is assigned the status of a deactivated

Account (Personal Account), a storage relationship arises between the Client and the

Company on the following conditions:

7.1. The Company (keeper) undertakes to keep the Client’s (depositor’s) Funds

assigned to him on the eWallet in the Company’s Trading System. The Company, in

order to ensure the safety and accounting of the Client’s Funds, has the right to transfer

the Funds from the Client’s Trading Account(s) to the Client’s eWallet in the

Company’s Trading System.

7.2. Change the method, place and other storage conditions by notifying the Client in

writing when such a change in storage conditions is necessary to ensure the safety of the

Funds.

7.3. The place of storage of the Client’s Funds – addresses (identifiers), bank

accounts, electronic wallets of the Company.

7.4. The Company accepts for safekeeping the Client’s Funds from the moment (date)

of assigning to the Account (Personal Account) the status of a deactivated Account

(deactivated Personal Account).

7.5. The Company has the right to charge the fee for the storage of the Funds,

deducting the fee from the Client’s Funds on a monthly basis, or as a lump sum after the

expiration of their storage period. The Company notifies the Client about the amount of

remuneration for keeping the Funds.

7.6. The expenses of the Company for the storage of the Funds are not included in the

remuneration for storage.

7.7. The storage period is 3 (three) years, starting from the day the Account (Personal

Account) is assigned the status of a deactivated Account (deactivated Personal

Account).

7.8. After the expiration of the specified storage period and on condition that the

Client has been notified, the Company has the right to dispose of the Funds (tokens) and

exchange them (sell them) for cash at a market price prevailing at the time of the decision

to sell tokens. The amount of the funds received from the sale (exchange) is transferred

to the Client, and if after the sale (exchange) of the Funds (tokens) the Client does not

withdraw funds, they remain in the storage of the Company for a new period, under the

same conditions, except for the condition on the amount of remuneration, or terms of

collection of the fee for maintaining unused (inactive) Accounts (Personal Accounts),

which will be valid for the Client in the amount established by the Company at the time

of sale (exchange) of the Funds (and which may change from time to time).

7.9. In the event that the conditions of clause 7 are applied to the Client not in

connection with circumstances arising from and aimed at fulfilling the obligations of the

Client, as well as the rights and obligations of the Company established by clauses 3.1

(a), 3.1 (h), 4.1 (b), 4.1 (d), 7.6, 7.7, 7.9, 7.10, 7.11, 7.12, 7.13, 7.15, 8.8, as well as any

clause from section 6 of the agreement for participation in token trading, the Client has

the right to demand to return the Funds at any time, except for clause 7.8. hereof, where

the Client has the right to demand to return the Funds.

7.10. In the event that the conditions of clause 7 apply to the Client in connection

with the circumstances arising from and aimed at fulfilling the obligations of the Client,

as well as the rights and obligations of the Company established by clauses 3.1 (a), 3.1

(h), 4.1 (b), 4.1 (d), 7.6, 7.7, 7.9, 7.10, 7.11, 7.12, 7.13, 7.15, 8.8, as well as any clause

from section 6 of the agreement for participation in token trading, the Client has the

right to demand to return the Funds, and in the event of occurrence of the circumstances

provided for in subclause 7.8. hereof, where the Client has the right to demand to return

the Funds, only after the requests of the Company have been totally fulfilled.

7.11. Other provisions of the legislation of the Republic of Belarus also apply

to the relations established by clause 7, which are not regulated by subclauses of clause

Appendix No. 4 to the Agreement for

participation in token trading (for

legal entities and individual

entrepreneurs) (as amended on

31.03.2026)

On the placement and sale of digital signs (tokens)

This Appendix is an additional agreement to the Agreement for participation in token

trading (hereinafter referred to as the “Supplementary Agreement”), which is concluded

between Pixel Internet Closed joint-stock companyand the Investor of Pixel Internet

Closed joint-stock company.

Compliance with the terms of this Supplementary Agreement is mandatory for all

Investors who plan to carry out and/or acquire digital signs (tokens) through the ICO

Investment account.

The Supplementary Agreement is concluded by accepting the Agreement for

participation in token trading (hereinafter referred to as the “Agreement”) in electronic

form, by putting a mark of consent with the terms of the Agreement and other documents

that are an integral part of this Agreement.

TERMS AND DEFINITIONS

In addition to the terms set forth in Appendix No. 1 to the Agreement, the following

terms apply to this Supplementary Agreement:

Customer is a person acting as an ICO customer in the process of issuing Tokens for

the Project.

Investors are individuals and legal entities who may be non-residents of the Republic

of Belarus or residents who meet the qualification requirements set forth in clause 4.2

of the Supplementary Agreement, who acquired a Token(s) during the initial placement

of tokens on the ICO Organizer’s platform or through the acquisition of a Token(s) from

its (their) owner (secondary acquisition).

ICO Investment Account is a unique Investor’s record within the Account (Personal

Account), designed to account for the Investor’s funds used to purchase digital signs

(tokens) within the ICO.

ICO Organizer is Pixel Internet CJSC, a cryptocurrency platform operator that

provides the Customer with services for the placement of tokens.

Project is an investment project implemented by the Customer or in which the

Customer participates, for which funding is attracted through ICO.

Token shall mean a token issued within the ICO for Project implementation.

1. SUBJECT OF THE SUPPLEMENTARY AGREEMENT

1.1. Under this Supplementary Agreement, the ICO Organizer undertakes to sell the

Customer’s Tokens to Investors in the manner and under the conditions established in

the White paper declarations corresponding to certain ICOs and Tokens created and/or

placed within such ICOs by the ICO Organizer located on the ICO Organizer’s website,

as well as on the respective websites of the Customers.

1.2. The sale of Tokens is organized for the purposes of implementation of Projects,

as defined in section 2 of this Supplementary Agreement

1.3. Tokens are sold by the ICO Organizer by providing the Investor with:

a) access to the Account (Personal Account) and technical support when using

this Account (Personal Account);

b) an ICO Investment account in the Account (Personal Account)/in the Trading

System; and using such an Account;

c) an opportunity for the Investor to acquire, store, dispose of Tokens

, as well

as an opportunity to take actions necessary to implement the rights

(requirements) of the Investors as owners of Tokens, stipulated during their

creation and placement (rights to the objects of civil rights, which are certified

by tokens).

1.4. The volume of the Tokens to be sold and the conditions for their sale are

stipulated in the corresponding White paper declaration published on the website of the

ICO Organizer and the ICO Customer.

1.5. The conditions and procedure for the circulation of Tokens acquired as part of

the ICO, including the rights (claims) of the owners of Tokens, conditioned upon their

creation and placement (rights to objects of civil rights, which are certified by Tokens),

are established in the corresponding White paper declaration posted both on the website

of the ICO Organizer and that of the ICO Customer.

2. GENERAL INFORMATION ABOUT TOKENS SOLD

2.1. The prospects and characteristics of the Project for which investments are

attracted, as well as the calculation of financial costs, are described in detail in the

corresponding White paper declaration available on the ICO Organizer’s website.

2.2. The Customer undertakes to use the funds raised in exchange for the issued

tokens exclusively for the purposes specified in the White Paper.

2.3. The Customer is prohibited from using the funds raised for purposes prohibited

by the legislation of the Republic of Belarus.

2.4. All payments are made exclusively through the accounts and/or virtual wallets

of the ICO Organizer.

3. GENERAL DESCRIPTION OF THE RELATIONSHIP OF THE PARTIES

3.1. The organizer of ICO is a resident of the HTP, the business project of which

specifies the type of activity that provides the rendering of services related to the

Access to the Account (Personal Account) is carried out on the terms and in the manner provided for by the

Agreement and taking into account the requirements of this Supplementary Agreement.

To the extent of the rights (claims) of the owners of Tokens, conditioned upon their creation and placement

(rights to objects of civil rights, which are certified by Tokens), provided for in the corresponding White Paper

declaration.

creation and placement of tokens using the Internet, including services for the promotion

of tokens, consulting and other related services.

3.2. Detailed data of the Customer, including information about the beneficial

owners, are indicated in the corresponding White paper declaration located on the

website of the ICO Organizer and that of the ICO Customer.

3.3. The ICO organizer will take legal, organizational, and technical measures aimed

at identifying and preventing unauthorized payment transactions and token transactions.

3.4. The ICO organizer will take measures to ensure that employees and other

involved parties are aware of the legislation and local regulations governing the creation

and placement of tokens.

4. REQUIREMENTS FOR INVESTORS

4.1. When concluding this Supplementary Agreement to the Agreement and

throughout the entire period of use of the ICO Investment account in the Account

(Personal Account), the Investor simultaneously assures and guarantees that:

a) the Investor is a person over the age of 18 and is a person capable of

participating in token trading, subject to the terms of the Agreement, this Supplementary

Agreement and the legislation of the state of which he is a citizen (for individual

entrepreneurs) or a legal entity duly registered and operating in accordance with the

legislation of jurisdiction of its registration (for legal entities);

b) the Investor acts on his own behalf, and not on behalf of another person (with

the exception of duly authorized representatives of the Investor

– a legal entity);

c) the Investor is not an individual entrepreneur who permanently resides (is

permanently domiciled, including for taxation purposes) in the states (territories)

included in the list of jurisdictions for which the provision of services by the Company

is limited, available at the principal website of the ICO Organizer

https://files.free2ex.com/download/legal/doc/jurisdictions_en.pdf);

d) the Investor is not an individual entrepreneur or a legal entity included in the

List of organizations and individuals involved in terrorist activities, approved by the

State Security Committee of the Republic of Belarus, as well as a legal entity whose

beneficial owner is included in this List;

e) the Investor will not carry out criminal or other illegal activities through the

Account (Personal Account), including but not limited to Legalization of proceeds, fraud

or any other crime;

f) the Investor will not use any insider information about tokens in an unfair

(unlawful) way;

g) the Investor will not allow other persons to use their Account (Personal

Account) (with the exception of their duly authorized representatives, if the Investor is

a legal entity);

Client - for the purposes of the Agreement.

h) the Investor will not carry out any activity that violates this Agreement and/or

causes (may cause) damage to other Investors and/or the ICO Organizer, including using

malicious software, carrying out hacker attacks, spreading “spam”, etc.

4.2. The ICO organizer is entitled to independently determine the criteria that non-

residents of the Republic of Belarus, as well as legal entities of the Republic of Belarus,

shall meet in order to sell their tokens (including requirements for financial standing and

reputation).

After registering in the ICO Organizer’s Information System, passing the Investor’s

Identification and Verification procedure in case the criteria are determined by the ICO

Organizer, and providing representations or documents confirming property status,

income or experience, the Investor is assigned the status according to the established

criteria (qualified, highly qualified, other).

4.3. When the ICO Organizer implements clause 4.2., the Client shall notify the ICO

Organizer of the loss of the status of a qualified or highly qualified investor before

carrying out the token purchase transaction.

The ICO Organizer is not entitled to sell tokens to an Investor from the moment of

receiving notification of the loss of the status of a qualified and/or highly qualified

investor by such an investor, or should he fail to provide the requested documents

(information).

4.4. The ICO Organizer does not sell Tokens to:

a) individual entrepreneurs under the age of 18;

b) individual entrepreneurs registered in the Republic of Belarus without an HTP

resident status.

c) non-residents of the Republic of Belarus, if this contradicts the legislation of the

state, the citizens (subjects) of which are non-residents of the Republic of Belarus and/or

on the territory of which they have a permanent place of residence in accordance with

the residence permit (or a similar document) (for individual entrepreneurs) or location

(are established, registered);

d) persons added into the list of organizations, individuals, including individual

entrepreneurs, involved in terrorist activities, as well as legal entities whose beneficial

owners are added into this list;

e) other persons, if provided for by legislation, acts of the Supervisory Board of

HTP, contractual obligations of the ICO organizer or internal regulations of the ICO

organizer.

5. CONTENTS OF TERMS FOR THE SALE OF TOKENS TO INVESTORS

5.1. To obtain the status of an Investor, an individual entrepreneur or a legal entity

concludes an Agreement and this Supplementary Agreement by putting a mark of

consent to conclude an Agreement on the terms proposed in it, creates an Account

(Personal Account) and an eWallet, undergoes Identification and Verification

procedures, opens (creates) an ICO Investment account.

5.2. The ICO Organizer reserves the right to verify any representations and guarantees

provided by the Investor at any time throughout the validity period of this

Supplementary Agreement.

5.3. The ICO Organizer carries out the process of Identification and Verification of

the Investor in the same way as this process is defined in the Agreement.

5.4. The ICO Organizer ensures the storage of confirmation of the fact of receipt of

guarantees and representations (as well as the results of verification of such

representations, if it has been performed), documents and data confirming the Investor’s

status (if any) for at least 5 years from the date of its receipt.

5.5. The ICO Organizer has the right to periodically send the Investor a request to

update information and documents, as defined in the Agreement.

5.6. The Investor sells Tokens in the secondary market as a Trading Member, as

defined in the Agreement, taking into account the provisions of the corresponding White

paper declaration available on the website of the ICO Organizer and the Customer.

5.7. In cases determined by the legislation in the field of preventing Legalization of

proceeds, the Organizer has the right to freeze funds, including by imposing a ban on

the disposal of tokens by their Investors and a ban on the fulfillment of obligations in

terms of Tokens by the Customer.

6. RIGHTS AND OBLIGATIONS OF INVESTORS, ICO ORGANIZER

6.1. The rights and obligations of the Investors, the ICO Organizer are stipulated in

the corresponding White paper declaration, available on the website of the ICO

Organizer and the Customer.

6.2. The rights and obligations of the Investors, the ICO Organizer are carried out in

a similar manner, as defined in the Agreement in the part which is non-contradictory to

the White paper declaration, available on the website of the ICO Organizer and the

Customer.

6.3. When providing token placement services as an ICO Organizer, as well as when

independently placing its own tokens, the Company shall:

6.3.1. comply with the requirements of the HTP Supervisory Board’s acts, act

reasonably and in good faith;

6.3.2. ensure that the first token holders are provided with all the information that

needs to be communicated to them;

6.3.3. post White Paper declarations on its website on the Internet, containing

information and conditions as per the acts of the HTP Supervisory Board, as

well as the location of the annual and interim (quarterly) accounting (financial)

statements of the Customers (when placing own tokens – statements of the

Company) and other information which is subject to placement on the websites

on the Internet;

6.3.4. take organizational and technical measures aimed at excluding the sale of

tokens in violation of the requirements stipulated by the acts of the HTP

Supervisory Board;

6.3.5. take measures aimed at identifying the circumstances that serve as the grounds

for suspending the placement of tokens;

6.3.6. immediately notify clients of suspending the placement of tokens and of the

circumstances that served as the ground for the suspension of their placement,

as well as of the information received (revealed) about significant facts

(events, actions) related to the financial and economic activities of Customers

(when placing own tokens – information related to the Company);

6.3.7. perform other obligations in accordance with the acts of the HTP Supervisory

Board.

6.4. When providing token placement services as an ICO Organizer, as well as when

independently placing its own tokens, the Company undertakes to suspend token

placement in the following cases:

a) the start of the Customer’s reorganization (liquidation) procedure (when placing

own tokens – initiation of the reorganization (liquidation) procedure of the Company);

b) initiation of economic insolvency (bankruptcy) proceedings against the Customer

(when placing own tokens – against the Company);

c) the occurrence of facts of non-performance (improper performance) by the

Customer (when placing own tokens – by the Company) of obligations in relation to

outstanding equity securities, tokens;

d) existence of other circumstances that may significantly affect the proper

performance by the Customer (when placing own tokens – by the Company) of its

obligations to the token holders.

7. RELATIONSHIP BETWEEN THE ICO ORGANIZER AND THE

CUSTOMER

7.1. The Customer and the ICO Organizer enter into an Agreement for the provision

of services within the framework of the ICO, which sets forth the terms of the token

creation method, the deadline(s) for the transfer by the ICO Organizer to the Customer

of civil rights assets received by the ICO Organizer from the initial holders of the issued

tokens, the Customer’s obligation to disclose on his website on the Internet his annual

and interim (quarterly) accounting (financial) statements within the time limits and

consisting of the documents established by the HTP’s requirements, the Customer’s

obligation to maintain separate accounting (for foreign Customers – other separate

records), the Customer’s obligation not to make amendments and/or additions to the

White Paper declaration after the start date of the token placement (with exceptions

according to the requirements of the HTP’s Supervisory Board), as well as other

essential conditions stipulated by the requirements of the legislation and acts of the

HTP’s Supervisory Board.

7.2. The ICO Organizer provides services exclusively to Customers who comply with

the requirements of the legislation of the Republic of Belarus and the regulations of the

HTP Supervisory Board.

7.3. The ICO Organizer is obligated to refuse to provide the Customer with token

creation and/or placement services if the Customer fails to meet one or more

requirements stipulated by the HTP Supervisory Board's regulations governing the

provision of services related to the creation and placement of digital tokens (tokens) and

the creation and placement of proprietary digital tokens (tokens), and if the ICO Services

Agreement does not stipulate that the ICO Organizer will provide acceptable services

aimed at ensuring the Customer's compliance with the requirements at the time of the

token placement commencement and to be provided prior to the token placement

commencement date.

7.4. If necessary, the ICO Organizer is obligated to request from the Customer

documents and information necessary to confirm compliance with legal requirements

and not enter into an ICO Services Agreement until these documents and information

are provided.

7.5. Detailed information about the relationship between the Customer and the ICO

Organizer, including the ability to influence each other's decisions and the parties'

affiliations, is specified in the relevant White Paper, located on the ICO Organizer and

the ICO Customer's website, and is also governed by the ICO Services Agreement.

7.6. The ICO Organizer is obligated to develop a White Paper if a White Paper

compliant with the requirements of the law and the ICO Organizer is not provided by

the Client prior to the conclusion of the Agreement.

7.7. The White Paper is approved by the Customer's manager prior to the

commencement of the token placement, indicating the approval date.

7.8. If the information contained in the White Paper or in the information provided

by the Customer for its development is inaccurate, the Customer shall indemnify the

ICO Organizer for any losses incurred, pay compensation for compensatory losses, and

bear liability for the Customer's violation of the information accuracy requirements in

the ICO Services Agreement.

7.9. If the information is found to be inaccurate, the ICO Organizer has the right to

unilaterally terminate the contract with the Customer for the provision of ICO services.

7.10. The Customer is obligated to disclose information about material facts (events,

actions) related to its financial and economic activities that may affect the value of its

tokens, to the extent required by the HTP Supervisory Board.

8. REDEMPTION OF TOKENS

8.1. The redemption of Tokens is carried out in the manner as defined in the

corresponding White paper declaration available on the website of the ICO Organizer

and the Customer.

9. LIABILITY OF THE PARTIES. MEASURES TO FULFILL THE

OBLIGATIONS OF THE ICO ORGANIZER

9.1. The liability of the Parties is determined and occurs in the manner specified in

the corresponding White paper declaration available on the website of the ICO

Organizer and the Customer, also, with regard to relations regulated by the Agreement

and Supplementary Agreements – as defined in the Agreement and in the Supplementary

Agreement, in the part which is non-contradictory to the White paper declaration.

9.2. Clauses of section 4, section 5 are the essential terms of this Supplementary

Agreement. In case of violation by the Investor of clauses 4 and 5 of this Supplementary

Agreement, this Supplementary Agreement shall be deemed not concluded, and

transactions made within its framework shall be invalid.

10. OTHER PROVISIONS

10.1. Information about risks is delivered in the manner as defined in the

corresponding White paper declaration located on the website of the ICO Organizer and

the Customer.

10.2. Other provisions that are not specified in this Supplementary Agreement and

Agreement are regulated in the manner as defined in the corresponding White paper

declaration available on the website of the ICO Organizer and the Customer, and by the

legislation of the Republic of Belarus.

10.3. From the moment the Investor sells Tokens in the secondary market, the

provisions of the Agreement and the Appendices to the Agreement apply to the relations

for the circulation of Tokens, with the exception of Appendix No. 4.

Appendix No. 5 to the Agreement for

participation in token trading (for

legal entities and individual

entrepreneurs) (as amended on

01.10.2025

INVOICE FORM

Act of Services Rendered

Issued on: ________, 2025

Basis: Agreement for participation in token trading as amended on 01.10.2025

Contractor:

CJSC Pixel Internet

220004 Republic of Belarus, Minsk, 4B Amuratorskaya Str,

apt. 22 (room 17)

TIN 590995582, NNBO 298741684000

A/c No. BY76MTBK30120001093300099292, BANK: CJSC

“MTBank”, 10 Tolstogo Str, 220007, Minsk, Belarus

BIC MTBKBY22

Customer:

Company name , TIN , eWallet

Service Period:

____________

This Act of Services Rendered is made and entered into by and between: CJSC Pixel Internet

(hereinafter referred to as the “Contractor”), on the one part, and by the Customer, on the other part

(hereinafter referred to as the “Customer”), to certify the fact that the Contractor has performed the

following services:

Description of Services

Amount

(BYN)

VAT Rate (%)

VAT Amount

Total (VAT

incl., BYN)

Account maintenance fee

VAT Exempt

Total

VAT Amount:

VAT exempt, according to: Clause 27 of the HTP Regulations,

Decree No. 12

Total Due:

____________________________________________________

The Contractor and the Customer hereby confirm that there are no outstanding claims

between the parties.

Contractor:

The invoice is valid with a facsimile copy of a seal and signature