FLY WING is a platform that provides one-stop blockchain related services. FLY WING is operated by and proprietary to Fly Wing Technologies Pte. Ltd. and its affiliates (together, the "Company" or "We" or "Us"). By accessing the website at www.flywing.com and the associated application program interface or mobile applications (each a "Site"), using the Services and/or registering an account with Fly Wing, you (the "User") have read, understood and agree to be bound by these terms and conditions between you and the Company, including any revisions from time to time as may be published by the Company (the "Agreement") as well as the Privacy Policy (available at www.flywing.com). In addition, in relation to the Services/Products, you may be subject to additional specific terms and conditions applicable to the relevant Service/Product (the "Product Terms"). In case of any conflict between the terms and conditions of this Agreement and the Product Terms, the latter shall prevail.

The Monetary Authority of Singapore (MAS) requires us to provide this risk warning to you as a customer of a digital payment token (DPT) service provider.

Before you:

• (a) pay or transfer your DPT service provider any money or DPT;
• (b) pay a third party any money or DPT under an arrangement by your DPT service provider;

you should be aware of the following:

• 1. Your DPT service provider is licensed by MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to your DPT service provider or any other third party referred to above , if your DPT service provider's or the third party's business fails.
• 1A. You should be aware that MAS does not supervise or regulate your DPT service provider for the provision of unregulated services. This includes any service of trading digital payment token derivatives such as futures
• 2. You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact is transferred or held by your DPT service provider.
• 3. You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens.
• 4. You should be aware that your DPT service provider, as part of its licence to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as "stablecoin".

Using the Services or purchasing, selling, holding or investing in the Products involves significant risks (including but not limited to loss of the Digital Currency, substantial decrease in or loss of the entire value of the Digital Currency, inability to trade, access or transfer the Digital Currency or to receive the benefits related to holders of the Digital Currency, unauthorised access or erroneous transfers, and legal, regulatory and tax risks) and is not suitable for everyone. Before doing so, you should ensure you fully understand the risks and nature of the relevant Services/Products and undertake your own independent review on whether the relevant Services/Products are suitable for you in light of your own financial situation, investment experience, investment objectives and risk appetite. If you have any question about the Services/Products available on the Site, you should seek professional advice from your own independent financial, legal and/or tax advisers. The risks set out in this Agreement are not comprehensive and does not reflect all of the risks (or other important factors) you should consider before using the Services or trading or acquiring the Products.

You understand and agree that Fly Wing is not your broker, intermediary, agent or advisor and has no fiduciary relationship or obligation to you in connection with any trades or other decisions or activities you make using the Services, whether such trades or other decisions or activities take place on the Site or not. You agree that nothing on the Site and no communication from Fly Wing shall constitute our investment, financial, trading or other advice to you.

Fly Wing's decision to support or not to support the trading, transfer or storage of any particular Digital Currency through the Services does not indicate Fly Wing's approval or disapproval of the Digital Currency or the integrity, security or operation of the Digital Currency or its underlying technology. Fly Wing makes no representation or undertaking on whether any Digital Currency will always be supported by Fly Wing and its affiliates or third party service providers and any Digital Currency is subject to de-listing in the sole and absolute discretion of Fly Wing. Fly Wing also does not own or control the underlying technology which governs the operation of Digital Currencies supported on the Site. Any Digital Currency or its underlying technology may change or otherwise cease to operate as expected due to a change made to the underlying technology, including without limitation, a "fork", a "rollback", or a "bootstrap" of a Digital Currency or blockchain. It is your responsibility to apprise yourself of any (potential) changes to any Digital Currency or its underlying technology.

There are no deposit protection schemes available to the Services/Products unless you obtain your own third party insurance. You understand and agree that the Digital Currencies that you hold with us may be commingled with Digital Currencies belonging to other users. You further understand and agree that under no circumstances shall Fly Wing and its affiliates be responsible or liable to you or any other person for any Losses arising from or in connection with your use or reliance on any Services/Products or this Agreement.

You agree to comply with all applicable Laws (including in respect of taxation, withholding or tax reporting), this Agreement, the relevant Product Terms, the Privacy Policy and all policies, procedures, or rules as may be announced by the Company from time to time. It is your responsibility to check the Site and your email address in our records frequently for any announcements and we are not responsible for any information that you obtain through unofficial channels not owned or controlled by the Company.

You acknowledge and agree that the Company does not provide custodial or safeguarding services for client assets. Accordingly, the Company's obligation to return client assets within T+1 pursuant to the Regulation excludes weekends, public holidays, and bank holidays in the relevant jurisdiction. Where settlement involves foreign banks or occurs in foreign jurisdictions with differing weekends or public holidays (including, without limitation, jurisdictions where weekends fall on Friday and Saturday), the Client acknowledges and agrees that: (i) settlement times may be extended beyond the standard T+1 timeframe; and (ii) any funds in transit and outside the direct control of the Company, including delays arising from third-party banking or settlement processes, shall not constitute a breach of the T+1 settlement requirements.

1. Definitions

As used in this Agreement, the following terms shall have the following respective meanings

1.1 "Business Day" means any day excluding Saturdays, Sundays, and public holiday or bank holiday;

1.2 "Cut-Off Time" means 1600 hours Singapore time (SGT);

1.3 "Digital Currency" shall mean any cryptocurrencies, decentralised application tokens and protocol tokens;

1.4 "Laws" shall mean laws and regulations, including without limitation, governmental and regulatory actions, orders, decrees, whether domestic or foreign;

1.5 "Products" / "Services" shall mean the products/services available on the Site;

1.6 "Regulation" means the Payment Services Regulations, 2019;

1.7 "T" refers to the date on which customer assets are received in the Company's wallet or bank account. For the avoidance of doubt, if the assets are received after the Cut-Off Time, the asset will be deemed to be received on the next business day;

1.8 "T+1" refers to the next Business Day after T.

2. Account Registration

2.1 You shall register an account (the "Account") with the Company before using the Services/Products. You agree to provide us with information that is accurate, current and complete at all times. Failure to do so constitutes a breach of this Agreement which may result in suspension or immediate termination of your Account or a Service/Product at the Company's sole and absolute discretion. You undertake to notify us immediately when any of the information provided by you changes. You agree that you will not register multiple Accounts with the Company, unless a writing consent from the Company is obtained.

2.2 You agree that the Company reserves its right to decline, at our sole and absolute discretion, to open an Account for any person without providing any reason.

2.3 You hereby represent, warrant and undertake to the Company as follows, which representations and warranties will be deemed repeated each time you access your Account or use the Services or purchase, sell or invest in the/Products:

• (1) as an individual, you are at least 18 years old and you have the requisite power to form a binding contract and perform your obligations in accordance with this Agreement under applicable laws and regulations;
• (2) as a legal person or organisation, you have full legal capacity and authorisation to enter into this Agreement;
• (3) all information in any form provided by you to the Company is accurate, current and complete;
• (4) you are not located in, established in, or a citizen or resident of any country or jurisdiction where use of the Services or your purchase, sale, holding of or investment in the Products is restricted or prohibited.
• (5) your use of the Services or your purchase, sale, holding of, or investment in the Products will not negatively affect the Company's reputation or cause the Company to be subject to any penalties, fines or sanctions, and is not subject to any contractual or other restriction binding on you or any of your assets you use to purchase or invest in the Products;
• (6) the assets you use to purchase or invest in the Products are not the direct or indirect proceeds of any criminal or fraudulent activity;
• (7) you are using the Services only for your own benefit and you are not using the Services or purchasing, selling, holding or investing in the Products on behalf of or for the benefit of any third party(ies), unless you have obtained prior written consent from us;
• (8) you are not subject to any economic sanctions programs administered or enforced by any relevant country or government or international authority, including but not limited to: the US Department of the Treasury's Office of Foreign Assets Control, the US Department of State, the United Nations Security Council, the European Union, Her Majesty's Treasury, the Hong Kong Monetary Authority or the Monetary Authority of Singapore; and
• (9) you have the necessary technical expertise and ability to review and evaluate the security, integrity and operation of any Digital Currency that you decide to acquire or trade, and the knowledge, experience, understanding, professional advice and information to make your own evaluation of the merits and the risks of any Digital Currencies.

2.4 You hereby understand and agree that you may be required to provide personal identification information to complete our client onboarding process including KYC ("Know Your Client"), AML ("Anti-money laundering") and CFT ("Counter-terrorist Financing") requirements. We may require such information during your Account registration process and on an on-going basis. We reserve the right to charge you any fees and costs associated with any enhanced due diligence that may be required in respect of your Account, although we will provide prior notice to you if we wish to do so. You understand and agree that our collection, use and disclosure of your personal identification information shall be governed by the Privacy Policy.

2.5 The Company is committed to maintaining the security of our Users' Digital Currency and has implemented industry-standard protection for our Services/Products. However, the actions of the User, other Users and other actors may pose risks. You are solely responsible for the security of your Account you agree and undertake:

• (1) to take necessary precautions to ensure the security of your login credentials and other forms of authentication (if applicable);
• (2) not to disclose such information to any third party; and
• (3) to notify the Company immediately if you are aware of any unauthorised. You acknowledge that granting permission to a third party to take specific actions on your behalf does not relieve you of any of your responsibilities under this Agreement;
• (4) to be fully responsible for all acts or omissions of any third party with access to your Account and any action of such third party shall be considered to be an action authorised by you.

3. Products and Services

3.1 You will be permitted to use the Services upon successful Account registration. You agree that the Company reserves the right at any time and without any notice to limit, modify (including disabling the withdrawal of Digital Currency), suspend or terminate all or part of the Services or to limit your ability to purchase, sell, hold or invest in the Products.

3.2 You agree and understand that you may not use certain Services and/or purchase, sell, hold or invest in certain Products if you do not have sufficient balance (the "Balance") in your Account.

4. Fees

4.1 You agree to pay the fees (the "Fees") for the Services/Products in accordance with the applicable fee schedule (the "Fee Schedule"). You agree that the Company shall have the right to adjust the Fees at any time and in its sole and absolute discretion. You authorise the Company to deduct or set-off from your Account any Fees charged to you.

5. Restrictions

5.1 You shall not use the Services to engage in any activities that violate applicable Laws. You shall not use the Services to:

• (1) support, incite or participate in any terrorist activities;
• (2) participate in any money laundering activities;
• (3) violate public interests or the legitimate interests of others, including but not limited to interfering, disrupting or negatively affecting other Users' use of the Services;
• (4) engage in any form of market manipulation which includes any actions taken or procured to be taken, or any course of conduct, by any market participant or a person acting in concert which are intended to or does, or is likely to create a false appearance or deceive or mislead other Users of active trading in any Digital Currencies (whether within and/or outside the Site), or with respect to the market for, or the price of, any Digital Currencies traded on the Site, artificially control or manipulate the price or trading volume of a Digital Currency, including but not limited to maintaining, inflating, depressing or causing fluctuations in the market price of a Digital Currency, or aid, abet, enable, finance, support, or endorse any of the foregoing; or
• (5) participate in any activities that may affect the normal operation of the Services and/or the security of the Site.

5.2 You shall not use any method (such as proxy, Tor, VPN, etc.) to encrypt or block your Internet traffic and/or IP addresses or use other technical services to conceal your identity and/or location.

5.3 This Agreement relates to the access and use of the Services/Products and Fly Wing does not transfer the ownership or intellectual property rights in and to the Services/Products. All text, graphics, user interfaces, visual interfaces, photographs, sounds, artwork, computer code (including html code), programs, software, products, information, and documentation as well as the design, structure, selection, coordination, expression, "look and feel," and arrangement of any content contained on or available through the Services and Products ("Data") are exclusively owned, controlled, and/or licensed by Fly Wing or its affiliates. You shall neither engage in any activities in the name of the Company nor use the information on the Site and/or the Company's Data without prior written authorisation from the Company.

6. Liabilities

6.1 The Company does not guarantee that any order will be executed, accepted, recorded or remain open. We may also endeavour to correct, reverse or cancel any order, trade, transfer, or other transaction or activity with respect to which the Company has discovered that there was an error (whether caused by you, the Company or a third party or due to technical issues or otherwise). You hereby authorise the Company to make any such correction, reversal or cancellation at its sole and absolute discretion. Notwithstanding, the Company provides no guarantee or warranty that any such attempt will be successful and will have no responsibility or liability for such error(s) or any correction attempt(s).

6.2 Without duplication of any other rights to recovery or indemnity set forth in this Agreement, you shall indemnify and hold harmless the Company, its affiliates, and their respective directors, officers, employees and agents from and against any losses (including indirect losses), claims, actions, proceedings, investigations, demands, suits, costs, expenses, and damages (including reasonable legal costs on a full indemnity basis, fines and penalties) (collectively, "Losses") arising out of or in connection with (1) your violation of any applicable Laws or the rights of any third parties; (2) your breach of this Agreement, any Product Terms or the Privacy Policy; (3) the actual or attempted enforcement or protection of any of our rights and remedies against you; and/or (4) your use of the Services or your purchase, sale, holding of or investment in any Product.

6.3 To the fullest extent permitted under applicable law, the Services/Products are offered on an "as is" and "as available" basis, and we expressly disclaim, and you waive, any and all other warranties of any kind, whether express or implied, including, without limitation, warranties of merchantability, fitness for a particular purpose, title or non-infringement or warranties arising from course of performance, course of dealing or usage in trade. Without limiting the foregoing, we do not represent or warrant that the Site or the Services/Products are accurate, complete, reliable, current, error-free, or free of viruses or other harmful components. Without prejudice to the other provisions of this Agreement, you agree that the Company will not be liable for any Losses arising out of or relating to: (1) any inaccuracy, defect or omission of price data, (2) any error, corruption, loss or delay, interruption, disruption, suspension, cessation or failure in the transmission of such data, (3) any regular or unscheduled maintenance carried out by the Company or any third party service equipment or providers (including third party equipment, software, hardware, internet, internet browsers, online networks, internet and telecommunication or other service providers), (4) any Losses caused by other Users' or other third parties' actions, omissions or violation of this Agreement.

6.4 In no event shall the company, its affiliates and their respective shareholders, directors, officers, employees and agents be liable for any special, incidental, indirect, punitive, consequential Losses (including but not limited to loss of data, profits, revenue, business opportunities) arising out of or in connection with the Services and/or Products even if the company has been advised of the possibility of such Losses, except to the extent there is a final and binding judicial determination that such Losses were caused by the Company's gross negligence, wilful misconduct or fraud.

7. Termination

7.1 You acknowledge and agree that the Company shall have the right (but not the obligation) in its sole and absolute discretion and without any notice to limit, modify (including disabling the withdrawal of Digital Currency), suspend or terminate your access to all or part of the Site, the Services (including freezing your Account) or to limit your ability to purchase, sell, hold or invest in the Products if:

• (1) we suspect that you have violated any applicable Laws, this Agreement, the Product Terms or other policies, procedures, or rules as may be announced by the Company;
• (2) we are required to do so to comply with sanctions requirements or where required by a subpoena, court order, or other government order or if the Balance should be attached or distrained or become the subject of any court order or other legal process;
• (3) the Account is subject to or related to any threatened or pending litigation, investigation, and/or governmental proceeding;
• (4) we suspect that there is any unusual, unauthorised or fraudulent activities or money laundering, terrorist financing or financial crime involved with the Account; or
• (5) we reasonably believe we need to do so in order to protect our reputation.

You agree that the Company shall not be liable to you for any Losses caused by our exercise of the above rights.

7.2 You acknowledge and agree that the Company shall have the right at any time without notice to you and without liability or providing any reasons, to refuse to accept any deposit(s) or to limit the amount(s) that may be deposited into your Account, return all or any part of the Balance, or to close your Account if:

• (1) we reasonably suspect you to be in breach or acting in breach of Laws, this Agreement, any applicable Product Terms, the Privacy Policy or any other policies, procedures or rules as may be announced by the Company from time to time;
• (2) the information provided by you to us is inaccurate, not current or incomplete;
• (3) you use the Services to engage in illegal activities;
• (4) any incapacity, bankruptcy, winding-up, judicial management, receivership or other insolvency proceedings are commenced or threatened against you; or
• (5) the Company determines at its sole and absolute discretion, and without providing any reason, that your Account shall be terminated.

7.3 If you choose to terminate your Account with us, you shall provide the Company with reasonable notice in writing of your intention to terminate the Account.

7.4 The closure of an Account shall not affect any rights and obligations incurred prior to the date of Account closure, including but not limited to your obligations to your counterparties (if any), any Fees, interests, costs (including withdrawal costs and reasonable legal costs) and expenses. You agree that the Company shall have the right to deduct or set-off your outstanding liabilities from your Balance before closing your Account.

7.5 The Company may, in our sole and absolute discretion, transfer the Balance to a suspense account (not bearing interest) in the event that your Account shall remain inactive or dormant.

8. Miscellaneous

8.1 License. Subject to your continued compliance with this Agreement, any applicable Product Terms and the Privacy Policy and all other policies, procedures or rules as may be announced by the Company from time to time, the Company hereby grants you, a limited, non-exclusive, revocable, non-transferable and non-sublicenseable license to access and use the Site for your own use only. You are not permitted to use the Services for any resale or commercial use including to place trades on behalf of another person or entity.

8.2 Force Majeure. The Company shall not be liable for delays or errors occurring by reason of circumstances beyond its reasonable control, including but not limited to restrictions on conversion or transfer of Digital Currency, unavailability of any third party service or system, war (declared or undeclared), terrorist activities, acts of sabotage, blockade, fire, lightning, acts of god, national strikes, riots, insurrections, civil commotions, quarantine restrictions, epidemics, earthquakes, floods, hurricanes, explosions and governmental, regulatory and administrative actions or delays. In the event of such force majeure, the company shall take commercially reasonable steps to minimise interruptions and loss but shall have no liability caused by or incidental to such force majeure. Upon the occurrence of such event, the obligations of Company are suspended for so long as such event continues.

8.3 Performance. You agree that the Company's performance of this Agreement (including acting on any instruction from you) is subject to, and shall be performed only in accordance with, the applicable Laws.

8.4 Governing Law. This Agreement and any non-contractual obligations arising out of or in connection with it shall be governed by and interpreted in all respects in accordance with the laws of the Republic of Singapore.

8.5 Dispute Resolution. In the event of any dispute arising in connection with this Agreement, either you or the Company may issue a notice to mediate (a "Mediation Notice"). The mediation must commence within 60 days of the Mediation Notice and conclude within 60 days of such commencement. Both parties shall endeavour to agree on an accredited mediator, failing which the mediator shall be selected by the Singapore Mediation Centre. Both parties shall abide by the terms of any settlement reached.

If the dispute cannot be resolved by mediation, such dispute shall be referred to and finally settled on an individual basis in binding arbitration administered by the Singapore International Arbitration Centre ("SIAC") under the SIAC Rules for the time being in force. The seat of the arbitration shall be in Singapore and the language of the arbitration shall be English. The arbitration tribunal shall consist of three arbitrators. You agree that the arbitration shall be kept confidential save where disclosure is required to fulfil a legal duty, protect or pursue a legal right, or enforce or challenge and award in bona fide legal proceedings.

8.6 Assignment. You shall not assign or transfer any of your rights or obligations under this Agreement without prior written consent from the Company. The Company shall be entitled to assign or transfer any or all of its rights and/or obligations under this Agreement without prior notice to and without consent from you.

8.7 Amendments. The Company reserves its right to amend, modify and/or change this Agreement at any time in its sole and absolute discretion and without prior notice to you. Save as otherwise expressly specified, such amendment, modification or change to this Agreement shall take effect once it is published on the Site. It is your responsibility to regularly check the Site for the latest version of this Agreement before using the Services or transacting in any Products. If you do not accept any changes to this Agreement, you should terminate your Account (by notifying us in accordance with Section 7.3) and terminate your use of all Services.

8.8 Waiver of rights. No delay or omission as to the exercise of any right, remedy or power under this Agreement constitutes a waiver of that right, remedy or power.

8.9 Interpretation. This Agreement shall be construed according to its fair language. The rule of construction to the effect that ambiguities are to be resolved against the drafting party shall not be employed in interpreting this Agreement.

8.10 Severability. Should any part of this Agreement be determined to be illegal, invalid or unenforceable, such determination shall not affect the remaining part of this Agreement.

8.11 Records. The Company shall have the right to keep and use the transaction data and any information related to your Account. You consent to telephonic or electronic monitoring or recordings of any communications for security and quality of service purposes and agree that the Company may produce telegraphic or electronic recordings or other electronic records as evidence in any proceedings brought in connection with this Agreement.

8.12 Conflicts of Interest Disclosure. In the course of providing Over-the-Counter ("OTC") Digital Payment Token ("DPT") services, the Company recognises that actual or potential conflicts of interest may arise between itself and its customers, or between customers. In accordance with our internal conflicts of interest framework, the Company is committed to managing such conflicts fairly and transparently. The following disclosures are made to ensure that customers are fully informed of the nature of any conflicts of interest, as well as the measures in place to mitigate them:

a) Business Practices That May Give Rise to Conflicts

As a principal counterparty to OTC DPT trades, the Company may take proprietary positions or execute transactions that are contrary to a client's position. Additionally, the Company may receive financial or commercial incentives, or adopt pricing practices that could present potential misalignment of interests. These activities, while permitted, may give rise to conflicts where the Company's interests are not fully aligned with those of our clients.

b) Nature of Conflicts Identified

Identified conflicts include, but are not limited to:

• The potential for financial gain at the customer's expense;
• Potential for staff to access or misuse sensitive client trade information;
• The Company having a distinct interest in the outcome of a trade, separate from the client's interest;
• Conflict between proprietary trading and client trades;
• Disputes over execution on price slippages in OTC trades.

c) Risks Associated with the Conflicts

These conflicts may result in outcomes such as less favourable terms or pricing for certain clients, limited market transparency, or diminished confidence in the impartiality of the service provided. There is also the risk of information misuse or decision-making bias due to internal incentives.

d) Measures Taken to Mitigate Conflicts

The Company has implemented a range of governance, operational, and procedural controls to manage, and mitigate conflicts of interest, which includes:

• Segregation of functions and reporting lines;
• Oversight by the Compliance Officer and periodic internal audits;
• Maintenance of a Conflicts of Interest Register;
• Restrictions on inducements and rules on employee conduct;
• A requirement that all staff report conflicts through line managers to the Compliance function;
• Regular training and monitoring to ensure awareness and compliance.

e) Residual Risks

While the Company takes all reasonable steps to manage and mitigate conflicts of interest, certain residual risks may remain. In such cases, the client is advised of the conflict to enable an informed decision to proceed.

JUNE 2025