Note

This document (hereinafter referred to as the "Terms") sets forth the procedure for implementing the "Investments with No Losses" promotion (hereinafter the "Promotion") conducted by Sirius Capital CJSC (hereinafter the "Company"), as well as the conditions of participation, the principles for providing and applying compensation, and the rights and obligations of the parties.

The purpose of the Promotion is to encourage the development of an investment culture and to increase confidence of investors by minimizing the short-term investment risks of new users.

Participation in the Promotion constitutes full and unconditional acceptance of these Terms.

The Company reserves the right to amend or supplement these Terms by publishing the updated version. Such changes shall take effect upon publication unless otherwise stated therein.

1. Key Definitions

1.1 Brokerage Account - An account opened in the name of the client for the purpose of providing investment services, intended for the registration, safekeeping, and execution of transactions involving funds and securities, in accordance with the investment services agreement concluded with the Company, the Company's internal legal acts, and the legislation of the Republic of Armenia.

1.2 New User (Participant) - An individual who opens a brokerage account with the Company for the first time during the Promotion Period and who did not have an active brokerage account with the Company prior to the start of the Promotion.

1.3 Investment Transaction (Transaction) - An investment (via purchase) made by a New User through the Company's mobile application in the SPDR S&P 500 ETF Trust (SPY) security, in an amount ranging from a minimum of 50 (fifty) to a maximum of 1000 (one thousand) US dollars.

1.4 Loss - A decrease in the market value of the investment made by the New User on the 30th day following the Investment Transaction, compared to the original investment amount, as recorded by the Company.

1.5 Compensation - Financial funds provided by the Company to the Participant, in accordance with these Terms, in reimbursement of a registered Loss, up to a maximum of 1000 (one thousand) US dollars.

1.6 Safe Period (Eligibility Period) - A thirty (30) calendar day period starting from the date of execution of the Investment Transaction.

1.7 Promotion Period - From 05․11․2025 through 05․02․2026, inclusive.

1.8 SPDR S&P 500 ETF Trust (SPY) Security (Security) - The security is listed in the relevant section of the Company's mobile application, as specified and published therein.

2. Legal Nature of the Promotion

2.1 The Promotion is a limited-time incentive initiative organized by the Company and shall not be interpreted as any of the following:

• the provision of investment advice,

• the offering of insurance services, or

• a proposal to invest with guaranteed returns.

2.2 These Terms do not replace or amend any existing agreements governing the provision of investment services by the Company. They function solely as an additional, temporary promotional initiative.

2.3 Under the Promotion, a participating New User acquires a conditional right to receive compensation in the event of a Loss, and only if all preconditions defined in these Terms are met.

3. Conditions of Participation

3.1 An individual is eligible to participate in the Promotion if they:

• Open a brokerage account via the Company's mobile application or other official platform;

• Fund their brokerage account with a minimum of $50 USD;

• Execute an Investment Transaction in SPDR S&P 500 ETF Trust (SPY) securities for an amount of not less than $50 and not more than $1,000 USD;

• Maintain the investment— i.e., do not sell or otherwise transfer the securities acquired under the Investment Transaction to third parties within 30 days following the purchase, and do not make additional purchases of SPDR S&P 500 ETF Trust (SPY) securities during that period.

3.2 The right to participate in the Promotion and any rights derived from participation are strictly personal and shall not be transferred to third parties.

3.3 Each New User may participate in the Promotion only once during the Promotion Period.

4. Rights and Obligations of the Parties

4.1 The Company shall:

• Ensure the proper execution of the Promotion and provide equal access to all eligible participants;

• Conduct ongoing monitoring of compliance with these Terms;

• Calculate the amount of Loss based on accurate indicators of its accounting systems and market data.;

• Transfer the compensation to the Participant's brokerage account in accordance with Section 5 of these Terms.

4.2 The Participant shall:

• Fully comply with all provisions and requirements set forth in these Terms;

• Refrain from any actions that may constitute manipulation, technical interference, or submission of false or misleading data in relation to the Promotion;

• Acknowledge that the Company's internal accounting and server-based data shall be superior, mandatory, and final basis for determining both Losses and compensation amounts.

5. Procedure for Providing and Executing Compensation

5.1 The right to receive Compensation arises only if the following conditions are met:

• The Participant has fully complied with and fulfilled all the conditions of participation of the Promotion;

• On the 30th day following the Investment Transaction, the value of the security (as per the Company's internal accounting and server data) has decreased.

5.2 The amount of compensation is determined based on the actual Loss, but shall not exceed $1,000 USD.

5.3 Compensation is provided in monetary form by crediting the corresponding amount to the Participant's brokerage account within 10 (ten) business days after the end of the Safe Period.

5.4 The Company shall not be obligated to provide compensation if the Loss results from: the sale of the securities (or any other transfer of rights over the securities to third parties), failure by the Participant to comply with the Promotion requirements, or any other actions by the Participant

5.5 The calculation and confirmation of the compensation amount shall be based on the data of Company's internal accounting systems, which shall be mandatory and shall not be subject to dispute..

5.6 The Participant may file a written objection regarding the amount of compensation or the refusal to provide it within 10 (ten) calendar days from the date of receipt of the notice of compensation (including its actual execution) or of denial thereof.

6. Limitations and Exclusions

6.1 The Company reserves the right to deny or cancel the provision of Compensation if:

• The information or documents provided by the Participant are false, inaccurate, or incomplete;

• a violation of the Promotion rules, circumvention or attempted circumvention of the Company's systems, or any other form of abuse is detected;

• The investment does not meet the requirements regarding the security or investment amount as defined in these Terms;

• any of the conditions or deadlines set forth in these Terms is violated.

6.2 In such cases, the Participant forfeits all rights granted under the Promotion, and the Company is released from any obligations.

7. Nature of the Compensation

7.1 The compensation provided under the Promotion may be considered taxable income.

7.2 The compensation does not constitute investment income, nor is it a guaranteed return offered by the Company or by any other means.

8. Limitation of Liability and Dispute Resolution

8.1 The Company shall not be held liable for any losses resulting from market volatility, fluctuations in security prices, or other investment actions taken by the Participant.

8.2 Any disputes arising between the parties within the scope of the Promotion shall be resolved through negotiation, and if an agreement cannot be reached, through the competent courts of the Republic of Armenia.

9. Language of the Terms

These Terms are drafted in Armenian, English, and Russian. In the event of any discrepancy, the Armenian version shall prevail.