Client Classification Policy Disclosure

1. Purpose and Regulatory Basis

Monolith Private Wealth Limited (“MPW”, the “Company”) is licensed by the Financial Services Commission of Mauritius (“FSC”) to carry on: i) Investment Dealer activity as a Full-Service Dealer (excluding Underwriting) under Section 29 of the Securities Act 2005; and ii) Investment Adviser activity (Unrestricted) under Section 30 of the Securities Act 2005.

The Company operates the Monolith Market online and mobile trading platform. This document (the “Disclosure”) explains how the Company classifies its clients under Mauritian securities law, the regulatory consequences of each classification, and the rights available to clients in connection with their classification.

This Disclosure is issued in accordance with:

• The Securities Act 2005 of Mauritius, in particular the definition of “Sophisticated Investor” in Section 2 and the provisions of Section 31;

• The FSC Code of Business Conduct, in particular Guiding Principle 4.4 on Communicating with Customers; and

• The Company's internal Client Categorisation Policy, approved by the Board of Directors.

Important: This Disclosure does not constitute legal or financial advice. Clients who require guidance specific to their circumstances should consult an independent legal or financial adviser. In the event of any conflict between this Disclosure and applicable Mauritian law or FSC rules, the law and rules prevail.

2. The Mauritian Framework: Two Client Categories

Mauritian securities law operates a two-tier client classification framework. Every client of an investment dealer or investment adviser licensed in Mauritius is classified as either:

• a Retail Investor; or

• a Sophisticated Investor.

There is no intermediate category under Mauritian securities law. The classification framework does not use the terminology of MiFID II or other foreign regulatory regimes. In particular, the Company does not use the labels “Professional Client” or “Eligible Counterparty” in respect of clients in Mauritius. The classification applied to a client:

• is determined at onboarding and applies across all services provided by the Company — Investment Dealing and Investment Advice — unless formally changed;

• is per client, not per transaction: the Company does not apply different classifications to the same client depending on the specific instrument or activity; and

• determines the level of regulatory protection that the Company is required to provide.

3. Retail Investor

3.1 Default Classification

All clients are classified as Retail Investors by default. A client remains a Retail Investor unless and until they qualify as, and are formally classified as, a Sophisticated Investor under the process described in Section 4.

A client does not become a Sophisticated Investor merely by reason of trading experience, stated risk appetite, professional background, or income level. These factors are considered in the Company's suitability and appropriateness assessment but do not, of themselves, change a client's classification.

3.2 Protections Afforded to Retail Investors

Retail Investors receive the highest level of regulatory protection available under Mauritian securities law. The following protections apply to Retail Investor clients of the Company:

4. Sophisticated Investor

4.1 Statutory Definition — Source

The term “Sophisticated Investor” is defined in Section 2 of the Securities Act 2005 of Mauritius. Section 31 of the Securities Act 2005 provides that certain solicitation, prospectus, and disclosure requirements do not apply to dealings carried out with Sophisticated Investors. The categories are statutory: the Company does not apply MiFID II or other foreign definitions.

4.2 The Fourteen Statutory Categories

A person qualifies as a Sophisticated Investor if they fall within any one of the following fourteen categories (Sub-categories (a) through (n)) as defined in Section 2 of the Securities Act 2005:

4.3 The Self-Warranting Route — Sub-category (m)

Sub-category (m) is the route by which an individual or entity that does not fall within any of Sub-categories (a) to (l) or (n) may nonetheless qualify as a Sophisticated Investor. The following requirements apply:

• Individual clients: net assets (excluding the value of the principal private residence and any related mortgage) of at least US$ 1,000,000, alone or together with associates within the meaning of the Securities Act 2005.

• Institutional or business clients: assets under management or balance-sheet assets of at least US$ 5,000,000, or such other business-activity threshold as may be prescribed.

• The client must sign a Sophisticated Investor Declaration, in the form maintained by the Company as an annex to the KYC Onboarding Requirements Notice and provide documentary evidence supporting the claimed threshold (e.g. bank statements, portfolio statements, audited accounts).

• The Company may not rely on the Declaration alone where the supporting documentation is incomplete or inconsistent. The Compliance Officer reviews each claim before the classification is applied.

• Sub-category (m) classifications are subject to annual review. The client is required to re-confirm compliance with the threshold and to refresh supporting evidence if requested.

4.4 Regulatory Consequences for Sophisticated Investors

Sophisticated Investor clients receive a streamlined regulatory framework. The following table summarises how the principal protections apply:

6. Onboarding and Classification Process

The following process applies when a prospective client applies to open an account on the Monolith Market platform:

• Each prospective client completes the Monolith Market onboarding workflow, including the KYC pack and the Client Investment Profile questionnaire.

• As part of the onboarding flow, the client is asked whether they qualify as a Sophisticated Investor under the Securities Act 2005 of Mauritius. Standard educational material explaining the available client categories is provided.

• If the client does not claim Sophisticated Investor status, they are classified as a Retail Investor. This is the default classification, and no additional documentation is required for it.

• If the client claims Sophisticated Investor status, they must identify the specific Sub-category — (a) through (n) — on which they rely, provide supporting documentation, and (for Sub-category (m)) sign the Sophisticated Investor Declaration.

• The Compliance Officer, or a designated reviewer, reviews the claimed classification and the supporting evidence before the client is permitted to transact on any basis that depends on that classification.

• The final classification is recorded in the client file. The client is notified of their classification through the platform and, where they are classified as Sophisticated, also through written confirmation.

• Classification is per client, not per transaction, and applies to both the Investment Dealing and Investment Advice services provided by the Company.

7. Reclassification Rights

7.1 Client Request: Retail → Sophisticated (Upward)

A Retail Investor may request reclassification as a Sophisticated Investor at any time by:

• submitting a completed Sophisticated Investor Declaration and the required supporting evidence; and

• identifying the specific Sub-category on which they rely.

The Compliance Officer will review the request and notify the client of the outcome. Reclassification applies only going forward and does not alter the protections that applied to previous transactions. If the request is declined, the client will be notified of the reason and may reapply if their circumstances change.

7.2 Client Request: Sophisticated → Retail (Downward)

A Sophisticated Investor may request to be reclassified as a Retail Investor at any time, to receive the full protections available to Retail Investors. The Company will not unreasonably refuse such a request and will normally apply the change within five (5) Business Days of receiving it. Reclassification applies only going forward.

Where a change to Retail Investor status affects existing positions (for example, where leverage levels exceed the limits that apply to Retail Investors), the Compliance Officer will agree a practical run-off arrangement with the client.

7.3 Company-Initiated Reclassification

The Company may reclassify a Sophisticated Investor as a Retail Investor where:

• new information shows that the original classification was incorrectly applied or that the client's circumstances have materially changed;

• a periodic review raises material doubt about the basis for the client's Sophisticated Investor status; or

• the client's trading behaviour shows, on an exceptional basis approved by the Compliance Officer, a lack of sophisticated understanding.

In each case, the Company will inform the client of the reclassification and the reasons for it before the change takes effect.

The Company will not reclassify a Retail Investor as a Sophisticated Investor on its own initiative. A client may only be reclassified upward if they submit the required declaration and evidence.

8. Protections That Apply to All Clients Regardless of Classification

The following protections apply to every client of the Company, whether classified as Retail or Sophisticated:

• Client money segregation: client money and client assets are segregated in accordance with the Company's procedures and applicable Mauritian requirements.

• AML/CFT/CPF: full application of the Company's anti-money laundering, counter-terrorism financing, and counter-proliferation financing framework, regardless of client category.

• Sanctions screening: full screening applied at onboarding and on an ongoing basis, regardless of category.

• Data protection: full application of the Data Protection Act 2017 of Mauritius and the Company's Privacy and Data Protection Policy.

• Complaints handling: every client retains access to the Company's Complaints Handling Procedure.

• External recourse: every client retains the right to refer matters to the FSC and to the Ombudsperson for Financial Services under the Ombudsperson for Financial Services Act 2018, regardless of classification.

• Conflicts of interest: the Company identifies, manages, and discloses conflicts of interest in respect of all clients.

• Cybersecurity and operational resilience: the Company maintains its security and resilience posture for the benefit of all clients.

9. Quick-Reference Comparison Table

The table below is a non-authoritative summary. The substantive provisions are set out in Sections 3 to 8 of this Disclosure and in the Company's internal Client Categorisation Policy.

10. Changes to This Disclosure

This Disclosure will be reviewed at least annually by the Compliance Officer and updated whenever there is a material amendment to the Securities Act 2005, relevant FSC guidance, or the Company's internal Client Categorisation Policy. Material changes will be communicated to clients through the Monolith Market platform, by email, or through such other durable medium as the Company considers appropriate. Clients are encouraged to review the current version of this Disclosure, which is available on the Company's website and through the platform.

11. Contact and Complaints

Clients with questions about their classification, or who wish to request a reclassification, may contact the Compliance Department through the channels published on the Company's website.

Complaints regarding the application of the Company's classification framework may be submitted in accordance with the Company's Complaints Handling Procedure. Unresolved complaints may be escalated to:

12. Disclaimer

This Disclosure has been prepared to comply with the Company's obligation to inform clients of the client classification framework applicable under Mauritian securities law. It does not constitute legal or tax advice and does not purport to be an exhaustive statement of all obligations applicable to the Company or to clients. Clients seeking specific guidance regarding their position should consult an independent legal or tax adviser. In the event of any conflict between this Disclosure and applicable Mauritian law or FSC rules, the applicable law or FSC rules shall prevail. This document is a draft for review by Mauritian regulatory counsel and approval by the Board of Directors before implementation; it is not legal advice.