Dormant Account Policy

DORMANT ACCOUNT & LOSS OF CONTACT POLICY

Monolith Private Wealth Limited

Regulated by the Financial Services Commission of Mauritius

1. Background and Purpose

Monolith Private Wealth Limited (“MPW” or the “Company”) is a company incorporated in Mauritius and licensed by the Financial Services Commission (“FSC”) as an Investment Dealer (Full Service Dealer, excluding Underwriting) and as an Investment Adviser (Unrestricted), pursuant to the Securities Act 2005 (Section 29), the Securities (Licensing) Rules 2007, and the Financial Services (Consolidated Licensing and Fees) Rules 2008.

This dormant account policy (the “Policy”) establishes the framework by which MPW identifies, manages, communicates with, and where appropriate, restricts, suspends, or terminates accounts that have been inactive for a sustained period. The Policy is designed to:

• Protect the funds and assets of clients whose accounts have become inactive;

• Minimise operational, fraud, cybersecurity, and AML/CFT risks associated with inactive accounts;

• Comply with the conduct, record-keeping, and AML/CFT obligations applicable to MPW under Mauritian law and FSC rules;

• Provide a clear, fair, and transparent framework for clients regarding the consequences of inactivity; and

• Establish an audit trail demonstrating that APW has acted reasonably and in accordance with applicable law in respect of dormant accounts.

This Policy applies to all client accounts opened with MPW through the Monolith Market platform, regardless of the channel (web or mobile application) and regardless of whether the client is classified as a retail investor or a sophisticated investor.

2. Regulatory Framework

This Policy is adopted in compliance with, and shall be read in conjunction with, the following principal instruments:

• Securities Act 2005 — Conduct of business and the duty of care owed by an investment dealer / investment adviser to its clients in respect of client money and client assets.

• Financial Services Act 2007 — FSC's mandate and licensee conduct obligations.

• FSC Code of Business Conduct — Guiding Principle 4 (Communicating with Customers) and Guiding Principle 5 (Protection of Customer Assets).

• FSC AML/CFT Handbook — AML monitoring and reporting obligations that apply equally to active and dormant accounts.

• FIAMLA 2002 / FIAMLR 2018 — Ongoing CDD obligations, record-keeping, and STR reporting obligations; relevant where dormancy itself or activity on a dormant account may constitute a red flag.

• Data Protection Act 2017 — Processing of personal data of dormant account holders.

• MPW Internal Policies — Particularly the Client Agreement, AML/CFT/CPF Procedures Manual, Complaints Handling Procedure, and Suitability and Appropriateness Policy.

Note: Mauritius does not currently maintain a specific dormant-investment-account statute equivalent to the unclaimed property legislation found in some jurisdictions. MPW therefore adopts a principles-based approach to dormant accounts, drawing on FSC conduct expectations, applicable AML/CFT requirements, and international best practice. Mauritian regulatory counsel should be consulted on any specific situation involving long-dormant accounts where the client cannot be located, cannot be contacted resulting in a reasonably long period where contact has been lost before any disposal or escheatment of funds.

3. Definitions

For the purposes of this Policy, the following terms shall have the meanings ascribed below:

“Active Account” A client account that has displayed Qualifying Activity within the preceding twelve (12) months.

“Business Day” a day, other than a Saturday, Sunday or public holiday in Mauritius, on which banks are generally open for ordinary banking business in Mauritius.

“Client Contact Channel” Any of the following durable media through which MPW communicates with the client: (i) email address on file; (ii) in-app secure messaging; (iii) push notification through the mobile application; (iv) postal address on file; and (v) registered telephone number on file

“Dormant Account” A client account that has not displayed any Qualifying Activity for a continuous period of twenty-four (24) months or more.

“Inactive Account” A client account that has not displayed any Qualifying Activity for a continuous period of more than twelve (12) months but less than twenty-four (24) months

“Inactivity Fee” A periodic fee that may be applied to Inactive or Dormant Accounts in accordance with the Costs and Charges Schedule and Section 7 of this Policy.

“Long-Dormant Account” A Dormant Account that has not displayed any Qualifying Activity for a continuous period of sixty (60) months or more.

“Qualifying Activity” Any of the following client-initiated actions on the account: (i) execution of a securities transaction (i.e., buy, sell, or any other order); (ii) deposit or withdrawal of funds or securities; (iii) an authenticated login to the Monolith Market platform (web or mobile); (iv) substantive contact with MPW client service, compliance, or other personnel; (v) update of KYC information or self-certification (FATCA/CRS); (vi) acknowledgement or acceptance of a material document update issued by MPW; or (vii) any other action recognised by the Compliance Officer as evidence of continuing client engagement. Automated communications generated by MPW (e.g., statements, system notifications, marketing emails) are NOT Qualifying Activity.

“Reactivation” The process by which a Dormant Account is restored to Active status following client request and the completion of any reactivation requirements specified in this Policy.

“Loss of Contact” A situation during the client life cycle where all contact channels fail or delivery returns undeliverable, The client cannot be reached nor traced. Loss of contact is a separate risk event and does not by itself change account status unless combined with inactivity or other risk factors

4. Account Status Framework

MPW classifies accounts into one of four status tiers based on the duration of continuous absence of Qualifying Activity. Each tier triggers distinct procedural steps:

Calculation of the inactivity period: The period of inactivity is calculated from the date of the most recent Qualifying Activity. The status of each account is recalculated daily by MPW's systems and may transition automatically between tiers based on activity (or further inactivity).

5. Client Notifications

MPW notifies clients at multiple stages of the dormancy cycle. Notifications are sent through all available Client Contact Channels in parallel, to maximise the likelihood that the client receives and acts upon them.

5.2 Content Standards for All Notifications

Every notification issued under this Policy shall:

• Be clear, fair, and not misleading, in accordance with FSC Code Principle 4.4.2;

• Identify Monolith Market as the platform and Monolith Private Wealth Limited as the operating entity;

• State the current account status and the upcoming status transition (with the relevant date);

• Explain the steps the client may take to maintain Active status or to reactivate;

• Identify any fees that have been or will be applied;

• Provide the URL or in-app path to this Policy and to the Costs and Charges Schedule;

• Be sent in English; and

• Be archived in the client file with date, channel, and delivery-status metadata.

5.3 Failure of Delivery & Loss of Contact

Where any notification is returned as undeliverable, bounces, or otherwise fails to reach the client, the Compliance Officer shall:

• Record the delivery failure in the client file;

• Attempt redelivery through alternative Client Contact Channels;

• Where all available channels have failed, treat the client as "not contactable" — this materially elevates the AML risk profile and accelerates the procedural steps described in Section 9;

• Document the date from which the client has been treated as not contactable; and

• Conduct an internal due-diligence enquiry (e.g., open-source searches, public records) to attempt to re-establish contact, in proportion to the value of any funds or assets in the account.

• Take reasonable measures for tracing client and contact details.

6. Restrictions Applied to Dormant Accounts

Upon transition to Dormant status (24 months of continuous inactivity), the following restrictions are automatically applied by MPW's systems:

7. Inactivity Fees

7.1 Fee Structure

Inactivity Fees are designed to reflect the operational costs that MPW continues to incur in respect of dormant accounts (record-keeping, ongoing monitoring, AML screening, system maintenance, and statutory reporting). The fee structure is set out in the Costs and Charges Schedule published alongside this Policy and is summarised below for convenience:

7.2 Limitations on Fee Application

In order to be fair and consistent with FSC Code expectations on costs and charges:

Inactivity Fees shall not be applied where the application of the fee would reduce the account balance below zero — i.e., MPW shall not create or extend a negative balance on a client account through application of Inactivity Fees;

Where the account balance is insufficient to absorb the full monthly fee, the fee shall be reduced to bring the account balance to zero, and no further fees shall be applied unless the account is funded;

Where the account contains securities but no cash sufficient to absorb the fee, APW shall not liquidate securities to recover the fee without specific client instruction;

Inactivity Fees are not punitive in nature and shall not be applied retrospectively;

Inactivity Fees may be waived in whole or in part by the Compliance Officer where extenuating circumstances are established (e.g., serious illness, bereavement, force majeure).

7.3 Disclosure

All Inactivity Fees and their structure are disclosed in:

• This Policy;

• The Costs and Charges Schedule published on the Monolith Market website and in the mobile application;

• The Client Agreement to which all clients have given electronic acceptance at onboarding; and

• Each notification issued at the 18-month and 24-month milestones.

8. Reactivation of Dormant Accounts

A client whose account has become Dormant may, at any time, request that the account be restored to Active status through a Reactivation procedure designed to balance ease of access for the client against the integrity and risk-management considerations applicable to a long-inactive relationship.

8.1 Reactivation Steps

Initiation: The client logs in to the Monolith Market platform (web or mobile). The dormancy banner provides a direct link to the Reactivation flow.

1. Identity re-confirmation: The client completes a multi-factor authentication challenge (e.g., login credentials + one-time password + biometric or device-based factor), confirming identity.

2. KYC refresh: The client confirms that the KYC information held on file remains accurate or provides updated information. Where any document on file has expired (e.g., passport, ID card), a new copy is required. Where the period of dormancy exceeds twenty-four (24) months, a full KYC refresh is required including liveness check.

3. FATCA / CRS self-certification refresh: The client confirms or updates the tax-residency self-certification.

4. Suitability Profile refresh: The client reviews and confirms (or updates) the Client Investment Profile (CIP). Where there has been a material change in circumstances, the full CIP questionnaire is presented.

5. Risk Disclosure re-acknowledgment: The client re-acknowledges the Risk Disclosure Statement.

6. Sanctions and PEP re-screening: MPW conducts a fresh sanctions, PEP, and adverse-media screening of the client.

7. Compliance review: The Compliance Officer (or designated reviewer) confirms that the reactivation request does not present any AML/CFT red flags. For accounts dormant for more than 36 months, the MLRO conducts an additional review.

8. Reactivation confirmation: Upon successful completion of all steps, the account is restored to Active status. A confirmation message is sent to the client through all Client Contact Channels.

8.2 Timing

Reactivation requests are typically processed within five (5) Business Days of receipt of all required information and documentation. Where additional due diligence is required (in particular for accounts dormant for more than 36 months), the process may take longer; MPW will keep the client informed of progress.

8.3 Refusal of Reactivation

MPW reserves the right to refuse a Reactivation request where:

• The reactivation flow cannot be completed because identity cannot be reasonably verified;

• Sanctions or adverse media findings against the client preclude continued business under MPW's AML/CFT policies;

• Updated KYC information cannot be provided by the client;

• The client appears on a restricted-jurisdictions list under MPW's geographic restrictions; or

• Any other circumstance that would justify refusal of a new account application.

Where reactivation is refused, the client shall be informed in writing (subject to any tipping-off restrictions under FIAMLA), with reasons where lawful, and shall be advised of the consequences for the account and its balance.

The client retains the right to challenge the refusal through the Complaints Handling Procedure.

9. AML/CFT Considerations for Dormant Accounts

Dormant accounts present specific AML/CFT risks that are addressed through enhanced controls operated jointly by the Compliance Officer and the MLRO.

9.1 AML Risk Factors Associated with Dormancy

• Sudden activity on a long-dormant account (e.g., large deposit followed by quick withdrawal) is a classic typology of layering;

• Identity-takeover and account hijacking become more likely as the account ages without active oversight by the legitimate owner;

• KYC information held on file becomes stale and may no longer accurately reflect the client's circumstances;

• Sanctions screening may have generated new matches against the client since the last screening event;

• Dormant accounts may be targeted by social-engineering or phishing schemes as the user is less vigilant.

9.2 Enhanced Monitoring

All Dormant and Long-Dormant Accounts are subject to enhanced monitoring including:

• Daily automated sanctions and adverse-media re-screening;

• Immediate alert to the MLRO upon any inbound deposit, login attempt, or contact-information change;

• Tighter transaction monitoring thresholds applied to any post-reactivation activity for a defined surveillance period;

• Additional CDD checks applied to any change of beneficial ownership or controlling persons (for entity clients) during the dormancy period.

9.3 Reporting Obligations

Where activity on a Dormant Account, or the absence of contact with a Dormant Account holder, gives rise to a suspicion of money laundering, terrorist financing, fraud, or proliferation financing, the MLRO shall file a Suspicious Transaction Report with the FIU through the GoAML portal in accordance with the AML/CFT/CPF Procedures Manual.

Tipping-off: Where MPW is conducting an AML investigation in connection with a Dormant Account or has filed an STR, the tipping-off rule under FIAMLA applies in full. APW shall not inform the client of the investigation or the report and shall not delay or refuse account operations in a manner that would alert the client to the existence of the report.

10. Long-Dormant Accounts

Accounts that have been dormant for sixty (60) months or more (“Long-Dormant Accounts”) require special handling. MPW recognises that funds and assets held on these accounts remain the property of the client (or their legal successors) and that MPW's role is one of stewardship.

10.1 Compliance Officer Review

Upon transition to Long-Dormant status, the Compliance Officer shall:

1. Compile a comprehensive file on the account including the client identity, all assets and liabilities on the account, the history of dormancy notices issued, and the responses (or lack thereof);

2. Conduct or commission a final attempt to locate the client, including (without limitation): repeated outreach through all Client Contact Channels; public-records searches (subject to data-protection limitations); enquiries with any known family members or representatives indicated in the client file; and (for high-value accounts) potential engagement of a tracing agent;

3. Document all efforts undertaken with date, channel, and outcome;

4. Refer the file to the MLRO for an AML risk assessment;

5. Refer the file to the Chief Executive Officer or the Board of Directors for review;

6. Where Mauritian regulatory counsel is engaged, obtain a legal opinion on the available courses of action consistent with applicable Mauritian law (in particular as it relates to unclaimed property, escheatment, or other claims-based regimes that may apply to the residual balance).

10.2 Possible Courses of Action

Following the Compliance Officer review, possible courses of action include (subject to legal advice):

• Continued retention of the funds and assets in a segregated dormant-account ledger under enhanced safekeeping (default position pending further action);

• Closure of the account where required and lawful, with proceeds held in an MPW-managed segregated dormant-account reserve pending client claim;

• Where Mauritian law provides for escheatment or transfer of unclaimed property to a public authority, compliance with such requirements in accordance with regulatory counsel's advice;

• Continued attempts to locate the client over an extended period;

• Other action as may be advised by counsel and approved by the Board of Directors.

Critical: MPW shall not appropriate to itself any funds or assets held in a Long-Dormant Account. Long-Dormant balances remain the property of the client (or their successors) and shall be maintained in a segregated dormant-account reserve and recorded as a liability of MPW. Any closure or restructuring of a Long-Dormant Account shall be subject to formal Board of Directors approval and a written legal opinion.

10.3 Client Successors and Probate Situations

Where MPW is informed that the client has died or has otherwise lost legal capacity, the account shall be treated in accordance with the Probate and Succession Procedure (separate document) and shall not be subject to the dormancy procedures in this Policy except in respect of the protection of the funds and assets pending resolution of the succession.

11. Account Closure

Account closure is a serious step that may only be taken in the circumstances and following the procedures set out below.

11.1 Circumstances in Which Account Closure May Be Considered

• The Long-Dormant Account review concludes that closure is the appropriate course of action and Board approval is obtained;

• Reactivation has been refused for AML/CFT, sanctions, or other regulatory reasons and the relationship cannot lawfully be continued;

• The client has positively requested closure of the account; or

• Any other lawful circumstance under which MPW may terminate the client relationship in accordance with the Client Agreement.

11.2 Procedure

Where closure is authorised:

• All open positions are closed at fair market prices, in accordance with the Order Execution Policy;

• The cash balance, after deduction of any sums lawfully owed to MPW, is determined;

• Where the client is contactable, the balance is paid to a verified bank account in the client's name;

• Where the client is not contactable, the balance is retained in the segregated dormant-account reserve in accordance with Section 10.2, pending future claim;

• Account records are retained for a minimum of seven (7) years following closure in accordance with the AML/CFT/CPF Procedures Manual and FIAMLA s.17(b);

• Closure is recorded in the Dormant Account Register and the Compliance Officer reports closures to the Board on a quarterly basis.

12. Record Keeping

12.1 Dormant Account Register

The Compliance Officer maintains a Dormant Account Register, which records the following information for each Inactive, Dormant, and Long-Dormant Account:

• Client identification and account number;

• Date of most recent Qualifying Activity;

• Date of each status transition (Active → Inactive → Dormant → Long-Dormant);

• Account balance and assets held at each transition;

• Date and channel of each notification sent, with delivery status;

• Inactivity Fees applied;

• Reactivation attempts (whether successful or not) with date and outcome;

• Compliance Officer / MLRO reviews and findings;

• Any AML alerts, escalations, or STRs filed in connection with the account; and

• Account closure events with date and basis.

12.2 Retention

Dormant Account Register records, supporting documentation, all notifications and delivery evidence, and Compliance/MLRO reviews shall be retained for a minimum of seven (7) years from the date of the relevant event, in line with the broader record-keeping framework adopted by APW. For Long-Dormant Accounts, records shall be retained for the longer of seven (7) years from final closure or the period required by any applicable unclaimed-property regime as advised by counsel.

13. Roles and Responsibilities

14. Interaction with Other Policies

15. Governance, Review and Updates

This Policy is owned by the Compliance Department and approved by the Board of Directors. It shall be reviewed at least annually, and earlier upon any of the following:

• Any material changes in Mauritian law or FSC regulation affecting dormant accounts (including the introduction of any specific unclaimed property regime applicable to investment dealers);

• Issuance of any relevant Dear CEO letter, circular, or guidance note by the FSC;

• Material changes in MPW's business model or product offering;

• Material findings from internal audit, compliance review, or FSC inspection relating to dormant-account management;

• Cumulative learnings from Long-Dormant Account reviews indicating the need for procedural change.

Material amendments to this Policy shall be approved by the Board of Directors. Where the amendment materially affects clients (for example, fee changes), it shall be communicated to all clients with reasonable advance notice through the Monolith Market platform, by email, or by such other durable medium as may be appropriate.

16. Legal Disclaimer

Disclaimer: This Policy has been prepared to support MPW's compliance with applicable Mauritius law, FSC regulation, and contractual obligations to clients. It does not constitute legal advice and does not purport to be an exhaustive statement of MPW's obligations or of clients' rights. Where any conflict arises between this Policy and applicable law, FSC rules, or the Client Agreement, the law, rules, or agreement (as applicable) shall prevail. Where any specific situation involves long-dormant balances or escheatment-type considerations, Mauritian regulatory counsel should be engaged. MPW reserves all of its rights under applicable law and the Client Agreement.

Annex A — Indicative Notification Templates

The following are short indicative templates for notifications under this Policy. The Compliance Officer may refine these templates and add localisation as appropriate. All templates shall include the Monolith Market platform identification and a clear identification of the operating entity (Monolith Private Wealth Limited).

Template 1 — First Inactivity Reminder (12 months)

Subject: Welcome back to Monolith Market

Body: Dear [Client Name], we have noticed that you have not logged in to Monolith Market for the past 12 months. We are writing as a friendly reminder that your account is still active and that your funds and assets remain securely held. If you no longer require your account, please let us know. Otherwise, simply log in at your convenience to keep your account fully active. From [date], if no activity is recorded, your account may transition to Inactive status, and from [date], Inactivity Fees may begin to apply. For full details, please refer to the Dormant Account Policy available on www.[domain].mu.

Kind regards, Monolith Market — Monolith Private Wealth Limited.

Template 2 — Formal Dormancy Notice (24 months)

Subject: Important — your Monolith Market account is now Dormant

Body: Dear [Client Name], as of [date], your Monolith Market account has been classified as Dormant due to 24 months of continuous inactivity. As a result, certain account features have been restricted, including the ability to place trades and to withdraw funds. Reactivation is quick and simple — log in to Monolith Market at your convenience and follow the on-screen Reactivation flow, which will guide you through the identity, KYC, and suitability refresh steps. An Inactivity Fee of [USD X / month] now applies to your account in accordance with the Costs and Charges Schedule. If you have any questions, please contact our support team at info@[domain].mu. For the full Dormant Account Policy, please visit www.[domain].mu/legal/dormant.

Kind regards,

Compliance Department

Monolith Private Wealth Limited, operator of Monolith Market.

Template 3 — Final Notice (60 months)

Subject: Final notice — Long-Dormant Monolith Market account

Body: Dear [Client Name], we have not received any communication from you for 60 months. Your Monolith Market account is now classified as Long-Dormant. We are writing to give you a final opportunity to confirm that you continue to wish to maintain your account with us. If we do not receive a response from you by [date — minimum 90 days from this notice], your account may be subject to further action including potential closure and retention of the balance in a segregated dormant-account reserve pending future claim. Please log in to Monolith Market or contact us directly at compliance@[domain].mu as soon as possible. For the full Dormant Account Policy, please visit www.[domain].mu/legal/dormant.

Kind regards,

Compliance Department

Abalone Private Wealth Limited, operator of Monolith Market.

End of Document: This Dormant Account Policy (Version 1.0) is to be read together with the Client Agreement, the Costs and Charges Schedule, the AML/CFT/CPF Procedures Manual, the Suitability and Appropriateness Policy, and the Complaints Handling Procedure. All employees in client-facing or compliance roles shall confirm understanding of this Policy as part of their onboarding and annual compliance training.