Privacy Policy

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RADIX HOLDINGS MANAGEMENT LLC

Effective: September 2026

1. POLICY STATEMENT

RADIX HOLDINGS MANAGEMENT LLC (“RADIX”), together with its affiliated and managed entities, is committed to conducting business with integrity, transparency, and appropriate risk-based controls.

RADIX maintains an Anti-Money Laundering (“AML”), Know Your Customer (“KYC”), Know Your Business (“KYB”), Counter-Terrorist Financing (“CTF/CFT”), sanctions-screening, and counterparty due-diligence program designed to reduce the risk that RADIX, its affiliates, personnel, business relationships, or transaction structures are used in connection with money laundering, terrorist financing, sanctions evasion, fraud, corruption, bribery, trafficking, proliferation financing, or other unlawful activity.

RADIX reserves the right to decline, suspend, terminate, or refuse to facilitate any transaction or business relationship that does not satisfy its compliance requirements.

No transaction is more important than compliance.

2. SCOPE

This policy applies, as appropriate, to prospective and existing:

* Buyers and sellers;

* Suppliers and purchasers;

* Title holders;

* Refineries and refinery representatives;

* Commodity traders;

* Producers and manufacturers;

* Mandates and authorized representatives;

* Brokers and facilitators;

* Consultants and referral sources;

* Joint-venture partners;

* Investors and capital providers;

* Escrow agents and paymasters;

* Logistics, storage and terminal providers;

* Inspection companies;

* Financial counterparties;

* Corporate entities and their beneficial owners;

* Other parties participating directly or indirectly in transactions involving RADIX.

Compliance requirements are applied on a risk-based basis considering the transaction, commodity, jurisdiction, counterparties, ownership structure, payment structure and other relevant circumstances.

3. RISK-BASED APPROACH

RADIX utilizes a risk-based approach to counterparty and transaction due diligence.

A counterparty or proposed transaction may be classified as standard, elevated, or high risk based on factors including:

* Country of incorporation;

* Country of operation;

* Commodity origin;

* Commodity destination;

* Ownership structure;

* Beneficial ownership;

* Transaction value;

* Payment method;

* Source of funds;

* Source of wealth when appropriate;

* Use of intermediaries;

* Number of parties in the transaction chain;

* Politically exposed person (“PEP”) exposure;

* Sanctions exposure;

* Adverse media;

* Unusual corporate structures;

* High-risk jurisdictions;

* Offshore structures;

* Unexplained third-party payments;

* Unusual banking arrangements;

* Transaction structures inconsistent with the counterparty’s normal business activities.

Higher-risk transactions may be subject to Enhanced Due Diligence (“EDD”) before RADIX proceeds.

4. KNOW YOUR CUSTOMER / KNOW YOUR BUSINESS

Before establishing certain business relationships or facilitating transactions, RADIX may require sufficient documentation to establish the identity, existence, ownership, authority and legitimacy of each relevant counterparty.

Individual Verification

RADIX may request:

* Full legal name;

* Date of birth;

* Residential or business address;

* Nationality;

* Government-issued identification;

* Passport;

* Driver’s license or national identification card;

* Telephone number;

* Email address;

* Proof of address;

* Professional or business information;

* Evidence of authority to represent another individual or organization.

Corporate Verification

Corporate counterparties may be required to provide:

* Certificate of incorporation or formation;

* Articles of incorporation or organization;

* Certificate of good standing;

* Corporate registration number;

* Registered business address;

* Principal operating address;

* Tax identification information where appropriate;

* Corporate website and business contact information;

* Directors and officers;

* Managers or managing members;

* Authorized signatories;

* Ownership structure;

* Beneficial ownership information;

* Corporate organizational chart where appropriate;

* Board resolution or authorization where required;

* Corporate Information Sheet (“CIS”);

* Banking information where relevant to the transaction;

* Evidence demonstrating the nature of the company’s business.

RADIX may independently verify information through corporate registries, governmental databases, sanctions databases, commercial databases, public records, banking documentation and other reliable sources.

5. BENEFICIAL OWNERSHIP

RADIX seeks to identify the natural persons who ultimately own or exercise material control over entities participating in transactions.

Depending upon the circumstances and risk level, RADIX may request identification of:

* Individuals owning 25% or more of an entity;

* Individuals exercising direct or indirect control;

* Managing members;

* General partners;

* Senior executive officers;

* Persons authorized to control or direct the transaction; and

* Other ultimate beneficial owners (“UBOs”) identified through the ownership chain.

RADIX may require disclosure through multiple corporate layers until the relevant natural-person ownership and control structure can reasonably be established.

Nominee shareholders, shell entities, trusts, holding companies, offshore entities and multilayer ownership structures may require additional documentation.

RADIX reserves the right to reject a transaction when beneficial ownership cannot be reasonably established or verified.

6. SANCTIONS & RESTRICTED-PARTY SCREENING

RADIX does not knowingly participate in transactions prohibited by applicable economic or trade sanctions.

Relevant counterparties may be screened against applicable sanctions and restricted-party databases, including sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), as appropriate.

Screening may include:

* Companies;

* Beneficial owners;

* Directors;

* Officers;

* Authorized representatives;

* Banks;

* Vessels;

* Shipping companies;

* Suppliers;

* Buyers;

* Commodity origin;

* Commodity destination; and

* Other material transaction participants.

A potential sanctions match may result in additional investigation, suspension of the transaction, rejection of the transaction, or referral to qualified legal or compliance professionals.

RADIX will not knowingly structure or facilitate a transaction for the purpose of circumventing applicable sanctions or other legal restrictions.

7. POLITICALLY EXPOSED PERSONS

RADIX may conduct enhanced review where a counterparty, beneficial owner, officer, representative, immediate family member or known close associate is identified as a Politically Exposed Person (“PEP”).

PEP status does not automatically prohibit a business relationship.

Instead, RADIX may apply additional risk-based review concerning:

* Identity;

* Position or public function;

* Ownership;

* Source of wealth;

* Source of funds;

* Transaction purpose;

* Geographic exposure;

* Adverse information; and

* Potential corruption or bribery concerns.

8. SOURCE OF FUNDS / SOURCE OF WEALTH

For transactions presenting elevated financial or compliance risk, RADIX may request evidence reasonably demonstrating the legitimate source of transaction funds.

Documentation may include, where appropriate:

* Bank confirmation;

* Bank Comfort Letter (“BCL”);

* Proof of Funds (“POF”);

* Bank statements;

* Audited financial statements;

* CPA or accountant verification;

* Financing agreements;

* Loan documentation;

* Investment documentation;

* Evidence of business revenue;

* Evidence relating to the underlying transaction.

RADIX may also request Source of Wealth (“SOW”) information from beneficial owners or funding parties when warranted by the risk profile.

A document represented as proof of funds does not, by itself, constitute final verification or acceptance of financial capability.

9. COMMODITY TRANSACTION DUE DILIGENCE

Because RADIX and its affiliates may participate in or facilitate international commodity transactions, additional transactional due diligence may be required.

Depending upon the commodity and transaction structure, RADIX may seek verification of:

* Seller authority;

* Buyer authority;

* Title-holder status;

* Product ownership;

* Product availability;

* Product origin;

* Storage arrangements;

* Terminal documentation;

* Tank Storage Receipts (“TSR”);

* Inspection reports;

* SGS or equivalent inspection documentation;

* Bills of Lading (“BOL”);

* Product manifests;

* Certificates of origin;

* Proof of Product (“POP”);

* Allocation documentation;

* refinery documentation;

* Vessel information;

* logistics documentation;

* import/export authority;

* transaction banking information; and

* contractual authority of representatives.

Documentation is reviewed in context and may be independently verified when appropriate.

Submission of a document does not require RADIX to accept the document as authentic or sufficient.

10. PRINCIPAL AND INTERMEDIARY VERIFICATION

RADIX seeks transparency regarding the role of every material participant in a transaction.

A party representing itself as a:

Principal Buyer may be required to demonstrate that it is the actual purchasing entity or has documented authority to purchase.

Title Holder or Seller may be required to demonstrate ownership, control, allocation, or legally sufficient authority to sell the commodity.

Mandate or Authorized Representative may be required to provide evidence of current authorization from the principal represented.

Broker, Facilitator or Referral Party must accurately disclose its role and must not represent itself as the owner, title holder, principal buyer, refinery, producer or authorized mandate unless documentation supports that representation.

RADIX may communicate directly with principals when reasonably necessary to confirm transaction authority and legitimacy.

11. NO UNDISCLOSED INTERMEDIARIES

RADIX discourages unnecessarily complicated transaction chains and undisclosed intermediary structures.

Material intermediaries should disclose:

* Legal identity;

* Corporate affiliation;

* Transaction role;

* Party represented;

* Basis of authority; and

* Compensation structure when relevant.

RADIX may reject transactions involving undisclosed parties, unverifiable mandates, excessive intermediary chains, conflicting claims of authority or parties refusing reasonable counterparty disclosure.

12. TRANSACTION MONITORING

Compliance review does not necessarily end after initial onboarding.

RADIX may monitor transactions and relationships for activity inconsistent with:

* Information previously provided;

* The stated purpose of the transaction;

* Expected transaction size;

* Expected geographic activity;

* Known business operations;

* Identified source of funds;

* Identified ownership; or

* Normal commercial practices.

Material changes may trigger renewed KYC/KYB or Enhanced Due Diligence.

13. AML / TRANSACTION RED FLAGS

RADIX personnel are expected to identify and escalate potentially suspicious circumstances.

Examples include:

* Refusal to disclose beneficial ownership;

* Unverifiable corporate registrations;

* False or altered documents;

* Forged banking documents;

* Unverifiable proof of product;

* Unverifiable proof of funds;

* Unexplained changes in bank accounts;

* Requests for payments to unrelated third parties;

* Payments originating from unexplained third parties;

* Multiple unrelated entities involved in payment;

* Payments inconsistent with contractual parties;

* Unexplained use of cryptocurrency;

* Requests to conceal a party’s identity;

* Attempts to circumvent sanctions screening;

* Product originating from a prohibited jurisdiction;

* Unexplained commodity-origin changes;

* False refinery affiliations;

* False mandate representations;

* Unusual urgency intended to prevent due diligence;

* Resistance to ordinary KYC procedures;

* Large unexplained commissions;

* Uncommercial pricing;

* Transactions lacking legitimate economic purpose;

* Significant inconsistencies between transaction documents;

* Parties unable to explain their role in the transaction;

* Repeated last-minute changes to buyers, sellers, banks or payment instructions.

The existence of a red flag does not necessarily establish illegal conduct. It may, however, require additional investigation before RADIX proceeds.

14. ENHANCED DUE DILIGENCE

Enhanced Due Diligence (“EDD”) may be required when a counterparty or transaction presents elevated risk.

EDD may include:

* Additional identity verification;

* Expanded beneficial-ownership analysis;

* Corporate-registry research;

* Litigation and public-record searches;

* Adverse-media review;

* PEP screening;

* Enhanced sanctions screening;

* Source-of-funds verification;

* Source-of-wealth verification;

* Direct principal verification;

* Bank verification where legally and commercially appropriate;

* Verification of commodity origin;

* Verification of title or authority;

* Independent verification of transaction documents;

* Legal or specialist compliance review.

RADIX may require satisfactory completion of EDD before proceeding.

15. ANTI-BRIBERY & ANTI-CORRUPTION

RADIX prohibits bribery, kickbacks and improper payments.

No employee, officer, representative, consultant or business partner acting on behalf of RADIX may knowingly offer, promise, authorize, request or accept an improper payment or benefit for the purpose of obtaining an unlawful business advantage.

This prohibition applies to dealings with both public officials and private commercial parties.

16. THIRD-PARTY PAYMENTS

RADIX generally expects transaction payments to originate from and be paid to the entities identified in the governing transaction documents.

Third-party payments may be rejected or subjected to additional compliance review.

RADIX may request documentation explaining:

* The identity of the third-party payer or recipient;

* Its relationship to the transaction;

* The legitimate commercial reason for the payment;

* Source of funds;

* Beneficial ownership; and

* Authority for the payment.

RADIX will not knowingly facilitate payments intended to disguise the true origin, destination, ownership or purpose of funds.

17. DIGITAL ASSETS / CRYPTOCURRENCY

Transactions involving cryptocurrency or other digital assets may be subject to enhanced review.

RADIX may require information concerning:

* Wallet ownership;

* Transaction counterparties;

* Source of digital assets;

* Transaction history;

* Exchange or custodian;

* Beneficial ownership;

* Conversion into or from fiat currency; and

* Economic purpose of the transaction.

RADIX reserves the right to refuse digital-asset transactions presenting unacceptable compliance risk.

18. DOCUMENT AUTHENTICITY

All documentation provided to RADIX must be genuine, accurate, current and authorized.

RADIX maintains a zero-tolerance policy for knowingly fraudulent documentation.

Providing falsified, forged, manipulated, materially misleading or fraudulently obtained documents may result in immediate termination of discussions or the business relationship and may be referred to legal counsel or appropriate authorities when required or appropriate.

19. CONFIDENTIALITY & DATA PROTECTION

Information obtained through KYC, KYB, AML and counterparty due diligence is treated as confidential business and compliance information and handled in accordance with applicable law and RADIX’s information-security and privacy procedures.

Information may be disclosed when reasonably necessary to:

* Conduct compliance verification;

* Perform due diligence;

* Obtain professional legal or compliance advice;

* Satisfy contractual requirements;

* Respond to lawful governmental requests;

* Comply with subpoenas, court orders or other legal process;

* Protect RADIX or its affiliates against fraud or unlawful activity; or

* Meet other applicable legal obligations.

20. RECORD RETENTION

RADIX may maintain appropriate compliance records concerning counterparties and transactions, including:

* Identification records;

* Corporate documentation;

* Beneficial-ownership information;

* Compliance screening results;

* Transaction documents;

* Due-diligence materials;

* Communications;

* Approvals;

* Risk assessments; and

* Supporting documentation.

Records will be retained for periods determined by applicable law, contractual obligations, legitimate business requirements and RADIX’s record-retention policies.

21. CONTINUING OBLIGATION TO UPDATE INFORMATION

Counterparties are expected to notify RADIX of material changes that could affect their KYC/KYB or compliance profile, including changes involving:

* Beneficial ownership;

* Control;

* Corporate registration;

* Authorized representatives;

* Banking information;

* Sanctions status;

* Transaction purpose;

* Product origin;

* Product destination; or

* Other material transaction information.

RADIX may require renewed verification at any time when circumstances warrant.

22. RIGHT TO REFUSE OR TERMINATE BUSINESS

RADIX reserves the right, subject to contractual and legal obligations, to decline, suspend or terminate a proposed or existing relationship when:

* Required information is not provided;

* KYC/KYB cannot be satisfactorily completed;

* Beneficial ownership cannot be reasonably established;

* Documentation cannot be authenticated;

* Material information appears false or misleading;

* Sanctions concerns cannot be resolved;

* AML or fraud concerns remain unresolved;

* Transaction authority cannot be verified;

* Source of funds cannot be reasonably established when required;

* Commodity origin or ownership cannot be satisfactorily established; or

* The transaction otherwise exceeds RADIX’s compliance risk tolerance.

RADIX is not obligated to proceed with a transaction merely because documentation has been submitted.

23. FACILITATOR STATUS

Unless RADIX expressly agrees otherwise in a written agreement executed by an authorized representative, RADIX’s participation in a transaction should not be construed as a representation that RADIX is the commodity title holder, refinery, producer, financial institution, bank, principal purchaser, principal seller, escrow institution or governmental compliance authority.

Where RADIX acts as a facilitator or contractual intermediary, its role is to facilitate legitimate commercial relationships and transactions between appropriate counterparties.

Each transaction participant remains independently responsible for satisfying its own legal, regulatory, tax, licensing, sanctions, banking and contractual obligations.

24. REGULATORY FRAMEWORK

RADIX’s compliance program is designed with reference, where relevant and applicable, to recognized U.S. and international AML/CFT, sanctions, anti-bribery and counterparty-due-diligence principles.

RADIX applies such principles according to the nature of its business and the particular transaction.

Nothing in this policy is intended to represent that RADIX is a bank, money-services business, securities broker-dealer or other regulated financial institution unless a specific RADIX entity is separately registered or licensed as such.

Likewise, adoption of controls derived from financial-industry best practices does not constitute a representation that every regulatory requirement applicable to a covered financial institution applies directly to RADIX.

25. ZERO-TOLERANCE COMPLIANCE PRINCIPLE

RADIX will not knowingly participate in or facilitate:

Money Laundering • Terrorist Financing • Sanctions Evasion • Fraud • Bribery • Corruption • Forged Documentation • Illicit Commodity Transactions • Concealment of Beneficial Ownership • Deliberate Misrepresentation of Transaction Authority

All counterparties are expected to cooperate with reasonable compliance and due-diligence requests.

Failure to cooperate may result in rejection or termination of the business relationship.

26. COMPLIANCE CONTACT

RADIX HOLDINGS MANAGEMENT LLC

1825 NW Corporate Blvd., Suite 110

Boca Raton, Florida 33431

United States

Corporate Operations:

Boca Raton • Austin • Houston • San Antonio • Shanghai • Dubai

Compliance inquiries and requested KYC documentation should be submitted only through authorized RADIX corporate representatives and approved communication channels.

IMPORTANT NOTICE

This policy describes RADIX HOLDINGS MANAGEMENT LLC’s general compliance standards and risk-management practices. It does not constitute legal, regulatory, tax or financial advice and does not create rights in favor of any third party.

Compliance requirements may vary according to jurisdiction, transaction type, commodity, counterparty, applicable law and changes in regulatory requirements.

RADIX reserves the right to modify, supplement or strengthen these procedures at any time.

RADIX HOLDINGS MANAGEMENT LLC

Integrity • Transparency • Compliance

YOUR SUCCESS IS OUR BUSINESS.

One current legal point is especially important before this goes live: as of August 11, 2026, FinCEN states that U.S.-created companies are exempt from federal Corporate Transparency Act BOI reporting to FinCEN under the revised rule. That is separate from RADIX voluntarily collecting beneficial-ownership information from counterparties for KYC/KYB purposes.  FinCEN also continues to recognize beneficial-owner identification and ongoing, risk-based due diligence as core CDD concepts for institutions subject to its CDD Rule.