1. Purpose and Legal Nature of This Disclosure

This Group Legal Structure & Regulatory Disclosure (the "Disclosure") is published to provide a transparent and accurate description of the legal, operational, and regulatory framework under which the Polar Tensor™ group of companies operates.

This Disclosure:

• is informational in nature;
• does not constitute an offer, solicitation, or recommendation of any financial product or investment;
• does not amend or replace any binding contractual documentation; and
• must be read together with the applicable customer agreements, risk disclosures, and entity-specific terms.

In the event of any inconsistency, the applicable customer agreement and mandatory legal disclosures shall prevail.

2. Structural Design Principles

The Polar Tensor™ group is intentionally structured to ensure strict functional separation between:

• legal custody and safeguarding of client digital assets;
• fiat payment processing and exchange services;
• automated trading execution technology; and
• research, development, and intellectual property creation.

No group entity combines these activities in a manner that would create:

• discretionary asset management;
• collective investment schemes;
• pooled investment vehicles; or
• unlicensed financial intermediation.

Each entity operates solely within the scope of its legally permitted activities under the laws of its jurisdiction.

3. Holding and Ownership Entity

Polar Tensor™ Corporation
Jurisdiction: British Virgin Islands

Polar Tensor™ Corporation acts exclusively as the ultimate holding company of the group.

It:

• holds equity interests in operating subsidiaries;
• exercises high-level corporate governance and ownership oversight; and
• may hold intellectual property rights at group level.

It does not:

• onboard clients;
• enter into customer contracts;
• hold, control, or safeguard client assets;
• execute trades or operate trading systems;
• provide payment services; or
• perform any regulated financial activity.

The holding company is not a crypto-asset service provider, money services business, or investment firm.

4. Automated Trading Technology & Execution Layer

Polar Tensor™ Corp.
Jurisdiction: Republic of Panama

Polar Tensor™ Corp. operates solely as a technology provider and execution infrastructure operator.

4.1 Nature of Services

Its activities are limited to:

• operating proprietary automated trading software;
• technically executing spot cryptocurrency trades based on predefined system logic;
• routing orders to third-party execution venues for liquidity and execution efficiency.

Trading logic:

• is system-defined and uniform;
• is not customised on a per-client basis; and
• is executed only after explicit client activation.

4.2 Explicit Exclusions

Polar Tensor™ Corp.:

• does not provide custody of client assets;
• does not onboard or contract with retail clients;
• does not accept fiat or crypto deposits from clients;
• does not provide personalised investment advice;
• does not exercise discretionary authority over client portfolios; and
• does not guarantee performance, returns, or capital protection.

Its role is strictly that of a non-discretionary technical execution agent.

5. United States & International (Non-EU) Client Entity

Polar Tensor™ US LLC
Jurisdiction: United States – Wyoming

Polar Tensor™ US LLC is the exclusive client-facing entity for:

• U.S. residents; and
• non-EU international clients.

5.1 Regulatory Status

• Registered with FinCEN as a Money Services Business (MSB).
• Holds a Wyoming Money Transmitter License.
• Maintains additional state-level registrations as required.

5.2 Responsibilities

Polar Tensor™ US LLC is solely responsible for:

• customer onboarding and account administration;
• KYC, AML, and sanctions compliance;
• legal custody and safeguarding of client digital assets;
• processing of deposits and withdrawals; and
• regulatory reporting and consumer disclosures.

No other group entity has independent withdrawal authority over U.S. or non-EU client assets.

6. European Union Client Entity

Polar Tensor™ Europe SP ZOO
Jurisdiction: Republic of Poland (European Union)

Polar Tensor™ Europe SP ZOO is the exclusive onboarding, custodial, and withdrawal entity for EU-resident clients.

6.1 Regulatory Status

• Registered as a Virtual Asset Service Provider (VASP).
• In the process of obtaining Crypto-Asset Service Provider (CASP) authorisation under Regulation (EU) 2023/1114 (MiCA).

6.2 Responsibilities

This entity alone performs:

• EU client onboarding;
• KYC and AML compliance;
• custody and safeguarding of EU client digital assets;
• deposit and withdrawal processing; and
• EU regulatory reporting and consumer-protection obligations.

No EU client is onboarded, custodied, or serviced by a non-EU entity.

7. Payments, Fiat Exchange & Card Services

Polar MSB Inc.
Jurisdiction: United States – Montana

Polar MSB Inc. operates as a payment services and fiat gateway provider.

Its services include:

• fiat on- and off-ramp processing;
• crypto-to-fiat and fiat-to-crypto exchange;
• crypto-to-crypto exchange; and
• card-based payment products via licensed third-party partners.

It does not:

• execute trading strategies;
• provide investment services;
• hold execution-layer trading balances; or
• receive performance-linked compensation.

8. Research & Development Entity

Polar Tensor™ LAB Limited
Jurisdiction: Hong Kong

Polar Tensor™ LAB Limited operates exclusively as a research and development entity.

Its activities are limited to:

• algorithmic research and testing;
• software development;
• infrastructure engineering; and
• technology innovation.

It has:

• no client interaction;
• no custody or control of client assets;
• no execution authority; and
• no payment or exchange role.

9. Client Asset Handling & Execution Transfers

Across all jurisdictions:

• Client assets remain under the legal custody of licensed custodial entities.
• Clients retain legal and economic ownership at all times.
• Any transfer of assets to execution layers is: temporary; strictly limited to spot trade execution; and revocable through client withdrawal rights.

Aggregated (omnibus) execution wallets, where used:

• are technical in nature only;
• do not constitute economic pooling; and
• do not create shared profit or loss exposure.

No client assets are lent, rehypothecated, pledged, or used for proprietary purposes.

10. Regulatory Characterisation

The structure is designed so that:

• automated trading is characterised as execution technology, not portfolio management;
• no collective investment scheme or alternative investment fund is formed;
• no discretionary investment mandate exists; and
• all regulated activities occur within properly licensed entities.

11. Important Risk & Responsibility Notice

Digital assets and automated trading involve substantial risk, including the risk of total loss.

No guarantees of performance, profit, or capital preservation are provided.

Clients are solely responsible for:

• deciding whether to use automated trading functionality; and
• assessing the suitability of the services for their individual circumstances.