Investor
Glossary

Account ID / Trader Code

A unique alphanumeric code assigned by the Broker to identify the Client and its transactions.

Additional Fee

A fee charged to the Client in the event of violation of the Capital Adequacy Ratio (CAR) in order to cover the Company’s expenses.

Adjusted Initial Margin (AIM)

The aggregate amount of margin requirements for all open positions and orders of the Client.

Analytical Value

A revalued market or calculated fair value of securities in a margin transaction, taking into account accrued interest.

Ancillary Services

Additional services provided together with investment services — reporting, custody, clearing, consulting, etc.

Bank / Custodian Bank

Any bank in which the Broker has opened bank accounts for the purposes of settlements for Clients’ transactions and/or its own operations.

Base Currency / Target Currency

The currency from (into) which conversion is carried out or in which an obligation is denominated.

Beneficial Owner

A natural person(s) who ultimately owns or controls the Client and/or on whose behalf a transaction or operation is conducted, including control exercised through an ownership structure or otherwise, directly or indirectly.

Broker

Rioni Capital LLC (the Broker) — a professional participant in the securities market holding a brokerage license of the National Bank of Georgia, acting in the name and at the expense of the Client, or in its own name and at the expense of the Client, when concluding transactions with Financial Instruments for remuneration (commission).

Broker (Company, Rioni Capital LLC)

The brokerage company Rioni Capital LLC, licensed by the National Bank of Georgia to conduct brokerage activities, which, when concluding transactions with financial instruments, acts on behalf and at the expense of the Client or in its own name and at the expense of the Client. With respect to the recording of the Client’s rights to dematerialized securities, the Broker acts as an “account-holding entity” within the meaning of the Law of Georgia “On Ownership of Dematerialized Securities” and ensures the recording of such rights with a depository/custodian.

Broker Notification

Any administrative or informational message exchanged between the Broker and the Client in the course of performance of the Agreement.

Brokerage Account

A structural unit for grouping information about operations related to movements of the Client’s Property in the Broker’s internal accounting system, used, inter alia, for the purposes of applying the Fee Schedule.

Brokerage Agreement

A brokerage services agreement concluded between Rioni Capital LLC (the Broker) and the Client, regulating the procedure for the Broker’s provision of services in financial markets, opening and maintaining the Client’s Brokerage Account, as well as the rights and obligations of the Parties. All appendices thereto, including these Regulations (Appendix No. 1 to the Brokerage Agreement), constitute an integral part of the Brokerage Agreement.

Broker’s Website

The official website of the Company (www.rioni-capital.ge), containing information and documents for Clients.

Business Day

A calendar day, excluding officially established weekends and public holidays under the legislation of Georgia, as well as transferred days off, on which the Broker conducts activities from 10:00 to 19:00 Georgian time (GET), unless otherwise established by the Broker and communicated to Clients via the Website. On days that are non-business days for the Broker but business days for any Trading Organizer and/or the state of the settlement currency, the Broker may, at its discretion, provide certain services, notifying Clients via the Website no later than 2 (two) Business Days in advance.

Business Relationship

A relationship between a reporting entity and a Client established in connection with the provision of services or products which, by their nature, imply a certain duration (including the opening and maintenance of an account).

Capital Adequacy Ratio (CAR)

An indicator of the ratio of net asset value to the sum of margin requirements and non-marginable assets: CAR = 100% × NAV / (AIM + NMI).

Cashless Transaction

A transaction in which settlements are carried out by transfer without the use of cash funds.

CCP (Central Counterparty)

A central counterparty — a legal entity performing clearing activities in accordance with the legislation of Georgia or foreign regulation and assuming the function of a central counterparty for transactions of Clients and the Broker. The CCP becomes the buyer to every seller and the seller to every buyer (novation), ensuring clearing, settlements, risk management, margin requirements, close-out procedures, and other functions provided for by its rules.

Central Securities Depository

A depository that has been granted the status of a central securities depository in accordance with the legislation of Georgia.

Clearing House

An organization entitled to perform clearing activities on the basis of a license or other authorization issued by the competent authority under the legislation of Georgia or the relevant foreign jurisdiction, as well as a foreign organization performing activities similar to clearing.

Clearing Member

A participant of a clearing organization entitled to perform settlements and bear responsibility for clients’ positions.

Clearing Session

A period of time during which the Clearing House performs settlements on open positions, recalculates margin, and records the obligations of the parties.

Client

A Client of the Broker — a natural or legal person having contractual relations with the Broker and applying to the Broker for the purpose of concluding transactions with Financial Instruments. The Client delegates to the Broker the authority to conclude transactions with Financial Instruments, providing the necessary resources and assuming the associated risks.

Client Application Software

Computer programs provided by the Broker to the Client and/or used by the Client in accordance with the Agreement and the Client’s agreements with third parties, intended for exchanging Notifications, submitting Instructions, and accessing the Broker’s services.

Client Assets

The Client’s cash, securities held in the Brokerage Account, precious metals, as well as the Client’s cash, securities, precious metals that are to be credited to the Brokerage Account as a result of settlements under transactions concluded by the Broker in the Client’s interests.

Client ID / Unique Client Identifier (UCI)

A personal alphanumeric code assigned to the Client upon registration on the Broker’s website and remaining unchanged throughout the relationship.

Client Portal

An authorized organizational and technical remote service system (software) used by the Broker and the Client, providing access to the Broker’s services, the Client’s accounts and transactions via the Internet. The Client Portal enables conclusion and termination of Agreements, receipt and provision of services, and exchange of Electronic Documents and Notifications. The right holder of the Client Portal is the Broker. Access is provided to the Client via a web service (including via a link placed on the Broker’s Website) and/or a mobile application. The Client Portal is provided to the Client in accordance with the Software Use Agreement “Client Portal” and remote client service agreement.

Client Portfolio

A structural unit for grouping the Client’s Sub-Accounts in the Broker’s internal accounting system under the Agreement, within which the Broker performs control of the Client’s risks and analysis of its transactions.

Client Questionnaire

A collective term for the Individual Questionnaire and the Legal Entity Questionnaire (forms in Appendix No. 1 to the Agreement).

Client Risk Classification

A category characterizing the maximum permissible level of risk for the Client in the Broker’s risk management system and determined by the Broker based on the Questionnaire and other information about the Client in accordance with the procedure established by the Agreement and the Broker’s internal documents.

Client Risk Profile

Parameters of the risk management system applied to the Client’s portfolio.

Client software

Software for electronic computing machines provided by the Broker to the Client and/or used by the Client in accordance with the Agreement and the Client’s agreements with third parties, intended for exchanging Messages, submitting Orders, and accessing the Broker’s services.

Client’s Assets (Confirmed)

Cash funds and securities of the Client that meet the Company’s requirements and are available as collateral.

Client’s Obligations / Indebtedness

The aggregate of the Client’s debt obligations to the Company, including commissions, interest, loan repayments, and other payments.

Collateral

Assets (cash, securities) provided as collateral to secure the Client’s obligations to the Broker or the clearing organization.

Commodity Exchange Act (CEA) of 1936

A law regulating trading in derivatives, futures, and swaps under the supervision of the CFTC; a functional analogue of MiFIR (regulation of trading and clearing).

Compensation Sum

A monetary amount or market value of securities payable by the Client in connection with execution of margin transactions.

Concentration Limit

A limit per single instrument / single counterparty.

Conditional Order

An Instruction contained in the text of the Agreement, its Appendices, or a separate agreement between the Client and the Broker, executed by the Broker only upon fulfillment of the conditions specified therein.

Confidential Information

Any information obtained within AML/CTF procedures, including Client data, CDD/KYC materials, results of transaction monitoring, grounds for suspicion, and the fact or content of reports to competent authorities, which is subject to protection and restricted disclosure in accordance with the law and internal documents.

Contract Multiplier

A coefficient used to determine the total value of a futures or options contract (price × multiplier).

Contract Specification

Standardized terms of a derivative financial instrument or transaction established by the Trading Rules and/or the Agreement (including the type of Instrument, underlying asset, lot size, term to maturity, settlement procedure and other parameters).

Corporate Actions

Events affecting securities (dividends, splits, conversions, etc.).

Counterparty Exposure

Counterparty risk.

Counterparty Reliability Score

An assessment of the counterparty’s financial and technological/operational resilience (if applicable).

Counterparty SLA Breach Indicator

Breach of SLA by the service provider.

Country Exposure Limit

The maximum limit per single country.

CQG Trading Platform

An international system for trading futures and derivatives; brokers apply mark-ups to its tariffs.

Currency

National or foreign monetary units, including the Georgian lari.

Currency Conversion

An over-the-counter conversion of cashless funds, i.e., an exchange of the Client’s source currency into the target currency at an agreed rate, including for the purpose of replacing the currency of a Liability. In an Instruction (including a Conditional Instruction) for Conversion for the purpose of replacing liabilities, the source currency means the currency into which the current currency of the Liability is converted; the target currency means the currency in which the Liability is denominated at the time such Instruction (Conditional Instruction) is submitted.

Custody Services

Custody and administration of financial instruments, including settlements, reporting, and corporate actions.

Customer Liabilities

All obligations of the Client to the Broker under agreements and transactions, including payment for services and expenses.

Customer Order / Client Instruction

An instruction-type message submitted by the Client to the Broker for the purpose of concluding a transaction and/or performing an operation in the Client’s interests.

Daily Reconciliation

The Broker’s recording in internal accounting of operations and entries to fix, in the Client Assets Portfolio, the Client’s rights and Liabilities as of 14:00:00 (GET) on the business day following the reporting calendar day.

Data Integrity Indicator

An indicator of data accuracy and completeness.

Dealing on Own Account

Trading operations conducted by the Company using its own funds rather than the Client’s funds.

Default Fund

A reserve fund of the clearing organization used to cover losses in the event of default by participants.

Delivery Month

The calendar month in which performance or delivery under a futures contract takes place.

Delivery Notice

A document submitted by a clearing participant when intending to perform a contract through delivery of the underlying asset.

Dematerialization (DEMAT)

Conversion of securities into book-entry form with record-keeping through a depository.

Derivative

A derivative financial instrument (DFI, derivative contract, derivative) — a contract under which the parties obtain rights or assume obligations to perform certain actions in respect of an underlying asset.

DevEx Electronic Trading Platform

An electronic trading system developed by Devexperts Solutions for access to financial market transactions via the Internet.

Directive 2014/65/EU on Markets in Financial Instruments (MiFID II)

The main EU act establishing requirements for the provision of investment services, client classification, and investor protection.

Downtime

Period of service/equipment unavailability.

DWAC / DRS Transfers

Operations for the direct transfer of shares through the DTCC depository without a physical certificate.

E / ER Type Account

A classification of client accounts at U.S. brokers that differentiates the level of margin rights and restrictions.

E-Sign (Remote Agreement)

Execution (acceptance) of the Agreement by sending to the Broker the documents and information required to enter into the Agreement and its Appendices, in electronic form (including using a simple electronic signature), via a dedicated section of the Website, the Client Portal, or the Partner’s web interface using special technical means, in accordance with applicable civil legislation of Georgia and NBG normative acts.

E-Signature

Information in electronic form attached to or logically associated with other electronic data and used to identify the signatory and confirm the integrity of an electronic document. Within these Regulations, a simple electronic signature is used in the meaning defined by applicable legislation of Georgia and the E-Signature Usage Agreement (Appendix No. 8 to the Regulations).

Electronic Document

Information recorded in electronic form containing mandatory requisites enabling unambiguous identification of its content, author, and time of creation. An electronic document has legal force equivalent to a paper document, provided that an established method of electronic confirmation is used (electronic signature, SSO authentication, qualified identification means, or other methods recognized by the regulator).

Eligible Counterparty

A large and experienced market participant conducting significant trading operations (financial institutions, funds, etc.).

Equity

The Client’s own capital. Cash funds and securities of the Client held in the Brokerage Account, as well as cash funds and securities of the Client to be credited to the Brokerage Account as a result of settlements on transactions concluded by the Broker in the Client’s interests [from the Regulations].

Error Rate of Manual Operations

The frequency of personnel errors when performing manual operations.

Eurobond

Bonds denominated in a currency other than the currency of the issuer’s country, issued by foreign governments and other public authorities, international organizations, large corporations and other legal entities, and traded on international capital markets.

Exchange / ATS

A legal entity, including a foreign one (exchange, trading venue, broker, bank), ensuring the functioning of an organized market for securities, currencies, derivative financial instruments and other Instruments in accordance with the legislation of the relevant jurisdiction and its own Trading Rules.

Exchange Rules

Rules, regulations, instructions, procedures, regulatory documents or requirements of the Trading Organizer that are mandatory or recommended for execution by all trading participants on the relevant Trading Venue.

Execution Data

Information on trade execution.

Execution Latency

Delay in the execution of Client orders.

Execution of Orders on Behalf of Clients

Execution by the broker of transactions with financial instruments on behalf of the Client.

Expected Exposure

A value reflecting the potential impact of market changes on the Client’s assets in accordance with NBG requirements.

Expenses

The Company’s expenses related to margin operations that are not included in the Compensation Sum.

Explanatory Note

A commentary to expense calculations, including accounting for dividends on securities that were included in the Client’s obligations as of the record date.

Exposure

The total level of risk on an open position.

Exposure at Default (EAD)

The risk of losses in the event of default.

Exposure Limits

The maximum permissible risk per instrument / Portfolio.

Failover

Switching to a backup circuit/component of the IT system.

Fee Schedule

A standard commercial offer form determined by the Broker, specifying the list of services provided and the procedure for determining their cost. The list of Fee Schedules and the conditions for their application are contained in Appendices No. 2 and 2a to the Agreement.

Fiduciary Standard

A basic principle for the protection of investors’ rights and interests, as defined by the legislation of Georgia.

Financial Instrument

The subject matter and main terms of a transaction (securities, derivative financial instruments, currency, etc.) that may be concluded by the Broker pursuant to the Client’s Instruction under the Agreement.

Financing of terrorism

Any activity or operation aimed at the provision, collection, transfer, or use of funds or other assets for the purpose of supporting terrorist activity, a terrorist, or a terrorist organization, regardless of the lawful or unlawful origin of such funds.

FIX Interface

A protocol for connecting external trading systems and algorithms to the broker; the cost depends on speed and the range of instruments.

FOP Transfers

Transfers of securities between brokers without cash settlement (settlement has already been performed earlier).

Foreign Currency

The official monetary unit of the relevant country or group of countries (including the euro), other than the Georgian lari.

Foreign Security

A financial instrument recognized as a security under the legislation of the relevant foreign jurisdiction and traded on foreign organized and/or unorganized markets, the rights to which are recorded with a foreign depository, custodian, clearing organization, or other professional participant regulated by the competent authority of its jurisdiction.

Funding Gap

The gap between sources of liquidity and liquidity needs.

Futures Contract Specification

A document establishing the standard terms of a futures contract: lot size, underlying asset, expiration date, settlement type, and tick size.

Futures Position

An obligation of a participant to buy (long) or sell (short) the underlying asset under a futures contract.

FX Exposure

Open foreign exchange position.

FX GAP

Mismatch between assets and liabilities in a currency.

FX Sensitivity

Portfolio response to changes in foreign exchange rates.

FX Transactions related to Investment Services

Currency transactions performed for the purpose of executing or supporting the Client’s investment transactions.

FX Volatility

Variability of foreign exchange rates.

Gap Sensitivity

Sensitivity of the Portfolio to sharp price jumps.

Government-Issued ID

One of the following documents: • passport of a citizen of Georgia; • identification card (ID Card) of a citizen of Georgia; • birth certificate of a citizen of Georgia (for citizens of Georgia under 14 years of age); • passport of a foreign citizen; • residence permit in Georgia or another document recognized by the legislation of Georgia as a proper identity document.

Hedging

An operation to reduce market risk using offsetting transactions or derivatives.

Identification

The procedure for obtaining and recording identification data of the Client, the Client’s representative, and/or the beneficial owner in accordance with AML/CTF legislation requirements.

Incident Frequency

The number of operational incidents over a period.

Informed Investor (Accredited Investor)

A person recognized as such in accordance with Order of the President of the National Bank of Georgia No. 223/04 dated 16 December 2020 “On Approval of the Procedure for Recognition of a Person as an Informed Investor”, in accordance with the Procedure for Decision-Making on Recognition of Persons as Informed Investors of Rioni Capital LLC, published on the Broker’s Website, and in accordance with the Client Categorization Policy of the brokerage company “Rioni Capital”.

Infrastructure institution

A prime broker, custodian, central securities depository, central counterparty, clearing organization, and other financial market infrastructure institutions.

Initial Margin (IM)

The minimum collateral required to open a position. (In the Regulations: the required level of collateral for opening a position.)

Initial Margin / Performance Bond

A parameter of the Broker’s risk management system determined by the Clearing House and/or based on the Clearing House requirements for the amount of individual clearing collateral for the Client’s Portfolio. The amount of Initial Margin displayed in the Client’s software may differ from the amount calculated by the Clearing House; the Client is obliged to independently monitor the amount of Initial Margin.

Initial Public Offering (IPO)

Placement of a company’s shares on an exchange for the purpose of raising capital.

Instant Messaging System

A channel for exchanging information and Notifications in real time within the software provided by the Broker to the Client.

Interest

An amount accrued for the use of borrowed funds and/or securities within margin transactions.

Interest Income

Any cash and/or other property received in respect of securities, including, but not limited to, dividends, interest, accrued coupon income, other types of income and distributions paid (transferred) by the issuer of securities or another person that issued the securities, net of taxes, fees, and other mandatory withholdings.

Investment Activities

A set of actions of the Company within the scope of its license, including proprietary trading, custody of assets, and currency operations.

Investment Advice

A personalized recommendation to the Client regarding the acquisition, sale, or holding of financial instruments.

Investment Adviser

A management company or fund managing assets or funds on the basis of a license.

Investment Advisory Services

The Broker’s service of providing the Client with personalized investment advice in accordance with the Agreement and Appendix No. 12 to the Regulations, as well as other internal documents of the Broker and the legislation of Georgia.

Investment Company Act of 1940 & Investment Advisers Act of 1940

The SEC regulatory framework governing the activities of funds and investment advisers; analogous to PRIIPs in terms of risk disclosure and duties toward retail investors.

Investment Research / Financial Analysis

Analytical activities aimed at providing information and forecasts on financial instruments and markets.

Investment Services

Activities licensed to the Company: reception and execution of orders, portfolio management, investment advice, etc.

Investment Services License

Authorization issued by the regulator (NBG/EU) to provide investment and ancillary services.

ISLA

An international association establishing standards and best practices for the securities lending market, including rules on securities return, income compensation, collateral management, and operational interaction among participants.

Issuer Concentration Limit

The maximum limit per single issuer.

KYC Data

Information about the Client, its representatives, and beneficial owners, provided to the Broker as part of the questionnaire and supporting documents.

Latency

Response delay.

Lending / Credit in respect of Financial Instruments

Granting credit or a loan to the Client for transactions with financial instruments, with the Company participating in the transaction.

Leverage

The ratio between the volume of an open position and the Client’s own funds, used to increase potential returns (and risk).

Limit Order

An Instruction to conclude a transaction at the price specified in the Instruction or at a price more favorable to the Client.

Liquidity Constraint

Limitation of positions based on liquidity.

Liquidity Coverage Ratio

The ratio of liquid assets to liabilities.

Liquidity Score

An indicator of an instrument’s liquidity.

Lock-up Period

A period established by the issuer (usually 90 days or more) during which shares may not be sold after placement.

Long Position

A position arising from the purchase of an asset with the expectation of an increase in its market value.

Maintenance Margin

The minimum margin level that the Client is required to maintain in order to keep open positions.

Maintenance Margin (MM)

The minimum collateral required to maintain positions.

Margin Call

A notification from the Broker to the Client of the need to replenish the account or close positions in order to restore the required CAR level.

Margin Call Trigger

The margin level at which a margin call is issued to the Client (a requirement to provide additional collateral or close the position to the required extent).

Margin Close-Out Level / Liquidation Level / Close-Out

The collateral level upon reaching which the Broker initiates forced liquidation of the Client’s position.

Margin Close-Out Trigger

The collateral level upon reaching which the Broker initiates forced liquidation of the Client’s position.

Margin Level

The ratio of equity to required margin.

Margin Loan

Cash or securities provided by the Company to the Client for execution of margin transactions.

Margin Requirements

The amount of collateral required by the Company from the Client to open and maintain a margin position.

Margin Transaction

A transaction executed by the Client using leverage provided by the Broker (margin loan).

Marginable Assets

Client assets that may be used as collateral for margin transactions.

Mark-to-Market Margin

Variation margin calculated by the Clearing House according to the variation margin calculation formula during a clearing session using the current settlement price of the i-th futures contract. The total Mark-to-Market Margin in the i-th currency forms the Client’s obligations/claims and is included in the Expected Position for the corresponding currency. The Client is obliged to independently monitor the Mark-to-Market Margin.

Market

A place for concluding transactions with Instruments of a certain type, determined by the Broker. Within the Agreement, the Broker distinguishes, inter alia, the equity market, derivatives market, and foreign exchange market.

Market Data Delay

Delay in the provision of up-to-date market quotations.

Market Depth (DOM)

Order book structure and a liquidity indicator.

Market Order

An Instruction to conclude a transaction at the price available to the Broker on the relevant trading venue at the time of execution of the Instruction (without specifying a price limit). The Trading Organizer may set maximum permissible price deviations when executing such Instructions; information about this may be obtained by the Client on the official website of the relevant Trading Organizer.

Maximum Leverage

The maximum permissible leverage.

Money laundering

Any actions or operations aimed at concealing or disguising the illegal origin of assets or proceeds obtained by criminal means, or at giving them the appearance of lawful origin, as defined by the AML/CTF legislation of Georgia.

National Bank of Georgia (NBG)

The central bank of Georgia exercising supervision and regulation of financial institutions, including brokerage companies, in accordance with the legislation of Georgia.

Net Asset Value (NAV)

The market value of the Client’s assets minus all obligations to the Company.

Netting

A process of offsetting mutual obligations between parties in order to reduce the total volume of settlements and risks.

NLV — Net Liquidation Value

The liquidation value of the Portfolio.

Non-marginable Assets (NMI)

Client assets that are not accepted as collateral for margin transactions.

Non-standard Report

An individual account report generated upon request (audit, tax authorities, court, etc.).

Non-trading Orders

Orders not directly related to trading operations (for example, transfers, reporting).

Notification

Any directive or informational message sent by the Broker to the Client or by the Client to the Broker in the course of performance of the Agreement, including via the Client Portal, Trading Platform, e- mail, Chat, and other agreed communication channels.

Offering of Investment Products

Sale to Clients of financial instruments corresponding to their risk profile and investment objectives.

Official Exchange Rate

The exchange rate established and published by the National Bank of Georgia (NBG).

Onboarding System

An authorized organizational and technical remote service system (software) used by the Broker and the Client to support the Client onboarding process: remote client identification, document exchange, conclusion of the Brokerage Agreement, and opening of a Brokerage Account. Access is provided to the Client via a web service and/or a mobile application.

Open Contract

The number of open (concluded) derivative (futures or options) contracts in the Client’s Portfolio that have not been settled at the current time, i.e., are pending settlement completion or contract expiration.

Open Interest

The total number of outstanding (not closed and not executed) contracts for a specific futures contract or option.

Open Position

An unclosed buy or sell transaction in an asset, maintaining potential profit or loss until it is closed.

Option Expiration

The date on which an option expires, after which the contract loses its validity and ceases to be tradable.

Option Premium

The price paid by the option buyer to the seller for the right (but not the obligation) to buy or sell the underlying asset at a specified price.

Option Type (Call / Put)

Determines the right to buy (Call) or sell (Put) the underlying asset at a fixed price.

Order Ticket

An instruction-type message for concluding transactions, submitted by the Broker (as a trading participant) to the Trading Organizer in the manner and on the terms established by the Trading Rules, for the purpose of executing the Client’s Instruction.

Over-the-Counter (OTC) Market

A venue or form of trading where transactions are concluded directly between counterparties rather than through an exchange.

Personalized Investment Advice

Information addressed to a specific Client about securities, derivative financial instruments, currency and/or transactions with them, prepared taking into account the Client’s objectives, experience, financial situation, and attitude to risk, meeting the requirements of Georgian legislation, NBG normative acts, and the Broker’s internal documents governing investment advisory activities.

Politically Exposed Person (PEP)

A natural person who is or has been entrusted with prominent public functions, as well as members of their family and persons closely associated with them, as defined by AML/CTF legislation and regulatory requirements.

Portfolio Management

Activities related to discretionary management of the Client’s assets based on the Client’s investment objectives and strategy.

Portfolio Value

The aggregate of the Client’s Expected Positions of one Portfolio, expressed in Georgian lari (or in a foreign currency if provided for by the Agreement). The Portfolio Value displayed in the Trading System software used by the Client for exchanging Notifications with the Broker may differ from the value calculated by the Broker and disclosed in the Client Portal; the Client is obliged to independently monitor the value of any of its Portfolios.

Primary Contact Number

The Client’s primary mobile phone number specified in the questionnaire and provided by the telecommunications operator.

Primary Market Data

Price information received from exchanges.

Prime Broker / Executing Broker

A foreign or Georgian professional market participant holding the relevant license/authorization to carry out brokerage activities, through which the Broker executes Clients’ Instructions on foreign trading venues and/or organized markets.

Principal Office

The principal place of business of the Broker and its divisions, as indicated on the Company’s website.

Professional Client

A client possessing sufficient knowledge, experience, and assets to understand risks and receiving limited protection under MiFID II.

Qualified Custodian

An organization carrying out the activity of a specialized custodian of investment funds, pension schemes and/or other collective investment institutions on the basis of a license or other authorization issued by a competent authority in accordance with the legislation of Georgia or the relevant foreign jurisdiction.

Quick Ratio

Coverage of liabilities by liquid assets.

Quote Currency

The currency in which the price of an instrument is expressed or in which settlement under a conversion transaction is carried out.

Real-time Market Data

A stream of quotations and trading information provided on a subscription basis.

Reasonable Assumption

A conclusion or assumption based on facts, documents, behavioral indicators, transaction patterns, or other objective data sufficient for AML/CTF assessment, initiation of additional analysis, and/or a decision on further actions.

Reception and Transmission of Orders

A service for receiving instructions from the Client and transmitting them to third parties for execution.

Redomiciliation

Re-registration of a legal entity or fund in another jurisdiction while preserving the ownership structure.

Reference Prices

Prices used for asset valuation.

Referral Partner

A legal entity with which the Broker has entered into a paid services agreement for the search and attraction of potential clients, as well as for organizing document flow between the Broker and the Client, including via a dedicated website (web interface) on the Internet.

Regulation (EU) No 1286/2014 on Key Information Documents for Packaged Retail and Insurance-based Investment Products (PRIIPs)

An EU regulation establishing requirements for the content and provision of Key Information Documents (KIDs) for transparency and protection of retail investors.

Regulation (EU) No 600/2014 on Markets in Financial Instruments (MiFIR)

An EU regulation supplementing MiFID II; regulates trade execution, reporting, transparency, and market access.

Related Transactions

Several interrelated transactions or operations united by a common economic substance, purpose, participants, source or destination of funds, or other characteristics which, for AML/CTF purposes, are subject to review in aggregate.

Reporting Format

The structure for presenting brokerage reports used for calculations and audits.

Responsible Employee

An employee of the Broker appointed to perform AML/CTF control functions, including Client identification and verification, transaction monitoring, escalation of suspicious cases, and interaction with competent authorities in accordance with legislation and internal policies.

Responsible Person

A person or organization entrusted, in accordance with the legislation of Georgia in the field of AML/CTF, with duties to prevent, detect, and control money laundering and terrorist financing risks, including compliance with established procedures and requirements (including financial institutions such as brokerage companies).

Retail Client

A client who is not a professional or eligible counterparty and receives the maximum level of regulatory protection.

Return

Change in the value of an instrument over a period.

Risk Groups

A set of parameters of the Broker’s Risk Management System (RMS) applied to a specific Client Portfolio. The list of Risk Groups and their parameters are determined by the Broker and published on the Broker’s Website.

Risk Weight

A risk weight used in the calculation of IM/MM.

Round Lot / Standard Lot

The minimum quantity of an instrument determined by the trading venue for concluding transactions.

RPO (Recovery Point Objective)

The acceptable data loss.

RTO (Recovery Time Objective)

The acceptable recovery time.

Safekeeping

A service for the secure custody of the Client’s securities and assets in a depository or with a custodian.

Sanctions Restrictions

Any restrictive measures (including economic, financial, trade sanctions and other restrictions) adopted or imposed by: • state authorities of Georgia; • authorities of foreign states, unions of states, international organizations (including, but not limited to, the United Nations Organisation, the United States Department of the Treasury, the Council of the European Union, HM Treasury, the Office of Foreign Assets Control), in respect of states, persons, currencies, financial instruments or transactions, and prohibiting directly or indirectly: i. purchase, sale, or investment; ii. servicing, financial intermediation, participation in primary offerings; iii. entering into and/or executing certain or all types of transactions with financial instruments; iv. making payments and/or transactions necessary for execution of the Client’s Instructions or obligations under transactions in the Client’s interests. Sanctions Restrictions include, in particular, the inclusion of the relevant persons in the U.S. Treasury sanctions list “SDN List”, as well as in other official sanctions lists.

Secondary Market Data

Price information received from data aggregators.

Secondary Public Offering (SPO)

An additional issuance of shares of a company already traded on an exchange.

Sector Exposure Limit

The maximum limit per single sector.

Securities

Issued and non-issued securities, including shares, bonds, investment units, other equity and debt instruments, as well as foreign securities recognized as such in accordance with the legislation of Georgia and/or applicable legislation of relevant foreign jurisdictions.

Securities Exchange Act of 1934

A fundamental U.S. law regulating the secondary securities market, the activities of broker-dealers and exchanges; functionally analogous to MiFID II in terms of regulation of services and disclosure.

Settlement Account

A special account used for conducting clearing settlements and mutual settlements between participants.

Settlement Delay

Clearing delay. Delay in settlements on transactions and operations.

Settlement Price

A price established by the Clearing House for the calculation of variation margin and participants’ obligations.

Shareholder Register

A list of persons (holders of securities) entitled to receive income on securities and other payments/distributions, compiled by the issuer of securities or another authorized person in accordance with applicable legislation.

Short Position

A position arising from the sale of securities without coverage (expectation of a price decrease).

Spot FX Transaction

A purchase and sale transaction of foreign currency on organized foreign exchange markets.

Spread Indicator

Deviation of the current spread from the average statistical spread.

Stop Order / Stop-Limit Order

An Instruction at a limit or market price for an exchange transaction with deferred conditions provided for by the functional capabilities of the software, execution of which becomes mandatory for the Broker after occurrence of the conditions for order placement and/or transaction conclusion specified in the Instruction.

Stress Prices

Prices used for stress testing.

Stress-Loss

Portfolio loss under stressed market movements.

Structured Products

Complex financial instruments combining securities and derivatives.

Sub-Account

A structural unit of the Broker’s internal accounting, constituting part of the Client’s Portfolio and intended for recording the quantity of the Client’s Property and Liabilities by reflecting transactions and operations with the Client’s securities, derivatives, precious metals, and cash. Within one Client Portfolio, at least one Sub-Account is opened; the number and structure of personal accounts are determined by the Client and/or the Broker in accordance with the Agreement.

Sub-Broker / Introducing Broker

A Client of the Broker who is a professional participant of the securities market and carries out brokerage activities in the interests and on behalf of its clients on the basis of a license or other authorization of the regulator of the country of registration of such Client.

Suspicious Transaction

A transaction, operation, or an attempt thereof in respect of which there are reasonable grounds to believe that it may be related to money laundering, terrorist financing, sanctions evasion, or other unlawful purposes and is therefore subject to analysis and, where necessary, reporting to the competent authorities.

Suspicious Zone

A corporate term (not a mandatory legal definition): a geographical area, jurisdiction, client segment, type of activity, or operational channel with elevated AML/CTF risk, identified by the Broker’s internal risk assessment and/or communications from competent authorities, in respect of which enhanced control and monitoring measures are applied.

Swaps and Structured Notes

OTC derivatives concluded directly between participants, outside an exchange.

System Outages

Unavailability of critical IT systems.

Tick Size

The minimum possible price change of a financial instrument established by the contract specification.

Trade Execution / Filled Order

A fully or partially executed Client Instruction having a unique number in the Broker’s system.

Trading Fee

An additional remuneration of the Broker for executing exchange transactions on behalf of the Client, in accordance with the Fee Schedule.

Trading Platform

An information and trading remote-access system provided by the Broker to the Client for transmitting Messages and Orders electronically via the Internet. The list of trading systems and software used by the Broker may be expanded and is specified on the Broker’s Website and/or in the Appendices to the Agreement.

Trading Session / Market Day

The period of time during which Trading Organizers conduct trading. The list of available Trading Organizers and their schedules is published on the Broker’s Website.

Transactions

Any operation or set of actions of the Client or the Broker related to financial instruments, funds, currency, or other assets, including submission and execution of orders, transfers, conversion, and settlements, for AML/CTF control purposes.

Uncovered Position

A negative value of the Client’s Planned Position formed within the Portfolio by a specific type of Assets; the amount of the Uncovered Position is increased by the Broker by the amount of the Client’s Liabilities.

Underlying Asset

A financial instrument, commodity, or indicator on which a derivative financial instrument is based. This may be a security, commodity, currency, interest rate, or other indicator.

Unusual Transaction

A transaction or operation which, by its amount, frequency, structure, economic substance, or inconsistency with the Client’s profile, is atypical and requires additional analysis for AML/CTF purposes; an unusual transaction may, but does not necessarily have to, be recognized as suspicious.

Uptime

Service availability percentage.

Value-at-Risk (VaR)

The maximum expected loss over a specified confidence interval.

Variation Margin

An amount of funds calculated by the Clearing House during a clearing session and subject to crediting to or debiting from the Sub-Account for each concluded futures contract and/or Open Position formed during previous clearing sessions, in accordance with the Specification of the relevant futures contract.

Verification

Verification of the accuracy of identification data of the Client, the Client’s representative, and/or the beneficial owner on the basis of documents, information, or reliable sources, in the manner established by AML/CTF requirements.

Volatility

A statistical measure of price variability.