PaxFinance

Public Offer

Pax Finance Limited Liability Partnership

BIN 260540020321

License of the National Bank of the Republic of Kazakhstan for dealer activity in the digital asset market - exchange operations with unbacked digital assets

No. 0126001O dated 30 June 2026

PUBLIC OFFER

(User Agreement — Adhesion Agreement)

on the provision of services for operations with unbacked digital assets on the platform of Pax Finance LLP

Public version for clients

Version 2.2

APPROVED

by order of the Director of Pax Finance LLP

Beispekov Aslan Galimovich

No. 7 dated 6 November 2026

This Public Offer (hereinafter the "Agreement") is a public offer by Pax Finance LLP, BIN 260540020321 (hereinafter the "Operator"), to conclude an adhesion agreement on the provision of services for operations with unbacked digital assets on the terms established by this Agreement. In other documents of the Company, this Agreement is also referred to as the "User Agreement".

The parties to the Agreement are the Operator and the Client. The Client is a natural person who has reached the age of 18 (eighteen) years and has the necessary legal capacity, or a legal entity, in accordance with paragraph 25 of the Rules for carrying out the activities of operators for the exchange of unbacked digital assets, approved by Resolution of the Board of the National Bank of the Republic of Kazakhstan No. 45 dated 29 April 2026 (hereinafter "Rules No. 45"), that has declared its adhesion to this Agreement by performing an acceptance in the manner established by this Agreement — in accordance with Article 389 of the Civil Code of the Republic of Kazakhstan.

In accordance with Article 396 of the Civil Code of the Republic of Kazakhstan, the actions of the Client aimed at obtaining the Operator's services, including registration of an account on the Platform, completion of identification procedures (CDD/KYC) and submission of Instructions to carry out Operations, are recognized as acceptance of this Agreement. The performance of such actions means the full and unconditional acceptance by the Client of all the terms of this Agreement and is equivalent to the conclusion of a bilateral written agreement.

Each of the Parties guarantees to the other Party that it has the necessary legal capacity and capability, as well as all the rights and powers necessary to conclude this Agreement and to duly perform the obligations arising from it.

The public nature of this Offer (its availability to an indefinite range of persons for the purposes of its acceptance) means the application of Article 389 of the Civil Code of the Republic of Kazakhstan (adhesion agreement) to the procedure for its conclusion and does not mean that the Agreement is a public agreement within the meaning of Article 387 of the Civil Code of the Republic of Kazakhstan, since the Operator's activity, by virtue of the requirements of the legislation of the Republic of Kazakhstan on AML/CFT/CPF, involves conducting due diligence, risk assessment and possible refusal to serve certain persons on the grounds established by the legislation of the Republic of Kazakhstan and sections 5, 12 of this Agreement. Such a refusal does not constitute the granting by the Operator of advantages to certain Clients and does not violate the rights of Clients who have duly completed the due diligence procedures.

1. Information about the Operator

Pax Finance LLP, BIN 260540020321, carries out the activity of organizing the exchange of unbacked digital assets for money on the basis of:

  • the License for dealer activity in the digital asset market - exchange operations with unbacked digital assets No. 0126001O dated 30 June 2026 (hereinafter the "License"), issued by the National Bank of the Republic of Kazakhstan;
  • Rules No. 45;
  • the Law of the Republic of Kazakhstan No. 193-VII dated 6 February 2023 "On Digital Assets in the Republic of Kazakhstan";
  • the Law of the Republic of Kazakhstan No. 191-IV dated 28 August 2009 "On Combating the Legalization (Laundering) of Proceeds of Crime, the Financing of Terrorism and the Financing of the Proliferation of Weapons of Mass Destruction" (hereinafter the "AML/CFT/CPF Law");
  • the Civil Code of the Republic of Kazakhstan and other legislation of the Republic of Kazakhstan.

Details of the Operator

  • Full name: Pax Finance Limited Liability Partnership
  • BIN: 260540020321
  • Location: 010000, Republic of Kazakhstan, Astana, Nura district, Kabanbay Batyr Avenue, 47/2, non-residential premises 2
  • Website: https://paxfinance.kz
  • Phone: +7 777 992 1113
  • Email: info@paxfinance.kz

2. Important notice and risk warning

2.1. Operations with digital assets involve the risk of the total or partial loss of the funds invested. The full list of risks is disclosed in the Company's Risk Warning (hereinafter the "Risk Warning"), posted on the Company's website and constituting an integral part of this Agreement. Familiarization with this Agreement does not replace familiarization with the Risk Warning.

2.2. If the Client does not agree with the terms of this Agreement or does not accept the risks set out in the Risk Warning, the Client is obliged to refrain from registering an account and using the Operator's services.

2.3. The Operator is not a broker, trustee, agent or investment advisor of the Client; no fiduciary relationship arises between the Parties. The Operator does not provide investment, legal or tax advice. Any information posted on the Platform is of an informational and reference nature and does not constitute a recommendation to carry out operations.

2.4. The services and information on the Platform are provided on an "as is" and "as available" basis; the Operator does not guarantee the continuity or uninterrupted nature of access but takes reasonable measures to maintain the operability of the Platform in accordance with the Company's Information Security and Cybersecurity Policy.

2.5. The Operator is not liable for the content of third-party sites, links to which may be posted on the Platform, or for the Client's access to the Internet and compatible equipment.

3. Subject of the Agreement

3.1. On the terms of this Agreement, the Operator provides the Client with services for the purchase and sale of unbacked digital assets for money (national and, for non-residents, foreign currency in the cases provided for by paragraph 26 of Rules No. 45) and provides access to such services through the Platform, as well as, subject to activation of the relevant service channel in the manner established by the Company's Payment Procedure, through the Operator's physical cash desk and (or) self-service points (crypto ATMs) (hereinafter jointly the "Operations"), in accordance with the Operator's tariffs.

3.2. By accepting this Agreement, the Client undertakes to: provide accurate and complete data upon registration and identification; pay the value of the unbacked digital assets purchased at the Operator's rate in the manner established by the Company's tariffs; use the Platform solely for lawful purposes.

3.3. Operations are carried out by the Operator in its own name and at its own expense (dealer model). The initiation and confirmation of an Operation is carried out by the Client by generating an Instruction (order) on the Platform.

3.4. The Platform fixes the purchase and (or) sale rate and the final amount of the Operation and presents them to the Client for confirmation before the Operation is carried out. The rate is deemed fixed from the moment the Client confirms the parameters of the Operation on the Platform. The payment procedure, the validity period of the fixed rate and the procedure for actions when payment is received outside this period are established by the Company's Payment Procedure (hereinafter the "Payment Procedure") and, for Large Operations, also by section 11 of this Agreement.

3.5. The Operator proceeds to execute the Operation subject to the Operator's receipt of money or digital assets from the Client in the manner provided for by the Payment Procedure. The grounds on which the Operation is not executed or its execution is suspended are established by the Payment Procedure, the Company's AML/KYC Policy and section 7 of this Agreement. The periods for the execution of Large Operations are established by section 11 of this Agreement.

3.6. This Public Offer does not apply to Clients that are legal entities that have concluded a separate written agreement with the Operator on the provision of services for exchange operations with unbacked digital assets. Only the terms of the relevant separate agreement, and not this Public Offer, apply to the relations of the Parties with such Clients.

4. Publication and amendment

4.1. The current version of the Agreement is posted by the Operator on the website https://paxfinance.kz.

4.2. The Operator has the right to unilaterally amend the Agreement, notifying the Client by posting a new version on the website. The amendments enter into force from the moment of publication, unless another date is specified in the new version. Continued use of the Platform after the said date means the Client's agreement to the new version of the Agreement.

4.3. The Operator informs the Client of changes to the terms of carrying out the licensed activity affecting the Client's rights and obligations within 3 (three) business days from the day of receipt of the relevant information from the National Bank of the Republic of Kazakhstan.

5. Access to the Platform and identification procedures

5.1. The Platform and the Operator's services are available solely to registered Clients who have completed the identification and verification procedures in accordance with the Company's AML/KYC Policy.

5.2. To obtain access to the services, the Client provides the Operator with information and documents to the extent established by the Company's AML/KYC Policy, including an identity document (for natural persons) or constituent and registration documents (for legal entities), IIN/BIN, information about the source of origin of money and (or) digital assets, information about tax residence and contact details.

5.2.1. Identification of Clients who are residents of the Republic of Kazakhstan is carried out by means of biometric authentication through the Identification Data Exchange Center of the National Bank of the Republic of Kazakhstan (IDEC). Identification of Clients who are non-residents of the Republic of Kazakhstan is carried out by means of the IDEC and (or) third-party remote identification services in the manner established by paragraph 30 of Rules No. 45 and the Company's AML/KYC Policy; for non-residents, an identity document of a foreign citizen (passport) is accepted.

5.3. The Client guarantees that: the Client, being a natural person, has reached the age of 18 and has the legal capacity necessary to conclude the Agreement; the Client, being a legal entity, is duly established and registered in accordance with the legislation of its jurisdiction, and the person acting on its behalf has the necessary powers confirmed by documents; the Client is not included in and is not associated with persons included in sanctions lists (of the UN Security Council, OFAC (USA), the European Union, authorized bodies of the Republic of Kazakhstan); the sources of the money and digital assets used by the Client are lawful; the use of the services does not contradict the legislation of the country of the Client's residence (for non-residents of the Republic of Kazakhstan).

5.4. The Operator has the right to conduct Enhanced Due Diligence of the Client and to request additional information about their activities, assets and sources of funds in accordance with the Company's AML/KYC Policy.

5.5. The Client's operation limits are established in accordance with paragraphs 53-56 of Rules No. 45 and the Company's AML/KYC Policy: for Clients who have not confirmed sufficient qualification based on the results of the questionnaire (test) — no more than 5,000,000 (five million) tenge per day for each direction of operations (purchase and sale separately); for qualified Clients, operations are carried out without the said limits. Other limits (country, transaction, etc.) may be established by the Company's Rules and the AML/KYC Policy.

6. The Client's account

6.1. To obtain access to the services, the Client creates and maintains an account (hereinafter the "Account"). The Operator has the right to refuse to create an Account on the grounds provided for by the Company's AML/KYC Policy and the legislation of the Republic of Kazakhstan.

6.2. The Client is responsible for the actions performed in their Account using their access identifiers, until the moment the Operator receives the Client's notification of a compromise of access.

6.3. Before obtaining access to the services, the Client undergoes the verification procedure, providing accurate and complete information. If such information changes, the Client immediately notifies the Operator.

6.4. The Client authorizes the Operator to send requests to third parties to the extent necessary for the verification of the Client and compliance with the requirements of AML/CFT/CPF, in the manner established by the Company's AML/KYC Policy and the Company's Personal Data Processing and Protection Policy.

6.5. The Operator stores the personal data and information about the Client's operations for at least 5 (five) years from the date of termination of the business relationship or from the date of the operation, in accordance with the AML/CFT/CPF Law and the Company's Personal Data Processing and Protection Policy.

6.6. The Operator has the right to change the parameters of access to the Account and the limits of Operations on the basis of an analysis of information about the Client. In the event of reasonable suspicions of the inaccuracy of the data, the Operator requests its updating; failure to fulfil such a request within the established period is a ground for suspending access to the Account in the manner provided for by the Company's AML/KYC Policy.

6.7. Access to the Account is carried out through the Platform using the access identifiers issued by the Operator; the Operator has the right to require the use of multi-factor authentication.

6.8. The transfer of access to the Account to third parties is not permitted and is a material breach of the Agreement, except in the cases provided for by the legislation of the Republic of Kazakhstan.

6.9. The Client is obliged to notify the Operator of detected unauthorized operations in the Account immediately, no later than 2 (two) hours from the moment of detection.

6.10. An Instruction sent using the Client's access identifiers is deemed authorized by the Client until the moment the Operator receives the Client's notification to the contrary; the Operator is not liable for operations carried out before the receipt of such notification, if the Operator has not violated its own security protocols.

6.11. The Operator has the right to record communications with the Client (correspondence in the personal account, email, telephone requests) for the purposes of quality control of service, compliance with legislation and consideration of requests, in accordance with the Company's Personal Data Processing and Protection Policy. Such records may be used by the Parties as evidence of the content of messages, which does not replace the procedure for recording the Operation itself established by the Payment Procedure.

7. Transaction limits

7.1. The Client's Operation limits are established in accordance with section 5 of this Agreement, Rules No. 45, the Company's Rules and the Company's AML/KYC Policy, including by the number, aggregate volume and frequency of Operations. The current limits are displayed in the Client's personal account.

7.2. The Operator has the right to change the limits applicable to the Client's Account by virtue of regulatory requirements or on the basis of an assessment of the Client's risk in accordance with the Company's AML/KYC Policy. An increase in limits for the Client is possible after successful completion of the qualification testing provided for by paragraphs 53-56 of Rules No. 45.

8. Digital assets

8.1. The services are provided solely in respect of unbacked digital assets, the list of which is established by paragraph 57 of Rules No. 45 and published on the Operator's website. The Operator has the right to suspend the servicing of individual assets in the absence of liquidity or technical readiness, with notification of Clients through the personal account and the website, in accordance with the Company's Rules. Expanding the list beyond that established by the National Bank of the Republic of Kazakhstan is not permitted.

8.2. The Operator does not carry out operations with digital assets using anonymization technologies (mixers, tumblers, "privacy coins"), as well as with assets having a confirmed connection with unlawful activity, in accordance with the Company's AML/KYC Policy.

9. Account security

9.1. The Client independently ensures the protection of their equipment and data from malicious software and is responsible for the confidentiality of their access identifiers (password, two-factor authentication codes).

9.2. The Operator does not request the Client's passwords and two-factor authentication codes under any circumstances.

9.3. If a compromise of the Account is suspected, the Client is obliged to immediately notify the Operator and, where technically possible, to block the Account through the Platform's functionality.

9.4. The Operator has the right to disclose information about a security incident to the competent authorities of the Republic of Kazakhstan in the manner established by the legislation of the Republic of Kazakhstan.

10. Exchange rates and the procedure for the formation of the Operator's income

10.1. The Operator carries out Operations at the purchase rates and sale rates of unbacked digital assets established by the Operator independently and published on the Operator's website. The Operator's income from Operations is formed solely from the difference between the purchase rate and the sale rate of the unbacked digital asset (the rate difference). No separate remuneration (commission, service fee) in excess of the rate difference is charged by the Operator from the Client.

10.2. The rate offered by the Operator for a specific Operation already includes the Operator's rate difference; the final rate and amount of the Operation are disclosed to the Client before confirmation of the Operation in the manner established by the Payment Procedure.

10.3. The Operator has the right to revise the purchase and sale rates unilaterally; the new rates apply to Operations initiated after their publication on the website.

11. Large Operations

11.1. The provisions of this section apply to Operations for the purchase and sale of unbacked digital assets in an amount exceeding 40,000,000 (forty million) tenge and, for Operations in foreign currency, in an amount whose tenge equivalent, at the rate applied by the Operator at the time the Operation is confirmed, exceeds 40,000,000 (forty million) tenge (hereinafter a "Large Operation"). In respect of Large Operations, the provisions of this section take precedence over the other provisions of the Agreement and the Payment Procedure, except for the grounds, provided for by paragraph 3.5 of this Agreement, on which an Operation is not executed or its execution is suspended.

11.2. The rate for a Large Operation fixed in accordance with paragraph 3.4 of this Agreement is valid for 2 (two) hours from the moment the Client confirms the parameters of the Operation on the Platform. If the Client's money or digital assets are received after the expiry of this period, the procedure established by the Payment Procedure for payment received outside the validity period of the fixed rate applies.

11.3. The Operator executes a Large Operation, as a rule, on the day on which the Operator has received the Client's money or digital assets in the manner provided for by the Payment Procedure and has completed the verification of the Operation in accordance with the Company's AML/KYC Policy (hereinafter "day T"), and no later than the end of the first business day following day T (hereinafter "day T+1"). A day that is not a day off or a public holiday in the Republic of Kazakhstan is recognized as a business day.

11.4. If on day T the Operator has insufficient liquidity to execute a Large Operation in full, the Operator has the right to postpone its execution to day T+1, notifying the Client thereof.

11.5. A Large Operation whose execution has been postponed to day T+1 is executed at the rate established by the Operator in accordance with section 10 of this Agreement as at the time of execution, taking into account the terms individually agreed with the Client (if any); paragraph 10.3 of this Agreement does not apply in this case. The amount due to the Client is recalculated at such rate; the Operator informs the Client of the final rate and amount when they are determined.

11.6. The Client expresses consent to the procedure established by paragraphs 11.4 and 11.5 of this Agreement separately upon the creation of each Large Operation by ticking a box on the Platform; a Large Operation is not created without such a tick. The Operator records the fact that the box was ticked, the date and time, the version of the consent text and the IP address from which the box was ticked.

11.7. Until the Operator determines the execution rate of a Large Operation postponed to day T+1, the Client has the right to cancel it in the Personal Account. In this case, as well as if a Large Operation has not been executed by the end of day T+1, the Operator returns to the Client, in full, the money or digital assets received, without withholding any commissions or other expenses, within 2 (two) business days in the manner established by the Refund Policy.

11.8. The Operator posts notifications on Large Operations in the Personal Account and sends them to the email address specified by the Client upon registration. A notification is deemed received by the Client from the moment it is posted in the Personal Account.

12. Closing the Account

12.1. The Client has the right to initiate the closing of their Account at any time in the absence of outstanding obligations to the Operator and unfinished Operations.

12.2. The Operator has the right to refuse to close the Account where there are unfinished Operations, open disputes, an outstanding debt of the Client to the Operator or measures to freeze funds applied in accordance with the legislation of the Republic of Kazakhstan on AML/CFT/CPF.

12.3. In the absence of activity in the Account for 12 (twelve) consecutive calendar months, the Operator sends the Client a notification to the contact details specified by them with a proposal to confirm the intention to keep the Account or to dispose of the balance of digital assets and money. If, within 30 (thirty) calendar days from the moment of sending the notification, the Client does not respond, the Operator takes additional reasonable measures to contact the Client through the communication channels known to the Operator; the procedure for the Operator's further actions in respect of such an Account is established by a separate internal act of the Company, approved in accordance with the legislation of the Republic of Kazakhstan. The Operator does not carry out a forced conversion of the Client's digital assets into other types of assets and does not transfer them to custodial storage with third parties otherwise than on the grounds directly provided for by the legislation of the Republic of Kazakhstan.

12.4. The Operator has the right to suspend access to the Account, refuse to carry out Operations or cease the provision of services to the Client where there are grounds provided for by the Company's AML/KYC Policy, the Payment Procedure, a requirement of an authorized state body or a court, as well as in the event of the Client's violation of the terms of this Agreement. The Operator notifies the Client of the grounds for such a decision to the extent not contrary to the requirements of the legislation of the Republic of Kazakhstan on AML/CFT/CPF.

12.5. Where the Operator has reasonable information that the assets in the Client's Account were obtained unlawfully, the Operator acts in the manner established by the Company's AML/KYC Policy and the legislation of the Republic of Kazakhstan, including the suspension of operations and informing the authorized body.

13. Intellectual property

13.1. All intellectual property belonging to the Operator, including software, trademarks and the content of the Platform, remains the exclusive property of the Operator.

13.2. The Operator grants the Client a non-exclusive royalty-free license to use the Platform solely for the purposes of obtaining services under this Agreement. Commercial use of the Platform without the written consent of the Operator is not permitted.

13.3. Materials posted by the Client on the Platform (where such a function is available) are used by the Operator to the extent necessary for the provision of services; the Operator is not liable for the content of such materials.

14. Prohibited use

14.1. The Client is prohibited from: violating the terms of this Agreement; using the services for purposes that harm the legitimate interests of third parties; using the Platform for commercial purposes or for operations in the interests of third parties without the written consent of the Operator; performing actions aimed at price manipulation (wash-trading, pump-and-dump, spoofing and similar schemes); providing inaccurate information; obtaining unauthorized access to the Operator's systems; using automated means to access the Platform without the Operator's consent; using the services in jurisdictions and by persons included in the sanctions lists specified in section 5 of this Agreement; transferring access to the Account or carrying out operations in the interests of third parties (money muling).

14.2. The Client represents that the information provided by them is accurate and up to date, that Operations are carried out on the basis of their independent risk assessment, and that the Client's activity complies with the legislation of the Republic of Kazakhstan and the legislation of the country of their residence.

15. Liability of the Parties

15.1. The Client reimburses the Operator for documented direct losses incurred as a result of the Client's violation of this Agreement or the legislation of the Republic of Kazakhstan.

15.2. The Operator's liability to the Client is limited to the amount of the direct damage actually caused to the Client that arose through the Operator's fault and does not include lost profits, except in cases of wilful misconduct, gross negligence or fraud on the part of the Operator or cases where the legislation of the Republic of Kazakhstan does not permit such a limitation.

15.3. The Operator is not liable for: the materialization of the risks specified in the Risk Warning; the specifics of the operation of the protocols underlying digital assets; changes in the value of digital assets; the actions and decisions of banks, payment systems, blockchain networks and other third parties not under the Operator's control; carrying out scheduled or emergency maintenance in compliance with the procedure for notifying Clients.

15.4. Nothing in this section releases the Operator from liability in cases where such release is not permitted by the mandatory provisions of the legislation of the Republic of Kazakhstan, including the legislation on the protection of consumer rights.

15.5. The Parties are liable for the disclosure of confidential information in accordance with the legislation of the Republic of Kazakhstan and section 17 of this Agreement.

16. Protection of personal data

16.1. The Operator carries out the collection, processing, storage and cross-border transfer of the Client's personal data for the purposes of performing this Agreement and complying with the legislation of the Republic of Kazakhstan in the manner established by the Company's Personal Data Processing and Protection Policy.

16.2. The Client guarantees that the personal data of third parties provided by them to the Operator (if any) has been obtained in compliance with the legislation of the Republic of Kazakhstan and with the consent of the relevant subjects. Upon the Operator's request, the Client provides confirmation of the existence of such consent within 3 (three) business days.

17. Confidentiality

17.1. The Parties undertake not to disclose to third parties confidential information obtained in the course of performing the Agreement (information about the volumes of Operations, tariff and pricing policy), except in the cases provided for by the legislation of the Republic of Kazakhstan, and to persons authorized by the Parties to receive such information in connection with the performance of the Agreement.

17.2. The fact of the conclusion of the Agreement and its subject are not confidential information.

17.3. The confidentiality obligations remain in force for 3 (three) years from the date of termination of the Agreement.

18. Force majeure circumstances

18.1. The Parties are not liable for the non-performance of obligations under the Agreement if it was the result of force majeure circumstances (fire, flood, earthquake and other natural phenomena), as well as decisions of state bodies, if such circumstances were beyond the will of the Parties and made the performance of obligations impossible.

18.2. The period for the performance of obligations is extended in proportion to the duration of the force majeure circumstances. The Party for which such circumstances have arisen notifies the other Party in writing within 10 (ten) calendar days from the moment of their occurrence or cessation.

18.3. If the force majeure circumstances last for more than 2 (two) calendar months, each of the Parties has the right to terminate the Agreement, notifying the other Party in writing no later than 10 (ten) calendar days before the intended date of termination.

19. Term of the Agreement. Procedure for amendment and termination

19.1. The Agreement enters into force from the date of acceptance of its terms by the Client and is valid indefinitely until its termination in the manner established by this section.

19.2. The Client has the right to terminate the Agreement unilaterally at any time by sending the Operator a notification through the Personal Account or in another manner established by the Payment Procedure, subject to the absence of outstanding obligations to the Operator and unfinished Operations, as well as payment to the Operator of the expenses actually incurred by it in connection with the performance of the Agreement (if any), in accordance with paragraph 1 of Article 686 of the Civil Code of the Republic of Kazakhstan.

19.3. The Operator has the right to terminate the Agreement unilaterally on grounds not related to the circumstances specified in paragraph 19.4 of this Agreement, by notifying the Client in writing at least 30 (thirty) calendar days in advance, subject to full reimbursement to the Client of documented losses directly caused by such termination, in accordance with paragraph 2 of Article 686 of the Civil Code of the Republic of Kazakhstan, and the conduct by the Parties of mutual settlements within a period of no more than 10 (ten) calendar days from the moment of sending the notification.

19.4. The Operator has the right to terminate the Agreement immediately, without observing the notice period provided for by paragraph 19.3 of this Agreement, and without the obligation to reimburse the Client for losses, since the relevant circumstances fall within the Client's area of responsibility and are equated to the fault of the customer within the meaning of paragraph 2 of Article 686 of the Civil Code of the Republic of Kazakhstan, in the cases provided for by section 12 of this Agreement, including grounds related to the legislation of the Republic of Kazakhstan on AML/CFT/CPF, the inaccuracy of the Client's representations provided for by paragraph 5.3 of this Agreement, or the inclusion of the Client in the sanctions lists specified in section 5 of this Agreement.

19.5. Upon termination of the License (including its revocation, suspension or expiry), the Operator notifies Clients of the cessation of the provision of services within the period established by the legislation of the Republic of Kazakhstan and fulfils its obligations to Clients in accordance with the concluded agreements and the legislation of the Republic of Kazakhstan. In this case, the Agreement is terminated due to the objective impossibility of performance in accordance with Article 374 of the Civil Code of the Republic of Kazakhstan, without the Operator's obligation to reimburse losses caused by such termination.

20. Dispute resolution procedure

20.1. Disputes arising in connection with the performance of the Agreement are resolved out of court through negotiations. A claim is considered by the receiving Party within 30 (thirty) calendar days from the day of receipt, unless another period is established by sections 8 and 12 of the Company's Policy on refunds of funds, digital assets and compensation for damages (procedure for applying and appealing a refusal).

20.2. If it is impossible to resolve the dispute through negotiations, the dispute is subject to resolution in the competent court of the Republic of Kazakhstan at the location of the Operator in accordance with the legislation of the Republic of Kazakhstan.

20.3. The legislation of the Republic of Kazakhstan applies to this Agreement and to the relations of the Parties.

21. Miscellaneous provisions

21.1. The Client undertakes to comply with the legislation of the Republic of Kazakhstan, including the legislation on the protection of personal data, on AML/CFT/CPF, tax and currency legislation, when using the Operator's services.

21.2. Official messages are sent to the Client at the email address specified upon registration; the Client is responsible for the currency of the specified contact details.

21.3. The recognition of an individual provision of the Agreement as invalid does not affect the validity of the remaining provisions of the Agreement.

21.4. The Client is not entitled to transfer their rights and obligations under the Agreement to third parties without the written consent of the Operator. The Operator has the right to assign its rights and obligations under the Agreement in cases of reorganization not contrary to the legislation of the Republic of Kazakhstan, with notification of Clients in the manner established by section 4 of this Agreement.

21.5. The provisions on confidentiality, intellectual property and liability remain in force after the termination of the Agreement to the extent necessary for their purpose.

21.6. The Operator does not act as an agent, partner, trustee or fiduciary manager of the Client; no fiduciary duties arise between the Parties.

21.7. The Client is independently responsible for the fulfilment of tax obligations and the requirements of the currency legislation of the Republic of Kazakhstan arising in connection with their Operations, in accordance with section 2 of the Company's Risk Warning. The Operator is not a tax or currency advisor of the Client but has the right to provide reports to authorized bodies in the cases provided for by the legislation of the Republic of Kazakhstan.

22. Terms and definitions used in the Agreement

Account

an account opened by the Operator for the Client for the purpose of recording their use of the Operator's services.

Access identifiers

login, password, two-factor authentication codes and other authentication means used by the Client to access the Account and submit Instructions.

Large Operation

an Operation in an amount exceeding 40,000,000 (forty million) tenge or the equivalent of this amount in foreign currency, the procedure for the execution of which is established by section 11 of this Agreement.

Platform

the website, mobile application, personal account and other channels for providing services approved by the Operator.

Payment Procedure

a document of the Company establishing the methods, procedure and deadlines for paying for Operations, posted on the Operator's website.

Risk Warning

a document disclosing the risks of operations with digital assets, approved by the Operator and posted on the website.

Sanctions lists

lists of persons involved in terrorist activity and the financing of the proliferation of weapons of mass destruction, formed by the authorized bodies of the Republic of Kazakhstan, as well as the lists of the UN Security Council, OFAC (USA), the European Union and other authorized bodies.

Instruction

an order, request or instruction transmitted by the Client to the Operator for the execution of an Operation.

Unbacked digital asset

a digital asset that is not a digital financial asset, operations with which the Operator has the right to carry out in accordance with the License and the list established by paragraph 57 of Rules No. 45.

AML/KYC Policy

the policy of customer due diligence and combating the legalization (laundering) of proceeds of crime, the financing of terrorism and the financing of the proliferation of weapons of mass destruction, approved by the Operator and posted on the website.

Personal Data Processing and Protection Policy

a document of the Company establishing the procedure for the collection, processing, storage and cross-border transfer of the Client's personal data, approved by the Operator and posted on the website.

Refund Policy

the Company's Policy on refunds of funds, digital assets and compensation for damages — a document of the Company establishing the procedure for the Client to submit a claim, the procedure for its consideration and the procedure for calculating the compensation for damage caused to the Client through the Operator's fault, approved by the Operator and posted on the website.

Company's Rules

the Rules for carrying out the Operator's activity, approved by the management body of the Operator in accordance with paragraph 23 of Rules No. 45, posted on the Operator's website.

23. Details of the Operator

Full name

Pax Finance Limited Liability Partnership

Short name

Pax Finance LLP

BIN

260540020321

Director

Beispekov Aslan Galimovich

Basis of activity

License No. 0126001O dated 30 June 2026, issued by the National Bank of the Republic of Kazakhstan

Registered address

010000, Republic of Kazakhstan, Astana, Nura district, Kabanbay Batyr Avenue, 47/2, non-residential premises 2

Website

https://paxfinance.kz

Phone

+7 777 992 1113

Email

info@paxfinance.kz

Effective date: 06.11.2026 Version: 2.2