PaxFinance

Policy on Refunds of Funds, Digital Assets and Compensation for Damages

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

POLICY

on refunds of funds, digital assets

and compensation for damages

Public version for clients Version 1.0

APPROVED

by order of the Director of Pax Finance LLP

Beispekov Aslan Galimovich

No. 6 dated 10 July 2026

1. General provisions

1.1. This Policy on refunds of funds, digital assets and compensation for damages (hereinafter the "Policy") has been developed by Pax Finance LLP, BIN 260540020321 (hereinafter the "Company", the "Operator"), 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, issued by the National Bank of the Republic of Kazakhstan.

1.2. This Policy is the public (client) version of Section 8 "Refund of money, digital assets and compensation for damages" of the Rules for carrying out the activities of the operator for the exchange of unbacked digital assets of the Company (hereinafter the "Rules"), approved in accordance with paragraph 23 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"), and fully complies with the terms, deadlines and grounds established by Section 8 of the Rules.

1.3. This Policy has been developed taking into account the Civil Code of the Republic of Kazakhstan, the Law of the Republic of Kazakhstan "On Protection of Consumer Rights", the Law of the Republic of Kazakhstan "On Payments and Payment Systems" and other applicable legislation of the Republic of Kazakhstan.

1.4. This Policy applies jointly with the User Agreement, the Risk Warning and the Company's Procedure for Handling Complaints and Resolving Disputes and is an integral part thereof.

1.5. The Client's use of the Company's services constitutes the Client's agreement to the terms of this Policy.

1.6. Nothing in this Policy limits or may be construed as limiting the mandatory rights of the Client as a consumer established by the legislation of the Republic of Kazakhstan, including the Law of the Republic of Kazakhstan "On Protection of Consumer Rights". If a particular provision of this Policy establishes less favourable terms for the Client than the mandatory provisions of the legislation of the Republic of Kazakhstan, the provisions of the legislation of the Republic of Kazakhstan shall apply.

2. Principle of irrevocability of executed operations

2.1. The Client's orders to purchase and (or) sell unbacked digital assets are executed by the Company in accordance with the Rules. After the Client confirms the parameters of the operation (rate, amount, direction of exchange, details) and the Company actually executes the operation, such operation is deemed to have been duly executed and is not subject to cancellation at the Client's initiative, except in the cases expressly provided for by section 3 of this Policy.

2.2. Operations with digital assets recorded in the relevant blockchain network are irreversible. This Policy does not and cannot provide for the cancellation or return of a digital asset transferred to a wallet address correctly specified by the Client.

3. Cases of refund of funds

3.1. A refund of funds is made by the Company in the following cases:

  • a technical failure or error of the Company's system that made it impossible to execute the operation;
  • an error by a Company employee in processing the order or in executing the operation;
  • insufficient liquidity where the Company cannot execute the operation within the established period;
  • a significant change in the rate, where the Client refused to have the order executed;
  • the Company's refusal of service on grounds not related to the Client's fault;
  • a failure of the banking system that made settlements impossible, if the Company has already withheld the Client's money;
  • other cases where the Client lawfully withdrew the order before its execution.

4. Cases of return of digital assets

4.1. A return of digital assets is made by the Company in the following cases:

  • a technical failure that made it impossible to pay out money when the Client sells digital assets;
  • an error by the Company in processing a sale order;
  • the Company's refusal of service on grounds not related to the Client's fault, after the assets have arrived at the Company's wallet;
  • cancellation of the order before execution at the initiative of the Client or the Company where there are no legal restrictions.

5. Cases in which a refund is not made or is suspended

5.1. A refund is impossible or is suspended in the following cases:

  • the assets or money are frozen on the grounds provided for by the Law of the Republic of Kazakhstan "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 Company has sent a report to the authorized financial monitoring body and has received a prohibition on carrying out the operation;
  • the assets did not arrive at the Company's wallet due to the Client's error (incorrect network, incorrect address);
  • the refund contradicts the requirements of the legislation of the Republic of Kazakhstan or results in the application of sanctions.

These grounds are mandatory and cannot be changed by an individual agreement with the Client.

6. Who decides on the refund

6.1. The decision on a refund is made by:

  • an operations specialist of the Company - in the case of an obvious technical failure confirmed by the internal log of technical failures;
  • the officer responsible for AML/CFT/CPF - where there are signs of legalization of proceeds, financing of terrorism, sanctions risk or a suspicious operation;
  • the director of the Company - where the refund amount exceeds the threshold value established by an internal order of the Company, or in a disputed situation.

7. Deadlines for consideration and execution

7.1. Consideration of the Client's request for a refund or compensation is carried out by the Company within no more than 5 (five) business days from the date of registration of the request.

7.2. A refund of funds is made within no more than 2 (two) business days from the moment the decision on the refund is made.

7.3. A return of digital assets is made within no more than 2 (two) business days from the moment the decision on the return is made.

7.4. If making a decision requires additional verification under the AML/CFT/CPF Law or waiting for a response from an authorized body, the refund period is suspended for the duration of such verification. In the absence of a requirement from an authorized body, the internal verification is completed no later than 30 (thirty) business days. The Client is notified of the reason for the delay in general terms without disclosing grounds related to AML/CFT/CPF.

7.5. A refund request that does not require additional investigation (paragraph 7.1) is considered within up to 5 (five) business days. If the Client's request is qualified by the Company as a complaint requiring investigation (including one related to a refund, compensation, delay of an operation or an alleged error of the Company), a period of up to 30 (thirty) business days applies to its consideration in the manner established by the Company's Procedure for Handling Complaints and Resolving Disputes (paragraph 17.2.2(2) of the Rules), with mandatory notification of the Client of the extension of the period no later than the 10th business day.

7.6. Regardless of which of the tracks specified in paragraph 7.5 was used to consider the request, a decision providing for a refund or compensation is executed within the periods specified in paragraphs 7.2-7.3 of this Policy. This rule is expressly established by paragraph 17.2.4 of the Rules and does not allow for any other interpretation.

8. Procedure for the Client's request

8.1. The Client submits a refund request in one of the following ways:

  • through the form in the Client's personal account;
  • to the Company's official email: info@paxfinance.kz;
  • by written request to the Company's registered address: 010000, Republic of Kazakhstan, Astana, Nura district, Kabanbay Batyr Avenue, 47/2, non-residential premises 2;
  • through a physical branch of the Company (if any).

8.2. The request is registered in the complaints/refunds log with a number assigned. Confirmation of registration is sent to the Client within 1 (one) business day.

8.3. When submitting a refund request, the Client provides (as applicable):

  • the order or operation identifier;
  • confirmation of the transfer of funds (payment order, statement);
  • the blockchain transaction hash and the sending wallet address - for digital assets;
  • bank details for the refund of funds;
  • other documents upon the Company's reasoned request.

9. Calculation of the refund amount

9.1. The amount of the refund of funds is calculated as the amount actually received to the Company's account. The exchange rate difference withheld by the Company is returned to the Client if the operation was not executed through the Company's fault.

9.2. The amount of the return of digital assets is calculated as the quantity of assets actually received to the Company's wallet.

10. Compensation for damages

10.1. Grounds for payment of compensation (fault of the Company)

Compensation for damages is paid by the Company in the following cases:

  • a technical failure of the Company's system not related to external factors that caused the Client financial losses;
  • an error by a Company employee in executing the operation;
  • the Company's violation of the established period for executing the operation without legal grounds for the delay;
  • sending digital assets to the Client in an incorrect quantity through the Company's fault;
  • other cases where the damage arose directly through the Company's fault in the provision of services.

10.2. Amount of compensation

The amount of compensation is determined on the basis of the damage actually caused to the Client that arose through the Company's fault in the provision of services. Compensation does not include lost profits, unless otherwise established by a decision of the Company's director or by a court.

10.3. Cases where compensation is not paid (no fault of the Company)

  • a change in the rate of an unbacked digital asset during the period of execution of the operation;
  • a failure of the blockchain network;
  • a failure of the banking system;
  • an error by the Client in specifying the wallet address or the blockchain network;
  • suspension of the operation at the request of authorized bodies of the Republic of Kazakhstan or under the AML/CFT/CPF Law;
  • the Client's loss of access to their digital asset wallet;
  • compromise of access to the personal account through the Client's fault.

11. Method and currency of executing the refund

This section describes the Company's current operational practice for the technical execution of a refund within the periods established by section 7. It does not form part of Section 8 of the Rules, does not establish additional grounds for refusing or delaying a refund and may not be construed as limiting the Client's rights provided for by sections 3-10 of this Policy, Section 8 of the Rules or the legislation of the Republic of Kazakhstan. The procedure in this section may be clarified depending on the requirements of the specific acquiring bank or payment system involved in the settlements.

11.1. As a general rule, a refund of funds is made to the same payment instrument (bank account, bank card) from which the original payment was made, except in cases where this is technically impossible for reasons dependent on the issuing bank or the payment system, or where the legislation of the Republic of Kazakhstan or the agreement of the Parties provides for another method.

11.2. As a general rule, a refund of funds is made in the same currency in which the original payment was made. Exchange rate differences arising solely from conversion on the side of the Client's issuing bank (outside the Company's control) are not subject to reimbursement by the Company; this does not affect the Client's right to compensation for damages under section 10 if such losses arose through the Company's fault.

11.3. A return of digital assets is made to the digital asset wallet from which they were received by the Company.

11.4. By this paragraph, the Company voluntarily establishes the procedure for refunding funds to Clients who are non-residents of the Republic of Kazakhstan. This procedure is not based on a direct requirement of the National Bank of the Republic of Kazakhstan or the Rules and is an internal policy of the Company applied by virtue of the general principles of the civil legislation of the Republic of Kazakhstan on the good-faith performance of obligations.

11.5. A refund of funds to a Client who is a non-resident of the Republic of Kazakhstan who previously paid an amount in foreign currency by means of an international bank transfer (SWIFT) is made to the same account in the same currency within a period not exceeding the periods established by paragraphs 7.2-7.3 of this Policy, taking into account the time for processing the transfer by the correspondent banks involved in the settlements, which is outside the Company's control and is not counted towards the Company's refund execution period.

11.6. The fees of correspondent banks and of the recipient bank withheld during the international transfer of the refunded amount are not reimbursed by the Company, except in cases where the withholding of such fees is caused by the Company's violation of the procedure for drawing up the payment order.

11.7. A return of digital assets to a non-resident Client is carried out in the general manner provided for by section 4 of this Policy, regardless of the Client's residence, since the execution of operations with digital assets does not depend on the currency and banking regulation applicable to money transfers.

12. Documenting decisions and appealing a refusal

12.1. The Company's decision on a refund or compensation is drawn up in writing (or recorded in the Company's information system) indicating the grounds, the amount, the responsible person, the date and the method of execution. The decision is kept in the refunds log for at least 5 (five) years.

12.2. In the event of a refusal of a refund or compensation, the Company notifies the Client indicating the justification for the refusal within 5 (five) business days.

12.3. A Client who disagrees with the Company's decision has the right to: re-apply to the director of the Company; send a complaint to the National Bank of the Republic of Kazakhstan; apply to a court of the Republic of Kazakhstan in the manner provided for by the legislation of the Republic of Kazakhstan.

13. Final provisions

13.1. The Company has the right to unilaterally amend this Policy in connection with changes in the legislation of the Republic of Kazakhstan, the requirements of the National Bank or a change in Section 8 of the Rules. In the event of a conflict between this Policy and Section 8 of the Rules, the provisions of Section 8 of the Rules shall apply.

13.2. The current version of the Policy is posted on the Company's official website https://paxfinance.kz and enters into force from the moment of publication, unless another date is specified in the new version.

14. Details and contact information of the Company

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: 20.07.2026 Version: 1.0