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Trek Labs Europe Ltd. dba Backpack EU

RISK DISCLOSURE POLICY

1. Introduction

Backpack EU is a brand name owned and operated by Trek Labs Europe Ltd (formerly FTX EU and FTX EU Ltd, respectively) (hereinafter referred to as the “Company,” “Backpack EU,” “us,” or “we”), a company incorporated in Cyprus with registration number HE 335683 and authorised by the Cyprus Securities and Exchange Commission (“CySEC”) under license no. 273/15, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus.

This risk disclosure document provides a general overview of the main financial products offered by the Company and their associated risks and is provided to you (our Client or prospective Client) in compliance with the Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law87(I)/2017,Directive 2004/39/EC of the European Parliament and of the Council of 21 April 2004 on markets in financial instruments amending Council Directives 85/611/EEC and 93/6/EEC and Directive 2000/12/EC of the European Parliament and of the Council and repealing Council Directive 93/22/EEC, as subsequently amended from time to time which is applicable to the Company.

All Clients and prospective Clients should read carefully the following risk disclosure before applying to the Company for a Client Account and before they begin to trade with the Company. However, it is noted that this document cannot and does not disclose or explain all of the risks and other significant aspects which the Client should take into account in relation to a particular investment in Financial Instrument (FI). It is intended to give the Client information on and a warning of the risks associated with FIs so that the

Client is reasonably able to understand the nature and risks of the services and of the specific types of Financial Instruments being offered and, consequently, to take investment decisions on an informed basis.

This Risk Disclosure forms part of the Client’s agreement with the Company and therefore by entering into an agreement with the Company you also agree to the terms of this Risk Disclosure, as set out in this document.

2. Acknowledgement

Clients are ultimately responsible for all of the losses suffered in their account. As a consequence, Clients should be prepared to lose all funds which they deposited. Clients are also responsible for losses that exceed their profits and deposits. Clients should never fund their trading activities with retirement savings, loans, mortgages, emergency funds, funds set aside for purposes such as education or home ownership, or funds required for current income or present or future medical expenses. Derivative Financial Instruments are complex products and are not suitable for all investors. Prior to trading, you are responsible to acknowledge and understand the risk associated with Derivative Financial Instruments and in the event, you do not understand them you should seek advice from a professional and independent financial advisor.

3. Risk warning

You fully understand and agree that the company cannot guarantee the initial capital that has been invested in Instruments or the value of your portfolio. In addition, regardless of any information that has been offered to you by the company, the value of any investment Instruments may fluctuate downwards or upwards and there is always a possibility that the entire investment will not carry any value.

You are fully aware that trading carries a high level of risk and more specifically the possibility of losing all of your invested funds. Therefore, trading may not be suitable for you. You should not engage in any investment directly or indirectly in Financial Instruments unless you know and understand the risks involved for each one of the Financial Instruments offered by the Company.

Prior to applying for and opening an account with the Company you should consider carefully whether investing in a specific Financial Instrument is suitable for you in the light of your personal circumstances and financial resources. In addition, as a client you should not invest money that you cannot afford to lose. Prior to trading, you are responsible to acknowledge and understand the risk associated with it. In the event, you do not understand them, you should seek advice from a professional and independent financial advisor. We do not offer investment advice.

You understand that trading in derivatives does not lead to ownership of the underlying instrument. Derivatives are complex products and are not suitable for all investors. Before trading, you should ensure that you fully understand the risks and costs involved. You should have extensive experience of trading in volatile markets as well as sufficient time to manage your investment on an active basis. If necessary, seek independent advice.

Trading derivatives can be utilized for the management of investment risk, some of these products are unsuitable and not appropriate for many clients as they carry a high degree of risk.

You acknowledge and accept the following:

• You fully understand and agree that the Company cannot guarantee the initial capital that has been invested in Financial instruments or the value of your portfolio. In addition, regardless of any information that has been offered to you by the Company, the value of any investment in Financial Instruments may fluctuate downwards or upwards and there is always a possibility that the entire investment will not carry any value.

• Information of the previous performance of an Instrument does not necessarily guarantee its current and/or future performance. The use of historical data does not constitute a binding or safe forecast as to the corresponding future performance of the Instrument to which the said information refers.

• Some Instruments may not become immediately liquid as a result, for example, of reduced demand and the Client may not be in a position to sell them or easily obtain information on the value of these Instruments or the extent of the associated risks.

• When an Instrument is traded in a currency other than the currency of the Client's country of residence, any changes in the exchange rate may have a negative effect on its value, price and performance.

• An Instrument on foreign markets may entail risks different to the usual risks of the markets in the Client's country of residence. In some cases, these risks may be greater. The prospect of profit or loss from transactions on foreign markets is also affected by exchange rate fluctuations.

• A Derivative Instrument (i.e. option, future, forward, swap, contract for difference) may be a non-delivery spot transaction giving an opportunity to make profit on changes in the underlying asset (currency rates, commodity, stock market indices or share prices) though you do not own the underlying asset.

• The value of the derivative Instrument may be directly affected by the price of the security or any other underlying asset which is the object of the transaction.

• The Client must not purchase a derivative Instrument unless he is willing to undertake the risks of losing entirely all the money which he has invested and also any additional commission and other expenses incurred.

• The value of the Instrument may decrease and the client may receive less money than originally invested or the value of the Instruments may present high fluctuations.

• The Client acknowledges and accepts that irrespective of what type of order they place with the Company under certain circumstances including but not limited the ones mentioned on our Order Execution Policy found on the Company’s Website may not be possible to be executed at all and any stop loss orders or orders with similar effect might not be able to reduce the Client losses and even though the Client placed a stop loss or a similar type of order they still run the risk of losing their entire investment.

• The Company is not responsible for any trading failure and not liable for any damage, cost or expenses the Client incurs caused directly or indirectly by malfunction and / or disruption and /or failure of its trading platform and website. The Company does not accept any liability if such events occurred.

• The Company has no responsibility in relation to your access to the Company’s website, and/or the Company’s trading platform if the internet is subject to events which may affect such access, including but not limited to internet disconnection, public electricity network failures, interruptions or transmission blackouts, or software and hardware failures. The Company shall not be responsible for any damages or losses resulting from such events which are beyond its control or for any other losses, costs, liabilities or expenses which may result from your inability to access the Company’s website and/ or trading platform or delay or failure in sending orders or transactions.

• The Client acknowledges and accepts that there may be other risks which are not contained above.

4. Instruments related to virtual Currencies

Virtual Currencies' values can widely fluctuate (high volatility) and may result in significant gain or loss over a short period of time. This applies to a derivative instrument with Virtual Currencies as underlying in the same manner. These products are not appropriate for all investors and you should not trade it, if you don't have the necessary knowledge and expertise, moreover be fully aware and understand the specific characteristics and risks of these products. Due to the high risks involved in the trading of CFDs on virtual currencies you are faced with a high risk of losing all of your invested capital. Furthermore, trading in such products you are not entitled to any protection under the Investors Compensation Fund and, in case of a dispute with the Company, you have no right to report to the Cyprus Financial Ombudsman.

5. Knowledge of our Trading Platform

Clients must be knowledgeable in the use and functionality of the trading platform provided by the Company or by any third-party provider, in order to correctly interpret account information and to be able to place orders correctly. Clients are responsible for all orders placed in their account. If a Client does not have complete understanding of the way the platforms operates, they should not trade before obtaining the required knowledge. Clients who are relatively new to electronic trading are urged to strictly limit both the number of trades they do and the size of their trades to reduce the risk of losses during the learning process.

The trading platform uses “One Click” functionality, the meaning of it is immediate execution of the order submitted. Therefore, the Client will have no opportunity to review the order after clicking "buy", "sell", "up", "down". The order will be a market order without the ability to be cancelled or modified.

You are strongly urged to try trading with a demo account before real trading. You agree to one click trading and accept the risk of this immediate execute feature.

6. Overnight positions & Swap charges

Holding positions overnight on Financial Instruments, may result in considerable losses. Prices of the next day can be significantly different from the previous day's prices. Also, trading in Financial

Instruments can unexpectedly be halted during trading hours for a variety of reasons and prices can vary dramatically at the re-opening of trading with no interim capabilities of trading during such time periods. Such price changes may significantly change the result of stop-loss orders and as a result such orders might not always be able to protect you and you are still having a significant risk of losing your entire invested capital.

If a Client holds any positions overnight then an applicable swap charge will apply. The swap charges are clearly stated on the trading platform and are accepted by the Client during the account registration process as they are described in the Company's terms and conditions.

The swap rate is mainly dependent on the level of interest rates as well as the Company's fee for having an open position overnight. The Company has the discretion to change the level of the swap rate on each Financial Instrument at any given time and the Client acknowledges that they can be informed about the current swap rates by checking these in the trading platform. The Client further acknowledges that they are responsible for reviewing the contracts specifications located on the trading platform for being updated on the level of swap value prior to placing any order with the Company.

7. Underlining Market Volatility

Derivatives are instruments that allow the client to trade on price movements in underlying markets/instruments. Even though the Company offers its own prices (as obtained by its Liquidity

Provider) at which the client trades, the Company’s prices are derived based on the underlying instruments/markets.

It is important for the client to understand that the fluctuation of the underlying instrument will affect the client’s profitability. The client should also be aware of “gapping” where such events can result in a significant profit or loss on the client’s account. “Gapping” can occur when the underlying instrument/market is open and when it is closed.

8. IT Risks

Trading Instruments that are derivatives of digital assets (such as Virtual Currencies) are exposed to native IT risks associated with digital assets. Those IT risks can be: hacks, bugs, exploits, misuse etc. All of these risks may result in a total loss of the value of the underlying and therefore also for the derivative Instrument.

9. Risk of Redemption in kind

The Company custodies any digital asset in its own name and on its own behalf. If a client redeems a position in kind (to the extent possible), the underlying will be delivered to the self-custodial wallet as specified by the client outside the trading platform. Not every underlying may be compatible with every wallet. It is your responsibility to check compatibility before requesting any redemption in kind as well as the accuracy of any data provided to us. Wrong data, type-os etc. may result in a total loss of funds. We do not assume any responsibility for wrong data or incompatible wallets provided by the client.

10. Costs and Charges

All relevant costs and charges will be provided by the Company.Clients should be aware of such costs and charges that may influence the account profitability of the client. Prior to the commencement of trading activities the Client should obtain details of all commissions and all related charges regarding which the Client will be liable.

11. Funding Rates

Perpetuals contain an hourly funding rate, this means that you either have to pay the funding rate

(which equals an ongoing cost component for you) or that you will be credited the funding rate.

The funding rate is calculated by the following formula: position size * time-weighted average price of ((future – index) / index) / 24.

12. Taxes

The Client should take the risk that his trades in Instruments may be or become subject to tax and/or any other duty, for example, because of changes in the legislation or their personal circumstances. The Company does not warrant that no tax and/or any other stamp duty will be payable. The Client should be responsible for any taxes and/or any other before the Client begins to trade, he should obtain details of all commissions and other charges for which the Client will be liable. If any charges are not expressed in money terms but for example, as a dealing spread, the

Client should obtain a clear written explanation, including appropriate examples, to establish what such charges are likely to mean in specific money terms.

13. Basic Investment Risks

13.1 Credit Risk

Credit risk is the risk arising from the counterparty’s inability or unwillingness to meet its contractual obligations normally due to a default and it is highly connected to settlement risk. This may result in a loss of the principal amount, investment opportunity, and market gains.

13.2 Liquidity Risk

Liquidity refers to the ability of market participants to buy or sell their Financial Instruments at a specific time. Risk of low or no liquidity can result in a loss of an investment opportunity to buy or sell instruments at competitive prices.

13.3 Volatility Risk

Some Derivative Financial Instruments are traded within wide intraday ranges with volatile price movements. Therefore, the Client must carefully consider that there is a high risk of losses as well as profits. The price of Derivative Financial Instruments is derived from the price of the underlying asset in which the Derivative Financial Instruments refer to. Derivative Financial Instruments and related underlying assets can be highly volatile. The prices of Derivative Financial Instruments and the underlying asset may fluctuate rapidly and over wide ranges and may reflect unforeseeable events or changes in conditions, none of which can be controlled by the Client or the Company.

Under certain market conditions it may be impossible for a Client’s order to be executed at declared prices leading to losses. The prices of Derivative Financial Instruments and the underlying asset will be influenced by, amongst other things, changing supply and demand relationships, governmental, agricultural, commercial and trade programs and policies, national and international political and economic events and the prevailing psychological characteristics of the relevant marketplace.

13.4 Market Risk

Market risk is referred to investment losses due to adverse movement in the financial market prices. Interest rate risk, currency risk and instrument price risk are the main market risk types.

Particularly:

13.4.1 Interest rate risk

Changes in interest rates may cause contrary effects to the value of an investment. Interest rate Derivative Financial Instruments have values that are linked to the movements of interest rates.

These may include interest rate future, options, swaps.

13.4.2 Currency risk

Currency risk is a form of risk that arises from the change in the price of one currency against another. Whenever investors or companies hold assets or operate in different currencies, they face currency risk if their positions are not hedged. Currency risk arises also from Financial

Instruments traded in currencies different than the investor’s reporting currency.

13.4.3 Price risk

Financial Instruments prices may undergo sharp price fluctuations due to general market conditions such as changes in economic or political conditions or specific conditions related to the issuer. Price fluctuations, the frequency and duration of which can be unpredictable, may cause the risk of loss.

13.5 Political risk

A number of factors such as national conflicts, racial and national tensions create political instability in a country. Any perceived, actual or expected disruptions or changes in government policies of a country, by elections or otherwise, can have a major impact on the value of instruments linked to those countries. Political risk can drag down investment returns or even restrict the potential to withdraw or transfer capital from an investment. A country under international attention or sanctions for its actions or practices against money laundering, terrorist financing or for its acts against ethnic, social, or economic matters may cause uncertainty in respect of the securities or assets of an issuer directly related to that country. Such securities may be subject to confiscation, blocking, or restrictions on any transactions. Political risk is higher when investing in Emerging Markets.

13.6 Inflation risk

Inflation risk is the possibility that the value of an asset or income will decrease as inflation shrinks the purchasing power of a currency where the said income or asset are denominated. Inflation causes cash to decrease in value at some rate and does so irrespective of whether the cash is invested or not. Clients must therefore assess the real value of their assets in terms of the real return they would expect from an investment.

Leverage Risk

Before the Client opens a trade on Derivative Financial Instruments, they are required to maintain a margin. Margin is usually a relatively modest proportion of the overall contract value. This means that the client will be trading using "leverage" . The "leverage" is often obtainable when trading in

Derivative Financial Instruments. This means a relatively small market movement can lead to a proportionately much larger movement in the value of the Client's position and this can work either against the Client or for the Client. The greater the leverage, the greater the risk

At all times during which the Client opens trades, he must maintain enough equity, consider all running profits and losses, for meeting the margin requirements. If the prices move against the

Client then the Client must deposit funds to avoid any margin calls otherwise the Company will be entitled to close one or more or all the Clients' trades regardless of whether the Client agrees with the Company's decision to close their positions.

13.7 Timing Risk

If you do not have enough time to monitor your investment on a regular basis, you should not trade derivatives or in complex Derivative Financial Instruments. These products are not suitable for 'buy and hold' trading. They can require constant monitoring over a short period of time.

Even maintaining your investment overnight exposes you to greater risk and additional costs. The volatility of the market together with the extra leverage on your investment can result in rapid changes to your overall investment position. Immediate action may be required to manage your risk exposure or to post additional margin.

13.8 General Risks Associated with Derivative Financial Instruments

A Derivative is a Financial Instrument, the value of which is derived from an underlying asset’s value. Derivatives are used for hedging investment risks or for arbitrage purposes. The Client should carefully assess all risks from such transactions. All Derivatives are subject to the main risk types as described above, in particular Market risk, Credit risk, Volatility risk and any specific risks related with the underlying assets.

Whilst Derivative Financial Instruments can be utilised for the management of investment risk, some investments are unsuitable for many investors. Different instruments involve different levels of exposure to risk, and in deciding whether to trade in such instruments the Client should be aware that Derivatives transactions involve risks, including but not limited to the following:

• Market Risk: Market risk is the risk of loss arising from adverse changes in the value of a Derivative Financial Instrument as a result of movements in the underlying market rate.

• Credit Risk: Credit risk is the risk that a counterparty may fail to meet its contractual payment obligations through insolvency or default. For Derivatives, the amount at risk is not the face value of the transaction but the positive fair value or replacement value of the transaction.

• Liquidity Risk: Liquidity risk is the risk of losses attributable to a lack of liquidity (i.e., very few market participants) in a particular market. This is usually indicated by wide bid/offer spreads and very few transactions being done in a particular product or market. The risk is that changes in the underlying market price may be infrequent but very large, and that an open position in the market is not able to be effectively hedged.

• Pricing Risk: For complex Derivative transactions, pricing is completed using various assumptions and mathematical models. Pricing risk is the risk that these models do not accurately reflect conditions

• Operational Risk: Operational risk is a wide-ranging area of risk. It can cover risks such as, but not limited to, the following:

  • transactional details are not accurately input into the trading platform;

  • computer systems break down;

  • computer files are lost;

  • experienced staff leave the organisation;

  • documentation relating to a transaction is incorrect; and

  • relying on a third party for the performance of any operational functions which are critical for the provision of continuous and satisfactory service to clients.

14. Specific Products and their Related Risks

14.1 Perpetual Futures

Perpetual Futures are a type of derivative financial instrument that allows traders to speculate on the price movement of an underlying asset without an expiry date. Receivables in connection with

Perpetual Futures are settled in cash. Unlike traditional futures contracts, which have a set maturity date, perpetual futures remain open indefinitely, provided that required margin is maintained. These contracts typically use a funding mechanism, whereby periodic payments are exchanged between long and short position holders based on the difference between the perpetual contract price and the reference index price of the underlying asset.

The reference price of the underlying asset is generally determined by the market price as reflected on major reference exchanges or aggregated from multiple liquidity providers, depending on the pricing methodology implemented. This price is influenced by several factors, including supply and demand dynamics, macroeconomic events, market sentiment, regulatory developments, and overall liquidity conditions. Additionally, external events such as geopolitical risks, technological advancements, and sudden market disruptions may cause significant price fluctuations.

By entering into a perpetual futures contract, the investor acknowledges and agrees that they are engaging in a legally binding agreement with the counterparty, subject to the applicable terms and conditions.

Due to the nature of perpetual futures, they are subject to high volatility, leverage, and liquidation risks. Investors should be aware that trading in perpetual futures may result in significant losses, including the loss of their entire invested capital.

15. Client Categorizations

In order to comply with the Markets in Instruments Directive (MiFID) of the European Union, the Company must classify the prospective client as Retail Client, Professional Client or Eligible

Counterparty when considering the application for opening an account, based on the information provided to the Company.

16. Loss of Funds

Trading Is Considered Risky and Speculative. Clients are ultimately responsible for all of the losses suffered in their account. As a consequence, Clients should be prepared to lose all funds which they deposited. Clients are also responsible for losses that exceed their profits and deposits. Clients should never fund their trading activities with retirement savings, loans, mortgages, emergency funds, funds set aside for purposes such as education or home ownership, or funds required for current income or present or future medical expenses.

17. Competition and sophistication

Trading requires in-depth knowledge of the financial markets, trading techniques and strategies.

In attempting to profit from Trading, Traders compete with Professional traders, market-makers, etc. and therefore, a high level of investment and trading experience is necessary. No guarantees are offered or represented by the Company regarding the returns that can be expected from Trading.

18. One Click Order

The meaning of it is immediate execution, you will have no opportunity to review the order after clicking “buy”, “sell”, “up”, “down” if chosen accordingly. You are strongly urged to try trading with a demo account before real trading. You agree to one click trading and accept the risk of this immediate execute feature. As default setting, you will have to confirm any order after review.

19. Recommendations

Recommendations on the website or in our third-party partners or via email are not personal and are not investment advice. There is no guarantee for profit or for expected investment results due to those recommendations. The client is knowledgeable and accepts that he/she is using his own judgment for each transaction that he is making and not relying on any recommendation.

20. ONLINE TRADING RISKS

Clients that use our services are trading via the internet. The Company is not responsible for any failure and not liable for any damage, cost or expenses caused directly or indirectly by malfunction and / or disruption and / or failure and / or transmission, computer and / or internet system and / or trading system.

Risk Warning: Our products are traded on margin and carry a high level of risk and it is possible to lose all of your capital. You should consider whether you understand how Financial

Instruments work and whether you can afford to take the high risk of losing money. Please read carefully this Risk Disclosure document, together with the Client Agreement (“Terms of Service”) and Privacy Policy available on our website in the Legal Documents list.

Disclaimer: The content on our website does not constitute financial or investment advice. Be advised that past performance is not an indication of future performance. Any information provided by the Company either through a website or any other means, is of a general nature and does not take into consideration your personal circumstances, investment experience or financial situation.

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Trek Labs Europe Ltd. dba Backpack EU

PRIVACY STATEMENT

DATA PROTECTION NOTICE

The controller as per the EU General Data Protection Regulation (GDPR) is:

Trek Labs Europe Ltd. („We“) 47, Stavrou Avenue, Building Floor 2, 2035, Strovolos, Nicosia, Cyprus E-Mail: info@eu.backpack.exchange

Data Protection Officer:

Trek Labs Europe Ltd.. Data Protection Officer 47, Stavrou Avenue, Building Floor 2, 2035, Strovolos, Nicosia, Cyprus E-Mail: privacy@eu.backpack.exchange

1. Data protection

We are pleased about your visit on our web pages and your interest in our offers. The protection of your personal data is an important concern for us. In this Privacy Statement we explain how we collect your personal data, what we do with it, for what purposes and on what legal basis this is done, and which rights and claims are associated with it for you. In addition, please refer to our Data Privacy Policy.

Our Privacy Statement for the use of our websites and the Data Protection Policy do not apply to your activities on the websites of social networks or other providers that you can reach via the links on our websites. Please check the websites of these providers for their data protection regulations.

2. Collection and processing of your personal data

a. When you visit our website, we store certain information about the browser and operating system you use, the date and time of your visit, the access status (e.g. whether you were able to access a website or received an error message), the use of website functions, the search terms you may have entered, the frequency with which you access individual websites, the designation of files accessed, the amount of data transferred, the website from which you accessed our websites and the website which you visit from our websites, either by clicking on links on our websites or by entering a domain directly in the input field of the same tab (or the same window) of your browser in which you opened our websites. We also store your IP ad-dress and the name of your Internet service provider for seven days for security reasons, in particular to prevent and detect attacks on our websites or attempts at fraud.

b. We only store other personal data if you provide this data, e.g. as part of a registration, a contact form, a survey, a price competition or for the execution of a contract, and even in these cases only insofar as this is permitted to us on the basis of a consent given by you or in accordance with the applicable legal provisions (further information on this can be found below in the section "Legal bases of processing").

c. You are not legally or contractually obliged to make available your personal data. However, it is possible that certain functions of our websites depend on the availability of personal data. If you do not make available personal data in these cases, this may result in functions not being available or only being available to a limited extent.

3. Purposes of use

a. We use the personal data collected when you visit our website in order to operate it in the most convenient manner for your use and to protect our IT systems from attacks and other illegal activities.

b. If you provide us with further personal data, e.g. within the scope of a registration, a contact form, a survey, a price competition or for the execution of a contract, we use this data for the purposes mentioned, for the purposes of customer administration and - if necessary - for the purposes of processing and accounting of any business transactions, in each case to the extent required for this.

4. Transfer of personal data to third parties; social plug-ins; use of service providers

a. Our websites may also contain an offer from third parties. If you click on such an offer, we transfer data to the respective provider to the required extent (e.g. information that you have found this offer with us and, if applicable, further information that you have already provided on our websites for this purpose).

b. When we use social plug-ins on our websites from social networks such as Facebook and Youtube, we integrate them as follows:

When you visit our websites, the social plug-ins are deactivated, i.e. no data is transmitted to the operators of these networks. If you want to use one of the networks, click on the respective social plug-in to establish a direct connection to the server of the respective network.

If you have a user account on the network and are logged in when you activate the social plug-in, the network can associate your visit to our websites with your user account. If you want to avoid this, please log out of the network before activating the social plug-in.

When you activate a social plug-in, the network transfers the content that becomes available directly to your browser, which integrates it into our websites. In this situation, data transmissions can also take place that are initiated and controlled by the respective social network. Your connection to a social network, the data transfers taking place between the network and your system, and your interactions on that platform are governed sole-ly by the privacy policies of that network. The social plug-in remains active until you deactivate it or delete your cookies.

c. If you click on the link to an offer or activate a social plug-in, personal data may reach providers in countries outside the European Economic Area that, from the point of view of the European Union ("EU"), may not guarantee an "adequate level of protection" for the processing of personal data in accordance with EU standards. Please remember this fact before clicking on a link or activating a social plug-in and thereby triggering a transfer of your data.

d. We also use qualified service providers (IT service providers, marketing agencies, IT-supplier) to operate, optimize and secure our websites. We only pass on personal data to third parties if and to the extent necessary for the provision and use of the websites and their functionalities, for the pursuit of legitimate interests or if you have consented to it (see section “Legal bases of processing” below).

5. Security

We use technical and organizational security measures to protect your data managed by us against manipulation, loss, destruction and against access by unauthorised persons. We are constantly improving our security measures in line with technological developments.

6. Legal bases of processing

a. Insofar as you have given us your consent for the processing of your personal data, that consent is the legal basis for the processing (Art. 6 para. 1 letter a GDPR).

b. For the processing of personal data for the purposes of initiating or fulfilling a contract with you, Art. 6 para. 1 letter b GDPR is the legal basis.

c. Insofar as the processing of your personal data is necessary for the fulfilment of our legal obligations (e.g. for the retention of data), we are authorized to do so pursuant to Art. 6 para. 1 letter c GDPR.

d. In addition, we process personal data for the purposes of safeguarding our legitimate interests and the legitimate interests of third parties pursuant to Art. 6 para. 1 letter of GDPR. Maintaining the functionality of our IT systems, (direct-) marketing our own and third-party products and services as well as documenting business contacts as required by law are such legitimate interests. As part of the consideration of interests required in each case, we take into account various aspects, in particular the type of personal information, the purpose of processing, the circumstances of processing and your interest in the confidentiality of your personal information.

7. Deletion of your personal data

Your IP address and the name of your Internet service provider, which we only store for security reasons, will be deleted after seven days. Otherwise, we delete your personal data as soon as the purpose for which we have collected and processed the data ceases to apply. Beyond this time period, data storage only takes place to the extent made necessary by the legislation, regulations or other legal provisions to which we are subject in the EU or by legal provisions in third-party countries if these have an appropriate level of data protection. Should it not be possible to delete data in individual cases, the relevant personal data are flagged to restrict their further processing.

8. Rights of the data subject

a. As a data subject, you have the right of access (Art. 15 GDPR), right to rectification (Art. 16 GDPR), right to erasure (Art. 17 GDPR), right to restriction of processing (Art. 18 GDPR) and right to data portability (Art. 20 GDPR).

b. If you have consented to the processing of your personal data by us, you have the right to revoke your consent at any time. The legality of processing your personal data before revocation remains unaffected. We may further process such data pursuant to another applicable legal basis, e.g. for the fulfilment of our legal obligations (see section "Legal bases of processing").

c. Right to object

Backpack EU is a brand name of Trek Labs Europe Ltd (formerly FTX EU Ltd, referred to as “FTX EUˮ), a company regulated by the Cyprus Securities and Exchange Commission under license no. 273/15, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus. You have the right to object at any time to the processing of your personal data pursuant to Art. 6 para. 1 letter e GDPR (data processing in the public interest) or Art. 6 para. 1 letter of GDPR (data processing on the basis of a balance of interests) on grounds relating to your particular situation. If you object, we will only process your personal data if we can prove compelling legitimate reasons that outweigh your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. To the extent we process your personal data for direct marketing purposes, you have the right to object thereto at any time without giving reasons.

d. We ask you to address your claims or declarations to the following contact address if possible: privacy@eu.backpack.exchange

If you believe that the processing of your personal data violates legal requirements, you have the right to lodge a complaint with a competent data protection supervisory authority (Art. 77 GDPR).

9. Newsletter

If you subscribe to a newsletter offered on our website, the data provided in the newsletter subscription will only be used for sending the newsletter, unless you agree to further use. You can unsubscribe at any time using the unsubscribe option provided in the newsletter.

10. Data transmission to recipients outside the European Economic Area

a. When using service providers (see section “Use of service providers”), personal data may be transferred and processed by recipients in countries outside the European Union ("EU"), Iceland, Liechtenstein and Norway (= European Economic Area), in particular the USA and Japan.

b. From the point of view of the EU, the following countries provide an adequate level of protection for the processing of personal data in accordance with EU standards (so-called adequacy decision): Andorra, Argentina, Canada (limited), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, South-Korea, Switzerland, United Kingdom, United States of America (limited), Uruguay. We agree with recipients in other countries to apply EU standard contractual clauses, binding company regulations or other applicable instruments (if any) in order to create an appropriate level of protection in accordance with the legal requirements. For more information, please use the contact details given in the section “Rights of the data subject” above.

11. STATEMENT ON THE USE OF COOKIES

We use cookies and similar software tools such as HTML5 Storage or Local Shared Objects (together "cookies") that are technically necessary to provide this website to you, including all of its functions and services that you use.

Functions and use of cookies

a. Cookies are small files that are placed on your desktop, notebook or mobile device by a website you visit. From this we can, for example, manage your selections in the online vehicle configurator, maintain your log-in status or manage your shopping cart (as relevant). Cookies may also contain personal data (such as a pseudonymous sequence of characters identifying your browsing session).

b. You can also visit our website without the use of cookies. This means that you can reject and delete cookies at any time by making the appropriate settings on your device. This is done as follows:

• i. Most browsers are pre-set to automatically accept cookies. You can change this setting by activating the setting do not accept cookies in your browser.

• ii. You can delete existing cookies at any time. You can find out how this works in detail in the instructions of your browser or device manufacturer.

• iii. Like the use of cookies, their rejection or deletion is also linked to the device used and also to the browser used in each case. You must therefore reject or delete the cookies separately for each of your devices and, if you use several browsers, also for each browser.

c. If you decide against the use of cookies, it is possible that not all functions and services of our websites are available to you or that individual functions or services are only available to you to a limited extent.

List of cookies

We use the following technical necessary cookies on our website:

Last update: February 2025

Legal: This website is operated by Trek Labs Europe Ltd (formerly FTX EU Ltd), registration number HE335683, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus. Trek Labs Europe Ltd (formerly FTX EU Ltd) is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) under license number 273/15.

You can review our Terms of Service for Backpack EU below:

Legal: This website is operated by Trek Labs Europe Ltd (formerly FTX EU Ltd), registration number HE335683, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus. Trek Labs Europe Ltd (formerly FTX EU Ltd) is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) under license number 273/15.

Trek Labs Europe Ltd. dba Backpack EU

1. Introduction

Backpack EU is a brand name owned and operated by Trek Labs Europe Ltd (formerly FTX EU and FTX EU Ltd, respectively) (hereinafter referred to as the “Company,” “Backpack EU,” “us,” or “we”), a company incorporated in Cyprus with registration number HE 335683 and authorised by the Cyprus Securities and Exchange Commission (“CySEC”) under license no. 273/15, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus.

This policy outlines the approach and commitment of Trek Lab Europe Ltd (the “Company”) in safeguarding the privacy rights of individuals and any personal data, including special categories of personal data which the Company stores and processes, in compliance with data protection law.

The Company will ensure that all the personal data that it stores and processes is done in line with the principles set out by the applicable Data Protection Legal Framework (including the General Data Protection Regulation (EU) 2016/679 – the “GDPR”, the Law on the protection of natural persons against the processing of personal data and the free movement of such data, Law 125 (I) /2018 and/or other applicable regulations).

This Privacy Policy applies to all clients (potential or existing clients), and it also covers any individuals visiting our website as described further below. Further information to whom this Policy is addressed to can be found below at Section 3.

This Privacy Policy should be read in conjunction with our other corporate policies and procedures.

2. Scope of this Policy

This Data Privacy Policy provides an overview of how the Company is processing Personal Data of natural persons. It is the Company’s policy to respect the confidentiality of information and the privacy of the Individuals. This Policy outlines how the Company manages personal data of the Individuals supplied to it by its Clients or by a third party in connection with the Company’s provision of services or which the Company collects from those that use its services and/or the Company’s app(s) or website(s). Furthermore, this Policy outlines the rights of the Individuals with respect to the processing of their personal data.

This Policy applies to the processing of personal data by the Company in connection with the provision of its services through the Website, including any personal data provided through the use of the Website.

This Policy also applies to the processing of personal data by affiliated companies who may provide financial and other back office services, including IT. For the purposes of this Policy “Processing” refers to any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

For the purposes of this Policy, "Personal data" shall mean any information relating to a natural person (‘data subject’) from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The Company is committed to process Personal Data in compliance with the provisions of applicable Personal Data protection law (including the GDPR, applicable as of 25 May 20018) . The Company has appointed a Data Protection Officer to ensure that the management of personal data is in accordance with this privacy policy and the applicable legislation.

3. How is personal data collected by the Company

As part of the Company’s everyday business, the Company may need to collect personal data from:

• the Clients or potential Clients or representatives, executives, shareholders, beneficial owners of Clients;

• the customers or potential customers of the Clients,

• the individuals that had or have a business relationship with the Company,

• the individuals connected with a Client or staff or a business associate of the Company where personal data is provided under a regulatory obligation e.g. to manage possible conflicts of interest and other regulatory obligations; and

• visitors to the Company’s website to ensure that the Company can meet the needs for a range of financial services and to provide them with information about the Company’s services.

(collectively referred to as “Individuals”)

We use different methods to collect data from and about the Individuals including through:

• Direct interactions. Individuals may give the Company their Identity, Contact and Financial Data by filling in forms or by corresponding with the Company by post, phone, email or otherwise. This includes personal data the Individuals provide when they:

  • apply to become Clients;

  • create an account on the Company’s website;

  • subscribe to the Company’s service or publications;

  • request marketing to be sent to them;

  • enter a competition, promotion or survey; or

  • give the Company feedback or contact the Company and/ or for any other similar purpose or reason.

• Automated technologies or interactions. As an Individual interacts with the Company’s website, the Company will automatically collect Technical Data about the Individual’s equipment, browsing actions and patterns, all in accordance with the Company’s Cookies Policy. The Company collects this personal data by using cookies, server logs and other similar technologies. The Company may also receive Technical Data about an Individual if the Individual visits oher websites employing the Company's cookies. Please see our cookie policy for further details.

• Third parties or publicly available sources. The Company will receive personal data about an Individual from various third parties and public sources as set out below:

We collect your personal data from the following sources:

• Directly from you (e.g., information provided during the onboarding stage, or through email or telephone correspondence).

• Background check agencies (e.g., world compliance checks, etc).

• Due diligence investigations.

• Internet searches.

• Other third-parties when we seek to verify your identity – e.g., identity verification agencies etc.

• When you visit our website, e.g., collection of personal data when you complete any forms or provide your details via our Website, collection of basic information about your visit provided by your browser.

4. Collection and Processing of personal data by the Company

The Company may collect and process the following types of personal data in relation to the Individuals:

• personal details such as name, surname, date of birth, place of birth, citizenship, nationality, including documentation required for the verification of your identity – e.g., passport, utility bills, bank statements etc;

• contact data such as residential address, email address and contact details;

• financial data, such as bank account details, investment portfolio, income, source of funds evidence (e.g., financial statements, tax returns etc);

• profession and employment details;

• transaction data on business initiation and ongoing business relationship (including date, time, communication channel, copy of correspondence, records of communication);

• usage data, i.e. information about how the Individual uses the Company’s Website.

• technical data such as information collected when the Individual accesses the Company’s Website, its internet protocol (IP) address, its login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices the Individual is using;

• Profile data includes the Individual’s username and password, purchases or orders made by the individual and interests and preferences; and

• marketing and communication data such as marketing and communication preferences of the Individual.

The Company may collect this information through the use of the provision of its investment services. These include, but are not limited to onboarding, news subscriptions and information provided in the course of ongoing client service correspondence. The Company may also collect personal data from other sources such as credit reference agencies, fraud prevention agencies or from publicly available sources to comply with its legal and regulatory obligations, such as Customer Due Diligence (CDD) and Anti-Money Laundering (AML) laws.

The Company may record the communication that takes place between the Individuals and the Company in relation to the provision of investment services. These recordings will be the Company’s sole property and will constitute evidence of the communication between the parties.

The Company may also obtain personal data through the use of its Website. This is achieved by using cookies on its Website, which in particular record which pages the Individual viewed on the Company’s Website. This information is necessary for maintaining the security of the Company’s services, providing necessary functionality, and improving the overall user experience.

5. Why the Company Processes Personal Data and on what legal basis

The Company shall process Personal Data, only if it has a legal basis to do so. Specifically, the Company must have one or more of the following reasons to process an Individual’s Personal Data:

• When it is in the legitimate interests of the Company or another person with whom the data is shared, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection. (Art. 6(1)(f) GDPR)

  • To investigate or settle enquiries or disputes - The Company may need to use personal data collected from Individuals to investigate issues and/or settle disputes with a Client as it is in the Company’s legitimate interests to ensure that issues and/or disputes get investigated and resolved as quickly and efficiently as possible.

  • To help the Company improve its products and services, including Client services, and develop new products and services - the Company may use from time to time personal information provided by the Individuals through the use of the services and/or through member surveys to help the Company improve its products and services. It is in the Company’s legitimate interests to use personal information in this way to ensure that the Company provides the Clients with the best products and services the Company can.

  • Data Analysis - The Company’s emails may contain web beacons or pixel tags or any other similar type of data analysis tools which allow the Company to track receipt of correspondence and to count the number of users that have opened the Company’s correspondence. Where an Individual’s personal data is completely anonymised, the Company does not require a legal basis as the information will no longer constitute personal data. However, where the Individual’s personal data is not in an anonymised form, it is in the Company’s legitimate interest to continually evaluate that personal data to ensure that the products and services the Company provides are relevant to the market.

  • Corporate restructuring - If the Company undergoes a corporate restructuring or part or all of its business is acquired by a third party, the Company may need to process the personal data of Individuals in connection with that restructuring or acquisition.

  • Security - If an Individual enters any of the Company's premises the Company may record the Individual’s image on the Company’s CCTV for security reasons. The Company takes pictures to document who entered its premises on a particular day. It is in the Company’s legitimate interest to do this to maintain a safe and secure working environment.

  • Surveys - from time to time, the Company may send the Individual surveys as part of its Client feedback process. It is in the Company’s legitimate interest to ask for feedback to ensure it provides the best service to its Clients. All responses to any survey the Company sends out will be aggregated and anonymised before survey results are shared with any third parties.

• When processing is necessary for compliance with a contractual obligation to which the Company is subject (Art. 6 (1) (b) GDPR)

  • To manage business relationship and fulfil any contractual obligations - The Company may need to process personal data in order to effectively manage the business relationship between the Company and the Client(e.g. to communicate with its Clients) to ensure that Clients are getting the best possible service from the Company.

• When processing is necessary for compliance with a legal obligation to which the Company is subject (Art 6(1)(c) GDPR)

  • To comply with applicable law, regulations, directives, court order, other judicial process or the requirements of any applicable regulatory authorities - the Company may need to use the Individual’s personal data to comply with applicable laws, court orders or other judicial process, or the requirements of any applicable regulatory authority. For example, the Company may process personal information to comply with MiFID II requirements in contract reporting and to fulfil its obligations under Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations.

  • Internal business purposes and record keeping - the Company may need to process personal data in order to comply with its legal and regulatory obligations.

• When the Individual has given consent to the processing of his or her personal data for one or more specific purposes (Art 6(1)(a) GDPR)

  • Marketing Communications - The Company may use the Individual’s personal data to send marketing communications by email or phone or other forms (including social media campaigns) to ensure that the Individual is always kept up to date with the Company’s latest products and services. When the Company sends marketing communications, the Company does so either because it has a legitimate interest in them (Art. 6(1)(f) GDPR) or with the Individual’s consent (Art. 6(1)(a) GDPR).

  • Surveys - from time to time the Company may ask Individuals to participate in order surveys (not part of the member feedback process). If the Individual agrees to participate in such surveys, the Company relies on its consent to use the personal data it collects as part of such surveys. All responses to any survey the Company sends out will be aggregated and anonymised before survey results are shared with any third parties.

6. Who receives the Personal Data

6.1 Within the Company

Within the Company, access to Individuals’ Personal data is given to those officers who require such access to perform the Company’s contractual, legal obligations and other required by law internal activities.

6.2 Outside the Company

We shall collect, use or otherwise process your personal data when the applicable Data Protection Legal Framework allows us to. More specifically, and depending on the processing activity, we rely on the following lawful basis for collecting, using or otherwise processing your personal data:

• You have provided us specifically with your consent to the processing of your personal data – Article 6(1)(a) of the GDPR.

• Necessary for the Performance of a Contract – Article 6(1)(b) of the GDPR.

• Necessary for Complying with a Legal Obligation as a duly authorized investment firm – Article 6(1)(c) of the GDPR.

• To pursue our legitimate interests (except in cases where such interests are overridden by your interests or fundamental rights) – Article 6(1)(f) of the GDPR.

The Company requires organisations that are not affiliated with it and process personal data to respect the confidentiality of that information, to undertake to respect the privacy of individuals, and to comply with all applicable data protection laws and this privacy notice.

With regard to transfers of personal data to companies outside of the EU or the European Economic Area, refer to the section below entitled ‘Transfers outside of the European Economic Area’.

Third party service providers such as credit referencing agencies may keep a record of any searches performed on the Company’s behalf and may use the search details to assist other companies in performing their searches.

6.3 List of Data Recipients

We may disclose personal data to third parties where necessary for regulatory compliance, operational requirements, or service provision. These recipients include:

• Regulatory and Supervisory Authorities – We may share data with the Cyprus Securities and Exchange Commission (CySEC), the European Securities and Markets Authority (ESMA), and other competent authorities as required under applicable laws and regulatory obligations.

• Financial Institutions and Legal Advisors – This includes banks, payment service providers, auditors, legal advisors, and compliance consultants involved in transaction processing, anti-money laundering (AML) compliance, and legal obligations.

• Third-Party Service Providers – We may engage cloud storage providers such as AWS, IT system vendors, KYC/AML screening service providers such as Sumsub Refinitiv and AristaFlow GMBH, trading platform operators, and other outsourced service providers who process data on our behalf under strict confidentiality and security measures.

• Affiliated Entities – Where applicable, data may be shared within our corporate group for internal administration, risk management, or business operations such Trek Labs Ltd FZE (United Arab Emirates), Trek Labs Japan KK (Japan) and Trek Labs Ltd (BVI).

• Law Enforcement and Judicial Authorities – We may disclose personal data to law enforcement agencies, courts, or other competent authorities in response to legal requests, fraud prevention measures, or regulatory investigations.

• Clients and Counterparties – In cases where transactions require the involvement of liquidity providers, executing brokers, or counterparties, data may be shared to facilitate trade execution.

• Marketing and Communication Partners (if applicable) – If you have provided consent, we may share limited data with marketing partners for promotional communications, with the option to withdraw consent at any time.

All data disclosures are conducted in compliance with the General Data Protection Regulation (GDPR) and applicable CySEC regulatory requirements, ensuring appropriate safeguards, contractual agreements, and confidentiality measures are in place.

7. Transfers outside of the European Economic Area

The Company may transfer Individuals’ personal data to countries outside of the European Union and/ or the European Economic Area, ensuring that the Personal Data are adequately protected and that such transfer will comply with the requirements of the Data Protection Legislation at all times.

If the Company transfers Individual’s Personal Data to a third country outside the European Economic Area, the Company will make sure that Personal Data is protected in the same way as if it was being used in the ΕΕΑ. The Company will ensure that at least one of the following safeguards is implemented:

• Personal Data is transferred to a third country with privacy laws that give the same protection as the ΕΕΑ, as certified by an adequacy decision of the European Commission.

• Personal Data is transferred to organisations that comply with binding corporate rules, or an approved code of conduct or certification mechanism that requires its protection to the same standards as applicable in the ΕΕΑ.

• Put in place a contract with the recipient which includes the standard data protection clauses adopted by the European Commission or adopted by the supervisory authority and approved by the European Commission.

• Where the recipient in the third country has signed up to a code of conduct, which has been approved by a competent supervisory authority. The code of conduct must include appropriate safeguards to protect the rights of individuals whose Personal Data transferred, and which can be directly enforced.

• Where the recipient in the third country has a certification, under a scheme approved by a competent supervisory authority. The certification scheme must include appropriate safeguards to protect the rights of individuals whose Personal Data transferred, and which can be directly enforced.

In the case where none of those bases apply, an Individual’s Personal Data may still be transferred to a third country under the following conditions/ derogations, where:

• the Individual explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers due to the absence of an adequacy decision and appropriate safeguards;

• the transfer is necessary for the performance of a contract between the Individual and the Company, or the implementation of pre-contractual measures taken at the Individual’s request;

• the transfer is necessary for the establishment, exercise or defence of legal claims;

8. Cloud Services and storage of Personal Data

Safeguarding the privacy of information is important to the Company, whether an Individual interacts with the Company personally, by phone, by mail, over the internet or any other electronic medium.

The Company holds personal data in a combination of secure computer storage facilities and paper-based files and other records, and takes steps to protect the personal data it holds from misuse, loss, unauthorised access, modification or disclosure.

The Company uses cloud technology to store Individuals’ Personal Data. The cloud service providers used by the Company and their data centres , are located in the European Union or outside EEA acting in accordance with the necessary provisions as stated under section 8. and thus, bound by the GDPR requirements.

Despite this, there are cases where Personal Data may be transferred to or accessed from a third country for the purposes of the provision of the services outsourced or, if required by law, In such case the Company shall ensure that the relevant safeguards as mentioned above will apply so that the Company is in compliance with its GDPR obligations.

The Company ensures contractually that the cloud service provider will apply principles of data minimization and will not use or otherwise process Personal Data for: (a) user profiling, (b) advertising or similar commercial purposes, or (c) market research aimed at creating new functionalities, services, or products or (d) any other purpose, unless such use or Processing is in accordance with Company’s documented instructions.

Retention of Personal Data on cloud shall be in line with the general retention policy of the Company as described below.

9. For how long is Personal Data retained

The Company shall retain your data as a duly authorised investment firm for a period of five (5) years, a timeframe that can be extended to seven (7) years under certain circumstances, specifically if this is requested by any competent authority.

Your data will be securely destroyed when it is no longer required for the fulfilment of the purposes for which such data was collected.

10. Rights of Individuals in relation to their Personal Data

The Individuals’ data protection rights, granted by GDPR regarding the processing of your personal data, are described below:

10.1 Right of Access

The Individuals have the right to request access to their personal information; this enables them to receive a copy of the personal information the Company holds about them and check that the Company is lawfully processing it.

10.2 Right to be informed

The Individuals have the right to be provided with clear and concise information about what the Company does with their personal data. Data subjects have the right to know how their personal information is collected and used. Under “the right to be informed”, businesses and websites must provide individuals with details of their personal data collection and processing.

10.3 Right to Rectification

The Individuals have the right to request to correct their personal information the Company holds about them that is inaccurate or incomplete and the Company must inform them and any third parties to whom they disclose Individuals’ information about the rectification.

10.4 Right to Erasure (also known as the “Right to be forgotten”)

The Individuals have the right to have the Company delete or remove their Personal Data in the following circumstances:

• The Processing of the Personal Data by the Company is no longer necessary for any of the reasons the Personal Data was collected and used.

• The Individual has withdrawn his/her consent and there is no other legal ground for the Personal Data Processing.

• The Individual has successfully objected to the Processing of the Personal Data by the Company

• The Personal Data has been unlawfully processed.

• Deletion is required by law.

It is clarified that the Company reserves its right to deny the said erasure, if the Processing is necessary for the Company to comply with its legal obligations, for reasons of public interest and/or for the exercise or defence of its legal claims, i.e. the right is not absolute, since it applies only in certain circumstances.

10.5 Right to restriction of Processing of Personal Data

The Individuals also have the right to restrict the Company's use of their Personal Data in the following circumstances:

• pending verification by the Company of Personal Data the accuracy of which the Individual has contested

• the Processing is unlawful, but the Individual does not want his/her Personal Data to be erased

• the Company no longer needs the Personal Data, but the Individual does not want it to be erased because the Individual needs it for the establishment, exercise or defence of legal claims

• pending the Company's assessment where the Individual has objected to Processing intended to safeguard the Company's legitimate interests.

10.6 Right to data portability

The Individuals have the right to receive their Personal Data from the Company in a structured, commonly used and machine-readable form. The Individuals can also ask the Company to transfer their Personal Data in this format to other organisations, where this is technically feasible. This right relates to the Personal Data which the Individuals have provided to the Company and which the Company processes electronically in reliance on their consent or for fulfilling the contract between the Individual and the Company.

10.7 Right to object

The Individuals have the right to object to the Company's use of their Personal Data and ask the Company to stop using their Personal Data in any of the following circumstances:

• The Individual has the right to object to the Processing of his/her Personal Data on grounds relating to the Individual’s particular situation, at any time to Processing of his/her Personal Data which is intended by the Company to safeguard its legitimate interests or to serve the public interest. If the Individual lodges an objection, the Company will no longer process his/her Personal Data unless the Company can demonstrate compelling legitimate grounds for the Processing which override the Individual’s interests, rights and freedoms or unless the Processing is for the establishment, exercise or defence of legal claims.

• The Individual has the right to object to the Processing of his/her Personal Data for direct marketing purposes, including profiling. If the Individual lodges such an objection, his/her Personal Data will no longer be processed for such purposes.

• The Individual has the right to object to the Processing of his/her Personal Data for scientific or historical research purposes or statistical purposes, on grounds relating to his/her particular situation, unless the Processing is necessary for the performance of a task carried out for reasons of public interest.

10.8 Right to withdraw consent

Where the Company relies on the Individual’s consent for the Processing of his/her Personal Data, the Individual can withdraw his/her consent at any time. If the Individual withdraws his/her consent, the Company may not be able to provide certain products or services to the Individual. If this is so, the Company will inform the Individual before giving effect to his/her withdrawal notification. Please note that the withdrawal of the consent does not affect the legality of the Personal Data processed prior to the withdrawal.

If the Individual wishes to exercise any of the above rights or seek more information about the collection, storage and handling of their personal data by the Company he must send an email to the designated Data Protection Officer of the Company at “privacy@eu.backpack.exchange” or contact the Company’s Customer Support Department at “support@eu.backpack.exchange”.

Note:

• The Company reserves the right to request specific information to confirm the Individual’s identity, speed up its response and ensure the Individual’s right to access their personal data or any other right as data subject.

• The Company must always respond to Individuals’ requests within reasonable time and keep them updated.

• Responses to ARs shall normally be made within one month of receipt, however this may be extended by up to two months if the AR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed accordingly without undue delay.

(*) Kindly be informed that there might be certain exceptions to the applicability of the aforesaid rights. If you have any questions or concerns about the exercise of your personal data rights, please contact us at support@eu.backpack.exchange.

11. Security and Data Breach

The Company always takes appropriate technical and organisational measures to ensure that Personal Data is secure. In particular, the Company trains its employees who handle personal data to respect the confidentiality of Client information and the privacy of individuals

In order to maintain security and prevent processing in infringement of the GDPR, the Company, in particular the Data Protection Officer, shall constantly monitor and evaluate the risks involved with data processing and implement measures to mitigate those risks.

As soon as the Company becomes aware that a personal data breach has occurred, the responsible person should notify the supervisory authority without undue delay and, where feasible, not later than 72 hours after having become aware of it. Additionally, the Company shall communicate with data subject to a personal data breach without undue delay, where that personal data breach is likely to result in high risk to the rights and freedoms of the natural person in order to allow him or her to take necessary precautions. The communication should describe the nature of the personal data breach as well as recommendations for the natural person concerned to mitigate potential adverse effects.

The Company regards breaches of privacy very seriously and will impose appropriate penalties, including dismissal where necessary.

Our website may contain links to external sites. In such a case, this Privacy Policy will no longer apply, since we are not responsible for the personal data handling practices followed by third-party sites. We, therefore, encourage you to consult the other sites’ privacy policies.

12. Changes / Amendments to the Privacy Policy

This Privacy Policy sets out the information that the Company must provide to the Individuals for the purposes of the GDPR. Any information in relation to the Processing of Personal Data that is included in any of the Company's existing circulars, manuals and associated forms on matters which are covered by this Policy are deemed to be superseded by the information in this Policy. The Company may revise or update this Policy from time to time. The new version of this Policy will be available on the Company’s website. ln case of significant changes (such as in relation to the reasons for which the Company uses Personal Data or to the way in which Individuals may exercise the rights described above), the Company will bring these changes to the Individuals’ attention.

13. Complaints

14. Contact us

February 2025

Legal: This website is operated by Trek Labs Europe Ltd (formerly FTX EU Ltd), registration number HE335683, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus. Trek Labs Europe Ltd (formerly FTX EU Ltd) is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) under license number 273/15.

You can review our User Agreement below:

Legal: This website is operated by Trek Labs Europe Ltd (formerly FTX EU Ltd), registration number HE335683, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus. Trek Labs Europe Ltd (formerly FTX EU Ltd) is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) under license number 273/15.

Trek Labs Europe Ltd. dba Backpack EU

1. Introduction

Backpack EU is a brand name owned and operated by Trek Labs Europe Ltd (formerly FTX EU and FTX EU Ltd, respectively) (hereinafter referred to as the “Company,” “Backpack EU,” “us,” or “we”), a company incorporated in Cyprus with registration number HE 335683 and authorised by the Cyprus Securities and Exchange Commission (“CySEC”) under license no. 273/15, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus.

Following the implementation of the Markets in Financial Instruments Directive 2014/65/EU (MiFID II) and in accordance to the provisions of the Investment Services and Activities and Regulated Markets Law of 2017 (Law 87 (I)/2017) (hereinafter called the “Law”), the Company is required to categorise its Clients into one of the following three categories, each with different levels of protection and rights: (a) Retail, (b) Professional or (c) Eligible Counterparty, depending on the information provided by each Client during the account opening process.

2. General Principles

The Company, prior to engaging in business relationship with its potential clients, it shall inform clients about their categorisation, their rights to request a different categorisation and about any limitations to the level of client protection that such change of categorisation would entail. It should be noted that each category entails a different level of client protection - maximum degree of protection is given to Retail Clients while minimum protection is given to Eligible Counterparties.

It is stated that the Company has the right to review the current Policy and if changes need to be made herein, the Company shall accordingly change the categorisation of a Client if this is deemed necessary subject to applicable Regulations.

3. Categorisation Criteria

The categorisation criteria set by the Law (as amended from time to time) are the following:

3.1 Retail Clients

‘Retail Client’ is a client who is not a Professional Client or an Eligible Counterparty.

3.2 Professional Clients

‘Professional Client’ is a client who possesses the experience, knowledge and expertise to make his own investment decisions and properly assess the risks that he incurs.

Certain categories of clients are considered to be Professional Clients on the basis of the provisions of MiFID II and the Law. These are also referred to as “per se” professional clients.

Other clients may be treated as Professional Clients on request provided that the relevant criteria and procedures provided in MiFID II and the Law are satisfied. Those are referred to as “Elective” professional clients.

A. Categories of clients who are considered to be professionals - Per se Professional Clients

The following should all be regarded as professionals in all investment services and activities and financial instruments for the purposes of MiFID II and the Law:

• Entities which are required to be authorised or regulated to operate in the financial markets. The list below should be understood as including all authorised entities carrying out the characteristic activities of the entities mentioned: entities authorised by a Member State under a Directive, entities authorised or regulated by a Member State without reference to a Directive and entities authorised or regulated by a non-Member State:

  • Credit institutions.

  • Investment firms.

  • Other authorised or regulated financial institutions.

  • Insurance companies.

  • Collective investment schemes and management companies of such schemes.

  • Pension funds and management companies of such funds.

  • Commodity and commodity derivatives dealers.

  • Local enterprises.

  • Other institutional investors.

• Large undertakings meeting two of the following size requirements on a company basis:

  • balance sheet total of minimum EUR 20,000,000;

  • net turnover of at least EUR 40,000,000;

  • own funds of at least EUR 2,000,000.

• National and regional governments, public bodies that manage public debt, Central Banks, international and supranational institutions such as the World Bank, the IMF, the ECB, the EIB and other similar international organisations.

• Other institutional investors whose main activity is to invest in financial instruments, including entities dedicated to the securitisation of assets or other financing transactions.

The entities mentioned above are considered to be professionals. However, they are allowed to request non-professional treatment and we may agree to provide a higher level of protection.

Where a Client is an undertaking referred to above, the Company must inform the Client, prior to any provision of services that, on the basis of the information available to us, the Client is deemed to be a Professional Client, and will be treated as such unless we and the Client agree otherwise.

The Company must inform the Client that he may request a variation of the terms of the agreement in order to secure a higher degree of protection.

It is the responsibility of the Client, considered to be a Professional Client, to ask for a higher level of protection when it deems it is unable to properly assess or manage the risk involved.

This higher level of protection will be provided when a Client who is considered to be a Professional Client, enters into a written agreement with us to the effect that it shall not be treated as a Professional Client for the purposes of the applicable conduct of business regime. Such agreement will specify whether this applies to one or more particular services or transactions, or to one or more types of products or transactions.

B. Clients who may be treated as professionals on request -“Elective” Professional Clients

Clients, other than those mentioned above[EG2] , including public sector bodies, local public authorities, municipalities and private individual investors, may also be allowed to waive some of the protections afforded by the conduct of business rules.

The Company is allowed to treat any of the above-mentioned Clients as Professional Clients provided that the relevant criteria and procedure mentioned below are fulfilled. These Clients will not, however, be presumed to possess market knowledge and experience comparable to that of the categories listed in paragraph I [EG3] above.

3.3 Eligible Counterparties

‘Eligible Counterparty’ is any of the following entities to which a credit institution or an investment firm provides the services of reception and transmission of orders on behalf of clients and/or execution of such orders and/or dealing on own account: Cyprus Investment Firms and remaining investment firms, credit institutions, insurance undertakings, UCITS and their management companies, pension funds and their management companies and other financial institutions authorised by a Member State or regulated under the laws of Cyprus or under the European Union law, national governments and their corresponding offices including public bodies that deal with public debt at national level, central banks and supranational organisations.

4. Request for Different Categorisation

The following requests may be submitted to the Company:

• Retail Clients can request to be categorized and treated as Professional Clients in which case they will be afforded a lower level of protection.

• Professional Clients can request to be categorized and treated as Retail Clients in which case they will be afforded a higher level of protection.

• Eligible Counterparties can request to be categorized and treated as either Retail or Professional Clients in which case they will be afforded a higher level of protection.

It is noted that the Company will assess specified quantitative and qualitative criteria in accordance with the provisions of the Law and the change of categorization will depend on its absolute discretion. In this respect, the Company reserves the right to decline any of the above requests for different categorisation.

5. Procedure for Change of Categorisation

5.1 Retail Clients who may be treated as professional clients on request (i.e. Elective Professional Clients)

Clients who have been initially classified by the Company as Retail Clients are allowed to request to be treated as Professional Clients, if an adequate assessment of the expertise, experience and knowledge of the client undertaken by the Company gives reasonable assurance, in light of the nature of the transactions or services envisaged, that the client is capable of making investing decisions and understanding the risks involved.

An example of the assessment of expertise and knowledge with regards to entities licensed under directives in the financial field could be the fitness test applied to the managers and directors of such entities. In the case of small entities, the person subject to that assessment shall be the person authorised to carry out transactions on behalf of the entity.

In the course of that assessment, as a minimum, two of the following criteria shall be satisfied:

• The client has carried out transactions, in significant size, at an average frequency of 10 per quarter over the previous four quarters.

• The size of the client’s financial instrument portfolio exceeds EUR 500.000.

• The client works or has worked in the financial sector for at least one year in a professional position, which requires knowledge of the transactions or services envisaged.

Those clients may waive the benefit of the detailed rules of business conduct only where the following procedure is followed:

• they must state in writing to the Company that they wish to be treated as a professional client, either generally or in respect of a particular investment service or transaction, or type of transaction or product;

• the Company must give them a clear written warning of the protections and investor compensation rights they may lose;

• they must state in writing, in a separate document from the contract, that they are aware of the consequences of losing such protections.

Before deciding to accept any request for waiver, the Company must take all reasonable steps to ensure that the client requesting to be treated as a professional client meets the relevant requirements stated above. An elective professional client should not be presumed to possess market knowledge and experience comparable to a per se professional client.

Professional clients are responsible for keeping the Company informed about any change, which could affect their current categorisation.

Should the Company become aware however that the client no longer fulfils the initial conditions, which made him/her eligible for a professional treatment, the Company shall take appropriate action. Where the appropriate action involves re-categorising that client as a Retail Client, the Company shall notify that client of its new categorization.

5.2 Professional Clients who may be treated as Retail Client on request

A Professional Client is allowed to request non-professional treatment and the Company may agree to provide a higher level of protection. In this respect, the Company notifies its clients, prior to the provision of services, in a written form, of their option to be classified as retail clients and secure a higher degree of protection. The Company proceeds in this action, in order to offer a uniform level of protection to all of its clients.

The higher level of protection will be provided by the Company when the client enters into a written agreement with the Company, to the effect that it shall not be treated as a professional. Such agreement shall specify whether this applies to one or more particular services or transactions or to one or more types of product or transaction.

It is the responsibility of the client who is classified as a professional client to ask for a higher level of protection when he is not in a position to properly assess and manage the risks involved in the transactions.

It should be pointed out to all the clients that Professional Clients are not covered by the Investor Compensation Fund for clients of investment firms.

The Company shall be entitled to assume that a Professional Client [EG4] has the necessary experience and knowledge in order to understand the risks involved in relation to those particular investment services or transactions, or types of transactions or product, for which the client is classified as a Professional Client and also that the client is able financially to bear any related investment risks.

The Company is not required to prioritize the overall costs of a transaction as being the most important factor, when providing Professional Clients with best execution.

5.3 Eligible Counterparties who may be treated as Retail or Professional Clients on request

An Eligible Counterparty is allowed to request, either on a general form or on a trade-by-trade basis, treatment as client whose business with the Company is subject to Sections 25, 26, 28 and 29 of the Law 87(I)/2017 and the Company may agree to provide a higher level of protection. In this respect, the Company notifies its clients, prior to the provision of services, in a written form, of their option to request such treatment.

The relevant request to the Company must be made in writing and shall indicate whether the treatment as retail client or professional client refers to one or more investment services or transactions, or one or more types of transaction or product.

Where an Eligible Counterparty requests treatment as a client whose business with an investment firm is subject to Sections 25, 26, 28 and 29 of the Law 87(I)/2017, but does not expressly request treatment as a Retail Client, the Company shall treat that Eligible Counterparty as a Professional Client.

Where the Eligible Counterparty expressly requests treatment as a Retail Client, the higher level of protection will be provided by the Company when the client enters into a written agreement with the Company, to the effect that it shall not be treated as a Professional. Such agreement shall specify whether this applies to one or more particular services or transactions or to one or more types of product or transaction. It is the responsibility of the client to ask for a higher level of protection when it deems unable to properly assess or manage the risks involved.

6. Protection Rights for Retail Clients

Where the Company treats you as a Retail Client, you will be entitled to more protections under the law than if you were to be categorised as a Professional Client.

In summary, the additional protections Retail Clients are entitled to are as follows (the list may not be exhaustive):

• A Retail Client will be given more information disclosures with regards to the Company, its services, its financial instruments and their performance, the nature and risks of financial instruments, its costs, commissions, fees and charges and the safeguarding of Client financial instruments and Client funds, including summary details of any relevant investor compensation or deposit guarantee scheme, as applicable.

• Under the law, where the Company provides investment services other than investment advice (in the form of personal recommendations) or discretionary portfolio management, the Company shall ask a Retail Client to provide information regarding his knowledge and experience in the investment field relevant to the specific type of product or service offered or demanded so as to enable us to assess whether the investment service or product envisaged is appropriate for the Client. In case the Company considers, on the basis of the information received that the product or service is not appropriate to a Retail Client, it shall warn the Client accordingly. Please note that the Company is not required to assess appropriateness in certain cases specified by law.

• The Company shall be entitled to assume that a Professional Client has the necessary experience and knowledge in order to understand the risks involved in relation to those particular investment services or transactions, or types of transactions or products, for which the Client is classified as a Professional Client. Consequently, and unlike the situation with a Retail Client, the Company should not generally need to obtain additional information from the Client for the purposes of the assessment of appropriateness for those products and services for which they have been classified as a Professional Client.

• When executing orders, investment firms (such as the Company) and credit institutions providing investment services must take all reasonable steps to achieve what is called ‘best execution’ for their Client orders (i.e. obtain the best possible result for their Clients). Where the Company executes an order on behalf of a Retail Client, the best possible result shall be determined in terms of the total consideration, representing the price of the financial instrument and the costs related to execution, which shall include all expenses incurred by the Client which are directly related to the execution of the order, including execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order.

• When providing Professional Clients with best execution the Company is not required to prioritise the overall costs of the transaction as being the most important factor in achieving best execution for them. The Company must provide a retail client with a summary of its order execution policy (focused on the total cost the client incurs). This summary must provide a link to the most recent execution quality data for each execution venue listed in the Policy. The Company is not obliged to provide a summary that complies with these specific requirements to professional clients. Information on the Company’s order handling and execution policy is, however, required to be provided to professional clients as well.

• The Company must inform Retail Clients of material difficulties relevant to the proper carrying out of their order(s) promptly upon becoming aware of the difficulty.

• The Company is required to provide Retail Clients with more information than Professional Clients as regards the execution of their orders.

• The Company is obliged to enter into a written basic agreement with the retail Client, setting out the essential rights and obligation of both parties.

• Under the law we are not allowed to enter into title transfer collateral arrangements with Retail Clients whereas in the case of Professional Clients’ money and financial instruments title transfer collateral arrangements are allowed. Title transfer collateral arrangements means the change of title ownership of clients’ money and financial instruments to be used as collateral against existing or future obligations. Money and financial instruments that are subject to title transfer will not be segregated from our assets and thus you are assuming credit risk against us.

• Only Retail Clients may be entitled to compensation from the Investor Compensation Fund in case of inability of the Company to repay its obligations.

• Professional clients are not protected by the Company against any minus balance in their trading account, which should be covered by them, however, retail clients can never lose more than the total sum invested for trading. There can be no residual loss or obligation to provide additional funds beyond those in the retail clients’ trading account.

7. Record – Keeping

The Company must keep records of each notice provided and each agreement entered into in accordance with the present Policy.

The Company shall keep records in relation to each client in relation to (a) the categorization established for the client, including sufficient information to support that categorization; (b) evidence of despatch to the client of any notice required under this Policy and a copy of the actual notice provided; and (c) a copy of any agreement entered into with the client under this Policy.

Legal: This website is operated by Trek Labs Europe Ltd (formerly FTX EU Ltd), registration number HE335683, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus. Trek Labs Europe Ltd (formerly FTX EU Ltd) is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) under license number 273/15.

Trek Labs Europe Ltd. dba Backpack EU

MONEY LAUNDERING PREVENTION POLICY

1. Introduction

Backpack EU is a brand name owned and operated by Trek Labs Europe Ltd (formerly FTX EU and FTX EU Ltd, respectively) (hereinafter referred to as the “Company,” “Backpack EU,” “us,” or “we”), a company incorporated in Cyprus with registration number HE 335683 and authorised by the Cyprus Securities and Exchange Commission (“CySEC”) under license no. 273/15, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus.

Trek Labs Europe Ltd operates in accordance with all relevant EU and local laws, including the European Markets in Financial Instruments Directive II (MiFID II), the Cyprus Investment Services and Activities and Regulated Markets Law of 2017 (Law 87(I)/2017), and the Prevention and Suppression of Money Laundering and Terrorist Financing Laws of 2007 to 2024 as amended from time to time.

2. Purpose

Trek Labs Europe Ltd in order to ensure timely and ongoing compliance with current Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) regulations, has established and implemented appropriate policies and procedures.

The main objective of this policy is to outline the Company’s internal policies, procedures, measures, practices and controls aimed to prevent money laundering and terrorist financing. These policies and procedures enable the Company to meet its obligations under various laws, regulations, and industry best practices by identifying and assessing potential money laundering and terrorist financing (ML/TF) risks associated with the provision of designated services and managing or mitigating those risks identified in accordance with the applicable legal and regulatory framework.

3. Legal & Regulatory Framework

• For the purpose of this document the “applicable legal and regulatory framework” shall include the following:

• The Prevention and Suppression of Money Laundering and Terrorism Financing Law 188(I)/2007, the “AML Law”, as subsequently amended;

• Directive of CySECregarding the Prevention and Suppression of Money Laundering and Terrorist Financing , the “CySEC AML Directive”, as subsequently amended,

• Directive (EU) 2018/843 (“AMLD V”) amending Directive (EU) 2015/849 (“AMLD IV”) of the European Parliament and the Council on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing, the ”EU AML Directive”.

• Risk factor Guidelines issued by the Joint Committee of the European Supervisory Authorities under Articles 17 and 18(4) of Directive (EU) 2015/849 on anti-money laundering and countering the financing of terrorism is referred to as the ‘' Risk Factors Guidelines”

• The Financial Action Task Force (FATF) recommendations Backpack EU is a brand name of Trek Labs Europe Ltd (formerly FTX EU Ltd, referred to as “FTX EU”), a company regulated by the Cyprus Securities and Exchange Commission under license no. 273/15, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus. 2

• CySEC’s applicable Directives, Circulars, Reporting Forms and other related documents

• Any other legislative act of the European Parliament and Commission currently in force substituting/ amending the above mentioned.

4. Compliance with AML/ CFT legal and regulatory requirements

Trek Labs Europe Ltd is dedicated to preventing money laundering activities in relation to the offering of our services and investment products, therefore, adhere to regulatory requirements by conducting as a minimum the following practices:

• Ensure that our clients identification is verified before the establishment of any business relationship;

• Identify, monitor and report any suspicious activity to the competent authorities on timely manner;

• Keep records related to transactions for at least five years following the end of the business relationship with the clients;

• Our staff is trained on an ongoing basis to recognise any suspicious activity and meet all relevant reporting obligations and requirements;

• Ensure that any suspicious activity is reported to the relevant competent authorities where the client is located.

5. Notices & Disclaimers

• Clients should be aware that all information submitted to the Company may be accessible to the appropriate regulatory and supervisory authorities in: (a) the country of incorporation of the Company, which is the Republic of Cyprus; (b) the country of origin of any funds transferred to the Company; and (c) the destination country for any funds refunded by or withdrawn from the Company.

• Trek Labs Europe Ltd reserves the right to decline processing a fund transfer at any point if it suspects any connection to criminal activities or activities concerning money laundering, bribery, corruption and financial crime.

• Trek Labs Europe Ltd reserves the right to terminate the Clients Agreement with immediate effect and/ or to refuse to execute any pending orders and/ or to freeze or block your trading account and any assets thereon if we reasonably believe that you may be acting in breach of applicable AML Laws. We may, where we consider this Backpack EU is a brand name of Trek Labs Europe Ltd (formerly FTX EU Ltd, referred to as “FTX EU”), a company regulated by the Cyprus Securities and Exchange Commission under license no. 273/15, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus. 3 necessary in order to comply with our obligations under the applicable AML Laws, refuse to provide you with further explanations as to any action or refusal or failure to take any action.

• Trek Labs Europe Ltd reserves the right to review and amend its Money Laundering Prevention Policy, when necessary or appropriate.

• The Money Laundering Prevention Policy is a standalone policy and forms part of our Terms and Conditions of Business. It is not intended to be contractually binding and does not impose any obligations on us that we would not otherwise have.

6. Contact Us

For any inquiries related to our Money Laundering Prevention Policy, please contact our Compliance Department at compliance@eu.backpack.exchange.

Legal: This website is operated by Trek Labs Europe Ltd (formerly FTX EU Ltd), registration number HE335683, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus. Trek Labs Europe Ltd (formerly FTX EU Ltd) is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) under license number 273/15.

Trek Labs Europe Ltd. dba Backpack EU

INVESTOR COMPENSATION FUND NOTICE

1. Purpose of the Investor Compensation Fund (ICF)

Pursuant to section 15 of the Investment Services and Activities and Regulated Markets Law of 2017 (the “Law”), Trek Lab Europe Ltd (referred to as the “Company”) is a member of the Investor Compensation Fund (the “ICF”).

The purpose of the ICF is to secure the claims of Covered Clients (as defined in the applicable legislation) against the Company, in case the Company is unable to meet any of its obligations that arise as a result of a Covered Client’s claim regarding the provision of investment or ancillary service(s) and the Company’s financial position is unlikely to change in the foreseeable future, provided that the criteria set out in the applicable legislation have been fulfilled. The provisions of the present Policy in relation to the operation of the ICF are in accordance with the provisions of Directive DI87-07 of 2019 and Directive DI87-07(A) of 2022 of “CySEC for the operation of the Investors Compensation Fund” (the “ICF Directive”).

The ICF pays compensation to Covered Clients for a successful claim brought in relation to a covered service provided by the Company given that the Company’s failure to fulfil its obligations is established.

Failure by the Company to fulfil its obligations to a Covered Client consists of the following:

• (a) either failure to return funds owed to a Covered Client or funds which belong to a Covered Client but are held by the Company, on the Covered Client’s behalf, in relation to investment services; or

• (b) failure to hand over to a Covered Client financial instruments that belong to a Covered Client and which the Company holds, manages, or administers on the Covered Client’s behalf, in relation to investment services.

2. Covered Clients

The ICF covers only Retail Clients of the Company. It does not cover Professional Clients nor Eligible Counterparties.

3. Non-covered Clients

Subject to the provisions of CySEC Directive DI 87-07, the ICF shall not compensate the following investor categories:

• (a) The following categories of institutional and professional investors:

  • (i) IFs;

  • (ii) legal entities associated with the Company and generally belonging to the same group of companies;

  • (iii) banks;

  • (iv) cooperative credit institutions;

  • (v) insurance companies;

  • (vi) collective investment undertakings in transferable securities and their management companies;

  • (vii) social insurance institutions and funds;

  • (viii) investors characterized by the member as professionals upon their request, pursuant to the provisions of paragraph Β of the Second Schedule of the Law.

• (b) Supranational institutions, government and central administrative authorities.

• (c) Provincial, regional, local and municipal authorities.

• (d) Enterprises that have close ties with the Company as the term «close ties» is construed in Article 2(1) of the Law.

• (e) Managerial and administrative staff of the Company.

• (f) Shareholders of the Company whose participation directly or indirectly in the capital of the Company amounts to at least 5% of its share capital, or its partners who are personally liable for the obligations of the Company as well as persons responsible for the carrying out of the financial audit of the Company as provided by the Law, such as its qualified auditors.

• (g) Investors having investments in enterprises connected with the Company and, in general, with the group of companies to which the Company belongs, positions or duties corresponding to those listed in sub-paragraphs (e) and (f).

• (h) Up to second-degree relatives and spouses of the persons listed in sub-paragraphs (e), (f) and (g), as well as third parties acting for the account of such persons.

• (i) Investors-clients of the Company responsible for facts pertaining to the Company that have caused its financial difficulties or have contributed to the worsening of its financial situation or have profited from these facts.

• (j) Other firms in the same group.

• (k) Investors in the form of a company, which due to its size, are not allowed to draw a summary balance sheet in accordance with the Companies Law or a corresponding law of a Member State.

In the cases of sub-paragraphs (e), (f), (g), (h), and (j) the ICF shall suspend the payment of compensation informing the interested parties accordingly until it reaches a final decision as to whether such cases apply.

4. Covered Services

ICF shall compensate any Covered Client of the Company in respect of a claim arising out of a covered service, meaning any investment or ancillary service(s) provided at the time by the Company and presented on the CySEC’s website and presented on: https://www.cysec.gov.cy/en-GB/entities/investment-firms/cypriot/72591/

The ICF covers claims due to the Company’s failure:

• to repay the funds owed to covered clients or belonging to them and held on their behalf in connection with investment operations; or

• to return to covered clients any financial instruments belonging to them and held, managed or administered on their behalf in connection with investment operations; in accordance with the legal and contractual conditions applicable.

It should be noted that the ICF shall pay no compensation to an individual who has been convicted of a criminal offence related to the Prevention and Suppression of Money Laundering Activities Law.

5. Procedure

The ICF shall initiate the compensation payment procedure when:

• (a) the Cyprus Securities and Exchange Commission (hereinafter “the CySEC”) has determined that a member of the ICF appears, for the time being, for reasons directly related to its financial circumstances, to be unable to meet its obligations arising out of investors' claims and has no early prospect of being able to do so.

• (b) a Court of the Republic, has made a ruling, for reasons directly related to a member's financial circumstances, which has the effect of suspending investors' ability to make claims against it.

CySEC shall issue its decision for the initiation of the compensation payment procedure by the ICF within a reasonable time, and publish the relevant information on its website.

Upon initiation of the compensation payment procedure, the ICF shall publish as soon as possible in at least two national newspapers, an invitation to submit applications for compensation, designating the procedure for the submission of the relevant applications, the deadline for their submission as well as their content as defined specifically in this paragraph

The publication provided above shall include at least:

• (a) the name and address of the headquarters and the trade name of the involved ICF member;

• (b) the deadline for the submission of the compensation applications, which cannot be less than five months or more than nine months from the date of initiation of the compensation payment procedure, or from the date of its publication;

• (c) the mode of submission of applications;

• (d) the address and/or website through which Covered Clients may obtain the relevant claim form provided by the ICF, as provided for in Paragraph 22 of the CySEC Directive DI 87-07.

The said publication shall be communicated immediately to CySEC, which shall post the publication on its website.

The ICF shall issue a claim form setting out the information and supporting evidence required in order to evaluate the claims of covered investors. Without prejudice to this, the ICF may request additional information where deemed necessary. A claim must be submitted by completing the claim form issued by the Fund.

The ICF may record and assess the submitted claims, either internally or by designating at least one expert in capital market issues and at least one lawyer with knowledge on capital market issues, who after initially reviewing the “compensation payment conditions” as described below, shall evaluate the said applications and recommend to the Administrative Committee their acceptance or rejection, in whole or in part.

The Administrative Committee shall examine the applications before it and decide whether the compensation payment conditions are fulfilled or not.

The Administrative Committee shall reject the application if the claimant has used false or misleading means in order to secure the payment of the compensation.

Upon completion of the procedure before the Administrative Committee, the ICF shall:

• (a) issue a decision listing the clients of the ICF member, determining the amount of money each one of them is entitled to receive, and communicate it to CySEC and the ICF member within five working days from its issue. The said decision shall also list those clients to whom no compensation shall be paid, and the reasons for this.

• (b) communicate to each affected client its decision the soonest possible from its issue.

The claimant to whom the ICF communicates its decision, may, in case of disagreement, submit an objection in writing to CySEC, within one month from the date on which the decision was notified, justifying its objection sufficiently. The objection shall be submitted at info@cysec.gov.cy and entitled “Objection to the decision of the ICF”.

CySEC shall conclude the examination of the objection within forty-five (45) days and in case that it identifies an error/mistake in the evaluation made by the ICF, CySEC shall require the Fund to rectify the mistake and pay to the claimant the correct amount of compensation.

6. Compensation Payment Conditions

The payment of compensation by the ICF shall entail the following:

• (a) the initiation of the compensation payment procedure;

• (b) the existence of a valid claim by a Covered Client against the ICF member, which derives from an investment operation;

• (c) the submission of an application form as prescribed in the CySEC Directive DI 87-07;

• (d) that the claims do not arise from transactions for which there has been a criminal conviction for money laundering as defined in the Prevention and Suppression of Money Laundering Activities Law of 2007

• (e) there are no pending criminal proceedings against the said Covered Client for money laundering as defined in the Prevention and Suppression of Money Laundering Activities Law of 2007,;

• (f) the right of a covered client has not been extinguished under the Limitation of Offences Act.

Upon submission of a compensation application, the Administrative Committee examines whether the conditions of points (a) - (f) above are fulfilled.

As also stated above, the Administrative Committee rejects the compensation application in case the claimant-client used false or misleading means in order to secure the payment of the compensation by the Fund.

7. Amount of Compensation

• (a) The amount of the claim of a Covered Client shall be calculated based on legal and contractual conditions and terms governing the relation of the covered client with the members of the Fund, in particular those relating to offsetting and counterclaims, that are applicable to the assessment on the date of the initiation of the compensation payment procedure, of the amount of the funds or value determined with reference to the market value, where possible, of the financial instruments belonging to the Covered Client and which such funds or instruments, the ICF member fails to repay or return, respectively.

• (b) The calculation of the compensation payable shall arise from the sum of the total established claims of the Covered Client against the ICF member, arising from all covered services provided by the member and regardless of the number of accounts

• (c) The ICF shall provide coverage for the claims referred to in Paragraph 19 of the CySEC Directive DI 87-07, which applies for the total claims of the Covered Client against a ICF member and shall be defined as the lower of 90% of the cumulative covered claims of the Covered Client and €20.000.

• (d) In the case of joint investment business:

  • (i) in the calculation of the coverage provided for in subparagraph (b), the share attributable to each covered investor shall be taken into account;

  • (ii) the claims shall be allocated equally amongst covered investors, unless there exist special provisions, and without prejudice to point

  • (iii), each investor is provided with separate coverage pursuant to the provisions of subparagraph (b); claims relating to joint investment business to which two or more persons are entitled as members of a business partnership, association or grouping of a similar nature, which has no legal personality, shall, for the purpose of calculating the coverage provided for in subparagraph (a), be aggregated and treated as if arising from an investment made by a single investor.

• (e) Where a covered client is not the ultimate beneficiary of the funds or financial instruments held by the member:

  • (i) compensation shall be paid to the ultimate beneficiary if his identity is or may be established prior to the date of the determination or ruling referred to in paragraph 18(1) of the CySEC Directive DI 87-07.

  • (ii) if the ultimate beneficiaries are more than one, in the calculation of the coverage provided for, the share attributable to each one of them according to the arrangements regulating the management of the funds or financial instruments shall be taken into account. This section shall not apply to undertakings for collective investments.

• (f) Compensation shall be paid in Euro, and, where the funds and/or financial instruments are expressed in a currency other than the Euro, the exchange reference rate of the said currency against the Euro fixed by the European Central Bank at the end of the day on which the compensation payment procedure was activated, shall be used.

Legal: This website is operated by Trek Labs Europe Ltd (formerly FTX EU Ltd), registration number HE335683, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus. Trek Labs Europe Ltd (formerly FTX EU Ltd) is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) under license number 273/15.

Trek Labs Europe Ltd. dba Backpack EU

CONFLICTS OF INTEREST POLICY

1. Introduction and Scope

2 Backpack EU is a brand name owned and operated by Trek Labs Europe Ltd (formerly FTX EU and FTX EU Ltd, respectively) (hereinafter referred to as the “Company,” “Backpack EU,” “us,” or “we”), a company incorporated in Cyprus with registration number HE 335683 and authorised by the Cyprus Securities and Exchange Commission (“CySEC”) under license no. 273/15, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus.

This Conflicts of Interest Policy (the “Policy”) contains information on how the Company identifies, manages and where possible, mitigates, or where applicable, discloses any conflicts of interest which may arise during the course of the business relationship between the Company and its Clients..

The Company is committed to act honestly, fairly and professionally, and in the best interests of its Clients, and to abide by the principles set out in the applicable legislation.

This Policy is not intended to, and does not create third-party rights or duties that would not already exist if the Policy had not been made available.

2. Regulatory Framework

This Conflicts of Interest Policy is issued pursuant to, and in compliance with the requirements of:

• Directive 2014/65/EU of the European Parliament and of the Council on markets in financial instruments, as amended from time to time (‘’MiFID II ’);

• The Law 87(I)/2017 regarding the provision of financial services, the exercise of investment activities and the operation of regulated markets and other related matters, as amended from time to time (the ‘’Law’);

• The Commission Delegated Regulation (EU) 2017/565, supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards organizational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive;

• Regulation (EU) No 596/2014 of the European Parliament and of the Council of 16 April 2014 on market abuse (“Market Abuse Regulation”);

In accordance with the Commission Delegated Regulation (EU) 2017/565, Investment Firms are required to establish, implement and maintain an effective conflicts of interest policy set out in writing and appropriate to the size and organisation of the Investment Firm and the nature, scale and complexity of its business.

In addition, according to the Law, Investment Firms must take all appropriate steps to identify conflicts of interest between

• itself, including its managers and employees, tied agents or other relevant persons, as well as any person directly or indirectly linked to them by control, Backpack EU is a brand name of Trek Labs Europe Ltd (formerly FTX EU Ltd, referred to as “FTX EU”), a company regulated by the Cyprus Securities and Exchange Commission under license no. 273/15, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus.

• their Clients or

• between one client and another,

that arise in the course of providing any investment and ancillary services, including those caused by the receipt of inducements from third parties or by the Company’s own remuneration and other incentive structures.

In this respect, Investment Firms must establish adequate policies and procedures sufficient to ensure compliance, including its managers, employees, tied agents and other relevant person(s), with its obligations pursuant to the Law and the directives issued pursuant to this Law, as well as appropriate rules governing personal transactions by such persons. The conflicts of interest policy established in accordance with the above legal acts shall include the following content:

• it must identify, with reference to the specific investment services and activities and ancillary services carried out by or on behalf of the investment firm, the circumstances which constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more Clients;

• It must specify procedures to be followed and measures, including controlled access and permissions within our systems, granted to authorized personnel as necessary and subject to management approval, in order to manage such conflicts.

This procedure is aimed to:

• prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more Clients;

• ensure the separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, Clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company;

• remove of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities;

• ensure measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities;

• ensure measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of conflicts of interest.

The process entails the following actions:

• Identification of conflicts of interest situations

• Prevention and management of conflicts of Interest situations

• Disclosure of conflicts of interest in cases such situations cannot be contained.

• Keeping and updating records of identified conflict situations Definitions: 'Relevant person' in relation to the Company means any of the following persons:

• Member of the board of directors, partner or equivalent, manager or tied agent of the Company;

• A member of the board of directors, partner or equivalent, or manager of any tied agent of the Company;

• An employee of the Company or of a tied agent of the Company, as well as any other natural person whose services are placed at the disposal and under the control of the Company or a tied agent of the Company who is involved in the provision by the Company of investment services or/ and the performance of investment activities;

• A natural person who is directly involved in the provision of services to the Company or to its tied agent under an outsourcing arrangement for the purpose of the provision by the Company of investment services or/and the performance of investment activities.

3. Identification of Conflicts of Interest Situations

A conflict of interest is a situation, arising in any area of the Company’s business, where the Company or an employee of the Company is in a position to exploit a professional or official capacity in some way which may benefit the Company, or an employee of the Company, or a client of the Company, whilst potentially damaging the interest of another client of the Company.

The affected parties where conflicts of interest arise can be between the Company, its employees or its clients. More specifically, a conflict of interest may arise, between the following parties:

• Between the Client and the Company (or other companies within the same group., the employees and directors);

• Between two Clients of the Company;

• Between the Company and its employees;

• Between a Client of the Company and an employee/manager of the Company.

The Company offers a variety of investment and ancillary services and is a member of a group of companies (“the Backpack Group”) which includes offering of services outside of the European Union. Generally, it is not feasible to define precisely or create an exhaustive list of all the revenant conflicts of interest that may arise, as per the current nature, scale and complexity of the Company’s business. However, the following list includes circumstances identified by the Company which constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more Clients, as a result of providing investment or ancillary services:

• Conflicts in dealing in any capacity;

• Conflicts associated with holding confidential information;

• Conflicts associated with misuse of inside information;

• Conflicts arising out of the charges of fees and commissions;

• Conflicts in the Company’s business relations with the issuers of financial instruments or non-financial instruments;

• Conflicts arising out of the group structure; ● Conflicts arising in relation to inducements;

• Conflicts associated with performance-related remuneration of employees;

• Conflicts arising from personal transactions of employees For the purposes of identifying the types of conflicts of interest that arise in the course of providing investment services or a combination thereof and whose existence may damage the interests of a client, the Company takes into account, by way of minimum criteria, the question of whether the Company itself or a relevant person, or a person directly or indirectly linked by control to the Company is in any of the following situations, whether as a result of providing investment or ancillary services or investment activities or otherwise:

• The Company or that person is likely to make a financial gain, or avoid a financial loss, at the expense of the client;

• The Company or that person is interested in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client's interests;

• The Company or that person has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client;

• The Company or that person carries on the same business as the client;

• The Company or that person receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of money, goods or services, other than the standard commission or fee for that service;

• The Company or that person has a relation with the issuers of the products, e.g. close family relation;

• The Company or that person keeps investor accounts in other investment firms without the prior authorization from the Company;

• The Company or that person hides information from investors which they have right or access to;

• The Company or that person uses inside information or non-public proprietary information for own purposes;

• Use inside information or non-public proprietary information to manipulate or take advantage of such information;

• The Company or that person discloses inside information to other Company personnel who are not authorized to it.

In addition, the Company’s employees are prohibited from misusing “inside” information. Indicative cases of conflict of interests are listed below:

• Entering into unnecessary and unprofitable transactions for the client so as to increase the amount of commission and other fees

  • This can happen in auto-liquidation situations. The Company will mitigate this risk by only liquidating sufficient funds in order to reach the maintenance margin. Positions will not automatically be liquidated fully unless necessary.

• Using confidential information provided by the client for the Company’s own benefits or benefits of its employees or third parties.

The following procedure sets out actions for avoidance and resolution of conflicts of interest situations by the Company. The procedure is communicated to all members of the Company and includes measures specifically required by CySEC and the Company.

4. Reporting Conflicts of Interest

In the case of identification of a possible conflict of interest, a staff member must refer it initially to their immediate supervisor to assist in the assessment of a risk of damage and send to the Company’s Head of Compliance a completed Conflict of Interest Notification Form together with full details (i.e. under what grounds he/ she believes the conflict of interest arises) to allow regulatory scrutiny, of:

• Corrective and preventing actions;

• How these actions were considered appropriate;

• Any conditions imposed; and

• Whether there are still ongoing conflicts, how these are being managed and advised to the client.

Based on the above it is the Management role to adopt a holistic view to ensure the identification of potential and emerging conflicts within and across business lines and support an independent review of the processes and procedures in place.

5. Managing Conflicts of Interest

In general, the procedures and controls that the Company follows to manage any identified conflicts include the following, but not limited to, measures (non-exhaustive list of measures):

5.1 Disclosure

The employees of the Company are obliged to disclose all business interests before commencing their employment with the Company and are under an obligation to update the Company of any changes to such business interests throughout their employment with the Company.

5.2 Independence

The following measures have been adopted by the Company for ensuring the requisite degree of independence:

• Measures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest (i.e. by establishing a Chinese Wall).

• Separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, Clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company. The Company’s department whose interests may conflict with Clients is the Market Surveillance Department and/ or the Marketing Department.

• Removal of any direct link between the remuneration of relevant persons principally engaged with one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities:

  • When the Company’s Management decides to reward employees with a variable remuneration, the Company checks and ensures that (1) the annual variable remuneration of any employee cannot exceed his/her annual fixed remuneration; (2) that the variable remuneration package does not lead to aggressive behaviour that might be for the detriment of Clients.

  • The Compliance Officer is required to approve all variable remuneration schemes, and the Company is required to disclose or make readily available these schemes to all Clients as a measure of last resort where the effective organisational and administrative arrangements established by the Company to prevent or manage its conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of the client will be prevented.

● Measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out and/or promotes investment or ancillary services or activities. Additionally, the person who decides or influences an individual’s bonus may exert undue influence over that individual’s integrity of judgement.

● Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities such as reception and transmission of Clients’ orders and tasks such as portfolio decision making and calculating performance, where such involvement may impair the proper management of conflicts of interest.

5.3 Chinese Wall

Chinese walls are information barriers which are used to prevent inside or highly confidential information possessed by one part of the business from being inappropriately passed to, or obtained by, another part of the business.

When a Chinese wall is used as a way of managing conflicts of interests, individuals on the other side of the wall will not be regarded as being in possession of knowledge denied to them as a result of the Chinese wall. For example, where arrangements have been put in place to ensure that entities belonging to the same group operate independently of each other with effective Chinese walls, the entities shall not be deemed to have knowledge of each other for conflicts of interest purposes.

The Company has taken appropriate measures to restrict the flow of information and data between the various business units within the Company. First and foremost, the Management bestowed upon the Compliance Department enough executive authority to establish and safeguard its independence from all other Departments within the Company. The Compliance Officer has unrestricted access to all information and to all Departments and reports directly to the Board of Directors and Four Eyes Committee (if applicable). The Company ensures that the provision/ receipt of inducements by the Company or relevant persons comply with the applicable inducements’ rules/ restrictions.

The Company has implemented Chinese walls around the following business areas:

• the Company and any group entity,

• Internal Audit Function, Risk Management Function and Compliance Function.

The Company has taken appropriate measures to restrict the flow of information between certain Departments / Functions within the Company. As a first step, the Management authorized the Compliance Department to establish and safeguard its independence from all other Departments / Functions within the Company. The Head of Compliance has unrestricted access to all information and to all Departments and reports directly to the Board of Directors and Four Eyes Committee (if applicable). The same applies to the Internal Auditor Function.

Persons and entities located within a Chinese wall are prohibited from inappropriately passing information to those outside the wall, except with the approval of the Company’s Head of Compliance where it is appropriate to the service being provided to the clients. More specifically, no person shall replace another person in his/ her duties without the prior consent and approval of the Compliance Officer in accordance with the Company’s Replacement Policy. Such a consent will be given by the Compliance Officer after all issues of possible conflict of interest have been reviewed.

The Company ensures that the provision/ receipt of inducements by the Company or relevant persons comply with the applicable inducements' rules/ restrictions.

In addition, the Company ensures that physical separation and relevant protocols (electronic means) are established such as - access rights in the trading platforms, restricted access to certain databases, electronic controls, practices and communication protocols - to prevent and control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of conflicts of interest, for the following business units:

• Compliance Department

• Back Office Function

• Accounting Department

• Brokerage Department

• Trading and own account

• Marketing Function

All control functions (i.e. the Compliance Officer, Risk Manager, Internal Auditor, External Auditor) are reporting directly to the Board of Directors and Four Eyes Committee and are strictly prohibited from making their annual and/ or other reports available to any employee, from any Department, prior to communicating the reports to the Board and Four Eyes Committee (if applicable) and obtaining their consent.

Additionally, the Company has in place non-disclosure and confidentiality agreements with all its Service Providers in relation to Clients’ personal data and information. Specifically, the dissemination of confidential information between the Company, its related parties and Services Providers is at all times subject to established information barriers.

6. Personal Transaction of Employees

All employees of the Company that are involved in activities that the Company is authorised to provide must be aware of the restrictions on personal transactions detailed below. This section also includes personal transactions which may be performed by persons who are employed by companies which perform an outsourced activity to the Company, if any. If any personal transactions are entered into by a relevant person as indicated above, the Company must be notified promptly.

For the purpose of this section, a personal transaction shall be a trade in a financial instrument effected by or on behalf of a relevant person, where at least one of the following criteria are met:

• the relevant person is acting outside the scope of the activities they carry out in their professional capacity;

• the trade is carried out for the account of any of the following persons:

  • The relevant person;

  • Any person with whom they have a family relationship, or with whom they have close links;

  • A person in respect of whom the relevant person has a direct or indirect material interest in the outcome of the trade, other than obtaining a fee or commission for the execution of the trade.

  Employees of the Company that are involved in the provision of investment services or other activities must not enter into the personal transactions which will cause the following:

• Enter into a transaction prohibited under the provisions of the Market Abuse Regulation,

• Misuse or cause improper disclosure of confidential information,

• Enter in a transaction that is likely to conflict with any obligations of the Company, or the employee, that are stated under the Law.

Where the employee has come into contact with information which is not publicly available to Clients or cannot readily be inferred from information that is so available, the employees must not act or undertake personal transactions or trade in the execution of an unsolicited client order, on behalf of any other person, including the Company.

The employees must not disclose any opinion other than in the normal course of business, if the person who is given the opinion is likely to enter into a transaction which is contrary to the above.

The employee also should not provide advice or provide to anyone any information, other than in the proper course of their employment, especially if it is clear that the person who is receiving such information will advise another party who might acquire or dispose of financial instruments to which that information relates.

Any client’s orders that have been relayed to any employees of the Company must not be disclosed to another party. An employee of the Company who has knowledge of a potential client’s order must not carry out a personal transaction that is the same as the client order, if this will cause a conflict of interest.

The Company shall keep records of the personal transactions notified to or identified by the Company, including any authorization or prohibition in connection with such transaction.

6.1 Disclosure of conflict of interest

When the measures taken by the Company to manage conflicts of interest are not sufficient to ensure, with reasonable confidence that risks of damage to Clients’ interest will be prevented, the Company proceeds with the disclosure of conflicts of interest to the client. Prior to carrying out a transaction or providing an investment or an ancillary service to a client, the Company must disclose any actual or potential conflict of interest to the client. The disclosure will be made in sufficient time and in a durable means and shall include sufficient detail, considering the nature of the client, to enable him to take an informed decision with respect to the investment or ancillary service in the context of which the conflict of interest arises.

Clients will be given the opportunity to decide on whether or not to continue their relationship with us with no unreasonable obstacles.

The Company shall ensure that disclosure to clients pursuant to this section is a measure of last resort that shall be used only where the effective arrangements established by the Company to prevent or manage its conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of the client will be prevented.

The disclosure should:

• clearly state that the organizational and administrative arrangements established by the Company to prevent or manage that conflict are not sufficient to ensure, with reasonable confidence, that the risks of damage to the interests of the client will be prevented;

• include specific description of the conflicts of interest that arise in the provision of investment and/or ancillary services, considering the nature of the client to whom the disclosure is being made. The description shall explain in sufficient detail to enable that client to take an informed decision with respect to the investment or ancillary service in the context of which the conflicts of interest arise:

  • the general nature and sources of conflicts of interest;

  • the risks to the client that arise as a result of the conflicts of interest; and

  • the steps undertaken to mitigate these risks.

  In the event that the Company is unable to deal with a conflict of interest situation it shall revert to the client and in the cases where the line management cannot resolve a conflict to the satisfaction of all parties, the Head of Compliance, shall have the final say for the decision.

6.2 Record Keeping

The Company’s Head of Compliance keeps and regularly updates a record of the kinds of investment and ancillary service or investment activity carried out by or on behalf of the Company in which a conflict of interest entailing a risk of damage to the interests of one or more Clients has arisen or, in the case of an ongoing service or activity, may arise.

The following documentation shall be maintained for a minimum period of five (5) years: ● This Policy, any functional variations if applicable;

• The internal Conflicts Log and the Conflicts Identification and Management Report;

• Rules, procedures and processes;

• Training material and training records;

• Conflicts of Interest Notification Forms;

• Details of any review work carried out (including any decisions made on conflicts management); and

• Any other documentation used to demonstrate the management of conflicts of interest.

Senior management shall receive on a frequent basis, and at least annually, written reports on situations referred to in this section.

6.3 Responsibilities

The Company’s Executive Directors are responsible for clearly allocating responsibility and delegating authority to accountable individuals to ensure that those involved are aware of their involvement and that the Conflict Officer has a sufficient level of authority and independence in order to carry out their responsibilities effectively.

The Company’s Senior Management is required to:

• fully engage in the implementation of policies, procedures and arrangements for the identification, management and ongoing monitoring of conflicts of interest;

• adopt a holistic view to ensure the identification of potential and emerging conflicts within and across business lines;

• raise awareness and ensure compliance of relevant individuals by ensuring: regular training (including to contractors and third-party service providers’ staff) both at induction and in the form of refresher training; the clear communication of policies, procedures and expectations; that awareness of conflicts procedures forms part of the performance review/ appraisal process, and that the best practice is shared throughout the Company;

• sponsor robust systems and controls and effective regular reviews to ensure that strategies and controls used to manage and mitigate risks remain appropriate and effective and that appropriate warnings and disclosures are issued to clients where necessary;

• utilize management information to remain sufficiently up-to-date and informed; and

• support an independent review of the processes and procedures in place.

Individuals are required to identify new conflicts of interest arising out of the activities/services that they perform and engage in the process to notify line management upon identifying any potential conflict.

The Company’s Head of Compliance who is responsible for the day to day management of the implementation of this policy. In particular, he, or his delegate, is responsible for:

• establishing the policy in relation to conflicts of interest; ● providing training oversight and aid;

• monitoring compliance with arrangements;

• the oversight of conflicts management; ● maintaining records in relation to conflicts of interest;

• whether a conflict of interest should be disclosed in line with the principles of this policy;

• reviewing and challenging the identification of conflicts and implementing any management actions; and

• providing appropriate internal reporting to the Board of Directors.

Overall, the Compliance Officer will monitor the application and effectiveness of the present Policy on a regular basis and may amend the current Policy at any time if it is deemed appropriate and necessary. The review will be carried out at least annually and the Company’s Senior Management shall take all appropriate measures to address any deficiencies which might be identified by the Compliance Officer.

7. Clients’ Consent

During the procedure of the Company entering into an agreement with the clients, for the provision of Investment and/or ancillary services, requests the clients’ consent to the application of the present Policy. Following the clients’ consent, the Company is authorized and able to deal with the clients in any manner the Company considers appropriate, notwithstanding any conflicts of interest or the existence of any material interest within transactions, without prior reference to the clients.

8. Review of the Policy

The Company reserves the right to amend the current Policy at its discretion and at any time it considers is suitable and appropriate.

Legal: This website is operated by Trek Labs Europe Ltd (formerly FTX EU Ltd), registration number HE335683, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus. Trek Labs Europe Ltd (formerly FTX EU Ltd) is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) under license number 273/15.

Trek Labs Europe Ltd. dba Backpack EU

COMPLAINTS HANDLING POLICY

1. Introduction

Backpack EU is a brand name owned and operated by Trek Labs Europe Ltd (formerly FTX EU and FTX EU Ltd, respectively) (hereinafter referred to as the “Company,” “Backpack EU,” “us,” or “we”), a company incorporated in Cyprus with registration number HE 335683 and authorised by the Cyprus Securities and Exchange Commission (“CySEC”) under license no. 273/15, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus.

This Policy and procedures detail how Trek Lab Europe Ltd (the “Company”) will deal with complaints when carrying out its business.

The Company is authorised by the Cyprus Securities and Exchange Commission (“CySEC”) as a Cyprus Investment Firm (CIF) and, as such, will act in accordance with the applicable framework relating to complaints handling from time to time.

2. General Framework

The Policy has been prepared in accordance with the following laws, regulations, directives and guidelines (the “Regulatory Framework”):

• Law 87(I)2017 regarding the provision of Investment Services, the exercise of investment activities and the operation of regulated markets (the “Law”);

• Commission Delegated Regulation (EU) 2017/565 of 25 April 2016 supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards organisational requirements and operating conditions for investment firms;

• CySEC Circular C338 - Guidelines on complaints-handling for the securities sector - Handling of client’s complaints by CIFs

3. General Scope of the complaints handling Procedure

The Company acting as a Cyprus Investment Firm and in accordance with the relevant provisions of the Law is required to have in place and disclose to its clients a Complaints Handling Procedure which is described in this document.

The Complaints Handling Procedure ('the Procedure') describes a fair and quick process of dealing and handling client's complaints that may arise from our relationship with clients. The purpose of the Procedure is to set out the internal complaint resolution mechanism which the Company has established, maintains and follows towards the resolution of complaints.

4. General Definition of an inquiry and complaint

If you are disappointed with the Company’s services, or you have any inquiries regarding your account or trading activity with us, you may contact our Customer Support Department via live chat, email or telephone.

The Company’s Customer Support Department shall determine if your inquiry can be resolved immediately or if it will require further investigation. In case your inquiry requires further investigation, we remain committed in addressing it and/or providing an outcome without undue delay.

If you are dissatisfied with the outcome of the inquiry, then you may raise this further with the Compliance Department following the process indicated in the following section.

An official complaint is an expression of dissatisfaction by a client regarding the provision of investment and/or ancillary services provided by the Company. Only a complaint submitted via the procedure outlined below shall be recorded as a Complaint by the Company and will be handled as such.

The Company considers important and essential to pay the proper attention to each and every complaint made by a client, irrelevant of the subject matter of the complaint.

5. Procedure

The Company shall establish a complaints management function responsible for the investigation of complaints.

The client may submit a complaint addressed to the Customer Support Department which will assist the Compliance Department to resolve the complaint based on the procedure mentioned in the following paragraphs, and by liaising with all departments/personnel that are connected with the complaint(s) received.

The client is encouraged to submit a complaint to the Company regarding the products and the services offered by the Company in any of the following ways:

• a) By sending by post or delivering in person a letter which will include all of the following information:

  • The client's full name

  • The client's trading account number

  • The Client's address and email address

  • The affected transaction(s) number (if applicable)

  • Date and time that the issue causing the complaint arose

  • A full and clear description of the issue causing the complaint/content of the complaint

    • The extent in financial terms of the potential loss that the Client claims has suffered

    • Reference to any correspondence exchanged between the Company and the client (such correspondence should be attached)

• b) By completing the Complaints Form, which can be found in Appendix A of this Procedure, and to be submitted via email at compliance@eu.backpack.exchange

Once a complaint is received by the Customer Support Department, and fulfils the above requirements, the following shall apply:

• A written acknowledgment from the Customer Support Department shall be sent to the client within five (5) days confirming receipt of the complaint and the estimated time under which the client shall be given a reply, and providing a unique reference number to the client for the specific complaint in accordance with CySEC's Circular C338; the client is advised to save his/her unique reference number to be used in all future contact with the Company, the Financial Ombudsman and/or the CySEC regarding the specific complaint;

• The Customer Support Department shall register the complaint directly to the Company's internal register, as soon as possible and in an appropriate manner (by including inter alia, the unique reference number provided to complaints);

• Within two (2) months of receipt, the Company shall investigate and send to the client a Final Response or a holding response, which will explain why it is not yet in a position to resolve the complaint and give an indication of when further contact shall be made. In such case a final answer to the Complaint shall be given within three (3) months from the date of reception of the complaint;

Upon completion of the investigation the Company shall send a written notice to the complainant informing him/ her of the outcome of the investigation along with the reasons for reaching such a decision or – if applicable – the nature and terms of any offer and/ or settlement.

• Please note that the Company shall consider complaint as closed when a period of three (3) months has elapsed from the date of submission of the complaint.

The responsible Departments shall thoroughly examine complaints taking into account all available relevant information including but not limited to the information contained in the books and records of the Company and the client's trading account journal and reach a fair and reasonable outcome.

Clients or potential clients can submit complaints to the Company free of charge. When handling a complaint, communication with clients or potential clients shall be clear, in plain language that is easy to understand.

All complaints will be treated with confidentiality.

6. Records and Reporting

The Company shall keep and continuously update records of all the complaints received by clients with details of the investigation conducted, the final outcome of these, any measures taken for their resolution and all the communication with the clients. The Company maintains an internal registry where all relevant details/information are maintained and the Customer Support Department is responsible to duly complete and/or update such accordingly.

Furthermore, the Company shall report on a monthly basis to CySEC information regarding Client complaints filed to the Company and how these are being handled, as per the requirements of CySEC's Circular C338.

7. Review of the policy

This policy shall be regularly reviewed and updated by the Compliance Function in line with applicable legislation updates and when considered necessary and each updated version shall be approved by the Company's Board of Directors.

The Company will inform its clients of any material changes to this procedure by posting the updated version of the policy on its Website.

8. Client’s dissatisfaction

In cases where a client is dissatisfied with the Company's approach and final response, the client may directly submit his/her complaint to the Financial Ombudsman Service or to the Cyprus Securities and Exchange Commission (CySEC).

Please refer to the information provided below.

If you are an individual, or a legal entity, trust or charitable entity that can be categorized as a consumer under the legislation governing the creation and operation of an Alternative Dispute Resolution framework in Cyprus (Financial Ombudsman), you are entitled to escalate the complaint to the Financial Ombudsman if the solution or action taken / provided by the Company is not to your satisfaction or if the Company does not respond at all.

In addition, clients may address their complaints to the Financial Ombudsman of Cyprus, provided that each complaint does not exceed the amount of two hundred and fifty thousand euro (250.000) within four (4) months from either the date of receipt of the reply from the Company or the deadline of the three (3) month period during which the Company had to respond to the client.

Contact Details of the Financial Ombudsman of the Republic of Cyprus:

Website: http://www.financialombudsman.gov.cy

Email: complaints@financialombudsman.gov.cy

Postal Address: P.O. BOX: 25735, 1311 Nicosia, Cyprus

Telephone: +35722848900

Fax: +35722660584, +35722660118

Contact Details of the Cyprus Securities and Exchange Commission:

Website: http://www.cysec.gov.cy

General email: info@cysec.gov.cy

Postal Address: P.O. BOX 24996, 1306 Nicosia, Cyprus

Telephone: +35722506600 Fax: +35722506700

For any further questions of information, do not hesitate to contact us at: support@eu.backpack.exchange.

Appendix A

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Legal: This website is operated by Trek Labs Europe Ltd (formerly FTX EU Ltd), registration number HE335683, with registered address at Aiolou & Panagioti Diomidous 9, Katholiki, 3020 Limassol, Cyprus. Trek Labs Europe Ltd (formerly FTX EU Ltd) is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) under license number 273/15.