PUBLIC OFFER

for entering into the Partner Agreement

1. Document Status

1.1. This document constitutes the Operator's public offer to enter into the Partner Agreement.

1.2. Acceptance of the offer shall be deemed the registration in the Partner Dashboard and the completion of the first purchase of internal accounting units (RUB).

1.3. As of the moment of acceptance, the Partner confirms its agreement with all terms and conditions of this offer.

2. Independence of the Parties

2.1. The Partner is an independent business entity.

2.2. The Partner acts:

• in its own name,
• at its own expense,
• at its own entrepreneurial risk.

2.3. The Parties do not have:

• agency relationships,
• mandate relationships,
• joint activity (partnership) relationships,
• representation relationships,
• employment relationships.

2.4. The Partner may not:

• assume obligations on behalf of the Operator,
• present itself as a branch or representative of the Operator,
• use wording that creates an impression of dependence.

3. Subject of the Agreement

3.1. The Operator grants the Partner the right to purchase internal accounting units (RUB) for subsequent independent resale to third parties.

3.2. The Partner independently:

• sets the resale price,
• determines the transaction terms,
• bears the risk of changes in the exchange rate and liquidity.

3.3. The Operator does not participate in the Partner's B2C relationships with its clients.

4. Procedure for Purchasing RUB

4.1. The Partner purchases RUB in the manner established by the Platform interface.

4.2. RUB purchases are made regardless of the availability of specific clients.

4.3. The Operator does not guarantee automatic replenishment of the Partner's balance.

4.4. Settlements for the purchase of RUB are made exclusively within B2B relationships.

5. Resale to End Clients

5.1. The Partner independently enters into agreements with end clients.

5.2. The Partner independently:

• accepts funds,
• issues receipts and other mandatory documents,
• complies with the applicable legal requirements governing payments and settlements.

5.3. The Operator is not a party to agreements between the Partner and clients.

5.4. Funds received by the Partner from clients are not funds received for the benefit of the Operator.

6. Partner's Compliance and Regulatory Obligations

6.1. The Partner undertakes to independently comply with:

• legislation governing payments and settlements,
• tax legislation,
• AML/CFT requirements,
• personal data protection requirements,
• other applicable norms.

6.2. The Partner confirms that it has:

• the necessary registrations,
• permits/authorizations,
• cash-handling and cash register compliance,
• tax accounting.

6.3. The Partner undertakes not to carry out activities requiring licensing without the relevant authorization.

6.4. The Partner independently bears responsibility before governmental authorities.

7. No Guaranteed Liquidity

7.1. The Operator does not guarantee the repurchase (buy-back) of RUB.

7.2. The Operator is not obliged to maintain the RUB rate.

7.3. The Partner assumes the risk of changes in the market value of RUB.

7.4. Any decisions to buy back RUB from clients are made by the Partner independently.

8. Separation of Cash Flows

8.1. The Operator does not accept cash from the Partner's clients.

8.2. The Partner independently disposes of funds received from clients.

8.3. The Operator does not control the Partner's fiat settlements.

9. Inspections and Audit

9.1. The Operator may request from the Partner confirmation of compliance with the law.

9.2. If violations are identified, the Operator may:

• restrict access to the Platform,
• suspend cooperation,
• terminate the agreement unilaterally.

10. Indemnification

10.1. The Partner undertakes to indemnify the Operator for losses arising as a result of:

• violations of law,
• misleading clients,
• holding itself out as a representative of the Operator.

11. Reputation Restrictions

11.1. The Partner undertakes not to use the Operator's brand in ways that may create the impression of structural dependence.

11.2. Any advertising activity shall be agreed separately.

12. Termination of Cooperation

12.1. The Operator may terminate cooperation in case of:

• violations of law,
• regulatory risks arising,
• a threat to the Platform's reputation.

12.2. After termination, the Partner must fulfil its obligations to its clients independently.

13. Governing Law and Disputes

13.1. This Agreement shall be governed by the law of the Operator's jurisdiction of registration.

13.2. Disputes shall be resolved in the arbitration agreed by the Parties.

APPENDIX 1. Partner Compliance Checklist

• Customer identification prior to the transaction (as required).
• Verification of documents and recording of the outcome.
• Sanctions screening / PEP screening (if applicable).
• Transaction logging (date, amount, employee, method).
• Record retention and availability for audit.
• Refusal procedures in case of AML risks.
• Staff training and appointment of a responsible officer.