TERMS & CONDITIONS

STEEL PRIVATE BANK TERMS AND CONDITIONS

Effective Date: April 9, 2025

Last Updated: April 9, 2025

Welcome to Steel Private Bank (“Bank,” “we,” “us,” or “our”). By accessing and using our website steelprivatebank.com (the “Website”) and our online banking services (the “Services”), you confirm that you have reviewed, understood, and agree to comply with the following

important legal information and Terms and Conditions. If you do not agree to Terms, please exit and do not use this Website or Services.

1. Introduction

A. These Terms and Conditions govern the use of Steel Private Bank’s Website and online banking platform.

B. These are the terms and conditions that will govern your relationship with the Bank and a Steel Private Bank Client, which are also referenced in your Service Agreement. While we have prepared key points for your easy reference, they are not meant to be a substitute for reading the details of the Agreement and you should familiarize yourself with all aspects of the Agreement.

By accessing our Website, you acknowledge that you understand and accept these Terms and our Privacy Policy.

C. We reserve the right to update or modify these Terms at any time without notice or access to, and use of the site may be restricted or terminated at any time. You are therefore advised to review these terms each time you access this website. Continued use of the

Website after changes signifies your acceptance of the revised Terms.

D. Access to and use of the site as well as the terms are governed by Mwali law.

2. Eligibility & User Obligations

A. You must be at least 18 years old and have legal capacity to enter into financial

agreements.

B. You agree to provide accurate and complete information when registering or conducting transactions.

C. You must not use the Website for any fraudulent, unlawful, or prohibited activities, including but not limited to money laundering, terrorism financing, or unauthorized trading.

D. The information, products, data, services, tools and documents contained or described on this site (the “Content”) are for informational purposes only and constitute neither an advertisement or recommendation nor an offer of solicitation to buy or sell investment

instruments, to effect any transaction or to enter into any legal relations.

E. The Financial products mentioned on this site are not suitable for all investors. Prior to making investment decisions investors should conduct a thorough investigation and obtain all necessary professional advice for all issues, including your eligibility to make

such investment in terms of the applicable law.

F. Nothing on this website constitutes investment, legal, financial, accounting or tax advice, or a representation that any investment or strategy is suitable or appropriate for individuals circumstances, or otherwise constitutes a personal recommendation for any

specific investor. Steel Private Bank recommends that investors and clients independently consult with a professional advisor, the specific financial risk as well as legal, regulatory,

credit, tax and accounting consequences.

3. Offshore Banking Services

A. The Bank offers private offshore banking services, including but not limited to account management, international wire transfers, wealth management, and investment advisory.

B. Access to specific banking services may be subject to jurisdictional restrictions and compliance with applicable regulations.

C. We may impose transaction limits, verification requirements, and due diligence checks as per our compliance policies.

D. The content provided on this website is not intended for use by or distribution to any individual or legal entity in any jurisdiction or country where such distribution, publication or use would be contrary to the law or regulatory provisions or in which members of the Group of entitles controlled by Steel Private Bank, does not hold the necessary registration or license. Individuals or legal entities in respect of whom such prohibitions apply, whether on grounds of their nationality, their place of residence or on other grounds, must not access or use the website.

E. Some entities, services, and products of Steel Private Bank may not be registered or licensed under legal and regulatory provisions governing financial services or products and their providers in certain countries, including the United States, the United Kingdom of Great Britain and Northern Ireland (U.K.), Canada, Japan, India, Italy, Spain, China

and other countries. Therefore, all users are requested to contact us to request information about products and services available in their country.

4. Security & Privacy

A. The Bank employs industry-standard encryption and cybersecurity measures; however, you acknowledge that online transactions carry inherent risks.

B. You are responsible for safeguarding your login credentials and account information. The Bank is not liable for unauthorized access resulting from your failure to maintain security.

C. All customer data is handled in accordance with our Privacy Policy, and we comply with international data protection regulations where applicable.

5. Fees & Charges

A. The Bank reserves the right to modify fee structures at any time with prior notice.

6. Transactions & Liability

A. All transactions conducted via the Bank’s online platform are subject to review and compliance verification.

B. The Bank is not responsible for losses due to currency fluctuations, third-party

transaction failures, or delays caused by international banking regulations

C. In case of unauthorized transactions, you must notify us immediately. Liability for fraudulent or disputed transactions will be determined based on our internal policies and applicable laws.

7. Third-Party Links & Services

A. Our Website may contain links to third-party sites, payment processors, or financial service providers. We are not responsible for their content, policies, or security.

B. Use of third-party services may be subject to additional terms and conditions imposed by those providers.

8. Compliance & Anti-Money Laundering (AML) Policies

A. The Bank complies with international AML, KYC (Know Your Customer), and CTF (Counter-Terrorism Financing) regulations.

B. We reserve the right to request additional documentation, freeze accounts, or report suspicious activities to relevant authorities without prior notice.

B. You represent and warrant that all funds deposited are legally obtained and not derived from illicit activities.

9. Dispute Resolution

A. Any disputes arising from the use of our Website or Services shall first be resolved through negotiation.

B. If a resolution is not reached, disputes shall be submitted to arbitration in Switzerland, in accordance with Chapter 12 (Articles 176-194) of the Swiss Private International Law Act (PILA).

C. You agree that the courts of Switzerland shall have exclusive jurisdiction over any legal

claims.

10. Intellectual Property & Copyright

A. All content on the Website, including text, logos, and software, is the property of the Bank and is protected by intellectual property rights and is the sole and exclusive property of Steel Private Bank.

B. You may not reproduce, modify, or distribute our content without explicit permission.

C. Except as expressly agreed in writing or to the extent necessary to use this Website in accordance with these Terms, you shall not: (i) copy the site in whole or in part, (ii) display, created derivative works from, sell transmit, rent lease, sublicense, or transfer in

any way exploit the website.

D. Except as expressly agreed in writing, you may not remove or obscure any copyright notice of Steel Private Bank, or any of its subsidiaries, suppliers, or strategic partners. You may also not use any of its trademarks, service marks, domain names, logos, or other

identifiers of Steel Private Bank or any of its subsidiaries.

E. Except to the extent permitted under law, you should not reverse engineer, decompile, dissemble, or access the source code of the Website.

11. Disclaimer of Warranties & Limitation of Liability

A. The Bank provides its Website and Services “as is” and makes no guarantees regarding uninterrupted access, accuracy, or completeness.

B. The Bank shall not be liable for any indirect, incidental, or consequential damages arising from the use of its Website or Services.

C. Except to the extent required by current laws and/or regulations, Steel Private Bank, including its directors, agents, employees or subcontractors: (1) disclaims any and all express or implied warranties and conditions including without limitation warranties and

conditions as to quality and fitness for a particular purpose; and (2) does not warrant that the Site, any content (including any third party content), goods and services referred to therein will be uninterrupted or error free, that defects will be corrected or that the Site,

the servers from which it is available or any connected website is free of viruses, trojan horses, worms, software bombs or similar items or processes or other harmful components. In order to safeguard against viruses, it is advisable to use up-to-date versions of browsers and to install and continuously update antivirus software. Users should strictly avoid opening e-mails of unknown origin or unexpected e-mail

attachments.

D. Any data, including but not limited to financial market data, quotes, notices, research or other financial information accessible through this Site, have been obtained from carefully selected sources believed to be reliable. All such information is provided “as is”

to the user without express or implied warranties of any kind, including warranties of quality, originality, non-infringement of intellectual property or fitness for any particular

purpose.

E. The information and opinions in the Site are descriptive of Steel Private Bank as a whole and the products and services described may not be available to or suitable for all investors. The fact that a user accesses the Site does not make him or her a client of Steel

Private Bank.

F. Any expressions of opinion, estimates and projections on the Site are those of the authors at the date of writing. They do not necessarily reflect the view of Steel Private Bank and are subject to change at any time without prior warning. Steel Private Bank and its

contractual partners may discontinue, or make changes in, the information, data and documents, and the products or services described herein, at any time without prior notice. Any information marked with a date is published as of this date only and no obligation or responsibility is undertaken to update or amend any such information.

G. To the maximum extent permitted by current laws and regulations, Steel Private Bank disclaims any and all liability for losses or damages of any nature arising either directly or indirectly as a result of the content, or accuracy on this website, or third party content

or links provided on this website; from any errors or omissions on this website; from use or access to this website; from inability to use or access the website for any reason.

H. To the maximum extent permitted by applicable laws and regulations, Steel Private Bank shall not be liable for any (i) loss of profits or revenue, savings, or any other economic loss, (ii) loss or damage to any data, (iii) loss of business, goodwill, or wasted or lost

time, (iv) incidental or special losses, or (v) indirect or consequential losses arising from the access to or use of this website, even of such loss was foreseeable and regardless to if

the user was advised of the possibility of such loss or damage.

12. Governing Law

A. These Terms shall be governed by and construed in accordance with the laws of Mwali.

13. Amendments & Termination

A. The Bank reserves the right to modify these Terms at any time.

B. The Bank may terminate or restrict access to Services at its sole discretion, with or without cause.

14. Contact Information

If you have any questions regarding these Terms, please contact us at: Info@steelprivatebank.com

Steel Private Bank