No Investment Advice, No Discretion & Execution-Only Disclaimer

1. Purpose and Legal Status

This No Investment Advice, No Discretion & Execution-Only Disclaimer (the "Disclaimer") is published to clearly define the legal nature of the services provided across the Polar Tensor™ group and to prevent any misunderstanding regarding the characterisation of such services under applicable financial laws and regulations.

This Disclaimer forms an integral part of the contractual and pre-contractual disclosures made available to users and must be read together with the applicable Terms and Conditions, Risk Disclosure Statement, and customer agreements.

2. No Investment Advice

No entity within the group:

  • provides investment advice, financial advice, or trading advice;
  • issues recommendations regarding the purchase, sale, holding, or allocation of any digital asset;
  • provides opinions on the suitability or appropriateness of any transaction or strategy; or
  • acts as an investment adviser, financial adviser, or similar regulated advisory service provider.

All information made available through websites, dashboards, software interfaces, documentation, or communications is general, factual, and informational in nature only.

3. No Discretionary Portfolio Management

The services provided do not involve discretionary management of client assets.

Specifically:

  • no entity has discretionary authority over client accounts;
  • no entity makes decisions on behalf of clients regarding when or how assets are traded;
  • no individualised or client-specific investment decisions are taken; and
  • no mandate, power of attorney, or discretionary control is granted.

Clients retain full and continuous control over their assets, including the ability to activate or deactivate any automated functionality and to withdraw assets in accordance with applicable terms.

4. Execution-Only and Technology-Based Services

Automated trading functionality, where offered, operates exclusively as execution-only technology.

Key characteristics include:

  • trading logic is predefined, system-driven, and uniformly applied;
  • trading execution occurs only following explicit, manual client activation;
  • no human discretion is applied on a client-specific basis; and
  • execution is limited to spot market transactions.

The technology facilitates order execution but does not replace or override client decision-making.

5. No Fiduciary Relationship

Use of the services does not create:

  • a fiduciary relationship;
  • a trustee relationship;
  • an advisory relationship; or
  • a relationship of reliance or confidence beyond that expressly stated in contractual documentation.

Each client acts independently and bears sole responsibility for their decisions and actions.

6. No Guarantees or Representations

No representations, warranties, or assurances are made regarding:

  • profitability or returns;
  • performance outcomes;
  • capital preservation; or
  • risk mitigation.

Any references to historical data, hypothetical performance, or illustrative examples are provided solely for explanatory purposes and do not constitute promises or expectations of future results.

7. Client Responsibility

Clients are solely responsible for:

  • determining whether to use any service or functionality;
  • assessing whether the services are suitable for their individual circumstances;
  • monitoring their accounts and activity; and
  • complying with applicable laws and regulations in their jurisdiction.

Clients should seek independent professional advice where they have any uncertainty.

8. Regulatory Interpretation

This Disclaimer is intended to reflect and preserve the correct regulatory characterisation of the services as:

  • non-advisory;
  • non-discretionary;
  • execution-only; and
  • technology-enabled.

Nothing in the services, communications, or documentation should be interpreted as creating regulated investment advisory, portfolio management, or collective investment activity.

9. Prevailing Terms

In the event of any inconsistency between this Disclaimer and any binding agreement, the terms of the applicable customer agreement shall prevail.