Legal Disclosures and Risk Warnings

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These Legal Disclosures and Risk Warnings (the "Disclosures") are issued by Hitomorrow Assessment Data Classification and Analysis L.L.C, a limited liability company incorporated in the United Arab Emirates under Commercial License No. 1275729, which operates the hi2morrow platform and related assessment services ("hi2morrow", "we", "us", or the "Company").

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1. PURPOSE AND SCOPE

1.1 These Disclosures apply to every person who accesses or participates in any Qualification Program, or in the Test Flight, offered by hi2morrow through its website or related platforms.

1.2 These Disclosures set out the nature of the services, the distinction between the two phases of engagement, and the risks associated with each. They should be read together with the General Terms & Conditions ("GTC"), the Qualification Terms of Service, the Risk Disclosure Statement and the Return & Refund Policy. Capitalised terms used in these Disclosures have the meaning given to them in the GTC or in the Qualification Terms of Service.

1.3 The risk parameters of every tier and of every Level are expressed in Risk Units. One Risk Unit ("R") is 0.250 per cent, and it is also the Daily Loss Limit. In a Qualification Program that percentage is calculated on the Allocated Buying Power, being the Buying Power allocated to the Qualification Account when the attempt opens and fixed for the whole of it; in the real capital phase it is calculated on the buying power of the Level. Buying Power itself moves with realised and unrealised profit and loss during an attempt, and no published limit is calculated on it: the Daily Loss Limit, the AutoStop, the Maximum Loss, the Profit Target and the position limits are all calculated on the Allocated Buying Power. Every tier and every Level runs the same parameters in R, save for the Maximum Loss in a Qualification Program and the allocation of a Level in the real capital phase, each of which is twenty-one (21) Risk Units less the number of the Level concerned and never fewer than ten (10). The two phases do not carry the same set of parameters: the Best Day exists only in a Qualification Program, and the Weekly and Monthly Loss Limits only in the real capital phase, as Section 5.2 sets out. What otherwise differs between tiers and Levels is only the amount to which the parameters are applied.

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2. NATURE AND PURPOSE OF QUALIFICATION PROGRAMS

2.1 The Qualification Programs are paid simulated trading assessments designed to evaluate a participant's trading skill, risk management, consistency and decision-making under defined rules and simulated market conditions, using real-time data from US equity exchanges. They are assessment tools only. They do not constitute an offer of employment, a contractor arrangement, an investment, or any form of live trading relationship.

2.2 Five tiers are offered. Each runs the same assessment in Risk Units, save for the Maximum Loss, which is the allocation of the Level the tier opens and which therefore falls as the tier rises; one consistency rule, the Best-Day Rule, applies at every tier. The tier determines the Allocated Buying Power, the resulting money figures, the Maximum Loss expressed in Risk Units, and the Level that a passing result may open.

Every money figure is calculated from the Allocated Buying Power of the tier: the Daily Loss Limit at 0.250 per cent, the AutoStop at 0.375 per cent and the Profit Target at 5.000 per cent, with the Best Day at twenty per cent (20%) of the Profit Target. The Maximum Loss is the allocation carried by the Level the tier opens, being twenty-one (21) Risk Units less the number of that Level and never fewer than ten (10), so that a participant is assessed under the room they would trade with at that Level. One attempt is included in the Participation Fee, a second attempt at the same tier costs half of it rounded down to the whole dollar, and the Return & Refund Policy, Section 2.3, sets out the price of every product including the price payable with a Test Flight Discount Code.

2.3 A Qualification Program runs for two (2) calendar months, beginning on the day the Qualification Account is opened. Every tier is open to every participant; no application, invitation or prior approval is required for any tier.

2.4 The Test Flight. The Test Flight is a separate product sold for $10, and it is a trial rather than an entry route. Before payment the participant selects the conditions of one tier from the table above, and the Test Flight then runs under the complete published rule set of that tier. The conditions are fixed at payment and may not be changed afterwards. The Term is one (1) calendar month rather than the two (2) calendar months of a Qualification Program, and the Test Flight does not renew.

2.5 Levels. No result achieved in a Test Flight, however strong, constitutes a pass of any Qualification Program, opens any Level, or is credited or carried over towards any Qualification Program purchased afterwards. What a participant takes from a Test Flight is the record of their own performance for that month under the conditions they selected, and, where the participant reaches half of the Profit Target of the tier selected, being ten (10) Risk Units, under the Best-Day Rule and within that tier's Maximum Loss, a Discount Code giving twenty-five per cent (25%) off the Participation Fee at that tier or at any tier below it, on the terms and at the thresholds set out in the Return & Refund Policy, Section 2.4(g). No other benefit arises. One Test Flight is permitted per person, and the Return & Refund Policy, Section 2.4(f), sets out the position where a participant withdraws from one.

2.6 Most participants do not complete a Qualification Program successfully. That outcome is inherent to an assessment and is not a defect in the service.

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3. SIMULATED ENVIRONMENT

3.1 All trading activity during a Qualification Program and during a Test Flight is conducted in a simulated environment using real-time market data. No financial instruments are bought or sold, no order reaches any exchange or counterparty, and no real market or counterparty risk is created for the participant or for hi2morrow.

3.2 Buying Power, equity, positions and profit and loss within the simulated environment are notional. They have no monetary value outside the assessment process and confer no ownership right, no claim against hi2morrow, and no right to the withdrawal of any amount.

3.3 The Participation Fee is a fee for access to that environment. It is not a deposit, is not capital, and is neither tradeable nor withdrawable.

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4. NO ENTITLEMENT TO REAL CAPITAL OR COMPENSATION

4.1 Successful completion of a Qualification Program does not create any right, entitlement or legitimate expectation to receive real firm capital, any form of compensation, any profit share, any bonus, or entry into any contractor or employment relationship.

4.2 Any allocation of real firm capital, if made at all, is granted at the sole discretion of hi2morrow and the relevant group entity. It is subject to a separate written agreement, to further due diligence, to full KYC and AML verification, and to all applicable regulatory and fit-and-proper requirements. Every candidate is reviewed individually and the final decision rests with the firm.

4.3 Qualification is the first step; candidates may be invited to the onboarding process that follows it.

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5. DISTINCTION BETWEEN QUALIFICATION PHASE AND REAL CAPITAL PHASE

5.1 There are two phases and they are separate products under separate documents. The first is a paid simulated assessment governed by these Disclosures, the Qualification Terms of Service and the GTC. The second, which arises only where the firm decides that it should, is trading with the firm's own capital under a separate written agreement with the relevant group entity.

5.2 The two phases compare as follows.

5.3 Order of the two phases. A participant purchases an assessment, completes it, and is then reviewed. A written agreement covering real capital comes into existence only after that review and only where the firm decides to proceed. No real capital is allocated at any earlier point, and no amount paid for an assessment is applied towards real capital.

5.4 The ladder. Where real capital is allocated, it is allocated at one of the Levels set out below. A passing result is assessed against the Level attached to the tier purchased, and it is at that Level that an allocation is considered; the allocation itself remains subject to Section 4, and at the Lead and Principal tiers to the verification described in Section 5.8. Movement between Levels thereafter is governed by the separate agreement.

Every figure in this table is calculated from the Buying Power of the Level: the Daily Loss Limit at 0.250 per cent, the AutoStop at 0.375 per cent, the Weekly Loss Limit at 0.750 per cent, the Monthly Loss Limit at 1.500 per cent and the target to move up at 5.000 per cent. The allocation is twenty-one (21) Risk Units less the number of the Level and never fewer than ten (10), which is why Principal I and Principal II carry the same allocation in Risk Units. The Levels form five bands, being Associate, Trader, Senior Trader, Lead Trader and Principal, and the profit share is a property of the band rather than of the individual Level. The target to move up is accumulated across calendar months at the Level concerned and carries no time limit. The final column names the tier, if any, whose passing result opens the Level in that row; the remaining Levels are reached only by promotion.

5.5 Partner, and the published profit share. The published profit share ladder runs from fifty per cent (50%) in the Associate and Trader bands to fifty-five per cent (55%) at Senior Trader, sixty per cent (60%) at Lead Trader and sixty-five per cent (65%) at Principal, and it ends there. A share above sixty-five per cent (65%) arises only under an individually negotiated Partner contract or under the terms of an agreement already in force.

Partner is a threshold above L12 rather than a published Level. It becomes available on cumulative performance of 60R at L12, begins at Buying Power from $1,000,000, carries a profit share of up to eighty per cent (80%), and is agreed individually. There is no published table of Partner terms and no such table forms part of these Disclosures.

5.6 How a Level is held. A Level is held on the conditions set out in the separate agreement and may be reduced or withdrawn under those conditions.

(a) The allocation. The allocation of a Level is measured as a drawdown: the distance between the highest cumulative result the trader has reached at that Level and their result at the time of measurement. Reaching the allocation ends the engagement. There is no cascade to a lower Level on that ground and no second allocation. The highest cumulative result is reset whenever the Level changes. Because a calendar month cannot close worse than the Monthly Loss Limit of 6R, and that limit holds only where it is enforced within the session and only in a continuous market, reaching the allocation takes at least two losing calendar months at the top of the ladder and four at the bottom.

(b) Demotion. Two consecutive calendar months that both close net-negative move the trader down one Level at the second month-end. The step of permitted size in force is carried down with the trader, and the lower Level begins with half of its allocation already used. A repeated adverse assessment of how results were produced, or an accumulated record of rule breaches, may also demote. Demotion is never more than one Level at a time, and a third demotion ends the engagement.

(c) How a result is produced. Alongside the money limits, each session is assessed on how the result was produced rather than on its size alone, and that assessment is reset at the end of each calendar month. A calendar month that closes at or above zero cannot cost a trader the engagement or the Level on that assessment, whatever it records.

5.7 Progression through the ladder carries no timetable and is not forecast. Nothing in these Disclosures, on the Website or in any marketing material constitutes a representation that a participant will reach any particular Level, receive any particular profit share, or receive any income at all.

5.8 Verification of track record at the Lead and Principal tiers. At the Lead and Principal tiers the participant's trading track record is verified after the Qualification Program has been completed and before any Level is allocated. No verification is required before purchase, and none is carried out at the Associate, Associate Plus or Senior tiers. The verification is conducted on the record of the completed Qualification Program together with such account statements, broker confirmations and other evidence of the participant's own trading history as hi2morrow requests, and the participant is given a reasonable period in which to provide them. The criteria applied are published before purchase and do not change after the participant has paid. Where the verified track record does not support the Level attached to the tier purchased, hi2morrow informs the participant of the highest Level which it does support, and the participant chooses between allocation at that Level and a refund of the full Participation Fee paid for that Qualification Program. The choice is the participant's, hi2morrow gives effect to it, and the passing result itself is not withdrawn by the verification. A refund requested under this Section is made on the terms of the Return & Refund Policy, Sections 5.6 and 5.8.

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6. TRADING RISKS

6.1 Trading financial markets involves substantial risk of loss. The principal risks include market volatility and price gaps, liquidity and execution risk, trading halts, the amplification of losses by leverage, technology and platform failure, regulatory change, and behavioural factors.

6.2 Past performance, whether in simulated or in live conditions, is not indicative of future results. Participation is suitable only for persons who can afford to sustain the loss of the Participation Fee and, in the real capital phase, only for persons who can accept variable income and the loss of the engagement.

6.3 These Disclosures summarise the risks. The full statement is set out in the Risk Disclosure Statement published on the Website, which forms part of the same contractual framework and should be read before purchase.

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7. HYPOTHETICAL AND SIMULATED PERFORMANCE

7.1 Results generated in the simulated environment are hypothetical. They do not reflect actual market liquidity, queue position, order rejection, partial execution, slippage, the cost and availability of borrowing shares in order to sell short, real transaction costs, or the psychological pressures present in live trading.

7.2 No representation is made that a result achieved in the simulated environment would be achieved, or would be capable of being achieved, when trading real capital.

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8. FEES AND PAYMENT

8.1 The Participation Fees are $99 for Associate, $199 for Associate Plus, $649 for Senior, $1,149 for Lead and $2,299 for Principal. The Test Flight fee is $10. One attempt is included in the Participation Fee; a second attempt at the same tier may be purchased at half that Fee rounded down to the whole dollar, and any attempt after the second is charged at the full Fee.

8.2 Fees are charged for access to the simulated assessment infrastructure and to the evaluation process. Fees are non-refundable except where required by mandatory consumer protection law.

8.3 Where a participant passes, is allocated real firm capital and receives a first profit share distribution under the separate written agreement, the Participation Fee paid for the attempt that qualified them is returned to them in full with that distribution. That return is a term of the trading agreement and is paid by the entity that provides the capital; it is not a refund of the purchase price, and it is not owed where no profit share distribution is made. The Fee is retained in respect of every attempt that does not lead to an allocation. The Return & Refund Policy, Section 5.8, sets out the one further circumstance in which the Fee is refunded, being a verification of the track record at the Lead or the Principal tier which does not support the Level purchased.

8.4 hi2morrow may change fees and published parameters. Such a change does not apply to an assessment already purchased, which continues on the parameters published at the time of purchase.

The Return & Refund Policy governs cancellation, statutory withdrawal rights and refunds in full.

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9. RULES, PROHIBITED PRACTICES AND TERMINATION

9.1 Participants must comply with all published rules, risk parameters and prohibited trading practices. The parameters that end an attempt are published for every tier before purchase and are as follows.

The Daily Loss Limit. A loss of 0.250 per cent of Allocated Buying Power (1R) within a single Calendar Day ends the participant's trading for that session. No further position may be opened and no open position may be added to until the next trading day, and a position already open is not closed by the risk system at this level: the participant may reduce it or close it, and it may run on to the AutoStop. No AutoStop is recorded against the attempt where a day ends on the Daily Loss Limit. The Daily Loss Limit and the AutoStop are distinct: the first governs what may be done for the remainder of the session, the second closes every open position.

The AutoStop. A loss of 0.375 per cent of Allocated Buying Power (1.5R) within a single Calendar Day causes the risk system to close all open positions. Two (2) AutoStops are permitted in any calendar month, and a third within the same calendar month ends the attempt.

The Maximum Loss. A cumulative loss equal to the Maximum Loss of the tier ends the attempt. The Maximum Loss is the allocation carried by the Level that the tier opens, being twenty-one (21) Risk Units less the number of that Level and never fewer than ten (10): $1,000 (20R) at Associate, $2,250 (18R) at Associate Plus, $5,250 (14R) at Senior, $9,000 (12R) at Lead and $15,000 (10R) at Principal. It is static, measured from the Starting Balance of the Qualification Account, and does not move with accumulated profit.

The Term. An attempt that has not reached the Profit Target within two (2) calendar months, or within one (1) calendar month in the case of a Test Flight, ends without a passing result.

The consistency rule. One consistency rule applies, on the same terms at every tier, and it is the Best-Day Rule. Where the net result of a Calendar Day exceeds twenty per cent (20%) of the current Profit Target, the Profit Target becomes the net result of that Calendar Day divided by 0.20. The attempt is not failed and the result of the day is not reduced: every dollar made on that day counts towards the Profit Target, and the Profit Target rises instead. The Profit Target never falls, it is not capped, and a losing Calendar Day does not affect it. The rule does not end an attempt and is not a violation of these Disclosures; the balance of the Qualification Account is unaffected by it.

Position limits. At Associate, Associate Plus and Senior no limit applies to the size of a single position. At Lead and Principal, and at Levels L9 to L12 in the real capital phase, a single position may not exceed fifty per cent (50%) of Allocated Buying Power, and that figure applies to every security alike. The aggregate of all open positions may not exceed one hundred per cent (100%) of Allocated Buying Power, and no position in a single security may exceed one half of one per cent (0.5%) of that security's twenty-day median daily volume. A Qualification Program and a Test Flight are conducted intraday only, and every position is flat at the close of the US regular session.

The limits in the real capital phase. In the real capital phase the same limits apply to the buying power of the Level, with three (3) AutoStops permitted in a calendar month and two (2) where the previous calendar month closed net-negative, and with the Weekly Loss Limit of 0.750 per cent (3R) and the Monthly Loss Limit of 1.500 per cent (6R) described in Section 5.2. Levels L1 to L8 trade intraday only. Levels L9 to L12 may, after six (6) months, hold positions overnight within the separate overnight limits set out in the separate agreement, and a position above those limits is reduced by the system at 15:30 Eastern Time.

9.2 The Profit Target is calculated net of the Virtual Commission of USD 0.0015 per share applied to every simulated trade.

9.3 An attempt that ends under Section 9.1 has ended in accordance with the published terms of the product. No adverse finding is made against the participant and no refund arises.

9.4 hi2morrow may disqualify a participant, terminate access, remove trades from performance calculations, or take other proportionate action in respect of a material breach of the rules or of the Governing Documents, without refund. Determinations under this Section are without prejudice to the participant's rights under Section 14 and under mandatory law.

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10. REGULATORY STATUS AND GROUP ENTITIES

10.1 During the qualification phase the services are assessment services. They are not regulated investment services, brokerage services or portfolio management, and a participant in that phase is not a client of any regulated investment firm.

10.2 Allocation of real firm capital and live trading, where offered, are provided through the relevant group entity, with execution through Hitomorrow Securities LTD, regulated by the Cyprus Securities and Exchange Commission under CIF License No. 237/14, on an A-Book basis. The group entity that contracts with the trader is identified in the separate written agreement.

10.3 The protections available to clients of a regulated investment firm, including any investor compensation scheme and the complaints procedures of a financial services regulator, do not apply to participation in a Qualification Program or in a Test Flight.

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11. LIMITATION OF LIABILITY

11.1 To the maximum extent permitted by applicable law, hi2morrow and its group entities, including officers, directors, employees, agents and affiliates, shall have no liability for indirect, incidental, special, consequential, punitive or exemplary damages, including loss of profits, revenue, data or opportunity, whether in contract, tort or otherwise.

11.2 Where liability is established by a competent court or authority, the total aggregate liability of hi2morrow and all group entities combined in connection with these Disclosures, with any Qualification Program or with any Test Flight shall not exceed the total fees paid by the participant for the relevant Qualification Program or Test Flight. This cap applies regardless of the number of claims.

11.3 Nothing in these Disclosures excludes or limits liability for fraud, for fraudulent misrepresentation, for death or personal injury caused by negligence, for any statutory remedy available to a consumer in respect of the lack of conformity of digital content or a digital service, or for any other liability that cannot be excluded or limited under mandatory applicable law.

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12. INDEMNIFICATION

12.1 Participants agree to indemnify and hold harmless hi2morrow and its group entities from all claims, losses, damages and expenses, including legal fees, arising from their breach of these Disclosures, of the GTC or of the applicable rules, or from their conduct during participation. This Section does not apply to a participant acting as a consumer to the extent that mandatory law prohibits it.

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13. DATA PROTECTION AND PRIVACY

13.1 Personal data is processed in accordance with hi2morrow's Privacy Policy and Cookie Policy, which set out the retention periods applicable to each category of data.

13.2 Trading activity, order flow, session data and behavioural data generated during a Qualification Program or a Test Flight are recorded and analysed. The legal basis is the performance of the contract for the evaluation of the participant's own results, compliance with legal obligations for anti-abuse and regulatory purposes, and the legitimate interests of hi2morrow and its group entities in considering eligibility for allocation of real firm capital.

13.3 Where an evaluation is carried out by automated means, the participant may request human intervention, may express their point of view, and may contest the outcome, in accordance with applicable data protection law.

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14. GOVERNING LAW AND DISPUTE RESOLUTION

14.1 These Disclosures are governed by the laws of the United Arab Emirates, and in particular the laws applicable in the Emirate of Dubai. The Real Capital Phase is not governed by this instrument: it is governed by the separate written agreement with the relevant group entity and by the law stated in that agreement. The courts of Dubai shall have jurisdiction, subject to mandatory consumer protections in the participant's country of residence. Where the participant is a consumer domiciled in the European Union or the United Kingdom, nothing in this Section deprives them of the right to bring proceedings in the courts of their place of domicile, or of the protection of being sued only in those courts.

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15. RELATIONSHIP WITH GENERAL TERMS & CONDITIONS

15.1 These Disclosures form part of the contractual framework and should be read together with the GTC, the Qualification Terms of Service, the Risk Disclosure Statement and the Return & Refund Policy. In case of conflict regarding the qualification phase, the GTC shall prevail. Real capital arrangements are governed exclusively by separate agreements.

15.2 If any provision of these Disclosures is held to be invalid or unenforceable, the remaining provisions continue in full force, and the invalid provision shall be modified to the minimum extent necessary to make it valid and enforceable.

15.3 Where these Disclosures are published in more than one language, the English version prevails in the event of any discrepancy, save where mandatory law provides otherwise.

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16. UPDATES

16.1 These Disclosures may be updated. An update does not apply to a Qualification Program or a Test Flight already purchased. Where an update materially affects a participant whose Term is running, hi2morrow shall give notice of it, and the participant may terminate and receive a refund proportionate to the unexpired part of the Term.

16.2 The current version is published on the Website and is identified by the version number and effective date at the head of this document.

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These Legal Disclosures and Risk Warnings do not constitute legal advice. The current version is available on this page.

Hitomorrow Assessment Data Classification and Analysis L.L.C United Arab Emirates | Commercial License No. 1275729 Trading as hi2morrow Group entities include Neoway Trading Ltd and Hitomorrow Securities LTD (Republic of Cyprus)