General Trading Terms of Business

1. Introduction

These General Trading Terms of Business (“Terms”) apply to your interaction with Herring Global Markets Inc. and its affiliates (collectively, “Herring Global”, “we”, “us”, or “our”) in relation to the provision of trading, market making, and liquidity services in digital assets.

Accessing our website or communicating with Herring Global via any communication channels does not constitute a client relationship. These Terms apply only if and when you engage Herring Global in trading activities under a separate, executed counterparty agreement.

These Terms do not override any express agreement between you and Herring Global. In the event of a conflict, the executed counterparty agreement prevails.

2. Eligible Counterparties and Onboarding

Herring Global provides trading and liquidity services only to informed and qualified counterparties. All prospective counterparties must complete Herring Global’s onboarding procedures, including KYC/AML checks. We reserve the right to reject or restrict any onboarding application based on jurisdictional or regulatory limitations. No application from a retail individual or entity will be approved.

3. No Advice

Herring Global does not provide investment, tax, or legal advice. You are responsible for evaluating the risks of any transaction and should seek independent professional advice. Trading of DPTs and related products is not suitable for all counterparties.

4. Conflicts of Interest and Pre-Hedging

Herring Global may act as either principal or agent when providing Digital Payment Token (DPT) services, including market making, over-the-counter trading, and trade execution. In doing so, we may face actual or potential conflicts of interest. We maintain internal policies and controls to identify, manage, and mitigate such conflicts fairly and consistently.

While not all conflicts can be entirely eliminated, we aim to handle them equitably and in accordance with applicable regulations. By engaging our services, clients acknowledge that execution outcomes—such as timing or pricing—may vary depending on the nature of our role. We do not act as fiduciaries or guarantee best execution unless specifically agreed in writing.

5. Pricing and Execution

There is no single reference price for DPTs. Prices quoted by Herring Global may be determined at our discretion, reflecting various internal and external considerations.

We execute trades with terms that are fair and aligned with market conditions. Best execution is not guaranteed unless explicitly agreed.

6. Risk Disclosure

Crypto asset trading involves substantial risk. Market volatility, technology risks, and regulatory uncertainty can lead to material losses. You may lose all funds committed to a transaction. You are responsible for understanding the risks associated with digital asset trading and ensuring that such activities are appropriate for your circumstances and legal status.

7. No Offer or Solicitation

Nothing in these Terms or on our website should be interpreted as:

• an offer to buy or sell digital assets;
• a solicitation to participate in any transaction; or
• a recommendation to engage in any trading strategy.

Access to our website or communications with our team does not constitute an offer to any person in a jurisdiction where such offer would be unlawful.

8. Updates and Amendments

Herring Global may amend these Terms periodically to reflect regulatory, business, or operational developments. Continued trading with us constitutes your acceptance of such amendments.