Terms of Business

Effective Date: June 2026

These Terms of Business (“Terms”) apply to all services provided by Central Advisors Limited (“Central Advisors”, “we”, “us”, “our”). Together with any Client Engagement Letter and Record of Advice issued to you, these Terms form the “Retainer” and constitute the entire agreement between you and us.

Our Regulatory Status

Central Advisors Limited is licensed by the Cayman Islands Monetary Authority (CIMA) under the Securities Investment Business Act (2020 Revision) as a Securities Advisor and Securities Arranger (Licence No. 2219932). We act solely in an advisory and arranging capacity. We do not hold client assets, execute trades on a discretionary basis, provide custody, or act as a product manufacturer.

We adhere to the Securities Investment Business Act, the Conduct of Business Regulations, all applicable CIMA Statements of Guidance, and the CFP® Professionals Code of Ethics.

Our Services

We provide independent financial advice and arranging services, including:

• Investment recommendations and ongoing portfolio advice tailored to your objectives, risk profile, and circumstances;
• Management of the underlying investment strategy and portfolio holdings within third-party platforms or product wrappers (client-directed with our professional recommendations);
• Assistance with platform and product wrapper selection and review;
• Regular portfolio reviews, rebalancing recommendations, and research support;
• Facilitating documentation, communication, and administrative support with third-party providers and platforms.

All recommendations are advisory only. You retain ultimate control and must give explicit approval for all transactions. We do not manage any in-house funds or proprietary investment products.

Our Independent Approach

As independent advisors, we do not create, manage, or offer proprietary investment products or in-house funds. We receive no revenue from the manufacture or management of any investment products.

Our remuneration structure follows a flexible hybrid Fee approach. This includes one or a combination of fees based on a percentage of Assets Under Management (AUM) or product-related commissions. These arrangements are fully disclosed to you in the relevant product documentation (such as the Illustration, Key Information Document, or Charges Schedule). In some cases, we may also enter into a separate fee agreement with you for advisory services.

This structure ensures that our recommendations are made solely on merit and in your best interests. It also provides flexibility, allowing clients to engage with us without being required to pay us a separate fee in every case. We have no incentive to recommend higher-cost or less suitable options because we work exclusively for our clients.

Client Responsibilities

You agree to:

• Provide us with accurate, complete, and up-to-date information regarding your financial circumstances, objectives, risk profile, tax status, residency, and any other relevant details (including PEP status);
• Promptly inform us of any material changes to your circumstances;
• Carefully review all documentation we provide, as well as all documents issued by third-party providers;
• Make your own informed final decisions regarding investments;
• Comply with all applicable laws, regulations, and exchange control requirements in your country of residence, domicile, or citizenship.
• You warrant that all information provided is true and complete, and you acknowledge that we rely on this information when providing advice.

Suitability Assessment

We will conduct a suitability assessment before providing any advice. Recommendations are based on the information you supply. You confirm that you have been asked about your PEP status and related parties and have answered truthfully.

Remuneration and Fees

Our remuneration is transparent and full details of charges will be disclosed to you prior to proceeding. Any direct fees payable by you (if applicable) will be separately agreed in writing. We do not apply firm-wide fee schedules — all terms are negotiated to suit your individual circumstances.

Third-Party Providers

You enter into a direct contractual relationship with any chosen product provider, platform, or issuer. We act only in an advisory and arranging capacity. We do not guarantee the performance, returns, solvency, or conduct of any third-party provider. We accept no liability for any loss, damage, or issues arising from third-party products, platforms, or services.

Complaints Procedure

We are committed to high standards of service. If you have any concerns, please raise them with your adviser in the first instance. Formal complaints should be directed to complaints@central.ky. We will acknowledge your complaint promptly and provide a written response in accordance with our Complaints Policy (available on request).

Confidentiality and Data Protection

We treat your information as confidential and comply with the Data Protection Act 2021. We may share your information with third parties where necessary for the purposes of conducting our normal business activities, such as with product providers, investment platforms, outsourced service providers (e.g. AML compliance), professional advisers, or regulators.

We will treat all information relating to you as confidential and will not disclose it to third parties except as required by law, regulation, or with your consent.

Conflicts of Interest

We maintain a Conflicts of Interest Policy. Any actual or potential conflicts will be disclosed to you, and appropriate mitigation steps will be taken.

Termination

The Retainer may be terminated by either party upon giving 30 days’ written notice. Termination does not affect any accrued rights, liabilities, or ongoing regulatory obligations (including record-keeping).

Limitation of Liability

We maintain Professional Indemnity Insurance in line with our regulatory requirements.

We are not liable for investment losses, market movements, or the failure, insolvency, or misconduct of third-party providers.

Governing Law

These Terms are governed by the laws of the Cayman Islands.

Amendments

We may update these Terms from time to time. Continued engagement after notification constitutes acceptance.