Product Specific Terms and Conditions

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These Product Specific Terms and Conditions (“Additional Terms”) supplement the Agreement and apply to your access to and use of any of Comply’s SaaS and/or Services offerings, as applicable.

Capitalized terms used but not defined shall have the respective meanings given to them in the Agreement. In addition, "Platform" means Comply's software as a service platform that, amongst other things, enables Customer and its Authorized Users to access the Services. As used herein, the terms “you” or “your” or “Customer” refers to the legal entity represented on your Order Schedule. Any references to terms such as “we,” “our,” “us,” and “Comply”. “Comply will mean the Comply entity described in the Agreement.

A. Product Specific Terms by Brand Directory

1. Comply Platform and Modules
• Employee Trade Monitoring
• Comply Program Management
• Political Contribution Verification Modules
2. Comply Platform (formerly ComplySci)
• Certifications Only
• Marketing Materials Only
• Limited Use Only
• Broker Feed Access Only
• Personal Trading Access Only
• Archival Use Only
• PTCC – Archival Use Only
• Statement Review and Data Entry Services
• Broker Feed Maintenance Services
• FTP Data Upload Services
• Custom Report Services
• Delivery Method
• Additional Services
• Comply Implementation Services
3. Comply for RIA (formerly RIA in a Box or MyRIACompliance)
• Comply for RIA Program
• Growth for All Comply for RIA SaaS Services
• Comply for RIA Enhanced Consulting
• Comply for RIA Automated Employee Trade Monitoring
• Comply for RIA Cybersecurity Platform
• Comply for RIA Private Fund Platform
• Comply for RIA Archiving Solution
• Registration Services Package
• Onboarding or Implementation
4. NRS
• ComplianceGuardian Marketing Review Module
• Applicable to all NRS Services
5. Comply Fiduciary Suite
6. illumis
• Applicable to all illumis Services
7. Comply Managed Services
• Code of Ethics Administration
• Licensing & Registration
• Email Review
• illumis Political Contribution Administration
• Advertising Review
8. Additional Professional Services Terms
9. Traillight

1. Comply Platform, and Employee Trade Monitoring, Comply Program Management, and Political Contribution Verification Modules

Comply Platform

The Comply Platform provides the technology platform for the Employee Trade Monitoring, Comply Program Management, and Political Contribution Verification modules. Three tiers of Users are available for each module – Standard, Advanced, and Premium.

Employee Trade Monitoring

Employee Trade Monitoring is a robust, mobile responsive compliance software solution built for monitoring employee activities including, trading, gifts and entertainment, outside business activities, marketing materials, IPO’s, private investments, and more. For employee trades, it leverages a direct broker feed network that includes global securities and cryptocurrencies. Managed Services-Code of Ethics Administration : When added as part of Premium, Comply will assist in streamlining the review process of initial, quarterly, and annual reporting by creating requested certifications and standard preconfigured reports from the Comply Platform or Comply for RIA (formerly MyRIACompliance) system, as applicable.

Comply Program Management

Program Management allows a compliance supervisory team to manage its compliance program from a central application emphasizing automation and streamlined reporting. It includes a customizable compliance calendar and tools to automate firm risk assessment and annual review processes.  Comply Program Management Consulting : When added as part of Premium, Comply will coordinate (i) a set-up call to review establish annual calendar items for the compliance program year, (ii) monthly calls to review the prior month’s calendar items and associated risk assessment tasks, (iii) planning the next month of activities, and (iv) an annual review call to help complete the annual review checklist based on the prior year’s calendar items and risk assessment. Marketing Review : When added as part of Premium, upon request, Comply will review marketing materials developed by Customer against SEC or corresponding state regulatory requirements, plus provide recommended form disclosures. This Managed Service is available each service year to a maximum of the greater of an hour per year for each User or 20 hours per Customer. Any hours not utilized by the Customer in a given service year will not be carried forward to subsequent years.

Political Contribution Verification

illumis offers comprehensive political contribution monitoring to streamline workflows and automate reconciling pre-clearance requests, featuring: (i) contribution information from all 50 states, hundreds of municipalities, and federal sources; and (ii) automatically reconcile pre-clearance requests; (iii) intelligent filters to help remove false positives.  Managed Services – Political Contribution Verification Administration:  When included as part of Premium, Comply will review political contribution submissions from Customer’s active illumis subscription and provide the illumis results for Customer’s use.

2. Comply SaaS & Professional Services Additional Terms

Comply Platform – Certifications Only: This version of the Comply Platform Risk & Compliance Platform™ is limited to use of the certifications features only and excludes access to all other features (e.g., broker feeds, pre-clearance, gifts and entertainment, marketing materials, etc.); access to which requires a different subscription.

Comply Platform – Marketing Materials Only: This version of the Comply Platform Risk & Compliance Platform™ is limited to use of the marketing materials features only and excludes access to all other features (e.g., certifications, broker feeds, pre-clearance, gifts and entertainment, etc.); access to which requires a different subscription.

Comply Platform – Limited Use Only: This version of the Comply Platform Risk & Compliance Platform™ excludes access to and use of personal trading features and functionality; access to which requires a different subscription.

Comply Platform – Broker Feed Access Only: This version of the Comply Platform Risk & Compliance Platform™ is limited to broker feeds only and excludes access to all other features (e.g., certifications, pre-clearance, gifts and entertainment, etc.); access to which requires a different subscription. Access is limited to two (2) Authorized Users (Supervisors) only. Any increase to the number of Authorized User accounts will be subject to the additional fees set forth in the Order Schedule.

Comply Platform – Personal Trading Access Only:  This version of the Comply Platform Risk & Compliance Platform™ is limited to the 'Personal Trading' (i.e., pre-clearance) features only and excludes access to all other features (e.g., certifications, broker feeds, gifts and entertainment, marketing materials, etc.); access to which requires a different subscription.

Comply Platform – Archival Use Only: This version of the Comply Platform Risk & Compliance Platform™ is limited to the right to audit, review, and/or export any Customer data entered in or otherwise collected by the Customer in its existing Comply site prior to the Effective Date of the applicable Order Schedule.

PTCC – Archival Use Only:  This version of the Personal Trading Control Center™ platform ("PTCC") is limited to the right to audit, review, and/or export any Customer data entered in or otherwise collected by the Customer in its existing PTCC site prior to the Effective Date of the applicable Order Schedule. Notwithstanding anything to the contrary contained in the Agreement, PTCC may be (a) terminated by a Party as permitted in the Agreement, or (b) terminated by Comply upon at least one hundred eighty (180) days advance written notice (email shall be sufficient) of its intention to sunset or otherwise cease supporting PTCC.

Statement Review and Data Entry – Digital Brokerage Statements and Paper Brokerage Statements and Ad Hoc

1. Services Description . The Services shall be comprised of the following brokerage statement entry and reconciliation services: Comply will ingest and process paper statements through a combination of OCR and human oversight and enter the following brokerage statement data:
• Trade activity (“buys” and “sells”);
• Stock splits and reverse stock splits;
• Dividend reinvestments;
• Other holdings where the quantity has changed as a result of non-trade brokerage activity,

(collectively, the “ Statement Data ”).

2. Authorized User Accounts . Customer is solely responsible for: (a) identifying which of Customer’s Authorized User’s brokerage accounts (the “ Accounts ”) require the brokerage statement entry services. Fees set forth in the Order Schedule shall apply to all Accounts for which Comply receives a brokerage statement whether digital or paper and/or whether an automated broker feed is otherwise available; and (b) delivering Account information to us via secure File Transfer Protocol (“ FTP ”).
3. Brokerage Statement Information .
• Each brokerage statement Customer submits to Comply must contain, at a minimum, the following information in the English language in order to be entered into the Comply Platform: (w) Identifiable employee name and account number; (x) Ticker symbol, CUSIP number, or other information identifying the securities in question; (y) Dates of transactions; and (z) Numbers of shares.
• Comply will not enter transactions or information in the Comply Platform for Authorized User Accounts for the following transactions: (w) Cash; (x) Sovereign debt; (y) Money market funds; and/or (z) Any other securities exempt from reporting.
• Brokerage statements submitted to Comply will be entered into the Comply Platform and added to the list of Authorize User Accounts.
4. Authorized User Account List . A list of Accounts for which brokerage statements have been submitted to Comply for manual entry into the Comply Platform (“ Authorize User Account List ”) will be updated and included with the quarterly invoice for the Services.
5. Margin Accounts .  Where the annual Fees were paid in advance, Comply will invoice and Customer will pay the difference between (i) the Fee per applicable Account (due or payable) in accordance with the Order Schedule, and (ii) the applicable Annual Fee for Margin Account.
6. Timing .  Customer acknowledges that the 'Statement Review' and 'Data Entry Services' are labor-intensive and that the volume of transactions is variable based on the activity levels for each enrolled Account. Accordingly, while Comply will use commercially reasonable efforts to complete the Services in a timely fashion, Comply does not make any representation that the Services will be completed by a fixed date.
7. Use Restrictions and Liability . Section 2.2 of the Agreement (Use of Services and Authorized Users) is amended by adding the following: Customer hereby releases Comply from and against any claim relating to the accuracy of information entered by Comply into the Accounts and/or otherwise through the Services unless such inaccuracy results from Comply's gross negligence or willful misconduct and Customer further agrees to indemnify, defend, and hold Comply harmless from and against any claim by an Authorized User or other third party arising from any inaccuracies in Account information.

Broker Feed Maintenance

1. Services Description . The Services shall be comprised of the following elements: (i) updating broker account numbers, (ii) updating broker names, (iii) configuring sites for feeding, and (iv) providing clarification for accounts that cannot be electronically fed.
2. Electronically Supported Brokers .  Comply reserves the right to deny any request(s) to establish or re-establish electronic feed connections for broker(s) with which Comply does not have an existing electronic feed connection established and/or for broker(s) that do not allow Comply to work on behalf of Customer to establish or re-establishing such electronic feed connection.
3. Primary Point of Contact . Customer shall identify a single point of contact through which all requests including change, updates and other discussions regarding the Services should be centralized. Customer understands and agrees that Comply reserves the right to deny any requests including changes, updates and discussions with any other individuals.
4. Legal Documents .  Customer understands and agrees that Comply is not an agent of Customer and that Comply is not authorized to execute any documents on behalf of Customer. Customer is solely responsible for executing any documents with brokers necessary for establishing electronic feeds.
5. Authorized User Accounts .  Customer is solely responsible for: (a) identifying which of Customer’s Authorized User’s brokerage accounts (“ Accounts ”) require the Broker Feed Maintenance, (b) delivering Account information to Comply via secure communication method, and (c) adding Accounts to electronic feeds with brokers that do not use the Comply electronic feed portal.
6. One-Time Services . 'One-Time Broker Feed Maintenance' services do not include future reconciliation of covered Accounts arising out of matters beyond Comply’s control and may be subject to additional Fees.

FTP Data Uploads

1. Services Description .  Comply will assist with the uploading of Excel/CSV templates into Customer’s Comply site. As applicable, this Service will consist of the following elements: (i) converting Excel/CSV files to .txt files, (ii) establishing FTP connections for Customer’s Comply site, (iii) renaming files, and (iv) providing clarification on proper formatting guidelines for all FTP file uploads.
2. Formatting Guidelines .  All files submitted for FTP uploads must be formatted per the Comply guidelines (“ FTP Formatting Guidelines ”); such guidelines shall be provided upon request. Comply reserves the right to deny any request to upload data if a file does not adhere to the FTP Formatting Guidelines, or if the requested data record change cannot be altered via FTP uploads.
3. File Delivery .  Customer is solely responsible for formatting Excel/CSV files for FTP uploading in accordance with the FTP Formatting Guidelines and in accordance with delivery instructions provided by Comply.
4. Upload Schedule (Annual Services) .  Comply reserves the right to deny any request to upload FTP files outside of Comply's standard business hours (US EST). FTP uploads are limited to a maximum frequency of once every two (2) weeks. One-Time Services are limited to a fixed number of templates.

Custom Report Services

1. Services Description .  Comply will assist with generating bespoke Excel/CSV reports as set forth in the Agreement.
2. Data Requirements .  Customer understands that all reports will solely utilize and depend on data from within the Customer's Comply site.
3. Delivery Schedule .  Comply reserves the right to deny any request to deliver reports outside of Comply's standard business hours (US EST). Customer understands that all reports are limited to the frequency set forth in the Order Schedule and that any change to the frequency shall be subject to a change order which may include additional fees.
4. Delivery Method .  Customer is solely responsible for establishing and providing access to a preferred secure delivery method for all custom reports.

Additional Services

1. Data Clean Up.  Comply will assist with the clean-up of the bad/duplicate data in Customer’s site as of the Effective Date of the applicable Order Schedule that is the result of human entry error (e.g., accidental uploads). The scope of data covered by such clean-up will be set forth in the applicable Order Schedule.
2. User Administration.  Comply will assist with bulk user loading, retiring/un-retiring Authorized Users, and updating other fields within “Users” identified by Comply and required as of the Effective Date of the applicable Order Schedule.
3. Site Reconfiguration – Data Services.  This is a post-implementation service during which Comply will assist with updating global settings, communication rules, building of questionnaires, pushing of certifications, building/editing preclearance rules, building/editing restricted lists, and updating role permissions.
4. SSO Set-Up.  Comply will assist with the set-up of SSO for the Comply Platform. This is a one-time project. Future maintenance and/or additional future support regarding SSO will be subject to additional fees.
5. Comply Implementation Services.  'Implementation Services' consist of initial configuration of certain Services to Customer’s website environment.

3. Comply for RIA SaaS and Professional Services Additional Terms

1. Comply for RIA Program.  The following is a general description of the current features included in the various versions of the Comply for RIA Program:

Comply RIA Platform for state-registered firms  (updated as of Feb 17, 2025):

Comply RIA Platform for SEC-registered firms:

• Growth for All Comply FOR RIA (FORMERLY MyRIACompliance) SaaS Services .  Subject to Section 12.1 (Growth) of the Agreement and the terms of the applicable Order Schedule, Customer understands and agrees that, the meaning of 'Growth' shall also include any changes in registration status (e.g., changing from state-registered to SEC-registered) and any increases in email domains, storage, websites, and/or social media connections which occur in any given month. Any such changes shall be audited and invoiced monthly without need for amendment to the applicable Order Schedule. The Parties acknowledge and agree that the number of Authorized Users may increase based on Customer’s information set forth in Item 5A of Form ADV Part 1A (or, in the future, wherever equivalent information is disclosed in Form ADV). The Parties further acknowledge and agree that all of Customer’s employees will be granted access to the Services as Authorized Users. Accordingly, the annual Fees will be adjusted to reflect any increase in Authorized Users under the applicable Order Schedule.
• Comply for RIA Enhanced Consulting  consists of the following:
• Unlimited compliance questions via e-mail and phone;
• Unlimited compliance review services for Customer’s investment advisory regulatory filings and compliance documents;
• Unlimited compliance review services for Customer’s investment advisory marketing materials (including website, letterhead, business cards, and advertisements);
• Creation and review of policies and procedures manual;
• Preparation and filing of IAR applications for up to three (3) additional IARs on an annual basis;
• Preparation and filing of Customer’s application for registration or notice filing in up to three (3) additional jurisdictions, together with associated paperwork on an annual basis; and
• Customer may request additional IAR’s and/or registration in additional jurisdictions subject to Comply's then current fees for such services, which shall be invoiced and paid by Customer in accordance with the Agreement.
• Comply for RIA Automated Employee Trade Monitoring  consists of the following:
• Customer gains access to direct data feeds to Authorized User brokerage accounts (when direct feed is available); and
• CCO gains access to Comply for RIA trade monitoring supervision module.
• Comply for RIA Cybersecurity Platform  consists of the following:
• Each of the Authorized Users has access to:
• Security awareness training, and
• Email phishing attack simulation.
• Supervisor users, as delegated by Customer, have access to:
• Security awareness training,
• Email phishing attack simulation,
• Inventory and risk evaluation for technology systems, employee access, and devices,
• Vendor due diligence tool,
• Information security policies and associated procedures, and
• Cybersecurity incident reporting.
• Comply for RIA Private Fund Platform  consists of the following:
• Private Fund Risk Assessment Tool
• Fund Inventory
• Form ADV Updates
• Form PF
• Form D
• Blue Sky Filings
• Comply for RIA Archiving Solution  consists of the following:
• Archiving of Customer’s email (1 domain);
• Archiving of Customer’s social media (up to 4 connected social media accounts);
• Archiving of Customer’s website on a monthly basis (up to 100 megabytes);
• Ability to conduct and document reviews of Customer email utilizing sampling and keyword flagging;
• Ability to conduct and document reviews of Customer website and firm social media;
• Integration of archiving and review activities into Comply for RIA compliance calendar and compliance log;
• Customer may request custom queries, or a full extract of all data subject to Comply's then current fees for such services, such fees which shall be invoiced and paid by Customer in accordance with the Agreement; and
• Upon expiration of the Comply for RIA/Comply Archiving Solution services, Customer may elect to have Comply store archived data from the 'Archiving Solution', without searchability or queries, for five (5) years, subject to Comply's then current fees, such fees which shall be paid annually in advance in accordance with the Agreement.
• Registration Services Package.  Registration Services Package includes:

1. Support completing the following forms leveraging the MyRIARegistration online platform:

• FINRA Entitlement
• Form ADV Part 1
• Form ADV Part 2A
• Form ADV Part 2B for one (1) IAR
• Form ADV Part 3 / Form CRS for SEC firms
• Form U-4 for one (1) IAR
• Three (3) months of simple Form ADV changes

2. Access to the following standard form templates:

• Client Advisory Contracts
• Privacy Policy Statement
• Code of Ethics
• Business Continuity Plan
• Policies and Procedures Manual

• Comply Onboarding Services or Implementation for Comply for RIA.  Onboarding/Implementation Services consist of initially configuring the Services to Customer’s website environment.

4. NRS SaaS and Professional Services Additional Terms

1. ComplianceGuardian Marketing Review Module .  In the event Customer’s use of the Compliance Guardian Marketing Review Module should exceed any of the parameters of the subscribed tier (e.g., Users and/or Reviews), Customer’s subscription shall automatically increase to the next applicable subscription tier, subject to Comply's then current standard Fees for such tier. Comply shall invoice the Customer for the increased Fees (which shall be pro-rated through the end of the then current contract year) which shall be paid by Customer in accordance with the Agreement.
2. Use Limitations .  Except as otherwise expressly identified in the applicable Order Schedule, use of the Services is limited to the Customer only and not its Affiliates. Additional Fees are payable if Customer allows or otherwise permits use of the Services by its Affiliates.
3. Services Content and Advice Disclaimer .  It is Customer’s responsibility to verify any content, advice and/or information provided in connection with the Services before relying on it.
4. Third Party Site Disclaimer .  Some of the websites listed as links are not under the control of Comply. Accordingly, Comply makes no representations or warranties whatsoever concerning the content of those websites. The inclusion of a link is NOT an endorsement, authorization, sponsorship, or indication of affiliation with any such websites by Comply with respect to such website, its owners, or its providers. Comply is providing these links only as a convenience to Customer only. Comply has not tested any information, software, or products found on these websites and therefore cannot make any representations whatsoever with respect to them. Customer acknowledges there are risks in using any information, software, or products found on the internet; and Comply cautions Customer to make sure that it completely understand these risks before retrieving, using, relying upon, or purchasing anything via the internet.
5. ComplianceGuardian PS .  ComplianceGuardian PS consists of initially configuring the ComplianceGuardian Services to Customer’s website environment.
6. Form N-PX.  Annual Form N-PX filing assistance for one (1) institutional investment manager annual filing for up to fifty (50) say-on-pay proxy votes.

5. Comply Fiduciary Suite.

• Addresses investment products, portfolio fit and alternatives, through a suite of applications. Applications include AccountCompare, PeerCompare and RolloverAnalyzer (third party applications).

6. illumis SaaS and Services Additional Terms

1. illumis Implementation Services . Implementation Services consist of initially configuring the Services to Customer’s website environment.
2. illumis Political Contribution Administration . This is a managed service for illumis system administration.

7. Comply Managed Services

1. Code of Ethics Administration.  Comply will assist Customer in streamlining the review process of initial, quarterly and annual reporting by performing the following tasks in Customer’s active Comply COE subscription:

• Employee onboarding and offboarding assistance.
• Certification and Attestation management by assisting with creation of new certifications at the direction of Customer’s CCO.
• 'Employee Personal Trading' system maintenance and administration (excludes broker feed setup and maintenance) by adding requested new accounts, reviewing preclearance request exception reports, and quarterly reporting.
• 'Gifts and Entertainment' maintenance and administration by reviewing submissions and reporting findings.
• 'Outside Business Activities' maintenance and administration assistance by reviewing submissions and reporting findings.
• 'Private Placements' administration reviews (if applicable) by reviewing submissions and reporting findings.
• 'List' maintenance (restricted, auto-approve) by adding and removing securities from lists based on Customer’s specific update items.
• Standard report creation and maintenance by preparing standard out-of-the-box reports from Comply.

2. Licensing & Registration.  Comply will, to the extent necessary and updated information is provided to Comply by Customer, file via IARD/FINRA amendments to Customer’s Form ADV, Form BD, Form U4, and Form U5, as applicable.
3. Email Review.  Comply will review a sample size of approximately one percent (1%) of Customer’s supervised persons’ emails per period, using a combination of keyword flags and random sampling. Comply will provide reports to Customer’s designated person regarding any inappropriate content or potential issues uncovered, as appropriate. Comply will utilize Customer’s active email archiving and surveillance solution (i.e., Smarsh, Global Relay, or Comply for RIA) to support their review process and, as such, Customer must arrange for an appropriate level of access for performance of these email reviews.
4. illumis Political Contribution Administration.  Comply will use Customer’s active illumis subscription to review political contribution submissions and report findings, including, as appropriate, a brief description of the findings.
5. Advertising Review.  Comply will review marketing materials developed by Customer, up to the maximum number of materials indicated in the applicable Order Schedule, against SEC or corresponding state regulatory requirements, plus provide recommended form disclosures. Any reviews not utilized by the Customer in a contract year will not be carried forward to subsequent contract years.

8. Additional Professional Services Terms (All Brands)

• The following terms apply to all professional services (whether Annual or One-Time) delivered by Comply to Customer: Comply will allocate resources with the skills necessary to complete the applicable Professional Services (as identified in the Order Schedule). Customer understands that Comply cannot and does not guarantee completion of the Services within any estimated timeframe, with completion being fully subject to and contingent upon (i) Customer providing access to internal and external resources, data, and information required to perform the Services, and (ii) Customer promptly completing any tasks including providing feedback, necessary and useful for Comply to perform the Services in the manner contemplated hereunder. Customer understands and agrees that any delays in responsiveness, completion of tasks, and/or access to required resources may cause delays in completion of the Services. Any additional work necessary to complete the Services shall be subject to an additional cost and to the terms of a separate Order Schedule which identifies such additional costs for any remaining work.
• Services for filings and registrations are dependent upon Customer delivery of required information, and Comply is not responsible for issues arising from inaccurate or incomplete information provided by Customer. Comply is not responsible for actions taken or not taken by governmental or regulatory bodies or other third parties, and Comply does not and cannot guarantee that any filing, registration, license or membership will be accepted or granted.

9. Trailight

• Access to Customer premises. Customer shall, if applicable and necessary for the provision of Professional Services, provide, for Comply, its agents, subcontractors, consultants and employees, in a timely manner and at no charge, access to the Customer's premises, office accommodation, data and other facilities as reasonably required by Comply;
• Nominees. In the event that the Professional Services include the provision of training by Comply to Customer), Customer shall:

• provide nominated individuals to be trained by Comply (“Nominees”), the number of such Nominees to be agreed by the parties at the commencement date of the Professional Services to be provided under the Order Schedule;
• ensure that the Nominees complete such training to a standard agreed by Comply and the Customer as competent (and that once such standard is achieved, certify (and procure that the Nominees (and each of them) certify) that the Nominees are competent to use the Professional Services and any associated applications (and in the event that the Nominees are not so certified, procure that the Nominees shall recommence such training and continue to be so trained until they are so certified);
• utilise the Nominees to train Customer’s employees in the use of the Professional Services and any associated applications;
• provide, in a timely manner, such information as Comply may reasonably require, and ensure that it is accurate in all material respects;
• be responsible (at its own cost) for preparing and maintaining the relevant premises for the supply of the Professional Services;
• inform Comply of all health and safety rules and regulations and any other reasonable security requirements that apply at any of the Customer's premises;
• obtain and maintain all necessary licences and consents and comply with all relevant legislation in relation to the Professional Services before the date on which the Professional Services are to start; and
• keep and maintain Comply's equipment at the Customer's premises in safe custody at its own risk, maintain Comply's equipment in good condition until returned to Comply, and not dispose of or use Comply's equipment other than in accordance with Comply's written instructions or authorisation.

• Customer acknowledges that the purpose of any provision of training by Comply to Customer is to enable the Nominees to provide training to Customer's employees.
• Should Professional Services be requested by Customer, then Customer shall provide its requirements which will be detailed in a project initiation document (the 'Project Initiation Document'). Such Project Initiation Document will be created from initial project meetings and on site business analysis to work out and document the scope of the project.
• If Comply's performance of the Professional Services under this agreement is prevented or delayed by any act or omission of Customer, its agents, subcontractors, consultants or employees, Comply shall not be liable for any costs, charges or losses sustained or incurred by the Customer that arise directly or indirectly from such prevention or delay.

• Trailight - Browser Compatibility: For Trailight, Comply will support the latest versions of Internet Explorer 11, Microsoft Edge, Firefox and Chrome browsers whilst these are actively developed by their vendors. Due to the technologies used, older and different browsers may work but are not supported. Safari is also supported, but only on iPads. As browser release strategies change, Comply will update the compatibility list to reflect this.

Last Updated: December 3, 2025 (Comply Name Updates)

Previous Versions: November 26, 2025 (Comply Name Updates)

October 30, 2025 (Trailight Added)