These Terms and Conditions (“Terms”) govern your access to and use of the Apex Risk website, services, reports and related materials (collectively, the “Services”). By accessing this website or engaging Sponsio, you agree to be bound by these Terms.

If you do not agree with these Terms, you must not use the website or Services.

1. About Apex Risk

Apex provides due diligence, compliance intelligence and risk reporting services to support organisations operating in regulated and high-risk environments. Sponsio is not a law firm, regulator, auditor or supervisory authority.

2. Scope of Services

Apex provides compliance intelligence, screening and due diligence reporting based on the scope agreed with the client. Services may include, but are not limited to:

• Sanctions and risk screening

• Adverse media analysis

• Beneficial ownership and control discovery

• Regulatory, enforcement and reputational risk intelligence

All Services are provided strictly for informational and compliance support purposes.

3. No Legal, Regulatory or Investment Advice

Nothing on this website or within any Apex report constitutes legal, tax, regulatory, financial or investment advice.

Clients are solely responsible for:

• Their compliance obligations

• Decisions made based on Apex outputs

• Seeking independent professional advice where appropriate

Apex does not provide opinions on legal compliance or regulatory approval.

4. Reliance on Reports

Reports are prepared exclusively for the commissioning client and for the specific purpose defined at the time of engagement.

• Third parties may not rely on Apex reports

• Redistribution, disclosure or reuse is prohibited without prior written consent

• Apex accepts no liability to any third party

5. Data Sources and Limitations

Apex reports are compiled using a combination of public records, proprietary databases, media sources and third-party data providers believed to be reliable at the time of reporting.

However:

• Data may be incomplete, outdated or subject to error

• Not all information is publicly available in all jurisdictions

• Apex does not guarantee accuracy, completeness or timeliness

6. Client Responsibilities

Clients are responsible for:

• Providing accurate and complete information

• Defining the appropriate scope of work

• Interpreting and applying findings within their compliance framework

Apex is not responsible for decisions made by the client based on report findings.

7. Confidentiality

All client information, reports and communications are treated as confidential and handled in accordance with contractual obligations and applicable data protection laws.

Confidential information will not be disclosed except:

• As required by law

• With client consent

• As necessary to deliver Services

8. Intellectual Property

All content, methodologies, reports, templates and materials produced by Apex are the intellectual property of Apex Risk & KYC Limited unless otherwise agreed in writing.

Clients may use reports internally for their intended purpose only. Reproduction, distribution or modification is prohibited without prior written consent.

9. Limitation of Liability

To the fullest extent permitted by law:

• Apex shall not be liable for indirect, incidental, consequential or punitive damages

• Liability is limited to the fees paid for the relevant Services

• Apex is not liable for losses arising from reliance on incomplete or inaccurate data

10. Website Use

Users agree not to:

• Misuse or interfere with the website

• Attempt unauthorised access to systems or data

• Copy or scrape website content

Apex reserves the right to restrict or terminate access at its discretion.

11. Data Protection and Privacy

Personal data is processed in accordance with applicable data protection laws and Apex’s Privacy Policy.

Clients confirm they have lawful grounds to request due diligence on individuals or entities.

12. Regulatory Responsibility

Apex does not assume responsibility for regulatory compliance outcomes. Regulatory responsibility remains solely with the client.

Use of Apex Services does not guarantee regulatory approval or risk mitigation.

13. Amendments

Apex may update these Terms at any time. Continued use of the website or Services constitutes acceptance of revised Terms.

14. Governing Law

Unless otherwise agreed in writing, these Terms are governed by the laws of the applicable contracting jurisdiction, without regard to conflict of law principles.