General Disclosure Statement

1. Introduction

This General Disclosure Statement ("Disclosure Statement" or "Statement") is issued by Phoenix Investment Bank (Labuan) Ltd. ("Phoenix", "PIBL", "the Bank", "we", "us", or "our"), a company incorporated in Labuan, Malaysia, and licensed by the Labuan Financial Services Authority (LFSA) under Registration Number LL22022.

Phoenix is a fully regulated regional investment bank established as a strategic expansion of the Fintrade Group, a global financial group comprising licensed entities across multiple jurisdictions, including New Zealand and Malaysia. The Group's principals collectively bring over 40 years of international banking and finance experience across securities markets, trade finance, investments, advisory, and regulatory environments.

This Statement is intended to provide clients, counterparties, and prospective clients with material information relating to Phoenix, its services, its regulatory standing, and the risks associated with engaging in financial transactions with or through Phoenix. It should be read carefully and in conjunction with any product-specific terms, agreements, or schedules provided to you.

2. Regulatory Status and Licensing

Phoenix Investment Bank (Labuan) Ltd. is incorporated in Labuan Federal Territory, Malaysia, and operates under the supervision and regulatory oversight of the Labuan Financial Services Authority (LFSA). The LFSA is the regulator responsible for licensing, supervision, regulation, and development of Labuan's financial services industry.

Our regulatory details are as follows:

Phoenix maintains a compliance framework aligned with international banking standards, including Anti-Money Laundering / Countering the Financing of Terrorism (AML/CFT) requirements and international risk management best practices. As Labuan Investment Bank, Phoenix is not permitted to accept deposit.

Clients are advised to independently verify Phoenix's current regulatory status with the LFSA at www.labuanfsa.gov.my prior to entering into any financial arrangement.

3. Scope of Financial Services

Phoenix delivers structured investment banking, wealth management, trade finance, and capital markets solutions to institutional, corporate, and professional clients globally. Our service suite includes, but is not limited to, the following categories:

3.1 Trade Finance

Integrated trade finance solutions encompassing Letters of Credit (LC), Standby Letters of Credit (SBLC), Bank Guarantees, Documentary Collections, and supply chain finance instruments, designed to facilitate secure and efficient domestic and cross-border transactions, optimize working capital, and manage transactional risk.

3.2 Investment Banking Services

Strategic advisory and capital markets services including primary market issuance, debt and equity structuring, capital raising, and transaction management for institutional and corporate clients.

3.3 Fund Management

Disciplined asset and fund management services encompassing portfolio strategy, asset allocation, risk-adjusted return management, and fiduciary oversight for institutional funds, family offices, and corporate treasury mandates.

3.4 Wealth Management

Comprehensive wealth management services for clients, including portfolio construction, investment advisory, estate planning support, and multi-currency solutions.

3.5 Broking & Securities

Brokerage and custody services for equities and fixed-income instruments, providing and securities custody for professional and institutional investors across global markets.

3.6 Loan Syndication

Arrangement and co-ordination of syndicated lending facilities across multiple lenders and jurisdictions, supporting large-scale corporate, infrastructure, and project financing mandates.

3.7 Mortgage and Secured Lending

Loan Against Property (LAP) and Loan Against Shares (LAS) solutions providing capital access against real estate and listed equity collateral, structured to meet specific client liquidity and leverage requirements.

3.8 Escrow Services

Neutral, regulated escrow agency services for mergers and acquisitions, real estate transactions, cross-border commercial deals, and performance-linked escrow arrangements, ensuring transparent, impartial custody and conditional release of funds.

3.9 Mergers & Acquisitions (M&A) Advisory

End-to-end M&A advisory including target identification, valuation, due diligence coordination, deal structuring, negotiation support, and post-deal integration planning.

3.10 Fund Raising Advisory

Strategic advisory for equity, debt, and hybrid fund-raising exercises, encompassing investor identification, deal structuring, documentation preparation, and investor relations support.

3.11 Consulting & Advisory

Bespoke financial and strategic consulting services covering regulatory strategy, capital structuring, financial feasibility assessments, and market entry support for institutional and corporate clients.

3.12 Card Solutions and Merchant Acquisition

Customizable prepaid cards solutions supporting domestic and cross-border payment requirements, together with scalable merchant acquisition services with reliable multi-currency settlements.

4. Important Client Disclosures

4.1 Nature of This Document

This Disclosure Statement is provided for general information purposes only. It does not constitute, and should not be construed as, an offer to sell, a solicitation of an offer to buy, a recommendation, or investment advice in relation to any financial product, instrument, or service. Phoenix does not provide personal recommendations or investment advice unless explicitly agreed to under a signed advisory engagement agreement.

4.2 Target Clients

Phoenix's services are directed exclusively at Professional Clients and Eligible Counterparties. Phoenix does not generally offer its services to Retail Clients.

4.3 No Guarantee of Returns

Nothing in this Statement, any product documentation, or any communication from Phoenix constitutes a guarantee of returns, capital protection, or financial performance. The value of investments and the income derived from them may go up as well as down. Past performance is not indicative of future results. Clients may receive back less than their original investment.

4.4 Reliance and Independent Advice

Clients should not rely solely on information or materials provided by Phoenix when making investment or financial decisions. Phoenix strongly recommends that all clients seek independent legal, financial, tax, and regulatory advice tailored to their specific circumstances, risk appetite, investment objectives, and financial situation before entering into any transaction or arrangement with Phoenix.

4.5 Currency Risk

Transactions denominated in foreign currencies are subject to exchange rate fluctuations. Changes in foreign exchange rates may have an adverse effect on the value, price, or returns of any instrument or investment denominated in a currency other than the client's home or base currency.

4.6 Conflict of Interest

Phoenix, its directors, officers, employees, advisors, and affiliates may, from time to time, have material interests, positions, or financial exposure in transactions, instruments, or entities that are the subject of services provided to clients. Phoenix maintains appropriate policies and procedures to identify, manage, and disclose conflicts of interest.

4.7 Confidentiality and Data Protection

Phoenix treats client information as confidential and processes it in accordance with applicable privacy laws. Client information may be shared with Fintrade Group entities, authorized third-party service providers, correspondent banks, or as required by law, strictly in accordance with Phoenix’s Data Protection Notice.

4.8 Document Hierarchy

General risk disclosures contained in this Statement do not replace product-specific disclosures, suitability assessments, or contractual risk warnings. In the event of any inconsistency between this General Disclosure Statement and a signed client agreement or product-specific terms, the signed client agreement and product terms shall prevail.

5. Risk Disclosures

Engaging in financial services and transactions involves inherent risks. Clients should carefully consider the following risk categories before proceeding:

5.1 Market Risk

The value of financial instruments can be significantly affected by changes in market conditions, including interest rate movements, equity price fluctuations, commodity price changes, credit spread movements, and macroeconomic developments. Clients should be prepared to absorb potential losses.

5.2 Credit Risk

There is a risk that a counterparty, issuer, or obligor may fail to meet its contractual obligations. Phoenix employs rigorous credit assessment procedures; however, credit risk cannot be fully eliminated. Clients assume counterparty credit risk in respect of transactions facilitated by Phoenix.

5.3 Liquidity Risk

Some financial instruments or structured products may be illiquid or may only be traded in limited markets. Clients may not be able to exit positions promptly or at prices reflecting fair value, particularly during periods of market stress.

5.4 Regulatory and Legal Risk

Changes in applicable laws, regulations, tax treatment, or regulatory interpretation across jurisdictions in which Phoenix operates may affect the value, structure, or viability of financial transactions. Clients are advised to seek jurisdiction-specific legal and regulatory advice.

5.5 Operational Risk

Operational disruptions — including technology failures, cybersecurity incidents, procedural errors, or third-party service provider failures — may adversely affect the delivery of financial services. Phoenix maintains operational risk frameworks and business continuity protocols to mitigate such risks.

5.6 Cross-Border and Political Risk

Phoenix serves clients across multiple jurisdictions. Cross-border transactions may be subject to geopolitical risk, sanctions exposure, currency controls, sovereign risk, and variations in legal enforceability across different legal systems.

6. Anti-Money Laundering, KYC and Compliance

Phoenix maintains a robust AML/CFT compliance framework consistent with the requirements of the LFSA and aligned with the Financial Action Task Force (FATF) recommendations. As part of its client onboarding and ongoing monitoring processes, Phoenix is required to:

• Conduct Know Your Customer (KYC) and Customer Due Diligence (CDD) checks on all clients and beneficial owners.
• Verify client identity, legal status, source of funds, and source of wealth.
• Screen clients and related parties against international sanctions lists and Politically Exposed Persons (PEP) databases.
• Perform ongoing transaction monitoring and Enhanced Due Diligence (EDD) where applicable.
• Report suspicious transactions to relevant authorities in accordance with applicable law.

Clients are required to provide accurate, complete, and up-to-date documentation as requested by Phoenix during the onboarding process and at any subsequent review. Failure to provide required documentation may result in the suspension or termination of services.

7. Correspondent Banking Network

Phoenix, through the Fintrade Group, has established a global correspondent banking network to facilitate cross-border trade flows, investment transactions, and financial intermediation. The Group's correspondent reach includes:

• Relationship Management Agreements (RMAs) with over 100 internationally established banks.
• Institutional connectivity across 48 countries.

This correspondent network enables Phoenix to support multi-jurisdictional deal structuring, trade instrument issuance, and international capital flows. Clients should note that correspondent relationships are subject to change and that the availability of specific services in particular jurisdictions may be affected by regulatory, banking, or operational conditions at any given time.

8. Governance and Leadership

Phoenix is guided by a distinguished Board of Directors and Board of Advisors comprising senior professionals with leadership backgrounds across global banking institutions, capital markets, regulatory bodies, multinational corporations, and public service.

Board members and senior advisors bring experience from globally recognized institutions including Standard Chartered Bank, Citigroup, Morgan Stanley, Emirates NBD, and Saudi Awwal Bank, ensuring strong governance, risk oversight, and strategic direction.

Independent Directors and Advisors bring specialized expertise in the following areas:

• AML/CFT regulation and compliance
• Corporate governance and enterprise risk management
• Capital markets, treasury, and structured finance
• Public policy and institutional engagement
• Cross-border financial structuring and advisory

Phoenix's governance framework is built on the principles of transparency, accountability, and long-term value creation for clients and stakeholders.

9. Jurisdiction and Distribution Disclosures

This Disclosure Statement and any associated materials are intended for distribution to institutional, corporate, and professional clients in jurisdictions where Phoenix is authorized or permitted to conduct business. Phoenix does not represent that any of its services, products, or materials are available to, or appropriate for, persons in all jurisdictions.

In particular:

• This document is not directed at, and should not be acted upon by, retail investors or any person who is not a qualified or accredited investor under applicable law.
• This document does not constitute a prospectus, offering memorandum, or product disclosure statement under the laws of any jurisdiction and should not be treated as such.
• Recipients are responsible for ensuring that their access to and use of this document and any associated services is in compliance with all applicable laws and regulations in their relevant jurisdiction.
• Phoenix reserves the right to decline to provide services in jurisdictions where it determines that doing so would require registration, licensing, or compliance steps that Phoenix has not taken.

10. Limitation of Liability

To the extent permitted by applicable law, Phoenix shall not be liable for losses arising from market movements or general reliance on this Statement. However, nothing in this clause excludes or limits Phoenix's liability for fraud, willful misconduct, non-excludable negligence, breach of statutory or regulatory duty, or obligations expressly assumed in signed client agreements.

11. Intellectual Property

All content, materials, and documentation produced by Phoenix including but not limited to this Disclosure Statement, product brochures, research commentary, and financial analyses are and remain the intellectual property of Phoenix Investment Bank (Labuan) Ltd. No part of any Phoenix document may be reproduced, redistributed, or transmitted in any form without the prior written consent of Phoenix.

12. Updates and Amendments

Phoenix reserves the right to amend this Disclosure Statement. Updated versions will be published on Phoenix's official website with an updated effective date. Where material amendments affect your contractual rights, Phoenix will notify you and, where legally required, seek your express acceptance of the updated terms.

13. Governing Law and Dispute Resolution

This Disclosure Statement shall be governed by and construed in accordance with the laws of Malaysia. Any disputes arising in connection with this Statement shall, in the first instance, be resolved through good-faith negotiation between the parties. Where negotiation fails, disputes shall be referred to the courts of Malaysia or such other dispute resolution mechanism as agreed between the parties in any applicable client agreement.

14. Contact Information

For any queries, clarifications, or concerns regarding this Disclosure Statement, or to request further information about Phoenix's services, please contact us: