Terms of Service & Anti-Slavery Statement

Galveston Group Limited
Registered Office: 6 Waterloo Place, Edinburgh, Scotland
Email: admin@galvestongroup.com

Effective Date: 5/12/25

PART A: TERMS OF SERVICE

1. ACCEPTANCE OF TERMS

By accessing or using the Galveston geopolitical intelligence platform ("Platform"), you agree to be bound by these Terms of Service ("Terms"). If you are accessing the Platform on behalf of an organization, you represent and warrant that you have authority to bind that organization to these Terms.

2. SERVICE DESCRIPTION

Galveston provides cloud-based geopolitical intelligence, risk analysis, and decision-support tools to institutional financial clients. Our Platform delivers real-time intelligence feeds, portfolio risk assessment, scenario modeling, and automated alerts. All services are provided on a subscription basis pursuant to executed Master Services Agreements or Order Forms.

3. ACCESS AND ACCOUNT SECURITY

You are responsible for maintaining the confidentiality of account credentials and for all activities conducted under your account. You must notify us immediately at admin@galvestongroup.com of any unauthorized access or security breach. Multi-factor authentication is mandatory for all accounts. You may not share account access or sublicense Platform use to third parties without our prior written consent.

4. ACCEPTABLE USE

You agree not to: (a) use the Platform for illegal purposes or in violation of any applicable laws; (b) attempt to gain unauthorized access to our systems or other users' accounts; (c) interfere with or disrupt Platform functionality or security measures; (d) reverse engineer, decompile, or extract source code from our Platform; (e) use automated tools to scrape, extract, or download Platform content in bulk; (f) resell, redistribute, or provide Platform access to competitors; (g) use the Platform to create competing intelligence products or services; (h) upload malicious code, viruses, or harmful content; or (i) manipulate or falsify data inputs to generate misleading intelligence outputs.

5. INTELLECTUAL PROPERTY RIGHTS

All Platform content, including software, algorithms, intelligence reports, data compilations, user interfaces, and branding, is owned by Galveston and protected by copyright, trademark, and other intellectual property laws. We grant you a limited, non-exclusive, non-transferable license to access the Platform during your subscription term. You retain ownership of data you upload, and we claim no proprietary rights to your portfolio information or investment strategies. We may use anonymized, aggregated data derived from Platform usage to improve our services, provided such data cannot identify you or your specific investment positions.

6. CLIENT DATA AND CONFIDENTIALITY

We process your portfolio data strictly in accordance with our Privacy Policy and applicable data protection laws. Your investment positions, holdings, and proprietary strategies remain strictly confidential and are never disclosed to third parties or used to train models accessible to other clients. We maintain SOC 2 Type II compliance and employ AES-256 encryption for data at rest and TLS 1.3 for data in transit. You grant us a limited license to process uploaded data solely for the purpose of delivering intelligence services to you.

7. SERVICE AVAILABILITY AND MODIFICATIONS

We strive to maintain 99.9% Platform uptime, excluding scheduled maintenance. We reserve the right to modify, suspend, or discontinue Platform features with reasonable advance notice. Emergency maintenance or security updates may be implemented without notice. We continuously enhance our Platform and may introduce new features, modify existing functionality, or retire outdated capabilities. Material changes affecting core service delivery will be communicated with at least 30 days' advance notice.

8. DISCLAIMERS AND LIMITATIONS OF LIABILITY

Investment Decisions: The Platform provides decision-support intelligence and risk analysis tools. All intelligence outputs, risk assessments, scenario models, and trade recommendations are informational only and do not constitute investment advice, financial advice, or recommendations to buy or sell securities. You are solely responsible for investment decisions and must conduct independent due diligence. We make no guarantees regarding investment performance or risk mitigation effectiveness.

No Warranties: The Platform is provided "as is" and "as available" without warranties of any kind, whether express or implied, including warranties of merchantability, fitness for particular purpose, or non-infringement. We do not warrant that the Platform will be uninterrupted, error-free, secure, or free from viruses or harmful components. Intelligence outputs may contain inaccuracies, and we do not guarantee completeness or timeliness of information.

Limitation of Liability: To the maximum extent permitted by law, Galveston shall not be liable for any indirect, incidental, consequential, special, or punitive damages, including loss of profits, trading losses, loss of data, business interruption, or loss of opportunity, arising from your use of the Platform, even if we have been advised of the possibility of such damages. Our total aggregate liability for all claims shall not exceed the fees paid by you in the 12 months preceding the claim. These limitations apply regardless of the legal theory of liability, whether in contract, tort, negligence, strict liability, or otherwise.

Exclusions: Some jurisdictions do not allow exclusion of implied warranties or limitation of liability for consequential damages. In such jurisdictions, our liability is limited to the maximum extent permitted by law.

9. INDEMNIFICATION

You agree to indemnify, defend, and hold harmless Galveston, its affiliates, officers, directors, employees, and agents from any claims, liabilities, damages, losses, costs, or expenses (including reasonable legal fees) arising from: (a) your use of the Platform; (b) your violation of these Terms; (c) your violation of any third-party rights; (d) your violation of applicable laws or regulations; or (e) investment decisions made based on Platform intelligence outputs. This indemnification obligation survives termination of these Terms.

10. FEES AND PAYMENT TERMS

Subscription fees are specified in your Master Services Agreement or Order Form and are payable annually in advance unless otherwise agreed. Fees are non-refundable except as required by law. We reserve the right to modify fees upon 90 days' written notice, effective at your next renewal period. Failure to pay fees when due may result in account suspension or termination. You are responsible for all taxes, duties, and assessments (excluding taxes based on our net income).

11. TERM AND TERMINATION

Term: Your subscription commences on the date specified in your Order Form and continues for the initial term stated therein, automatically renewing for successive periods of equal length unless either party provides written notice of non-renewal at least 60 days prior to renewal date.

Termination for Cause: Either party may terminate immediately upon written notice if the other party materially breaches these Terms and fails to cure within 30 days of notice. We may suspend access immediately if we reasonably believe you pose a security risk or are engaging in fraudulent activity.

Effect of Termination: Upon termination, your access to the Platform ceases immediately. You must pay all outstanding fees through the end of your then-current subscription term. We will retain your data for 90 days following termination, during which you may request data export. After 90 days, we will delete your data in accordance with our Privacy Policy, except data we are required to retain by law.

Survival: Sections 4, 5, 6, 8, 9, 12, 13, and 14 survive termination.

12. DISPUTE RESOLUTION AND GOVERNING LAW

Governing Law: These Terms shall be governed by and construed in accordance with the laws of Scotland and the United Kingdom, without regard to conflict of law principles.

Jurisdiction: The courts of Scotland shall have exclusive jurisdiction over any disputes arising from or relating to these Terms, except as specified below.

Arbitration: For disputes involving claims under £100,000, either party may elect binding arbitration administered by the London Court of International Arbitration (LCIA) under its rules. The arbitration shall be conducted in Edinburgh, Scotland, in English, before a single arbitrator. The arbitrator's decision is final and binding.

Injunctive Relief: Either party may seek injunctive or equitable relief in any court of competent jurisdiction to protect intellectual property rights or confidential information.

13. GENERAL PROVISIONS

Entire Agreement: These Terms, together with your Master Services Agreement, Order Form, and Privacy Policy, constitute the entire agreement between you and Galveston regarding Platform use and supersede all prior agreements and understandings.

Amendment: We may modify these Terms by providing 30 days' written notice. Continued use of the Platform after the effective date constitutes acceptance. If you do not agree to modifications, you may terminate your subscription.

Assignment: You may not assign or transfer these Terms without our prior written consent. We may assign these Terms in connection with a merger, acquisition, or sale of assets upon notice to you.

Severability: If any provision of these Terms is held invalid or unenforceable, the remaining provisions remain in full force and effect, and the invalid provision shall be modified to the minimum extent necessary to make it valid and enforceable.

Waiver: Our failure to enforce any right or provision of these Terms does not constitute a waiver of such right or provision.

Force Majeure: Neither party shall be liable for failure or delay in performance due to causes beyond its reasonable control, including acts of God, war, terrorism, civil unrest, government action, labor disputes, or internet/telecommunications failures.

Notices: All notices must be in writing and sent to admin@galvestongroup.com or the address specified in your Master Services Agreement. Notices are deemed given when delivered via email or five business days after posting if sent by post.

No Third-Party Beneficiaries: These Terms are for the sole benefit of the parties and do not create rights for any third parties.

14. REGULATORY COMPLIANCE

Galveston operates in compliance with applicable financial services regulations. We are not a regulated investment advisor and do not provide investment advice. Our Platform is designed for use by institutional financial professionals capable of making independent investment decisions. If you are subject to specific regulatory requirements, you are responsible for ensuring your use of the Platform complies with such requirements.

STATEMENT PURSUANT TO SECTION 54, UK MODERN SLAVERY ACT 2015

Financial Year Ending: 2025

1. ORGANIZATIONAL STRUCTURE AND BUSINESS

Galveston Group Limited is a financial technology company headquartered at 6 Waterloo Place, Edinburgh, Scotland, providing geopolitical intelligence software to institutional financial clients globally. Our business operates exclusively through cloud-based software services with annual turnover exceeding £36 million, requiring disclosure under the Modern Slavery Act 2015.

2. SUPPLY CHAIN OVERVIEW

Our supply chain comprises: cloud computing infrastructure (AWS, Microsoft Azure), professional services (legal, accounting, recruitment), financial data vendors (Bloomberg, Refinitiv), telecommunications services, and office facilities management. We recognize that modern slavery risks exist in all industries, particularly in lower-tier suppliers, IT equipment manufacturing, and facilities services.

3. POLICIES AND COMMITMENT

We maintain a zero-tolerance policy toward modern slavery and human trafficking. Our Employee Code of Conduct explicitly prohibits forced labor, human trafficking, and any form of modern slavery. All employees acknowledge these standards annually. Our Supplier Code of Conduct requires suppliers to comply with all modern slavery laws, maintain slavery-free operations, provide safe working conditions, respect workers' rights including freedom of association, and permit audit rights for compliance verification. We maintain a confidential whistleblowing mechanism accessible to employees, contractors, and suppliers to report suspected violations without retaliation.

4. DUE DILIGENCE AND RISK ASSESSMENT

We conduct annual supply chain risk assessments identifying higher-risk categories including IT equipment manufacturing, facilities management and cleaning services, construction and office fit-out, and recruitment agencies. Before engaging suppliers in high-risk categories, we require completion of modern slavery questionnaires, evidence of compliance policies, confirmation of ethical labor practices, and right-to-work verification processes. We conduct periodic supplier compliance reviews and require annual confirmations of ongoing compliance.

5. TRAINING AND AWARENESS

All Galveston employees receive annual training on modern slavery awareness, including recognizing exploitation indicators, reporting procedures, UK Modern Slavery Act requirements, and corporate responsibility. Procurement, HR, and legal personnel receive specialized training on supply chain due diligence, supplier vetting, and risk assessment methodologies.

6. EFFECTIVENESS MEASURES

We measure effectiveness through: 100% supplier acknowledgment of our Supplier Code of Conduct, 100% employee completion of annual modern slavery training, systematic supplier risk assessments, and investigation of all whistleblowing reports within 14 days. We have identified zero instances of modern slavery or trafficking in our operations or supply chains to date.

7. CONTINUOUS IMPROVEMENT

For the coming financial year, we commit to: enhancing supplier audit programs, expanding training to client-facing teams, developing supplier collaboration programs, implementing technology solutions for supply chain transparency, strengthening contractual remediation clauses, and engaging with industry bodies to share best practices.

8. BOARD APPROVAL AND ACCOUNTABILITY

This statement has been approved by the Board of Directors of Galveston Group Limited. We remain committed to conducting business ethically and transparently, recognizing that combating modern slavery requires continuous vigilance and improvement.

Approved and Signed:

Rhys J. Cooper
Chief Executive Officer
Galveston Group Limited

Date: 23/11/25

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