Aspis Risk Disclosure

Effective date: 1 October 2026

If you had an account with us before 1 October 2026, this Risk Disclosure applies to you from 1 November 2026. Until then, the Risk Disclosure you were given before continues to apply.

Please read this before you use the Services.

Cryptoassets are high risk. You could lose all of the cryptoassets you deposit into a vault or trade using the Services.

Aspis Protocol Ltd is not authorised or regulated by the Financial Conduct Authority (FCA). If something goes wrong, you are unlikely to be protected. The Financial Services Compensation Scheme (FSCS) does not cover the Services, and the Financial Ombudsman Service cannot consider complaints about them.

1. About this statement

1.1 Who issues it. This Risk Disclosure is issued by Aspis Protocol Ltd ("Aspis", "we", "us" and "our"). We are a private limited company registered in England and Wales with company number 15506799. Our registered office is at 167-169 Great Portland Street, 5th Floor, London W1W 5PF, United Kingdom.

1.2 What it covers. It applies to our website at aspis.finance, the Aspis web app at v3.aspis.finance, Aspis Copilot (our Telegram bot @aspisprotocol_bot) and the organisation API. Together, we call these the "Services". Some words in this statement have the meanings given in our Terms of Use: "vault", "self-managed vault", "Copilot-run vault", "manager wallet" and "guardian". A "legacy vault" is a Copilot-run vault or Agent-Fund created before 1 October 2026 (section 6.12).

1.3 What it is, and what it is not. This statement explains the main risks of using the Services. It cannot describe every risk, and new risks may arise. It is information, not advice. It is not a recommendation, and it is not an offer or an invitation to buy, sell or deposit any cryptoasset.

1.4 How it fits with our Terms of Use. Our Terms of Use set out what we are and are not responsible for. This statement does not change them, and it does not take away any of your legal rights. If you are not sure whether something is right for you, speak to an independent, appropriately qualified adviser.

2. Regulatory status and protection

• Not regulated by the FCA. Aspis Protocol Ltd is not authorised or regulated by the Financial Conduct Authority. We do not offer the Services as regulated financial services, and you do not have the protections that apply to regulated services.
• No compensation. The FSCS does not cover the Services. You are unlikely to get compensation if something fails, whether that is Aspis, a vault, a vault manager or anyone else involved.
• No ombudsman. The Financial Ombudsman Service cannot consider complaints about the Services. You can complain to us as described in the "Complaints" section of our Terms of Use.
• Fewer protections. Some protections for customers of regulated investment services do not apply to the Services. These include checks on whether a product is suitable or appropriate for you, rules on how firms hold customers' assets, and the FCA's Consumer Duty.
• Rules are changing. The UK and other countries are bringing in new rules for cryptoassets. New rules could require us to change, restrict or stop some Services, in some or all countries, possibly at short notice.

3. Risks of cryptoassets

• Prices can move sharply. Cryptoasset prices can rise or fall a great deal in a short time, at any hour of any day. They can fall to zero.
• You could lose everything. You could lose all of the cryptoassets you deposit into a vault or trade.
• Stablecoins can fail. Stablecoins aim to keep a steady value, but they can lose it. Their issuers can also freeze tokens held at particular addresses.
• You may not be able to sell. Some tokens have few buyers. You may not be able to sell them when you want to, or only at a much lower price than the one shown.
• Tokens can fail. The project behind a token can fail, be abandoned or turn out to be a fraud. A token's smart contract can also contain hidden features that harm holders. A token being available on Aspis does not mean we have checked it or consider it safe.
• Markets can be manipulated. Cryptoasset markets are exposed to manipulation. Examples are pump-and-dump schemes, and automated bots that trade just ahead of other people's transactions to profit from them (sometimes called front-running or sandwich attacks).
• Information can be poor. Information about cryptoassets can be limited, out of date or misleading.

4. How vaults work, and what can go wrong

4.1 Smart contracts can fail. Vaults are smart contracts. Smart contracts can contain errors or weaknesses that others can exploit, and they can behave in ways their designers did not expect. An audit reduces this risk but does not remove it. Blockchain transactions cannot be reversed, so losses from an exploit are usually permanent.

4.2 Vault code cannot be changed, even to fix it. The roles that could upgrade vault code have been given up on all vaults, so nobody, including us, can change a vault's code. So the rules in a vault's code stay as they are. But if an error is found in a vault's code, nobody can fix it in that vault. Withdrawing may then be the only way to avoid the problem.

4.3 Vaults created before 1 October 2026: one failed price feed can block every such vault on a network. These vaults include legacy vaults and older self-managed vaults. When anyone deposits into or withdraws from one of them, the vault is valued using a shared registry of tokens and price feeds for the whole network. The price of every token in the registry is checked, not only the tokens that vault holds. Suppose a single price feed stops working, for example because its provider (usually Chainlink) retires it. Deposits and withdrawals can then fail for every vault on that network that was created before 1 October 2026. Only we can fix this, by updating the registry through the guardian.

This has already happened twice, because price feeds used by the registries were retired. The first time, in March 2026, deposits and withdrawals failed for the vaults on the affected network. The second time, deposits and withdrawals failed for every vault on Arbitrum, BNB Chain and Polygon. We found that failure on 18 August 2026, and it may have started as early as June 2026. Each time, deposits and withdrawals worked again only after we updated the registries. While they were blocked, depositors could not leave their vaults, and the value of the vaults' assets kept changing.

We now check the health of the price feeds every 6 hours, with alerts to our team, and where a provider publishes a date for retiring a feed, we remove the feed before that date. This reduces the risk but does not remove it. It could happen again. If Aspis stopped operating, nobody might be able to update the registry, and withdrawals from these vaults could stay blocked indefinitely.

4.4 Vaults created from 1 October 2026: withdrawals do not depend on prices, but deposits do. When you withdraw from one of these vaults, you receive your share of each token the vault actually holds, in proportion to your vault tokens. No price is looked up, so a failed price feed cannot block your withdrawal. Deposits still use price feeds. If the feed for a token fails, deposits may fail until we fix the registry.

4.5 Fixing a failed price feed can cost depositors. To fix a failed feed, we may remove a token from the registry. For a vault created before 1 October 2026, any balance of that token held by the vault may then no longer be paid out on withdrawal. In March 2026, small balances held by some vaults were lost in this way.

4.6 Wrong prices mean wrong values. A price feed can give a wrong price through an error, a delay or deliberate manipulation. A vault can then be valued incorrectly when someone deposits, or, for a vault created before 1 October 2026, when someone withdraws. You could receive fewer vault tokens than you should when you deposit, or less than your fair share when you withdraw from an older vault. Other depositors could gain or lose at your expense.

4.7 We control the guardian. The guardian is controlled by a multisig of ours: any action needs approval from at least two of our authorised signers. The guardian maintains each network's shared registry of tokens and price feeds, and it can put a vault into an emergency stop. Until the stop is lifted, some or all of the vault's functions do not work. For a vault created before 1 October 2026, this can include withdrawals. For a vault created from 1 October 2026, an emergency stop does not stop withdrawals. If enough of our signers' keys were lost, misused or compromised, every vault on a network could be affected. We will tell affected users of any emergency stop or token removal. Section 7 of our Terms of Use sets out how we will use the guardian.

4.8 Vault settings can stop you withdrawing when you want. A vault's settings can include a lock-up period, withdrawal windows, a freeze period or a fundraising period. These can stop you withdrawing for a time, even while prices are falling. A private vault accepts deposits only from addresses on its allowlist.

4.9 Fees reduce what you get back. Vaults can charge three kinds of fee paid to the vault's manager: an entrance fee on each deposit, a yearly fund management fee, and a performance fee on profits. Some vaults also charge an early exit fee (a "rage quit fee"), which takes a percentage of what you withdraw if you withdraw outside the vault's withdrawal window. Depending on how a vault's smart contract is set up, its fees may be able to change after you deposit. You also pay network fees for your own transactions, including transactions that fail. Fees can take a large share of any gain, especially on small amounts.

4.10 What you get back may not be what you put in. When you withdraw, you receive your share of whatever the vault holds at the time, after fees. This may be several different tokens, including tokens that are hard to sell, and it may be worth less than you deposited. You may need to pay further fees to swap them.

4.11 Everything is public. Deposits, withdrawals, trades and allowlists are recorded permanently on a public blockchain. Anyone can see them, and nobody can delete them.

5. Vault creators and managers

• Anyone can create a vault. We do not check vault creators' identity, experience, qualifications or honesty, and we do not monitor or approve their strategies.
• Managers can lose money. A manager's trading can lose some or all of a vault's value. Strategies can be risky, for example if they concentrate on a few tokens or on tokens that are hard to sell.
• Managers can act against depositors. A dishonest or careless manager can cause losses within the vault's rules, for example by trading at poor prices or buying tokens that benefit the manager.
• Fees and incentives. Managers earn entrance and management fees whether or not the vault does well. Their interests may therefore differ from depositors'.
• Depositors usually cannot replace a manager. Whether a vault's manager can be changed depends on the vault. A self-managed vault's depositors can replace its manager by a vote, but only if the vault was created with that option; the vault's page shows whether it was, and the voting rules. The owner of a Copilot-run vault created from 1 October 2026 can change its manager to another wallet, which then controls the vault's trading within its settings. The manager of a legacy vault cannot be changed. If a manager stops trading, the vault stays in its last positions, and your only way out is to withdraw.
• Vault information is not checked. Vault names, descriptions, links and claims come from their creators. We do not verify them.

6. Copilot-run vaults: automated trading

This section applies if you create a Copilot-run vault (in Copilot, or as an Agent-Fund in the web app), or deposit into one. Copilot-run vaults and Agent-Funds created before 1 October 2026 ("legacy vaults") work differently until 31 December 2026: see section 6.12.

6.1 Your wallet is the manager, and our software trades under a limited permission. The manager of a Copilot-run vault is the owner's own wallet: a wallet they connect (a browser wallet or WalletConnect), or an email or social-login wallet from a wallet provider. We never hold the keys to it. To use automated trading, the owner signs an on-chain permission in their own wallet. That permission lets our trading software swap the vault's assets, but only through the vault's permitted exchanges, and make the token approvals those swaps need. Each trade accepts a price no more than 3% worse than the quoted price (slippage), and this limit is enforced on every trade. The permission does not let our software transfer or withdraw the vault's assets, claim manager fees, or change the vault's settings or manager. Depositors' cryptoassets stay in the vault's smart contract. Our software carries out only the owner's instructions; it does not decide trades.

6.2 The permission ends when you revoke it or when it expires. The permission expires after 90 days unless you renew it by signing again. You can revoke it at any time from your own wallet, without needing us. "Stop automated trading" in the web app and in Copilot prepares the revoke transaction for you to sign. When the permission is revoked or expires, our software stops and cancels your open orders, including stop-loss orders, and we tell you which orders were cancelled. From then on, those orders no longer protect you, and the vault stays in its current positions until you or the manager trade it.

6.3 If our systems were compromised. An attacker who took over our trading software could do only what your permission allows: swap the vault's assets through its permitted exchanges, within the 3% limit on each trade. A series of trades at poor prices could still reduce the vault's value. The attacker could not transfer or withdraw the vault's assets, claim its fees, or change its settings or manager. Revoking the permission stops our software trading the vault.

6.4 Dependence on our systems. If our systems are unavailable, no automated trades or orders happen for a Copilot-run vault, including stop-loss orders. You can still trade the vault yourself from your own wallet. If we stop offering automated trading, or Aspis stops operating, our software will stop, but you keep control of the vault through your own wallet. Depositors could still withdraw, subject to section 4.

6.5 Whoever controls your wallet controls the vault. Because your own wallet is the vault's manager, anyone who gets control of that wallet, or of the sign-in for an email or social-login wallet, can trade the vault, change its settings where the vault allows, change its manager and claim its manager fees. We cannot recover your wallet or reverse its transactions. See section 7.

6.6 Manager fees. The vault pays manager fees to the manager wallet, which is the owner's own wallet. The owner claims them from that wallet. Aspis never receives or holds them. If you lose access to your wallet, you cannot claim them.

6.7 The vault API key. Anyone who has a vault's API key can instruct trades and orders for the vault, within the permission. The key cannot claim manager fees. We show the key once and store only a scrambled version of it (a hash), so we cannot show it to you again. If you think someone else has it, revoke it and create a new one in the web app or in Copilot. Copilot never asks for your API key, so do not paste it into the chat. Anything you type in the chat becomes part of your chat history, which we store and send to our AI provider.

6.8 Automated orders. Limit, stop-loss and take-profit orders run automatically once our own price service shows that your price condition has been met. Our system checks prices about every 30 seconds. When the condition is met, it carries out the order straight away as a market trade through Odos, or through 1inch if Odos fails, without asking you again. It accepts a price up to 3% worse than the quoted price. Before each order, it checks that the permission is still active. Orders last until they are carried out or cancelled, or until the permission ends.

• Your order may be carried out late, at a worse price, or not at all.
• If our price service shows a wrong price, an order could be triggered when it should not be, or not triggered when it should be.
• A brief, sharp price movement can trigger a stop-loss and sell at a low price, even if the price recovers soon afterwards.
• A stop-loss order cannot make sure that your loss will be limited.
• If the permission has been revoked or has expired, orders are cancelled and do not run.

6.9 Trading by chat message. Copilot uses AI to turn your chat messages into trades, and it can misunderstand you. Before it makes a trade you asked for in the chat, Copilot shows you a summary of the tokens, the amount, the route and the maximum slippage, and it trades only after you press Confirm. If you do not say which token to use, Copilot asks you. Check the summary carefully: once a trade is on the blockchain, it cannot be reversed.

6.10 Depositing into someone else's Copilot-run vault. If you deposit into a Copilot-run vault owned by someone else, you depend on that owner's decisions, on how well they protect their wallet, and on our systems. The owner can revoke or renew the permission, trade the vault themselves or change its manager. You have no control over any of this.

6.11 Network fees. We currently pay the network fees for the trades our software sends. That may change after we give notice, which would add to your costs. You pay the network fees for transactions you sign yourself, such as granting, renewing or revoking the permission, and claiming fees.

6.12 Legacy vaults. A legacy vault is a Copilot-run vault or Agent-Fund created before 1 October 2026. It is labelled "Legacy vault" in the web app, in Copilot and in the API. It works differently from sections 6.1 to 6.7:

• We hold its key until 31 December 2026. Our servers created the vault's manager wallet and keep its private key, encrypted, in a key management service with access logged. The owner never received the key, and the manager cannot be changed. The vault therefore depends on how well we protect that key. Someone who obtained it could trade the vault within the limits of its smart contract, for example at very poor prices, although they could not withdraw depositors' cryptoassets.
• Closed to new deposits. From 1 October 2026, our apps and API do not accept new deposits into legacy vaults. The vault's smart contract itself may still accept a deposit made to it directly. Do not make one.
• Trading only if the owner confirms. We are asking owners to confirm by 31 October 2026 whether they want automated trading to continue until 31 December 2026. Where the owner confirms, our software keeps carrying out their instructions until then. Where the owner does not confirm by 31 October 2026, our software stops trading the vault on 1 November 2026 and cancels its open orders, including stop-loss orders, and we tell the owner. From then on, the vault stays in its last positions unless depositors withdraw.
• Manager fees. Manager fees are claimed straight to the owner's verified payout address. The owner proves control of that address by signing in with that wallet. Changing the address needs the owner to sign in again, and takes effect after 48 hours.
• On 31 December 2026. Trading and orders stop, a final manager-fee claim is sent straight to the owner's payout address, and the keys are permanently destroyed. After that, nobody can trade the vault or claim its fees, and it stays in its last positions.
• Depositors can leave directly. Depositors can withdraw directly from the vault's smart contract at any time, before and after 31 December 2026, subject to the vault's settings and to section 4.3.
• Moving to a new vault. An owner can create a new Copilot-run vault under sections 6.1 to 6.7 and tell their depositors. Depositors who want to move must withdraw and deposit again themselves. We never move depositors' assets. Moving can cost network fees and any early exit fee, and it can have tax consequences.

7. Your own wallet and account

• Losing your keys. We never hold the private key or recovery phrase of your own wallet. If you lose them, or someone else gets them, you may lose everything in that wallet, and control of any vault it manages. If you use an email or social-login wallet, the wallet provider's sign-in protects your wallet instead, so keep that sign-in secure. We cannot recover keys, and we cannot reverse transactions.
• Scams and impersonation. Fraudsters create fake websites, fake Telegram bots and fake support accounts. Our only official Telegram bot is @aspisprotocol_bot. We will never ask for your wallet's private key or recovery phrase, or for your vault API key.
• Token approvals. When you approve a smart contract to use your tokens, it can move them. A malicious or faulty contract you have approved can take your tokens.
• Signing permissions. Read what your wallet shows you before you sign anything, including the automated-trading permission. Only sign permissions on the official web app or through the official Copilot bot.
• Mistakes cannot be undone. If you send cryptoassets to the wrong address or on the wrong network, they are usually lost.
• Connection services can fail. Wallet connection services, such as WalletConnect, can stop working, either on the provider's side or because of an error in how we have set them up. That may stop you using your wallet with the web app for a time.
• Telegram. Copilot works only through Telegram. If Telegram is unavailable, or you lose access to your Telegram account, you may not be able to use Copilot, including to give instructions for a Copilot-run vault. You can still revoke the permission or trade the vault from your own wallet.

8. AI output and automated information

• AI can be wrong. Copilot's answers and reports are produced by AI models. They can be wrong, out of date or made up, and they can sound confident when they are wrong.
• Nobody checks it first. No person checks AI output, including market reports, before you see it.
• Reports describe, they do not recommend. Copilot's market reports and technical-analysis reports describe indicators. They do not tell you to buy or sell. They are general information, not advice, even when they refer to your vault.
• Alerts about other wallets. Alerts about trades by wallets you follow can be delayed or incomplete. The wallets you follow may be trading for reasons you do not know, and some may deliberately take advantage of people who copy them. By the time you act, the price may have moved. Copilot does not copy trades automatically. If you use the Copy button, the trade is your decision and carries the same risks as any other trade.
• Technical analysis looks backwards. Technical-analysis reports describe past price patterns. They cannot predict future prices.
• Wallet analysis is limited. Analyses of wallets are based on public blockchain data and can be incomplete or wrong.

9. Performance figures and other information we show

• Past performance is not a reliable guide to future results.
• Performance figures are estimates. A vault's page shows its history, which we calculate from blockchain and price data. The figures can be wrong or delayed, and they may not reflect all fees and network costs. They may not match your own result, which depends on when you deposited and withdrew. Short track records can be especially misleading.
• Vault lists are not rankings. We list vaults in a neutral order, not by performance. A vault's place in a list does not mean we have checked it or recommend it.
• Vault information comes from creators. We do not check it.
• Third-party data can be wrong. Prices, balances and other data from third-party providers can be wrong or delayed.

10. Conflicts of interest

• We run our own trading. We operate a vault of our own that is traded using AI. We do not publish its trades.
• People may hold what we mention. Our staff, vault creators and other users may hold or trade cryptoassets that Copilot's reports mention or that vaults hold.
• How we earn money. We earn money from paid plans.

11. Blockchain networks and other third parties

• Networks. Blockchain networks can become congested. Transactions can then be slow or expensive, or can fail, and you still pay network fees for failed transactions. Networks can also stop, split, or be changed by their developers.
• Exchanges. Vault trades go through exchanges and exchange aggregators, currently 1inch, Odos and Uniswap. They can fail, be exploited or give poor prices.
• Price feeds. Price feed providers can change, pause or retire their feeds (see sections 4.3 and 4.4).
• Wallet providers. If you use an email or social-login wallet, you depend on its provider to sign in to your wallet. If the provider is unavailable, you may not be able to use your wallet for a time.
• Data providers. The data we show comes partly from third-party providers and can be wrong or delayed.
• Other services. Copilot depends on Telegram and on our AI providers. If they are unavailable, Copilot may not work.

12. Our own operations

• Faults and attacks. Our systems can fail, contain errors, be attacked, or be affected by human error. The web app or Copilot could show wrong balances, prices or performance.
• Changes to the Services. We may change or stop Services, as our Terms of Use describe.
• If Aspis stops operating. Our software would stop trading Copilot-run vaults. Owners of vaults created from 1 October 2026 keep control through their own wallets, but legacy vaults could no longer be traded and their fees could not be claimed. Nobody might maintain the shared registries either. A later price-feed failure could then block deposits into any vault, and withdrawals from vaults created before 1 October 2026, indefinitely.
• No compensation scheme covers any of these risks.

13. Legal and regulatory risks

• Laws can change. Changes in the law in the UK or in your country could make some Services unavailable to you, or change how they work.
• Uncertain status. The legal, regulatory and tax treatment of vaults and vault tokens is uncertain and differs between countries.
• Your local law. You are responsible for making sure you are allowed to use the Services where you live. If you use them where it is not allowed, we may suspend your access.
• Sanctions. Sanctions can change quickly. They may affect whether we can keep providing the Services to you.

14. Tax

• You are responsible for your tax. Tax on cryptoassets can be complex. In the UK, HM Revenue and Customs treats most cryptoassets as property. Swapping one cryptoasset for another, depositing into or withdrawing from a vault, and receiving manager fees can all have tax consequences. The rules are different in other countries.
• Keep records. Keep your own records of your transactions. We do not give tax advice or provide tax reports.
• Further information. HMRC's guidance is in its Cryptoassets Manual. If you are unsure, speak to a tax adviser.

15. Questions to ask yourself before you deposit or trade

• Can I afford to lose everything I am putting in?
• Do I understand how this vault works, what it charges and when I can withdraw?
• Who runs this vault, and why do I trust them?
• Is this a Copilot-run vault, where Aspis's software carries out the owner's trades, or a legacy vault?
• Which tokens does the vault hold or trade, and how easy are they to sell?
• Am I using the official website and the official Copilot bot?
• Do I understand the tax rules that apply to me?
• Am I allowed to use the Services where I live?

If you are not comfortable with your answers, think carefully before you go ahead, and consider getting independent advice.

16. Contact us

If you have questions about this Risk Disclosure, email us at info@aspis.finance or write to us at our registered office.