Client Information Handling

Rules of Arev Securities hf. on Client Information

Introduction.

These rules are made in accordance with Article 19(b) of the Act on Financial Undertakings, No. 161/2002. The rules govern how information on individual clients is maintained. All information provided by a client about their financial situation and that of related parties shall be treated as confidential.

How information is managed.

Employees who have access to confidential information from clients shall, in the course of their work, first and foremost comply in all respects with the requirements set out in the signed confidentiality agreement, if one has been made. If no confidentiality agreement is in place, they shall comply in full with the rules of Arev Securities concerning security and communication protocols.

Employees must respect and promote compliance with the provisions of applicable laws and regulations concerning the handling of insider information and confidentiality.
Confidential and insider information shall be kept within as narrow a group as possible. An employee is only permitted to disclose such information if, in light of their position, they have authorisation to do so or have received authorisation from a superior, and if the recipient requires the information for their job or position, or if the law requires such information to be provided. The disclosure of information must comply with the provisions of the law on the handling of inside information and the provisions of the law on the confidentiality obligations of employees of financial institutions.
Documents marked as confidential shall only be opened by those who are clearly authorised to access such information. If there is any doubt, the head of the relevant department is authorised to open such documents to verify the individual's authorisation to access them.
Employees must ensure that confidential and insider information is protected from access and does not reach unauthorised persons, i.e. those who do not necessarily need such information for their work or position. Such information should, where appropriate, be stored in locked cabinets or saved in databases to which only relevant personnel have access.
Confidential and insider information must not be left out in the open at the end of the working day, nor should it be handled in such a way that unauthorised persons can access it. Furthermore, computer access must always be properly locked at the end of the working day.
The duplication of data containing confidential or insider information shall be kept to a minimum.
The person sending confidential or insider information must ensure that it is received only by the intended recipient.

Decision on the client contact person

Each agreement entered into with a client (including contracts for work) shall specify which entities of Arev Securities are the client's contacts and have access to their data.

Accessibility

These rules shall be made available to clients, and they shall be informed of their existence when entering into agreements for business with Arev Securities hf.

Disclosure of information about traders and supervision.

The company's Compliance Officer is responsible for, and makes decisions on, the disclosure of information about clients to internal audit, regulatory authorities and the police, in consultation with the company's Managing Director. Should such enquiries be received by staff, they must be referred to the Compliance Officer without exception.

The following shall apply to supervision under the rules:

The club's rules officer shall oversee compliance with the provisions of the rules, take the lead in their interpretation and make decisions in accordance with them. The rules officer shall also provide training at least once a year.
Duty to report. The Compliance Officer shall report breaches to the board or the managing director, as appropriate. The managing director or the board shall send information about the breach to the Financial Supervisory Authority.
Complaints. The Compliance Officer shall keep a record of complaints from clients regarding alleged breaches of the rules and direct them to the appropriate channel.

Sanctions.

Breach of these rules may be subject to an administrative fine or a criminal penalty, in accordance with the Securities Trading Act No. 108/2007. Furthermore, breaches of the rules may result in a reprimand or dismissal.

Coming into force.

These rules supersede the previous rules adopted in 2025. These rules shall come into force upon the approval of the company's board of directors.

Approved by the Board of Directors of Arev Securities hf. on 27 March 2026.

Terms of Reference for the Managing Director of Arev Securities hf.

General

These rules are issued on the basis of Act No. 161/2002 on financial undertakings, and in light of, inter alia, the requirements set out in Regulation No. 150/2017 on the conduct of fitness and propriety assessments of senior executives and members of the board of financial undertakings.

Eligibility requirements

The managing director shall at all times meet the fitness requirements set out in Article 52 of the Act on financial undertakings, No. 161/2002 (general fitness requirements), or any statutory provisions which replace or supplement them. The managing director shall at all times comply with the fitness requirements set out in Article 52. of the Act on Financial Undertakings are made for staff in securities business, as well as the conditions imposed on executive directors in Regulation No. 150/2017 on the conduct of fitness and propriety assessments for the executive directors and members of the boards of financial undertakings. Furthermore, the Managing Director shall at all times meet the requirements that Arev imposes on key personnel, in accordance with Arev's rules on the eligibility of key personnel.

Division of responsibilities between the board and the managing director

The Managing Director is responsible for the company's operations to its board, and for ensuring that its activities are carried out within its operating licence and in accordance with the relevant legislation.

The board determines the association's strategy and working methods. The managing director participates in shaping the company's strategy for both the short and long term. He is responsible for implementing the policies approved by the board. Any project considered major, or any other significant decision, must be submitted to the board of directors or the chair of the board before a decision is made. Projects are considered major and decisions significant if they deviate in material respects or in a significant way from the approved plan for the relevant operating period.

The duties of the Managing Director are the management of the company's day-to-day operations; personnel management and other matters relating to general business. The Managing Director represents the company in all matters concerning its ordinary business. The Managing Director is responsible for hiring, dismissals and employment contracts with the company's employees. The Managing Director is responsible for the accounting. The Managing Director shall provide the board members and auditors with all information about the company's operations that they may request and are required to provide by law. Such information shall, as a rule, be provided at board meetings.

Regular reporting to the board

The Managing Director shall ensure that the board receives the following information:

At the end of each year, a budget for the following year's operations and investments shall be submitted.
1. The annual accounts shall be presented within three months of the end of the financial year.
1. The half-yearly accounts shall be available within two months of the end of the period.
1. The following shall be on the agenda for board meetings:
  1. Statement of Equity
  1. An overview of the year's income and expenditure up to the end of last month.
1. Annual report on the activities of the compliance officer, the money laundering and terrorist financing reporting officer, and the internal auditor.

Other duties of the managing director

The Managing Director is not permitted to undertake any other paid or unpaid work for a third party without the written consent of the Board in each individual case. The Managing Director is permitted to serve on the board of companies connected with the company's operations, but this requires the board's approval on each occasion, which must be recorded in the minutes of the board meetings. The Managing Director is permitted to undertake part-time teaching at university level without written approval.

These rules are not exhaustive of the executive director's other duties and obligations to the board or Arev. The executive director's duties and obligations are further detailed, for example, in Arev's articles of association, the board's rules of procedure, and the rules on the eligibility of Arev's key personnel.

Obligation of confidentiality

The Managing Director is bound by confidentiality regarding everything he becomes aware of in the course of his work that is intended to be confidential, unless it concerns circumstances which, by their nature, must be disclosed to a third party.

Coming into force

These rules shall come into force upon the board's signature. Furthermore, the previous rules of procedure for the Managing Director shall be repealed from 2025.

So resolved at a board meeting of Arev Securities hf., 27 March 2026.