ANTI FRAGILE
SYSTEM

1. Status of the Notice and Authority

This notice is published by the acting Managing Partner of the Anti Fragile System (Global) group of companies, within the scope of their authority in risk management, compliance, and the protection of third-party interests.The notice reflects the official position of the company’s governing body and forms part of its internal risk management and due diligence procedures.

2. Status and Role of the Identified Individual

Ms. Yulia Brottsman (hereinafter referred to as the “identified individual”) is not a managing partner nor a person exercising management over Anti Fragile System.During the period of cooperation and as of the date of publication of this notice, the identified individual holds a minority ownership interest.The acting director of the company has not received any notifications regarding the transfer, disposal, or other change of the specified ownership interest, and no documents confirming the withdrawal of the identified individual from the shareholders of the company have been signed by the director.In light of ambiguous and mutually inconsistent public statements made by the identified individual regarding her status and role, the company is conducting a review of the circumstances related to the public positioning of the identified individual and potential attempts to misrepresent her corporate status.Irrespective of the ownership interest status, during the period from 2023 until the date of publication of this notice, the identified individual was granted extended operational access, including involvement in client-related and operational activities, within the framework of preparation and training for work with the company’s clients.Such access did not constitute a managerial, representative, or dispositive mandate and did not confer authority to make corporate, financial, or strategic decisions on behalf of the company.

3. Identification of Risks

As a result of internal review and analysis of corporate processes, the following categories of material risks associated with the actions of the identified individual have been recorded:

— unauthorized disclosure of confidential information, including sensitive client data;

— breach of contractual obligations, including confidentiality provisions (NDA);

— causing financial damage to the company and generating related reputational and operational risks;

— risks to third parties arising from public statements, representations, and positioning of the identified individual.These risks have been confirmed at the company level and are currently subject to internal and external review.

4. Public Positioning and Risk of Misinformation

The company has identified mutually inconsistent public self-presentations of the identified individual across professional and public communication channels.These representations use varying and uncoordinated status qualifications, including wording that creates the impression of ownership, management, or partnership at a decision-making level.Such public qualifications do not correspond to the company’s corporate structure, the actual distribution of ownership interests, or the scope of managerial authority.These inconsistencies are capable of:

— misleading clients, partners, and third parties;

— distorting the perception of responsibility allocation;

— creating additional reputational, operational, and compliance risks.The recorded discrepancies in public positioning emerged after the identification of contractual breaches and the occurrence of damage, which necessitated additional risk fixation and clarification of the status and role of the identified individual for third parties.

5. Temporary Risk Classification and Restrictive Measures

Until the completion of the relevant procedures, the identified individual is classified by the company as a temporary element of heightened risk.Accordingly, the company officially states that:

— any affiliation, partnership, representation, or other interaction between Anti Fragile System (including affiliated entities) and Yulia Brottsman is neither confirmed nor supported;

— the company does not confirm or support any public statements, self-presentations, or positioning made by the identified individual in the context of consulting, coaching, strategic advisory, or management;

— any communications related to this matter are conducted exclusively through the acting director and/or managing partner of the company.

6. Regulatory and Status Context (ACC / PCC)

The company is aware that the identified individual continues to publicly use and declare professional statuses (including ACC / PCC) obtained during the period of cooperation and training financed by the group’s corporate structures.In this regard, the company draws the attention of third parties to the following:

— the existence of a formal professional status does not exclude the identified risks;

— public declarations of ethical, moral, and professional standards do not confirm the absence of harm caused to clients and partners;

— the use of such statuses in the current context may create a false sense of safety for third parties.

7. Conditional Legal Qualification and Subject of Review

In the event of an attempt to transfer or dispose of the identified minority ownership interest to third parties without proper notification of co-owners and the acting director of the company, and without compliance with mandatory corporate and notarial procedures, such actions will be regarded as violations of applicable corporate law and may entail civil, administrative, and (in the relevant jurisdiction) criminal liability.Until the completion of the review and receipt of official confirmations, the company refrains from legal qualification of such actions and records this matter as the subject of a separate legal and regulatory analysis.The stated position and conclusions regarding potential risks are formed exclusively on the basis of public statements and materials disseminated by the identified individual in open sources and are not based on internal documents or confirmed corporate notifications that, as of the publication date of this notice, have not been received by the acting director of the company.

8. Warning to Third Parties

The company officially warns all individuals and legal entities that:

— any financial, consulting, strategic, or other interaction with Yulia Brottsman,

— as well as the transfer of sensitive, commercial, or personal information,is carried out solely at the discretion and risk of such parties.The company bears no responsibility for any consequences of such interaction.

9. Disclaimer

This notice:

— does not constitute an admission of fault by any party;

— does not contain final conclusions of any investigation;

— is published exclusively for the purposes of risk management, compliance, and the protection of third parties.This notice may be supplemented and clarified as new information becomes available and relevant procedures are completed; the current version of the notice is published with the date of amendments and additions indicated.