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Stifel Institutional Client Access Terms of Use Agreement

Last updated February 25, 2025

Welcome to Stifel Institutional Client Access.

PLEASE REVIEW THIS AGREEMENT, WHICH SETS OUT THE TERMS OF YOUR USE OF STIFEL INSTITUTIONAL CLIENT ACCESS (“CLIENT ACCESS” OR THE “PLATFORM”) AND THE CONTENT (DEFINED BELOW) AND THE SERVICES (DEFINED BELOW) PROVIDED ON THE PLATFORM. THIS IS A BINDING AGREEMENT BETWEEN YOU AS A USER OF THE PLATFORM AND THE SERVICES (A “SUBSCRIBER”) AND STIFEL, NICOLAUS & COMPANY, INCORPORATED, THE PROVIDER OF THE PLATFORM AND THE SERVICES. BY ACCESSING THE PLATFORM AND/OR USING THE SERVICES, YOU AGREE TO BE BOUND BY AND TO COMPLY WITH THIS AGREEMENT.

YOU ARE BEING GIVEN ACCESS TO THE PLATFORM BECAUSE YOU ARE AN EXISTING CLIENT OF STIFEL, NICOLAUS & COMPANY, INCORPORATED, AND HAVE ENTERED INTO SEPARATE AGREEMENT(S) WITH STIFEL, INCLUDING, WHERE APPLICABLE, THE STIFEL ACCOUNT AGREEMENT AND DISCLOSURE BOOKLET

(https://www.stifel.com/disclosures/account-agreement). THE TERMS OF SUCH OTHER AGREEMENT(S) ALSO GOVERN YOUR USE OF THE PLATFORM AND THE SERVICES. IF YOU ARE NOT A CLIENT OF STIFEL, OR DO NOT AGREE TO BE BOUND BY AND COMPLY WITH THIS AGREEMENT, YOU MUST IMMEDIATELY CEASE ACCESSING THE PLATFORM AND USING THE SERVICES.

THIS AGREEMENT REQUIRES ALL DISPUTES TO BE RESOLVED BY WAY OF BINDING ARBITRATION. THE TERMS OF THE ARBITRATION CLAUSE APPEAR IN SECTION 14 BELOW OF THIS AGREEMENT.

1. Our Services

Stifel, Nicolaus & Company, Incorporated (“Stifel,” “we,” “us,” or “our”) is the provider of the Platform. The Platform is an online financial information retrieval and management platform that allows you, as a Subscriber (“you” or “your”), to, among other things, view, consolidate, and manage some of the information concerning your account(s) with Stifel or any of our affiliates (“Stifel Account Data”). All content delivered on the Platform shall collectively be referred to as the “Content,” and all services delivered on the Platform shall collectively be referred to as the “Services.” The Platform is provided strictly as a convenience and is not, and shall not be considered, a substitute or replacement for account statements or other documentation provided by Stifel or any of our affiliates or third- party account providers. Please consult your official account statements for information regarding your account balances, positions, and transactions.

2. Your Agreement with Stifel

This Agreement, and any amendments hereto (collectively, this “Agreement”), is an agreement between you and us which sets forth the terms and conditions applicable to your access and use of the Services. This Agreement incorporates by reference our Privacy Statement (https://www.stifel.com/privacy), which governs how we gather, use, disclose, and process your personal data. PLEASE READ OUR PRIVACY STATEMENT

(https://www.stifel.com/privacy) CAREFULLY.

You represent that you are of applicable legal age and able to enter into legally binding contracts, and you agree that this online Agreement legally binds you in the same manner that you would be bound by a signed, written, paper contract. You may not use the Platform or the Services in any manner, or attempt to access the Platform or the Services, if you are not willing to be bound and abide by this Agreement.

We reserve the right to change or modify any portion of this Agreement or our Privacy Statement (https://www.stifel.com/privacy), or modify or discontinue any portion or all of the Services or features and functionality provided through the Platform, from time to time. If we decide to change this Agreement, we will notify you (in a manner consistent with Section 15 below) and post

or provide a link to the amended Agreement on the Platform or otherwise on our website. You agree that such changes will be effective at the time such notice of the amended terms is provided, and that such notice constitutes adequate and effective notice. By accessing and logging in to the Platform and/or accessing the Services, after such amendment, you are agreeing to the Agreement terms as amended.

3. Fees for the Platform and the Services

Your use of the Platform and the Services are offered free of charge as part of your relationship with Stifel. Stifel reserves the right, in our sole discretion, to amend or change its pricing policy for its current Services or any additional services that we may offer.

4. Your Obligations and Eligibility to Use the Services

By agreeing to this Agreement and accessing the Platform and/or using the Services, you acknowledge and agree that:

  1. The Platform and the Services are provided by Stifel, but we may retain affiliates and/or other third-party services providers to assist or support us in providing the Services (including with respect to any security, technology, support, legal, compliance, administrative, or similar function) (each a “Third-Party Provider”).
  2. The Platform and the Services are intended to be accessed and used only by individuals who have reached the legal age of majority in the jurisdiction where they are located, which may be 18 years or older, depending on the jurisdiction. You may not use or access the Platform and the Services unless you have reached the legal age of majority in the jurisdiction where you are located.
  3. You represent and warrant that (i) you are not located in a country that is subject to a U.S. government embargo, or that has been designated by the U.S. government as a “terrorist-supporting” country, and (ii) you are not listed on any U.S. Government list of prohibited or restricted parties.
  4. The Platform and the Services depend on your provision to us of, and you agree to provide, complete, accurate, and up-to-date information for as long as you use the Platform and the Services.
  • You represent that you are a customer of Stifel and acknowledge and agree that your relationship with Stifel, including any investment advice or recommendation that may be unintentionally construed as being delivered through the Platform, is governed by the terms and conditions contained in the agreement(s) you have entered into with Stifel, including, where applicable, the Stifel Account Agreement and Disclosure Booklet (https://www.stifel.com/disclosures/account-agreement). For the avoidance of doubt, the terms and conditions of this Agreement apply specifically to the Services available through the Platform, and are not intended to supersede the terms and conditions of the other agreements you have entered into with Stifel (including, where applicable, the Stifel Account Agreement and Disclosure Booklet), which relate generally to your account with Stifel and the services Stifel provides to you.
  • Prohibited Use of the Services. We and our Third-Party Providers have the right but not the obligation to monitor and remove any communications content in the Platform or any Service that we find in our sole discretion to be objectionable in any way. You will NOT do any of the following:
    • Violate any applicable law or contractual duty or use the Platform, the Services, or any User Profile (defined below), Stifel Account Data (defined above) for illegal purposes;
    • Use the Platform or the Services to transmit anything that is threatening, abusive, obscene, vulgar, offensive, profane, unlawful, libelous, intended to harass, violate the rights of another, or otherwise inappropriate, as determined by us;
    • Disseminate information on the Platform that is intended to adversely affect or could reasonably be expected to materially adversely affect any third party or its business based on the reasonably contemplated dissemination of such information relating thereto on the Platform and subsequently by other users;
    • Engage in behavior that will put your Personal Information at unnecessary risk, such as leaving, transmitting, or publishing your Credentials (defined below);
    • Disclose or misuse any trade secret or other confidential business information, or infringe on any patent, trademark, copyright, right of publicity, or other right of any other person or entity;
    • Resell, transfer, or make any commercial use of the Platform or the Services, as they are intended solely for your use as an end user;
    • Create/register accounts or aggregate financial institutions with the Service through unauthorized means, including by using an automated device, script, robot, spider, harvester, crawler, or scraper;
    • Reverse engineer or decompile any technology associated with the Platform or the Services, including to any software applications, Apps (defined below), Java applets, or plug-ins associated with the Services;
    • Use any robot, spider, web crawler, scraper, deep link, or similar automated extraction or data-gathering mechanism, program, or tool to access, copy, or monitor (including, manually or automatically) the Platform or the Services or any portion thereof without our prior written consent;
    • Post or transmit any file or e-mail which contains malware, including viruses, worms, Trojan horses, or any other damaging or destructive elements;
    • Disseminate information that you know, or should know based on reasonable inquiry, contains software viruses, any other computer codes, files, or programs that are designed or intended to disrupt, damage, limit, or interfere with the proper function of the Platform or the Services or any associated software, hardware, or telecommunications equipment, or to damage or obtain unauthorized access to any system, data, password, or other information of us or of any third party;
    • Take any action that imposes or may impose (as determined by us) an unreasonable or disproportionately large load on our (our affiliates’ or our Third-Party Providers’) infrastructure, unless you obtain our prior express written consent in each instance, which we may rescind at any time, with or without notice or cause;
    • Interfere or attempt to interfere with the proper functioning of the Platform, the Services, or any activities conducted on the Platform;
    • Seek to access the information of any other user of the Platform, without such user’s consent; or
    • Bypass or circumvent, or attempt to bypass or circumvent, any measures we may use to prevent or restrict access to the Platform (or other accounts, computer systems, or networks connected to the Services).

5. Our Right to Suspend or Terminate Your Access

In addition to our rights to terminate this Agreement under Section 13 below, we reserve the right to modify, temporarily suspend, or permanently discontinue your access to the Platform or any portion thereof, or any of the Services (in our discretion,

temporarily or permanently), notify law enforcement, regulatory authorities, impacted third parties, and others as we deem appropriate, and/or take legal action against you, including where we (a) believe that the Platform or the Services are being used in violation of this Agreement or applicable law; (b) believe your use of the Platform or the Services interferes with the normal operations of the Platform or creates any threat to the security of the Platform or other users thereof, or otherwise breaches this Agreement; (c) become aware of what we, in our sole discretion, deem a credible claim that the Platform or any portion thereof infringes upon the intellectual property rights of a third party; or

(d) are required to do so by law, in each case with or without prior notice to you. We also reserve the right, at any time, to modify, add to, or remove any portion or feature of the Platform or the Services, and you agree that we shall not be liable to you or any third party for any such modification or cessation of the Platform or the Services or any modification of this Agreement.

Your right to access the Platform and use the Services is revoked where this Agreement or use of the Platform or the Services is prohibited or to the extent the offer, sale, or provision of the Platform or any of the Services conflicts with any applicable law, rule, regulation, policy, procedure, contract, agreement, or understanding. Stifel may, in its sole discretion, revoke any user’s access or refuse to offer any user access to the Platform or the Services, or change the Platform’s eligibility criteria, at any time.

6. Your Registration Information and Credentials

In order to use the Platform or the Services, you first need to create a Platform user account (“User Profile”) through the Platform. To establish a User Profile, you must provide true, accurate, and complete Personal Information (defined below) that is collected on the secure enrollment page, and

also promptly maintain such information as true, accurate, and complete. We may deny your registration for a User Profile, for any reason and at our sole discretion.

You agree and understand that you are responsible for maintaining the confidentiality of the login information and password for your User Profile (“Credentials”). You should also maintain appropriate anti-virus software on your computer or other device used to access the Platform and the Services, as well as keep the operating system of such computers or devices up-to- date, so that your Credentials are not compromised through your own negligence. If you think your Credentials have been lost, stolen, or otherwise compromised, or that someone has committed fraud by accessing your Credentials, you must contact us IMMEDIATELY at [email protected] (mailto:[email protected]).

7. Your Data and Associated Risks

The data that you supply to the Platform and the Services, including Stifel Account Data (whether directly by you, which is transferred to the Services through connections with your third-party financial institutions or Stifel or its affiliates, to other users, or otherwise) (collectively, “Your Data”) is your confidential information, and we will process and use it only as permitted in this Agreement.

The overall accuracy and integrity of the data collected in the Platform and the Services is an important element in providing you with an accurate picture of your personal finances. Stifel, however, shall not be responsible for and cannot guarantee the accuracy or timeliness of (i) Your Data, Stifel Account Data, or other information retrieved from third-party financial institutions where your accounts are held; or (ii) data available in the Services that is supplied by third- party research/market data providers.

You acknowledge that when you share or disclose any of Your Data, Stifel Account Data, or other information retrieved from third-party financial institutions where your accounts are held to other subscribers on the Platform, you do so at your own risk and without Stifel’s control. You should not share Your Data, Stifel Account Data, or other information retrieved from third-party financial institutions where your accounts are held with other subscribers on the Platform that you deem to be private or confidential information.

You should at all times maintain copies of Your Data. We have the right to retain any or all of Your Data in connection with the provision of the Services, including for record-keeping purposes, to the extent such data exists in business records or in archived materials, or as may be necessary to comply with any regulatory requirements or other applicable law, and/or to protect and enforce its rights hereunder.

You acknowledge that it cannot be guaranteed that software and technology systems will be free of error or failure. We may not be able to foresee or anticipate technical or other difficulties which may result in any of the following (whether by us, our affiliates, Third-Party Providers that assist us in providing the Services, or any necessary systems, equipment, or network for communications): a failure to obtain data, corruption of data, unauthorized access to Confidential Information (defined below), errors in the Platform, the Services, personalization settings, service failures, or other service interruptions. Stifel assumes no responsibility for the timeliness, accuracy, deletion, non-delivery, or failure to store any user data, loss of user data, communications, or personalization settings. You are encouraged to periodically confirm the data presented by the Services directly with independent sources or providers, such as an investment adviser, broker-dealer, or other financial institutions where you maintain accounts.

You acknowledge that there are risks inherent in maintaining Your Data in a remote server and software network (“cloud-based”) environment, including the risk of hacking or other unauthorized third-party access to Your Data, including your Personal Information (defined below), and exposure to viruses and malware. Stifel and our affiliates shall not be responsible to you for any unauthorized access to Your Data or the unauthorized use of the Services.

Your Data may contain information that identifies a particular individual, such as names and e-mail addresses (collectively, “Personal Information”). For all Personal Information that you supply to the Platform or the Services (whether directly by you, through connections with your third-party financial institutions, Stifel or its affiliates, to other subscribers, or otherwise), you agree that you have sufficient rights under applicable law (including U.S. privacy law and any E.U. Privacy Directives) to transmit, store, copy, use, and transfer into the Platform such Personal Information, and to authorize Stifel and any of its affiliates and Third-Party Providers to process Your Data in connection with the provision of the Services.

You acknowledge that Stifel will collect and create data related to your use of the Platform and the Services, including metadata generated by your activity on the Platform (“Activity Metadata”), as well as aggregated and/or de-identified data that is derived from Your Data and data of or related to other subscribers (including User Profile, Stifel Account Data, and Activity Metadata (such aggregated and anonymized data, “Derived Data”).

We may access, archive, or monitor Activity Data, and we may use tools, scripts, software, cookies, and utilities to monitor and administer the Platform and provide the Services. You also consent to the recording of any electronic or written correspondence and any or all telephone conversations between you, us, and any of our affiliates in connection with this Agreement, the Platform, or the Services and agree and understand that recordings may be submitted in evidence in any legal proceeding relating to this Agreement. For compliance and regulatory purposes, we reserve the right to keep an audit trail of your use of the Platform and the Services and all information that we provided to you. You agree that our monitoring activities shall not entitle you to any cause of action or other right with respect to

the manner in which we monitor your usage of the Platform and enforce, or fail to enforce, this Agreement and we shall not be liable for any damages resulting from such monitoring.

8. Feedback and Confidentiality

We are happy to receive feedback from you, including any complaints, comments, or suggestions related to the Platform and the Services, whether provided in writing or orally (collectively,

“Feedback”). You agree that all Feedback becomes our Confidential Information and that you irrevocably assign to us all rights, title, and interest in and to the Feedback. Feedback may be submitted to [email protected] (mailto:[email protected]).

In connection with our provision of the Platform and the Services, we may provide, or you may come to learn of information (nonpublic or otherwise), including business and technical information relating to the Services, the Platform, investment research reports, and other market commentary, all of which is deemed confidential and/or proprietary (“Confidential Information”). During the term of this Agreement and for a period of three (3) years thereafter, you agree not to disclose, reproduce, or otherwise upload, publish, or distribute in any way whatsoever the Confidential Information, except as you may be required or otherwise compelled by operation of law or regulation.

Notwithstanding the foregoing, nothing contained in this Agreement prohibits, limits, or restricts you from communicating with any federal or state regulatory agency or body about the Services. If you inadvertently receive information about another person or Platform end user through any Service, you agree to promptly notify us, and to keep such information confidential.

9. Content or Tools Provided by Third Parties

To facilitate our provision of the Platform and the Services, we license Content or tools from certain third parties. From time to time, we may revise this Agreement as requested by such third parties as licensors and/or require that you agree to additional pass-through terms with respect to such third parties. We make no guarantee as to the accuracy, timeliness, completeness, or usefulness of any Content or tools from such third parties, and you agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with your downloading, installing, use of, or

reliance on any data, content, or software provided by/from such third parties, irrespective of whether the data, content, or software provided by these third parties are provided from within the Platform or require you to leave the Platform and enter the website of such third party. Your use of the data, content, or software provided by such third party shall be subject to the terms of use/service and the privacy policy of such third parties. Also, when you use or access the websites of your financial services providers, you will be subject to their terms of use/service and any other policies they may have.

10. Ownership, Copyright, and Trademark

The technology and Content used to offer, or provided in connection with, the Platform, the Services, Feedback, Derived Data, Activity Metadata, browser software plug-in, smart phone software, and tablet software, and all intellectual rights in the foregoing (collectively, “Stifel Property”) are either owned by us or licensed by us from a third party as described in Section 11 above, and nothing in this Agreement shall restrict the applicable owner from sharing or otherwise using Stifel Property for any purpose. Such Content includes the look and feel of the Platform, all our promotional materials, and in general includes all text, information, research, graphs, graphics, photographs, illustrations, images, videos, tutorials, notices, page headers, custom graphics, button icons, scripts, software, and other content, which is protected by the copyright law of the United States and international treaties, trademark and patent laws, and other intellectual property laws.

In connection with your use of the Platform and the Services, we grant you a revocable, non-exclusive, limited, and royalty-free license during the term of this Agreement for you to use (i.e., to download and display locally and print) the Platform and the Services solely for your personal, non-commercial use.

All trademarks and logos appearing on the Platform are either trademarks or registered trademarks that belong to us, the Third- Party Providers, or our licensors. You may not copy, reproduce, perform, create derivative works from, republish, upload, post, transmit, or distribute in any way whatsoever any of our Content, information, or the trademarks that appear on the Platform without express, written consent from us.

You do not acquire any ownership interest in any Stifel Property as part of your access to the Platform or the receipt of any the Services, and no license rights (including rights arising by implication or estoppel) are granted to you other than those expressly granted in this Agreement.

By accessing and using the Platform, you hereby grant to us a worldwide, non-exclusive, perpetual, irrevocable, royalty-free, fully paid, sublicensable, and transferable license to use, edit, modify, truncate, aggregate, reproduce, prepare derivative works of, display, store, analyze, process, adapt, publish, distribute, incorporate, perform, and otherwise fully use Your Data (including User Profile, Stifel Account Data, or External Account Data) into any form, medium, or technology now known or later developed only as necessary to provide the Services and to operate, develop, and maintain the Platform in accordance with this Agreement.

11. Disclaimer of Representation and Warranty; Disclaimer of Liability

NOTWITHSTANDING ANYTHING TO THE CONTRARY HEREIN, STIFEL AND OUR AFFILIATES, THIRD-PARTY PROVIDERS, LICENSORS, AND AGENTS (COLLECTIVELY, THE “STIFEL ENTITIES”) MAKE NO, AND HEREBY DISCLAIM ALL, REPRESENTATIONS OR WARRANTIES OF ANY KIND WITH RESPECT TO THE SERVICES AND THE PLATFORM, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON- INFRINGEMENT. ALL SERVICES ARE PERFORMED AND THE PLATFORM ARE PROVIDED ON AN “AS-IS, AS-AVAILABLE” BASIS,

AND THE STIFEL ENTITIES ASSUME NO RESPONSIBILITY FOR ERRORS OR OMISSIONS MADE BY YOU, OR ERRORS OR OMISSIONS IN THE CONTENT WHICH ARE REFERENCED BY, LINKED TO, OR PROVIDED BY OR THROUGH THE SERVICES AND/OR THE PLATFORM. YOUR USE OF THE PLATFORM AND THE SERVICES AND ALL CONTENT (INCLUDING THAT OF THIRD PARTIES) INCLUDED IN OR ACCESSIBLE THEREIN IS AT YOUR SOLE RISK. THIS PARAGRAPH GIVES YOU SPECIFIC LEGAL RIGHTS, AND YOU MAY ALSO HAVE OTHER LEGAL RIGHTS THAT VARY FROM STATE TO STATE.

WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, THE STIFEL ENTITIES SHALL NOT BE LIABLE FOR THE ACCURACY OR RELIABILITY OF ANY CONTENT, FOR ANY SERVICES INTERRUPTIONS, INTERNET OR TELECOMMUNICATIONS FAILURE, OR YOUR INABILITY TO ACCESS THE SERVICES OR THE PLATFORM OR FOR ANY FAILURE OR DELAY RESULTING FROM ANY FORCE MAJEURE EVENT (DEFINED BELOW). STIFEL AND THE STIFEL ENTITIES CANNOT ALWAYS ANTICIPATE TECHNICAL OR OTHER DIFFICULTIES WITH THE SERVICES, EITHER PRESENTLY OR AS THEY EVOLVE; THE PLATFORM AND THE SERVICES MAY CONTAIN BUGS, ERRORS, OR OTHER PROBLEMS, WHICH MAY RESULT IN LOSS OF DATA OR SETTINGS. THE STIFEL ENTITIES DO NOT GUARANTEE THE COMPLETE SECURITY OF THE PLATFORM AND THE SERVICES; THAT THE QUALITY OF ANY PRODUCTS, SERVICES, INFORMATION, OR OTHER MATERIAL PURCHASED OR OBTAINED BY YOU THROUGH THE SERVICES WILL MEET YOUR EXPECTATIONS; OR THAT ANY ERRORS IN THE TECHNOLOGY WILL BE CORRECTED. YOU AGREE THAT ANY DOWNLOADS OF CONTENT OR MATERIALS RELATED TO THE PLATFORM, THE SERVICES, OR THE WEBSITE IS DONE AT YOUR OWN RISK AND YOU ARE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER/SYSTEM OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOAD OF OR ACCESS TO ANY SUCH MATERIALS. SOME JURISDICTIONS DO NOT ALLOW THE

EXCLUSION OF CERTAIN WARRANTIES OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES AS DESCRIBED IN SECTION 12; ACCORDINGLY, SOME OF THE ABOVE LIMITATIONS MAY NOT APPLY TO YOU.

NO STIFEL ENTITY SHALL BE RESPONSIBLE FOR INVESTMENT AND OTHER FINANCIAL DECISIONS, DAMAGES, OR OTHER LOSSES RESULTING FROM USE OF THE SERVICES, AND NO STIFEL ENTITY SHALL BE CONSIDERED AN “EXPERT” UNDER THE SECURITIES ACT OF 1933. NO STIFEL CLIENT ACCESS ENTITY WARRANTS THAT ANY OF THE SERVICES PROVIDED UNDER THIS AGREEMENT COMPLIES WITH THE REQUIREMENTS OF THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, THE SECURITIES AND EXCHANGE COMMISSION, OR ANY SIMILAR ORGANIZATION OR REGULATOR OR WITH THE SECURITIES LAWS OF ANY JURISDICTION. USE OF THE SERVICES DOES NOT CREATE AN ADVISER/CLIENT OR OTHER FIDUCIARY RELATIONSHIP WITH YOU.

12. Limitation of Liability

IN NO EVENT SHALL ANY STIFEL ENTITY BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, OR PUNITIVE DAMAGES OF ANY KIND, IN CONNECTION WITH OR ARISING OUT OF THIS AGREEMENT, INCLUDING ANY DAMAGES FOR LOST PROFITS, LOST OPPORTUNITY, LOSS OF DATA, LOSS OF GOODWILL, LOSS OF USE, OR OTHER ECONOMIC ADVANTAGE OR OTHER INTANGIBLE OR SPECULATIVE LOSSES, WHETHER OR NOT THE LOSS IS THE RESULT OF MALFUNCTION OF THE SERVICES AND/OR THE PLATFORM, OR THE COST OF SUBSTITUTE GOODS OR SERVICES; ANY PRODUCTS, DATA, INFORMATION, OR SERVICES PURCHASED OR OBTAINED OR MESSAGES RECEIVED OR TRANSACTIONS ENTERED INTO, THROUGH, OR FROM THE SERVICES; UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA, STATEMENTS, OR CONDUCT OF ANYONE RELATED TO THE SERVICES; THE PERFORMANCE OR NON-PERFORMANCE OF ANY

WEBSITE OF ANY THIRD PARTY THAT PROVIDES YOUR EXTERNAL ACCOUNT DATA, IN EACH CASE WHETHER OR NOT SUCH STIFEL ENTITY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IN NO EVENT SHALL ANY STIFEL ENTITY HAVE ANY LIABILITY OF ANY KIND OR NATURE TO YOU OR ANY THIRD PARTY THAT (I) ARISES FROM OR IS RELATED TO ANY EQUIPMENT, SOFTWARE, FACILITIES, SERVICES, INFORMATION, MATERIALS, OR INFRASTRUCTURE PROVIDED BY YOU OR ANY THIRD PARTY AND NOT FURNISHED BY THE STIFEL ENTITIES OR (II) RESULTS FROM IMPROPER OR NEGLIGENT USE OR OPERATION BY YOU OF THE PLATFORM OR OTHER SERVICES OR WHICH IS IN VIOLATION OF THIS AGREEMENT. WITHOUT LIMITATION OF THE FOREGOING, IN NO EVENT SHALL THE LIABILITY IN CONNECTION WITH THIS AGREEMENT OF ANY STIFEL ENTITY TO YOU OR ANY THIRD PARTY EXCEED TEN U.S. DOLLARS ($10), REGARDLESS OF THE FORM OF ACTION. IT IS FURTHER UNDERSTOOD THAT CERTAIN APPLICABLE LAWS, INCLUDING THE U.S INVESTMENT ADVISERS ACT OF 1940 (THE “ADVISERS ACT”) AND 12 CFR PART 1005 – ELECTRONIC FUND TRANSFERS (“REGULATION E”), MAY IMPOSE LIABILITY OR ALLOW FOR LEGAL REMEDIES EVEN WHERE WE HAVE ACTED IN GOOD FAITH AND THAT THE RIGHTS UNDER THOSE LAWS MAY BE NON-WAIVABLE. SOME JURISDICTIONS DO NOT PERMIT THE LIMITATION OR EXCLUSION OF CERTAIN CATEGORIES OF LIABILITY, SO SOME OF THE ABOVE LIMITATIONS MAY NOT APPLY TO YOU.

13. Terminating Your Access to the Platform

This Agreement and your access to the Platform will continue to apply until terminated by either you or us as set out below, or immediately upon the closure of your Stifel Account(s). If you want to terminate your access to the Platform, you must close your User Profile following the process described below.

Send an e-mail to [email protected] (mailto:[email protected]) from the e-mail address associated with your User Profile, indicating “CANCEL” in

the subject line of the message. After confirming you are the User Profile owner, we will close your User Profile and your Stifel Account Data and External Account Data will no longer be accessible to you on the Platform. We have no obligation to maintain such information or make it available to you after termination.

We reserve the right to terminate your access to the Platform or our legal agreement with you for any reason or no reason, in our sole and absolute discretion, by providing notice of such termination to you. The termination of this Agreement will not affect any of our rights or your obligations arising under this Agreement prior to termination and upon termination of this Agreement: (i) all rights granted to you to your access to the Platform and use of the Services shall immediately cease, and (ii) Sections 7, 8, 10-15, and 17-20 shall survive termination of this Agreement.

14. Arbitration

General. This Agreement contains a predispute arbitration agreement. By signing an arbitration agreement, the parties agree as follows:

a. All parties to this Agreement are giving up the right to sue each other in court, including the right to a trial by jury, except as provided by the rules of the arbitration forum in which a claim is filed.

b. Arbitration awards are generally final and binding; a party’s ability to have a court reverse or modify an arbitration award is very limited.

c. The ability of the parties to obtain documents, witness statements, and other discovery is generally more limited in arbitration than in court proceedings.

d. The arbitrators do not have to explain the reason(s) for their award unless, in an eligible case, a joint request for an explained decision has been submitted by all parties to the panel at least 20 days prior to the first scheduled hearing date.

e. The panel of arbitrators may include a minority of arbitrators who were or are affiliated with the securities industry.

f.  The rules of some arbitration forums may impose time limits for bringing a claim in arbitration. In some cases, a claim that is ineligible for arbitration may be brought in court.

g. The rules of the arbitration forum in which the claim is filed, and any amendments thereto, are incorporated into this Agreement.

Disputes Subject to Arbitration. Stifel and you (for yourself and on behalf of your principals, agents, beneficiaries, successors, heirs, and assigns) agree that all claims, controversies, and disputes between you and Stifel, Stifel’s agents, employees, officers, and directors, any entity affiliated with Stifel that is a FINRA member firm, and/or any clearing agent of Stifel (collectively “Disputes”) shall be resolved by binding arbitration before FINRA Dispute Resolution.

Stifel and you agree that all Disputes shall be arbitrated whether the Disputes arose prior to, on, or subsequent to the date hereof. Stifel and you further agree that Disputes includes, but is not limited to, claims, controversies, and disputes concerning, relating to, or arising from:

    (i) Any account maintained by you at any time with Stifel, any entity affiliated with Stifel that is a FINRA member firm, or any clearing agent of Stifel, whether maintained by you individually and for your own benefit, jointly with any other person or entity, or in any representative capacity, including, but not limited to, as a trustee or guardian;

   (ii) Any account in which you claim a beneficial interest maintained by any person other than you with Stifel, any entity affiliated with Stifel that is a FINRA member firm, or any clearing agent of Stifel;

  (iii) Any transaction involving Stifel or any predecessor or successor firms by merger, acquisition, or other business combination and you, whether you acted individually, jointly with another person, or in a representative capacity and whether or not such transaction occurred in an account referenced in (i) or (ii) above;

  (iv) Any recommendation of any securities transaction or investment strategy involving securities, including a recommendation of a type of account, made by Stifel or any predecessor or successor firms by merger, acquisition, or other business combination to you, whether or not the recommendation resulted in a securities transaction in an account referenced in (i) or (ii) above;

   (v) The construction, performance, or breach of this Agreement or any other agreement between you and Stifel, any entity affiliated with Stifel that is a FINRA member firm, and/or any clearing agent of Stifel; or

  (vi) The business activities of Stifel, an associated person of Stifel, any entity affiliated with Stifel that is a FINRA member firm, and/or any clearing agent of Stifel.

Stifel and you agree that any issue concerning the validity, enforceability, or scope of the arbitration agreement, including the arbitrability of a particular claim, controversy, or dispute, shall be resolved by binding arbitration before FINRA Dispute Resolution.

The Arbitration Forum. Any and all Disputes shall be submitted exclusively to FINRA Dispute Resolution and administered under the then current FINRA Code of Arbitration Procedure for Customer Disputes and other applicable FINRA rules, as amended from time to time (collectively, the “FINRA Code of Arbitration Procedure”).

Arbitration Hearing Locale. The hearing location for any arbitration of any Dispute in accordance with this Agreement shall be determined by the FINRA Director of Dispute Resolution in accordance with the FINRA Code of Arbitration Procedure.

Enforcement of This Arbitration Agreement. This arbitration agreement shall be enforced and interpreted exclusively in accordance with applicable federal laws of the United States, including the Federal Arbitration Act.

If you file any Disputes in court, Stifel may seek to compel arbitration of the Disputes, and you agree not to oppose any efforts to compel arbitration of such Disputes.

Judgment confirming any arbitration award in any arbitration conducted in accordance with this Agreement may be entered in any court having jurisdiction.

This arbitration agreement shall survive the termination of this Agreement.

Class Actions. No person shall bring a putative or certified class action to arbitration. No person shall seek to enforce any predispute arbitration agreement against any person who has initiated in court a putative class action; or who is a member of a putative class who has not opted out of the class with respect to any claims encompassed by the putative class action until: (i) the class certification is denied; or (ii) the class is decertified; or (iii) the customer is excluded from the class by the court.

Such forbearance to enforce an agreement to arbitrate shall not constitute a waiver of any rights under this Agreement except to the extent stated herein.

A copy of this arbitration agreement is hereby given to you, and you acknowledge receipt thereof by signing the Signature Document and/or Agreement Confirmation provided to you.

Waiver of Rights to Trial by Jury. In the unlikely event any controversy or dispute between you and Stifel is determined to be ineligible for arbitration or not required to be arbitrated, you agree as follows: THE PARTIES TO THIS AGREEMENT SHALL NOT EXERCISE ANY RIGHTS THEY MAY HAVE TO ELECT OR DEMAND A TRIAL BY JURY. YOU AND STIFEL HEREBY EXPRESSLY WAIVE ANY RIGHT TO A TRIAL BY JURY. You acknowledge and agree that this provision is a specific and material aspect of the agreement between the parties and that Stifel would not enter into this Agreement with you if this provision were not part of the agreement.

Forum Selection Clause. Without limiting in any respect the arbitration agreement contained in this Agreement and your agreement and obligation to arbitrate all Disputes, any suit, claim, or action filed against Stifel or its present or past parents, subsidiaries, affiliates, officers, agents, or employees in court shall be brought and heard only in the State of Missouri in St. Louis County Circuit Court. Entering into the Agreement constitutes your consent to submit to the personal jurisdiction of the courts of the State of Missouri. You hereby waive any objection based on forum non conveniens and any objection to venue in relation to any such any action.

This paragraph shall apply even if you have related disputes with other parties that cannot be resolved in the same locale

15. Your Consent to Electronic Notices

All notices, requests, approvals, and other communications regarding the Platform, the Services, and other offerings under this Agreement shall be in writing and will be deemed to have been duly given with respect to this Agreement when posted on the Platform; when sent via e-mail to any e-mail address associated with your User Profile; by sending you an in-product message within the Platform or the Services; mailing it to any postal address that you have provided us; and/or by sending it as a text message to any mobile phone number that you have provided us, including to the mobile phone number that you have listed in any Service setup or customer profile. All notices by any of these methods shall be deemed received by you no later than twenty-four (24) hours after they are sent or posted, except for notice by postal mail, which shall be deemed received by you no later than three (3) Business Days after it is mailed. You may request a paper copy of any legally required disclosures, and you may terminate your consent to receive required disclosures through electronic communications by contacting us at [email protected] (mailto:[email protected]). Communications regarding the Platform or the Services may involve the electronic transmission of information to any e-mail address associated with your User Profile, and you agree and consent to such electronic transmission of such information.

16. Amendments to This Agreement

We may revise this Agreement at any time, and therefore, we recommend that you check this Agreement as posted on the Platform from time to time. If we modify this Agreement, we will notify you (in a manner consistent with Section 17 above) and post or provide a link to the amended Agreement on the Platform or otherwise on our website, and such changes will be effective at such time, and that such notice constitutes adequate notice. By

logging into the Platform and/or using the Services, after such amendment, you are agreeing to the Agreement terms as amended.

17. Indemnification

You agree to indemnify, defend, and hold us and any Stifel Entity and all of their respective officers, directors, employees, agents, information providers, and licensors harmless from and against any and all third-party claims, losses, claims, proceedings, demands, damages, liabilities, penalties, interest, and expenses (including, attorneys’ and other professional advisors’ fees and costs) incurred by any of these parties that arise out of or are caused by: (i) your use of the Services and/or the Platform; (ii) your violation of this Agreement; (iii) your negligence or willful misconduct in connection with this Agreement or your access of the Platform or use of the Services; or (iv) your violation of the rights of a third party, including the infringement by you of any intellectual property rights, or violation by any user of your Credentials or User Profile.

In the event that there are third-party claims against you for which you properly seek damages from us under this Agreement, or we are subject to any claim for which we have the right to be indemnified by you, we reserve the right, at our expense in the case of claims by third parties against you and at your expense in the case of claims for which we have the right to be indemnified by you, to assume the exclusive defense and control of any such claim, and you agree that in any event no such claim can be settled without our written consent.

18. Advisory and Brokerage Services

Disclaimers:

You Are Not Receiving Investment Advice and Your Acknowledgement of Investment Risks. By using the Platform and the Services, you understand and acknowledge that the Platform and the Services

are not intended to provide financial advice and that Stifel does not guarantee any investment results. All information displayed by the Platform and the Services, including all financial and market commentary, stock, bond, fund, or other securities research, is for convenience and general information purposes only and not intended to be relied upon as investment advice. All investments entail a risk of loss, and you may lose money. You also understand that all investments are subject to various market, currency, economic, political, business, and other risks. Investments, particularly those in international stocks and stocks of smaller companies, present numerous risks, can be very volatile, and can result in a loss of principal. International investments include risks of currency fluctuation, political and economic instability, and differences in financial reporting in addition to the risks present in domestic investments. Investments in smaller companies may involve greater risks than investments in larger, more mature companies. The value of debt securities frequently is reduced (sometimes dramatically) by increases in interest rates. While the financial insights we provide may assist in helping you understand your finances, you should consult with a professional investment adviser before making investment decisions or deciding on changes to your personal financial strategy. You should not engage in any financial transactions based on the information provided or presented to you by the Platform and the Services.

Neither Stifel, nor any of its Third-Party Providers, guarantees the availability, accuracy, completeness, reliability, or timeliness of any financial or other information provided through the Platform and the Services.

No Offer or Solicitation. You acknowledge and agree that the Platform and the Services do not constitute an offer (or solicitation of an offer) to buy or sell securities, commodities, currencies, financial instruments, or contracts for the exchange of value, services, or risk.

Not a Legal or Tax Advisor. Neither we nor the Platform nor the Services give, offer, or render tax or legal advice. Before making financial or investment decisions, we recommend that you contact an investment adviser, or tax or legal professional.

Stifel and Third-Party Offers. Some parts of the Platform and the Services may, either today or in the future, be supported by advertising or marketing partnership relationships.

Financial Advisory Services by Stifel. The Services are a tool made available for use by you, and are not intended to be, nor shall they be construed as, investment advisory services. This Agreement applies only to your use of the Platform and the Services and does not apply to any trades executed in your account with Stifel, nor does it apply to any investment advice or recommendations provided by any Stifel personnel. Any advisory and brokerage services provided by Stifel are governed by your Stifel Account Agreement and Disclosure Booklet (https://www.stifel.com/disclosures/account-agreement).

19. Additional Terms For Services Provided Through a Web or Mobile

With respect to the Platform and the Services provided through a web or mobile app (an “App”), we grant you during the term of this Agreement a limited, terminable, non-exclusive license to download and install a single copy of the App solely on your own computer or mobile device, for use solely to connect to and use the Services as permitted under this Agreement. This license is not transferable to any third party. On termination of this Agreement for any reason, including in the event you close your User Profile, you will delete any downloaded or installed copies of the App.

You acknowledge that this Agreement is between Stifel and you, and not with the owner or operator of any app store through which the App is distributed (the “App Store Provider”). In addition to the terms of this Agreement, your use of the App, the

Platform, and any Services provided through the App will be subject to the terms of any user agreement associated with the app store or other venue through which you downloaded or obtained the App.

Without limiting Section(s) 13 and 14 above: (a) Stifel is solely responsible for providing any maintenance and support services with respect to the Platform as provided in this Agreement or under applicable law, and the App Store Provider has no obligation whatsoever to furnish any maintenance and support services with respect to the App, Platform, or the associated Services; (b) the App Store Provider is not responsible for any product warranties for the App, the Platform, or the Services (to the maximum extent permitted by applicable law, the App Store Provider will have no other warranty obligation whatsoever with respect to the App or the Services, and any other claims, losses, liabilities, damages, costs, or expenses attributable to any failure to conform to any warranty will be Stifel’s sole responsibility); and

(c) Stifel, and not the App Store Provider, is responsible for addressing any claims by you or any third party relating to the App and the Services.

Stifel and you acknowledge and agree that the App Store Provider is a third-party beneficiary of the provision of this Section 21 and other provisions of this Agreement applicable to the App Store Provider hereunder, and upon your acceptance of the terms and conditions of this Agreement, the App Store Provider will have the right (and will be deemed to have accepted the right) to enforce such provisions of this Agreement against you as a third-party beneficiary thereof.

20. Miscellaneous

This Agreement, the Platform, and any Services provided hereunder will be governed exclusively by the laws applicable in the State of Missouri, excluding its provisions on conflicts or

choice of law, provided that nothing herein shall be construed in a manner inconsistent with the Advisers Act.

Neither any Stifel Entity nor Subscriber shall be responsible for, nor be in default under this Agreement due to any delays or failure of performance (except payment obligations) resulting from acts or causes beyond its reasonable control, including acts of God, acts of war, acts of terror, civil unrest, strikes or other labor problems, power failures, floods, earthquakes, other natural disasters, denial-of-service attacks, or other similar events, including any such event that impacts Subscriber or any Stifel Entity (each, a “Force Majeure Event”).

We do not waive our rights by delaying or failing to exercise them at any time. If any provision of this Agreement shall be determined to be invalid or unenforceable under any rule, law, or regulation of any governmental agency, local, state, or federal, the validity or enforceability of any other provision of this Agreement shall not be affected.

Section headings in this Agreement are for convenience of reference only, and shall not govern the interpretation of any provision of this Agreement. The use of the term “including” means “including, without limitation” throughout this Agreement.

In the event that any of the terms of this Agreement are determined invalid, unlawful, or unenforceable to any extent, such term shall be construed to the maximum extent enforceable in accordance with the intent of the parties, and the remaining terms shall continue to be valid to the fullest extent permitted by law.

This Agreement, including, the licenses granted by us, is personal to you, and is not assignable, transferable, or sub-licensable in whole or part by you except with our prior written consent.

The Agreement, including the separate Privacy Statement (https://www.stifel.com/privacy), and any other documents referred to herein, represents the entire understanding between both you and us regarding the Platform and the Services (as defined herein) and the subject matter hereof and supersedes any prior statements or representations. In the event of a conflict between the terms of this Agreement and the terms of an annex, exhibit, amendment, schedule, addendum, or disclosure, the terms of the annex, exhibit, amendment, schedule, addendum, or disclosure shall prevail, but solely as to the subject matter herein. In the event of a conflict between the terms of this Agreement with any other agreements related to any Stifel Account Data, or other agreements include terms that are not addressed in this Agreement, then the other agreements will control and take precedence, unless this Agreement specifically states otherwise. The other agreements will only control to the extent necessary to resolve the conflict or inconsistency. For the avoidance of doubt, additional provisions of other agreements regarding the Stifel Account Data that do not appear in this Agreement will continue to apply.