Statutory Legal & Regulatory Disclosures

01 Corporate Identity & Legal Perimeter

AETHELIS LTD (trading interchangeably as Neurallity Quant Systems) is a private limited liability technology company duly incorporated and operating under the laws of England and Wales:

• Company Registration Number: 16245256
• Jurisdiction of Incorporation: England and Wales, United Kingdom
• Registered Corporate Address: 165-167 Great Portland Street, London, W1W 5PF, United Kingdom
• Primary Corporate Domain: https://aethelisquant.com
• Standard Industrial Classification (SIC): 62012 (Business and domestic software development); 62020 (Information technology consultancy activities); 62090 (Other computer related services).

Explicit Negative Declarations

To eliminate any ambiguity regarding its commercial, corporate, and regulatory nature, Aethelis Ltd hereby explicitly, irrevocably, and affirmatively declares that:

1. Aethelis Ltd is NOT a Broker-Dealer, introducing broker, or executing broker under the UK Financial Services and Markets Act 2000 (FSMA), US Securities Exchange Act of 1934, or EU MiFID II Directive 2014/65/EU.
2. Aethelis Ltd is NOT an Asset Management Company, fund manager (AIFM / UCITS Management Company), discretionary portfolio manager, or registered investment adviser (RIA).
3. Aethelis Ltd is NOT a Credit Institution, bank, trust company, or payment services provider.
4. Aethelis Ltd is NOT a Crypto-Asset Service Provider (CASP) or Custodian Wallet Provider under EU Regulation 2023/1114 (MiCA) or UK Money Laundering Regulations.
5. Aethelis Ltd is NOT subject to prudential supervision by the UK Financial Conduct Authority (FCA), the European Securities and Markets Authority (ESMA), or the US Commodity Futures Trading Commission (CFTC) as an authorized investment business, as its activities fall completely outside the perimeter of reserved regulated financial activities.

02 Strict Non-Custodial Architecture & Capital Segregation

The structural cornerstone of the Aethelis Quant platform (Release v6.2.0 QUANT) is the Absolute Zero-Custody Mandate. At no stage throughout the operational lifecycle of the software does Aethelis Ltd receive, hold, handle, touch, transfer, or maintain custody of any fiat currency, digital asset, derivative contract, or financial collateral belonging to any client.

Hardware & Firmware Withdrawal Prohibition

Connection between Aethelis Quant execution daemons and client trading accounts occurs exclusively via encrypted REST v5, WebSocket, and TCP Socket APIs. All API keys and FIX sessions are subject to strict technical constraints:

• Read & Trade Privileges Only: Credentials permit reading market telemetry and dispatching order placements/cancellations.
• Permanent Withdrawal Invalidation: API keys must be created with withdrawal permissions permanently disabled on the venue console.
• Pre-Flight Daemon Halts: Every execution engine runs an automated cryptographic check during startup. If any credential exhibits withdrawal or internal transfer capabilities, the engine executes a fatal halt immediately, dropping all trading loops.
• Static IP Enclave: API credentials are locked to the static IPv4 address of the client's dedicated Frankfurt OCI execution server, rendering credentials inert if intercepted outside the host perimeter.

03 No Collective Investment, Capital Pooling or Performance Guarantees

Aethelis Ltd strictly prohibits the pooling or commingling of capital across client deployments. Each institutional deployment runs inside an isolated, containerized tenant sandbox with separate configuration stores, separate execution daemons, and dedicated local database schemas.

Mathematical Nature of Algorithmic Output

All algorithmic models embedded within Aethelis Quant—including but not limited to Recursive Kalman Filters (Desk 4), NYMEX 3:2:1 Refinery Margins (Desk 5), FX Volatility Regime Locks (Desk 6), Bollinger/Keltner Compression Squeezes (Desk 1), Causal Momentum Guards (Desk 2), Auction Market Theory Value Area Profiles (Desk 3), and Delta-Neutral Cash-and-Carry equations (Desk 7)—represent pure mathematical and statistical computations.

Such mathematical outputs do not constitute:

• A solicitation, offer, or recommendation to buy or sell any security, derivative, commodity, or crypto asset.
• Personalized investment advice, financial advice, or portfolio management.
• A guarantee of capital preservation or positive return on investment.

Institutional clients retain sole, unshared fiduciary, legal, and operational responsibility for reviewing algorithmic configurations, establishing circuit breaker thresholds, and directing execution parameters on their accounts.

04 Institutional & Eligible Counterparty Restriction (B2B Only)

The technology, software solutions, and analytical suites developed by Aethelis Ltd are designed, marketed, and licensed exclusively for institutional, professional, and corporate business-to-business (B2B) market participants.

Retail Exclusion: Individuals classified as retail clients under UK or European regulations are strictly ineligible to license, deploy, or access Aethelis software. Applications for sandbox evaluation or software licensing from retail consumers will be rejected unconditionally.

05 Intellectual Property & Proprietary Algorithmic Kernels

All intellectual property rights associated with Aethelis Quant v6.2.0—including source code, compiled binaries, state-space Kalman equations, Causal State Guard state machines, database schemas, API interfaces, trade secret configurations, and technical manuals—are and remain the exclusive, proprietary intellectual property of Aethelis Ltd.

• No Source Code Transfer: Software licensing confers a revocable, non-exclusive, non-transferable operational license for internal treasury or proprietary execution purposes only.
• Prohibition of Reverse Engineering: Decompilation, disassembly, reverse engineering, unauthorized sniffing, or replication of closed-source alpha kernels is strictly prohibited and subject to civil litigation and criminal prosecution under the UK Computer Misuse Act 1990 and international copyright treaties.
• Confidentiality of Documentation: Technical manuals, operating runbooks, and Q-LAB audit reports contain confidential proprietary information and may not be redistributed without prior written consent.

06 International Regulatory Cross-Perimeter Summary

The regulatory perimeter of Aethelis Ltd across key international supervisory authorities is summarized as follows: