Risk Disclosure Statement

Statement Version 1.0, published and effective 11 September 2026.

1. Introduction

Battrust Investment Bank ("Bank", "we", "us", or "our") is licensed by the Labuan Financial Services Authority ("Labuan FSA") to carry on, among other things, custodian and investment banking business in and from Labuan. Before you engage us to provide custodian services and/or investment services, you should read this Risk Disclosure Statement carefully so that you understand, in general terms, the nature and risks of the services and products we offer. This statement cannot and does not disclose every risk associated with custody and investment activities. It is intended to give you a general overview only, and you should not rely on it as a substitute for independent professional, financial, legal or tax advice suited to your own circumstances.

You should not use our custodian or investment services unless you understand their nature, and the extent of your exposure to risk. You should independently assess, with your own professional advisers where necessary, whether a product or service is appropriate for you having regard to your investment objectives, financial situation, risk tolerance and particular needs. Nothing in this statement should be construed as investment advice or a recommendation to enter into any transaction.

This statement forms part of, and should be read together with, the account opening documentation, client agreement(s) and any other terms and conditions issued by the Bank from time to time. In the event of any inconsistency, the terms of the applicable client agreement shall prevail.

2. General investment risk

The value of any investment, and the income derived from it, can fall as well as rise, and you may not get back the amount you originally invested. Where an investment is denominated in a currency other than your base or reporting currency, movements in exchange rates may have an additional favourable or unfavourable effect on its value.

There is no guarantee that any investment strategy or trading approach will achieve positive returns.
Where no active or recognised market exists for an investment, it may be difficult to realise the investment or to obtain reliable pricing information, which can make it harder to assess the true value of, or risk associated with, that holding.
Markets can be highly volatile and subject to sudden and significant price movements arising from a wide range of factors, some of which may be outside our control or that of any issuer.
Early withdrawal, redemption or termination of an investment may result in you receiving less than the amount originally invested, and cross-border investments carry additional risk of capital loss arising from currency fluctuations, differing accounting standards, or political and economic instability in the relevant jurisdiction.
Concentrated positions and investments in smaller or less-established companies generally exhibit greater price volatility than diversified holdings in larger, more established issuers.
Past performance of any investment, portfolio, manager or strategy is not a reliable indicator of future results, and your decision to invest should never be based solely, or predominantly, on historical performance.

3. Custody and safekeeping risk

When you appoint us to act as custodian, your assets are held in safekeeping either directly by us or through sub-custodians, depositories, clearing systems or nominees. Although we exercise due care in the selection and ongoing monitoring of any such third party, the following risks remain relevant:

Assets held in custody may, depending on local market practice and law, be registered in the name of a nominee or held in an omnibus account together with assets of other clients, rather than segregated in your own name. This may affect the ease, speed and manner in which your entitlement to those assets can be identified and recovered, particularly in an insolvency scenario.
Different jurisdictions apply different legal regimes to the segregation and protection of client assets. In some markets, client assets may not be as well protected from the insolvency of a custodian, sub-custodian or depository as they would be in Malaysia or Labuan.
The insolvency, default or operational failure of a sub-custodian, depository, central securities depository or settlement system may delay the return of your assets or, in certain circumstances, result in a shortfall that is shared proportionately among affected clients.
Corporate actions (such as rights issues, takeovers or class actions) affecting custodied assets are processed based on information available to us or our sub-custodians, and there is a risk that instructions may not be actioned in time, or that entitlements may be lost, if information is not received or processed promptly.

4. Sub-custodian and nominee risk

We may appoint sub-custodians, agents or nominees, including in overseas jurisdictions, to hold assets on your behalf where this is necessary or customary for the relevant market. While we apply due diligence in appointing and periodically reviewing such parties, we do not guarantee their solvency, performance or conduct. You accept that assets held through a sub-custodian are subject to the laws, market practices, and insolvency regime of the jurisdiction in which that sub-custodian operates, which may differ materially from those applicable in Labuan or Malaysia and may offer a lower level of investor protection.

5. Counterparty and issuer risk

Any transaction we undertake on your behalf, or any instrument we hold for you, exposes you to the risk that the issuer of a security, or a counterparty to a transaction (including brokers, banks, clearing houses and exchanges), may fail to perform its obligations, whether due to insolvency, default or other cause. Where this occurs, the relevant investment may become impaired or worthless, and any related trading costs or unrealised gains may become irrecoverable.

6. Market and liquidity risk

The price of securities and other instruments fluctuates continuously and may fall as well as rise, at times sharply and without warning. Under certain market conditions, it may become difficult or impossible to buy or sell a position at a fair price, or at all. For example, where trading in a security is suspended, where a market experiences a "limit move", or where there is simply no willing buyer or seller. Certain investments may need to be held to maturity, or may lack a readily available secondary market altogether, which can affect both pricing and your ability to exit a position when you wish to do so.

7. Currency and foreign exchange risk

Where assets under custody or investment are denominated in a currency other than your reference currency, changes in exchange rates may reduce (or enhance) their value when converted back into your reference currency, independently of the underlying performance of the investment itself. Where leveraged foreign exchange transactions are involved, a relatively small movement in exchange rates can have a disproportionately large effect on the funds you have deposited or committed, and losses may exceed the amount originally placed.

8. Country and emerging market risk

Investments made in, or issued out of, a foreign jurisdiction, including markets linked to your home market, are subject to the laws, regulatory framework, and political and economic conditions of that jurisdiction. Recovery of invested capital or realised gains may be delayed, reduced or prevented by exchange controls, expropriation, debt moratoria, taxation changes or other government or regulatory action. Emerging markets in particular may present heightened sovereign, liquidity, settlement and custody risk, less developed regulatory oversight, and less reliable information on which to assess an investment, compared to more developed markets.

9. Legal, regulatory and enforcement risk

Changes in law or regulation, in Labuan, Malaysia or any other relevant jurisdiction, may affect the value, liquidity, tax treatment or legal enforceability of your investments, or our ability to continue providing a particular service or product. Where an issuer or counterparty defaults, pursuing legal recourse across borders can be costly, slow, and uncertain in outcome, particularly where local enforcement mechanisms are weak or where assets are located in a jurisdiction with limited legal protection for foreign investors.

10. Alternative investments, derivatives and structured products

Where your portfolio includes alternative investments (such as private equity, hedge funds or other non-traditional asset classes) or derivative instruments (such as options, futures, warrants or structured products), you should be aware that these products are generally more complex, less liquid, and carry a materially different risk profile from listed equities or bonds:

Alternative investments are typically intended for experienced and financially high net worth investors able to bear a total or substantial loss of capital. They often feature limited or no secondary market, restrictions on transfer or redemption, delayed or limited valuation information, higher fees than conventional funds, and less regulatory oversight.
Derivatives can be used for hedging or efficient portfolio management but carry their own risks. The value of an option or warrant depends on the terms attached to it and on the volatility of the underlying asset, and it may expire worthless, resulting in the loss of the entire premium paid plus transaction costs.
Selling or "writing" an option or derivative generally carries a materially higher risk than purchasing one. Depending on whether the position is "covered" or "uncovered", potential losses may substantially exceed the premium received and, in the case of uncovered positions, may in theory be unlimited.
Stop-loss or stop-limit orders, which are designed to limit losses, may not always be capable of being executed at the intended price, particularly in fast-moving or illiquid markets, and do not guarantee protection against loss.

11. Operational, technology and electronic trading risk

Custody and investment services rely on operational processes and computer-based systems for order routing, execution, settlement, registration, reporting and safekeeping of records. As with any system, these are subject to the risk of temporary disruption, error or failure, whether affecting the Bank, an exchange, clearing house, sub-custodian or other service provider. Where a system failure occurs, an instruction may not be executed at all, may be executed incorrectly, or may be delayed, and your ability to access or transact in respect of your assets may be temporarily affected. We maintain business continuity and operational risk controls designed to mitigate these risks but cannot guarantee that disruption will never occur.

12. Cybersecurity and data risk

The Bank maintains information security controls designed to protect client data and assets from unauthorised access, use or disclosure. Nonetheless, no system connected to electronic networks can be guaranteed entirely free from the risk of cyberattack, unauthorised intrusion, malware or data breach. Such incidents, whether affecting the Bank or a third-party service provider, could result in unauthorised access to, or loss, corruption or disclosure of, your information or assets, and in service disruption.

13. Conflicts of interest

In the course of providing custodian and investment services, the Bank, its officers, employees or related entities may have interests, relationships or arrangements that could potentially conflict with your interests. For example, where we or a related entity act as counterparty, receive commissions, fees or other benefits from a third party, or provide services to more than one client with competing interests. We maintain policies designed to identify, manage and, where required, disclose such conflicts in accordance with applicable Labuan FSA requirements, and to ensure fair treatment of clients.

14. Taxation

Income or gains arising from your investments may be subject to withholding tax, capital gains tax or other taxes imposed by the jurisdiction of the issuer, the jurisdiction in which a transaction is effected, or your own jurisdiction of tax residence. Unless expressly stated otherwise, any amount payable to you will be net of any such taxes that we or a sub-custodian are required to withhold or deduct. You are responsible for determining and complying with your own tax obligations, and we recommend you seek independent tax advice.

15. No investment advice; your own assessment

Unless we have separately and expressly agreed in writing to provide you with investment advice or a discretionary/non-discretionary portfolio management service with a defined mandate, our custodian and investment services do not constitute a recommendation or personal advice as to the merits of any particular investment, and we do not assess the suitability of any transaction for you. You remain solely responsible for your investment decisions, and should ensure you understand the features, risks and costs of any product before transacting.

This Risk Disclosure Statement is not exhaustive and does not disclose all of the risks and other significant aspects of investing in, or holding, securities and other instruments through custodian and investment services. You should not deal in, or make use of, our custodian or investment services unless you understand their nature and the extent of your exposure to risk, and you are satisfied that the product or service is suitable for you in light of your circumstances, objectives, and financial resources. We recommend that you seek independent legal, financial and tax advice before entering into any agreement with us.

Contact us

Battrust Investment Bank Limited
1-23(A), First Floor, Paragon, Jalan Tun Mustapha, 87008 Labuan F.T., Malaysia
Telephone: 087-413161
Email: compliance@battrustinvestment.com