PoM Wealth Management is a wealth tech platform for digital wealth consolidation and management, operated by PoM Wealth Management LTDA (CNPJ 46.019.534/0001-60), with registered office at Avenida Angélica, 2529, 4th floor, Bela Vista, São Paulo/SP, ZIP 01227-200 (“PoM”).

PoM is not limited to the traditional multi family office (MFO) model. It operates as technological infrastructure that integrates a unified wealth view, reports, wealth planning, and orchestrated access to services of the business group and strategic partners, in a model of modern, digital, and multichannel MFO.

1.2. PoM ecosystem — platform, MFO, group, and partners

The PoM ecosystem combines:

| Layer | Description |

|-------|-------------|

| Wealth tech platform (PoM Wealth Management) | Wealth consolidation, visualization, reports, single interface, and the Client's digital journeys |

| Multi family office (MGN Investimentos) | Contracted asset management, advisory, and wealth planning |

| Group entities | Insurance (MGN Corretora), foreign exchange (MGN Correspondente Bancário), and other regulated business lines |

| Strategic partners | Custodians, financial institutions, insurers, operators, travel providers, and specialists that actually provide products or services accessed via the Platform |

The purpose of the ecosystem is to offer the Client an integrated trusted advisor experience — a point of trust for understanding their wealth and accessing, in a coordinated manner, the business lines relevant to their financial, wealth, succession, protection (insurance), mobility (travel), and related needs, without replacing the specialized Providers or the regulatory authorizations of each one.

The group entities below may act according to the service contracted, always within the limits of their regulatory authorizations:

| Entity | CNPJ | Typical role |

|--------|------|--------------|

| MGN Investimentos LTDA | 44.859.863/0001-94 | Asset manager / multi family office (MFO) |

| MGN Administradora e Corretora de Seguros de Vida Ltda. | 31.588.179/0001-73 | Insurance broker |

| MGN Serviços de Correspondente Bancário LTDA | 42.736.048/0001-02 | Banking correspondent |

Strategic partners — custodians, banks, insurers, operators, travel agencies, foreign exchange institutions, asset managers, and specialists — provide products or services accessed via the Platform according to the Client's integrations and contracts.

1.3. Supplementary documents

These Terms are integrated with and must be read together with:

Privacy Policy — processing of personal data (LGPD, GDPR, U.S. laws)
Regulatory Notice — informational nature, data sources, and sector-specific notices
Cookie Policy — cookies and similar technologies
Security Notice — security measures and User responsibilities
Artificial Intelligence Use Notice — generative AI and automated decisions
Specific contracts — when applicable (management, advisory, brokerage, foreign exchange, travel, insurance)
MGN Investimentos policies — https://mgnpartners.com.br/

In the event of a conflict between these Terms and an individually signed contract for a specific service, the specific contract prevails with respect to matters peculiar to it.

1.4. Regulatory notices — MGN Investimentos LTDA

MGN Investimentos LTDA. (“MGN”) is a company duly authorized by the Brazilian Securities and Exchange Commission (Comissão de Valores Mobiliários) to carry out the activity of portfolio management of securities, in the category of “asset manager” and as an institution adhering to the self-regulatory codes of ANBIMA. MGN does not market or distribute shares of investment funds or any other financial asset. The distribution of investment funds is carried out through authorized partners that are part of the securities distribution system.

MGN is not responsible for errors, omissions, or inaccuracies in the content of the information disclosed, nor for investment decisions made based on this Platform. The information contained on this Platform is exclusively informational in nature and does not constitute any type of investment advice, notably securities analysis and advisory services.

Under the self-regulation of the Brazilian Association of Financial and Capital Markets Entities — ANBIMA, for the evaluation of investment fund performance, an analysis of at least 12 (twelve) months is recommended.

Resources invested in investment funds are not guaranteed by the administrator, manager, custodian, any insurance mechanism, or the Credit Guarantee Fund — FGC. Past performance does not represent a guarantee of future results. The performance presented for investment funds is not net of taxes.

Investment funds under MGN's management, through their investment strategies, may be subject to various risks inherent to the business, such as concentration of assets from the same issuer and high exposure to derivatives, investments outside the country, and events that result in non-payment of the assets comprising their portfolio, including by reason of intervention, liquidation, temporary administration regime, bankruptcy, judicial or extrajudicial recovery of the issuers responsible for the fund's assets. These strategies may result in significant patrimonial losses, and may even lead to losses exceeding the capital invested and the consequent obligation of the shareholder to contribute additional resources to cover the fund's losses, subject to applicable regulation.

Investors are recommended, before investing, to conduct a detailed analysis of the investment funds' regulatory documents, notably the section relating to risk factors.

MGN Investimentos LTDA acts as a foreign exchange correspondent of EBURY BANCO DE CÂMBIO S.A., in accordance with Central Bank of Brazil (BACEN) Resolution CMN No. 4.935, of July 29, 2021, Article 14.

MGN's corporate and regulatory policies — including Code of Ethics, Reference Form, Internal Controls Manual, Risk Management, Liquidity, AML/CFT Policies, and related documents — are available at https://mgnpartners.com.br/.

2. Definitions

Platform: the PoM Wealth Management system, a wealth tech platform for wealth consolidation, including web interfaces, authorized APIs, reports, PDFs, dashboards, and other digital channels operated by PoM.
Wealth tech: use of technology to consolidate, visualize, analyze, and monitor wealth and investments from multiple sources, integrating data from custodians, partners, and Client declarations in a unified view.
PoM ecosystem: integrated set comprising the wealth tech Platform, business group entities (including MFO), Strategic partners, and Providers that participate in the Client's journey.
Strategic partner: institution or company with a structured commercial or technological relationship with PoM or group entities to make products, services, data, or integrations available to the Client via the Platform or related channels.
Trusted advisor (PoM model): integrated experience in which the PoM ecosystem seeks to be the Client's point of trust for consolidated wealth view and coordinated access to specialized services; it does not imply, unless under a specific contract, that PoM or the Platform personally provide all advisory services or guarantee results across all business lines.
User: natural person authorized to access the Platform by invitation or valid credential.
Client: holder, beneficiary, representative, or entity whose wealth data is consolidated or processed on the Platform.
Authorized administrator: user with permission to invite, revoke access, or manage settings of the contracting organization.
Custodian: financial institution or partner that holds, records, or provides data on positions, transactions, and performance.
Consolidated data: aggregated information from custodians, brokerages, asset managers, insurers, and other authorized sources.
Invitation: secure, temporary, and non-transferable link sent by an authorized administrator for first access.
Foreign exchange operation: request, confirmation, or monitoring of currency conversion (including USD, EUR, GBP, CHF, BRL, and others), intermediated by MGN Serviços de Correspondente Bancário LTDA with EBURY BANCO DE CÂMBIO S.A., the authorized financial institution responsible for the foreign exchange operation.
Wealth planning: wealth, succession, tax, goals, cash flow, insurance, pension, and related planning, including IPS (Investment Policy Statement), diagnostics, and advisory reports.
Travel services: inquiry, quotation, booking, or request for airline tickets, accommodation, car rental, travel insurance, transfers, and tourism or mobility services.
Insurance products: life insurance, national or international health insurance, health plans, and related products.
Partner or Provider: financial institution, custodian, insurer, health plan operator, travel agency, foreign exchange institution, asset manager, MFO, consultant, or third party that actually provides the service or issues the product contracted by the Client, even if access begins on the Platform.
Material information: data or event that, if omitted or misrepresented, may significantly alter plans, proposals, coverages, operations, or decisions regulated under these Terms.

3. Purpose, scope, and nature of the Platform

3.1. Purpose — wealth tech platform for wealth consolidation

The Platform is intended to:

consolidate wealth and investments from multiple sources (onshore, offshore, various custodians);
monitor evolution, performance, allocation, and exposure in a unified view;
visualize and report positions, transactions, and indicators for Clients, managers, bankers, and qualified investors;
orchestrate access — when available — to wealth planning, foreign exchange, travel, insurance, and other business lines of the PoM ecosystem;
centralize the Client's digital journey in a modern MFO supported by technology, the business group, and strategic partners.

This model distinguishes PoM from purely traditional MFOs (without a consolidation platform) and purely informational aggregators (without a regulated services ecosystem): PoM combines wealth tech + MFO + partners in an integrated trusted advisor proposition.

3.2. Nature as a wealth tech platform

Unless expressly provided in a specific contract, PoM predominantly acts as a technological platform for wealth consolidation, interface, Client experience, and orchestration of access to services provided by Strategic partners, Providers, and group entities (including MGN Investimentos as MFO), within the limits of the regulatory authorizations of each entity.

The Platform facilitates the Client's relationship with the ecosystem; it does not automatically unify the regulatory or contractual responsibility of each Provider.

3.3. What the Platform is not

PoM does not replace custodians, insurers, operators, travel agencies, foreign exchange institutions, asset managers, or qualified professionals in the provision of underlying services. Contracts, policies, tickets, vouchers, plan regulations, general conditions, and receipts of the Partner or Provider prevail over summaries or screens on the Platform.

Unless under a specific advisory, management, or advisory contract, the Platform does not constitute, by itself, a regulated trusted advisor across all business lines — although it seeks to be a hub of trust for consolidation and integrated access.

3.4. Order execution and transactions

The Platform does not constitute, by itself, a channel for execution of orders, transfers, or financial transactions of custodied investments, except when expressly indicated for a specific contracted and enabled functionality.

3.5. Ecosystem modules

Wealth planning, foreign exchange, travel, and insurance are modules of the PoM ecosystem, accessible via the Platform according to Client enablement. The availability of modules does not alter the informational nature of wealth consolidation and visualization areas, except as to the specific rules of each module (Sections 17 through 20).

3.6. Ecosystem evolution

PoM may include new integrations, partners, and functionalities compatible with the wealth tech model, by updating these Terms and supplementary documents, with new acceptance when material.

4. Eligibility, invitation, and credentials

4.1. Access is exclusively by invitation or credential issued by an authorized administrator of the contracting organization, except for expressly provided corporate flows.

4.2. The User declares being 18 (eighteen) years of age or older and having full civil capacity to accept these Terms, or being a legally authorized representative.

4.3. Credentials (login and password) are personal and non-transferable. The User is responsible for keeping them confidential, for devices used, and for all activities performed with their account, except upon proof of a security failure attributable exclusively to PoM.

4.4. PoM may require password policies, session revocation, or preventive blocking in the face of security risk or suspected misuse. Multi-factor authentication (MFA) is not available on the Platform in this version.

4.5. The User must promptly update registration and contact data relevant to legal, operational, and security communications.

5. Source, nature, and limitations of financial data

5.1. Data displayed are, as a rule, provided by custodians and partners (including, according to contracting, BTG, XP, Avenue, and others).

5.2. PoM is not the custodian of assets and does not guarantee accuracy, completeness, absolute timeliness, or absence of discrepancies in information received from third parties.

5.3. Delays, omissions, duplications, methodology discrepancies, classification, or reference dates may occur between the Platform, official statements, and custodian systems. Primary responsibility for source data lies with the providing institutions.

5.4. Onshore, offshore, and consolidated positions may be presented with distinct criteria for consolidation, exchange rates, and mark-to-market.

5.5. The User must verify critical information directly with custodians, asset managers, or Partners before making investment, tax, succession, or contractual decisions.

6. Evolution, availability, and problem reporting

6.1. The Platform is in continuous evolution, with updates, improvements, corrections, and, eventually, discontinuation of functionalities.

6.2. Unavailability, scheduled maintenance, bugs, display errors, or calculation discrepancies may occur. There is no guarantee of uninterrupted, fault-free operation, or suitability for the User's specific purpose.

6.3. Upon identifying inconsistencies, errors, unavailability, or suspected incident, the User must notify hello@pomwm.com, with description, screenshots, dates, affected accounts, and perceived impact.

6.4. PoM will use commercially reasonable efforts to investigate and correct reported problems, without obligation of a fixed deadline except as agreed in a specific contract or required by law.

7. Acceptable use, integrity, and anti-fraud

The User is prohibited, directly or indirectly, from:

sharing credentials or allowing access by unauthorized third parties;
using the Platform for unlawful, fraudulent, or unauthorized purposes;
providing false, incomplete, outdated, or misleading information, especially in wealth planning, insurance, travel, foreign exchange, or regulated proposals;
using the Platform in bad faith, simulation, concealment of wealth, income, liabilities, claims, or relevant data;
circumventing access controls, performing reverse engineering, unauthorized automated scraping, or attempts to compromise security;
reproducing, distributing, sublicensing, or commercially exploiting Platform content without authorization;
inserting malware, performing denial-of-service attacks, or overloading systems;
using the identity, documents, or powers of representation of third parties without valid authorization.

PoM may suspend, restrict, or terminate access, preserve records, and notify authorities in the event of violation of this Section or suspected unlawful conduct, including money laundering, fraud, or financial crimes, in accordance with internal policies and applicable law.

8. Confidentiality

8.1. Wealth, contractual, health (when applicable), strategy, and communication information accessed on the Platform is confidential, subject to a duty of confidentiality compatible with the nature of the service and applicable legislation.

8.2. The User undertakes not to disclose to unauthorized third parties data or reports obtained on the Platform, except with the holder's consent, legal obligation, or contractual provision.

8.3. PoM adopts measures to protect confidentiality in accordance with the Privacy Policy and Security Notice, without guaranteeing absolute inviolability.

9. Conflicts of interest, suitability, and trusted advisor

9.1. The PoM ecosystem — Platform, MFO (MGN Investimentos), other group entities, and Strategic partners — may operate across multiple business lines (consolidation, management, distribution, brokerage, foreign exchange, insurance, travel), with potential for conflict of interest, regulated by internal policies and applicable rules for each entity.

9.2. The integrated trusted advisor model aims to align the Client's interests with a holistic wealth view and coordinated access to services; it does not eliminate the need for specific contracts, disclosure, and suitability when required by regulation or product.

9.3. Unless under a specific advisory, consulting, or management contract, generic Platform content does not constitute personalized investment recommendation nor replace analysis of profile, objectives, horizon, and risk tolerance (suitability).

9.4. The Client is responsible for informing relevant changes to profile, wealth, objectives, tax residence, or restrictions that impact the adequacy of products, plans, or operations in the ecosystem.

9.5. Rebates, retrocessions, or remuneration from Strategic partners, when they exist, will be handled in accordance with contracts, regulation, and applicable transparency policies.

10. Privacy, cookies, and security

10.1. Processing of personal data is governed by the Privacy Policy, in compliance with the LGPD (Law 13.709/2018), GDPR when applicable to data subjects in the European Union/United Kingdom, and relevant U.S. privacy laws in the specific case.

10.2. Cookies and similar technologies are governed by the Cookie Policy. Cookies strictly necessary for authentication and security may be used in accordance with applicable legal basis.

10.3. User-facing security measures are set out in the Security Notice. Use of AI is set out in the Artificial Intelligence Use Notice.

11. Intellectual property and license to use

11.1. Software, interfaces, reports, trademarks, logos, compiled databases, and other Platform content are owned by PoM and/or licensors, protected by applicable legislation.

11.2. These Terms grant the User a limited, revocable, non-exclusive, and non-transferable license of access and use according to the contracted purpose, with commercial exploitation or reverse engineering prohibited.

11.3. Feedback or suggestions sent by the User may be used by PoM without obligation of compensation, unless otherwise agreed in writing.

12. Disclaimers, limitation of liability, and indemnification

12.1. Information presented is indicative and informational in nature, not constituting investment recommendation, public offering, solicitation, or personalized advisory, except under a specific contract.

12.2. Past performance, benchmarks, simulations, and projections do not guarantee future results.

12.3. To the maximum extent permitted by law, PoM and group entities shall not be liable for indirect damages, lost profits, loss of opportunity, or decisions made based exclusively on Platform information, without prejudice to non-excludable legal liabilities.

12.4. Partner services and misuse. With respect to wealth planning, foreign exchange, travel, insurance, and other functionalities provided by Partners or Providers, PoM does not guarantee availability, price, coverage, approval, issuance, booking confirmation, or plan outcome. To the extent permitted by law, PoM and group entities shall not be liable for acts, omissions, failures, delays, cancellations, coverage denials, or breaches attributable to Partners, Providers, or the Client, including misuse, bad faith, or false or incomplete information.

12.5. Indemnification. The Client undertakes to indemnify and hold harmless PoM and group entities from claims, fines, costs, losses, proceedings, or third-party liabilities arising from violation of these Terms, fraudulent or willful use, incorrect information provided by the Client, or breach of obligations owed to Partners or Providers.

12.6. Nothing in these Terms excludes non-waivable consumer rights or specific legal liabilities of a group entity in the exercise of regulatory authorization (e.g., insurance brokerage, banking correspondent), within the limits of applicable law.

13. Consumer relationship and communications

13.1. When the Brazilian Consumer Defense Code (Law 8.078/1990) applies, non-waivable consumer rights prevail over conflicting provisions of these Terms to the extent required by law.

13.2. Operational, security, material terms changes, and regulatory notices may be sent by registered email, in-app notification, or other means indicated on the Platform.

13.3. The User is responsible for maintaining a valid email address and reviewing communications sent by PoM.

14. Amendments to the Terms and record of acceptances

14.1. These Terms may be updated by publication of a new version on the Platform, with indication of version and effective date.

14.2. Material changes will require new acceptance before continued use, except when the law permits notification with an objection period.

14.3. The history of acceptances (document, version, date/time, User identifier, and technical metadata) is maintained for audit, compliance, and defense of rights.

15. Term, suspension, and termination

15.1. These Terms remain in effect from acceptance by the User until access termination or replacement by a new accepted version.

15.2. Access may be suspended or revoked by the administrator or by PoM in the event of violation of these Terms, prolonged inactivity, contractual termination, security risk, or legal requirement.

15.3. Confidentiality, limitation of liability (to the extent permitted), indemnification, intellectual property, and governing law clauses survive termination.

15.4. Deletion or retention of data will follow the Privacy Policy, specific contracts, and legal/regulatory retention obligations.

16. Governing law, jurisdiction, and dispute resolution

16.1. These Terms are governed by the laws of the Federative Republic of Brazil.

16.2. The courts of the District of São Paulo/SP are elected as the forum, except for mandatory legal provision in favor of the consumer or specific regulatory jurisdiction.

16.3. Data subjects in other jurisdictions may exercise rights provided under local legislation in accordance with the Privacy Policy.

16.4. The parties may, beforehand, seek an amicable solution through the channel hello@pomwm.com before judicial measures, without prejudice to limitation periods.

17. Foreign exchange operations

17.1. The Client may request or confirm Foreign exchange operations through the Platform or integrated flows, subject to commercial conditions, regulatory limits, and procedures of MGN Serviços de Correspondente Bancário LTDA and EBURY BANCO DE CÂMBIO S.A., under CMN Resolution No. 4.935/2021 and applicable foreign exchange rules. MGN Investimentos LTDA acts as foreign exchange correspondent of EBURY BANCO DE CÂMBIO S.A. in accordance with Article 14 of the aforementioned CMN Resolution and BACEN rules.

17.2. Quotes, simulations, indicative rates, and deadlines are referential until formal confirmation in the systems of EBURY BANCO DE CÂMBIO S.A. Effective rate, IOF, fees, spread, taxes, charges, and applicable VET/CET will be informed before confirmation.

17.3. Deposit commitment. Upon confirming a Foreign exchange operation, the Client declares, to the extent permitted by law:

(a) to have read and understood the values, deadlines, currencies, costs, and conditions presented;
(b) to commit to deposit, transfer, or make available 100% (one hundred percent) of the resources necessary for settlement, including principal, IOF, fees, spread, and informed charges;
(c) to acknowledge that confirmation may generate obligations owed to EBURY BANCO DE CÂMBIO S.A., including rate reservation or foreign exchange contracting, regardless of subsequent withdrawal or default.

17.4. Default. If the Client fails to deposit or make available the full amount within the required period, they will be exclusively responsible for costs, losses, fines, interest, exchange differences, fees, chargebacks, reversals, or penalties incurred by EBURY BANCO DE CÂMBIO S.A., MGN Correspondente Bancário, and/or group entities.

17.5. To the maximum extent permitted by law, PoM, MGN Correspondente Bancário, and other group entities shall not bear costs of confirmed and unsettled operations due to the Client's fault, willful misconduct, or omission, and the Client shall indemnify PoM and group entities for related claims and expenses.

17.6. Measures in case of default: cancellation or suspension of the operation; collection or offset of amounts due, when contractually provided and legally permitted; restriction of functionalities; refusal of new operations.

17.7. Foreign exchange operations do not constitute investment recommendation or guarantee of future rate. The Client declares use of the functionality at their own risk, in compliance with Brazilian foreign exchange regulation and anti-money laundering rules.

17.8. Personal and financial data in the foreign exchange context will follow the Privacy Policy and may be shared with EBURY BANCO DE CÂMBIO S.A. to the extent necessary for execution, compliance, and registration of the operation.

18. Wealth planning

18.1. The wealth planning functionality allows the Client to provide and monitor wealth data, goals, flows, insurance, pension, income, liabilities, corporate structures, succession, and other information for preparation of plans, diagnostics, or reports by professionals or group entities (including MGN Investimentos), according to contracting.

18.2. Accuracy and updating. The Client declares that all information provided is true, complete, and up to date, assuming exclusive responsibility for omissions, inaccuracies, or outdated data. Plans, projections, and recommendations derive from the quality of the information provided.

18.3. The Client undertakes to promptly communicate material changes (acquisitions, disposals, debts, litigation, family, tax, or tax residence changes) that impact plans or deliverables.

18.4. Wealth planning does not constitute, unless under a specific contract, a promise of result, patrimonial guarantee, or performance obligation. Projections are hypothetical and subject to assumptions that may not materialize.

18.5. Deliverables may involve third-party specialists (lawyers, accountants, consultants), whose services are governed by their own contracts when contracted directly.

18.6. PoM and group entities shall not be liable for decisions made based on plans prepared from incorrect, omitted, or outdated data provided by the Client.

19. Travel

19.1. The travel functionality allows inquiry, quotation, and request of airline tickets, accommodation, travel insurance, transfers, and related services intermediated by Partners or Providers.

19.2. Prices, availability, cancellation policies, baggage, schedules, and conditions displayed are indicative until confirmation by the Partner. Booking or issuance may depend on payment, documentation, eligibility, and acceptance of supplier terms.

19.3. Upon confirming a request or payment, the Client undertakes to comply with informed deadlines, amounts, documents, and conditions, including non-refundable fares or fares subject to penalties.

19.4. Delays, cancellations, overbooking, itinerary changes, boarding denial, or dissatisfaction with tourism services are governed by supplier contracts and policies and, when applicable, by contracted travel insurance.

19.5. PoM does not operate transportation, accommodation, or insurance directly and shall not be liable for failures attributable to third-party suppliers, except for non-excludable legal liability.

19.6. In the case of a confirmed request that is unpaid, improperly cancelled, or not honored, the Client will be liable for costs, fines, chargebacks, and supplier penalties, in accordance with Section 12.5.

20. Insurance and health plans

20.1. The insurance functionality allows inquiry, simulation, request, or contracting of life insurance, national or international health insurance, and national health plans, intermediated by MGN Administradora e Corretora de Seguros de Vida Ltda. and/or partner insurers and operators, according to eligibility and applicable regulation.

20.2. PoM is not an insurer or health plan operator. Coverages, waiting periods, exclusions, provider networks, premiums, copayments, and conditions are governed by proposals, policies, regulations, and general conditions issued by the insurer or operator.

20.3. Simulations and comparisons are informational in nature and do not guarantee risk acceptance, issuance, or enrollment. Underwriting depends on eligibility, examinations, health declaration, and Partner approval.

20.4. The Client declares providing true and complete information in proposals and health declarations. Omissions or false information may result in loss of coverage, termination, or claim denial, being the exclusive responsibility of the Client.

20.5. Claims, reimbursements, authorizations, and complaints must be handled through the channels and deadlines of the contracted policy or product regulation.

20.6. PoM shall not be liable for coverage denial, delays, or decisions of the insurer or operator, except for specific legal liability of the broker within the limits of applicable regulation.

21. Contact

PoM Wealth Management LTDA

Avenida Angélica, 2529, 4th floor, Bela Vista, São Paulo/SP

General email: hello@pomwm.com

Privacy and data subject rights: hello@pomwm.com or Privacy Request

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Table of Contents

1. Parties, business group, and supplementary documents

1.1. Platform operator