AT-COR-001 — Alta Terminal Governance Charter

1. Purpose

Alta Terminal LLC (“Alta Terminal”) is a subsidiary of Alta Group N.V. responsible for brokerage-style account, portfolio, research, order-entry, and market-access services within supported virtual economies.

Alta Terminal exists to connect eligible Customers to approved market infrastructure while providing a consistent Alta account experience. Alta Terminal is not a real-world securities exchange, bank, clearing agency, broker-dealer, cryptocurrency exchange, or financial custodian. Subject to this Charter, it may operate an internal custodial ledger venue for fictional, florin-denominated Minecraft-economy crypto instruments.

2. Ownership

Alta Terminal is wholly owned and controlled by Alta Group N.V. unless Alta Group approves a different ownership arrangement in writing.

Customers, vendors, data providers, execution providers, employees, contractors, and counterparties do not acquire ownership or governance rights through their use of or relationship with Alta Terminal.

3. Relationship with Alta Group

Alta Group retains final authority over:

• ownership and capitalization;
• appointment and removal of Terminal leadership;
• material strategy and product scope;
• customer-facing agreements and disclosures;
• selection of material execution, custody, data, banking, and settlement providers;
• fees and material commercial arrangements;
• risk appetite and control standards;
• major technology changes;
• branding and intellectual property;
• mergers, reorganization, suspension, sale, or dissolution; and
• matters reserved under Alta Group corporate documents.

Alta Terminal may conduct ordinary operations within approved policies and budgets.

4. Management

Alta Terminal shall be managed by a Director or President appointed by Alta Group. The appointed leader is responsible for daily operations, product delivery, customer support, provider coordination, staff supervision, risk escalation, and implementation of Alta Group directives.

The appointed leader may assign operational roles subject to Alta Group oversight. No operational title limits Alta Group’s reserved authority.

5. Authorized Activities

Subject to feature readiness, provider availability, and Alta Group approval, Alta Terminal may:

• open, maintain, restrict, and close Customer accounts;
• provide portfolio, watchlist, research, statement, and reporting tools;
• receive and validate Customer order instructions;
• route eligible instructions to approved independent providers;
• issue, administer, price, and retire approved fictional Alta Crypto instruments;
• execute eligible Alta Crypto market orders against an approved internal custodial ledger venue;
• maintain portfolio crypto wallets, treasury inventory, protected reserves, stabilization balances, and associated ledgers;
• establish and administer disclosed crypto pricing formulas, fees, supply limits, lifecycle states, and market-integrity controls;
• reconcile provider confirmations, positions, balances, and corporate actions;
• provide market and reference data obtained from approved sources;
• collect disclosed fees;
• investigate errors, abuse, fraud, or security events;
• maintain records and audit trails;
• publish Customer agreements, disclosures, and operational procedures; and
• perform other brokerage-support activities approved by Alta Group.

6. Prohibited or Reserved Activities

Alta Terminal may not, without an express amendment approved by Alta Group:

• operate or represent itself as a real-world securities exchange, cryptocurrency exchange, or public trading venue;
• represent itself as a real-world regulated broker, adviser, bank, custodian, or clearing agency;
• offer margin, lending, short selling, options, discretionary management, or securities lending;
• guarantee returns, liquidity, execution, settlement, or provider performance;
• issue ownership interests in Alta Terminal;
• create a subsidiary;
• borrow funds or pledge material assets;
• enter a material provider or partnership agreement;
• transfer material intellectual property;
• materially change its business model; or
• dissolve, merge, sell, or reorganize.

7. Provider Model

Alta Terminal may depend on independent providers for execution, venue access, custody or position records, settlement, market data, identity, communications, or banking services.

Before enabling a provider-dependent feature, Alta Terminal shall document:

• the provider’s responsibilities;
• Alta Terminal’s responsibilities;
• authentication and authorization controls;
• error, cancellation, and reconciliation procedures;
• service limits and failure handling;
• data use and retention;
• financial and operational dependencies; and
• termination and transition procedures.

Provider appointment does not transfer Alta Terminal’s responsibility for accurate Customer disclosures or reasonable oversight of its own systems.

7A. Alta Crypto Market Authority

Alta Group authorizes Alta Terminal to operate Alta Crypto solely as a fictional, florin-denominated Minecraft-economy service. Alta Crypto is an internal ledger venue, not a blockchain, public order book, external wallet network, or real-world financial market.

Alta Group retains final authority to approve:

• each crypto instrument and its initial configuration;
• supply limits, treasury inventory, pricing formulas, fees, and reserve rules;
• activation, material economic changes, redemption-only operation, closure, or retirement;
• the permitted uses of stabilization balances and accrued revenue; and
• any future customer-to-customer transfers, external transfers, payment functionality, or blockchain connectivity.

Alta Terminal management may perform ordinary market operations within approved configurations, including processing market orders, maintaining custodial records, reconciling balances, halting unsafe activity, moving an asset to redemption-only status, and applying auditable corrections. Management may not silently change an authoritative pricing formula, divert a protected reserve, fabricate supply, erase transaction history, or activate a material new crypto capability without the approval required by Alta Group.

Alta Terminal acts simultaneously as issuer or administrator, internal venue operator, custodian of ledger balances, reserve administrator, and fee recipient for Alta Crypto. Those roles create conflicts of interest. Customer disclosures must describe those roles, the absence of independent price discovery, the applicable fee allocation, and the limits of reserves and stabilization balances.

Protected reserves, treasury inventory, stabilization balances, accrued revenue, and Customer portfolio balances must be separately identifiable in authoritative records. Protected reserves may be used only for the corresponding disclosed redemption or curve-liability purpose, corrections attributable to that purpose, or another use expressly approved by Alta Group and disclosed before it affects Customers. Stabilization balances do not belong to Customers and do not guarantee price support, liquidity, or recovery from loss.

8. Customer Protection Principles

Alta Terminal shall seek to:

• distinguish live features from planned or simulated features;
• disclose material fees and risks before Customer action;
• use authenticated, idempotent instructions where appropriate;
• maintain understandable account and transaction records;
• separate Customer permissions from staff permissions;
• protect credentials and sensitive information;
• investigate reported errors consistently;
• identify material affiliate or provider conflicts; and
• avoid representing fictional services as real-world regulated products.

9. Order and Account Controls

Alta Terminal may establish eligibility, funding, instrument, quantity, price, velocity, concentration, and account controls. Controls shall be documented, consistently administered, and capable of preventing or restricting unsafe activity.

Orders may be rejected or held before transmission when they fail validation or risk controls. Provider responses shall be recorded and reconciled to Customer-facing status.

10. Records and Audit

Alta Terminal shall maintain records reasonably necessary to explain:

• account approval and permissions;
• Customer instructions;
• provider transmissions and responses;
• executions, cancellations, corrections, and failures;
• positions and cash movements;
• fees;
• staff actions;
• disputes and resolutions; and
• material operational incidents.

Production records shall not be silently replaced by mock, preview, or test data.

11. Conflicts and Affiliates

Alta Terminal may use services provided by Alta Group affiliates, including Alta Bank. Affiliate use must not be presented as independent advice or independent provider selection.

Material compensation, preferential routing, ownership, or provider relationships that could affect Customer activity shall be disclosed when relevant.

12. Risk and Incident Management

Alta Terminal shall maintain procedures for provider outages, stale or incorrect data, duplicate instructions, reconciliation breaks, unauthorized access, compromised credentials, market interruptions, and service suspension.

Material incidents shall be escalated to Alta Group and documented through appropriate operational and audit channels.

13. Legal and Customer Documents

Alta Terminal shall maintain, at minimum:

• a Customer Agreement;
• Trading and Order Handling Terms;
• a Risk Disclosure;
• Market Data and Third-Party Services Terms; and
• a Fee Schedule.

Alta Terminal shall also maintain a crypto trading and custody disclosure while Alta Crypto is offered.

Additional agreements shall be adopted before margin, lending, advisory services, institutional accounts, customer-to-customer crypto transfers, crypto payments, external wallets, blockchain connectivity, or other materially different products are enabled.

14. Amendments

Alta Group may amend this Charter. Alta Terminal management may propose amendments but may not adopt them without Alta Group approval.

15. Approval

This Charter establishes Alta Terminal as a standalone Alta Group subsidiary and supersedes any prior description of Terminal as a product or division of another market operator.