Regulatory Disclosures

1. Regulatory Status and Licensing

Growth Capital operates in accordance with applicable UAE federal and emirate-level regulations governing financial advisory and consulting services. Our firm provides advisory, consulting, and intermediary services from our offices at Meydan Grandstand, 6th Floor, Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates.

The regulatory landscape in the United Arab Emirates encompasses multiple authorities with distinct mandates, including:

• Securities and Commodities Authority (SCA) — the federal regulator of securities and commodities markets across the UAE;
• Central Bank of the UAE (CBUAE) — the regulator of banking, insurance, payment services, and stored value facilities;
• Dubai Financial Services Authority (DFSA) — the independent regulator of financial services conducted within or from the Dubai International Financial Centre (DIFC);
• Financial Services Regulatory Authority (FSRA) — the regulator of financial services within the Abu Dhabi Global Market (ADGM).

Growth Capital does not operate from within the DIFC or ADGM free zones and is therefore not regulated by the DFSA or the FSRA. Where our advisory activities require licensing or regulatory approval under UAE federal law or the regulations of any particular emirate, Growth Capital maintains compliance with such requirements. Clients should be aware that not all advisory and consulting services are subject to the same regulatory framework as discretionary portfolio management, fund management, or broker-dealer activities.

Where Growth Capital facilitates introductions to regulated entities, including private banks, fund managers, or licensed financial advisers, those entities are independently regulated and licensed by the applicable authorities. Growth Capital encourages clients to verify the regulatory status of any such entity before entering into a relationship.

2. Nature of Services

Growth Capital provides advisory, consulting, and intermediary services in the areas of wealth management, legal advisory, accounting and tax advisory, tax relocation planning, premium residency and golden visa facilitation, private banking introductions, wealth structuring, and access to venture capital, private equity, real estate, and secondary market investment opportunities.

Our services are advisory and consultative in nature. Growth Capital does not:

• exercise discretionary management over client assets or portfolios;
• hold, custody, or control client funds or securities;
• act as a broker-dealer, market maker, or underwriter of securities;
• provide regulated legal services in any jurisdiction unless through a separately licensed legal entity or appropriately qualified counsel;
• provide audit or assurance services.

All investment decisions remain the sole responsibility of the client. Growth Capital may introduce clients to third-party providers, including regulated fund managers, private banks, legal counsel, and tax advisers, who operate under their own regulatory authorisations and are independently responsible for the services they provide.

3. No Offer or Solicitation

The content on this website, including all text, data, graphics, and other materials, is provided for general informational purposes only. Nothing on this website constitutes an offer to sell, a solicitation of an offer to buy, or a recommendation of any security, financial product, investment strategy, or transaction.

The information presented does not constitute investment advice, financial advice, legal advice, tax advice, or any form of personalised recommendation. Any descriptions of past or current investment opportunities, market conditions, or advisory services are provided solely for illustrative and informational purposes and should not be relied upon as a basis for making investment decisions.

Growth Capital does not make any representation or warranty, express or implied, as to the accuracy, reliability, completeness, or timeliness of any information on this website. All content is subject to change without notice.

4. Investment Risk Disclosures

Investing in venture capital, private equity, real estate, fund secondaries, and other alternative investments involves substantial risk, including the possible loss of the entire amount invested. Prospective investors should carefully consider the following risk factors:

4.1 Capital Loss

All investments carry the risk of partial or total loss of capital. There is no guarantee that any investment strategy, fund, or transaction will achieve its objectives or generate positive returns. Investments in early-stage ventures and unlisted companies carry a particularly elevated risk of total capital loss.

4.2 Illiquidity

Private market investments, including venture capital, private equity, and direct real estate, are inherently illiquid. There may be no secondary market for such investments, and investors may be unable to redeem, sell, or otherwise exit their positions for extended periods, which may span several years. Liquidity events are not guaranteed, and the timing and terms of any exit are uncertain.

4.3 Past Performance

Past performance is not indicative of future results. Any performance data, returns, or track record information presented by Growth Capital or any third-party fund manager relates to historical outcomes and does not guarantee or predict future performance. Market conditions, economic environments, and regulatory frameworks change over time, and past success is no assurance of future profitability.

4.4 Currency and Exchange Rate Risk

Clients investing across multiple jurisdictions are exposed to currency and foreign exchange risk. Fluctuations in exchange rates can materially affect the value of investments denominated in a currency other than the investor's base currency. While the UAE Dirham (AED) is pegged to the US Dollar, clients with exposures in Euro, British Pound, Singapore Dollar, Thai Baht, or other currencies should be aware of the potential for adverse currency movements.

4.5 Concentration Risk

Individual investments or strategies may involve concentration in particular sectors, geographies, or asset classes. Concentrated exposures can amplify both gains and losses and may result in disproportionate impact from sector-specific or region-specific adverse events.

4.6 Regulatory and Political Risk

Investments in multiple jurisdictions are subject to the regulatory, political, and legal environments of those jurisdictions. Changes in law, regulation, tax policy, sanctions regimes, or political stability in any relevant jurisdiction may adversely affect the value, liquidity, or enforceability of an investment.

4.7 Valuation Risk

Private market assets are often valued using methodologies that involve significant judgement and estimation. Valuations may not reflect realisable prices in an actual transaction, and interim valuations may differ materially from eventual exit proceeds.

5. Cross-Border Advisory Disclaimers

Growth Capital advises clients across multiple jurisdictions, including the United Arab Emirates, Singapore, Thailand, Portugal, Saudi Arabia, Hong Kong, Panama, and Mexico. Clients should be aware of the following:

• Jurisdictional availability. The services described on this website may not be available or permissible in all countries or jurisdictions. It is the responsibility of any person accessing this website to ascertain and comply with the laws and regulations of their country of residence or domicile. Growth Capital does not target or solicit persons in jurisdictions where such activity would contravene local law.
• Local regulatory requirements. Financial advisory, investment, tax, and legal services are regulated differently in each jurisdiction. Services facilitated by Growth Capital may be subject to local licensing, registration, or other regulatory requirements in the client's jurisdiction. Where required, Growth Capital works with locally licensed professionals to ensure compliance with applicable local law.
• Tax obligations. Clients are solely responsible for understanding and meeting their own tax obligations in all relevant jurisdictions. Growth Capital does not provide binding tax opinions and does not assume liability for a client's tax position. All tax-related guidance provided by Growth Capital is general in nature and should be supplemented by advice from qualified tax professionals in the applicable jurisdiction.
• Residency and immigration. Residency and visa applications are subject to the approval of the relevant government authorities. Growth Capital facilitates applications and provides advisory support but does not guarantee the outcome of any application. Processing times, eligibility criteria, and programme terms are determined by the relevant authorities and may change without notice.

6. Anti-Money Laundering and Counter-Terrorism Financing

Growth Capital is committed to combating money laundering, terrorist financing, and other forms of financial crime in accordance with the laws and regulations of the United Arab Emirates, including UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations, as amended, and its implementing regulations (Cabinet Decision No. 10 of 2019 and subsequent amendments).

In fulfilment of these obligations, Growth Capital:

• conducts customer due diligence (CDD) and, where appropriate, enhanced due diligence (EDD) before establishing a business relationship with any client;
• verifies the identity of clients, beneficial owners, and authorised representatives through reliable and independent documentation;
• monitors client transactions and activities on an ongoing basis and reports any suspicious transactions to the UAE Financial Intelligence Unit (FIU) as required by law;
• maintains records of all client identification documents, transaction records, and due diligence files for a minimum period of five years from the date of the transaction or the termination of the business relationship, in accordance with applicable law;
• provides regular AML/CFT training to all relevant personnel.

Clients are required to provide accurate and complete information during the onboarding process and to promptly notify Growth Capital of any material changes to their personal or corporate information, ownership structure, or source of wealth.

7. Sanctions Compliance

Growth Capital complies with all applicable sanctions laws and regulations, including those administered and enforced by the UAE, the United Nations Security Council, and, where applicable to our operations and client relationships, the sanctions programmes of the United States (OFAC), the European Union, and the United Kingdom (OFSI).

Growth Capital does not knowingly engage in transactions or business relationships with sanctioned persons, entities, or countries. All clients and counterparties are screened against applicable sanctions lists during onboarding and on an ongoing basis. Where a potential sanctions concern is identified, the matter is escalated in accordance with our internal compliance procedures and reported to the relevant authorities as required by law.

8. Conflicts of Interest

Growth Capital is committed to identifying, managing, and, where necessary, disclosing conflicts of interest that may arise in the course of providing advisory and consulting services to our clients.

Potential conflicts of interest may arise in the following circumstances, among others:

• Growth Capital or its principals may have financial interests in, or business relationships with, entities or transactions that are recommended or introduced to clients;
• Growth Capital may receive compensation from third-party providers, including fund managers, private banks, legal counsel, residency programme facilitators, or other service providers, in connection with client introductions or referrals (see Section 9 below);
• Growth Capital may advise multiple clients whose interests may not always be aligned, including in connection with access to limited allocation investment opportunities;
• Growth Capital's principals or employees may hold personal investments in the same assets, funds, or transactions that are presented to or recommended to clients.

Growth Capital manages these conflicts through internal policies and procedures, including information barriers, allocation policies, and disclosure to affected clients. Where a conflict cannot be adequately managed, it will be disclosed to the affected client prior to the relevant transaction or engagement.

9. Compensation and Fee Disclosure

Growth Capital may receive compensation for its services in the form of advisory fees, consulting fees, retainers, or success-based fees, as agreed with each client on an individual basis.

In addition to fees paid directly by clients, Growth Capital may receive referral fees, introduction fees, placement fees, or commissions from third-party service providers in connection with client introductions. These may include, without limitation:

• fees from fund managers, general partners, or investment platforms in connection with capital introductions or placement activity;
• referral fees from private banks, custodians, or financial institutions in connection with account openings or relationship introductions;
• commissions or fees from residency and immigration programme facilitators, real estate developers, insurance providers, or other professional services firms.

The existence and general nature of any such compensation arrangements will be disclosed to the relevant client. Clients may request further details regarding the compensation arrangements applicable to their specific engagements by contacting [email protected].

10. Professional Indemnity and Insurance

Growth Capital maintains professional indemnity insurance cover appropriate to the nature, scale, and complexity of its advisory and consulting activities. This insurance is designed to provide protection to clients in the event of loss arising from professional negligence or error in the provision of our services, subject to the terms, conditions, and limitations of the applicable policy.

The existence of professional indemnity insurance does not constitute a guarantee of compensation, and coverage is subject to the insurer's assessment of each claim. Details of our insurance arrangements are available upon request.

11. Complaint Handling Procedure

Growth Capital is committed to treating all clients fairly and resolving any concerns promptly and transparently. If you are dissatisfied with any aspect of our services, we encourage you to raise the matter through the following procedure:

Step 1 — Initial Contact

Please submit your complaint in writing to our Compliance team at [email protected], or by post to: Growth Capital, Meydan Grandstand, 6th Floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E. Please include your full name, contact details, a clear description of the complaint, and any supporting documentation.

Step 2 — Acknowledgement

Growth Capital will acknowledge receipt of your complaint within five (5) business days and will assign a designated officer to investigate the matter.

Step 3 — Investigation and Response

We aim to provide a full written response within thirty (30) business days of receiving your complaint. If the matter requires additional time for investigation, we will inform you of the expected timeline and provide interim updates.

Step 4 — Escalation

If you are not satisfied with our response, you may escalate your complaint to the relevant regulatory authority. Depending on the nature of your complaint, this may include the Securities and Commodities Authority (SCA), the Central Bank of the UAE (CBUAE), or such other authority as may have jurisdiction over the subject matter of the complaint.

12. FATCA and Common Reporting Standard (CRS) Compliance

The United Arab Emirates is a signatory to the Common Reporting Standard (CRS) for the automatic exchange of financial account information, and has entered into an intergovernmental agreement with the United States in respect of the Foreign Account Tax Compliance Act (FATCA).

While Growth Capital does not hold client funds or maintain financial accounts on behalf of clients, our advisory services may involve the facilitation of banking, investment, and structuring arrangements in multiple jurisdictions. Clients should be aware that:

• financial institutions with which clients hold accounts may be required to report account information to the relevant tax authorities under CRS and FATCA;
• clients may be required to provide tax identification numbers (TINs), self-certification forms, and other documentation to their financial institutions for CRS and FATCA compliance purposes;
• US persons (including US citizens, green card holders, and US tax residents) are subject to US tax reporting obligations regardless of their country of residence and should consult with a qualified US tax adviser;
• failure to comply with CRS or FATCA reporting obligations may result in penalties imposed by the relevant tax authority or financial institution.

Growth Capital does not provide CRS or FATCA compliance services directly, but works with qualified professionals who can assist clients in meeting their reporting obligations.

13. Data Protection and Confidentiality

Growth Capital processes personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the UAE Data Protection Law) and applicable regulations. We are committed to protecting the confidentiality of all client information and maintaining appropriate technical and organisational measures to safeguard personal data against unauthorised access, loss, or misuse.

Client information is shared with third parties only where necessary for the provision of our services, where required by law or regulation, or with the express consent of the client. For further information, please refer to our Privacy Policy.

14. Limitation of Liability

To the fullest extent permitted by applicable law, Growth Capital, its directors, officers, employees, and affiliates shall not be liable for any direct, indirect, incidental, consequential, or special damages arising out of or in connection with the use of this website, reliance on any information provided herein, or any advisory or consulting services rendered by Growth Capital, except in cases of wilful misconduct or gross negligence.

Growth Capital does not guarantee the outcome of any investment, transaction, application, or advisory engagement. Clients acknowledge that all investment decisions are made at their own risk and that Growth Capital's role is limited to providing advisory and consulting services as described herein.

15. Governing Law and Jurisdiction

These disclosures and Growth Capital's advisory and consulting services are governed by and construed in accordance with the laws of the United Arab Emirates. Any disputes arising out of or in connection with these disclosures or Growth Capital's services shall be subject to the exclusive jurisdiction of the courts of Dubai, United Arab Emirates, unless otherwise agreed in writing between the parties.