Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239

Cloud9 Technologies – Service Description

May 2019

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Cloud9 Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239

Contents 1. Overview ...... 3 2. Cloud9 Technologies Service Summary ...... 3 3. Major Service Components ...... 4 3.1 Trading Turret Interface Options ...... 4 3.2 Cloud9 Directory (Trader Voice Connectivity) ...... 6 3.3 Voice Recording ...... 8 3.4 Enterprise Communications ...... 13 3.5 Cloud9 Portal (Service Self-Management) ...... 14

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Cloud9 Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239 1. Overview The following document provides a description of the service, features and technology offered by Cloud9 Technologies. 2. Cloud9 Technologies Service Summary Cloud9 Technologies is a leading fintech company that is leveraging cloud and VoIP technologies to offer an alternative technological solution to traditional voice trading systems. Uniquely, our solution encompasses the turret functionality, the private line connectivity, enterprise communications and voice recording into a single SaaS based service offering that firms can manage themselves. The Cloud9 service offers greater security and resiliency (i.e. encrypted voice), with a dramatic reduction in the total cost of ownership. Our solution is simpler for firms to manage and provides flexibility as firms grow/reduce their trading business requirements.

Ultimately our mission is to continue to grow a global community of trading firms that use our platform daily to connect, communicate and then analyze the results of their trading communications activity. Cloud9 is a community, not a telephone system. We commercially deployed our cloud-based service offering in the 4th quarter of 2014. In just a relatively short time span, our service has been adopted by more than 5000 traders in 40+ countries. Currently, Cloud9 is the only voice trading communications vendor that is ISO27001 certified and has full SOC II accreditation. Cloud9 is a global company with offices in New York, Boston, Houston, Chicago, London, Hong Kong and Singapore.

The benefits of deploying our cloud-based service are impactful: • Mobility with Compliance – seamlessly connect to counterparties from anywhere in while remaining secure and compliant. • Inherent Disaster Recovery – no need to procure and deploy costly infrastructure/real estate • Simple and economical to deploy and scale up or down as required – it’s just an application. • Eliminate expensive proprietary hardware and the hassle of dealing with telecommunications carriers. • Easy transition from traditional trading turrets / ability to have side- by-side usage -eliminates risky cutovers • An economical way to communicate across departments and regions at a fraction of the cost

Some of the key things that differentiate Cloud9 from traditional turret systems include: • An easy to use application that eliminates the need for a traditional turret on the trader’s desktop • Unlimited connections and a global directory that lets you quickly find and connect with trading counterparties.

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Cloud9 Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239 • Integrated call recording that provides compliance and recording from any location without the need to procure and integrate with a 3rd party voice recording system • A customer portal from which you can manage and maintain your global trading environment • No service or maintenance contracts • A simple SaaS business model that lets you scale your business up or down monthly. 3. Major Service Components As mentioned in the previous section, the Cloud9 service offering includes the functionality of several important services that are required for financial trading communications:

• Trading Turret Interface Options • Cloud9 Directory (Trader Voice Connectivity) • Voice Recording • Enterprise Communications • Cloud9 Portal (Service Self-Management)

This section provides detail for each of these major service components that are currently part of the Cloud9 service offered to our global customer base.

3.1 Trading Turret Interface Options Cloud9 provides users with several hard and soft UX options at the trader’s desktop. These options do not require expensive proprietary hardware. The user interface is delivered through the C9 Trader application installed on the user’s desktop computer. The application provides turret-like features as well as the option to use the Cloud9 Button Board if a physical turret interface is preferred by the user.

One of the unique aspects of the Cloud9 SaaS model is no long-term service commitments, and no maintenance costs. In fact, firms are free to download and use the C9 Trader application on as many computers in their corporate environment as they like. Cost is user subscription based.

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Cloud9 Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239 The Cloud9 application is a Windows based (Windows 7, 8 and 10) application designed for financial traders. It provides the core features necessary for traders to communicate within their global organizations as well as with counterparty firms.

Multi-button support The Cloud9 application supports as many as 650 button appearances that can be a combination of internal/external shout down, ring down, PBX, Hoot & Holler, TV-Audio and Intercom connections.

Multi-audio device support The Cloud9 application allows a user to select up to three devices distinct audio devices (microphone/speaker, primary handset/headset and secondary handset/headset) to be used. Users can move active calls between these devices with global muting options that allow for both open and confidential conversations.

Cloud9 Button Board The Cloud9 application supports the connection of three external button board device options: • 24 Button Cloud9 Button Board

Each of the button board device options allow the user to program their connections onto the physical interfaces. This allows the Cloud9 application to be minimized so that it takes up no screen real estate as well as providing users with a physical push- button interface. Cloud9 24 Button Board

Cloud9 Gooseneck Microphone Noise cancelling, unidirectional gooseneck that connects to computer soundcard or USB port.

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Cloud9 Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239 Cloud9 Handset The Cloud9 handset has been designed specifically for enterprise trading floor environments. It can be ordered with noise cancelling push to talk or push to mute options.

Ergonomic Trading Desk options Given the variety of device options, the C9 Trader application allows firms to customize the user’s desk for a variety of different trading styles.

3.2 Cloud9 Directory (Trader Voice Connectivity) The Cloud9 application allows users to view all visible counterparty firms and internal users that are part of the Cloud9 community. Each firm controls its visibility properties when viewed by external firms. If visible, potential trading partners can use the Cloud9 directory to

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Cloud9 Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239 find/discover external trading firms and trading desks within the listed directory. The directory also allows provisioning to internal users to support a global intercom capability.

Note: Firm and associated trading desk visibility on the Cloud9 directory is controlled by designated IT administrators within each firm. Cloud9 recommends that a firm trialing the service keep their identity private to external firms, but visible to other Cloud9 trading groups within their firm.

New connection invitation notification Cloud9 users can receive notifications when new connection invitations are sent to their designated trading group. These new connections requests can be generated by other traders within the same firm, counterparty firms or by IT administrators via the Cloud9 customer portal.

New connection creation When enabled, Cloud9 users can search the directory of Cloud9 firms to request connections. These connections can be external trader voice connections or internal hoot, PBX and internal connections. Each firm can control this user feature by enabling/disabling through the customer portal. Cloud9 In-App Directory Button provisioning Cloud9 users can perform several button settings features via the user interface. All of these changes are automatically saved so it will follow the trader if they log into the service from other authorized locations. • Add new buttons to their UI interface by accepting new connection invitations • Add/delete buttons by displaying the connection list associated with their predefined trading desk they have been assigned to • Customize button label (only affects individual user’s button) • Reorder buttons • View detail button information (i.e. Current button subscribers)

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Cloud9 Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239 3.3 Voice Recording One of the most critical of our cloud service is support for greater call analytics and regulatory record keeping. The regulatory requirements placed on financial trading firms typically require all trade activity be recorded and archived. While traditional voice logging systems have been used by firms to meet this general regulatory obligation, these legacy systems lack the support for many future requirements (i.e. Mifid 2). Regulatory bodies are challenging firms to provide compliance with the following:

• Periodic call recording reconciliation – Firms must prove they have captured all related trade communications. Exceptions must be documented and reported. • Proof of intact archive – Regulatory agencies need firms to confirm electronically that archived content has not been altered. • Accurate voice transcription – Regulatory agencies will want firms to accurately transcribe voice recording into metadata text files to improve audit processing and trader detection. • User mobility – During this era of BYOD, firms must decide if their traders can trade from multiple locations and how they can ensure voice recording is in place.

Cloud9 Technologies has considered the current state of trader voice call recording and the future demands firms will have for greater regulatory compliance and reconciliation. We have designed our service platform to consider these demands. As such, we provide several options to help our customers integrate with their current voice logging systems as well as offer a seamless transition to cloud- based archiving which simplifies the management of critical trade records and considers the future regulatory requirements.

One of the principal design goals for the Cloud9 platform is to provide our customers with an open, non-proprietary archive solution that offers the following options:

• Cloud-based archive • Customer premises-based archive (i.e. Nice NTR integration) • Integration with External Archive platforms (i.e. Global Relay)

Each one of our archive options is commercially available and field proven by many financial trading firms. In this section of the document each option listed above will be reviewed. In conclusion, we will compare and contrast these three basic archive options, so the reader can make an informed decision on the option(s) that is best suited for their firm.

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Cloud9 Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239 Cloud-based archive option Cloud9’s cloud-based archive is a standard option for many of our customers. Traditional trading turret systems require external third- party voice logging systems. The concept behind our cloud-based archive option is to offer firms a completely compliant and integrated solution that ensures traders are always recorded, regardless of where they are permitted to log into our global service. This option has several benefits:

• Economic monthly subscription- based service with no equipment purchase • Cloud-based solution that supports global free-seating for mobile traders • Administrative access to portal to run audits and get copies of voice recording files and call record statistics

With the cloud-based recording, administrators log into the Cloud9 Portal at the Cloud9 Technologies website (www.c9tec.com). There is a button on the web page for portal login. Once logged into the portal, a complete listing of the firm’s call records is Intuitive portal user interface for auditing trader voice records and voice recordings displayed in the user’s browser window.

Administrators can filter through the displayed call records in several ways to quickly find the call event(s) and related voice recording file(s) to listen to. Voice recording files can be played back through the computer browser or downloaded locally to the user’s computer for local playback and compliance distribution.

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Cloud9 Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239 Each listed call record provides the following information: • Local/remote user name • C9 button used • Call start time, duration and end time • Counterparty • Quality measurement for call (MOS score) • Playback capability of associated voice recording file

The simple design of the browser-based interface allows administrators to quickly filter and find call records. This provides fast auditing to help confirm trade details or to collect important records during audit requests and legal hold periods.

Customer premises-based archive option Many Cloud9 customers already have a voice logging platform in place when they begin to consider migrating away from traditional turret systems. In this case, it is important that the Cloud9 solution properly integrate with these traditional premises-based voice recording systems.

Cloud9 has developed an Analytics API specifically to support integration between the Cloud9 application installed on the user’s computer and the existing on-premises voice recording system. Detailed information on the Cloud9 Analytics API is provided at the following website (http://docs.c9analyticsv2.apiary.io/#). There is no cost for using the Analytics API and we encourage developers to visit the apiary site to get detailed information on its use. While Cloud9 continues to work with 3rd party archive firms to develop and test integrations with our service, the following vendor solutions have already been evaluated:

• Nice Systems NTR • Red Box Recorders • Verint • Verba • Fonetic • Behavox

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Cloud9 Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239 When firm administrators establish new user accounts via the Cloud9 portal they can select the voice archive solution they desire. This can be selected on an individual user account basis.

Configuring user account for call archiving options

As the figure on the previous page illustrates, specific archive features can be selected for the individual user: • Voice recording requirement (Y/N) – General voice recording option • Enhanced metadata – Should call records included advanced analytics (Y/N) not available in standard trading turret systems • Archive option (Cloud/Local) – Local or cloud-based option per user account

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Cloud9 Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239 • Local Archive address – Tells Cloud9 application where to send call record and voice recording files in the event local archiving option is selected

External Archive Services option Beyond local and cloud-based archive solutions, many Cloud9 customers use External Archive service providers to help manage storage of their trading activity records. A typical example is Global Relay. This firm is a leading provider of Messaging and Archiving solutions specifically focused on regulatory compliance. In many cases financial trading firms use the Global Relay’s service to archive their trader email and messaging activity. Cloud9 supports integration with Global Relay. This allows firms to use a single archive solution for all their trading related communications. This includes, email, IM and Cloud9 voice recordings and call records.

Enhanced Metadata As this section has discussed, Cloud9 is continuing a thoughtful process of expanding our archive and analytics capabilities. This includes the content of our call records. Traditional trading turret systems can record trader voice calls and can even provide basic details on your trader’s turret activities. However, there is no information on whom they were speaking with. There is the ability to know which line was in use and infer the counterparty firm. However, there is no way to know the individual the local trader was communicating with. Counterparty information is crucial during a regulatory audit but has never been attainable with any degree of accuracy with legacy trading turret systems.

When the Enhanced Metadata option is turned on for a Cloud9 user, the application provides Enhanced Metadata. Call record information from the Cloud9 application to cloud-based or premises-based analytics systems includes detailed information about the counterparty individuals that are part of recorded call events. This additional information is a key element that allows firms to get a better understanding of the counterparty individuals their traders are communicating with.

Voice Transcription Cloud9 has begun customer testing of a unique voice transcription feature. We have developed our own voice-to-text transcription engine that is integrated into the Cloud9 application. This first phase transcription engine has been customized for English language – commodities trading environments. It is designed using modern machine learning techniques to help Cloud9 produce an industry- leading transcription capability that will offer highly accurate (>85%) text conversion of Cloud9 high fidelity voice recording files. Transcription is a key ingredient in our enhanced metadata service strategy.

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Cloud9 Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239 3.4 Enterprise Communications One of the most important aspects of aspects of the Cloud9 service is to support the transition between legacy trading system environments and the plan for most financial services firms to migrate to a cloud-only future. As such, the Cloud9 service supports integration with several important legacy telecom technologies.

• Cloud9 Gateway service – Integration with traditional Trader Voice Carrier services • Click-To-Call – Integration with SIP-based IP-PBX and PSTN services

Cloud9 Gateway service (Trader Voice Integration) While the C9 Trader application makes it fast and simple to connect with any firms on the Cloud9 community, there often are times when connections to firms not yet using the Cloud9 service are necessary. This is the primary purpose of using Cloud9’s gateway service. Cloud9 can establish its gateways at the customer premises or can host these at traditional datacenter globally. Traditional trader voice circuits (i.e. E1/) from telecom providers can be interfaced to the Cloud9 gateways so non-Cloud9 firms can be connected to trading desks using the C9 Trader application.

Click-To-Call (Integration with Cisco CUCM and SIP-based PSTN services) The Cloud9 application supports SIP-UA connectivity with SIP-Based PSTN services and IP-PBX systems. This feature (Click-To-Call) will allow Cloud9 users to have access to PSTN/PBX service in addition to Cloud9-to- Cloud9 communications. By adding support for SIP into the Cloud9 application it simulates the basic function of any third-party SIP telephone. The Click-To-Call feature also allows the Cloud9 Application to integrate with the user’s Click-To-Call Display Microsoft Outlook Contacts, so users can quickly provision their personal speed dials.

Click-To-Call features are also supported on the Cloud9 Button board device. Allowing users to assign multiple speed dials to this physical hardware interface device.

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Cloud9 Technologies LLC. 565 Fifth Avenue New York, NY 10017 +1.866.753.4239 3.5 Cloud9 Portal (Service Self-Management) One of the most important benefits of the Cloud9 service is the ability for firms to tightly manage their deployment and cost for service. Cloud9 provides all customers with no-cost access to the Cloud9 portal to let them manage their trading communications needs on a global basis. The portal provides a variety of important features:

• Single management tool that can be permissioned for local, regional or global control • Secure browser interface that can be integrated with Corporate Directory Controls (Single Sign on) • Dynamic Roles & Permissions control that allow the portal to be customized for a firm’s own unique support workflow and compliance requirements • Full provisioning control to establish user accounts, connectivity, voice recording options, usage reports, QOS tracking, call records, etc. • Full on-line help, user and administrator training tools • Continuously expanding feature set automatically available to Cloud9 firms

Cloud9 Portal

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