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How Does the SteelEye and FundApps Integration Affect My Contract?

Overview

As part of the integration of SteelEye into FundApps, these frequently asked questions address the legal and administrative updates we are making to align our contracting structure with our operating model.

For clients, our priority is continuity: no interruptions to service, no changes to pricing or commercial terms, and no changes to the team supporting you. We are committed to making this process as straightforward as possible and appreciate your support as we complete these formal steps.

General

Q: Why are these changes happening?

A: Following the announcement of the integration between SteelEye and FundApps: https://www.steel-eye.com/news/fundapps-and-steeleye-merge-to-create-a-unified-end-to-end-global-regulatory-compliance-platform, we are aligning parts of the business to create a simpler and more unified operating model. This is intended to support long-term service continuity and product development for clients while ensuring that our legal and operational structure properly reflects how services are delivered going forward.

Q: What happens to my contract?

A: This depends on which SteelEye entity you contracted with. If you signed your agreement with SteelEye Ltd, SteelEye Inc or SteelEye Pte Ltd, we will novate your agreement so that the relevant FundApps entity replaces the current SteelEye contracting party.

Q: What is a novation?

A: A novation is the legal process used to transfer a contract from one entity to another. In simple terms, the new entity becomes the contracting party for the future. In this case, it means that the relevant FundApps entity will step into the place of SteelEye under your existing agreement.

Q: Why is a novation needed?

A: As part of the integration, the employees responsible for delivering and supporting the services in the UK, US and Singapore will transfer to the equivalent FundApps entities. The novation ensures that the legal contracting party matches the entity that will be responsible for providing the services going forward.

Q: Why would you use a novation instead of an assignment?

A: An assignment usually transfers contractual rights only. A novation is used where the contract itself is moving from one entity to another, including obligations as well as rights. If the novation is not signed by the date we have specified however, we reserve the right to implement an interim assignment by notice as a temporary measure pending completion of the novation. The current SteelEye contracting entity would remain party to the agreement unless and until the novation is completed.

Q: Do we need to sign something?

A: Yes. To complete the transfer of your contract to the relevant FundApps entity, you must sign a novation agreement. Please review and sign the agreement by 12 June 2026.

Q: Can this be done just by notifying us?

A: Mere notice is not usually enough for a novation because novation typically requires the agreement of the relevant parties. Notice may still be part of the process, but it is not usually the whole process.

Service and Commercials

Q: Does this affect the service we receive?

A: Our goal is continuity and a seamless transition. The purpose of these changes is to align the contractual paperwork with the operating structure. Your existing services, platform access, relationship, and day-to-day support will remain uninterrupted, as the updates are purely for legal and operational alignment and will not affect how services are delivered.

Q: Are commercial terms changing?

A: There are no changes to your existing agreement, pricing, or commercial terms. The only change is the legal contracting entity.

Q: Who will our relationship team be?

A: You will continue to work with the same team members you know and trust. As part of one combined company, you will also have the opportunity, should you wish, to access the broader FundApps team and explore our wider range of regulatory and compliance solutions.

Security

Q: What security certifications does FundApps hold?

A: FundApps maintains a SOC 2 Type II attestation and is ISO 27001 certified.

FundApps has established a comprehensive information security programme encompassing all relevant control domains, with formal audit and assurance policies, procedures and standards in place. Security is embedded by design across systems, products and business practices in accordance with industry best practices.

FundApps employs a multi-layered security approach, including Datadog Workload Protection for real-time threat detection and continuous monitoring of cloud infrastructure, Static Application Security Testing (SAST) for vulnerability prevention during development, and Web Application Firewall (WAF) capabilities for internet-facing services. Logging and monitoring policies are formally established and maintained, alongside a dedicated cryptography, encryption and key management risk programme that includes risk assessment, treatment, monitoring and feedback provisions.

The organisation takes a proactive approach to security, given its access to sensitive client information, with security responsibilities embedded across all staff and overseen by the CTO.

Q: Where can I find security reports and policies?

A: Clients can access the Trust Portal for SOC 2 reports, ISO certifications, and penetration test results. Detailed security and risk management policies are available on the Policy Portal.

Corporate Structure

Q: Who is FundApps?

A: FundApps provides cloud-based, automated compliance monitoring and regulatory reporting software for financial institutions, including asset managers, hedge funds, and banks, specialising in automating shareholding disclosure, position limits, and short-selling regulations across 100+ jurisdictions, using "Regsperts" to update rules in real-time.

Q: Are FundApps and SteelEye part of the same group?

A: Yes. FundApps and SteelEye are part of the same group structure called the Rio Group.

Q: Who ultimately owns FundApps?

A: Day-to-day operational control is exercised collectively by the Rio Group Board. FundApps forms part of the Rio Group structure. Ownership is held through institutional holding companies within the Rio Group and staff shareholders. The ultimate owner of the Rio Group is FTV Capital, a US-based growth equity investment firm.

Q: Is there any individual who owns or controls 25% or more of FundApps or SteelEye?

A: No. No individual directly or indirectly owns or controls 25% or more of the shares or voting rights in FundApps Ltd or SteelEye Limited.

Q: Are the group entities wholly owned?

A: Yes. All operating subsidiaries are wholly owned except where local law requires a nominal local shareholding. These local formalities do not affect group control.

Q: Does FundApps have international entities?

A: Yes. FundApps has entities in the UK, USA, and Singapore, and SteelEye entities are located in the UK, USA, Singapore, Portugal, and India.

Q: Can you provide company registration numbers and addresses?

A: Please see the corporate structure information in the due diligence materials that outlines the relevant entity details.

Rebrand and Name Change

Q: Are SteelEye and FundApps changing name?

A: As part of the broader transition, we expect to rebrand to a new name, to reflect our new structure as one combined company.

Q: When will the new name be announced?

A: The new name will be communicated separately through a public announcement and broader client marketing communications before the formal name change steps are completed.

Q: Is the rebrand happening at the same time as the novation?

A: Not necessarily. The novation is the legal step to move your contract to the relevant FundApps entity. The rebrand and any formal name change will follow separately once the relevant legal formalities have been completed.

Q: Will the future name change affect the Novation Agreement?

A: No. The Novation Agreement transfers your agreement to the correct FundApps legal entity. If that entity later changes name as part of the rebrand, we will provide confirmation of the name change, including a certificate of name change where applicable. The novation does not need to wait for the rebrand.

Q: Will you provide evidence of the entity name change?

A: Yes. Once the relevant legal formalities have been completed, we will provide confirmation of the name change, including a certificate of name change where applicable.

Q: Does the future name change affect my contract?

A: No. The future name change will not change your services, pricing, commercial terms, or day-to-day contacts. We will provide formal confirmation so your records can be updated.

Q: Will we need to sign another agreement because of the new name?

A: We do not expect a separate agreement to be required solely because of the name change. Once the name change has been completed, we will provide the relevant confirmation or certificate of name change for your records.

Q: Should we update our vendor records now?

A: For now, please follow the details set out in the novation agreement provided to you. We will send a further update once the formal name change has been completed, together with any supporting documentation needed for your vendor records.

Q: Will invoices change after the rebrand?

A: Following the novation, please make payments using the invoicing and bank details provided in your novation agreement and due diligence pack. Once we have notified you that the entity name change is complete, future invoices will be issued under the new name. Supporting documentation, including a certificate of name change where applicable, will be provided for your records.

Q: Will there be any impact on service delivery?

A: No. The rebrand and name change will not affect your services, platform access, support arrangements, pricing, or commercial terms.

Q: Why are you changing the name?

A: The new name will reflect the combined company and our future structure following the merger of SteelEye and FundApps.

Q: Who can I speak to if I have questions?

A: Please contact your usual SteelEye representative or [email protected], who will be happy to help.

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