Akuna Employee Handbook

EMPLOYEE HANDBOOK UPDATED FEBRUARY 2023

Akuna Employee Handbook Welcome to Akuna Capital! Thank you and congratulations on joining Akuna Capital! On behalf of your colleagues, I welcome you and wish you every success here. Established in Chicago in 2011, Akuna is a fast-growing boutique trading company specializing in derivatives market-making and arbitrage. Akuna pairs talented people with innovative technology to create a flexible and dynamic approach to trading. We provide employees opportunities to develop and grow with the business, ensuring a stimulating work environment for all. We believe that each employee contributes directly to Akuna's growth and success. We hope you will take great pride in being a member of our exciting team. This Handbook was developed to describe the expectations of our employees and to outline the policies, programs and benefits available to eligible employees. Employees should familiarize themselves with the contents of the Handbook upon starting their employment with Akuna; it will answer many questions you may have initially and is a great resource throughout the course of your employment. Departments may have additional policies or procedures, which are specific to their needs. These will supplement the Handbook. However, this Handbook cannot anticipate every situation or answer every question about employment at Akuna. It is not an employment contract and is not intended to create contractual obligations of any kind. Your employment remains, at all times, an at-will employment arrangement. The policies and procedures outlined in this Handbook apply to all US subsidiaries of Akuna Holdings LLC including but not limited to Akuna Capital LLC, Akuna Securities LLC, Akuna Digital Assets LLC, Akuna Investment Operations LLC and Akuna Technologies LLC. In order to retain necessary flexibility in the administration of policies and procedures, Akuna reserves the sole and exclusive right, without prior notice, to delete, modify, and interpret any of the policies and/or benefits described in this Handbook. The only recognized deviations from the stated policies and procedures are those authorized in writing by Management of Akuna. Once again, congratulations and thank you for joining the team. We look forward to your contributions in growing a prosperous business together! Sincerely, Ryan Duckworth Chief Executive Officer – US 2

Akuna Employee Handbook Table of Contents DISCLAIMER ..................................................................................................................................................... 5 DEFINITIONS...................................................................................................................................................... 6 DIVERSITY & INCLUSION .................................................................................................................................. 8 Non-Discrimination/Anti-Harassment Policy and Complaint Procedures ......................................... 8 Equal Employment Opportunity............................................................................................................. 8 Americans with Disabilities Act (ADA)....................................................................................................... 10 All Unlawful Retaliation Prohibited............................................................................................................... 10 Religious Accommodation ................................................................................................................... 11 EMPLOYMENT ....................................................................................................................................................... 12 Background and Fingerprint Checks ................................................................................................... 12 Employment Eligibility Verification ....................................................................................................... 12 Foreign National Employees ....................................................................................................................... 12 Performance Evaluation ....................................................................................................................... 12 Personnel Records ........................................................................................................................................ 12 Employment Verification and Job References .................................................................................. 13 COMPENSATION............................................................................................................................................ 14 Paydays .......................................................................................................................................................... 14 Overtime ................................................................................................................................................. 14 Timekeeping ................................................................................................................................................. 14 Administrative Pay Corrections ........................................................................................................... 14 Salary Reviews ........................................................................................................................................ 14 Bonus Vesting ......................................................................................................................................... 14 EMPLOYEE BENEFITS ............................................................................................................................................. 16 Waiting Period........................................................................................................................................ 16 Open Enrollment .......................................................................................................................................... 16 Qualifying Life Event ..................................................................................................................................... 16 Medical, Dental & Vision Insurance ..................................................................................................... 16 Life Insurance ......................................................................................................................................... 16 Long-Term Disability Plan (STD) ............................................................................................................. 16 Short-Term Disability Plan (LTD) ............................................................................................................. 17 401(k) ....................................................................................................................................................... 17 Flexible Spending Accounts (FSAs) ...................................................................................................... 17 Continuation of Health Coverage ..................................................................................................... 17 Workers' Compensation Insurance .................................................................................................... 18 Employee Assistance Program ............................................................................................................ 18 Education Assistance ............................................................................................................................ 18 Employee Referral Program ................................................................................................................. 18 EMPLOYEE TRAVEL & REIMBURSEMENTS ................................................................................................... 20 Travel Policy ............................................................................................................................................ 20 Expense Reimbursement ....................................................................................................................... 20 3

Akuna Employee Handbook TIME OFF AND LEAVES OF ABSENCE ......................................................................................................... 21 Vacation Leave ..................................................................................................................................... 21 Sick Leave ............................................................................................................................................... 21 Holidays .................................................................................................................................................. 22 Parental Leave ...................................................................................................................................... 22 Bereavement Leave ............................................................................................................................. 24 Political Participation and Voting Leave .......................................................................................... 24 Jury Duty Leave ..................................................................................................................................... 25 Volunteer Leave .................................................................................................................................... 25 Family and Medical Leave ................................................................................................................. 25 Military Leave ......................................................................................................................................... 26 State Paid Family & State Disability Leave ........................................................................................ 26 WORKPLACE EXPECTATIONS ....................................................................................................................... 27 Work Attire .............................................................................................................................................. 27 Attendance and Punctuality ............................................................................................................... 27 Meal Periods ........................................................................................................................................... 27 Working from Home ............................................................................................................................. 27 Safety....................................................................................................................................................... 30 Workplace Violence Prevention ......................................................................................................... 30 Drug and Alcohol Use ........................................................................................................................... 31 Smoking/Vaping .................................................................................................................................... 32 Business Ethics and Conduct................................................................................................................ 32 Romantic Relationships ......................................................................................................................... 32 Outside Employment ............................................................................................................................. 32 Confidential Information ....................................................................................................................... 33 Procurement ........................................................................................................................................... 35 IT Resources and Communications Systems Policy ............................................................................ 35 Information Technology and Security Policies .................................................................................. 39 Communications to the Press ............................................................................................................... 40 Compliance Policies .............................................................................................................................. 40 SEPARATION OF EMPLOYMENT ................................................................................................................... 41 Advance Notice .................................................................................................................................... 41 Termination ............................................................................................................................................ 41 Termination Procedures ........................................................................................................................ 41 Return of Akuna Property ...................................................................................................................... 41 EMPLOYEE HANDBOOK RECEIPT ACKNOWLEDGEMENT .......................................................................... 42 4

Akuna Employee Handbook DISCLAIMER This Employee Handbook contains information about Akuna Capital's employment policies and procedures and an overview of Akuna Capital's benefits. For specific information about Employee benefits, you should refer to the plan documents, which are controlling. The policies and procedures in this Handbook are guidelines only. Akuna Capital reserves the sole and exclusive right, without prior notice, to delete, modify, and interpret any of the policies and/or benefits described in this Handbook as needed and as permitted or required by law. Except for the policy of “at will” employment, oral statements or representations cannot supplement, change or modify the provisions in this Handbook. Each Employee should read and become familiar with the information contained in this Handbook. Each Employee may also be subject to additional Akuna Capital policies or policies of Akuna Capital’s affiliates including each Written Supervisory Procedures document that governs Akuna Capital as a regulated entity and each of its regulated affiliates. If you have any questions regarding what policies apply to you, please contact your Manager or reach out to the Human Resources department. Failure to comply with Akuna Capital's policies or procedures may result in discipline, up to and including termination. The provisions in this Handbook are not intended to in any way create any contractual obligations with respect to your employment. NOTHING IN THIS HANDBOOK NOR ANY OTHER COMMUNICATION BY AN AKUNA CAPITAL REPRESENTATIVE OR ANY OTHER EMPLOYEE, WHETHER ORAL OR WRITTEN, IS INTENDED TO IN ANY WAY CREATE A CONTRACT OF EMPLOYMENT. UNLESS A WRITTEN EMPLOYMENT AGREEMENT IS SIGNED BY AN AUTHORIZED AKUNA CAPITAL REPRESENTATIVE, EMPLOYMENT IS “AT WILL” AND NOTHING IN THIS HANDBOOK CAN BE CONSTRUED TO CONTRADICT, LIMIT OR OTHERWISE AFFECT AN EMPLOYEE’S RIGHT OR AKUNA CAPITAL'S RIGHT TO TERMINATE THE EMPLOYMENT RELATIONSHIP AT ANY TIME WITH OR WITHOUT NOTICE OR CAUSE. This Handbook supersedes all prior versions published or distributed by Akuna Capital and all inconsistent oral or written statements. Akuna is headquartered in Illinois and this Handbook has been drafted to provide Federal and Illinois specific guidelines. However, Akuna will comply with any relevant state specific guidelines as applicable for those employees that are not based in Illinois. Any non-Illinois employee may contact HR directly for state specific questions and wherever possible Akuna will provide state specific information on the HR wiki or via a state specific appendix to the Handbook as appropriate. For purposes of this Handbook, (a) the words \"include,\" \"includes,\" and \"including\" are deemed to be followed by the words \"without limitation\"; (b) the word \"or\" is not exclusive; and (c) the words \"herein,\" \"hereof,\" \"hereby,\" \"hereto,\" and \"hereunder\" refer to this Handbook as a whole. Whenever the singular is used herein, the same shall include the plural, and whenever the plural is used herein, the same shall include the singular, where appropriate. 5

Akuna Employee Handbook DEFINITIONS AKUNA/COMPANY: The term “Akuna” or “Company” shall mean Akuna Capital LLC and its US subsidiaries, including but not limited to, Akuna Securities LLC, Akuna Digital Assets LLC, Akuna Investment Operations LLC and Akuna Technologies LLC. ANNIVERSARY DATE: The term “Anniversary Date” indicates the date which is twelve months from the Employee’s Start Date, and twelve months from any subsequent Anniversary Date. MANAGER: The term “Manager” includes any person who has been granted the authority by Management and is responsible for directing the work of subordinates. DISABILITY: The term “Disability” refers to a physical or mental impairment that substantially limits one or more major life activities. This includes a record of such an impairment, even if an individual does not currently have a disability. It also includes the impression of having a Disability. A person may also be disabled if they have a history of Disability. EMPLOYEE: The term “Employee” indicates a person employed by Akuna who receives wages or salaries through Akuna’s payroll. ESSENTIAL FUNCTION: The term “Essential Function” includes those fundamental or core job duties of a position, distinguished from a marginal duty. FULL-TIME EMPLOYEE: The term “Full-Time Employee” indicates any Employee who is not in a temporary status and who is regularly scheduled to work Akuna's full-time schedule. Full-Time Employees must work a minimum of 30 hours per week and must be employed on a permanent basis. Full-Time Employees are eligible for all employment benefits offered by Akuna, subject to the terms, conditions, and limitations of each benefit program. HUMAN RESOURCES: The term “Human Resources” or “HR” refers to any Akuna Employee granted the authority by Management to handle all confidential paperwork related to a person’s employment with Akuna including, but not limited to, employee benefits, on the job injuries and disciplinary actions. IMMEDIATE FAMILY: The term “Immediate Family” includes the Employee's spouse, domestic partner, parent, child, sibling, grandparent, or grandchild; the E mployee's spouse or domestic partner’s parent, child, sibling, grandparent, or grandchild; the E mployee's child's spouse. This includes all step-, foster- or adoptive- Immediate Family relations. MANAGEMENT/SENIOR OFFICERS: The term “Management” or “Senior Officers” refers to those individuals granted the authority to carry out all managerial decisions of Akuna, including, but not limited to the hiring, discipline and T ermination of any Employee. Appointment of Management is at the sole discretion of Andrew Killion, CEO. NONEXEMPT EMPLOYEE: The term “Nonexempt Employee” indicates all Employees who are not exempt from minimum wage or Overtime Pay under the Fair Labor Standards Act (FLSA). These Employees receive Overtime Pay for hours worked in excess of 40 hours in any one workweek. OFFICE/WORKPLACE: The term “Office” or “Workplace” includes any building or site owned, leased, used, or controlled by Akuna. 6

Akuna Employee Handbook OVERTIME PAY: The term “Overtime Pay” indicates payment made to a Nonexempt Employee at a rate of one and one-half times the Nonexempt Employee’s regular hourly rate of pay for every hour worked over 40 hours in one work week. PROTECTED CHARACTERISTICS: The term “Protected Characteristic” refers to any individual’s characteristics that relate to the individual’s race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability, genetic information, marital status, citizenship, amnesty or status as a covered veteran or any other protected class under federal or state law. QUALIFIED INDIVIDUAL: The term “Qualified Individual” indicates any E mployee with a D isability who, with or without reasonable accommodation, can perform the Essential Functions of a position at Akuna. SMOKING: The term “Smoking” includes using pipes, cigars, cigarettes, or tobacco in any form, including e-cigarettes. START DATE: The term “Start Date” is the month, day and year on which an E mployee commenced work on behalf of Akuna. Start Date is also known as the Employee’s date of hire. TEMPORARY EMPLOYEE: The term “Temporary Employee” refers to an Employee who is expected to leave Akuna within a certain period of time. Temporary Employee includes the Employee classification of Intern. TERMINATION: The term “Termination” indicates the discontinuation of employment with Akuna for any reason. THEFT: The term “Theft” includes the taking and/or removing of personal or Company property with intent to deprive the rightful owner of it (e.g., removal of Akuna property by an Akuna Employee that was entrusted to that Employee as part of their official responsibilities). THREAT OF VIOLENCE: The term “Threat of Violence” includes any behavior that could be interpreted by a reasonable person as an intent to cause, or actual cause of, harm (physical, emotional, financial, or otherwise) to another person or damage to the property of another. UNDUE HARDSHIP: The term “Undue Hardship” refers to accommodation that would be unduly costly, substantial, or disruptive, or that would fundamentally alter the nature or operation of an Akuna department, program, service or activity. 7

Akuna Employee Handbook DIVERSITY & INCLUSION Non-Discrimination/Anti-Harassment Policy and Complaint Procedures Akuna is committed to a work environment in which all individuals are treated with respect and dignity. Everyone has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits unlawful discriminatory practices, including harassment. Therefore, Akuna expects that all relationships among persons in the Office will be professional and free of bias, prejudice, and harassment. It is the policy of Akuna to ensure equal employment opportunities without discrimination or harassment on the basis of Protected Characteristics. Akuna will not tolerate unlawful discrimination or harassment of any kind. Appropriate disciplinary action will be taken against any Employee who violates this policy. Akuna encourages reporting of all perceived incidents of discrimination or harassment. It is the policy of Akuna to promptly and thoroughly investigate such reports. Akuna prohibits retaliation against any individual who reports discrimination or harassment or who participates in an investigation of such reports. Equal Employment Opportunity Akuna promotes equal opportunities in employment and educational programs and activities. Discrimination is prohibited on the basis of Protected Characteristics. Equal employment opportunity includes, but is not limited to, recruitment, hiring, promotion, Termination, compensation, benefits, transfers, training, education, tuition assistance, and social and recreational programs. Equal employment opportunity results when all applicants are treated fairly and consistently at every stage of recruitment and employment. It is the policy of Akuna to ensure equal employment opportunity without discrimination or harassment on the basis of race, color, religion, sex, sexual orientation, gender identity or expression, age, disability, marital status, citizenship, national origin, genetic information, or any other characteristic protected by law. Akuna prohibits any such discrimination or harassment. Definitions of Harassment • Harassment in the Workplace: Harassment against individuals on the basis of their Protected Characteristics is a form of unlawful discrimination and is strictly prohibited under Title VII of the Civil Rights Act of 1964, various federal, state and local laws, and by Akuna’s policies and procedures. Under this policy, harassment may be verbal, written, or physical conduct that denigrates or shows hostility or aversion toward an individual because of their Protected Characteristics or the Protected Characteristics of their relatives, friends or associates, and that a) has the purpose or effect of creating an intimidating, hostile, or offensive work environment; b) has the purpose or effect of unreasonably interfering with an individual's work performance; or c) otherwise adversely affects an individual's employment opportunities. When harassment based on an individual’s Protected Characteristics has the purpose or effect of substantially interfering with an individual’s work performance or creates an intimidating, hostile, or offensive working environment, it rises to the level of unlawful discrimination. 8

Akuna Employee Handbook Harassing conduct includes, but is not limited to, epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes; and written or graphic material that belittles or shows hostility or aversion toward an individual or group and that is placed on walls or elsewhere on the employer's premises or circulated in the Workplace, on Company time or using Company equipment via e-mail, phone (including voice messages), text messages, tweets, blogs, social networking sites or other means. All such activity is strictly prohibited. • Sexual Harassment: Sexual harassment also constitutes discrimination and is illegal under federal, state, and local laws including the laws of the city of Chicago. For the purposes of this policy, sexual harassment is defined in accordance with Section 6-010-020 of the Chicago Human Rights Ordinance as any “(i) unwelcome sexual advances or unwelcome conduct of a sexual nature; (ii) requests for sexual favors or conduct of a sexual nature when (1) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment;, or (2) submission to or rejection of such conduct by an individual is used as the basis for any employment decision affecting the individual;, or (3) such conduct has the purpose or effect of substantially interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment; or (iii) sexual misconduct, which means any behavior of a sexual nature which also involves coercion, abuse of authority, or misuse of an individual’s employment position”. Sexual harassment may include a range of subtle and not-so-subtle behaviors. Depending on the circumstances, these behaviors may include unwanted sexual advances or requests for sexual favors; sexual jokes and innuendo; verbal abuse of a sexual nature; commentary about an individual's body or sexual prowess; leering, whistling, or touching; insulting or obscene comments or gestures; display of sexually suggestive objects or pictures in the Workplace; or other physical, verbal or visual conduct of a sexual nature. Individuals and Conduct Covered This policy and the procedures outlined apply to Employees of Akuna, whether related to conduct engaged in by Employees or with someone not directly connected to Akuna (e.g., an outside vendor or consultant). Conduct prohibited by this policy is unacceptable in the Workplace and in any work-related setting outside the Workplace, such as during business trips, business meetings, and business- sponsored social events. Annual Training All Akuna Employees are required to participate in a minimum of one hour of sexual harassment prevention training annually. Anyone who supervises or manages Employees shall participate in a minimum of two hours of sexual harassment prevention training annually. Additionally, all Employees must participate in one hour of bystander training annually. Complaint Process Akuna’s Human Resources staff is responsible for the administration of this policy and the associated procedures. Individuals who believe they have been the victims of conduct prohibited by this policy or who believe they have witnessed such conduct should discuss their concerns with Human Resources. A Discrimination and Harassment Complaint Form, which may be found on the Company’s internal wiki, may be submitted to Human Resources via hand delivery or via email at [email protected]. Akuna encourages the prompt reporting of complaints or concerns so that rapid and constructive action can be taken before relationships become irreparably strained. Any reported allegations of harassment, discrimination or retaliation will be investigated promptly. The investigation may include individual interviews with the parties involved and, when 9

Akuna Employee Handbook necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge. Duty to Act Any Human Resources staff or Management who becomes aware of information that would lead a reasonable person to believe that harassment has occurred will notify Human Resources within five (5) business days of becoming aware of the information by completing the Discrimination and Harassment Complaint Form. The form can be found on the Company’s internal wiki or by sending an email to [email protected]. Confidentiality Akuna will make every reasonable effort to conduct all proceedings in a manner that will protect the confidentiality of all parties. Parties to the complaint should treat the matter under investigation with discretion and respect for the reputation of all parties involved. Akuna has an obligation to address allegations and suspected instances of harassment when it obtains information that would lead a reasonable person to believe that this policy has been violated. Akuna will take any action it deems appropriate, including informing the alleged harasser of the complaint and pursuing an investigation, even in cases when the complainant is reluctant to proceed. Corrective Measures When it has been determined that harassment has occurred, steps will be taken to ensure that harassment is stopped immediately. Corrective measures, consistent with the severity of the offense, will be imposed. These measures will be consistent with applicable Akuna procedures and may include sanctions. Sanctions imposed on the harasser may include, but are not limited to, a reprimand, suspension, or dismissal from Akuna. Sanctions may also be imposed on any individual with a duty to act (under this policy and associated procedures) who fails to respond to a complaint of sexual harassment in a manner consistent with the provisions of this policy and the associated procedures. The complainant will be informed of the corrective measures taken. Additional Resources for Filing Sexual Harassment Complaints In addition to internal reporting methods, employees have the right to file charges of sexual harassment with the government agencies listed below. All external charges of discrimination in which Akuna is identified as a Respondent, should be immediately directed to Human Resources. Chicago Commission on Human Relations 740 N. Sedgwick, 4th Floor Chicago, IL 60654 312-744-4111 [email protected] U.S. Equal Employment Opportunity Commission (EEOC) Chicago District Office 230 South Dearborn St., Suite 1866 Chicago, Illinois 60604 321-872-9744 https://publicportal.eeoc.gov/Portal/Login.aspx Illinois Department of Human Rights 555 W. Monroe Street, Suite 700 Chicago, IL 60601 312-814-6200 10

Akuna Employee Handbook Americans with Disabilities Act (ADA) It is the policy of Akuna to comply with all federal and state laws concerning the employment of persons with Disabilities and to act in accordance with regulations and guidance issued by the Equal Employment Opportunity Commission (EEOC). Furthermore, it is Akuna’s policy not to discriminate against Qualified Individuals regarding application procedures, hiring, advancement, Termination, compensation, training, or other terms, conditions, or privileges of employment. To assure equal opportunity, the Company will provide Q ualified I ndividuals reasonable accommodations so that the Employee can perform the Essential Functions of a job unless doing so causes a direct threat to the Employee or others in the Workplace and/or if the accommodation creates an Undue Hardship to Akuna. This policy governs all aspects of employment, including selection, job assignment, compensation, discipline, Termination, and access to benefits and training. Contact Human Resources with any questions or requests for accommodation. All Unlawful Retaliation Prohibited Akuna strictly prohibits and does not tolerate unlawful retaliation against any Employee by any Employee. All forms of unlawful retaliation are prohibited, including any form of discipline, reprisal, intimidation, or other form of retaliation for participating in any activity protected by law. Examples of protected activities include: • lodging a good faith internal complaint (written or oral) with Human Resources or Management specifically regarding unlawful discrimination, harassment, or violations of wage and hour law • filing a good faith complaint of unlawful discrimination or harassment with the US Equal Employment Opportunity Commission (EEOC), Illinois Department of Human Rights or in court • participating in Akuna's internal investigation into allegations of discrimination or harassment • filing a good faith complaint with the US Department of Labor (DOL) or in court about (a) wage and hour violations or unfair pay practices or (b) participating in a wage and hour investigation or audit conducted by the DOL or state or local administrative agency • requesting an accommodation under the Americans with Disabilities Act or any other local, state or federal fair employment practices law • requesting or taking leave under the Family and Medical Leave Act or any state or federal leave statute • filing a worker's compensation claim The examples above are illustrative only, not exhaustive. No form of retaliation for any protected activity will be tolerated. Religious Accommodation Akuna respects the religious beliefs and practices of all Employees; the Company will make, on request, accommodation for such observances when a reasonable accommodation is available that does not create an Undue Hardship on the Company’s business. An Employee whose religious beliefs or practices conflict with their job, work schedule or with the Company’s policy on work attire, or with other aspects of employment, and who seeks a religious accommodation must submit a written request for the accommodation to their Manager or Human Resources. H R a n d the M a n a g e r will evaluate the request, considering whether a work conflict exists due to a sincerely held religious belief or practice and whether an accommodation is available that is reasonable and that would not create an Undue Hardship on the Company’s business. An accommodation may be a change in job, using paid leave or leave without pay, allowing an exception to the work attire expectations, or one affecting other aspects of employment. 11

Akuna Employee Handbook EMPLOYMENT Background and Fingerprint Checks All offers of employment are contingent upon satisfactory results from background and fingerprint checks. Due to Akuna and its affiliates’ statuses as regulated entities under various federal securities and futures laws, all Employees will be required to complete background and fingerprint checks. Background checks are conducted in compliance with the Federal Fair Credit Reporting Act, the Americans with Disabilities Act, and state and federal privacy and anti-discrimination laws. Reports are kept confidential. Employment Eligibility Verification Akuna is committed to employing United States citizens and foreign nationals who are l ega l l y authorized towork in the United States. It does not unlawfully discriminate on the basis of citizenship or national origin. In compliance with the Immigration Reform and Control Act of 1986, each new employee, as a condition of employment, must complete the Employment Eligibility Verification Form I-9 and present documentation establishing identity and employment eligibility in accordance with the Form’s guidelines. Former Employees who are rehired must also complete the form if they have not completed an I-9 with Akuna within the past three years, or if their previous I-9 is no longer retained or valid. Employees with questions or those seeking more information on immigration law issues are encouraged to contact Human Resources. Foreign National Employees Akuna may provide immigration counsel to facilitate the immigration process for its foreign national Employees. All Employees that utilize these services are required to sign and acknowledge the terms contained in the Foreign National Employee Handbook which outlines the terms of these resources and Akuna policy. Please reference this document for a more comprehensive detailing of foreign national Employee policies. Performance Evaluation Managers and Employees are strongly encouraged to discuss job performance and goals on an informal, day-to-day basis. A formal performance evaluation is conducted at the end of an Employee's initial period of hire, known as the introductory period. Additional formal performance evaluations are to be conducted on a semi-annual basis to provide both Managers and Employees the opportunity to discuss job tasks, encourage and recognize strengths, identify and correct weaknesses, and consider positive, purposeful approaches for achieving goals. Personnel Records & Data Privacy Employee files are maintained by Human Resources and are confidential. Management and Managers may only have access to personnel file information on a need-to-know basis. Human Resources retains employment-related documents in compliance with federal and state record retention laws. Akuna is required by federal law, under HIPAA, to maintain the privacy and security of employee protected health information. Akuna provides HIPAA Privacy Notices to all new hires upon their first day of employment that details their rights and responsibilities under HIPAA. 12

Akuna Employee Handbook It is important that the Company maintain accurate personnel records at all times. Employees are responsible for notifying Human Resources of any change in name, home address, telephone number, marital status, number of dependents, immigration status, or any other pertinent information. By promptly notifying the Company of such changes, the Employee will avoid compromise of their benefit eligibility, the issuance of W-2 forms, or similar inconveniences. Akuna maintains a comprehensive Employee Personal Data Privacy Policy which is incorporated into this Employee Handbook by specific reference and can be found on the Akuna Wiki here. Employment Verification and Job References All requests for work-related references for both current and former Employees must be directed to Human Resources. No other Employees are authorized to release any written or verbal reference information. Akuna’s policy regarding references for former Employees is to disclose only the dates of employment and associated job title(s). If a former or current Employee authorizes additional disclosures in writing, the Company may provide a prospective employer or financial agency additional information. 13

Akuna Employee Handbook COMPENSATION Paydays All Employees are paid semi-monthly on the 15th and the last day of the month. In the event that a regularly scheduled payday falls on a day off, such as a weekend or holiday, Employees will receive pay on the last business day before the regularly scheduled payday. Wherever legally permissible, employees must have pay directly deposited into bank account(s) in accordance with Company specifications. An itemized statement of wages will be available to Employees when Akuna makes direct deposits each payday. Overtime Nonexempt Employees who exceed 40 hours of work time in a workweek will be paid time and one half their normal rate of pay. Employees who anticipate the need for Overtime to complete the week’s work must notify their Manager in advance and obtain approval before working hours that extend beyond their normal schedule. Timekeeping Nonexempt Employees must complete a time record according to a mutually agreed upon schedule and method, established by their Manager and Akuna. Proof of time worked must be submitted to Human Resources for payroll processing. Falsifying time worked (either by inflating hours worked or failing to record all hours worked) is a serious offense, which is subject to discipline, up to and including immediate termination. The Company prohibits directing an Employee to report less than all hours worked, i.e. to work “off the clock”. Nonexempt Employees who work on holidays or regular days of rest will be paid at their regular rate for all hours worked up to a 40- hour workweek. Administrative Pay Corrections Akuna takes all reasonable steps to ensure that Employees receive the correct amount of pay in each paycheck and that Employees are paid promptly on the scheduled payday. In the unlikely event that there is an error in the amount of pay, the Employee should promptly bring the discrepancy to the attention of Human Resources so that corrections can be made as quickly as possible. Salary Reviews Compensation increases are given by the Company in its complete and sole discretion and in consideration of various factors including, but not limited to, individual and Company performance. Compensation is generally reviewed at the end of each year by Management. Bonus Vesting All employee annual bonuses are subject to the company’s Bonus Vesting Schedule and Bonus Eligibility outlined below. The eligibility and granting of any bonus payment in no way constitutes a promise that you will earn a payment in any given amount (or at all) or modifies the “at will” nature of your employment in any way. All bonus amounts referenced below will be paid per the Company’s standard payroll procedures and will be subject to all applicable taxes and withholdings. Any dates listed in this policy or any schedule provided to you will be impacted by weekends or holidays per the Company’s standard payroll procedures. 14

Akuna Employee Handbook Bonus Vesting Schedule • FIRST VESTING PAYMENT: The first $50,000.00 of any annual bonus plus 50% of any amount above $50,000.00 will be paid on the last pay period in March per the Company’s standard payroll procedures. • SECOND VESTING PAYMENT: The next $25,000.00 of any annual bonus plus 50% of any amount above $25,000.00 of the remaining balance after the First Vesting Payment has been made will be paid on the last pay period in June per the Company’s standard payroll procedures. • FINAL VESTING PAYMENT: Any bonus amount remaining after the First and Second Vesting Payment will be paid in full on the last pay period in September per the Company’s standard payroll procedures. Bonus Eligibility Your eligibility for any bonus is conditioned upon your full-time employment by the Company as of the payment date corresponding to any and all payments provided in the Bonus Vesting Schedule as well as continuing to abide by the terms of your original employment Offer and your Restrictive Covenant and Employee Work Made for Hire Agreement (“RCA”). All Bonus amounts are also subject to proration based on employee’s start date. For the avoidance of doubt, and notwithstanding anything to the contrary, (i) you are not entitled to, do not vest in, and do not earn a payment unless you are employed full-time on the payment date of the payment, and until such payment date; and (ii) if your employment with the Company terminates for Cause (as defined in your RCA) any unvested and/or unpaid payments will be subject to automatic forfeit. In no event will you be eligible for any bonus related payment for any future calendar year(s) following the calendar year of your termination date. However, for the sake of clarity, should your employment be terminated for reasons other than Cause after you have received the First Vesting Payment of a bonus that is subject to a bonus vesting schedule, you remain eligible for any unvested or unpaid scheduled bonus payable within the same calendar year if both conditions below are met: 1) You abide by your RCA, including any Non-Competition Restricted period elected by the company. If a Non-Competition Restricted Period is elected by the Company, any remaining eligible payments will be combined into a single Final Vesting Payment which will coincide with the end of the Non-Competition Restricted Period, as defined in your RCA, and in accordance with the Company’s normal payroll practices. If the Company does not elect a Non-Competition Restricted Period, any remaining eligible payments will continue to be paid per the original vesting schedule. 2) You are employed on the date the First Vesting Payment is made. If you are not employed on the date of the First Vesting Payment per an awarded bonus vesting schedule, any remaining payments may be void at the Company’s sole discretion. 15

Akuna Employee Handbook EMPLOYEE BENEFITS This section describes the benefits provided by the Company and information on Employee eligibility for those benefits. For more information regarding benefit programs offered by Akuna, please refer to the Company’s Summary Plan Descriptions (SPDs) or contact Human Resources. Waiting Period Full-time Employees are eligible to participate in the various insurance programs offered by Akuna on the first of the month following their Start Date. If they begin employment on the first of the month, their benefit eligibility begins that day. Eligible Employees have 31 days from their Start Date to enroll in Akuna’s medical, dental and vision plans. There will be an Open Enrollment period annually. If an Employee declines to participate in these programs during their initial enrollment window, the Employee may request entry into the plan during Open Enrollment or if the employee experiences a Qualifying Life Event. Open Enrollment The Open Enrollment period allows E mployees to add or change their benefit coverages. Applications for medical, dental, and vision insurance, among others, may be submitted during this period. Changes, additions and other elections made during Open Enrollment will take effect on the effective date of the next plan year. Once a change has been made, the Employee cannot change that selection until the next Open Enrollment period, except in the case of a major life status change, outlined below. Qualifying Life Event A Qualifying Life Event, such as certain life status changes – i.e. marriage, birth or adoption of a child, or loss of other coverage – may grant an Employee entry into a plan as long as application for coverage is made within 31 days of the qualifying event. For specific details regarding Qualifying Life Event enrollments, please refer to the SPD or contact HR. Medical, Dental & Vision Insurance The Company offers comprehensive group benefits for medical, dental and vision insurance for Employees and their dependents. These programs are administered by major insurance carriers. Employees are generally expected to pay 0% of healthcare premiums. Based on their benefit elections, Employee contributions are deducted from an Employee’s salary. Please refer to the SPDs for explanations regarding the coverage and limitations of these benefits. Life Insurance Eligible Employees are automatically enrolled in a group term life insurance program, which includes accidental death and dismemberment (AD&D). Enrollees may designate or change the beneficiary for this policy at any time. Akuna pays the premium for this program. Eligible Employees may purchase supplemental life and AD&D insurance for themselves and their dependents at a group rate. Supplemental life insurance is a voluntary benefit. Enrollees should refer to the SPD for eligibility requirements, plan limitations, and additional information. Long-Term Disability Plan (LTD) Eligible Employees are automatically enrolled in a noncontributory long-term disability (LTD) plan. This plan provides 60% of basic monthly earnings to a maximum benefit of $10,000 per month. Eligible Employees are automatically enrolled once they become eligible. LTD begins on day 91 of an accident or illness. Employees should refer to plan documents for more information on when LTD coverage ends. 16

Akuna Employee Handbook Short-Term Disability Plan (STD) Akuna’s short-term disability (STD) plan is a voluntary benefit available to e l i g i b l e E mployees that provides partial pay if they are unable to work due to illness, injury or disability. This plan provides 60% of basic monthly earnings to a maximum benefit of $2,500 per week. STD begins on day 1 of an accident and day 8 of an illness. Employees should refer to plan documents for more information on plan limitations and additional information. 401(k) Akuna has established a 401(k)-retirement plan to provide Employees the option to contribute to their future financial security. Employees may elect to participate either in a traditional 401(k) savings plan or a Roth 401(k) savings plan. To be eligible to join the 401(k) savings plan, Full-time Employees must be 18 years of age or older. Employees may enroll or make changes to their contributions on a monthly basis. Flexible Spending Accounts (FSAs) HealthCare FSA Akuna offers a HealthCare Flexible Spending Account (HC-FSA) that allows Employees to set aside pre-tax dollars from their salary to pay for qualified health-related expenses. Qualified expenses include but are not limited to medical or dental insurance deductibles, copayments, and out-of- pocket costs for medical, dental and vision care. Employees may rollover a specific amount of unused HC-FSA funds into the following plan year, which will be determined by the IRS each year. Rollover funds expire at the end of the following year. The IRS sets annual contribution limits for HC-FSAs. Eligibility to contribute to an HC-FSA is dependent on your medical coverage plan. Health Savings Account Subject to an Employee’s active enrollment in the High Deductible Health Plan (HDHP), eligible Employees are able to elect pre-tax dollars to a Health Savings Account (HSA). Contributions may be used to pay for qualified health-related expenses; there is no expiration date on funds. Dependent Care FSA A Dependent Care Flexible Spending Account (DC-FSA) allows employees to pay for qualified dependent care expenses, such as care for children under the age of 13 or adult daycare expenses for a disabled spouse or IRS tax dependent, with pre-tax dollars. The primary purpose of dependent care expenses must be for \"custodial care\". If married, an employee’s spouse must be working or enrolled in school on a full-time basis to be eligible to participate. Unlike the HC-FSA, if there are unused funds at the end of the plan year, they are forfeited. Commuter Akuna offers a pre-tax commuter program. Employees may enroll or make changes to their orders on a monthly basis. The maximum amount eligible for pre-tax benefits is determined by the IRS and is subject to change. Continuation of Health Coverage Federal law generally requires employers with 20 or more employees to give employees, spouses and dependent children the right to continue group health benefits for limited periods of time under certain circumstances, such as voluntary or involuntary job loss, reduction in hours worked, death, divorce, and other life events. Full-time Employees enrolled in Akuna’s COBRA eligible plans (medical, dental, vision and flexible spending) may continue their health-related coverage for up to 18 months, or up to 36 months in some cases, when their employment terminates for any reason. 17

Akuna Employee Handbook Workers' Compensation Insurance Akuna provides a comprehensive workers' compensation insurance program at no cost to Employees. This program covers any injury or illness sustained in the course of employment that requires medical, surgical, or hospital treatment. Subject to applicable legal requirements, workers' compensation insurance provides benefits after a short waiting period or, if the Employee is hospitalized, immediately. Employees who sustain work-related injuries or illnesses should inform their Manager or Human Resources immediately. No matter how minor an on-the-job injury may appear, it is important that it be reported promptly. This will enable an eligible Employee to qualify for coverage as quickly as possible. Employee Assistance Program Akuna provides an Employee Assistance Program for Employees and their family members at no cost. The program provides support and guidance for matters that range from personal to legal or financial issues. It is a completely confidential telephonic, in-person, and/or web-based counseling program. Education Assistance Akuna supports Employees who wish to continue their education to secure increased responsibility and growth within their professional careers. Akuna has established a reimbursement program for expenses incurred through approved educational institutions and organizations. Eligible Employees may participate in this program as long as the activity is job-related and approved by Management and Human Resources. Eligible Employees must complete a form prior to undertaking the activity in order to be reimbursed. Further policy requirements are outlined on these forms. The form may be found on the internal Company wiki page or by asking HR for a copy. If an Employee voluntarily leaves the Company within twelve (12) months following the date they receive education assistance reimbursement, the Employee will reimburse 100% of all fees and costs incurred by Akuna. Employee Referral Program Akuna actively seeks experienced talent and recognizes the value of Employee referrals. Therefore, Akuna has adopted an Employee Referral Program to encourage greater Employee involvement in identifying talented and qualified individuals for employment with the Company. Referral Bonus Details: • $15,000.00 bonus for Senior level hires • $10,000.00 bonus for Mid-level hires • $5,000.00 bonus for Junior level hires • $1,000.00 bonus for Intern hires Program Rules: • Referrals need to be submitted via Greenhouse (www.greenhouse.io) using the steps outlined below. New employees will receive a log-in invitation from Greenhouse during their first month of employment. • Hiring managers and supervisors who will directly oversee the referred Employee, as well as members of Management, HR and the Recruitment department are not eligible to receive Referral Bonuses. • Only open positions advertised on Akuna’s website (www.akunacapital.com) are eligible for a Referral Bonus. 18

Akuna Employee Handbook • Employees must respect any active non-solicit agreements or other restrictive covenants they may have with their previous employers. • Candidates already in Akuna’s applicant tracking system are not eligible for the Referral Program; former Akuna Employees are not eligible to be referred through this process. • Full Time Employee Referrals: Both the referrer and referred Employee need to be successfully employed with Akuna for 12 consecutive months from the referred Employee’s Start Date in order for the referrer to claim the Referral Bonus. • Intern Referrals: Both the referrer and referred Intern need to be successfully employed with Akuna on the final payroll date of the internship in order for the referrer to claim the Referral Bonus. Payment: • Full Time Employee Referrals: o Referral Bonuses will be payable after 12 months of successful, continuous employment by the referred Employee. o Referral Bonuses will be based on the level (Senior, Mid-level, Junior) of the referred Employee at the time of payment. o Therefore, if the referral is promoted within the first 12 months following their Start Date, the Referral Bonus applicable to the referred Employee’s level at the time of payment will be awarded. • Intern Referrals: o Referral Bonuses will be payable on the final payroll of the internship of the referred Intern. • Payments will not be made to those who do not follow the Steps to Submit a Referral, outlined below. Steps to Submit a Referral: 1. Log into Greenhouse, hover over the “+” icon in the upper right-hand corner of the main dashboard and select Add a Referral from the dropdown menu. 2. It is not possible to refer a prospect; a job must be chosen for the referral. If the referral is a good fit for several distinct roles, choose one then write a note to the Recruiter outlining the other roles. The Recruiter will be able to assess the information provided to ensure the referred candidate is placed in the appropriate job role pipeline(s). 3. When submitting a referral, be sure to complete the fields under Details to provide background as to the relationship with the referred candidate. The Recruitment department will use their best judgment in determining the validity of the relationship between the Employee and candidate. The referrer must meaningfully affirm the referral’s personal or professional acumen. 4. Once a referral is submitted, the referred candidate’s status and interview stage may be tracked by scrolling down Greenhouse’s main dashboard to the My Referrals panel. 19

Akuna Employee Handbook EMPLOYEE TRAVEL & REIMBURSEMENTS Travel Policy Akuna maintains a Travel Policy document that outlines provisions for all Company-related travel. It is the policy of Akuna to reimburse employees for reasonable and necessary expenses incurred in connection with approved travel or other business on behalf of Akuna during the period they are employed by the Company. Subject to the guidelines and procedures set forth in Akuna’s Travel Policy, available on the internal wiki, Employees must obtain advance written approval from their direct Manager and department head, must maintain receipts or other appropriate substantiating documentation for all travel and other business expenses incurred, and follow all other practices and procedures outlined therein. Expense Reimbursement Akuna recognizes that situations may arise where an Employee may have to pay for business- related expenses out-of-pocket. Should any Employee pay for business-related expenses with personal income, said Employee may submit a report for reimbursement. Employee expense reimbursement reports must be approved by the Employee’s Manager and include supporting documentation (receipts, purchase orders, etc.). Completed and approved reimbursement reports will be processed by the Finance department through Expensify (www.expensify.com), and the reimbursable amount will be added to the Employee’s next applicable paycheck. Instructions and procedure on submitting reimbursements can be found on Akuna’s internal wiki page. Employees should obtain proper approval for reimbursements prior to incurring expenses. 20

Akuna Employee Handbook TIME OFF AND LEAVES OF ABSENCE Employees must enter their leave requests via Akuna’s Human Resources Information System (HRIS) for approval by their M a n a g e r . Vacation Leave Paid vacation time is available to eligible Employees in order to provide opportunities for rest, relaxation, and personal pursuits. Full-time Employees are eligible to earn and use vacation time as described in their Offer letter. Employees begin to accrue vacation leave on a monthly basis starting on their Start Date. Any accrual that coincides with a partial month of employment will be prorated. A maximum of ten (10) unused, accrued vacation days may be carried over into the next calendar year. Days carried over must be used in the year following and cannot be carried over thereafter. Paid vacation time can be used in minimum increments of one-half day. Vacation leave should be requested and approved at least two weeks’ in advance. Requests will be reviewed based on several factors, including business needs and staffing requirements. The Company reserves the right to direct Employees to take vacation in line with business requirements. Vacation leave is paid based on the Employee's base salary rate at the time of vacation. It does not include Overtime or any special forms of compensation such as incentives or bonuses. Upon Termination of employment, Employees will be paid for any unused, accrued vacation days that have been earned through the last day of work. Sick Leave Akuna provides paid sick leave benefits to all eligible Employees for periods of temporary absence due to illnesses, injuries, or any other medically related absence (such as doctor’s appointments). An eligible Employee may use sick leave benefits for an absence due to their own illness or injury, or that of an Immediate Family Member. Sick leave benefits are intended to provide income protection in the event of the employee or Immediate Family Member’s health condition; need for diagnosis, care, treatment or preventative care; or reasons related to domestic/sexual violence or stalking. For employees in states that allow for use of sick leave under other circumstances not mentioned here, Akuna will abide by state laws. Sick leave benefits will not be paid to Employees upon Termination of employment and, since sick leave benefits are not limited in number, they are not eligible to be carried over into the following year. In order to encourage a healthy work environment, provide flexibility to Employees to care for themselves and Immediate Family Members, and meet all US state minimum guidelines related to paid sick leave Akuna has a flexible sick leave policy that allows for unlimited days of paid sick leave, within certain guidelines. Although the Company provides for unlimited days of paid sick leave, there are certain criteria and guidelines that must be met- please see below for guidance as it relates to this policy: • Employees who are unable to report to work due to illness, injury or another qualifying reason are required to notify their Manager before the scheduled start of their workday when circumstances permit. The Manager and HR must also be contacted on each additional day of absence by the Employee. • Employees must enter the time taken for sick leave via the Company’s standard time off tracking system. 21

Akuna Employee Handbook • A doctor’s certificate is required for three (3) or more consecutive sick days and Akuna reserves the right to request a doctor’s certificate for any period of flexible sick leave requested. • No single absence for sick leave will be paid for more than five (5) consecutive days; at that point the Company will work with the Employee to initiate unpaid leave and/or FMLA, short term disability or long term disability insurance benefits, if eligible, dependent upon the Employee circumstances. • Flexible paid sick leave may not be used as a means to extend other types of leave, such as FMLA, Parental, Short or Long Term Disability, Vacation, leaves required by state law, and other extended leave situations. If a pattern of such usage arises, Akuna reserves the right to request a doctor’s certificate. • Paid sick leave benefits will be calculated based on the Employee’s base salary rate at the time of absence and will not include any special forms of compensation, such as incentives or bonuses. Akuna expects all Employees will utilize this benefit as needed in a responsible and honest manner. Any abuse of this policy will result in disciplinary action up to and including termination. Holidays Generally, Akuna observes the holiday schedule of supported exchanges and local public holidays. These generally include: • New Year’s Day • Martin Luther King, Jr. Day • Presidents’ Day • Good Friday • Memorial Day • Juneteenth • Independence Day • Labor Day • Thanksgiving Day • Christmas Day Akuna will be partially staffed for public holidays in which some exchanges may still be open. If an Employee takes leave on an early market close day, it is considered a full day of leave. If an Employee has a question regarding Akuna’s Holiday policy, they are encouraged to speak to Human Resources. Parental Leave Akuna provides paid, parental leaves of absence for the birth of an Employee’s own child or the placement of a child with the E mployee in connection with adoption or foster care. Parental leave is not charged against any other accrued leave. Paid leave under this policy shall run concurrently with Family and Medical Leave Act leave (see “Family and Medical Leave”). Full-time E mployees are eligible for parental leave only after having completed t w e l v e ( 12) months of successful, continuous employment. Eligible E mployees should make requests for parental leave at least thirty (30) days in advance when circumstances permit. When leave ends, the Employee will be reinstated to the same or similar position, unless either the job ceases to exist because of legitimate business reasons or because means of preserving the job would substantially undermine Akuna’s ability to operate safely and efficiently. If the same position is not available, the Employee may be offered a comparable position in terms of pay, location, duties, and promotional opportunities. 22

Akuna Employee Handbook Subject to the terms, conditions, and limitations of the applicable plans, Akuna will continue to provide health insurance benefits for the full period of the approved parental leave. The Employee will remain responsible for paying their portion of the benefits. This parental leave policy is conditional upon the Employee completing a continuous period of twelve months’ service upon their return to work at the end of parental leave. If the employment terminates for any reason on or before the one-year Anniversary Date of the Employee’s return, the salary paid out during the time of leave will be repayable to Akuna on demand. Primary Carer’s Leave Akuna defines a Primary Carer as the parent of a newborn or newly placed child who will solely be providing the primary care during the typical work hours for the duration of the Primary Carer’s Leave. Primary Carer’s leave will consist of up to twelve (12) weeks paid leave immediately following the birth, adoption, or foster placement of a child. After completing twenty-four (24) months of continuous employment, leave will increase to up to sixteen (16) weeks paid leave immediately following the birth, adoption, or foster placement of a child and allow for an additional 4 weeks of unpaid, job-protected leave (in addition to the rights granted by FMLA, outlined below). Primary carer’s leave is to be taken within twelve (12) months following the event and may be taken consecutively or as otherwise agreed upon with Management. The Employee may take up to two (2) weeks of allotted leave prior to the birth, adoption, or foster placement of a child. To be eligible for Primary Carer’s Leave, employees must meet the criteria outlined in the Primary Carer’s Leave Policy and sign and return a Certificate of Care Attestation stating that the Employee will be the primary carer for their child and that there is no other person claiming to be the Primary Carer for the newborn or newly placed child. If at any time during Primary Carer’s Leave, the Employee’s status changes and they are no longer the Primary Carer, they are to immediately notify HR and will no longer be eligible for Primary Carer’s Leave. Secondary Carer’s Leave Akuna defines a Secondary Carer as the parent of a newborn or newly placed child who is not solely providing the primary care during the typical work hours for the duration of the Primary Carer’s Leave. Secondary Carer’s leave will consist of ten (10) business days paid leave immediately following the birth, adoption, or foster placement of a child. After completing twenty-four (24) months of continuous employment, leave will consist of fifteen (15) business days paid leave immediately following the birth, adoption, or foster placement of a child. Secondary Carer’s leave is to be taken within six months following the event and may be taken consecutively or as otherwise agreed upon with Management. Coordination with Other Policies All Paid Parental Leave taken under this policy will run concurrently with leave under the FMLA; thus any leave taken under this policy that falls under the definition of circumstances qualifying for leave due to the birth or placement of a child due to adoption or foster care, the leave will be toward the twelve (12) weeks available FMLA leave per a twelve (12) month period. All other requirements and provisions under FMLA and applicable state mandated Paid Family Leave Laws apply. Please refer to the Family and Medical Leave Policy for further guidance on the FMLA. If a Company holiday occurs while the employee is on Paid Parental Leave such day will be charged to holiday pay; however, such holiday pay will not extend the total paid leave entitlement. Vacation accruals will be suspended while the employee utilizes Paid Parental Leave. 23

Akuna Employee Handbook Requests for Paid Parental Leave Employees will provide his/her Manager and HR with notice of the request for leave at least thirty (30) days prior to the proposed date of the leave (or if the leave was not foreseeable, as soon as possible). The employee must complete and return the necessary documentation as required by the HR department to substantiate the request. As in the case with all company policies, Akuna has the exclusive right to interpret this policy. Bereavement Leave We know that loss is incredibly difficult, and we understand that employees undergoing difficult circumstances may need to take leave to attend to necessary obligations and commitments and to be with family. All Full-time Employees are eligible to receive up to three (3) days, per annum, of paid bereavement leave followed by an additional seven (7) days of unpaid bereavement leave to take time off due to the (i) death of an Immediate Family Member or (ii) the miscarriage, unsuccessful round of intrauterine insemination or of an assisted reproductive technology procedure, failed adoption, failed surrogacy agreement, diagnosis that negatively impacts pregnancy or fertility, or stillbirth endured by the Employee or their spouse/domestic partner. Additional requests for bereavement leave in the same calendar year will consist of up to ten (10) days of unpaid bereavement leave. Employees should notify their manager immediately when bereavement leave is needed. Bereavement pay is calculated based on the base salary rate at the time of absence and will not include any special forms of compensation, such as incentives or bonuses. Employees may, with their Managers’ approval, use any available paid leave for additional time off as necessary. Political Participation and Voting Leave Akuna considers the Workplace unsuitable for political action and campaign activities. Employees are prohibited from engaging in political activities that interfere with or disrupt Akuna's business. Accordingly, the following practices are forbidden when Employees are on Akuna’s premises during the workday: • soliciting monetary political contributions from any Employee • soliciting any contribution of services or resources for political purposes from any Employee • taking any personnel action or making any promise or threat of action with regard to any Employee because that person has given or withheld a political contribution or service • engaging in solicitation or politically motivated behavior that is harassing or discriminatory • using Akuna’s name, letterhead, or facilities in connection with any political communications Employees are typically able to find time to vote either before or after their regular work schedule. If Employees are unable to vote in an election during their non-working hours, Akuna will grant up to two to four hours of paid leave to vote, in compliance with state laws. Akuna reserves the right to specify the hours during which Employees may be absent for voting purposes. Employees should request time off to vote from their Manager at least two working days prior to Election Day. Advance notice is required to schedule the leave appropriately and to allocate 24

Akuna Employee Handbook sufficient resources to accommodate the leave. Voting should occur outside of market trading hours unless approved by Management ahead of time. Jury Duty Leave Akuna supports E mployees fulfilling their civic responsibilities by serving jury duty when required. Employees may take as many days as necessary to fulfill these civic responsibilities. Full-time Employees may request up to ten (10) business days of paid jury duty leave over any 2- year period. Jury duty pay will be calculated on the Employee's base salary rate. Employees must report to work on any normal workday in which they are not required to report for jury duty or are released early. If an Employee is required to serve jury duty beyond the period of paid jury duty leave, they may use any available paid time off (for example, vacation leave) or may request an unpaid jury duty leave of absence. Employees must show the jury duty summons to their Manager and Human Resources as soon as possible so that the Manager may make arrangements to accommodate their absence. Akuna will continue to provide health insurance benefits for the full term of the jury duty absence. Additionally, vacation leave will continue to accrue during jury duty leave. Volunteer Leave Akuna recognizes the responsibility as a corporate citizen to give back to the greater community. In order to support volunteer activities that enhance and serve the community, Full-time Employees receive two (2) days paid volunteer leave per annum. Time may be used in increments of 0.25 days (2 hours), and the balance is reset at the beginning of each calendar year. Volunteer leave requests must include the name and/or activity of the charitable organization included within the ‘Notes’ section of the request. As with all leave requests, approval is up to the discretion of your Manager or Management. Employees must submit, and be approved for, the volunteer activity at least two weeks in advance of the activity and must provide a letter confirming their volunteer efforts from the organization upon their return. Family and Medical Leave Akuna will comply with the Family and Medical Leave Act (FMLA) of 1993. Akuna posts the mandatory FMLA Notice and, upon hire, provides all new Employees with notices required by the U.S. Department of Labor (DOL) on Employee Rights and Responsibilities under FMLA. The function of this policy is to provide Employees with a general description of their FMLA rights. In the event of any conflict between this policy and the applicable law, Employees will be afforded all rights required by law. Under FMLA, Akuna will grant up to 12 weeks (or up to 26 weeks of military caregiver leave to care for a covered service member with a serious illness or injury) of unpaid, job-protected leave. Employees must have been employed by Akuna for at least 12 months and have worked at least 1,250 hours during the preceding 12-month period to qualify for FMLA leave. Only 12 weeks of FMLA leave may be taken within a 12-month period. This 12-month period is calculated on a calendar year basis, January 1 – December 31. Eligible Employees may take FMLA for one or more of the following reasons: • the birth of a child or placement of a child with the Employee for adoption or foster care; 25

Akuna Employee Handbook • to care for a spouse, child, or parent who has a serious health condition; • for a serious health condition that makes the Employee unable to perform the Essential Functions of their job; or • for any qualifying exigency arising out of the fact that the Employee’s spouse, child, or parent is a military member on covered active duty. Employees must request leave 30 days in advance. If an E mployee is unable to foresee the need for leave, the Employee must provide notice as soon as possible under the circumstances. All E mployees requesting FMLA leave must provide verbal or written notice of the need for leave to their Manager and Human Resources. No benefit accruals, such as vacation leave, will continue during the approved FMLA leave period. Generally, upon return from FMLA leave, an Employee will be restored to their original job or to an equivalent job with equivalent pay, benefits, and other terms and conditions of employment. Military Leave Akuna is committed to protecting the job rights of Employees on military leave. In accordance with federal and state law, it is the Company’s policy that no Employee or prospective employee will be subjected to any form of discrimination on the basis of the individual’s membership or obligation to perform service for any of the Uniformed Services of the United States. Specifically, no person will be denied employment, re-employment, promotion, or other benefit of employment on the basis of such membership. Employees may take unpaid military leave, as needed, to enable them to fulfill their obligations as service members. Such military obligations include leaves of absence taken by members of the Uniformed Services, including Reservists and National Guard members, for training, periods of active military service and funeral honors duty, as well as time spent being examined to determine fitness to perform such service. Employees requesting leave for military duty should contact Human Resources to request leave as soon as they are aware of the need for leave. State Paid Family Leave & State Disability Leave Employees working from states in which Paid Family Leave and/or State Disability Leave is mandated by the state will additionally be eligible for these types of leave. State PFL and DBL notices can be found on the Akuna Wiki. 26

Akuna Employee Handbook WORKPLACE EXPECTATIONS Work Attire All Employees of Akuna are expected to present a clean, well-groomed and professional appearance. No clothing worn shall display indecent, obscene, sexually explicit, pornographic, or illegal images or messages; be discriminatory or harassing; be offensive or abusive in that its context is or could be considered to be a personal attack, rude, sexist, racist, or generally offensive and distasteful; or defamatory towards Akuna in a manner that could adversely impact the image of Akuna to others. Attendance and Punctuality Management will advise Employees of their individual work schedules. Staffing needs and operational demands may necessitate variations in start and end times, as well as variations in the total hours that may be scheduled each day and week. Trading and IT staff are not to be absent from the Workplace during market trading hours without the approval of their Manager, unless on a meal or rest break. Vacation leave must be scheduled with one’s Manager in advance. Sick leave may be used in the case of an accident or sudden illness without prior scheduling. Patterns of absenteeism or tardiness may result in discipline, even if the Employee has not yet exhausted available paid time off. Not reporting to work and not calling to report the absence is a no-call/no-show and is a serious matter. The first instance of a no-call/no-show will result in a written warning. The second offense may result in Termination of employment with no additional disciplinary steps. A no-call/no-show lasting three days may be considered job abandonment and may be deemed an Employee’s voluntary resignation of employment. Meal Periods It is Akuna’s policy to comply with state and federal laws regarding meals and breaks. All Employees who work more than 7 hours per day are allowed a 30-minute meal period, per state-specific guidelines. Working from Home Akuna may allow Employees to telecommute (work remotely or work from home [“WFH”]). This policy applies to Employees permitted to telecommute on a regular basis and does not apply to requests for reasonable accommodation or occasional WFH arrangements. Employees requesting to telecommute as a reasonable accommodation should contact Human Resources for requests for reasonable accommodation. Eligibility All telecommuting arrangements must be approved in advance by Akuna Management and HR. Permission to telecommute is at Akuna's sole discretion and can be withdrawn at any time. Requests to Telecommute Akuna will consider requests to telecommute from Employees on a case-by-case basis. Akuna also reserves the right to direct Employees to WFH should the need arise (i.e. due to safety concerns). A request to telecommute should be: • in writing • submitted to the Employee’s direct Manager and Department Head, copying HR. 27

Akuna Employee Handbook If the request involves telecommuting from a state other than the employee’s home state (as determined by their home address on file), the employee will need to fill out and submit a “Working From a Different State Approval Form.” HR can provide a copy of this form upon request. Upon receipt of a request, Akuna may contact the Employee for additional information and ask for explanation as to why their job responsibilities are suitable for telecommuting and how the Employee plans to stay in contact with their Manager. Akuna will also perform an analysis to determine whether the request can be supported weighing regulatory, tax, and/or legal considerations. When a request to telecommute is approved, the Employee will be required to abide by the terms outlined in this policy. Authorization to telecommute may be withdrawn at any time in Akuna’s sole discretion upon notice to Employee. Akuna May Approve Requests to Telecommute for a Trial Period Akuna may approve a request to telecommute for a trial period. At the conclusion of the trial period, the telecommuting arrangement will be reviewed by Akuna and may be withdrawn or approved for a longer period of time. Akuna's Policies Remain in Effect An Employee permitted to telecommute (“WFH Employee”) must: 1. Continue to abide by Akuna's Employee Handbook and all other Akuna policies and procedures. Failure to follow Akuna policies may result in discipline, including termination of the WFH arrangement or termination of employment. WFH Employees are prohibited from engaging in unauthorized work during work hours. 2. Perform all duties and responsibilities, including, but not limited to, complying with the hours of work (rest/meal breaks, overtime, and other wage and hour requirements) and frequency of communication outlined in the Employee Handbook and indicated by WFH Employee’s Manager. 3. Maintain a safe environment in which to work- including, but not limited to, appropriate work stations with proper ergonomic support. Telecommuting and Technology Remote or VPN access to the Akuna network is provided to WFH Employees. Protecting Akuna’s confidential information and intellectual property is a condition of employment. It is the responsibility of each WFH Employee to safeguard Akuna’s proprietary and confidential information and resources. As a condition to the authorization to receive telecommuting privileges and as evidenced by execution of the Employee Handbook, each WFH Employee agrees to abide by Akuna’s VPN and Remote Access Policy, summarized below: 1. only use the remote access to the Akuna network exclusively for Akuna business-related activities; 2. not store Akuna proprietary and/or confidential information, including, but not limited to, trade information, information on trading strategies, financial information, and source code on personal systems or devices; 3. not access or disseminate confidential or proprietary information unless such access or dissemination is required by WFH Employee’s job and authorized by Management; 4. ensure that telecommuting does not inappropriately expose or compromise Akuna’s confidential and proprietary information in WFH Employee’s remote working environment; 5. protect and not share their password or remote access with any third party; 28

Akuna Employee Handbook 6. immediately notify Management if WFH Employee has any reason to believe Akuna proprietary or confidential information has been made available to unauthorized individuals (including unauthorized Akuna Employees); 7. have no expectation of privacy in the use of Akuna’s systems/technology and understands that the use of all Akuna systems/technology including remote access is monitored for Akuna business purposes including regulatory compliance and information technology best practices; and 8. promptly report to work at Akuna's offices following a request by WFH Employee’s Manager or any member of Akuna Management. Equipment and Technology Support WFH Employee will provide all furniture and equipment needed to telecommute. Akuna will not be responsible for any damage to WFH Employee’s furniture or equipment. Any equipment supplied by Akuna is to be used solely by WFH Employee and for business purposes only and shall remain the sole property of Akuna. Akuna will be responsible for repairing any Akuna equipment. However, WFH Employee is responsible for any damage caused by WFH Employee or third parties that are not Akuna Employees and safeguarding all Akuna property from theft. Akuna's IT support is available to assist WFH Employees. Expenses Additional expenses incurred by telecommuting will be considered on a case-by-case basis with WFH Employee’s Manager and Akuna Management. WFH Employees should discuss telecommuting expenses with and obtain approval from their Manager and Akuna Management prior to submitting a reimbursement via Expensify. Akuna will not reimburse any telecommuting expenses without advance written approval. Workers' Compensation Workers' Compensation does not apply to injuries to any third parties or members of WFH Employee's family on the WFH Employee's premises. In the event of a job-related injury, WFH Employees are required to report the incident to the WFH Employee’s Manager as soon as possible. Tax Implications It will be the employee’s responsibility to determine any income tax implications under IRS, state and local government laws, and/or restrictions while working remotely. Akuna will not provide tax guidance, nor will Akuna assume any additional tax liabilities. Employees are encouraged to consult with a qualified tax professional to discuss income tax implications. Administration of This Policy The HR Department is responsible for the administration of this policy. If Employees have any questions regarding this policy or if any Employee has questions about telecommuting that are not addressed in this policy, please contact HR. At Will Employment Akuna is an “at-will” employer, meaning that employment relationships between Akuna at its Employees may be terminated at any time by either Akuna or the Employee, with or without notice or cause. Telecommuting arrangements are not contracts or promises of employment. Nothing in a telecommuting arrangement guarantees employment 29

Akuna Employee Handbook Safety Akuna provides a clean, hazard-free, healthy, and safe environment in which to work and makes every effort to comply with all relevant federal, state, and local occupational health and safety laws, including the federal Occupational Safety and Health Act. Employees have a duty to comply with the safety rules of the Company and are expected to take an active part in maintaining this hazard-free environment. Employees should observe and adhere to all posted safety rules. Each workspace should be kept neat, clean, and orderly. Employees are required to report any accidents or injuries – including any breaches of safety – and to promptly report any unsafe equipment, working conditions, processes, or procedures to their Manager or HR. Workplace Violence Prevention Akuna is committed to preventing Workplace violence and to maintaining a safe work environment. Akuna has adopted the following guidelines to deal with intimidation, harassment, or other Threats of Violence that may occur during business hours or on its premises. All Employees should be treated with courtesy and respect at all times. Employees are expected to refrain from fighting, \"horseplay,\" or other conduct that may be dangerous to themselves or others. While on the premises of Akuna and/or while conducting business on behalf of Akuna, E mployees are prohibited from possessing, brandishing, carrying, displaying or using weapons, firearms, and any other dangerous or hazardous devices or substances. Conduct that threatens, intimidates, or coerces another Employee, consultant, vendor, or member of the public at any time, including off-duty periods, will not be tolerated. This prohibition includes all acts of harassment, including harassment that is based on an individual's Protected Characteristic. Prohibited conduct includes, but is not limited to, injuring another person physically; engaging in behavior that creates a reasonable fear of injury in another person; engaging in behavior that subjects another individual to extreme emotional distress; damaging property intentionally; and threatening to injure an individual or damage property. All T hreats of Violence, both direct and indirect, should be reported as soon as reasonably possible to a Manager and HR or any other member of Management. This includes Threats of Violence by Employees, as well as Threats of Violence by consultants, vendors, solicitors, or other members of the public in the scope of an Employee’s employment. When reporting a Threat of Violence, Employees should be as specific and detailed as possible. All suspicious individuals or activities should also be reported as soon as possible to Human Resources. Akuna will promptly and thoroughly investigate all reports of Threats of Violence and suspicious individuals or activities. The identity of the individual making a report will be protected as much as is practical. Anyone determined to be responsible for Threats of Violence or other conduct that is in violation of these guidelines will be subject to prompt disciplinary action up to and including termination of employment. Akuna encourages Employees to bring their disputes or differences with other Employees to the attention of their Managers and Human Resources before the situation escalates into potential violence. Akuna is eager to assist in the resolution of Employee disputes and will not discipline Employees for raising such concerns, unless the Employee knowingly, or with reckless disregard for the truth, makes false accusations. 30

Akuna Employee Handbook Drug and Alcohol Use To promote Akuna’s endeavor to provide a safe, healthy and productive work environment, Employees are required to report to work in appropriate mental and physical conditions to perform their jobs in a satisfactory manner. For these reasons, Akuna is committed to the elimination of drug and alcohol abuse in the workplace. Akuna expressly prohibits the following activities any time Employees are either (1) on duty or conducting Akuna business (either on or away from Akuna's premises), or (2) on Akuna's premises (whether or not the Employee is working): • the use, abuse, or being under the influence of illegal drugs, or other impairing substances • the possession, sale, purchase, transfer, or transit of any illegal or unauthorized drug, including prescription medication that is not prescribed to the Employee or drug- related paraphernalia • the illegal use or abuse of prescription drugs Nothing in this policy is meant to prohibit the appropriate use of over-the-counter medication or other medication that is legally prescribed under both federal and state law, to the extent that it does not impair an Employee's job performance or safety or the safety of others. Employees who take over-the-counter medication or other medication that is legally prescribed under both federal and state law as treatment should inform their Manager before reporting to work while under the influence of that medication if they believe the medication will impair their job performance, safety, or the safety of others or if they believe they need a reasonable accommodation. Due to Akuna’s status as a financially regulated company, an Employee is required to notify Human Resources within five (5) calendar days if they are convicted of a criminal drug violation. Employees who fail to make such notification could face disciplinary action at work up to and including termination. If any Employee appears to be under the influence of medication, illicit drugs, or alcohol while at work, the Company reserves the right to make a determination that the Employee may be dismissed for the remainder of the day. Violations of this policy may lead to disciplinary action, up to and including immediate Termination of employment or requiring the Employee’s satisfactory participation in a drug abuse assistance or rehabilitation program approved for such purposes by a federal, state or local health, law enforcement or other appropriate agency. Such violations may also have legal consequences. Alcohol Use at Akuna Social Events: Only Employees of legal drinking age may consume alcohol at Akuna social events where alcohol is available. Attendance at an Akuna social event, whether sponsored by the Company or not, is completely at the discretion of the individual and is entirely voluntary. Any participation by an Employee to partake in the consumption of alcohol is solely the choice of that individual and Akuna always encourages responsible and NOT excessive consumption of alcohol at Akuna social events. In doing so, that Employee assumes all liabilities stemming from such participation including, but not limited to, injuries, accidents, and criminal implications to the fullest extent legally possible. Employees are expected always to behave appropriately at social events, whether sponsored by the Company or not. Employees are reminded that they are the face of Akuna and any inappropriate behavior jeopardizes the professional reputation of Akuna. Examples of inappropriate behavior include, but are not limited to, making derogatory, offensive or 31

Akuna Employee Handbook discriminatory comments or jokes, excessive inebriation, and sexual, unlawful, or unwelcome harassment towards co-workers or guests of Employees. A violation of any of the above is subject to disciplinary action, up to and including immediate termination of employment. Smoking/Vaping In order to provide a safe and comfortable working environment for all E mployees, smoking is strictly prohibited at all times inside any Akuna Workplace. Business Ethics and Conduct The successful business operation and reputation of Akuna is built upon the principles of fair treatment and ethical conduct of its Employees. It is the responsibility of every Akuna Employee to act in the highest ethical manner possible. Akuna will comply with all applicable laws and regulations and expects Management and Employees to refrain from any illegal, dishonest, or unethical conduct. In general, the use of good judgment based on high ethical principles will guide E mployees with respect to lines of acceptable conduct. If a situation arises where it is difficult to determine the proper course of action, the matter should be discussed immediately with the Employee’s Manager and Human Resources prior to taking any action. Compliance with this policy of business ethics and conduct is the responsibility of every Akuna Employee. Disregarding or failing to comply with this standard of business ethics and conduct could lead to disciplinary action, up to and including termination of employment. Romantic Relationships Akuna recognizes that Employees may sometimes wish to enter into a consensual dating relationship where both individuals are working for the Company. Although Akuna generally discourages such relationships, which can complicate the Workplace environment, it respects Employees’ right to make such personal choices. Nonetheless, if Employees choose to continue such a relationship, Akuna requires that they handle the situation in a mature and professional manner. Akuna expects all Employees to exercise good judgment about any relationship. The Company will not tolerate any favoritism toward an Employee because of a personal relationship with another Employee. The Company will also not tolerate any harassment and/or retaliation against any Employee because of the existence, desire for, or ending of a dating relationship. If any Employee experiences any work-related problem as a result of a dating relationship, he or she should immediately bring it to the attention of Human Resources. The Company does prohibit any dating relationship between Employees where it would cause a potential conflict of interest, such as a romantic or sexual relationship between a manager and their subordinate. If such a relationship should develop, the Manager has the responsibility and mandatory obligation to promptly disclose the existence of the relationship to Human Resources. Employees in violation of this policy are subject to disciplinary action, up to and including termination. Outside Employment Akuna recognizes that some Employees may want to engage in outside employment and other activities, including second jobs, consulting engagements, self-employment, and volunteer activities. To protect Akuna's confidential information and trade secrets and to comply with various federal securities and futures regulations and other business interests while employees are 32

Akuna Employee Handbook engaged in outside employment and volunteer activities, Akuna has adopted the following rules and guidelines regarding outside employment and volunteer activities by Employees: • Before beginning outside employment or volunteer activities, Employees must complete the Outside Business Activities Approval Form, send this form to the Compliance department, and receive advance written approval for the outside employment from the Chief Compliance Officer (CCO). • Outside employment and volunteer activities must not interfere with the Employee's work performance or work schedule. • Employees may not use Akuna's property, facilities, equipment, supplies, IT systems (such as computers, networks, email, telephones, or voicemail), time, trademarks, brand, or reputation in connection with any outside employment or volunteer activities. • Employees engaging in outside employment or volunteer activities must comply with Akuna's policies including policies on Conflicts of Interest, Confidential Information, and relevant Written Supervisory Procedures. If you are considering outside employment or volunteer activities but are not sure if it complies with the rules and guidelines in this policy, you must seek guidance from Compliance, Legal and HR, who will help you determine whether the outside employment complies with this policy. Any Employee, regardless of position or title, who the Company determines has violated this policy will be subject to discipline, up to and including termination of employment. Confidential Information Confidential Information includes, but is not limited to, all information not generally known in spoken, printed, electronic or any other form or medium, which was obtained from Akuna, or which was learned, discovered, developed, conceived, originated, or prepared by an Employee in the scope and course of employment, relating directly or indirectly to: (i) trade secrets and other non-public information relating to the Company or its affiliates, which may include, but not be limited to source code of trading applications, trading or investment strategies, methodologies and results; trading or investment systems; investment or investment instrument positions of the Company or its affiliates; risk management models; revenue models; quantitative or other strategies and methodologies, procedures and techniques; business plans and strategies, recruiting practices and materials, pricing and other financial information; lists of investors, clients, vendors and suppliers of the Company or its affiliates; any confidential information of any such investors, clients, vendors or suppliers; the source code and any non-public information or data comprising or related to the Work; and other proprietary technologies and processes and other proprietary information used by the Company or its affiliates in connection with their respective businesses and/or which the Company or any of its affiliates is obligated to any third party to maintain as confidential, and (ii) any information concerning the Company’s or its affiliates’ investments or trading performance, including the profits and losses therefrom, return on investment and other performance or “track record” information. Confidential Information also includes other information that is marked or otherwise identified as confidential or proprietary, or information that would otherwise appear to a reasonable person to be confidential or proprietary in the context and circumstances in which the information is known or used. Confidential Information does not include terms and conditions of employment. Protocols for Maintaining Confidentiality Akuna limits disclosure of its Confidential Information to: • employees with a need to know in order to perform their jobs • third parties requiring the information for a legitimate business purpose, including: o prospective suppliers, vendors, brokers, and counterparties o individuals and companies contemplating a joint venture or other business relationship with Akuna 33

Akuna Employee Handbook Employees must treat all Confidential Information as strictly confidential, both during and after employment with Akuna ends. To maintain the confidentiality of Akuna's Confidential Information, all Employees must follow these protocols: • Employees shall not access or use any Confidential Information to which Akuna has not provided the Employee access or authorization to use. • Employees shall not directly or indirectly disclose, publish, communicate, or make available Confidential Information to any entity or person that does not have a need or the authority to know and use the Confidential Information, except as required for the Employee to perform authorized job duties or otherwise permitted by this policy. • If an Employee's authorized job duties require sharing Confidential Information with a third party, the Employee must not do so until Akuna and the third party enter into a confidential confidentiality agreement and the Employee receives advance consent from Management. • Employees shall not discuss Confidential Information in any public place where it may be overheard. • Visitors to Akuna's Offices must be accompanied by an Employee at all times or while in locations where Confidential Information might become known. • In the event of an inadvertent disclosure of Confidential Information, Employees must immediately inform Management so that measures can be taken to minimize damage to Akuna. • Departing Employees must return any Confidential Information in their possession to Akuna upon Termination of employment. This policy is not intended to restrict Employees' communications or actions that are protected or required by state or federal law, including discussing terms and conditions of employment, exercising protected rights under Section 7 of the National Labor Relations Act or otherwise disclosing information as permitted or required by law. This policy does not prohibit or restrict any Employee from initiating communications with, responding to any inquiry from, or providing testimony before the Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), any other self-regulatory organization, or any other state or federal regulatory authority regarding a possible securities law violation. Any Employee who is unsure whether information should be kept confidential should always check with their Manager before disclosing the information or taking any other action. All Employees are required to comply with the terms of this policy. Any Employee who violates this policy may be subject to disciplinary action, up to and including termination of employment. Disclosure of Trade Secrets Under the Defend Trade Secrets Act Notwithstanding any other provision of this policy: • As provided for by the Economic Espionage Act of 1996, as amended by the Defend Trade Secrets Act of 2016, an Employee will not be held criminally or civilly liable under any federal or state trade secret law for any disclosure of a trade secret that is made: o in confidence to a federal, state, or local government official, either directly or indirectly, or to an attorney, and solely for the purpose of reporting or investigating a suspected violation of law; or o in a complaint or other document that is filed under seal in a lawsuit or other proceeding. • If an Employee files a lawsuit for retaliation by Akuna for reporting a suspected violation of law, the Employee may disclose Akuna's trade secrets to the Employee's attorney and use the trade secret information in the court proceeding if the Employee: o files any document containing the trade secret under seal; and o does not disclose the trade secret, except pursuant to court order. 34

Akuna Employee Handbook Disclaimer of Restrictions on Employees' Rights This policy is not intended to restrict communications or actions protected or required by state or federal law. Procurement All purchases must be approved by Management and must comply with this Procurement Policy. All Akuna purchases shall require approvals from the following: • Business Operations Management • The recipient’s respective department head Business Operations Management may require additional approvals depending on the risk and dollar amount of any individual purchase. In the event that a purchase requires or is subject to a contract, Business Operations Management and Legal will represent Akuna in such negotiations and will expect the Employee, or someone on the Employee’s team to introduce Business Operations Management prior to any pricing and/or terms related discussion. The Employee or someone on the Employee’s team shall provide necessary support to Business Operations Management as the subject matter expert. All invoices should be directed to [email protected]. Billing will coordinate with Employee to review all invoices and confirm that all charges are proper, consistent with negotiated terms, and approved. IT Resources and Communications Systems Policy Akuna encourages the use of computers, internet and electronic media because they are an integral part of the services Akuna provides as a proprietary trading company and because they can make communication more efficient and effective. Akuna's computers, networks, communications systems, and other Information Technology (IT) resources are intended for business purposes only (except for limited personal use as described below). To protect Akuna and its Employees, it is the Company's policy to restrict the use of all IT resources and communications systems as described below. Each user is responsible for using these resources and systems in a productive, ethical, and lawful manner. The Company's policies prohibiting harassment apply to the use of the Company's IT resources and communications systems. No one may use any communication or computer system in a manner that may be construed by others as harassing or offensive based on Protected Characteristics. The use of Akuna's IT resources and communications systems by an Employee shall signify their understanding of an agreement to the terms and conditions of this policy, as a condition of employment. Administration of this Policy IT Management is responsible for the administration of this policy. If you have any questions regarding this policy, please contact the Human Resources department. Security, Access, and Passwords Security of Akuna's IT resources and communication systems is the responsibility of the IT department, including approval and control of access to systems and suspension or termination of access in cases of misuse or when a user is no longer an Employee or otherwise is ineligible to use the systems. 35

Akuna Employee Handbook It is the responsibility of each Employee to adhere to IT security guidelines including but not limited to the creation, format, and scheduled changes of passwords. All usernames, pass codes, passwords, and information used or stored on the Company's computers, networks, and systems are the property of Akuna. No Employee may use a username, pass code, password, or method of encryption that has not been issued to that Employee or authorized in advance by the Company. No Employee shall share usernames, pass codes, or passwords with any other person. An Employee shall immediately inform the IT department if they know or suspects that any username, pass code, or password has been improperly shared or used, or if Akuna’s IT security has been violated in any way. Resources and Systems Covered by This Policy This policy governs all IT resources and communications systems owned by or available at Akuna, and all use of such resources and systems when accessed using an Employee's own resources, including but not limited to: • email systems and accounts • internet and intranet access • telephones and voicemail systems, including wired and mobile phones, and smartphones • printers, photocopiers, and scanners • fax machines and e-fax systems • all other associated computer, network, and communications systems, hardware, peripherals, and software, including network key fobs and other devices • closed-circuit television (CCTV) and all other physical security systems and devices, including access key cards and fobs No Expectation of Privacy All contents of the Company's IT resources and communications systems are the property of the Company. Therefore, Employees should have no expectation of privacy whatsoever in any message, file, data, document, facsimile, telephone conversation, social media post, conversation, or any other kind or form of information or communication transmitted to, received, or printed from, or stored or recorded on the Company's electronic information and communications systems. You are expressly advised that, to prevent against misuse, Akuna reserves the right to monitor, intercept, and review, without further notice, every Employee's activities using the Company's IT resources and communication systems, including but not limited to email (both outgoing and incoming), telephone conversations and voice mail recordings, instant messages, and internet activities. You consent to such monitoring by your acknowledgement of this policy and your use of such resources and systems. This might include, without limitation, the monitoring, intercepting, accessing, recording, disclosing, inspecting, reviewing, retrieving, and printing of transactions, messages, communications, postings, logins, recordings, and other uses of the systems as well as keystroke capturing and other network monitoring technologies. Akuna specifically reserves the right for authorized personnel to access, retrieve, read, and delete any communication that is created on, received through, or sent in the email system to assure compliance with all Company policies. To achieve compliance, Akuna reserves the right to employ monitoring software and, pursuant to regulatory requirements, will on a periodic basis check on the use and content of email through specific search criteria without notice to Employees. The Company may also store copies of such data and communications for a period of time after they are created and may delete such copies from time to time without notice. 36

Akuna Employee Handbook Employees are not to use the Company's IT resources and communications systems for any matter desired to be kept private or confidential from the Company. Network Systems Akuna maintains integrated computer and data communication networks to facilitate all aspects of its business. An Employee may never sign on to any network equipment using the password or username of another Employee. No Employees should access, attempt to access, alter, or delete any network document except in furtherance of authorized Akuna business. Downloading and Installing Software/Website Agreements Emails and downloads from the internet are prime sources of viruses and other malicious software. Therefore, no Employee may download or install any software or shareware to their hard drive that is not expressly authorized or approved by the IT department. In addition, Employees may not accept the terms or conditions of website agreements. Confidentiality and Proprietary Rights Akuna's Confidential Information and intellectual property (including trade secrets) are extremely valuable to Akuna. Employees must treat them accordingly and avoid jeopardizing them through business or personal use of electronic communication systems, including email, text messaging, internet access, social media, and telephone conversations and voice mail. Disclosure of the Company's Confidential Information to anyone outside Akuna and use of the Company's intellectual property is subject to the Company's Confidentiality Information policy. Do not use Akuna's name, brand names, logos, taglines, slogans, or other trademarks without written permission from the Compliance department. This policy also prohibits use of the Company's IT resources and communications systems in any manner that would infringe on or violate the proprietary rights of third parties. Electronic communications systems provide easy access to vast amounts of information, including material that is protected by copyright, trademark, patent, and/or trade secret law. Employees should not knowingly use or distribute any such material downloaded from the internet or received by email without the prior written permission of the Akuna Legal department. Email and Text Messaging Akuna provides certain Employees with access to email and/or text messaging systems for use in connection with performing their job duties. Akuna seeks to provide stable and secure email and text messaging systems (including SMS and internet-based instant messaging) with rapid, consistent delivery times that promote communication for business purposes without incurring unnecessary costs or generating messages that are unproductive for the recipient. Many of the policies described below governing use of the Company's email and text messaging systems are aimed at reducing the overall volume of messages flowing through and stored on the network, reducing the size of individual messages, and making the system more efficient and secure. Spam Unfortunately, users of email and text messaging will occasionally receive unsolicited commercial or bulk messages (spam) which, aside from being a nuisance and a drain on IT resources, might be a means to spread computer viruses and other malicious software. Avoid opening unsolicited messages and report any suspicious messages to IT. Do not reply to, forward, or engage with the message in any way, even if it states that you can request to be removed from its distribution list. If delivery persists, contact IT who will block any incoming messages from that address. Electronic Media Etiquette Proper business etiquette should be maintained when communicating via email, Slack, and text messaging. When writing business communications, be as clear and concise as possible. Sarcasm, poor language, inappropriate comments, attempts at humor, and so on, should be avoided. 37

Akuna Employee Handbook Email, Slack and text communications should resemble typical professional and respectful business correspondence. Electronic media cannot be used for knowingly requesting, transmitting, retrieving, uploading, downloading, distributing or storing any communication that is or might be considered to: • be indecent, obscene, sexually explicit, pornographic or illegal • be discriminatory or harassing • be offensive or abusive in that its context is or could be considered to be a personal attack, rude, sexist, racist, or generally offensive and distasteful • affect or have the potential to affect the performance of, damage, or overload the Company’s system, network, and/or communications in any way or introduce any form of a computer virus onto the Company’s resources • be defamatory or incur liability on the part of Akuna or adversely impact the image of the Company • be a breach of any compliance policy or regulatory requirement issued by an exchange that Akuna participates on • be contrary to software license agreements or in violation of copyright laws ( such as illegally duplicating software, installing software for use on multiple machines) and/or related documentation of computer software that was purchased by Akuna for business purposes Please limit the use of your Company email to business-related communication. Internet and Social Media Akuna provides internet access to Employees for use in connection with performing their job duties. The following outlines Akuna's expectations regarding internet and social media access and use by Employees. Personal Use of the Internet Employees may occasionally desire to access the internet (including social media) for personal activities at the Office or by means of the Company's computers, networks, and other IT resources and communications systems. The Company authorizes such occasional use so long as it does not involve unprofessional or inappropriate content and does not interfere with Employees’ responsibilities or productivity. Using the internet (including social media) to access pornographic, sexually explicit, or \"hate\" sites, or any other website that might violate law or Akuna policies against harassment and discrimination is never permitted. Akuna expressly reserves the right, without further notice, to monitor and review records of all websites visited by Employees, any postings or downloads Employees make while visiting websites, and during other internet activities using the Company's IT resources and communications systems; Employees consent to such monitoring and review by acknowledgment of this policy and use of internet access provided by the Company. Use of Social Media The internet provides unique opportunities to participate in discussion groups and activities, and to share information on particular topics using a wide variety of social media. Akuna respects the right of any Employee to use social media. However, to protect the Company's interests and ensure Employees focus on their job duties, Employees must adhere to the general internet use guidelines and rules in this policy, and the following related specifically to social media use: • Anything an Employee posts or sends using social media, even outside the Workplace, could reflect on Akuna, in addition to the Employee, and might create legal liabilities for Akuna or damage its business or reputation. 38

Akuna Employee Handbook • To avoid the risk of the Company incurring legal liability or business damage as a result of an Employee’s use of social media, even outside of the Workplace, be advised that the Employee is solely responsible for all content they post or send. Employees should avoid identifying themselves as an Akuna Employee, using their Akuna email address or mentioning Akuna unless they receive written instructions or permission from Management to do so • If the Employee’s job duties require them to speak on behalf of the Company in a social media environment, they must be authorized by the Compliance to act as Akuna's representative. • Ensure that none of your social media participation violates any contractual obligations you have to Akuna or Akuna policies. • Do not post or send anything through social media that co-workers or business partners, suppliers, vendors, or other stakeholders of Akuna or its affiliates could reasonably find offensive, including ethnic slurs, sexist comments, discriminatory comments, or obscenity. • Employees are bound not to disparage Akuna. • Any conduct that under the law is impermissible if expressed through any other public forum is also impermissible if expressed through social media. • It is the responsibility of every Employee to notify their Manager or the Human Resources department immediately if they see content in a social media environment that reflects poorly on Akuna or its stakeholders. Inappropriate Use of Company IT Resources and Communications Systems Employees are never permitted to use the Company's IT resources and communications systems, including email, text messaging, internet access, social media, telephones, and voicemail, for any inappropriate or unlawful purpose. This includes but is not limited to: • misrepresentation as another individual or company • sending, posting, recording, or encouraging receipt of messages or information that may be offensive because of their sexual, racist, or religious content • revealing proprietary or Confidential Information, including official Akuna information, or intellectual property without authorization • conducting or soliciting illegal activities • representing personal opinions as that of Akuna’s • interfering with the performance of Akuna’s business activities • for any other purpose that violates Akuna policies or practices Electronic Records Akuna is required by law to preserve all electronic communication sent and received in accordance with regulatory requirements. Therefore, Akuna’s procedures and policies for record retention apply to electronic communications, just as they do to other written communications. Additionally, electronic communications that have been deleted from an individual Employee’s computer will remain in Akuna’s electronic communication archive and can be traced and retrieved. Therefore, all persons having a part in creating or forwarding any offensive, harassing, or otherwise unlawful electronic communications can be identified. Electronic communications in both hard copy and electronic form can be admissible in a court of law. Discipline Employees who violate any provision of these policies are subject to discipline, up to and including termination of employment. Information Technology & Security Policies Akuna Employees must adhere to all Information Technology & Security Policies including: • High Privilege Access • IT Acceptable Use Policy 39

Akuna Employee Handbook • Passwords Policy In addition to the acknowledgement of this handbook, all employees will participate in regular security and phishing training administered by the Information Security team. Information Technology & Security Policies can be found on the Akuna Wiki here. Communications to the Press In your role as an Akuna employee, you may be contacted by members of the Press for a statement related to your experience in the financial industry. In addition, you should also be mindful that any request for an interview or information related to your experience in the financial industry can easily be misinterpreted or considered as a statement from Akuna. Any related press requests should be forwarded to the Legal department at [email protected] for review before you respond. Compliance Policies Akuna Employees must adhere to all Compliance Policies regarding Personal Trading, Permissible and Prohibited Trading Activities, Review of Employee and Registered Persons Transactions, Virtual Currencies, Compliance Training and Trader License Requirements. In addition to the acknowledgement of this handbook, all employees will participate in annual compliance training and will execute acknowledgements of all compliance policies. A full list of Akuna Compliance policies, procedures and attestations can be found on the Akuna Wiki at https://wiki/display/AC/Compliance. 40

Akuna Employee Handbook SEPARATION OF EMPLOYMENT Advance Notice Employees who resign or retire are requested to give as much advance notice to Akuna as possible. A minimum notice of two weeks is recommended. This notice may be given orally; however, the Employee is responsible for providing their Manager and/or Human Resources with a written letter of resignation or retirement. The resignation shall be final unless both the Manager and the Employee agree that the resignation may be withdrawn prior to the effective date of resignation or retirement. Termination Unless an Employee has an individual employment agreement to the contrary, every Employee of the Company has the status of “employee at will”, meaning the Company and Employee each retain the right to terminate employment at any time, with or without notice. Employees who fail to report to work or fail to contact their Manager for three (3) consecutive workdays shall be considered to have abandoned the job without notice, effective at the end of third day. Termination Procedures Employees will be paid for time worked and any unused, accrued vacation time as part of their last paycheck. Used, unaccrued vacation time is not considered wages earned and will not be included in the Termination payment. Unused sick time, however, is not paid upon Termination. When employment is terminated for any reason, the Company will pay all wages on the date required by law or, if not specified by law, the regular payday for the pay period during which the Termination occurred. This procedure will be followed less any outstanding issues that may preclude the Company from executing final wages on the Termination date including, but not limited to, outstanding documents that must be agreed to before final payments are issued. Return of Akuna Property Upon the termination of Employee’s relationship with the Company for any reason, and/or upon the Company’s request, the Employee shall return Akuna property in accordance with the stipulations outlined in their Restrictive Covenant and Employee Work Made for Hire Agreement (RCA) or as otherwise directed by Management. 41

Akuna Employee Handbook Last Updated October 2022 EMPLOYEE HANDBOOK RECEIPT ACKNOWLEDGEMENT I acknowledge I have received Akuna Capital LLC’s (“Akuna” or the “Company”) Employee Handbook (“Handbook”) which is a guide to the Company’s basic policies and procedures. I acknowledge that it is my responsibility to read and understand the matters set forth in this document and the policies incorporated herein, including the Information Technology & Security Policies and the Employee Personal Data Privacy Policy. I further acknowledge that I should consult my Manager or Human Resources regarding any questions not answered in the Handbook or the incorporated policies. I understand that no statement contained in this Handbook creates any guarantee of continued employment or creates any obligation, contractual or otherwise, on the part of Akuna. I understand that my employment with Akuna remains at all times at will, not governed by any oral or written contract, and terminable by either the Company or the E mployee at any time, with or without cause and with or without notice. I will only rely on any promises, statements, or representations to the contrary if they are in writing and signed by an authorized member of Management. I understand that nothing contained in this Handbook may be construed as creating a promise of future benefits or a binding employment contract with the Company for benefits or for any other purpose. I understand and acknowledge that Akuna has the sole and exclusive right, without prior notice, to delete, modify, and interpret the policies, practices, procedures, benefit plans, and other institutional programs within the limits and requirements imposed by law. I understand that, unless otherwise expressly indicated, any new policy or Handbook supersedes any previously issued verbal or written policies, practices, procedures, or Handbooks. Employee Signature: __________________________________________ Date: _________________ Printed Name: ________________________________________________ 42