China Commercial Intelligence Brief Published by Ascendancy Advisors Limited Effective date: 1 June 2026

1. Acceptance of Terms

By subscribing to, accessing, or reading the China Commercial Intelligence Brief (the “Publication”), you agree to be bound by these Terms of Service (”Terms”). If you do not agree to these Terms, you should not subscribe to or access the Publication. These Terms constitute a binding agreement between you and Ascendancy Advisors Limited (Company No. 15179861), a company registered in England and Wales (”we”, “us”, “our”).

2. Nature of the Publication

The China Commercial Intelligence Brief publishes open-source analytical intelligence on China's commercial risk, export controls, counterparty due diligence, and related strategic topics. All content is produced for general professional information purposes only.

The Publication is not a financial adviser, investment adviser, legal adviser, or regulated information service. Nothing published in the China Commercial Intelligence Brief constitutes:

• Investment advice or a recommendation to buy, sell, or hold any financial instrument

• Legal advice on any matter, including export control compliance, sanctions, or corporate law

• Regulated financial analysis under MiFID II, FCA rules, or any equivalent regulatory framework

• A substitute for independent professional advice on any transaction or compliance matter

Readers are solely responsible for their own investment, legal, and compliance decisions. Ascendancy Advisors Limited accepts no liability for any decision made in reliance on content published in this Publication.

3. Subscription and Access

3.1 Free subscriptions grant access to published free-tier content as designated by the Publication at its sole discretion.

3.2 Paid subscriptions grant access to premium content for the duration of the active subscription period. Access terminates upon cancellation or non-renewal.

3.3 Subscription fees are charged in advance and are non-refundable except where required by applicable consumer protection law in your jurisdiction.

3.4 We reserve the right to modify subscription tiers, pricing, and content access at any time with reasonable notice to existing subscribers.

4. Licence and Intellectual Property

4.1 All content published in the China Commercial Intelligence Brief — including but not limited to articles, reports, analytical frameworks, tables, and graphics — is the exclusive intellectual property of Ascendancy Advisors Limited and is protected by copyright under the laws of England and Wales and applicable international conventions.

4.2 Your subscription grants you a personal, non-transferable, non-exclusive licence to read and retain copies of content for your own professional use only.

4.3 You may not, without prior written consent from Ascendancy Advisors Limited:

• Reproduce, republish, or redistribute any content in whole or in part

• Share, forward, or distribute content to persons who are not active subscribers

• Use content for commercial purposes, including resale, licensing, or incorporation into third-party products

• Remove, alter, or obscure any copyright notice, watermark, or attribution

4.4 Brief quotation of content for professional commentary, academic citation, or media reporting is permitted provided that clear attribution to the China Commercial Intelligence Brief and Ascendancy Advisors Limited is given and a link to the original publication is included where possible.

5. Subscriber Obligations

5.1 You agree to provide accurate information when subscribing and to maintain the accuracy of that information.

5.2 Your subscription credentials are personal and non-transferable. You may not share access with third parties.

5.3 You agree not to use the Publication’s content in any manner that is unlawful, misleading, or contrary to applicable sanctions, export control, or financial crime regulations.

5.4 You agree not to attempt to circumvent any access controls, watermarking systems, or document identification mechanisms applied to Publication content.

6. Personalised Document Identification

6.1 Premium content distributed as PDF documents may contain personalised watermarks, embedded subscriber identifiers, and unique document tracking codes linked to your subscription.

6.2 These identifiers are used solely for the purpose of identifying unauthorised distribution of licensed content.

6.3 You acknowledge that the presence of these identifiers does not constitute surveillance of your personal use of the content within the scope of your licence.

7. Disclaimers and Limitation of Liability

7.1 All content is published in good faith and based on open-source information available at the time of writing. We make no representation or warranty as to the accuracy, completeness, or currency of any content.

7.2 To the maximum extent permitted by applicable law, Ascendancy Advisors Limited shall not be liable for any direct, indirect, incidental, consequential, or special damages arising from your reliance on Publication content, including but not limited to financial losses, missed opportunities, or compliance failures.

7.3 Our total aggregate liability to any subscriber shall not exceed the total subscription fees paid by that subscriber in the twelve months preceding the event giving rise to the claim.

8. Privacy

8.1 We collect and process subscriber personal data (name, email address, payment information) for the purposes of operating the Publication and delivering content.

8.2 We do not sell subscriber personal data to third parties.

8.3 Subscriber data is processed in accordance with our Privacy Policy, available at ascendancyadvisors.substack.com, and in compliance with applicable data protection law, including the UK GDPR and the Data Protection Act 2018.

9. Amendments

We reserve the right to amend these Terms at any time. Material changes will be notified to active subscribers by email with a minimum of 14 days’ notice. Continued subscription following notification of amended Terms constitutes acceptance of the revised Terms.

10. Governing Law and Jurisdiction

These Terms are governed by the laws of England and Wales. Any dispute arising from or in connection with these Terms shall be subject to the exclusive jurisdiction of the courts of England and Wales.

11. Contact

Ascendancy Advisors Limited AAL Suite Ra01, 195–197 Wood Street, London E17 3NU Company No. 15179861 info@theaalgroup.com