Security Policy

Information Security Policy Statement for Point Nine

At Point Nine, we are committed to safeguarding the confidentiality, integrity, and availability of all information assets under our control, ensuring they are protected against threats, whether internal or external, deliberate or accidental. As a provider of comprehensive, high-quality, and reliable trade and transaction reporting services, we recognize that the protection of sensitive information is critical to maintaining the trust of our clients, complying with regulatory requirements, and sustaining our reputation in the marketplace.

The scope of POINT NINE DATA TRUST LTD is: Providing a comprehensive, high quality and reliable TRADE AND TRANSACTION REPORTING SERVICES

To achieve this, Point Nine has established an Information Security Management System (ISMS) aligned with ISO 27001:2022 standards and relevant regulatory requirements, including but not limited to GDPR, MiFID II, and EMIR. The company is committed to the following objectives:

• Ensure Confidentiality: Protect all sensitive information from unauthorized access and disclosure, ensuring it is shared only with authorized individuals and entities.
• Maintain Integrity: Safeguard the accuracy and completeness of all information and data assets, preventing unauthorized alterations or destruction.
• Guarantee Availability: Ensure that information and associated assets are available to authorized users when needed, supporting uninterrupted business operations and compliance with service level agreements.
• Comply with Legal and Regulatory Requirements: Adhere to all applicable laws, regulations, and contractual obligations relevant to our information security practices and business activities.
• Continually Improve the ISMS: Regularly review and enhance our ISMS by identifying, assessing, and mitigating risks, and addressing evolving security threats and vulnerabilities.
• Promote a Security-Aware Culture: Foster a culture of information security awareness and responsibility among all employees and contractors through regular training, awareness programs, and adherence to established security policies and procedures.
• Respond to Security Incidents: Implement effective incident detection, response, and recovery processes to minimize the impact of information security breaches and ensure timely resolution.

Responsibility and Enforcement

All employees, contractors, and third parties with access to Point Nine’s information assets are required to understand and comply with this Information Security Policy. The management team is responsible for establishing and maintaining the ISMS, providing the necessary resources, and demonstrating leadership and commitment to information security.

Non-compliance wicontract andy may result in disciplinary action, including termination of employment or contract, and may be subject to legal penalties as applicable.

Nestoras Nestorides Chief Operating Officer Point Nine Data Trust Limited

Date: 01/06/2024