Governance · Benchmark Administration

Statement of Compliance with the IOSCO Principles for Financial Benchmarks

How The Pulse Rolex Index is governed. A voluntary statement of how the Administrator designs, operates and oversees the Index against the international standard for financial benchmarks (IOSCO FR07/13).

Benchmark

The Pulse Rolex Index

Standard

IOSCO FR07/13

Version

1.0 · July 2026

Basis

Voluntary

Management statement Adherence summary Governance Quality of the benchmark Quality of the methodology Accountability Proportionality

1 · Introduction

The Administrator and the Benchmark

1.1 The Administrator. The Pulse.fun (the "Administrator"), a legal entity currently in formation, is, or on incorporation will be, the sole administrator of The Pulse Rolex Index (the "Index" or the "Benchmark"), responsible for its definition, methodology, data sourcing, calculation, quality assurance, publication and governance.

1.2 The Benchmark. The Pulse Rolex Index is a rules-based, value-weighted price index measuring the market value of the luxury-watch secondary (resale) market. It is expressed on a base of 100 set on 20 May 2026: a level above 100 indicates the market has risen since the base date, and below 100 that it has fallen. Full detail sits in the Methodology & Rulebook.

1.3 Voluntary basis and status. This statement is published voluntarily. As at its date, the Index is pre-launch and is not used as a reference for financial instruments traded on a regulated venue. The Index is not authorised, registered or recognised under any benchmark regulation. The Administrator keeps under review whether any authorisation applies and notes that, given the Benchmark's scale, formal authorisation may not be required.

1.4 Proportionality. The Principles are applied proportionately: The Pulse Rolex Index is a novel, pre-launch, low-usage benchmark administered by a small organisation, and the framework is scaled accordingly and strengthened as usage grows.

1.5 Structure. This statement follows the four groupings of the Principles: Governance (1–5), Quality of the Benchmark (6–10), Quality of the Methodology (11–15) and Accountability (16–19). It is reviewed at least annually and on material change.

2 · Management's statement

Statement of compliance

As the founding team of The Pulse.fun (the "Administrator", a legal entity currently in formation), we are responsible for establishing the governance arrangements, processes and controls necessary to administer The Pulse Rolex Index (the "Benchmark") in accordance with the IOSCO Principles for Financial Benchmarks (Final Report FR07/13, July 2013) (the "Principles").

This statement is made voluntarily and applies the Principles in a manner proportionate to the size of, and the risks posed by, the Benchmark and the Administrator.

As at the date of this statement the Benchmark is pre-launch and its governance framework is being established. This document describes the framework the Administrator has designed and is implementing, rather than a retrospective attestation of a live benchmark. The Administrator intends to issue its first full Statement of Adherence for the period 1 January 2026 to 31 December 2026 once the Administrator is incorporated, the Oversight Committee is appointed, and the Benchmark is in live production.

On that basis, we consider that the Benchmark has been designed to meet, in all material respects, the Principles applicable to it, subject to: Principle 14 (Submitter Code of Conduct), not applicable, as the Benchmark relies on no submitters or contributor panel; and Principle 17 (Audits), applied proportionately, with adherence reviewed internally initially and independent external assurance planned as usage and resources grow.

For and on behalf of The Pulse.fun (in formation)
The Founding Team · Effective July 2026 · Version 1.0

3 · Statement of adherence

The nineteen principles, at a glance

As the Benchmark is pre-launch, statuses reflect the designed framework pending go-live. A full attestation of live adherence will follow once the framework is operational.

#	Principle	Group	Status
01	Overall responsibility of the administrator	Governance	By design
02	Oversight of third parties	Governance	By design
03	Conflicts of interest	Governance	By design
04	Control framework	Governance	Proportionate
05	Internal oversight	Governance	Being established
06	Benchmark design	Quality of the benchmark	By design
07	Data sufficiency	Quality of the benchmark	By design
08	Hierarchy of data inputs	Quality of the benchmark	By design
09	Transparency of determinations	Quality of the benchmark	By design
10	Periodic review	Quality of the benchmark	By design
11	Content of the methodology	Quality of the methodology	By design
12	Changes to the methodology	Quality of the methodology	By design
13	Transparency of changes	Quality of the methodology	By design
14	Submitter code of conduct	Quality of the methodology	Not applicable
15	Internal controls over data collection	Quality of the methodology	Proportionate
16	Complaints procedures	Accountability	By design
17	Audits	Accountability	Proportionate
18	Audit trails	Accountability	By design
19	Cooperation with regulators	Accountability	By design

01–05

Governance

Overall responsibility of the administrator

The Administrator should retain primary responsibility for all aspects of the benchmark determination process.

The Pulse.fun is, or on incorporation will be, the sole Administrator of the Index and retains primary responsibility for its definition, methodology, data sourcing, calculation, quality control, publication and governance, including for any activity delegated to a third party. Accountabilities are set out in the Governance Charter and a roles matrix.Proportionate note: as a small administrator, one senior individual may hold several operational roles; this is mitigated by the independent oversight function (P5) and the conflicts controls (P3).

Oversight of third parties

The Administrator should have clearly defined written arrangements with, and monitor, third parties.

The Administrator's material third parties are its market-data sources and any calculation or publication provider it may engage. Each relationship is governed by a written agreement setting out data-quality obligations, permitted use, audit and inspection rights, service levels and escalation, with ongoing monitoring and exception reporting to the Oversight Committee.

Conflicts of interest

The Administrator should identify, disclose, manage and avoid conflicts, including those arising from ownership or control.

The Administrator maintains a Conflicts of Interest Policy. The principal conflict is that the Administrator, its affiliates or founders may derive commercial benefit from products that reference the Index. This is managed by: (i) information and functional separation between index determination and any commercial or product function; (ii) a rules-based methodology that removes discretion over the Index level from anyone with a commercial interest in it; (iii) a prohibition on determination personnel holding positions whose value depends on the Index, plus personal-account-dealing rules; (iv) Oversight Committee review of the conflicts register; and (v) public disclosure of material conflicts.

Control framework

The Administrator should implement and disclose an appropriate control framework, including whistleblowing.

The Administrator operates, proportionately, a documented control framework covering data validation and outlier handling, calculation verification (four-eyes sign-off), access controls and segregation of duties, change management, business continuity and record-keeping, together with a confidential whistleblowing channel.Proportionate note: certain controls are performed manually but are documented and evidenced.

Internal oversight

The Administrator should establish an independent oversight function, which may be a committee.

The Administrator is establishing the Oversight Committee, an independent function that will review and challenge the methodology, data sources and sufficiency, material discretionary decisions, methodology changes, control exceptions, complaints and conflicts. It will include at least one member independent of the Administrator's commercial functions and will meet at least semi-annually, with minutes maintained. Members are not yet appointed; the Committee will be constituted before the Index enters live production.

06–10

Quality of the benchmark

Benchmark design

The Benchmark should reflect the economic realities of the interest it measures and minimise distortion.

The Pulse Rolex Index is designed to measure the market value of the luxury-watch resale market. It tracks a transparent, rules-based basket of liquid reference models selected for trading frequency and data availability, with defined weighting and rebalancing, expressed as a value-weighted index on a base of 100. Design choices (universe, weighting, outlier treatment, frequency) are documented in the Methodology and chosen to represent genuine market conditions while limiting the influence of illiquid or anomalous observations.

Data sufficiency

Benchmark data should be sufficient to represent the interest measured, anchored in an observable market.

The Index is calculated from observable secondary-market data, completed sale transactions and executable asking prices, reflecting the competitive forces of supply and demand in the resale market. The Methodology defines minimum data-sufficiency thresholds and the treatment applied where a constituent temporarily fails them.

Hierarchy of data inputs

The Administrator should establish and publish a clear hierarchy of inputs and the use of expert judgment.

The Methodology publishes a data-input hierarchy: (1) verified completed sale prices; (2) live executable asking prices where completed-sale data is insufficient; (3) recent comparable-reference or model-family data; and (4) documented, governed expert judgment only where higher tiers are unavailable. Any expert judgment is rules-bounded, logged with its rationale, subject to four-eyes review, and reported to the Oversight Committee.

Transparency of benchmark determinations

Users should be able to understand how a determination was made.

The Administrator publishes the Index on thepulse.fun on a daily schedule, together with the Methodology and explanatory notes sufficient for users to understand how each value is derived, the data types used, and any material application of the input hierarchy or expert judgment. Non-standard determinations are accompanied by an explanatory note.

P10

Periodic review

The Administrator should periodically review whether the Benchmark remains appropriate.

The Administrator reviews the Index's design and methodology at least annually, and upon defined trigger events (material changes in market structure, liquidity or data availability), to confirm the Index continues to reliably measure the intended market. Reviews are documented and considered by the Oversight Committee.

11–15

Quality of the methodology

P11

Content of the methodology

The Administrator should document and publish the methodology in sufficient detail.

The Administrator publishes a complete Methodology & Rulebook covering: the interest measured; the constituent universe and eligibility criteria; data sources and the input hierarchy; the index calculation formula; rebalancing; the publication calendar; data-sufficiency thresholds; error and restatement handling; and the change and consultation process, detailed enough for a knowledgeable user to understand and substantially reproduce the Index.

P12

Changes to the methodology

The Administrator should have clear published procedures for methodology changes, including consultation.

The Methodology Change & Consultation Policy sets out how changes are proposed, assessed for materiality, consulted upon with users where material, approved with Oversight Committee sign-off, and implemented with adequate notice. Records of changes and their rationale are retained.

P13

Transparency of changes

Material changes, and the outcomes of any consultation, should be publicly disclosed with notice.

The Administrator publicly announces material methodology changes on thepulse.fun in advance of implementation, with the rationale and, where a consultation was held, a summary of feedback and the Administrator's response. Non-material and administrative changes are logged and disclosed as appropriate.

P14

Submitter code of conduct · Not applicable

Where a Benchmark relies on submissions from Submitters, the Administrator should maintain a Submitter Code of Conduct.

Not applicable. The Index does not rely on submissions from Submitters or a contributor panel. It is calculated from observable secondary-market data (completed transactions and executable asking prices) sourced from marketplaces and dealers, and involves no voluntary submissions of price data by contributing firms.Forward-looking note: should the Administrator later introduce a contributor or dealer submission panel, it will adopt and enforce a Submitter Code of Conduct consistent with Principle 14 (and the related controls in Principle 15) before doing so.

P15

Internal controls over data collection

The Administrator should have controls over data collection and transmission, including anti-manipulation controls.

Although the Index has no Submitters, the Administrator applies internal controls over its automated data collection: source-integrity and connectivity checks, validation and plausibility screening of ingested records, de-duplication, and screening for manipulative or non-genuine activity (for example fictitious, wash, or outlier listings). Exceptions are logged and escalated.Proportionate note: these controls are scaled to a data-driven, non-submission benchmark; the Submitter-specific elements of this Principle do not apply (see P14).

16–19

Accountability

P16

Complaints procedures

The Administrator should have a written complaints procedure.

The Administrator maintains and publishes a Complaints Policy enabling any stakeholder to submit complaints about a determination, the methodology, or the Administrator's application of the Principles, via info@thepulse.fun. Complaints are logged, investigated within defined timelines, escalated to the Oversight Committee where material, and responded to; records are retained.

P17

Audits

The Administrator should appoint an independent internal or external auditor to periodically review adherence.

Adherence to these Principles is reviewed by an independent function. Given the Administrator's current scale, this review is initially conducted internally, by the Oversight Committee or a person independent of the determination process, on at least an annual basis. The Administrator intends to commission independent external assurance (for example under ISAE 3000) once the Index's usage and resources warrant, and will publish that assurance report alongside this Statement when obtained.Proportionate note: external assurance has not yet been obtained; this is disclosed in the management statement.

P18

Audit trails

The Administrator should keep written records for a defined period.

The Administrator retains records of data inputs, calculations, expert-judgment decisions and their rationale, methodology versions, changes, sign-offs, complaints and Oversight Committee proceedings for at least five years, sufficient to reconstruct and reproduce any historical determination.

P19

Cooperation with regulatory authorities

The Administrator should make relevant records available to, and cooperate with, relevant authorities.

The Administrator will cooperate promptly with any relevant regulatory authority and make relevant records available on request, subject to applicable law. Record retention (P18) is aligned to support this.

4 · Proportionality

How the Principles are applied proportionately

Consistent with the Principles' own guidance that their application should be proportional to the size and risks posed by each benchmark and administrator, the Administrator has applied them having regard to the Index's current characteristics: it is a novel, pre-launch, currently unused benchmark, not referenced by financial instruments on a regulated venue; it is rules-based and data-driven, with minimal discretion and no reliance on submitters; and it is administered by a small organisation currently in formation.

Areas of proportionate application, each disclosed above, are: combined roles within a small team, mitigated by independent oversight and conflicts controls (P1, P4); manual but documented control procedures (P4); an oversight function that is being established (P5); internal rather than external assurance at this stage (P17); and Principle 14 not applicable (no submitters).

The Administrator will scale its governance, controls and assurance as the Index's usage, referencing products and resources grow, in particular before the Index is used as a reference for financial instruments on a regulated venue, at which point it will reassess its obligations and whether any authorisation or registration is required.

Legal notice

This Statement of Compliance is published by The Pulse.fun on a voluntary basis and describes the Administrator's implementation of the IOSCO Principles for Financial Benchmarks as at the date stated.

The Pulse Rolex Index and its values are provided "as is" without warranty of any kind; the Administrator does not guarantee their accuracy, completeness or timeliness and, to the maximum extent permitted by law, accepts no liability for any loss arising from their use. Nothing in this Statement constitutes a representation that the Index is authorised, registered, endorsed or recognised under any benchmark regulation unless expressly stated.