Conclusion of Inspection No. 39/KL-TT regarding MB Securities Joint Stock Company

On July 22, 2026, the State Securities Inspection issued Inspection Conclusion No. 39/KL-TT regarding the inspection at MB Securities Joint Stock Company. The full conclusion is as follows:

1. General Overview MB Securities Joint Stock Company, formerly Thang Long Securities Joint Stock Company. In December 2013, Thang Long Securities Joint Stock Company merged with VIT Securities Joint Stock Company to form MB Securities Joint Stock Company according to the securities business license No. 116/GP-UBCK issued by the State Securities Commission (SSC) for the first time on December 9, 2013. The license was adjusted according to the most recent securities business license No. 43/GPDC-UBCK issued by the SSC on April 8, 2026. The charter capital of the Company as of March 31, 2026, was 6,673,189,810,000 VND. Legal representative: Mr. Phan Phuong Anh - Chairman of the Board of Directors. The Company's headquarters is located at Area 1 - Floors 7-8, MB Building, No. 21 Cat Linh, O Cho Dua Ward, Hanoi City; with 06 branches (including Trading Floor Branch 1, Hanoi Branch, Hai Phong Branch, Ho Chi Minh City Branch, Saigon Branch, and North Saigon Branch). Licensed business activities: Securities brokerage; Proprietary trading; Securities investment advisory; Securities underwriting. The Company has been approved to provide the following services and activities: margin trading, advance payment for securities sales, online securities trading, and derivatives trading. The Company has no subsidiaries or affiliated companies. Based on the shareholder list finalized by the Vietnam Securities Depository and Clearing Corporation (VSDC) as of February 23, 2026, to organize the 2026 Annual General Meeting of Shareholders, the Company has one major shareholder: Military Commercial Joint Stock Bank (MB), holding 439,766,963 shares as of February 23, 2026, representing a holding ratio of 66.76%. Regarding business performance: According to the audited Financial Statements (FS) for 2024 and 2025 by KPMG Vietnam Limited Liability Company, and the Q1/2026 FS prepared by the Company: total revenue for 2024, 2025, and Q1/2026 were 3,131 billion VND, 3,665 billion VND, and 1,023 billion VND respectively; among which, revenue from securities brokerage and financial services accounted for the highest proportion, reaching 24% and 43% of total company revenue (in Q1/2026). Net profit after tax for 2024, 2025, and Q1/2026 were 744 billion VND, 1,131 billion VND, and 292 billion VND respectively.

2. Inspection and Verification Results 2.1. Maintenance of conditions for issuing Securities Business License and Derivatives Trading License The Company was issued Securities Business License No. 116/UBCK-GP on December 9, 2013, by the State Securities Commission (SSC) to perform 04 securities business activities: securities brokerage, proprietary trading, securities underwriting, and securities investment advisory; Certificate of Condition Compliance No. 05/GCN-UBCK on May 19, 2017, to perform derivatives trading activities: derivatives brokerage, derivatives proprietary trading, and derivatives investment advisory; Certificate of Condition Compliance for Providing Clearing and Settlement Services for Derivatives Trading No. 14/GCN-UBCK on December 16, 2026. Inspection results show that the Company maintains the conditions for issuing the Securities Business License regarding capital, shareholders, infrastructure, and human resources as stipulated in Clause 1, Point c and Point d Clause 2, Clause 4, and Clause 5 Article 74, Point a Clause 1 Article 85 of the Securities Law; Clause 1 Article 175 of Government Decree No. 155/2020/NĐ-CP dated December 31, 2020, detailing the implementation of some articles of the Securities Law (Decree No. 155/2020/NĐ-CP). The Company maintains conditions for derivatives trading activities as stipulated in Point a Clause 1 Article 6 of Government Decree No. 158/2020/NĐ-CP dated December 31, 2020, on derivatives securities and derivatives securities market (Decree No. 158/2020/NĐ-CP), amended and supplemented by Clause 5 Article 2 of Government Decree No. 306/2025/NĐ-CP dated November 25, 2025, amending and supplementing some articles of Government Decree No. 156/2020/NĐ-CP dated December 31, 2020, on administrative penalties in the securities and securities market field (Decree No. 156/2020/NĐ-CP) (amended and supplemented by some articles according to Government Decree No. 128/2021/NĐ-CP dated December 30, 2021) and Decree No. 158/2020/NĐ-CP (Decree No. 306/2025/NĐ-CP).

2.2. Implementation of Securities Brokerage Activities

• Human resources for brokerage: As of May 5, 2026, the brokerage department had 250 employees with professional certificates (CCHN), of which 161 employees held derivatives securities and derivatives market certificates, meeting the minimum number of employees with CCHN at the main office and branches for securities brokerage as stipulated in Clause 5 Article 74 of the Securities Law, Point d Clause 2 Article 190 of Decree No. 155/2020/NĐ-CP, and the minimum number of employees with CCHN and derivatives certificates as stipulated in Point d Clause 2 Article 4 of Decree No. 158/2020/NĐ-CP.

• Procedures related to brokerage activities: The Company has issued procedures including: Procedures for opening, closing, and changing information of basic and derivatives trading accounts at the Company; Procedures for balance reconciliation and management of investor deposits at Commercial Banks; Procedures for balance reconciliation and management of investor deposits in individual bond trading settlement at Commercial Banks; Procedures for online trading at the Ho Chi Minh City Securities Exchange/Hanoi Securities Exchange of the Company; Procedures for clearing and settlement of basic securities transactions at the Company; Code of Professional Ethics; Procedures for receiving and handling customer complaints/reports of the Company.

• Opening securities trading accounts: As of May 5, 2026, the number of securities trading accounts opened at the Company was 807,438 accounts, including 806,987 domestic accounts (of which 805,986 individual accounts, 1,001 institutional accounts), and 451 foreign accounts (of which 360 individual accounts, 91 institutional accounts). Customers of the Company sign a Securities Trading Account Opening Contract to be issued a custodial account and sub-accounts under the customer's trading account. When opening a custodial account, customers defaultly have 01 ordinary securities trading sub-account (005Cxxxxxx). If customers have needs, they can sign a Contract with the Company to open other specialized sub-accounts within the custodial account such as margin trading sub-account (sub-account 8), derivatives account (sub-account D). Inspection sampling results for 25 ordinary trading accounts showed: Basically, the securities trading account opening contracts between investors and the Company have complete signatures of both parties, ID card/identity card numbers (for individual customers), business registration license/incorporation license (for institutional customers); the content of the Company's ordinary securities trading account opening contracts with customers basically meets the requirements stipulated in Clause 1 Article 15 of Circular No. 121/2020/TT-BTC dated December 31, 2020, by the Minister of the Ministry of Finance on the activities of securities companies (Circular 121/2020/TT-BTC).

• Receiving and executing customer trading orders: Through review of the customer order book, it was seen that customers place orders via online trading channels and at the counter. Inspection sampling results of transactions for 20 accounts on some trading days showed: For orders placed at the counter, the Company provided order slips confirmed by the customer and the Company, with information on the order slips containing complete content: security code, order volume, order price, order reception time. For the online channel, the Company provided evidence of order placement showing security code, order volume, order price, order reception time, device identification information for order placement, and IP address of order placement. Inspection sampling results of some order placement times for the 20 trading accounts mentioned above showed that at the times of order placement, customers had sufficient funds in their securities trading accounts, complying with the stipulations in Point a Clause 1 Article 7 of Circular No. 120/2020/TT-BTC dated December 31, 2020, by the Minister of the Ministry of Finance on trading listed stocks, registration for trading, and fund certificates, corporate bonds, listed warrant certificates on the securities trading system (Circular No. 120/2020/TT-BTC).

• Management of customer securities trading deposits: The Company signed a Cooperation Contract for providing investor account services between the Company and MB No. 01/MB-MBS/KHCN/2014 dated January 14, 2014, regarding the management of investor deposit accounts serving securities transactions in the case where customers open accounts directly at the bank. According to the Company's report, as of the current time, the Company has 06 customers using this service. According to the Company's report, the Company opened 44 specialized accounts at 19 commercial banks to manage investor securities trading deposits (specialized accounts). Inspection sampling results of the Business Operation Situation Reports for January 2024, June 2024, December 2024, January 2025, June 2025, December 2025, and January 2026 showed that the Company reported the list of banks managing investor securities trading deposits according to the template in Appendix II of Circular No. 121/2020/TT-BTC.

• Department responsible for customer communication and resolving customer inquiries/complaints: The Company has established a specialized department responsible for customer communication and resolving customer inquiries/complaints (Trading Management and Customer Care Department).

2.3. Implementation of Derivatives Securities Brokerage Activities

• The Company has issued business procedures related to derivatives securities brokerage activities including: Risk Management Procedures for derivatives trading activities at the Company; Derivatives Securities Trading Procedures - Futures Contracts at the Company; Derivatives Securities Transaction Clearing and Settlement Procedures.

• Opening derivatives securities trading accounts: As of May 5, 2026, the total number of derivatives securities trading accounts for customers at the Company was 27,049 domestic investor accounts, 09 foreign investor accounts. According to the Company's report, the Company did not generate authorization contracts on derivatives securities trading account opening contracts. Inspection sampling results of 10 derivatives securities trading accounts opened at the Company showed that the derivatives securities trading account opening contracts between the Company and customers basically had content and information according to the stipulations in Article 26 of Decree No. 158/2020/NĐ-CP.

• Derivatives securities trading methods: The Company provides derivatives securities trading services through the following forms: derivatives securities trading at the Company's counter; derivatives securities trading via telephone; online derivatives securities trading. As of the current time, all customers placing derivatives securities trading orders do so through online trading. Investors open derivatives securities trading accounts to access the Company's online electronic trading system. Order entry and approval of customer trading orders are performed automatically on the securities trading management software system. Website address to access online securities trading services: https://s24.mbs.com.vn/login/.

• Management of customer derivatives trading funds: The Company opened 21 accounts at banks to receive customer derivatives securities trading/margin deposits and 03 general accounts to perform margin deposits, profit/loss settlement of positions with VSDC.

• Derivatives securities trading fee schedule: The Company has published the derivatives securities trading fee levels on the Company's website according to the stipulations in Clause 5 Article 14 of Circular No. 121/2020/TT-BTC.

2.4. Provision of Account Management Delegation Services for Individual Investors

• The Company has issued business procedures related to account delegation management activities including: Procedures, policies for managing delegated accounts of the Company, Appendix of Regulations on Online Registration for Account Delegation Management Services.

• Implementation of account delegation management activities: As of May 5, 2026, the number of delegated securities trading accounts opened at the Company was 40,103 accounts (only including domestic customers). Inspection sampling results of 25 delegated securities trading accounts showed that the delegated securities trading contracts signed by the Company with customers basically meet the stipulations in Article 19 of Circular No. 121/2020/TT-BTC. According to the Company's report, from April 2026, the Company stopped allowing new customer registrations and has a roadmap to stop providing account delegation management services for individual investors from September 2026.

2.5. Distribution or Agency Distribution of Securities The Company has issued Procedures for consulting offering documents and agency distribution of corporate bonds to the public/individual corporate bonds. The Company was issued a Certificate of Registration for Public Fund Certificate Distribution Activities No. 29/GCN-UBCK on July 13, 2021, by the SSC. During the inspection period, the Company only generated bond distribution activities, specifically: The Company performed distribution/agency distribution for 19 bond issuance rounds of 08 issuing organizations including: 10 rounds (in 2024); 8 rounds (in 2025) and 01 round (in the first 4 months of 2026).

2.6. Provision of Securities Holder List Management Services for Other Enterprises The Company has issued Procedures for managing shareholders/bondholders. During the inspection period, the Company managed securities holder lists for 8 organizations of 10 issuance rounds, including 05 bond issuance rounds and 05 stock issuance rounds.

2.7. Customer Service Activities 2.7.1. Advance Payment for Securities Sales Activities The Company was approved by the SSC to provide advance payment for securities sales services according to Decision No. 154/QĐ-UBCK dated March 23, 2022. The Company has issued business procedures related to advance payment for securities sales services including: Procedures for providing advance payment for securities sales services at the Company; Risk Management and Control Procedures for advance payment services. According to the audited FS for 2024, 2025, reviewed semi-annual FS for 2024, 2025, and according to the Company's report, the total balance of advance payment for sales at the times of June 30, 2024, December 31, 2024, June 30, 2025, December 31, 2025, and May 5, 2026, were 155,776.64 million VND, 173,945.11 million VND, 162,145.63 million VND, 523,646.6 million VND, and 532,290.71 million VND respectively.

2.7.2. Margin Trading Activities The Company has issued Regulations on Providing Margin Trading Securities Services. As of May 5, 2026, the number of margin trading accounts opened at the Company was 599,825 accounts, including 599,539 domestic individual accounts and 286 domestic institutional accounts, with no foreign investor accounts. a) Opening margin trading accounts Inspection sampling results of 25 account opening files registered to use margin trading services showed that the content of the Company's margin trading account opening contracts with customers basically meets the requirements stipulated in Article 12 of Decision No. 87/QĐ-UBCK dated January 25, 2017, by the Chairman of the SSC on issuing Regulations on Margin Trading Securities (Decision No. 87/QĐ-UBCK). b) List of Securities Permitted for Margin Trading Every month, the Company compiles and announces the list of securities permitted for margin trading to customers. In addition, the Company has published the updated list of permitted trading securities on the Company's website. According to the Company's Announcement of the list of securities permitted for margin trading from January 2024 to May 2026, the list of securities permitted for margin trading announced by the Company is consistent with the list announced by the Hanoi Securities Exchange and the Ho Chi Minh City Securities Exchange. c) Margin Lending Limits

• Limit on total margin lending balance According to the audited FS for 2024, 2025, reviewed semi-annual FS for 2024, 2025, Q1 2026 FS prepared by the Company, the margin lending balance of the Company at the times of January 1, 2024, June 30, 2024, December 31, 2024, June 30, 2025, December 31, 2025, March 31, 2026, were 8,519,473 million VND, 9,822,846 million VND, 10,119,783 million VND, 12,633,508 million VND, 14,516,938 million VND, 14,867,436 million VND respectively. According to the Company's report, the margin lending balance of the Company at the times of April 24, 2025, July 31, 2025, November 30, 2025, May 5, 2026, were 10,943,617 million VND, 12,468,136 million VND, 14,547,501 million VND, and 15,305,826 million VND respectively. Through reviewing the total margin trading balance of the Company at the times of January 1, 2024, June 30, 2024, December 31, 2024, April 24, 2025, June 30, 2025, July 31, 2025, November 30, 2025, December 31, 2025, March 31, 2026, and May 5, 2026, it was seen that the total margin lending balance of the Company did not exceed 200% of the Company's equity, complying with the stipulations in Clause 1 Article 9 of the Regulations on Margin Trading Securities issued with Decision No. 87/QĐ-UBCK.
• Limit on total margin lending to one customer The Company provided margin trading balances of margin trading accounts at the times of January 1, 2024, June 30, 2024, December 31, 2024, April 24, 2025, June 30, 2025, July 31, 2025, November 30, 2025, December 31, 2025, March 31, 2026, and May 5, 2026. Inspection results showed that at these times, the total margin lending of the Company to the customer with the largest balance at each time did not exceed 3% of the Company's equity, complying with the stipulations in Clause 2 Article 9 of the Regulations on Margin Trading Securities issued with Decision No. 87/QĐ-UBCK.
• Limit on total lending balance for one type of security and total securities lent for margin trading for one type of security Inspection sampling results of balances for some security codes at some times (January 1, 2024, June 30, 2024, December 31, 2024, June 30, 2025, December 31, 2025, March 31, 2026, and April 29, 2026) with margin lending disbursement showed: Total lending balance for one type of security did not exceed 10% of the Company's equity, and total securities lent for margin trading for one type of security did not exceed 5% of the listed volume of securities, complying with the stipulations in Clause 3 and Clause 4 Article 9 of the Regulations on Margin Trading Securities issued with Decision No. 87/QĐ-UBCK. d) Margin Trading Disbursement Inspection results of statements, order books of 26 accounts with margin trading transactions on some days showed that the Company disbursed margin lending not exceeding the purchasing power on the customer's margin trading account, complying with the stipulations in Point d Clause 5 Article 13 of the Regulations on Margin Trading Securities issued with Decision No. 87/QĐ-UBCK. On some days July 24, 2025, November 6, 2025, November 17, 2025, and January 5, 2026, the Company allowed some customers with account numbers 005C3968TT, 005CHA1002, 005C208716, and 005C225388 to conduct margin trading for security codes not permitted for margin trading, violating the stipulations in Clause 4 Article 9 of Circular No. 120/2020/TT-BTC.

2.8. Coordination with Credit Institutions for Customers to Borrow Money to Buy Securities During the inspection period, the Company conducted activities coordinating with credit institutions to allow customers to borrow money to buy securities, whereby the Company signed Loan Request Contracts combined with Credit Contracts with Military Commercial Joint Stock Bank (MB) and customers (Tripartite Contracts). According to the Company's report, in the period from January 1, 2024, to May 5, 2026, the Company coordinated with MB to allow 1,250 customers to borrow money to buy securities, with a total lending amount of 38,009,703.72 million VND, and total interest income for MB was 321,735.79 million VND. As of May 5, 2026, the Company still had 383 customers with outstanding balances totaling 2,841,114.22 million VND. Inspection sampling results of 04 Loan Request Contracts combined with Credit Contracts signed by customers with MB and the Company showed that the Company coordinated with MB to allow customers at the Company to borrow money to pay for securities when not approved by the SSC, violating the stipulations in Point e Clause 1 Article 87 of the Securities Law (providing services stipulated in Point b Clause 1 Article 86 of the Securities Law).

3. Conclusion 3.1. Conclusion on Inspection Contents During the inspection period, the Company had some violations and shortcomings as stated in Section 2 of the Inspection Conclusion as follows:

• Providing services stipulated in Point b Clause 1 Article 86 of the Securities Law without prior written approval from the SSC, specifically: In the period from January 1, 2024, to May 5, 2026, the Company coordinated with Military Commercial Joint Stock Bank to provide services for customers to borrow money to buy securities without prior written approval from the SSC, violating the stipulations in Point b Clause 1 Article 86 and Point e Clause 1 Article 87 of the Securities Law.
• Violating regulations on securities permitted for margin trading, specifically: On some days in the period from July 24, 2025, to January 5, 2026, the Company allowed customers with account numbers 005C3968TT, 005CHA1002, 005C208716, 005C225388 to conduct margin trading for security codes not permitted for margin trading, violating the stipulations in Clause 4 Article 9 of Circular No. 120/2020/TT-BTC.

3.2. Responsibility The Company, General Director, leaders, and employees of relevant departments are responsible for the Company's violations (Providing services stipulated in Point b Clause 1 Article 86 of the Securities Law without prior written approval from the SSC, Violating regulations on securities permitted for margin trading).

4. Handling Measures within Competence The State Securities Inspection has reported and recommended to the SSC regarding administrative penalties for the Company's violations stated in Section 2 of the Inspection Conclusion. On June 29, 2026, the State Securities Inspection issued Administrative Penalty Decision No. 355/QĐ-XPHC against the Company, specifically as follows:

• For the act of providing services stipulated in Point b Clause 1 Article 86 of the Securities Law without prior written approval from the SSC

• Main penalty form: Fine of 275,000,000 VND (Two hundred seventy-five million VND) stipulated in Point a Clause 3 Article 25 of Decree No. 156/2020/NĐ-CP, amended and supplemented according to Point a Clause 9 Article 1 of Decree No. 306/2025/NĐ-CP.

• Supplementary penalty form: Temporary suspension for 2.5 months of the service coordinating with credit institutions to provide services for customers to borrow money to buy securities of the Company, according to the stipulations in Clause 5 Article 25 of Decree No. 156/2020/NĐ-CP, supplemented according to Point c Clause 9 Article 1 of Decree No. 306/2025/NĐ-CP.

• For the act of violating regulations on securities permitted for margin trading: Fine of 65,000,000 VND (Sixty-five million VND) stipulated in Point a Clause 4 Article 26 of Decree No. 156/2020/NĐ-CP.

5. Recommendations for Handling Measures The State Securities Inspection requests the Company to urgently take measures to rectify and overcome the shortcomings after the inspection, specifically as follows:

• Regarding the violation of regulations on securities permitted for margin trading: Review and strictly comply with regulations on not allowing customers to conduct margin trading for security codes not permitted for margin trading.
• Immediately stop, do not continue...