Conclusion of Inspection No. 52/KL-TT regarding Inspection at DNSE Securities Joint Stock Company

On September 7, 2026, the State Securities Inspectorate issued Conclusion of Inspection No. 52/KL-TT regarding the inspection at DNSE Securities Joint Stock Company (Company/DNSE). The full text of the Inspection Conclusion is as follows:

1. General Overview

DNSE Securities Joint Stock Company, formerly DN Securities Joint Stock Company, was established under Operation License No. 62/UBCK-GP issued by the Chairman of the State Securities Commission (SSC) on October 30, 2007, with initial charter capital of 38 billion VND. In 2021, the company changed its name to DNSE Securities Joint Stock Company. The most recent establishment and securities business operation license is No. 38/GPĐC-UBCK issued on March 25, 2026. The Company's charter capital as of March 31, 2026, was 4,282,498,060,000 VND. Legal representative: Ms. Nguyen Ngoc Linh - General Director.

The Company's headquarters is located on the 6th Floor, Pax Sky Building, 63 – 65 Ngo Thi Nhjem, Hai Ba Trung Ward, Hanoi; with 01 branch in Ho Chi Minh City (address at C – 00.01, C – 00.02, C – 00.03, Lot C1, Low-rise Area Area III (Sarina Apartment Complex), No. 62 Hoang The Thien, An Khanh Ward, Ho Chi Minh City).

Licensed business activities: Securities brokerage; Proprietary trading; Securities investment consulting; Securities underwriting.

The Company provides the following services and activities: margin trading, pre-paid securities sales, online securities trading. The Company has been issued a Certificate of conditions for derivatives business operation and a Certificate of registration for public fund distribution activities.

The Company has no parent company, subsidiary, or affiliated company;

Based on the shareholder list finalized by Vietnam Securities Depository (VSDC) as of March 24, 2026, the Company has 4 major shareholders including: Encapital Financial Technology Joint Stock Company, Encapital Holdings Joint Stock Company, PYN Elite Funds (Non-UCITS), and Capella Group Joint Stock Company, with ownership ratios of 39.3%, 9.63%, 9.71%, and 9.8% respectively. The Company commits that Encapital Financial Technology Joint Stock Company and its related parties do not own more than 5% of the charter capital of any other securities company.

Regarding business results: According to the audited Financial Statements (FS) for 2024 and 2025 by KPMG Vietnam Co., Ltd., and the self-prepared Q1/2026 FS: The Company's total revenue for 2024, 2025, and Q1/2026 was 829 billion VND, 1,462 billion VND, and 397 billion VND respectively; among which, revenue from securities brokerage and financial services accounted for the highest proportion, reaching 30% and 37% of total Company revenue (in Q1/2026). The Company's net profit after tax for 2024, 2025, and Q1/2026 was 182 billion VND, 273 billion VND, and 11 billion VND respectively.

2. Inspection and Verification Results

2.1. Maintenance of Conditions for Issuance of Securities Business License and Derivatives Business Operation

The Company was issued Securities Business License No. 62/UBCK-GP dated October 30, 2007, by the State Securities Commission (SSC) to perform 04 business activities: securities brokerage, proprietary trading, securities underwriting, and securities investment consulting; Securities Custody Activity Registration Certificate No. 60/GCN-UBCK dated October 28, 2022; Certificate of Conditions for Derivatives Business Operation No. 44/GCN-UBCK dated August 29, 2022, permitting derivatives business activities: derivatives brokerage, derivatives proprietary trading, derivatives investment consulting; Certificate of Conditions for Clearing and Settlement Services for Derivatives No. 60/GCNUBCK dated October 28, 2022; Decision No. 455/QD-UBCK dated May 10, 2017 approving online securities trading services; Decision No. 204/QD-UBCK dated April 14, 2022 approving pre-paid sales services.

Inspection results show that the Company maintains the conditions for issuance of Securities Business License regarding capital, shareholders, infrastructure, and personnel 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 certain articles of the Securities Law (Decree No. 155/2020/NĐ-CP).

The Company maintains conditions for derivatives business operation 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 at Clause 5 Article 2 of Decree No. 306/2025/NĐ-CP.

2.2. Status of Securities Brokerage Business Implementation

• Regarding procedures related to brokerage activities: The Company has issued procedures including: Procedure for opening and closing securities trading accounts, Procedure for underlying securities trading, Procedure for registering and canceling online securities trading services, Procedure for clearing and settling underlying securities transactions, Procedure for reconciling balances and trading assets with Custody Member and Commercial Banks, Procedure for managing cash on securities trading accounts, Procedure for exercising rights for securities holders, Procedure for freezing and unfreezing securities, Procedure for securities custody, Procedure for correcting errors during trading hours for listed and registered securities, Procedure for order slip control, Procedure for operating securities trading systems, Procedure for risk control in providing online securities trading services to investors, Procedure for IT operation; Procedure for backup and data recovery; Procedure for handling online trading system incidents.

• Regarding opening securities trading accounts: As of June 16, 2026, the number of securities trading accounts opened at the Company was 1,785,420 accounts, including 1,785,383 domestic customer accounts (of which 1,785,095 individual accounts, 288 institutional accounts), and 37 foreign customer accounts (of which 25 individual accounts, 12 institutional accounts). Company customers sign a Securities Trading Account Opening Contract to be issued a custody account and sub-accounts under the customer's trading account. When opening a custody account, customers are defaulted with 01 securities trading sub-account (064Cxxxxxx). The Company does not open separate margin sub-accounts for customers but manages them on a single master account. On the securities trading account, customers can choose to trade in cash (not using borrowed money) or margin securities trading. According to the Company's report, the Company manages customer margin trading per transaction (including accounting for purchases, sales, and loan risk management).

Inspection results sampling 25 regular trading accounts showed: Regarding the content of the securities trading account opening contract, reviewing the sample "Securities Trading Account Opening Contract" along with the Terms and Conditions issued with the contract and sample account opening files, the content of the securities trading account opening contract signed by the Company 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 securities company activities (Circular 121/2020/TT-BTC); contracts opened via EKYC have been fully recorded by the Company's system with confirmation from both parties (including investors and the Company).

• Regarding receiving and executing customer trading orders:

Reviewing customer order books shows that customers place orders through online trading channels and at the counter.

Inspection results sampling transactions of some regular 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 all contents: stock code, volume, price, time of order receipt. For online channels, the Company provided order evidence showing stock code, volume, price, time of order receipt, device identification information, and IP address of the order.

Inspection results sampling some order placement times of some trading accounts on some days showed that at some order placement times, the Company allowed some customers to place stock purchase orders without sufficient funds, specifically: customers with account numbers 064C182182 (April 24, 2024), 064C168525 (June 24, 2024), 064C072152 (November 18, 2025, and November 12, 2025), 064C292223 (September 27, 2024). The Company allowing customers to place stock purchase orders without sufficient funds in the securities trading account violates 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, registered securities, and fund certificates, corporate bonds, listed warrant certificates on the securities trading system (Circular No. 120/2020/TT-BTC), amended at Clause 1 Article 1 of Circular No. 68/2024/TT-BTC dated September 18, 2024, by the Minister of the Ministry of Finance amending certain articles of circulars on securities trading on the securities trading system; clearing and settling securities transactions; securities company activities and information disclosure on the securities market (Circular No. 68/2024/TT-BTC).

• Regarding managing customer securities trading deposits:

The Company signed a Securities Trading Collection Service Contract via direct connection – account linking method No. 01/2024/DNSE-TCB dated October 10, 2024, with Vietnam Technological and Commercial Joint Stock Bank (Techcombank) regarding managing investor deposit accounts for securities trading in case customers open accounts directly at the bank. According to the Company's report, as of June 16, 2026, the Company has 8,734 customers using this service.

According to the Company's report, the Company opened 40 special accounts at 23 commercial banks to manage investor securities trading deposits (special accounts).

• Regarding the specialized department responsible for customer communication and resolving customer inquiries and complaints:

The Company issued a Decision on establishing the Customer Experience Center. Accordingly, the Customer Service Department is tasked with receiving requests, answering inquiries, and handling customer complaints through DNSE's support channels.

2.3. Status of Derivatives Securities Brokerage Business Implementation

• The Company has issued Derivatives Securities Brokerage business procedures including: Procedure for opening and closing derivatives securities trading accounts; Procedure for risk management in providing clearing and settlement services for derivatives securities; Procedure for internal control of direct clearing and settling derivatives securities transactions; Procedure for derivatives securities trading; Procedure for clearing and settling derivatives securities transactions; Procedure for correcting derivatives securities trading errors during trading hours; Procedure for remote derivatives securities trading on the Hanoi Stock Exchange order entry system; Procedure for operating derivatives securities trading systems; Procedure for backup and data recovery for derivatives securities trading; Procedure for risk management in derivatives securities activities.

• Regarding opening derivatives securities trading accounts: As of June 16, 2026, the total number of derivatives securities trading accounts for customers at the Company was 278,899 domestic investor accounts, 04 foreign investor accounts. According to the Company's report, the Company did not generate authorization contracts on derivatives securities trading account opening contracts. Inspection results sampling 10 derivatives securities trading accounts opened at the Company showed that the contract content basically meets the requirements of Article 15 of Circular No. 121/2020/TT-BTC.

• Regarding derivatives securities trading methods: The Company provides derivatives securities (DS) trading services through the following forms: Online DS trading; DS trading via brokerage; Direct DS trading. The Company has registered online trading with the SSC. Investors open DS trading accounts to access the Company's electronic online trading system. Order entry and approval of customer orders are automatically performed on the securities trading management software system. Electronic information page address to access online securities trading services: https://ol.dnse.com.vn.

• Regarding derivatives securities trading fee schedule: The Company has published derivatives securities trading fees on the Company's electronic information page.

• Regarding managing customer derivatives trading funds: The Company opened 02 accounts at Saigon Thuong Tin Joint Stock Bank - Capital Branch and Vietnam Asia Joint Stock Bank - Hanoi Branch to receive customer derivatives securities/margin trading deposits and 01 account at Vietnam Joint Stock Commercial Bank for Construction (Vietinbank) – Ba Dinh Branch for clearing and settling with VSDC.

• Regarding providing pre-paid services for derivatives securities trading: Through inspection of transaction statements of sample accounts and according to the Company's report, the Company has provided pre-paid services for derivatives securities trading and collected service fees, including: Position Interest Pre-payment, After-hours Margin Withdrawal Pre-payment, Margin Pre-payment.

The Company's General Director issued Decision No. 16A/2023/QĐ-TGĐDNSE dated June 05, 2023, No. 05A/2023/QĐ-TGĐ-DNSE dated February 26, 2024, No. 13A/2023/QĐ-TGĐ-DNSE dated April 28, 2025, on issuing fees for the above services.

According to data provided by the Company, from January 01, 2024, to June 16, 2026, the total generated value and total fees collected for the 03 above services were as follows: Position Interest Pre-payment (1,301,255.67 and 0 billion VND), After-hours Margin Withdrawal Pre-payment (1,164,706.15 and 393.97 billion VND), Margin Pre-payment (5,241,710.16 and 3.63 billion VND).

The Company providing position interest pre-payment, after-hours margin withdrawal pre-payment, and margin pre-payment without reporting to the SSC violates the stipulations in Clause 5 Article 86 of the Securities Law.

2.4. Status of Acting as Agent to Manage Securities Trading Accounts of Individual Investors

According to the Company's report, the Company did not generate activities acting as agent to manage securities trading accounts of individual investors during the inspection period.

2.5. Status of Distributing or Acting as Agent for Securities Distribution

The Company was issued a Certificate of Registration for Public Fund Distribution Activity No. 53/GCN-UBCK dated December 15, 2021, by the SSC. According to the Company's report, during the inspection period, the Company did not generate public fund distribution activities. From 2024 to June 16, 2026, DNSE acted as agent for 6 stock issuance rounds, with a distribution volume of 35,812,632 stocks. Total revenue from agency distribution recorded as of June 16, 2026, was 2,656,066,456 VND.

2.6. Status of Providing Shareholder List Management Services for Other Enterprises

During the inspection period, according to the Company's report and documents provided by the Company, the Company is managing shareholders for 01 organization, Golden Gate Corporation Joint Stock Company, starting date October 17, 2024, revenue 75,800,000 VND (of which, service fee revenue from the issuing organization was 50,000,000 VND recorded in 2025, share transfer fee revenue from holders when generated in 2024, 2025, and 2026 were 4,600,000 VND, 13,300,000 VND, and 7,900,000 VND respectively).

2.7. Customer Service Activities

2.7.1. Pre-paid Securities Sales Activity

The Company was approved by the SSC to provide pre-paid securities sales services under Decision No. 204/QD-UBCK dated April 14, 2022.

The Company issued Pre-paid Securities Sales Business Procedure under Decision No. 08.1/2022/QĐ-DNSE-TGĐ dated March 28, 2022, by the General Director.

According to the audited FS for 2024, 2025, reviewed semi-annual FS 2024, 2025, and according to the Company's report, the total pre-paid sales balance at times January 01, 2024, June 30, 2024, December 31, 2024, June 30, 2025, December 31, 2025, and June 16, 2026, was 71,239.47 billion VND, 186,623.15 billion VND, 97,616.6 billion VND, 217,657.53 billion VND, 584,105.68 billion VND, and 138,884.01 billion VND respectively.

According to data provided by the Company, interest income from pre-paid securities sales for customers in semi-annual 2024 (cumulative from the beginning of the year), 2024, semi-annual 2025 (cumulative from the beginning of the year), 2025, and the period from January 01, 2026, to June 16, 2026, was 10,668.46 billion VND, 18,127.91 billion VND, 9,294.65 billion VND, 32,326.12 billion VND, and 16,140.59 billion VND respectively.

2.7.2. Margin Trading Activity

The Company issued Margin Trading Procedure under Decision No. 01.02/2026/QĐ-DNSE-TGĐ dated January 05, 2026, by the General Director.

As of June 16, 2026, the number of margin trading accounts opened at the Company was 21,300 accounts, including 21,276 domestic individual accounts and 24 domestic institutional accounts, with no foreign investor accounts.

a) Regarding opening margin trading accounts

Inspection results sampling 25 account opening files registered to use margin trading services provided by the Company showed: The Terms and Conditions (T&C) is determined to be an inseparable part of the Contract and confirmed by customers when registering to use the service. The Company's provision of margin trading services basically complies with the contents stipulated in Article 12 of the Margin Trading Regulations for Securities issued with Decision No. 87/QĐ-UBCK dated January 25, 2017, by the Chairman of the SSC on issuing Margin Trading Regulations for Securities (Decision No. 87/QĐ-UBCK).

b) Regarding the List of Securities Permitted for Margin Trading

Monthly, the Company prepares and announces the list of securities permitted for margin trading to customers. Additionally, the Company has published the updated list of securities permitted for trading on the Company's electronic information page.

On May 06, 2024, DNSE reported to the Vietnam Stock Exchange the list of securities for margin trading in April 2024; accordingly, DNSE included stock code L18 (stock code added to the list of securities not meeting margin trading conditions from April 08, 2024, by the Hanoi Stock Exchange) in the margin trading securities list; DNSE provided margin loans for stock code L18 from April 08, 2024, to May 08, 2024. Regarding the above violation, the SSC issued Administrative Penalty Decision No. 1203/QĐ-XPHC dated November 05, 2024, against the Company for violating regulations on margin trading restrictions.

The list of securities permitted for margin trading from January 2024 to May 2026 (excluding April 2024) announced by the Company complies with the list announced by 02 Stock Exchanges.

c) Regarding Margin Trading Lending Limits

• Limit on total margin trading loan balance

According to the audited FS for 2024, 2025, reviewed semi-annual FS 2024, 2025, Q1 2026 FS prepared by the Company, the Company's margin trading loan balance at times June 30, 2024, December 31, 2024, June 30, 2025, December 31, 2025, March 31, 2026, was 3,411,047 billion VND, 3,783,968 billion VND, 4,834,959 billion VND, 5,248,085 billion VND, 5,655,551 billion VND respectively.

According to the Company's report, the Company's margin trading loan balance at times April 24, 2025, July 31, 2025, November 30, 2025, June 16, 2026, was 4,378,621 billion VND, 5,883,515 billion VND, 4,943,260 billion VND, and 6,196,920 billion VND respectively.

Reviewing the Company's total margin trading balance at times 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 June 16, 2026, shows that the Company's total margin trading loan balance does not exceed 200% of the Company's equity as stipulated in Clause 1 Article 9 of the Margin Trading Regulations for Securities issued with Decision No. 87/QĐ-UBCK.

• Limit on total margin trading lending to one customer

The Company provided margin trading loan balances for margin trading accounts at times 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 June 16, 2026. Inspection results at the above times show that the Company's total margin trading lending to the customer with the largest balance does not exceed 3% of the Company's equity as stipulated in Clause 2 Article 9 of the Margin Trading Regulations for Securities issued with Decision No. 87/QĐ-UBCK.

• Limit on total loan balance for one stock type and total securities lent for margin trading for one stock type

Inspection results sampling balances for some stock codes at some times (January 01, 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, June 16, 2026) with margin lending disbursement show: Inspection results sampling balances for some stock codes at the above times show that the total securities lent for margin trading for one stock type does not exceed 5% of the listed volume as stipulated in Clause 4 Article 9 of the Margin Trading Regulations for Securities issued with Decision No. 87/QĐ-UBCK.

Inspection results of monthly activity reports from January 01, 2024, to June 16, 2026, show that at some times, the total loan balance for one stock type exceeded 10% of the Company's equity, violating the stipulations in Clause 3 Article 9 of the Margin Trading Regulations for Securities issued with Decision No. 87/QĐ-UBCK, specifically:

Time Stock Code Balance/Equity Ratio (%)
30/09/2024 VPB 10.17%
28/02/2025 VPB 11.93%
30/04/2025 GEX 10.64%
31/05/2025 GEX 10.13%
31/07/2025 VIX 10.20%
31/08/2025 VIX 10.26%
30/09/2025 GEX 10.36%
30/09/2025 VIX 10.41%

Regarding the violation of margin trading lending limits, on November 25, 2025, the SSC (Inspectorate) issued Administrative Penalty Decision No. 440/QĐ/XPHC against the Company.

d) Regarding margin trading disbursement

Inspection results sampling statements and order books of 20 accounts with margin trading transactions show:

• At some times, the Company allowed some customers with securities trading account numbers 064C059982 (September 26, 2025), 064CQUOCVN (August 11, 2025), 064C123925 (May 22, 2025), 064C118879 (August 14, 2025), 064C776869 (September 13, 2024, and October 04, 2024) to use borrowed money to purchase securities not meeting margin trading conditions, violating the stipulations in Clause 4 Article 9 of Circular No. 120/2020/TT-BTC.

At certain times, the Company disbursed margin trading loans exceeding the buying power on the margin trading accounts of certain customers with securities trading account numbers 064C083696 (on 20/11/2025 and 22/12/2025); 064C075301 (on 07/10/2024); 064CQUOCVN (on 27/11/2025); 064CTCPVII (on 10/09/2025); 064CPXD888 (on 23/12/2025), violating the provisions at point d, Clause 5, Article 13 of the Regulations on Margin Trading Guidelines issued together with Decision No. 87/QĐ-UBCK and Clause 8, Article 9 of Circular No. 120/2020/TT-BTC.

2.8. Lending Restrictions

2.8.1 Restrictions on lending to insiders and related parties of insiders
The results of checking the bank statements of the Company's insiders, related parties of insiders, and major shareholders from 01/01/2024 to 16/6/2026 show that the Company disbursed margin loans and advanced sales proceeds to certain individuals who are insiders or related parties of insiders, violating the provisions at Clause 3, Article 27 of Circular No. 121/2020/TT-BTC.

2.8.2 Other contents
The results of checking the Company's detailed revenue ledger for the year 2024 show that the Company recognized revenue of 14,846.6 million VND from penalties for breach of share purchase contracts.

Inspection results show that the Company signed 07 share purchase contracts whereby the Company agreed to deposit a sum of money with the seller (an individual) to purchase shares with specific quantities and values, with agreements to return the deposit and pay penalties if the transaction is not completed due to the seller refusing to sell shares to the buyer or the seller violating other contract provisions. The contracts signed by the Company were not executed, and the sellers had to pay penalties to the Company. The Company's act of executing share purchase contract deposits but not executing the purchase, instead transferring money to the seller for a specified period according to the agreement, with repayment of principal and fees, constitutes money lending, violating the provisions at Clause 1, Article 27 of Circular No. 121/2020/TT-BTC.

2.9. Other Activities

During the inspection period, the Company signed Loan Agreements (LA) with customers having securities trading accounts with the Company to borrow money on the customers' securities trading accounts. Accordingly, customers wishing to lend to DNSE could submit a transaction request to DNSE to propose lending; the source of lending funds was available funds in the securities trading account or funds in other payment accounts; the money would be transferred from the customer's securities account/bank account to one of DNSE's bank accounts. Terms such as the loan amount, interest rate, loan start date, and repayment date were specified in the Transaction Request.

According to the Company's report, the LAs and transaction requests were signed electronically via the Company's mobile application or directly. The status of LA implementation using the method of deducting lending funds from the customer's securities trading account from 01/01/2024 to 16/6/2026 in the years 2024, 2025, and cumulatively as of 16/6/2026 is as follows:

Unit: million VND

Year	Number of lending customers	Total principal loan amount	Total principal repaid	Total interest repaid	Outstanding value (as of 31/12/2024 or 16/6/2026)
2024	98	12,954,924.98	12,540,934.24	18,828.6	413,990.74 (as of 31/12/2024)
2025	408	20,951,468.31	20,598,408.64	23,163.4	767,050.41 (as of 31/12/2025)
2026	504	7,011,005.72	7,194,275.72	14,910.03	583,780.41 (as of 16/6/2026)

The Company's provision of other financial services (signing loan agreements to borrow money on customers' securities trading accounts) without reporting to the State Securities Commission (SSC) violates the provisions at Clause 5, Article 86 of the Securities Law.

3. Conclusions

3.1. Conclusions on inspection contents
During the inspection period, the Company had certain violations and shortcomings as stated in Section 2 of the Inspection Conclusion as follows:

• Violation of regulations on receiving and executing customer orders (At certain times, the Company allowed customers with account numbers 064C182182 (on 24/04/2024), 064C168525 (on 24/06/2024), 064C072152 (on 18/11/2025 and 12/11/2025), 064C292223 (on 27/09/2024) to place buy orders for securities when there was insufficient money in the securities trading account), violating the provisions at point a, Clause 1, Article 7 of Circular No. 120/2020/TT-BTC, amended and supplemented by Clause 1, Article 1 of Circular No. 68/2024/TT-BTC.
• Providing other financial services that must be reported to the SSC before implementation but failing to report to the SSC, or when there is no written opinion from the SSC, or when there are no guiding regulations from the competent state authority (From 01/01/2024 to 16/6/2026, the Company provided services of margin interest application, after-hours margin withdrawal, and advance margin for derivatives securities brokerage without reporting to the SSC; From 01/01/2024 to 16/6/2026, the Company signed loan agreements to borrow money on customers' securities trading accounts), violating the provisions at Clause 5, Article 86 of the Securities Law.
• Violation of regulations on margin lending limits (At certain times, the total loan balance for a type of security exceeded 10% of the Company's equity), violating the provisions at Clause 3, Article 9 of the Regulations on Margin Trading Guidelines issued together with Decision No. 87/QĐ-UBCK.

The SSC issued Decision No. 440/QĐ/XPHC on administrative violation handling dated 25/11/2025 regarding the above acts of the Company.

• Allowing customers to execute margin trading exceeding the available buying power on the customer's margin trading account (At certain times, the Company disbursed margin trading loans exceeding the buying power on the margin trading accounts of customers with securities trading account numbers 064C083696 (on 20/11/2025 and 22/12/2025); 064C075301 (on 07/10/2024); 064CQUOCVN (on 27/11/2025); 064CTCPVII (on 10/09/2025); 064CPXD888 (on 23/12/2025)), violating the provisions at point d, Clause 5, Article 13 of the Regulations on Margin Trading Guidelines issued together with Decision No. 87/QĐ-UBCK and Clause 8, Article 9 of Circular No. 120/2020/TT-BTC.
• Violation of regulations on margin trading restrictions (On 06/05/2024, the Company reported to the Vietnam Stock Exchange the list of securities for margin trading in April 2024; accordingly, the Company included the security code L18 (a security code that had been added to the list of securities ineligible for margin trading by the Hanoi Stock Exchange since 08/04/2024) in the list of securities for margin trading; the Company executed margin lending for security code L18 from 08/04/2024 to 08/05/2024), violating the provisions at Clause 2, Article 10 of the Regulations on Margin Trading Guidelines issued together with Decision No. 87/QĐ-UBCK. The SSC issued Decision No. 1203/QĐ-XPHC on administrative violation handling dated 05/11/2024 regarding the above acts of the Company.
• Violation of regulations on securities eligible for margin trading (At certain times, the Company allowed customers to use loan money to buy securities that do not meet the conditions for margin trading for customers with securities trading account numbers 064C059982 (on 26/09/2025), 064CQUOCVN (on 11/08/2025), 064C123925 (on 22/05/2025), 064C118879 (on 14/08/2025), 064C776869 (on 13/09/2024 and 04/10/2024)), violating the provisions at Clause 4, Article 9 of Circular No. 120/2020/TT-BTC.
• Violation of regulations on lending restrictions (From 02/01/2024 to 10/06/2026, the Company disbursed margin loans and advanced sales proceeds to certain individuals who are insiders or related parties of insiders of the Company, violating the provisions at Clause 3, Article 27 of Circular No. 121/2020/TT-BTC; From 01/02/2024 to 25/12/2024, the Company lent money to certain individuals through the form of signing share purchase deposit contracts), violating the provisions at Clause 1, Article 27 of Circular No. 121/2020/TT-BTC.

3.2. Responsibilities
The Company, General Director, leaders, and employees of relevant departments are responsible for the Company's violations (Violation of regulations on receiving and executing customer orders, Providing other financial services that must be reported to the SSC before implementation but failing to report to the SSC, or when there is no written opinion from the SSC, or when there are no guiding regulations from the competent state authority, Violation of regulations on margin lending limits, Allowing customers to execute margin trading exceeding the available buying power on the customer's margin trading account, Violation of regulations on margin trading restrictions, Violation of regulations on securities eligible for margin trading, Violation of regulations on lending restrictions).

4. Handling measures within competence
   The State Securities Inspectorate reported and recommended to the SSC administrative penalties for the violations of the Company stated in Section 2 of the Inspection Conclusion. On 17/8/2026, the State Securities Inspectorate issued Decision No. 461/QĐ-XPHC on administrative violation handling against the Company, specifically as follows:

• For the violation of regulations on receiving and executing customer orders: A fine of 137,500,000 VND (One hundred thirty-seven million five hundred thousand VND) stipulated at point g, Clause 3, Article 26 of Decree No. 156/2020/NĐ-CP.
• For the act of providing other financial services that must be reported to the SSC before implementation but failing to report to the SSC, or when there is no written opinion from the SSC, or when there are no guiding regulations from the competent state authority.
  • Main penalty form: A fine of 275,000,000 VND (Two hundred seventy-five million VND) stipulated at point d, Clause 5, Article 24 of Decree No. 156/2020/NĐ-CP, supplemented by point b, Clause 8, Article 1 of Decree No. 306/2025/NĐ-CP.
  • Supplementary penalty form: Mandatory cessation of providing other financial services stipulated at point d, Clause 8, Article 24 of Decree No. 156/2020/NĐ-CP, supplemented by point d, Clause 8, Article 1 of Decree No. 306/2025/NĐ-CP (Mandatory cessation of providing margin interest application services, after-hours margin withdrawal services, advance margin for derivatives securities brokerage services, and signing loan agreements to borrow money on customers' securities trading accounts).
• For the act of allowing customers to execute margin trading exceeding the available buying power on the customer's margin trading account: A fine of 137,500,000 VND (One hundred thirty-seven million five hundred thousand VND) stipulated at point c, Clause 4, Article 26 of Decree No. 156/2020/NĐ-CP.
• For the violation of regulations on securities eligible for margin trading: A fine of 65,000,000 VND (Sixty-five million VND) stipulated at point a, Clause 4, Article 26 of Decree No. 156/2020/NĐ-CP.
• For the violation of regulations on lending restrictions: A fine of 187,500,000 VND (One hundred eighty-seven million five hundred thousand VND) stipulated at point d, Clause 5, Article 26 of Decree No. 156/2020/NĐ-CP.

5. Recommendations for handling measures

The State Securities Inspectorate requests the Company to urgently take measures to rectify and overcome the shortcomings after the inspection, specifically as follows:

• Review and strictly comply with regulations on receiving and executing customer orders; do not allow customers to place buy orders for securities when there is insufficient money in the securities trading account.
• Review all of the Company's service provision activities; cease providing services of margin interest application, after-hours margin withdrawal, and advance margin for derivatives securities brokerage services, and cease signing loan agreements to borrow money on customers' securities trading accounts.
• Review and strictly comply with regulations on margin lending limits and margin trading restrictions; do not allow customers to execute margin trading exceeding the available buying power on the customer's margin trading account; do not allow customers to trade margin for security codes not eligible for margin trading.
• Review and strictly comply with regulations on lending restrictions; do not lend to subjects who are insiders or related parties of insiders of the Company; do not lend money in any form except for the cases stipulated in Clause 1, Article 86 of the Securities Law.

The State Securities Inspectorate requires the Company to implement the rectification and overcoming measures immediately after the inspection within 30 days from the date of signing the inspection conclusion. The result report must be sent to the State Securities Inspectorate within 05 days from the end of the rectification and overcoming period./.