Sydney's $250k Tab

All Eligible Members may claim one $10 Trade Credit while supplies last, subject to the eligibility requirements below.

Welcome to Sydney's $250k Tab (the "Promotion"), where eligible participants who have a Novig Account (as defined below) may claim one $10.00 Trade Credit while supplies last. The Promotion is an Iteration Period under the Trade Credit Pool Program, the terms of which Ludlow Exchange, LLC, d/b/a Novig ("Novig" or the "Exchange"), has certified to the Commodity Futures Trading Commission (the “CFTC”) and posted on ludlowexchange.com/filings (the “Program Terms”). The Promotion has a Total Pool Value of $250,000.00, or 25,000 Trade Credits of $10.00 each. Novig, a CFTC-designated contract market located at 169 Madison Avenue #2199, New York, NY 10016, sponsors the Promotion. The terms "you" or "your" mean the person who participates in this Promotion.

Participation in this Promotion is expressly conditioned upon acceptance of and compliance with these Terms and Conditions, the Ludlow Rulebook (the "Rulebook"), and the Ludlow Member Agreement (the "Member Agreement"). Capitalized terms used but not defined in these Terms and Conditions have the meanings given to them in the Program Terms, the Rulebook, and the Member Agreement. ANY DISPUTE RELATING TO THIS PROMOTION WILL BE RESOLVED IN ACCORDANCE WITH SECTION 11 BELOW, AND PARTICIPANTS WAIVE THE ABILITY TO BRING CLAIMS IN A CLASS ACTION FORMAT.

The Promotion opens at 6:00 PM Eastern Time ("ET") on October 26, 2026, and runs for 24 hours, ending at 6:00 PM ET on October 27, 2026 (the "Promotion Period"). Claims are accepted until the end of the Promotion Period or until all 25,000 Trade Credits have been claimed, whichever comes first. Claims made before or after the Promotion Period do not qualify. Trade Credits claimed during the Promotion Period may be used for 48 hours from issuance, as described in Section 7.

Notice of the Promotion Period, stating its start date and time and its Total Pool Value, will be posted on the Novig website, in the Novig app, or both, at least 48 hours before the Promotion Period opens. Notice of any suspension or termination will be posted on the Novig website.

You are eligible for the Promotion if you: (i) have been approved for Membership and hold an open trading account; and (ii) are not the subject of an open compliance investigation or review and do not have a suspended account or suspended account privileges for any compliance or financial reason. You must meet each of these requirements at the time you claim a Trade Credit. A Member who does not meet them at the time of a claim is not eligible for that claim, even if the Member met them earlier in the Promotion Period. No minimum tenure, deposit, trading history, or trading activity is required to claim a Trade Credit.

The following are not eligible to participate, even if the requirements above are satisfied: (i) Affiliates of the Exchange (as defined in the Rulebook); (ii) Members who have executed a Market Maker Agreement or Entity Onboarding Agreement with the Exchange; and (iii) Introducing Brokers, Futures Commission Merchants, and customers thereof when transacting via the IB or FCM. All Promotion participants remain subject to the Rulebook.

Each Member may receive only one Trade Credit during this Promotion. If your Social Security number is associated with more than one Novig Account in Novig's records, you may claim only one Trade Credit across all of those accounts.

During the Promotion Period, you must claim your Trade Credit through the Novig mobile app or website. Trade Credits may not be claimed through any application programming interface or other automated means.

Claims are fulfilled strictly in the order in which Novig's systems receive them, without regard to the identity of the Member making the claim, until the earlier of (i) all 25,000 Trade Credits being claimed or (ii) the end of the Promotion Period. A Trade Credit is issued to your account automatically upon a timely claim if you meet the requirements in Section 3 at that time. Novig exercises no discretion over which Eligible Members receive a Trade Credit, and no Trade Credit is awarded by chance or selection. If you claim after all 25,000 Trade Credits have been claimed, you will not receive one.

Reminder opt-in. At any time during the 48 hours before the Promotion Period opens, you may opt in through the Novig app to be notified when the Promotion Period opens. Opting in is optional. It does not reserve a Trade Credit, place you ahead of other Members, or give you earlier access to claim. Every eligible Member may claim on the same terms whether or not they opted in.

To participate in the Promotion, eligible individuals must register a Novig Account and verify their identity in order to trade on the Novig platform (a "Novig Account"). Creating a Novig Account is free. By submitting your information and creating a Novig Account, you agree to the Member Agreement and the Rulebook, and consent to the Novig Privacy Policy. If you do not agree to these terms, you cannot create a Novig Account or participate in this Promotion.

In addition to the eligibility requirements in Section 3, the Chief Regulatory Officer may at any time revoke your eligibility and disqualify trades or activity inconsistent with the purpose of this Promotion or the Rulebook, including where you are found, following review by the Compliance Department, to have: (a) tampered with the registration process, the claim process, or the operation of the Promotion; (b) acted in violation of these Terms and Conditions; or (c) acted in a manner inconsistent with these Terms and Conditions or the Rulebook. This Promotion is void where prohibited by law. Trade Credits issued under this Promotion may not be combined with your own funds or with any other Incentive Program or promotion offered by Novig.

Each Trade Credit issued under this Promotion has a value of $10.00. Trade Credits are non-transferable and non-withdrawable, and have value usable solely for trading on the Exchange. A Trade Credit is a standalone credit. It is not a loan, an extension of credit, or a margin accommodation, and you owe Novig nothing for it. When applied to a trade, a Trade Credit collateralizes your position in the same manner as deposited funds, consistent with the fully-collateralized nature of Novig's markets.

Trade Credits may be used on any Contract listed for trading on Novig, at any price at which the Contract may trade, subject to the following conditions:

Each Trade Credit expires 48 hours after issuance. Any Trade Credit not used within that period is forfeited.

Proceeds from a trade made using a Trade Credit settle to your account as ordinary funds and are withdrawable under Novig's standard withdrawal procedures. You are not required to meet any trading volume requirements before withdrawing proceeds. If a Contract acquired with a Trade Credit settles worthless, you receive no proceeds and owe Novig nothing. Novig does not reimburse losses on any trade.

If you are found to have provided false or fraudulent information on your Membership application, or to have engaged in conduct that circumvents the Promotion, including multi-accounting, identity duplication, collusion, or bonus abuse, you will be disqualified from the Promotion and the value of any Trade Credit used is subject to clawback.

Novig may adjust, reduce, cancel, or claw back any Trade Credit, or Contracts acquired with a Trade Credit, where:

(i) the Trade Credit was issued in error, regardless of fault, including through technical malfunction, system error, or administrative mistake;

(ii) the underlying order is voided or reversed;

(iii) the Chief Regulatory Officer reasonably determines that the Trade Credit was obtained or used through fraud, misrepresentation, collusion, multi-accounting, or other activity inconsistent with these Terms and Conditions, the Program Terms, or the Rulebook; or

(iv) Applicable Law or the directive of a competent regulatory authority requires Novig to void or reverse the underlying transaction.

Determinations under this Section are made by the Chief Regulatory Officer or the Chief Regulatory Officer's designee. Any correction under clause (i) will be computed from and supported by Novig's records of Promotion activity. Novig will notify you of any clawback or correction.

Should you wish to cancel your participation in this Promotion at any time, please contact [email protected]. Any unused Trade Credit will be forfeited on cancellation. Proceeds that have already settled to your account are not affected. Complaints about this Promotion may also be sent to [email protected].

Novig conducts ongoing surveillance of activity under this Promotion pursuant to Chapter 9 of the Rulebook and keeps records of all activity, issuances, and clawbacks. The Chief Regulatory Officer may revoke a Member's eligibility, disqualify trades or activity inconsistent with the purpose of the Promotion or the Rulebook, and suspend or terminate the Promotion where necessary to preserve fair and orderly markets or to address conduct inconsistent with the Rulebook. A suspension or termination may take effect immediately, and notice will be posted on the Novig website.

No suspension or termination will affect Contracts already acquired with a Trade Credit or revoke a Trade Credit already issued to you, except as provided in Section 8. The terms of this Promotion may not be amended except pursuant to a new rule certification filed with the CFTC.

Any dispute relating to this Promotion is a "Dispute" governed by the informal dispute resolution, mandatory arbitration, and class action waiver provisions of the Member Agreement (Sections 22-25) and Chapters 10-11 of the Rulebook, including the opt-out rights and carve-outs set forth therein.

Administration: Novig administers this Promotion under the Program Terms and the Rulebook. Questions about eligibility or administration are determined by the Chief Regulatory Officer or the Chief Regulatory Officer's designee.

Indemnification and Limitation of Liability: Your indemnification obligations under Section 18 of the Member Agreement, and the limitation of liability set forth in Rule 12.3 of the Rulebook, apply in full to your participation in this Promotion.

Relationship to the Program Terms and Rulebook: These Terms and Conditions describe the Promotion in plain language and are subject to the Program Terms and the Rulebook. If these Terms and Conditions conflict with the Program Terms or the Rulebook, the Program Terms and the Rulebook govern.