RESPONSE TO COMMENTS ON THE PUBLIC OFFER
“IMAN HALAL INVESTMENTS KOMMANDITNOE TOVARISHESTVO” limited partnership
Comment 1
Six or seven documents pop up one after another, impossible to make sense of
Our response:
This is not a legal objection but a complaint about the app interface. The Partnership’s documents have been brought into line with the law, which is why several documents were presented to the contributor for review at the same time.
Comment 2
The offer is dated 16 September, but only appears on 26–27 October
Our response:
The offer was posted in the mobile app on 17 September 2026. The notice is shown when the user opens the app, so contributors who had not opened the app for a long time saw the documents later. Under clauses 2.6 and 2.7 of the Offer, a new edition applies to a contributor from the date they accept it; until then the previous edition remains in effect.
Comment 3
The old offer said terms would change only with prior notice
Our response:
The offer of 22 August 2025 contained no such provision. Its clause 2.4 consisted of a single sentence on confirming consent by pressing the “I agree to the terms” button, and its clause 13.1 stated: “Amendments, additions, letters, notices and documents relating to this offer and/or the Investors’ participation in the partnership are sent by the Parties via the IMANUM platform (www.imanum.app)”. The rule that amendments to the Offer are published in the IMANUM mobile app with prior notice to the contributor was introduced precisely by clause 2.4 of the new edition.
Comment 4
By confirming the offer, you are deemed to agree to the new terms
Our response:
The previous edition had no rules on editions; this protection was introduced by the new edition. Under clause 2.7, a contributor who has not accepted the new edition remains under the previous edition until the end of their tariff term. Under clause 2.11, the tariff terms in force on the date of the Transaction, including the participation term and the profit-sharing ratio, do not change until the end of the tariff term. Under clauses 2.8 and 2.9, the list of rules that apply regardless of acceptance is exhaustive, and the terms for returning funds are not on it.
Comment 5
Under clause 7.3, early exit pays the value of a share in the property, not the balance
Our response:
Under Article 25 of the Law “On Business Partnerships”, a withdrawing participant is paid the value of the part of the partnership’s property corresponding to their share in the charter fund. Under Article 81 of the Civil Code, objects of civil rights include things, including money, as well as property; payment is therefore made in money. Under that Article, property may be handed over in kind only by agreement of the participants, and the Offer provides for no such procedure. Under clauses 7.2.4 and 7.11 of the Offer and clause 18.18 of the Founding Agreement, payment is made by bank transfer to the contributor’s bank account or bank card.
Comment 6
The amount may be less than the balance, and faster repayment has turned from an obligation into a right
Our response:
Under clause 18.8 of the Founding Agreement, the value of a Limited Partner’s share cannot be less than the nominal value of their contribution to the charter fund; under clause 18.15, no deductions from the contribution are allowed. Under clause 14.6, if no application is submitted, profit is directed to increasing the charter fund and becomes part of the contribution, so the rule of clause 18.8 applies to it as well.
The Partnership’s obligation is the 90-calendar-day term set in clause 7.3.1, reduced from 126 calendar days. Early repayment has never been an obligation in any edition. Repaying one or several contributors early does not change the term set for the other contributors.
Comment 7
Now three quarters of the profit is withheld, while before three quarters was yours
Our response:
The recalculation procedure is set by the normative part of clause 7.3.2, not by the example given with it. The previous edition also provided for withholding the overpaid amount and stated that the purpose of recalculation is to cover additional costs; the overpaid amount is the profit attributable to the unexpired part of the tariff term.
The new edition sets a calculation formula, caps the recalculation at the Partnership’s actual costs, prohibits deductions from the contribution to the charter capital, and applies no recalculation on exit at the end of the tariff term.
Comment 8
For some amounts the repayment term has been extended to 60 days
Our response:
The longer terms apply only to sub-clauses “b” and “e” of clause 7.2.1 and only to amounts above UZS 30 million.
The main term for early exit under clause 7.3.1 has been cut from 126 to 90 calendar days, and the term for exit at the end of the tariff term from 14 to 10 calendar days. Under sub-clauses “b” and “e”, the terms for all amounts up to UZS 30 million have also been shortened.
Comment 9
This specifically violates investors’ rights
Our response:
The terms of the new edition do not apply to a contributor until they accept them. The only exception is the exhaustive list in clause 2.8, which does not include repayment terms, the contribution amount or the profit-sharing ratio. Accepting the new edition amends the contract by agreement of the parties under Article 382 of the Civil Code; a person who has not accepted it remains under the previous terms until the end of the tariff term.
Comment 10
The old offer said the reserve fund insures losses 100 percent
Our response:
Under the principles of Islamic finance, participants share both profit and the risk of loss, and guaranteeing the return of a contribution or income is not permitted. The previous wording did not match this principle, so it was brought into line.
The scope of coverage has not changed. In the example given in the previous edition, coverage was also limited to the funds accumulated in the fund, and the same rule is set in clause 6.4 of the current Offer.
Comment 11
The reserve fund no longer exists
Our response:
The claim that the Partnership has no Reserve Fund is unfounded: the Reserve Fund and the clauses on it are set out in section 6 of the Offer of 22 August 2025 and in section 6 of the current Offer published on 17 September 2026. Its target size is 15 percent of the charter capital (clause 6.1), it is built from monthly allocations (clause 6.2), losses are covered within the funds accumulated in it (clause 6.4), and information on the fund is reported in the financial statements and open to contributors (clause 6.7).