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Exinity Liquidity Client Agreement

The Client Account Agreement outlines the terms between Windsor Brokers International Ltd and its clients regarding the opening and maintenance of trading accounts for financial instruments. It includes provisions on trading authorization, applicable rules, fees, risk of loss, and indemnification, emphasizing that clients are solely responsible for their trading activities and any associated risks. The document also states that the Company is not liable for third-party insolvency or losses resulting from market fluctuations.

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0% found this document useful (0 votes)
13 views43 pages

Exinity Liquidity Client Agreement

The Client Account Agreement outlines the terms between Windsor Brokers International Ltd and its clients regarding the opening and maintenance of trading accounts for financial instruments. It includes provisions on trading authorization, applicable rules, fees, risk of loss, and indemnification, emphasizing that clients are solely responsible for their trading activities and any associated risks. The document also states that the Company is not liable for third-party insolvency or losses resulting from market fluctuations.

Uploaded by

shizzydee137
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

CLIENT ACCOUNT AGREEMENT

Windsor Brokers International Ltd


FSA Seychelles

1224
DISCLAIMER
This is a live document and should be read by the intended recipients,
that being the current and/or prospective clients of Windsor Brokers
and/or those individuals, natural and/or legal persons, which are
authorised by Windsor Brokers. The material and information provided
within are protected by copyright owned by Windsor Brokers. Any
reproduction, retransmission, republication, or other use of all or part
of any procedure including but not limited to posting, linking, or
otherwise modifying its contents is expressly prohibited, unless prior
written permission has been granted by Windsor Brokers. Windsor
Brokers, retains the right to alter and/or amend any of its terms at its
absolute discretion without first obtaining the consent of the client.
Except as required by law, Windsor Brokers shall not accept any
responsibility and/or be held liable for any damages (direct, indirect,
incidental, special, consequential, or exemplary), resulting from
unlawful and/or inappropriate use of information provided.
Windsor Brokers International Ltd (the “Company” ”) is a Seychelles Company regulated by the Seychelles
Financial Services Authority (“FSA”). The Company is incorporated and registered under the laws of
Seychelles with registration number 8425783-1 and has its registered office at Scenic Car Hire Building No.
G3, Parcel Nos: H1238, H1239, H7524, Majoie, Mahe, Seychelles, with contact information
compliance@[Link] .

By this Client Account Agreement (the “Agreement”), the Company agrees to open and maintain for the
Client (the “Client” or “you”) one or more trading accounts and to act as the counterparty to the Client’s
transactions, involving the purchase and sale of financial instruments, including but not limited to foreign
exchange transactions and contracts for differences.

By accepting this Agreement, the Client hereby agrees that they have read, understood and accepted the
provisions included in this Agreement, including its Appendices, and the various documents included in the
Company’s website.

1. DEFINITIONS AND INTERPRETATIONS

1.1. Clients shall mean any natural or legal persons that have accepted this Agreement and
themselves have funded their trading account with the Company.

1.2. Unless the content of this Agreement states otherwise, the definitions and interpretations can
be viewed by the Client on the Company’s website.

2. TRADING AUTHORIZATION
The Company is authorized to offer for purchase and sale as well as to purchase sell Financial
Instruments for the Client’s accounts in accordance with verbal or written instructions including digital
or hand written instructions or in any other form provided to the Company by the Client, the Client's
designated agent / representative of the Client. The Client hereby waives any defense in cases where
such instructions were not in writing. The Company is also authorized, in its sole discretion, to employ
clearing members and floor brokers as clients’ agents in connection with the execution, carrying,
clearance, delivery and settlement of any such purchases and sales of Financial Instruments. Financial
Instruments bought or sold will be transactions between the Client and the Company as the
counterparty in accordance with the Company’s license. The Company anticipates offering prices to its
clients that are reasonably related to prices offered by other counterparties, such prices may however
vary. The Company shall have no liability for failure to execute order/request and makes no
representations, warranties or guarantees of the Client’s order/request’s priority over the order/request
of other clients. The Client shall be directly and personally responsible for performing obligations under
every transaction entered into, with the Company, and the Client indemnifies the Company in respect
of all liabilities, losses, expenses and/or costs of any kind or nature whatsoever which may be incurred
as a direct or indirect result of any failure by the Client to perform any obligations.

3. APPLICABLE RULES AND REGULATIONS


3.1. All order/requests entered into for the purpose of purchase/sale of Financial Instruments and
all transactions executed for the Client's accounts shall be subject to the constitution, by-laws, rules,
regulations, customs and usages (collectively “rules”) where such transactions are executed and to
the rules and regulations promulgated there under (collectively “laws”). The Company shall not be
liable to the Client as a result of any action taken by the Company or its agents in compliance with any

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of the foregoing rules or laws. This paragraph is solely for the protection and benefit of the Company,
and any failure by the Company or its agents to comply with any of the foregoing rules or laws shall
not relieve the Client of any obligation under this Agreement nor be construed to create rights under
this Agreement in favor of the Client against the Company. In the event that any term of this
Agreement be inconsistent with a requirement set by regulatory authority and/or the law, after the
production of this Agreement, the Company will update terms and conditions of this Agreement, to
comply with new regulatory requirement and/or the law, while such changes will automatically be
applicable to the relationship between the Company and the Client.

3.2. The Company may also hold money on behalf of the Client in different banks or entities from
the one used by the Client for transferring funds to the Company. In such cases, the legal and
regulatory regime applying to any such bank or entity will be applicable in the event of the insolvency
or any other analogous proceedings in relation to that bank or entity.

3.3. The Company will not be liable for the insolvency, acts or omissions of any third party referred
to in this Agreement, nor of any law imposed in any such given country at any such time where the
Company has no control over such and any acts of force majeure.

4. PROVISION OF INFORMATION AND REPORTING


4.1. The Client hereby agrees that the Company may, at any time, request information from the
Client and that Client will provide such information, in order to comply with the legislative
requirements at the given time. In addition, the Client undertakes to disclose any changes to the
information provided to the Company.

4.2. The Client also acknowledges that the Company may use such information for the purpose of
conducting research, its own and/or third-party, in order to verify the identity of the Client and gather
relevant information to complete the economic profile of the Client.

5. CHARGES/COSTS/FEES/COMMISSIONS/EXPENSES PAYABLE BY CLIENT


5.1. The Client agrees and confirms paying:

a. any fees, charges, commissions applicable to specific Financial Instruments and accounts held
by the Client, related to execution of trades;
b. such charge/costs related to carrying open trades on specific Financial Instruments;
c. such charge/costs related to rolling over of Financial Instruments;
d. such charge/costs related to inactive accounts;
e. such transfer-related fees, including but not limited to charge/costs applied on
deposits/withdrawals, returned withdrawals, issuing and returns of issued [Link]
Company, may at its own discretion, apply the full transactional (deposit/withdrawal) fee
otherwise given to client should it think that the purpose of the deposit does not fulfill or
correspond to the purpose of the trading account;
f. Spread, mark-up or mark-down when compared to prices that the Company receives or
expects to receive, when covering its trades with another counterparty;
g. Currency conversion related to trading costs and profits/losses occurred from trading activities;
h. Currency conversion related to amounts received in currencies different from the basic
currency used by the accounts;
i. Such charge/costs required by regulatory body and/or legal requirement;
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j. Such other taxes or costs that may exist that are not applied by the Company;
k. the amount of any loss that may result from transactions made by the Company, on the Client's
behalf, including any deficit balance;
l. Such relevant amounts related to subscriptions of the Client to an exchange.

5.2. The Client further acknowledges:

a. unless otherwise stated, prices offered to the Client through Online Trading Platform(s) are
exclusive of taxes and costs that may be applied to the services which are not offered or paid
through the Company itself;
b. there are no specific costs applied by the Company to the Client’s accounts for using Online
Trading Platform(s);
c. charge/costs may be applied to specific types of accounts which are notified to clients prior to
the implementation of such charge/costs;
d. in cases where the notification of specific charge/costs is not provided to the Client, for
whatsoever reason, the Client should inquire and obtain the reasonable explanation for such
charge/costs;
e. fees, charges, commissions are applied separately from the price offered to the Client;
f. Spreads are as offered with Online Trading Platform(s).

5.3. The Client should request/obtain a clear explanation of all trading terms & conditions, including
any applicable charges/costs, prior to trading. For more information, please refer to the Product
Outline in the website.

5.4. The Client further acknowledges and accepts that an administration charge (e.g. for the account
review, monitoring etc.) will be applied to the Client’s account on termination where the balance is
below US$50 (or currency equivalent). In such cases, the Company will zero out any remaining balance
below the threshold and will have no obligation to refund the Client.

5.5. Even in cases where the balance is above the threshold, the Company reserves the right to apply
the administration charge on termination in instances where in the Company’s reasonable discretion
it may not be able to refund the Client, including, but not limited to, where the Client closed the bank
account in Company's records or where the Company cannot locate the Client, i.e. within a 3-month
period from the date the decision to terminate the account was taken.

6. DISCRETIONARY BENEFITS
6.1. The Client acknowledges and agrees that monetary benefits, including but not limited to
bonuses, rewards, interest or other payments (collectively referred to as "Discretionary Benefits"), may
be credited to the Client's account from time to time. Such Discretionary Payments do not constitute an
obligation or guarantee by the Company.

6.2. The Client further acknowledges that the Company is not responsible for initiating, managing,
or continuing any Discretionary Payments, nor is it liable for the cessation, reduction, or modification of
such payments. The presence or absence of these payments in the Client's account shall not alter the
terms of this Agreement or affect the Client's obligations under it.

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7. RISK OF LOSS
7.1. All transactions effected for the Client's accounts and all fluctuations in the market prices of the
Financial Instruments carried in the Client's accounts are at the Client's sole risk and the Client shall
be solely liable under all circumstances at any given time. By execution of this Agreement, the Client
warrants that the Client is willing and financially able to sustain any such losses. The Company is not
responsible for the obligations of the persons with whom the Client's transactions are effected, nor is
the Company responsible for delays in transmission, delivery or execution of the Client's
orders/requests due to malfunctions of communications facilities or other causes. The Company shall
not be liable to the Client for the loss of any margin deposits which is the direct or indirect result of
the bankruptcy, insolvency, liquidation, receivership, custodianship or assignment for the benefit of
creditors of any bank, another clearing broker, exchange, clearing organization or similar entity.

7.2. The Client understands and agrees that the risk of loss in trading of Financial Instruments
including but not limited to stocks, options, futures, forex, foreign equities, bonds, contract for
differences, can be substantial. Trading of Financial Instruments involves a high degree of risk and are
not suitable for all investors; the amount the Client may lose may be greater than the initial
investment. Such markets may be subject to regulation which may offer different or diminished
investor protection. The Client understands, before trading, that the Client should enquire as to any
rules relevant to the particular transactions.

7.3. The Client understands that most of the electronic trading facilities are supported by computer-
based component systems for the order-routing, execution, matching, registration and/or clearing of
trades. Facilities and systems may be vulnerable to temporary disruption or failure. The Client’s ability
to recover certain losses may be subject to limits on liability imposed by the system provider, the
market, the clearing house, and/or member firms.

7.4. The Client acknowledges and confirms that the Client is fully aware of all risks that may arise in
the event of adverse movements of a currency and/or a pair of currencies. The Company warns the
Client of the high risks involved in trading whereby the Client can sustain losses and/or damages to
some or all of the capital/monies invested. All transactions effected are at the Client’s sole risk and
the Client is liable under any given circumstances. Additionally, the Client understands and confirms
that the Company will not be held responsible for any delays in transmissions, delivery or execution
of requests, due to force majeure, malfunctions of communications facilities or other causes.

7.5. The Client understands and accepts that some of the investments may not be realizable if the
market in the Financial Instrument in concern is illiquid, therefore the identification of the risk to
which the Client may be exposed may be difficult to quantify. The price, value of, and income from
any of the Financial Instruments may fall as well as rise and clients may not receive back the amount
invested or may be required to pay more.

8. SAFEGUARDING OF CLIENT FINANCIAL INSTRUMENTS, ASSETS AND FUNDS


8.1. The Company may hold, on behalf of the Client, such client’s assets/property and/or funds with
custodians whereby the domestic legal and regulatory regime, may be applicable to any such entity.
Therefore, in the event of the insolvency or any other analogous proceedings, in relation to such entity,
the Client’s assets/property and/or funds may be treated differently from the treatment which would
apply if the assets/property and/or funds were held in other jurisdiction.

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8.2. The Company will not be liable for the insolvency, acts or omissions of any third party, referred
to in this paragraph, nor of any law imposed in any such given country, at any such time where the
Company has no control over.

8.3. The Client acknowledges that the Company has established adequate measures to ensure its
compliance with legal requirements in order to safeguard the Client’s Financial Instruments and funds
belonging to the Client. The Client understands that the Company, during the existence of the
business relationship with the Client, will keep records necessary for the Company to distinguish
Financial Instruments and funds held for the Client from the Financial Instruments and funds held by
the Company for other clients and from the Company’s Financial Instruments and own funds.

8.4. The Client’s funds are segregated from the Company’s own funds and are not used for the
Company’s own account.

8.5. The Client acknowledges that the Company will not pay any interest to the Client on any funds
held on the Client’s behalf or otherwise under this Agreement and the Client further waives any
entitlement to interest on such funds.

9. INDEMNIFICATION
9.1. The Client hereby agrees to indemnify the Company and hold the Company harmless from any
liability, cost and/or expenses (including attorneys' fees and expenses and any fines and/or penalties
imposed by any governmental agency, contract market, exchange, clearing organization or other
regulatory or self-regulatory body or institution) which the Company may incur or be subjected to,
with respect to the Client's accounts or any transaction or position therein. Without limiting the
generality of the foregoing, the Client agrees to reimburse the Company on demand for any cost of
collection incurred by the Company in collecting any sums owing by the Client under this Agreement
and any cost incurred by the Company, including legal action/proceedings, in defending against any
claims asserted by the Client, including all attorneys' fees, interest and expenses. The Client hereby
agrees and acknowledges being liable for the Client’s own costs and/or expenses, unless directed
otherwise by any court of law and/or regulatory body. The Client furthermore confirms and agrees
that all information provided to the Company for purposes of account opening is true and correct, the
Client will provide all the relevant information regarding Client’s knowledge and experience in the
investment field relevant to product and/or service as the case may be, and as requested by the
Company. In the event that the Client provides insufficient/false information regarding knowledge
and experience as to any product and/or service, the Client understands and agrees that such
information will not allow the Company to determine whether the investment services and/or
Financial Instruments envisages is appropriate for the Client.

9.2. The Client understands and accepts that the Company does not provide financial, legal, tax or
other advice, nor should any investment or any other decisions be made solely based on the
information obtained from the Company, the Company recommends the Client to obtain advice on
such matters from specialists.

9.3. All information and opinions expressed by the Company is obtained from sources believed to be
reliable and in good faith, no representation or warranty, express or implied, is made as to its accuracy
or completeness. All material provided by the Company represents current views and is provided

7
under reasonable duty of care and the Company will have no liability for any direct or indirect
damages arising out of the use of information when accepted and/or used by the Client. The Client
furthermore accepts that any information on Financial Instruments, including but not limited to asset
classes, asset allocations and the like are only indicative, and the Company assumes no obligation to
ensure that such information are brought to the attention of any client.

9.4. The Company furthermore will not be held liable for any taxation assessed upon or payable
directly or indirectly by the Client or for any loss or expense suffered by the Client in connection with
any such assessment. If the Company is, at any time, assessed for taxation in respect of or in
connection with the Client’s assets, income, activities or residence, including without limitation any
claim for recovery of monies paid to or for the Client, in excess of the amounts which should properly
have been paid, the Client undertakes to indemnify the Company in respect of the relevant taxation,
together with all expenses, including but not limited to any legal fees. The Client is solely responsible
for the management of affairs for tax purposes, and the Company accepts no responsibility for any
tax consequences of anything carried out within scope of authority.

9.5. In addition, the Company will not be liable for any loss or expense suffered by the Client in
connection with the terms and conditions, including but not limited to the insolvency or other default
of any counterparty or custodian, unless such loss or expense arises from the Company negligence,
willful default or fraud. Without prejudice to the foregoing, the Client accepts to reimburse the
Company of any cost, loss, liability or expense whatsoever which may be suffered or incurred by the
Company, whether directly or indirectly, in connection with or as a result of the Client’s failure to
perform or delay in performing any obligations stemming from this Agreement.

9.6. The Company gives no warranty as to the performance or profitability of any Financial
Instrument in order for the Client to secure a level of income or capital gain.

9.7. The Company will not be responsible for any loss or loss of opportunity, whereby the value of
the Financial Instruments, assets and/or funds could have been increased, nor for any decline in the
value of such, nor for any loss arising from errors of fact or judgment or any action taken or omitted
to be taken, however arising and whether direct, indirect, financial or consequential loss howsoever
causes, except to the extent that any such error, act or omission is caused by the Company negligence,
willful default or fraud.

9.8. Furthermore, the Client acknowledges and agrees that initiating any transaction in any of their
accounts subsequent to filing a complaint and/or other claim regarding their accounts signifies their
acceptance of the account's status as of the complaint's filing date. The execution of such transactions
by the Company, following the initiation by the Client, shall serve as mutual consideration for resolving
the claim. Additionally, the Client undertakes not to pursue reopening the case subsequent to this
resolution, thereby affirming their understanding and commitment to the finality of the resolution
process.

10. RECORDING
10.1. The Client understands that all communication regarding the Client's accounts, orders/requests
for acquiring Financial Instruments, between the Client and the Company, may be recorded by the
Company, and the Client irrevocably consents to such recordings and waives any right to object to the
Company’s use of such recordings in any proceeding or as the Company otherwise deems appropriate.

8
10.2. The Client agrees and consents that the Company, records telephone conversation between the
Company and the Client. The Client agrees that such recordings remain the property of the Company
and may be used as a proof of evidence, legal and/or moral obligations.

10.3. The Client further acknowledges that existing recordings of conversation and data traffic records,
executing and documenting the communications and execution of transactions, may constitute crucial
evidence to detect and prove the existence of insider dealing and market manipulation. It is
understood that the existing recordings of conversation, electronic communications and data traffic
records, may be used by the Company for the legal purposes.

10.4. The Client agrees and confirms that he must only use the official communication channels
agreed upon between the Client and the Company to communicate with the concerned employees.

10.5. The Client further waives all rights to object to the admissibility of recordings in any legal matters
and/or proceedings, at any given time or within any jurisdiction.

11. FOREIGN CURRENCY


11.1. In cases where the transactions for the Client's accounts are effected through Online Trading
Platform, on any exchange or in any market on which transactions are settled in a foreign currency,
and the assets and/or funds of the Client are displayed in the base currency of the accounts, any profit
or loss arising, as a result of a fluctuation in the rate of exchange between the traded currency and
the base currency of the accounts shall be entirely for the Client's accounts and at the Client's sole
risk. The Company is hereby authorized to convert funds in the Client's accounts into and from such
foreign currency, at such currency conversion rate based on the prevailing market rate plus/minus 1%
up to 2%.

11.2. In cases where the funds’ transactions for the Client’s accounts is effected and settled in a
foreign currency, whereby the exchange is not performed by the Company, the Client hereby
acknowledges and agrees that the Company is not liable for such conversion.

12. MARGIN REQUIREMENTS


12.1. The margin requirement is considered a collateral for each open position/transaction and is
based on the leverage applicable on the Client’s accounts. The Client agrees to maintain at all times,
without demand from the Company, margin requirements for the open positions/transactions held in
the Client's accounts. The Client will, at all times, maintain such margin or collateral for the Client's
accounts, as requested. Margin deposits shall be made by wire transfer of immediately available
funds, or by such other means as the Company may direct and shall be deemed to have been available
when received by the Company.

12.2. Accounts where the margin level has dipped to 100% or below of the required margin are
considered to be on “margin call”. Accounts on “margin call” should be supported with additional
funds or reduce their exposure by closing and/or “hedging” open positions to increase the margin
level, and remove the account from margin call status. The margin level is always visible on the Trading
Platform.

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12.3. The Client will not receive any notification or message informing them that their Account is on
margin call. It is the Client’s sole responsibility to always be aware of their margin level and act
accordingly to avoid further reduction of their margin level, which may result in a possible “stop out”.

12.4. The Client furthermore agrees and confirms that margin requirement may be changed by the
Company, with or without notice, and that such change shall be applicable to the existing open
positions/transactions as well as the transactions that shall take place in the future. In cases where
the Client does not meet obligations towards the margin requirements, the Client’s accounts becomes
subject to “stop out” activity and consequently open positions/transactions may be partially or fully
hedged and/or closed/liquidated by the Company. The price levels whereby the Company may hedge
and/or liquidate open positions/transactions are based on prevailing market prices and/or last
available prices on the specific Financial Instruments.

13. LEVERAGE
13.1. Leverage is defined as a borrowed capital, used to increase or reduce the potential return on an
investment. The Client agrees and acknowledges that marginal trading is based on the leverage
applied on the Client’s accounts. The higher leverage, the higher the level of risk and the higher
possibility of a profitable return or loss.

13.2. The leverage is subject to changes. The Company may, at any time, in its sole discretion, reduce
the leverage applied to the Client’s accounts by notifying clients about such changes.

14. LIQUIDATION OF POSITIONS/TRANSACTIONS


In the event that (a) the Client shall fail to timely deposit or maintain margin or any amount hereunder;
(b) the Client (if an individual) passes away, or be judicially declared incompetent, or placed under
curatorship or (if an entity) shall be dissolved or otherwise terminated or placed under curatorship;
(c) a proceeding under the Bankruptcy Act and/or any Legislation, an assignment for the benefit of
creditors, or an application for a receiver, custodian, or trustee shall be filed or applied for by or
against the Client; (d) attachment is levied against the Client's accounts; (e) the property deposited as
collateral is determined by the Company in its sole discretion, regardless of current market quotations,
to be inadequate to properly secure the accounts; or (f) at any time the Company deems it necessary
for its protection for any reason whatsoever, the Company may, in the manner it deems appropriate,
close out the Client's open trades in whole or in part, sell any or all of the Client's property held by the
Company, buy any securities, Financial Instruments, or other property for the Client's accounts, and
may cancel any outstanding order/request and commitments made by the Company for the Client.
Such sale, purchase or cancellation may be made at the Company's discretion without advertising the
same and without notice to the Client or his/her Business Introducer, agent and/or representative
and without prior tender, demand for margin or payment, or call of any kind upon the Client. The
Company may sell or purchase the whole or any part thereof free from any right of redemption. It is
understood that a prior demand or call or prior notice of the time and place of such sale or purchase
shall not be a waiver of the Company's right to sell or buy without demand or notice as herein provided.
Subject to applicable laws and rules, and in order to prevent non-permitted trading in debit/deficit
accounts, profits on any transactions executed without the Company's express permission, for the
Client’s account that is debit/deficit at the time the order/request is placed, shall be for the
Company's account if the Company in its discretion so elects. Losses on any such transactions shall be
jointly and severally borne by the Business Introducer, agent and/or representative if any, and the

10
Client, decision made by the Company in its sole discretion. The Client shall remain liable for and pay
the Company the amount of any deficiency in any of the Client’s account held with the Company
resulting from any transaction described above. The Company’s determination of the current market
value and the amount of additional and/or variation margin shall be conclusive and shall not be
challenged by the Client.

15. TRADING LIMITATIONS


15.1. The Client agrees and acknowledges that the Company at any time, in its sole discretion, may
limit the number of open positions/transactions which the Client may maintain or acquire with the
Company, and the Company is under no obligation to effect any transaction for the Client's accounts
which would create positions/transactions in excess of the limit which the Company has set. The Client
agrees not to exceed the position/transaction limits established for any contract market or type of
account, whether acting alone and/or with others at any given time.

15.2. The Company, in its sole discretion, reserves the right to change the leverage applied to clients’
accounts, provided that, at the time of the conclusion of the transactions, the total number of open
positions/transactions, held by the Client’s accounts, has reached the preset limitation and/or in cases
where the Client has deliberately and/or systematically based on his/her trading strategy or other
probable behaviour with an attempt to exploit the ability of using marginal trading, with the aim to
increase the potential return of an investment, while such an activity automatically increases the level
of risk and the possibility of a loss.

16. ERRORS
16.1. It is possible that errors may occur in the prices for Financial Instruments quoted by the
Company or its Service Providers due to specific market circumstance or system malfunctions,
including but not limited to errors in feeds received from data providers, counterparties, illiquidity or
any other reasons. In such circumstances, without prejudice to any rights it may have under the Law,
the Company shall not be bound by any contract which purports to have been made (whether or not
confirmed by the Company) at a price which:

a. The Company is able to substantiate to the Client was manifestly incorrect at the time of the
transaction; or
b. Was, or ought to have reasonably been known by the Client to be incorrect at the time of the
transaction.

16.2. In the above-mentioned cases the Company reserves the right to either:

a. cancel the transaction altogether,


b. correct/modify the erroneous price at which the transaction was executed to the price at which
the Company hedged the transaction,
c. correct the erroneous price alternatively to the fair market value of the price, as determined by
the Company, in its sole discretion, at the time such error occurred.

16.3. In cases where the prevailing market prices represent prices different from the prices that were
offered on Online Trading Platform(s), the Company will endeavor to execute transactions on or close
to the prevailing market prices, or at prices that the Company deems to be reasonable.

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16.4. Mistype of a quote or misquote might be given by telephone and/or electronic means. In such
occasions, the Company will not be held liable for any resulting errors that may be displayed in the
Client’s accounts and reserves the right to make necessary corrections or adjustments with respect to
the accounts involved.

16.5. Any errors (as outlined in the present clause) may adversely affect realised and unrealised gains
and losses of accounts. The Client explicitly agrees that the Company shall not be liable for any such
adverse effect, and the occurrence of pricing errors does not entitle the Client to be reimbursed with
any gains generated from such error, either by the Company or the Company's insurance providers.

17. ABUSIVE TRADING STRATEGIES


17.1. The Client undertakes not to act in any way unlawfully under this Agreement.

17.2. The Client agrees not to deliberately enter into riskless trading activity and not to trade in a
manner that would amount to any type of market abuse and/or manipulation (either by the Client
themselves or acting jointly with another person), e.g., by entering the market in opposite directions
just before a major event, which is expected to cause high market volatility.

17.3. Similarly, practices that deliberately aim to exploit negative balance protection are considered
to be abusive and therefore not acceptable by the Company.

17.4. Further, the Client understands that market abuse encompasses unlawful behavior in the
financial markets, which includes but is not limited to insider trading, unlawful disclosure of inside
information and market manipulation, and the Client furthermore undertakes not to act in any way
unlawfully under this Agreement.

17.5. Trading strategies aimed at exploiting errors in prices and/or concluding transactions at prices
that are not representing the market value, are not permitted/accepted.

17.6. The Company reserves the right to act upon clients found to be using abusive trading strategies,
whether by using sophisticated technology or manual methods when such trading is based on errors.

17.7. Clients’ trading accounts found to be using the abusive trading strategies, associated with
algorithmic and high frequency trading are subject to corrections/modifications and in cases may be
subject to closure of the trading accounts, should the Company find such an activity fit.

17.8. The Company is entitled to take one or more of the following counter measures:

a. adjust the prices provided to the Client;


b. adjust the price spreads offered to the Client;
c. change the trading conditions/limitations applied to the Client’s accounts;
d. cancel and/or reverse the transactions;
e. delay in price confirmation and/or re-quote the prices offered;
f. restrict the Client’s access to streaming, instantly tradable quotes, by providing manual
quotation only;

12
g. retrieve from the Client’s accounts any historic trading profits, provided that the Company
candocument that such trading profits have been made through exploiting of errors in
prices, at any time during the relationship with the Client;
h. deduct and/or recover any applicable charges, costs, or fees on deposits, withdrawals, as
outlined in Clause 5 above, including any other charges generally not previously applied.
This includes the right to recover such amounts if the account holder is suspected to have
engaged in abusive behavior at any time.
i. terminate the relationship with the Client immediately;
j. any other action that may be relevant for the Company to take.

17.9. Trading strategies where transactions are executed within a short time scale, may be permitted
by the Company for as long as the trading strategy used by the Client is not considered abusive.
However, should the Client base the trading strategy for the purpose of abusing prices offered by the
Company, the Company is entitled to take one or more of the above mentioned counter measures.

17.10. Swap-free offers that are provided to clients primarily engaging in normal trading activity, where
the majority of their trading volume is opened and closed within a single trading day. Clients who
solely maintain positions with negative swap values for extended periods without engaging in intraday
trading activity will be disqualified from swap-free offers or storage group benefits and the company
has the right to proceed with the necessary adjustments and terminate their account.

18. EXERCISES AND ASSIGNMENTS


With regard to options transactions, the Client understands that some exchange clearing houses
have established exercise requirements for the tender of exercise instructions and that option will
become worthless in the event that the Client does not deliver instructions by such expiration times. At
least two business days prior to the first notice day in the case of long positions in futures or forward
contracts, and at least two business days prior to the last trading day in the case of short positions in
open futures or forward contracts or long and short positions in options, the Client agrees that the Client
will either give the Company instructions to liquidate or make or take delivery under such futures or
forward contracts, or to liquidate, exercise, or allow the expiration of such options, and will deliver to
the Company sufficient funds and/or any documents required in connection with exercise or delivery. If
such instructions or such funds and/or documents, with regard to option transactions, are not received
by the Company prior to the expiration of the option, the Company may permit an option to expire. The
Client also understands that certain exchanges and clearing houses automatically exercise some “in the-
money” options unless instructed otherwise. The Client acknowledges full responsibility for taking action
either to exercise or to prevent exercise of an option contract, as the case may be; the Company is not
required to take any action with respect to an option, including without limitation any action to exercise
a valuable option contract prior to its expiration or to prevent the automatic exercise of an option,
except upon the Client's express instructions. The Client further understands that the Company also has
established exercise cut-off times which may be different from the times established by the contract
markets in clearing houses. In the event that timely exercise and assignment instructions are not given,
the Client hereby agrees to waive any and all claims for damage or loss the Client might have against the
Company arising out of the fact that an option was or was not exercised. The Client understands that
the Company randomly assigns exercise notices to clients, that all short option positions are subject to
assignment at any time, including positions established on the same day that exercises are assigned, and
that exercise assignment notices are allocated randomly from among all clients' short option positions
which are subject to exercise.

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19. SECURITY AGREEMENT
19.1. Financial Instruments, funds, securities, and/or other property in the Client's accounts or
elsewhere now or at any time in the future held by the Company for any purpose, including
safekeeping, are subject to a security interest and general lien in the Company's favor to secure any
indebtedness at any time owed by the Client to the Company, including any indebtedness resulting
from any guarantee of a transaction or of a accounts of the Client or the Client's assumption of joint
responsibility for any transaction or of a accounts. From time to time and without prior notice to the
Client, the Company may transfer interchangeably between and among accounts of the Client, held
by the Company, any of the Client's funds (including segregated funds), securities, commodities,
Financial Instruments and/or other property for purposes of margin, reduction or satisfaction of any
debit balance, or any reason which the Company deems appropriate. Within a reasonable time after
any such transfer, the Company will confirm the transfer in writing to the Client;

19.2. The Client hereby grants to the Company the right to pledge, repledge, hypothecate, or invest
either separately or with the property of other clients, any securities or other property held by the
Company for the Client’s accounts or as collateral therefore, including without limitation to any
exchange or clearing house through which transactions of the Client are executed. The Company shall
be under no obligation to pay to the Client or to his/her accounts for any interest income or benefit
derived from such property and funds or to deliver the same securities or other property deposited
with or received by the Company for the Client. The Company may deliver securities or other property
of like or equivalent kind or amount; the Company shall have the right to offset any amounts it holds
for or owes to the Client against any debts or other amounts owed by the Client to the Company.

20. AUTHORITY TO EFFECT TRANSFER


Until further notice in writing from the Client, the Company is hereby authorized at any time,
without prior notice to the Client, to transfer between any accounts of the Client, held by the Company,
or any exchange member through which the Company clears the Client’s transactions, such excess funds,
securities, commodities, commodity futures contracts, commodity options, and/or other property or
Financial Instruments of the Client as in the Company's sole judgment may be required for margin in any
other such accounts or to reduce or satisfy any debit balances in any other accounts provided such
transfer or transfers comply with relevant governmental and exchange rules and regulations applicable
to the same. The Company is further authorized to transfer any property held in any such accounts of
the Client whenever, in the Company's sole judgment, such transfer is necessary in order to effectuate
the above authorized action. Within a reasonable time after making any such transfer, the Company will
confirm same in writing to the Client.

21. INACTIVE AND ARCHIVED ACCOUNTS


21.1. The Client acknowledges and confirms that accounts, held with the Company, without any
trading activity for a period of six (6) months, are considered to be inactive accounts. Such inactive
accounts will no longer be available for trading and will be subject to relevant charge/costs relating
to the maintenance/administration of such inactive accounts.

21.2. The Client acknowledges and confirms that any accounts with the Company without any trading
activity for a period of one month or more with zero balance are considered inactive accounts.

21.3. The Client further agrees that, in order to resume trading, additional conditions set by the
Company should be met.

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21.4. The Client acknowledges and agrees that an inactive account is further considered dormant
account and removed from the systems accordingly.

21.5. The Company may, at its absolute discretion, also terminate any of the Client's additional
accounts which the Company considers that are not being used. It is clarified that a Client may open
an additional account with the Company after a purpose for the account opening is established and
justified.

21.6. Regardless if the account is active or inactive, in case the Client’s account reaches 10,000
transactions (i.e. each trade, deposit, withdrawal, maintenance charge etc. is considered as 1
transaction) the Company may choose to archive that account and replace it with a new account
number. The historical data of an account that is archived remain accessible to the client for view only
purposes.

21.7. The Client further agrees that their trading account may be terminated by the Company without
further notice if they haven't made any deposits or trades within one month of creating their account,
or as the Company may deem necessary.

22. NOTICES AND COMMUNICATIONS


The Client shall deliver all notices and communications to the Company by using any of the
available communication means, as provided on the Company’s website. All communications from the
Company to the Client may be sent to the Client at the address indicated on the Client Account
Application or to such other last known address as the Client thereafter directs in writing. In addition,
communication may be effected by telex, courier, telephone, telegraph, messenger, facsimile, electronic
mail, chatting system or otherwise (in the case of mailed notices), or communicated (in the case of
telephone notices), sent to the Client at the Client's or designated agent's or representative’s address
(or telephone number), as given to the Company from time to time, shall constitute personal delivery to
the Client whether or not actually received by the Client, and the Client hereby waives all claims resulting
from failure to receive such communication. Confirmation of transactions, balances, equity,
order/request, margin calls etc, either through statements of accounts or through Online Trading
Platform(s), shall be binding on the Client for all purposes, unless the Client calls any error therein to the
Company's attention in writing prior to the start of business on the next business day following such
occurrence and within maximum 24 hours. None of these provisions, however, will prevent the
Company, upon discovery of any error or omission, from correcting it. The parties agree that such errors,
whether resulting in profit or loss, will be corrected in the Client's accounts; the account will be credited
or debited so that it is in the same position it would have been if the error had not occurred. Whenever
a correction is made, the Company will promptly make written or oral notification to the Client. Client
agrees and understands that it is Client’s responsibility to send written notice of any change of any
personal details.

23. PRINTED MEDIA STORAGE


The Client acknowledges and agrees that the Company may reduce all documentation relating to the
Client's accounts, including but not limited to the documents provided by the Client when opening
accounts with the Company, by utilizing a printed media storage device such as micro-fiche or optical
disc imaging. The Client agrees to permit the records stored by such printed media storage devices
and/or methods to serve as a complete, true and genuine record of the Client's accounts, documents
and signatures.

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24. SAFEGUARDING OF PERSONAL INFORMATION
24.1. The Client acknowledges that the Company endeavors to safeguard and to keep the Client’s
personal and financial information (“Client’s information”), obtained for the purpose of entering into
and signing this Agreement, secure at all times. The Client further consents and acknowledges that
the Company may use Service Providers solely in the event of executing acts pursuant to and
originating from this Agreement and that the Client’s information will be further subject to
confidentiality between such parties. The Client furthermore indemnifies the Company and holds the
Company harmless from and against any and all liabilities, losses, costs, or expenses related to the
Client’s information in cases where Service Providers are used in the execution of their obligations
towards the Company and that of the Client. The personal information may be disclosed to the
Company’s affiliates or, if so required, to local or foreign regulatory authorities, fraud and prevention
agencies and other organizations involved in crime, fraud and money laundering prevention, for
assessment and statistical analysis of the Company’s business, without a prior notice to the Client.
24.2. The Company and its affiliates may use this information to keep the Client informed about other
products, services and offers (including those supplied by third parties) which the Company think may
be of interest to the Client, using the range of methods, including but not limited to post, facsimile,
electronic mail, telephone, SMS etc.

24.3. Any queries regarding data protection, including subject access requests and complaints, can be
directed to the Companys Data Protection Officer at: compliance@[Link] .

25. REPRESENTATIONS
The Client represents that:
a. (if an individual) is of the age of majority, of sound mind, and authorized to open accounts and
enter into this Agreement and to effectuate transactions in Financial Instruments as
contemplated hereby;
b. (if an entity) the Client is validly existing and empowered to enter into this Agreement and to
effect transactions in Financial Instruments as contemplated hereby;
c. the statements and financial information contained on the Client's Account Application
submitted herewith (including any financial statement therewith) are true and correct; and
d. no person or entity has any interest in or control over the accounts to which this Agreement
pertains except as disclosed within the Agreement.
e. except as heretofore disclosed to the Company in writing, the Client is not an officer or employee
of any exchange, board of trade, clearing house, or an employee or affiliate of any futures
commission merchant, or an introducing broker, or an officer, partner, director, or employee of
any securities broker or dealer, is not a US person.
f. Agree to furnish appropriate financial statements to the Company, to disclose to the Company
any material changes in the financial position of the Client and to furnish promptly such other
information concerning the Client as the Company reasonably requests.

26. INTRODUCERS
26.1. The Client, introduced to the Company through introducers, acknowledges and confirms that
the Company is not responsible for the conduct and/or representations of the introducers or its
associated persons while representing the Client to the Company. The Client agrees to waive any
claims the Client may have against the Company, and to indemnify and hold the Company harmless
for any acts or omissions of the introducer or its associated persons. The Client acknowledges and

16
confirms that the Company does not bear responsibility for whatever agreements may be reached
between the Client and the Client’s introducer. The Client furthermore confirms and acknowledges
that an introducer may act only independently or as an Agent of the Client and that the introducer is
not authorised to make representations concerning the Company or its services nor is authorised to
act on behalf of the Company as an agent or otherwise.

26.2. The Client acknowledges and confirms that the Company has the right to provide the Client’s
introducer and its associated persons with the information related to the transactions of the Client’s
accounts. The Client acknowledges, agrees and confirms that additional costs, including but not
limited to increased spread, commission, fees etc, and may be applicable in cases where the Client is
introduced to the Company through introducer, since the Company may be required to pay
commissions, fees or other related costs to the introducer and associated persons. Costs related to
transactions are provided to clients prior to commencement of business relationship or during the
business relationship in cases of changes.

27. CONFLICTS OF INTEREST


27.1. The Company, its associates or other persons connected with the Company may have an interest,
relationship or arrangement that is material in relation to any Financial Instruments affected under
this Agreement. Such interests, relationships or arrangements may not necessarily be separately
disclosed to the Clients at or prior to the time of the services offered. However, the Company, at a
minimum, shall identify with reference to the services carried out by the Company, the circumstances
which constitute or may give rise to a conflict of interest entailing a material risk of damage to the
interests of one or more Clients and specify appropriate procedures to be followed and measures to
be adopted in order to manage such conflicts.

27.2. By entering into this Agreement the Client agrees that the Company may transact such business
without prior reference to the Client. In addition, the Company may provide advice and other services
to third parties whose interests may be in conflict or competition with the Client's interests. The
Company, its Associates and the employees of any of them may take positions opposite to the Client
or may be in competition with the Client to acquire the same or a similar position. The Company will
not deliberately favor any person over the Client but will not be responsible for any loss which may
result from such competition. Upon the Client request, the Company shall provide further details of
its conflicts of interest policy.

28. CREDIT CARDS


28.1. The Client hereby confirms and acknowledges that any payments made by Credit Card, will bear
the Client’s name and will be credited into Client’s accounts held with the Company. The Client
confirms and acknowledges that the sole purpose for such payments is in accordance with the
purpose of this Agreement signed with the Company. The Client further confirms and acknowledges
that the right of the Chargeback shall not be permitted in cases when the Company has already
executed a requested transaction.

28.2. The Client hereby confirms and acknowledges that the right of the Chargeback shall not be
permitted if the Credit Card has been stolen taking into consideration the 3D secure policy, used by
the Company, by which such payments are not approved. Additionally, the Client confirms and
acknowledges that due to the type of services and activities provided by the Company, the Client is
not permitted to claim that the performance did not correspond to a written description so as to
17
cancel the services. Should the Client request the Chargeback claiming that the performance did not
correspond as per the Client’s instruction, the Client confirms and acknowledge that the Company has
the right to provide any relevant entity/person, with the required documentation in regards to such
Client’s accounts, in order to prove any transactions/allegation.

28.3. The Client confirms and acknowledges that the Company will not be held responsible regarding
any delays that may occur in regards to Credit Card transactions, caused by third parties, during the
process of such transactions, or due to any other laws/impediments given or made in any jurisdiction
at such given time of any such transactions.

28.4. In the event of a dispute related to the Chargeback, the Client agrees that the Company has the
right to withhold the Chargeback in a reserve until the dispute is finalized. The Client understands and
agrees that it may happen, as a consequence of the reserved Chargeback, that such Chargeback may
reflect on any of the transactions of the Client’s accounts.

28.5. The Client shall be liable for all and any of the costs paid to the credit card processors or banks,
other third parties, attorneys' fees and other legal expenses, and the reasonable value of the time
that the Company spent on the matter, incurred during the process of the dispute resolution.

28.6. To the extent permitted by law, the Company may set off against the balances for any obligation
and liability of the Client, including without limitation any Chargeback amounts.

29. DEPOSITS AND WITHDRAWALS


29.1. Deposits and Withdrawals are made using the authorised transfer channels in the currency
stipulated by the Company to the Client.

29.2. The Client hereby agrees and acknowledges that the Company shall consider only the net amounts
received while costs related to deposits and withdrawals shall be borne by the Client. Amounts
received in a currency other than designated account’s currency may be subject to foreign currency
exchange. Regardless of the payment method, funds are credited into clients’ accounts unless the
Company requires further information/justification/clarification regarding the deposits. The Company
reserves the right to return the funds to the sender should the originator of the funds not meet the
requirements. The Company shall not be held liable in cases where fund transfers are aimed to
support accounts that are on margin call while the funds are not received/confirmed by the Company.

29.3. The Client acknowledges and agrees that request for withdrawals from the Client’s accounts must
be received by the Company in writing using authorised communication channels. Only amounts that
are in excess of the required margin requirement can be withdrawn from the Client’s accounts. The
withdrawals are affected only upon receipt and approval of such request by the Company. The Client
further acknowledges and agrees that the Company reserves the right to withhold or reject (partially
or in whole) the Client’s request for withdrawal in cases where:

a. the requested amounts would affect the ability of the Client to carry open positions;

b. the requested amount would be required to meet the Client’s current or future requirements in
regards to carrying open positions;

18
c. the requested amount would be affected by other accounts held in the Client’s name;

d. there is a dispute between the Company and the Client related to transactions performed within
accounts held in the name of the Client or accounts linked to the Client;

e. there is reasonable doubt regarding the requests for withdrawals received by the Company;

f. there is reasonable doubt regarding the activities within the Client’s accounts;

g. the beneficiary is a third party;

h. the request for withdrawal is in currency other than the designated accounts currency;

i. the withdrawal request is not acknowledged/confirmed by the Company as authorised payment


method.

29.4. The Client acknowledges that the Company shall not be held liable for any delays or issues that
may arise during the deposit and withdrawal process.

29.5. The Company reserves the discretion to decline deposit and withdrawal transactions if the email,
telephone number, identity, address, or any other information provided or collected by the Client is
not fully verified or up to date, as determined by the Company.

29.6. The Client acknowledges and agrees that withdrawals will only be processed towards the Client.
The Company strictly prohibits withdrawals to any third party or anonymous accounts.

29.7. The Company reserves the right to decline a withdrawal request of the Client asking for a specific
transfer method and the Company has the right to suggest an alternative.

29.8. The Client further acknowledges that deposits and withdrawals facilitated via a Payment Service
Provider (PSP) are subject to the terms, policies, and procedures of the PSP as these may be found in
the PSPs website. The Company shall not be held liable for any losses, damages, or disputes arising
out of or in connection with the PSP's policies or use of the PSP's services.

29.9. The Client expressly releases the Company from any claims or actions related to the PSP's
processes, including any errors, delays, or issues that may occur in relation to the Client’s payment
transactions, and agrees to address and resolve any such claims directly with the PSP, in which case
the Company may facilitate the discussion at its sole discretion, without having any obligation as to
the resolution of the claim.

30. BINDING EFFECT OF AGREEMENT; MODIFICATIONS; TERMINATION


30.1. This Agreement shall be binding upon and inure to the benefit of the Company, its successors
and assigns, the Client’s heirs, executors, administrators, legatees, successors, personal
representatives and assigns. The Client acknowledges and accepts to be bound by the provisions of
this Agreement and any amendment or variation thereof. From time to time, as a result of changes to
the Client’s information, the Company requires to be updated with the relevant changes, related to
personal details, accounts or otherwise. In some cases, the Company may require to be provided with
additional data/documents to justify the reasoning for the [Link] addition, the Client
acknowledges and agrees that the first transaction in any of the Client’s accounts initiated by the
Client, following a change to the terms and conditions of this Agreement as abovementioned, shall
constitute the Client’s acceptance of the change as of the effective date of the amendment or
variation and such initiation and the subsequent execution of such transaction by the Company shall
19
constitute reciprocal good consideration for the variance or amendment. The Client understands that
the terms and conditions of this Agreement may be varied or amended from time to time, as case
may be and notice of such amendment of change will be provided to the Client by the Company either
by posting such change on the Company’s website or by sending a notification to the Client whereby
such amendment/variation will be applicable with immediate effect or as otherwise stated.

30.2. In the event of the incapacity/death of the Client, the Company will freeze the accounts upon
receipt of legal notification of the incapacity/death of the Client. The Client acknowledges that in the
event of his/her incapacity/death, legal notification such as letters of administration/executorships,
and/or grant of probate and/or any other legal document, will have to be provided to the Company,
by respective relevant persons over the Client in order for the Company to accept any instructions or
take any action, over any account held in the Client’s name. The Client acknowledges that the
Company will not be held responsible for any kind of losses or any charges/costs in the Client’s
accounts during the period between the Client’s incapacity/death and receipt by the Company of any
legal notice to that effect.

30.3. The Company may terminate this Agreement for any reason by providing the Client with a 7
(seven) days written notice. The Company at its absolute discretion may decide to set the client
accounts on a mode that they won’t be able to effect further new trades, however they will be able
to manage closing of the existing open ones during the notice period and or whenever the Company
deems appropriate.

30.4. In addition, the Company may terminate this Agreement with immediate effect at any time by
means of written notice if:
a. the Client is in repeated or serious breach of this Agreement;
b. The Company reasonably suspect that the information provided by the Client is false;
c. The Client has not provided recent or up to date personal information;
d. The Client fails to provide the documents that the Company requests;
e. The Company reasonably suspect that the accounts is used for an illegal purpose;
f. The Client has behaved in an abusive or threatening manner towards the Company’s staff;
g. The Company reasonably believes that the Client has changed physical location without notifying
the Company of such change;
h. The Company reasonably believes that the activities of the Client’s accounts are no longer in
accordance with the terms of this Agreement;
i. The Company reasonably determines that the Client is no longer eligible to perform the activities
in accounts;
j. A petition of bankruptcy/liquidation is presented to the Company against the Client;
k. Any other legal valid reason to take such action;
l. Accounts did not record any activities within the predefined period;
m. Legislative requirements.

30.5. The Client has the right to withdraw from or to cancel this Agreement without any reason,
obligations or liabilities, within fourteen (14) days of the account activation (the ‘Cooling-off Period’),
provided that the Client has not made any deposits or engaged in any trading activity. If the Client
fails to cancel/withdraw from this Agreement within the Cooling-Off Period, or if he has made any
deposits or engaged in any trading activity, he will be able to terminate this Agreement in accordance
with the provisions of this Clause 30.

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30.6. The Client may terminate this Agreement at any time and for any reason by actual delivery of
notice confirmed by an officer of the Company of written notice received by the Company, provided
however that no termination will affect any existing liabilities or indebtedness to the Company or any
liabilities or indebtedness that may arise subsequent to such termination in respect of any act or
omission that took place prior to such termination.

30.7. In the event of termination of this Agreement, the Company will return any amount held by the
Client’s accounts after deduction of any charges/costs and fees or any other deductions required by
the law or in accordance with this Agreement.

31. FORCE MAJEURE EVENTS


31.1. The Company may, in its reasonable opinion, determine that an emergency or an exceptional
market condition exists (a "Force Majeure Event"). A Force Majeure Event shall include, but is not
limited to, the following:

a. Any act, event or occurrence (including without limitation any strike, riot or commotion, interruption
or power supply or electronic or communication equipment failure) which, in the Company’s opinion,
prevents it from maintaining an orderly market in one or more of the investments in respects of
which the Company ordinarily deal in Financial Instruments;
b. The suspension or closure of any market or the abandonment or failure of any event upon which
the Company base, or to which the Company in any way relate, or quote, or the imposition of limits
or special or unusual terms on the trading in any such market or in any such event;
c. The occurrence of an excessive movement in the level of any Financial Instrument and/or the
underlying market or the Company’s anticipation (acting reasonably) of the occurrence of such
movements.

31.2. If the Company determines that a Force Majeure Event exists the Company may in its absolute
discretion, without notice and at any time, take one or more of the following steps:

a. Increase the Client’s accounts margin requirements;


b. Close any or all of the Client’s accounts open trades in Financial Instruments at such closing level as
the Company reasonably believe to be appropriate;
c. Suspend or modify the application of all or any of the terms of this Agreement to the extent that the
Force Majeure Event makes it impossible or impracticable for the Company to comply with the term
or terms in question; or
d. Alter the time for trading of a particular Financial Instrument.

32. HEADINGS
The headings of each provision are for descriptive purposes only and shall not be deemed to modify or
qualify any of the rights or obligations set forth in each provision.

33. GOVERNING LAW


This Agreement shall be governed by the laws of Seychelles. No action, regardless of form, arising out of
transactions under this Agreement may be brought by the Client after three months have elapsed from
the day that the cause of action arose.

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34. ACCEPTANCE OF AGREEMENT
This Agreement shall constitute an effective contract between the Company and the Client upon
acceptance by an authorized officer of the Company.

35. MULTIPLE ACCOUNTS


35.1. The Client agrees that the Company may, from time to time, change the account number
assigned to any account covered by this Agreement, and that this Agreement shall remain in full force
and effect. The Client further agrees that any account, if closed and reopened, as well as any additional
account opened in the Client's name with the Company, shall be covered by this Agreement with the
exception of any account that was opened by signing a new Client Account Agreement.

35.2. Further the Company may, at its absolute discretion, also terminate any of the Client's additional
accounts which the Company considers that are not being used. Furthermore, it is clarified that a
Client may open an additional account with the Company after a purpose for the account opening is
established and justified.

36. ASSIGNMENT
The Company may assign the Client's account to another financial institution by notifying the Client of
the name of the intended assignee and the date of the assignment, five (5) days prior to the assignment.
Unless the Client objects to the assignment in writing, prior to the scheduled date for assignment, this
will indicate the Client’s tacit acceptance and the assignment will be binding on the Client.

37. CLIENT ACKNOWLEDGMENTS AND SIGNATURE


The Client hereby declares that the Client fully understands the contents of this Agreement and agrees
to all of the terms and conditions of this Agreement set forth above. The Client further declares that
they are the real beneficiary of the accounts and that the funds deposited in the accounts come from
legitimate sources. The Client acknowledges that trading with Financial Instruments is speculative,
involves a high degree of risk and is appropriate only for those who can assume risk of loss in excess of
their margin deposits.

38. CONFIDENTIALITY
38.1. The Company acknowledges that confidential information regarding the Client's personal details
is of valuable, special and unique asset and as such belongs to the Client and that such information
will not be used to advance the interests of any persons other than the Client. The Company procures
that its employees, Service Providers, to whom the confidential information is disclosed, are informed
of such nature and the employees and the Company shall limit the disclosure of the Client's personal
information on a need to know basis only.

38.2. The Client's consent will not be required in the event where disclosure of confidential
information is required by any governmental authority or by any law or regulations requesting such
disclosure. Furthermore, the Client's personal information may be submitted to cooperate with
regulatory authorities and entities to comply with any legal official request, and as necessary to
protect any of the Company’s legal obligations and/or rights. The Company will protect the Client's
rights regarding the privacy, confidentiality and anonymity of any information furnished to the
Company and all data so furnished will be processed fairly and legally and will be collected for
specified and legitimate purposes. Additionally the Client consents that personal information may be

22
given by the Company to relevant institutions should such be required in order to perform the
activities during the business relationship.

38.3. The Client understands and agrees that the Competent Authorities are empowered to exercise
their functions and powers either:

a. directly
b. in collaboration with other authorities or with market undertakings,
c. under the competent authority’s own responsibility by delegation to such authorities or to market
undertakings or
d. by the application to the competent judicial authorities, and that the Competent Authority is
empowered with supervisory and investigatory powers in order to fulfill their duties.

38.4. The Client furthermore agrees that an individual and/or entity making the information available
to the Competent Authority, arising from this Agreement, shall not be considered to be infringing any
restriction on disclosure of information imposed by contract or by any legislative, regulatory or
administrative provision, and shall not involve the person notifying in liability of any kind related to
such notification.

39. ELECTRONIC SIGNATURE


The Client consents and agrees that the use of an electronic signature under the Electronic Signature
Law, constitutes as the Client’s signature, and has legal effect and will be admissible as evidence in any
legal proceedings in any country. The Client consents and agrees that the use of key pad, mouse or
other device constitute the Client’s signature, acceptance and agreement as if actually signed by the
Client in writing. The electronic signature is not denied legal effectiveness and admissibility as evidence
in legal proceedings solely on the grounds that it is in electronic form, or not based on a qualified
certificate, or not based upon a qualified certificate issued by an accredited certification service provider
or not created by a secure signature creation device. In addition the Client agrees that no third party
verification is necessary to the enforceability of their signature between the Client and the Company. At
the Company’s sole discretion, documents signed and transmitted online may be accepted as original
documents, and is considered to have the same binding effect as an original signature on an original
document. The Client consents to receive the information and agreements or any other document
electronically, and agreements electronically signed will be seen as electronic contracts which have been
freely entered into.

40. JOINT ACCOUNTS


Joint Accounts will be treated in accordance with the Company’s policies and local rules.

41. TRADING TERMS & CONDITIONS


41.1. The Company anticipates offering prices to its clients that are reasonably related to prices
offered by other counterparties, such prices may, however, vary. The prices offered by the Company
to the Client may differ from those offered to the Company by other counterparties. However, the
Company is under no obligation to disclose prices obtained from the counterparties to the Client. In
the event that counterparty, such as service providers, liquidity providers etc, do not provide prices,
or provide erroneous prices, during a specific period, on a specific Financial Instrument, the Client
understands and accepts that the Company may not be in a position to provide prices and may

23
therefore be obliged to reject the Client’s request/order and/or may delay the time of confirmation.
The Client furthermore acknowledges and confirms that spreads on Financial Instruments, offered
during normal market conditions, may differ in the events of volatile markets. During the volatile
markets, it may happen that the spreads offered are wider than the spreads otherwise offered. The
Client understands and accepts that the stop orders, on all types of accounts, are considered the
market orders, once alerted, and therefore, the market level of the specific Financial Instrument, at
the time of activation of the order, is taken into consideration and not the level requested by the
Client. It is further acknowledged and confirmed by the Client that the levels requested by the Client,
when placing stop orders, are not guaranteed to be completed at the requested levels, and that if
pending orders remain for more than 1 month and client has no other activity then the pending orders
will be cancelled. The Company shall have no liability for failure to execute orders/requests and makes
no representations, warranties or guarantees to the Client’s orders/requests priority over the
orders/requests of other clients. The Client shall be directly and personally responsible for performing
obligations under every transaction entered into, whether the Client is dealing as principal directly or
through a designated agent, or representative or as an agent for another person, or intermediary, and
the Client indemnifies the Company in respect of all liabilities, losses, expenses and/or costs of any
kind or nature whatsoever which may be incurred as a direct or indirect result of any failure by the
Client to perform any obligations.

41.2. The Client should request/obtain a clear explanation of all trading terms & conditions, including
any applicable charges/costs, prior to trading. For more information, please refer to the Product
Outline in the website. The Client acknowledges and consents that the Client has no right to cancel
this Agreement on the basis that it is a distance contract.

41.3. Existing trading conditions may be modified, altered, suspended or terminated or new
conditions may be imposed, which will become new applicable trading terms & conditions.
Furthermore, the Company may at any time reject, cancel, or make any adjustment which it deems
necessary, to any request made by the Client when, the Company considers, at its sole discretion, that
such request may breach or may have breached the provision of the trading terms & conditions.

42. COPY TRADING


42.1. Copy Trading
With Copy Trading Functionality clients can register a trading account to become either followers or
Providers through WB Copy Trading Platform. The clients who choose to follow the trading activities of
other clients are called ‘Followers’ whereas the clients whose trading activities are copied are called
‘Providers’. The association between a Follower and a Provider is called a ‘Subscription.’

It is important to note, that the Company has absolutely no involvement or responsibility in the
relationship between followers and providers. The Company's role is strictly limited to providing the
technology infrastructure and platform for facilitating the copy trading functionality.

In addition, the company does not offer portfolio or asset management services or provide advice to
clients regarding copy trading, and the Copy Trading functionality should not be considered as such.

Kindly note that the utilization of the Copy Trading feature offered by the Company may vary based on
the client's country of residence, potentially resulting in restrictions on its accessibility. For
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comprehensive details regarding the availability of this functionality within your specific jurisdiction, we
kindly recommend reaching out to our dedicated customer support team.

42.2. Providers

a. The Providers are required to be registered and approved by the Company or any of the Windsor
related entities that operate through the website [Link] and any other sub
domain. In addition, it is the responsibility of the Provider to ensure they possess all required
domestic and foreign governmental and regulatory licenses as may be necessary.

b. The Company at its own discretion may decide to remove and or restrict a Provider at any point in
time.

42.3. Followers

a. Followers may follow the Providers by subscribing to their account, to automatically copy their
trades at the best available market price. By choosing to copy the trades of the provider, you agree
that this will be interpreted as placing the trades yourself. A copy order will recreate the activities
of the Provider’s account in your account with the Company, on a pro rata basis and with the same
instruments based on the risk management options and copy trading strategies you may choose on
the WB Copy trading Platform.

b. In cases, where you copy a Provider from another related entity you will be limited to copying only
the instruments that are offered by the Company you are registered with. Furthermore, the
aforementioned, are subject to any regulatory restrictions that may apply to the entity your trading
account, or the Provider is registered with.

c. It is pointed out that you can copy either existing/open and new trades or only new trades from a
Provider. When choosing to copy existing trades, the Company will open your position at the best
available market price at the time of copying and not the price at the time which the trade being
copied was originally opened. Whereas, if you are copying only new trades the Company will open
your trades at the market price at the time the trades are copied. All instructions carried (stop loss,
take profit etc.) in the copied trade will be automatically replicated (pro rata) in your account. In
addition, please be aware that there may be a slight time gap between when the Provider opened
the trade and when you copied it, which could result in a price difference. Amongst other factors
such as server latency or high market volatility can contribute to the widening of this gap.

d. When choosing to copy the trading activity of a Provider, the Company will make every effort to
replicate all of the Provider’s trades in your Follower’s account. However, there are certain
situations where the Follower’s account may not have sufficient available margin to copy the
Provider’s trades, resulting in the rejection of the copying order. Furthermore, the Follower’s risk
management and copying strategies may lead to the rejection of a trade being copied by the
Follower, if the lot size of the Provider’s position falls outside the specified minimum and maximum
volume range set by the Follower. Instances of high market volatility can also result in the rejection
of trades. This can happen when the trading system, despite multiple attempts, is unable to provide
a satisfactory market price due to the high market volatility. It is important to note that rejected
trades will not be included in any reports generated.

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e. Copy trading involves automated trading execution whereby trades are opened and closed in your
account without the need for any further manual intervention. Nevertheless, you shall have at any
time the option to manually close trades that you are copying from the WB Copy Trading Platform.
You can choose to close either all trades or all unprofitable trades by using the risk management
options available in WB Copy Trading Platform. Please note that if you choose to close all trades, all
trades will be closed collectively, and you cannot select specific trades for closure. The same applies
for unprofitable trades as well.

f. In addition, it is important to note that, based on the risk management and copying strategies you
set, a materially different result than the Provider you copied may be achieved. If you decide to
unsubscribe from the Provider, all trades, whether they are profitable or unprofitable will
automatically close.

g. Other actions such as but not limited to, Provider’s withdrawals, may also generate a materially
different result than the Provider that you copied as it may affect the copy trading proportions. This
is due to several different factors including starting account balance, minimum trade size, the
investor’s account settings, differences in spread, the interest and investment price at time of
investment, and the difference in fees that may be incurred.

h. Additionally, it's essential to understand that the activation of risk parameters, determined by your
selected risk management settings, may not occur instantly but may be subject to occasional delays,
which could result in losses exceeding your chosen risk limits. In such cases, you
acknowledge and agree that the Company bears no responsibility for such losses due to system
delays.

i. When following or copying you acknowledge that you may be following or copying the trading
decisions of Providers whose experience, risk appetite, objectives and financial status is different
than yours.

42.4. Performance Fees

a. A Performance Fee is a percentage of a profitable trading result of a Follower’s subscription, which


is paid to the Provider. The fee is only earned when the profit of the Follower’s subscription
surpasses the most recent High Water Mark (HWM), which is the maximum recorded level or value
of profit that was last achieved by the Follower’s subscription. In case of a Trading result does not
surpass the High Watermark, the Performance fee calculation is skipped.

b. Performance fee calculation is determined by the (Subscription’s Closed Profit + Floating Profit/Loss)
* (Performance Fee Percentage % determined by the Provider).

c. Profit, and therefore the Performance Fee, are calculated on a Weekly Trading Interval. The
calculation can be determined by the difference between the current equity, and the equity of the
previous week. Equity is your account balance plus the floating profit (or loss) of all your open trades.

d. The Performance Fee % is determined by the Provider based on the offer they want Followers to
subscribe to, but the formula is always the same: Performance fee = Subscription’s Profit x Fee %

26
e. The Performance fee % can be is determined by the Provider based on the offer they allow followers
to subscribe to. In general, Performance fee is calculated as:

Performance fee = Subscription’s Profit * Fee %


For example:

Performance Fee = 10%

Week 1 PnL = $400 → $40 Performance fee


Week 2 PnL = -$200 → No Fee ($400 - $200 = $200 < $400 HWM)
Week 3 PnL = $300 → $10 Performance fee ($400 - $200 + $300 = $500; $500 - $400 = $100)

The Company ensures that the performance fee information will be readily accessible to both
followers and providers. The performance fee details, including calculations and payout history,
will be available on the WB Copy Trading platform at all times. This allows followers and
providers to track and monitor the performance fee amounts and associated transactions.

42.5. Performance Fee Payout

a. WB Copy Trading initiates the payment of Performance Fees to the Provider from each Follower
subscription weekly. Once the weekly trading interval ends, WB Copy Trading initiates the
payment of performance fees to the Provider from each Follower subscription. The amount is
withdrawn from the Follower’s trading account and recorded as a fee.

b. When a Follower initiates the withdrawal process from their account, the Company Conducts a
thorough assessment to calculate the performance fees owed by the Follower. This evaluation
is carried out for all Withdrawal methods. It is important to note that the client will not be able
to withdraw an amount greater than the available equity in their account minus the
performance fees owed. Once the payment transaction is initiated, the performance fees owed
are paid in full to the Providers, regardless of the size of the withdrawal. This ensures that the
Providers receive their performance fees in a timely manner.

c. In addition, If a Follower decides to withdraw funds or unsubscribe from the Provider before the
end of the weekly trading interval, the performance fee will be calculated up to that point in
time and the payout will occur immediately upon requesting to withdraw funds, or upon ending
the subscription to the Provider.

42.6. Inactive Accounts

For both Providers and Followers, an account is considered inactive if there has been no trading
activity as specified in the clause ‘INACTIVE AND ARCHIVED ACCOUNTS’ of this Client Account
Agreement (CAA). All inactive Providers’ and Followers’ accounts should be subject to the
provisions of this clause, and they may be terminated accordingly.

42.7. Termination

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For both Providers and Followers, termination of their account is subject to the termination
clause outlined in this CAA.

42.8. Miscellaneous
 Clients can either use their trading accounts as followers or providers, but not both
simultaneously. It is important to note that a client cannot utilize their Follower account to
follow their Provider account. Furthermore, it is not possible for a Provider to follow another
Provider.
 Each follower trading account can only subscribe to one Provider at a time. To follow multiple
Providers, clients need to open additional trading accounts.
 Follower accounts can be funded via an internal transfer from other trading accounts owned by
them. However, it is important to note that follower accounts are not permitted to initiate
internal transfers or transfer funds to other trading accounts.
 Clients are not allowed access to the trading terminal of their Follower accounts. Management
of trades of a Follower account is done using the WB Copy Trading platform. Whereas clients
are allowed access to the trading terminal of their Provider accounts as per usual.
 The Company reserves the right at any time to modify, expand, or revise the functionalities of
the copy trading functionality as it sees fit. This includes the ability to add, remove, or change
the options available to users when it comes to copying trades from a Provider. The specific
changes may include, but are not limited to, the ability to copy all trades of a Provider or only to
copy new trades.
 The Company may add, remove, or change the functionalities of the copy trading service, at its
discretion, for example whether you can copy all trades or only new trades of a Provider.
 The Provider explicitly agrees that the Company is authorized to disclose the Provider's details
and performance ratios, to ensure transparency and enable potential followers to thoroughly
evaluate the Provider's performance. The Provider fully acknowledges and grants consent to the
Company for sharing such information. The Company reserves the right to disclose these details
to its related entities, on its website and its official communication channels.
 It is understood and agreed the relationship between the Company and the Providers is that of
independent contractors. No agency or partnership is created, and the Provider shall not hold
itself out as or represent itself to be an agent, representative or employee of the Company.
Furthermore, the Provider agrees that no promotional material shall be disclosed or distributed
without the prior written approval of the Company.
 Any explanation or information which the Company provides about copy trading is provided
solely for informational purposes. In addition, any information that may be shared by the
Providers cannot be considered as a financial advice and in any case does not bind the Company.
 Past performance, risk scores, statistics and any other information should not be considered as
reliable indicators of future performance. Such information does not mean that you will achieve
profits like those shown on the Provider that you are copying.
 The Company reserves the right to restrict the usage of certain symbols for Copy Trading. This
implies that while the Provider can trade these symbols, the Follower is not permitted to copy
trades involving these symbols. This information is clearly stated in the MT4 Product Outline
available on the Company's website.

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 The Provider may, at their discretion, cooperate with Agents, including Public Agents and
Additional Agents, to facilitate the referral of followers who will register with them. For this
service, the Agents will receive a percentage from the performance fee that the Provider collects
from the followers. These arrangements are set by the Provider through their portal on the WB
Copy Trading Platform or by the Company at the Provider request through official Company's
channels. The Provider understands and agrees that these arrangements are separate
agreements between the Provider and the public and additional agents, and the Company is not
a party to these agreements.
The Company shall not be liable for any percentage-based compensation arrangements, or any
other arrangement made between the Provider and the public or additional agents. Any
disputes or issues arising from these arrangements are the sole responsibility of the Provider
and the respective agents. The Provider agrees to indemnify and hold the Company harmless
from any claims, disputes, or liabilities related to these arrangements.
42.9. Liability

a. The Provider hereby covenants and agrees to indemnify and keep harmless the Company, its
directors, officers, employees and agents from and against any claims, demands, actions, causes
of action, damages, losses, costs, liabilities, expenses, penalties or fines (including legal fees)
which any of the Company’s Indemnified parties may sustain and may arise directly or indirectly
in any way by reason of, out of, in respect of or in connection with:
I. any non-fulfillment of any covenant or agreement on the part of Provider under this
Agreement;
II. any incorrectness in or breach of any representation of Provider contained in this
Agreement;
III. any act or omission, including, without limitation, any negligence or other tortuous act,
committed by Provider and its directors, officers, employees, agents and representatives
in the performance of its obligations under this Agreement;
IV. any untruth, inaccuracy or incorrectness of any of the marketing materials prepared and
distributed by Provider pertaining to the Services;
V. any advice, recommendation given or made by the Provider to any third party and or any
other activities that require authorization and or licensing as per the applicable Laws;
VI. any activities performed by the Provider outside the scope of this Agreement and or any
damages that may be caused, directly or indirectly, by the Provider to third parties.
b. The Follower acknowledges and agrees that they may not hold the Company liable for any
actions taken by the Company when following your(s) instructions or for any results from your(s)
own decisions to follow or copy any Providers.

c. The Follower acknowledges that any financial or non-financial outcomes resulting from such
decisions are the sole responsibility of the Client, and the Company shall not be held accountable
for any associated results or implications.

d. Copy trading carries a high level of risk, and Follower's should carefully consider their objectives,
financial situation, and risk tolerance before engaging in copy trading. The performance of the
Providers is not guaranteed and may result in the loss of invested capital.

29
e. By participating in the Copy Trading functionality offered by the Company, both Followers and
Providers explicitly agree to release the Company from any and all claims, demands, and
liabilities related to the trades copied, Providers followed or any issues arising from their
interaction with each other.

43. COMPLAINT HANDLING


43.1. The Company cares about keeping its clients happy and satisfied with its services. In instances
where the Client may not be satisfied, the Company has established an effective and transparent
procedure for the immediate complaint handling of all existing clients.

43.2. The Clients may lodge a complaint with the Company via mail or email, or by personally
attending the Company’s office, or via utilizing the complaint box available at the Company’s office,
as applicable from time to time.

43.3. The Company will work to address the complaint and communicate the decision to the Client
within a reasonable period (eg., a period not exceeding fifteen (15) days from the date of receipt of
the complaint, or more based on the circumstances of the complaint). This period may be extended
once and for a similar period if the nature of the Complaint so requires.

43.4. In the unlikely event that the Company is unable to resolve the Client’s complaint, or if the Client
is not satisfied with the Company’s final response, the Client may refer his complaint to the Financial
Services Authority (FSA) in the Seychelles for further examination.
The contact details for the Financial Services Authority (FSA) in Seychelles are set out below:

Address: PO Box 991


Bois de Rose Avenue
Roche Caiman Victoria, Mahe, Republic of Seychelles
Phone: (+248) 438 08 00
Fax: (+248) 438 08 88
Website: [Link]
Email: enquiries@[Link]

43.5. For additional information,, you can refer to the Company’s Complaint Handling Policy, available
on the Company’s website.

44. ABOUT US
More Information can be found on the website and under the ‘About’ section.

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ONLINE ACCESS AGREEMENT
This Online Access Agreement (the “Online Agreement”) sets forth the terms and conditions under which the
Company shall permit the holder of one or more accounts with the Company (the “Client”) to have access to
one or more terminals, one or more Online Trading Platforms, through the Client’s internet browser, for the
electronic transmission of orders/requests and/or transactions, for the Client’s accounts held with the
Company. This Online Agreement sets forth the terms and conditions under which the Company shall permit
the Client electronically to execute and monitor the activity, orders/requests and/or transactions in the Client
accounts (collectively, the "Online Service"). For purposes of this Online Agreement the term "Online Service"
includes all software and communication links, or any of its functions, provided that the Company deems it
necessary, the Client agrees to the following:

1. LICENSE GRANT AND RIGHT OF USE


By signing this Online Agreement, the Company agrees to supply the Client with software for using the Online
Service. The Client agrees to use the software solely for the ordinary course of its own internal business. The
Client agrees that neither the software nor the Online Service may be used to provide third party training or
to be used as a service bureau for any third parties. The Client agrees to use the Online Service and the
software strictly in accordance with the terms and conditions of Client Account Agreement, as amended from
time to time. The Client also agrees to be bound by any rules, procedures and conditions established by the
Company concerning the use of the Online Service.

2. ACCESSES AND SECURITY


2.1. The Online Service may be used to transmit orders/requests, receive and confirm execution of
orders/requests, subject to prevailing market conditions and applicable rules and regulations. The Company
consents to the Client’s access, in reliance with the safeguarding procedures, adopted by the Client for
preventing unauthorized access to and use of the Online Service, and in any event, the Client agrees to any
financial liability for transactions executed through the Online Service. The Client acknowledges, represents
and warrants that:

a. The Client has received a number, code or other sequence which provides access to the Online
Service (the "Password");
b. The Client is the sole and exclusive owner of the Password;
c. The Client is the sole and exclusive owner of any identification number or Account number or Login
number (the "Login"); and
d. The Client accepts full responsibility for use and protection of the Password and the Login as well as
for any transaction occurring in accounts opened, held or accessed through the Login and Password.
e. The Client agrees that the Company has the right to “reset” the Password, for security purposes, if
the accounts have been inactive for a certain period of time.

2.2. The Client accepts full responsibility for monitoring accounts’ activities. The Client agrees to
immediately notify the Company in writing, should the Client become aware of any of the following:

a. any loss, theft or unauthorized use of the Client’s Password and/or Login number; or

31
b. any failure by the Client to receive a message indicating that an order/request was received and/or
executed; or
c. any failure by the Client to receive an accurate confirmation of an execution; or
d. any receipt of confirmation of an order/request and/or execution of an order/request which the
Client did not order/request; or
e. any failure to receive accurate information for the Client’s accounts balances, positions/transactions,
or transaction history; or
f. any other reason whatsoever.

3. MULTI-TERMINAL FUNCTION OF THE ONLINE SERVICE


3.1. Multi-Terminal shall mean one of the functions provided by one or more Online Trading Platforms
offered by the Company, through Online Service, which can be used by the Client for simultaneous
management of multiple accounts. The Multi-Terminal function of the Online Trading Platform, offered
through Online Service, is granted to Clients in the Company’s sole discretion.

3.2. In cases where the Company permits the Client to have access to the Multi-Terminal, the Client
agrees and acknowledges the following:
a. The Company reserves the right, if it is deemed necessary, to delay confirmation of orders/requests
and/or transactions for the Client’s accounts;

b. The Company reserves the right, if it is deemed necessary, to reject partially or in full any request for
such orders and/or transactions for the Client’s accounts;

c. The Company reserves the right, if it is deemed necessary, not to execute all orders/requests and/or
transactions for the Clients’ accounts in the same manner;

d. The Company reserves the right, if it is deemed necessary, to reverse any orders/requests and/or
transactions for the Client’s accounts.

3.3. In addition, the Client agrees that any orders/requests and/or transactions should not exceed the
number of lots, per Financial Instrument, as specified within the Client’s Online Trading Platform or any other
additional documentation provided by the Company for the specific type of account.

4. RISKS OF ONLINE TRADING


4.1. Access to the Online Service or any portion thereof, may be restricted or unavailable during periods
of peak demands, extreme market volatility, systems upgrades or any other reasons. The Company or its
Service Providers makes no express or implied representations or warranties to the Client regarding the
usability, condition or operation thereof. The Company or its Service Providers does not warrant that access
to or use of the Online Service will be uninterrupted or error free or that the Online Service will meet any
particular criteria of performance or quality. The Company or anyone else involved in creating, producing,
delivering or managing the Online Service shall, under no circumstances including negligence, be liable for
any direct, indirect, incidental, special or consequential damages that result from the use of or inability to
use the Online Service, or out of any breach of any warranty, including, without limitation, those for business
interruption or loss of profits.

4.2. The Client expressly agrees that the use of the Online Service is at Client’s sole risk. The Client
acknowledges full responsibility and risk of loss that may result from use of, or materials obtained through,
the Online Service. Neither the Company nor any of the Company’s directors, officers, employees, agents,
32
contractors, affiliates, third party vendors, facilities, information providers, licensors, exchanges, clearing
organizations or other suppliers providing data, information, or services, warrant that the Online Service will
be uninterrupted or error free, nor does the Company make any warranty as to the results that may be
obtained from the use of the Online Service or as to the timeliness, sequence, accuracy, completeness,
reliability or content of any information, service, or transaction provided through the Online Service.

4.3. In the event where the Client’s access to the Online Service, or any portion thereof, is restricted,
unavailable or delayed, the Client agrees to use other available means (if any), provided by the Company, to
place the Client’s orders/requests for transactions or to access information. The Company is not liable for
any losses, lost opportunities or increased costs, increased commissions etc. that may result from the Client’s
inability to use the Online Service to place orders/requests for transactions, receive confirmation for
transactions or access information. By placing orders/requests through the Online Service, the Client
acknowledges that the Client orders/requests may not be reviewed by the Company prior to execution. The
Client agrees that the Company is not liable for any losses, lost opportunities or increased costs, increased
commissions/charges/costs etc. that may result from the execution of orders/requests made by the Client.

5. MARKET DATA AND INFORMATION


5.1. Neither the Company nor any Service Provider shall be liable in any way to the Client or to any other
person for:

a. Any inaccuracy, error or delay in, or omission, non-performance, interruption of any such data,
information or messages or the transmission or delivery of any such data, information or messages; or
b. Any loss or damage arising from or occasioned by any such inaccuracy, error, delay, omission, non-
performance, interruption in any such data, information or message, due to either any negligent act or
omission or to any condition of force majeure or any other cause, whether or not within the Company’s or
any Service Providers’ control.

5.2. The Company shall not be deemed to have received any orders/requests or communication
transmitted electronically by the Client, through Online Service, until the Company has actually
acknowledged such orders/requests or communication.

6. ADDITIONAL IMPORTANT INFORMATION AND DISCLAIMERS REGARDING EXPERT ADVISORS


The Expert Advisors are provided by one or more Online Trading Platforms offered by the Company, through
Online Service, and are intended merely as a tool for implementing technical ideas that can be incorporated
into a personally designed trading strategy or system for experienced traders only. No support, technical,
advisory or otherwise, is offered by the Company in their usage. Use of the Expert Advisors are entirely at
the Client’s own risk and the Client acknowledges and understand that the Company makes no warranties or
representations concerning the use of Expert Advisors and that the Company does not, by implication or
otherwise, endorse or approve of the use of the Expert Advisors and shall not be responsible for any loss to
the Client occasioned by their usage.

7. REPRESENTATIONS
7.1. The Client acknowledges that from time to time, and for any reason, the Online Service may not be
operational or may be otherwise unavailable for the Client’s use due to servicing, hardware malfunction,
software defect, service or transmission interruption or any other cause, and the Client agrees to hold the
Company and any Service Provider harmless from liability of any damages which may result from the

33
unavailability of the Online Service. The Client acknowledges that the Client has alternative arrangements
which will remain in place for the transmission and execution of the Client’s orders/requests, in the event
that for any reason, circumstances prevent the transmission and execution of all, or any portion of, the
Client’s orders/requests through the Online Service.

7.2. The Client represents and warrants that the Client is fully authorized to enter into this Online
Agreement and is under no legal impediment which prevents the Client from trading, and that the Client is
and shall remain in compliance with all laws, rules and regulations applicable to the Client’s business. The
Client agrees that the Client is familiar with and will abide by any rules or procedures adopted by the
Company and any Service Provider in connection with use of the Online Service. The Client further
acknowledges to have obtained necessary training in its use.

7.3. The Client shall not (and shall not permit any third party) to copy, use analyze, modify, decompile,
disassemble, reverse engineer, translate or convert any software provided to the Client in connection with
use of the Online Service or distribute the software or the Online Service to any other third party.

8. BINDING EFFECT OF ONLINE AGREEMENT; MODIFICATIONS


The Client acknowledges and accepts to be bound by the provisions of this Online Agreement and any
amendment or variation thereof duly effected in accordance with the provisions of this clause 8. Unless
otherwise provided for in this Online Agreement, the Company may change the general terms and conditions
of this Online Agreement at any time by updating the Online Agreement on the Company’s website and the
Client is required to inquire for any updates that may be made to the Online Agreement during the business
relationship with the Company. Seven working days after publication of the update on the Company’s
website, it will be deemed that the Client has read and accepted the general terms and conditions included
within the Online Agreement, and that the same will be applicable to the Client. The Client acknowledges
and agrees that the first transaction in any of the Client’s accounts, initiated by the Client, following
notification of a change to the terms and conditions of this Online Agreement, as abovementioned, shall
constitute the Client’s acceptance of the change as of that date, and such initiation and the subsequent
execution of such transaction by the Company shall constitute reciprocal good consideration for the variance
or amendment abovementioned, the sufficiency of which is hereby acknowledged and agreed by the Client
and the Company respectively. Unless the context clearly indicates otherwise, a reference to this Online
Agreement will include a reference to this Online Agreement as varied or amended from time to time in
accordance with this clause 8. The Company may terminate this Online Agreement at any time by means of
written notice to that effect. The Client may terminate this Online Agreement at any time by a written notice
confirmed by the Company provided however that no termination will affect any existing liabilities or
indebtedness to the Company or any liabilities or indebtedness that may arise subsequent to such
termination in respect of any act or omission that took place prior to such termination. Upon termination,
any software license granted to the Client herein shall automatically be terminated.

9. INDEMNITY
The Client agrees to indemnify and hold the Company harmless and each Service Provider and their
respective principles, affiliates and agents from and against all claims, demands, proceedings, suits and
actions and all losses (direct, indirect or otherwise), liabilities, costs and expenses (including attorney fees
and disbursements), paid in settlement, incurred or suffered by the Company and/or Service Providers
and/or the Company’s or their respective principals, affiliates and agents arising from or relating to the
Client’s use of the Online Service or the transactions contemplated hereunder. This indemnity provision shall
survive termination of this Online Agreement.
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10. MISCELLANEOUS
10.1. The Client shall not be permitted to amend the terms of this Online Agreement. The Company may
amend the general terms and conditions of this Online Agreement. By continued access to and use of the
Online Service, the Client agrees to any such amendments to this Online Agreement.

10.2. This Online Agreement is the entire Agreement between the parties relating to the subject hereof,
and, except with respect to the Client Account Agreement between the parties, all prior negotiations and
understandings between the parties, whether written or oral, are hereby merged into this Online Agreement.
Nothing in this Online Agreement shall be deemed to supersede or modify any party's rights and obligations
under the Client Account Agreement.

11. GOVERNING LAW


This Online Agreement shall be governed by the laws of Seychelles.

12. ACCEPTANCE OF ONLINE AGREEMENT


This Online Agreement shall constitute an effective contract between the Company and the Client upon
acceptance by an authorized officer of the Company.

13. RECIPIENT ACKNOWLEDGMENTS AND SIGNATURE


The Client hereby declares that the Client has read and fully understands and agrees to all the terms and
conditions of this Online Agreement set forth above.

Each of the undersigned herein agrees to the terms and conditions as set forth in this Online Access
Agreement.

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MOBILE TRADING AGREEMENT
This Mobile Trading Agreement (the “MT Agreement”) sets forth the terms and conditions under which the
Company shall permit the holder of one or more accounts with the Company (“the Client”) to have access to
accounts, through mobile devices. This MT Agreement sets forth the terms and conditions under which the
Company shall permit the Client electronically to monitor the activity, place orders and/or execute
transactions for the Client’s accounts (collectively, the "Mobile Trading Service"). For purposes of this MT
Agreement the term “Mobile Trading Service" includes all software and communication links, or any of its
functions, downloaded onto the Client’s mobile devise and in consideration thereof, the Client agrees to the
following:

1. GENERAL
1.1. By entering into and signing this MT Agreement, the Client agrees to use the Mobile Trading Service
solely for the purpose of accessing accounts via the mobile device. The Mobile Trading Service is provided
for specific mobile devices that can be viewed on the Company’s website. The Client agrees to use the Mobile
Trading Service strictly in accordance with the terms and conditions set by the Company's Client Account
Agreement and all other documents that collectively form the agreement between the Company and the
Client (“AOD”), as amended from time to time. Client also agrees to be bound by any rules, procedures and
conditions established by the Company concerning the use of the Mobile Trading Service.

1.2. This MT Agreement shall be exclusively applied to the Client’s use of the Mobile Trading Services, in
addition to the terms set by the Company within Online Access Agreement. Unless separately defined in the
MT Agreement, expressions capitalized in the MT Agreement shall have the meanings given to them in the
AOD. In cases of any inconsistency between the provisions of the MT Agreement and the provisions of AOD,
insofar as it relates exclusively to the Client’s use of Mobile Trading Service, the MT Agreement shall prevail.

1.3. The Client acknowledges that accessing accounts using a mobile device is at his/her own risk and that
such access will not be error free or always operate as expected.

2. ACCESS AND SECURITY


2.1. For using Mobile Trading Service, the Client should hold accounts and have available access to the
Username/Login and Password. Mobile Trading Service may offer limited functionality and information
compared to the functionality and information available by accessing accounts, using Online Service.

2.2. The functionality and information provided when accessing accounts through Mobile Trading Service
are subject to change without prior notice.

2.3. The Client understands and accepts that the Mobile Trading Service may be provided through Service
Providers. All information shall be treated with confidentiality at all times, and furthermore the Client
undertakes to indemnify the Service Providers and the Company against any and/or all losses, expenses,
damages, any inaccuracy, error or delay in, or omission, non-performance, interruption of any such data,
information or messages or the transmission or delivery of any such data, information or messages; and/or
any losses and/or damages arising from and/or occasioned by any such inaccuracy, error, delay, omission,
non-performance, interruption in any such data, information or message, due to either to any negligent act
or omission or to any condition of force majeure or any other cause, whether or not within the Company or
any Service Providers’ control.

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2.4. The Client acknowledges and agrees that the Mobile Trading Service is provided without any
representations or warranties, to the extent permitted by law, as to the compatibility, security and accuracy
of the Mobile Trading Service. Any material downloaded or otherwise obtained through the use of the Mobile
Trading Service is carried out at the Client’s own discretion and risk.

3. RESPONSIBILITIES AND LIABILITIES


3.1. Mobile Trading Service is not directed at or intended to be used by any person in any jurisdiction or
country where such use and/or distribution would be contrary to local law and/or regulation. It is the Client’s
responsibility to ensure that using Mobile Trading Service would not be in a breach with any local law or
regulation to which the Client is a subject to.

3.2. The Client agrees that the use of Mobile Trading Service shall not lead, in any way, to the
encouragement, procurement or carrying out of any criminal or unlawful activities. Furthermore, the Client
agree that the use of Mobile Trading Service will not cause damage to Mobile Trading Service or our servers,
systems or equipment or those of third parties, nor access or attempt to access any users' data or to
penetrate or attempt to penetrate Mobile Trading Service’s security measures.

3.3. The Client is responsible for keeping the Username and Password of accounts confidential at all times
ensuring that all reasonable steps are taken in order to prevent fraudulent use of this information. Any access
to accounts, using the Client’s Username and Password, will be deemed to have been done by the Client. In
cases where the Client suspects that the information has been obtained by any other person without the
Client’s consent, it is the Client’s responsibility to notify the Company immediately. In failing to do so, the
Client will be liable for any such “unauthorized” access to accounts.

3.4. The Client hereby accepts any and all risks, including but not limited to, failure or damage to
hardware, software, and communication lines of systems while using Mobile Trading Service. The Client
further acknowledges full liability for any losses, costs, or expenses which may arise directly or indirectly from
the Client’s use of, or reliance on, the Information provided by the Mobile Trading Service.

3.5. The Client is responsible to notify the Company in the event of a delay or defect in or failure of the
whole or any part of the Mobile Trading Service.

4. THIRD PARTIES
Mobile Trading Service may be provided by a distributor or other third party. The Client’s personal data used
for the purpose of accessing accounts will be treated with a strict confidentiality. In cases where the Mobile
Trading Service is provided by a distributor or a third party, the Company will do its outmost as to ensure
that such information is treated in the same manner. However, the Client should acknowledge that such
personal data may be passed by the third party service provider according to the agreement so signed
between the Company and the third party service provider in order to effect the service, and/or personal
data bay be passed onto third parties in cases where it is so required by law or court order at such given time
and place.

5. INDEMNITY
5.1. The indemnity provision in this clause applies exclusively to this MT Agreement and is separate from
and in addition to the indemnity provision set out within the AOD. In case of any conflict between the

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indemnity provision of the MT Agreement and AOD to the extent where the provisions relate to the subject
matter of the MT Agreement, the provisions in the MT Agreement will prevail.

5.2. The Company does not warrant that any software downloaded onto the Client’s mobile device will
operate without interruption or be error free nor implicitly guarantee any level of service. Additionally the
Company does not guarantee as to the accuracy, suitability, reliability, completeness, or performance of the
Mobile Trading Service. The Mobile Trading Service may be adversely affected by factors such as the
limitations of the Client’s mobile device, network performance and other factors which are beyond the
Company’s control and may fail to operate satisfactorily or at all. The Company will not be liable to any
planned or unplanned downtime or any outages on any mobile device network or in cases where the Client
is not in an area of mobile coverage, at any given time or place.

5.3. The Company will have no liability in relation to any loss or damage that may result due to any delay
or defect in or failure of the whole or any part of Mobile Trading Service, provided that the occurrence of the
delay, defect or failure was beyond the Company’s reasonable control. However, in cases where any defect
of failure of the Mobile Trading Service, which is beyond the Company’s reasonable control, results in
disagreement between records kept by the Company and those of the Client, the version of events supported
by the Company’s records will prevail.

6. CHARGES
The Client acknowledges that Mobile Trading Service may be subject to charges in cases where the access is
obtained when in different jurisdictions, however, the Company will not apply any charge for the use of the
Mobile Trading Service.

7. SEVERABILITY
In cases where any provision of this MT Agreement is determined to be void or unenforceable, the remaining
provisions set by AOD shall remain valid and be given full force and effect.

8. VARIATIONS TO THIS AGREEMENT


The version of MT Agreement posted on the Company’s website will be considered as the version that will
be in force at any given time. Terms of the MT Agreement may be amended at any time. Any such
amendment will be published on the Company’s website and Client acknowledges and agrees that the first
transaction effected in any of the Client’s accounts, initiated by the Client, following any such amendment,
shall constitute the Client’s acceptance of the change. Should the Client wish not to be governed by the
amended MT Agreement, it is the Client’s responsibility to cease using the Mobile Trading Service
immediately.

9. TERMINATION
9.1. The Company reserves the right to suspend or terminate the Client’s access to or use of Mobile
Trading Service, in addition to the Client’s access to Online Trading Platform, if the Company determines, in
its sole discretion, that the Client has in any way breached the agreement between the parties based on any
of the terms and conditions so accepted by the Client.

9.2. The Company may terminate all or part of Mobile Trading Services at any time. The Company shall
not be liable to the Client or any other person if any or all Mobile Trading Service is modified or terminated.

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10. GOVERNING LAW
This Agreement is governed by laws of Seychelles and subject to the jurisdiction of the Seychelles courts.
Thus, this Agreement has been thoroughly read, understood and accepted by the Client on the signing of the
MT Agreement.

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RISK DISCLOSURE STATEMENT
This brief statement does not disclose all risks and other significant aspects related to trading with Financial
Instruments such as futures, options, commodities, contracts for differences, foreign exchange and other
instruments ("Financial Instruments"). In light of the risks, the Client should undertake such transactions only
if the Client understands the nature of the Financial Instruments (and contractual relationships) into which
the Client is entering and the extent of the Client’s exposure to risk.

Trading with Financial Instruments is not suitable for many members of the public. The Client should carefully
consider whether trading is appropriate for the Client in the light of the Client’s experience, objectives,
financial resources and other relevant circumstances.

1. FUTURES
1.1. Effect of “Leverage” or “Gearing”
Transactions in futures carry a high degree of risk. The amount of initial margin is small relative to the value
of the future contracts so that transactions are "leveraged" and "geared." A relatively small market
movement will have a proportionately larger impact on the funds deposited or will have to be deposited by
the Client; this may work against the Client as well as for the Client. The Client may sustain a total loss of
initial margin funds and any additional funds deposited with the Company to maintain the Client’s open
positions/transactions. If the market moves against the Client’s open positions/transactions or margin levels
are increased, the Client may be called upon to pay substantial additional funds on short notice to maintain
the Client’s open positions/transactions. If the Client fails to comply with a request for additional funds within
the time prescribed, the Client’s open positions/transactions may be liquidated with a loss and the Client will
be liable for any resulting deficit.

1.2. Risk-reducing orders/requests or strategies


The placing of certain types of orders/requests (e.g., "stop-loss" order/request, or "stop-limit" order/request,
where permitted) which are intended to limit losses of open positions/transactions to certain amounts, may
not be effective because market conditions may make it impossible to execute such orders/requests.
Strategies using combinations of positions/transactions, such as "spread" and “straddle"
positions/transactions may be as risky as taking simple "long" or "short" positions/transactions. The Client
should get familiar with the execution venues related to specific types of orders/requests.

2. OPTIONS
Transactions in options carry a high degree of risk. Purchasers and sellers of options should familiarize
themselves with the type of option (i.e. “put” or “call”) which they contemplate trading and the associated
risks. The Client should calculate the extent to which the value of the options must increase for the Client’s
open position to become profitable, taking into account the premium and all transaction costs. The purchaser
of options may offset or exercise the options or allow the options to expire. The exercise of an option results
either in a cash settlement or in the purchaser acquiring or delivering the underlying interest. If the option is
on a future contract, the purchaser will acquire a futures open position with associated liabilities for margin
(see the section on Futures above). If the purchased options expire worthless, the Client will suffer a total
loss of the Client’s investment which will consist of the option premium plus transaction costs. If the Client
is contemplating purchasing deep-out- of-the-money options, the Client should be aware that the chance of
such options becoming profitable ordinarily is remote. Selling ("writing" or "granting") an option generally
entails considerably greater risk than purchasing options. Although the premium received by the seller is

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fixed, the seller may sustain a loss well in excess of that amount. The seller will be liable for additional margin
to maintain the position if the market moves unfavorably. The seller will also be exposed to the risk of the
purchaser exercising the option and the seller will be obligated to either settle the option in cash or to acquire
or deliver the underlying interest. If the option is on a future, the seller will acquire a position in a future with
associated liabilities for margin (see the section on Futures above). If the option is "covered" by the seller
holding a corresponding position in the underlying interest or a future contract or another option, the risk
may be reduced. If the option is not covered, the risk of loss can be unlimited. Certain exchanges in some
jurisdictions permit deferred payment of the option premium, exposing the purchaser to liability for margin
payments not exceeding the amount of the premium. The purchaser is still subject to the risk of losing the
premium and transaction costs. When the option is exercised or expires, the purchaser is responsible for any
unpaid premium outstanding at that time.

3. OFF EXCHANGE TRANSACTIONS / OTC


The Company is acting as the Client’s counterparty to the off exchange (“OTC”) transaction. It may be difficult
or impossible to liquidate an existing open position/transaction, to assess the value, to determine a fair price
or to assess the exposure to risk and for these reasons, these transactions may involve increased risks. Off-
exchange transactions may be less regulated or subject to a separate regulatory regime due to the fact that
there is no exchange or central clearing house to support the transaction. Before the Client undertakes such
transactions, the Client should familiarize himself/herself with applicable rules and related risks. The Client
should get familiar with the execution venues related to specific types of orders/requests and Financial
Instruments.

4. FOREIGN EXCHANGE
4.1. Foreign Exchange can be highly volatile and transactions therein carry a substantial risk of loss.

4.2. The high degree of “gearing” or “leverage” which is often obtainable in trading stems from the
payment of what is comparatively modest deposit or margin when compared with the overall contact value.
As a result, a relatively small market movement can, in addition to achieving substantial gains, where the
market is in the Client’s favor, result in substantial loss which may exceed the Client’s original investment
where there is an equally small market movement against the Client.

4.3. The Client’s risk exposure increases if the Client’s transactions are denominated in a foreign currency
or in a basic currency.

4.4. The Client should get familiar with the execution venues related to specific types of orders/requests
and Financial Instruments.

5. CONTRACT FOR DIFFERENCES (CFDs)


5.1. Financial instruments can also be traded as contracts for differences (“CFDs”). These can be futures
and options on the FTSE100 index or any other index or share, as well as currency and interest swaps.
However, unlike other futures and options, these contracts can only be settled in cash. Investing in CFDs
carries the same risk as investing in futures or options and Client should be aware of these as set out above.
Transaction in CFDs may also have a contingent liability and the Client should be aware of the implication of
this.
5.2. The Client should get familiar with the execution venues, costs and any other information related to
specific types of orders/requests and Financial Instruments.

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6. ADDITIONAL RISKS
6.1. Terms and conditions of contracts

The Client should request from the Company to be provided with the terms and conditions for trading with
the specific Financial Instrument and type of account as well as associated obligations (e.g. the circumstances
under which the Client may become obligated to make or take delivery of the underlying interest of a future
contract and, in respect of options, expiration dates and restrictions on the time for exercise). Under certain
circumstances, the specifications of outstanding contracts (including the exercise price of an option) may be
modified by the exchange or clearing house to reflect changes in the underlying interest.

6.2. Suspension or restriction of trading and pricing relationships

Market conditions (e.g. liquidity) and/or the operation of the rules of certain markets (e.g. the suspension of
trading for any Financial Instrument, trading hours, dealing hours etc. may increase the risk of loss by making
it difficult or impossible to effect transactions or liquidate/offset open positions/transactions. If the Client
has sold options, this may increase the risk of loss. Further, normal pricing relationships between the
underlying interest and the future, and the underlying interest and the option may not exist. This can occur
when, for example, the futures contract underlying the option is subject to price limits while the option is
not. The absence of an underlying reference price may make it difficult to judge "fair" value to the transaction.
It may be difficult or impossible to liquidate an existing open position/transaction, to assess the value, to
determine a fair price or to assess the exposure to risk. For these reasons, these transactions may involve
increased risks. Market conditions are related to all types of Financial Instruments.

6.3. Deposited cash and property

The Client should get familiarized with the protections of the Client’s money or other property deposited by
the Client for trading with Financial Instruments, particularly in the event of a firm’s insolvency or bankruptcy.
The extent to which the Client may recover the Client’s money or other property may be governed by specific
legislation or local rules. In some jurisdictions property which had been specifically identifiable as the Client’s
own property will be appropriated in the same manner as cash for purposes of distribution in the event of a
shortfall.

6.4. Commission and other charges/costs

Before the Client begins to trade, the Client should obtain a clear explanation of all commissions, fees and
other charges/costs for which the Client will be liable. These charges/costs will affect the Client’s net profit
(if any) or increase the Client’s loss.

6.5. Limiting losses

Where permitted, placing a stop-loss order/request will not necessarily limit the Client’s losses to the
intended amounts, for market conditions may make it impossible to execute such orders/requests at the
stipulated price. A spread, straddle or hedge position/transaction may be risky as a simple long or short
position/transaction and can be more complex.

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6.6. Transactions

Transactions with Financial Instruments on specific markets may expose the Client to additional risk. Such
markets may be subject to regulation which may offer different or diminished investor protection.
Before the Client begins to trade, the Client should enquire about any rules relevant to the particular
transactions related to specific Financial Instruments. The Client’s local regulatory authority will be unable to
compel the enforcement of the rules of regulatory authorities or markets in other jurisdictions where Client’s
transactions have been effected.

6.7. Currency risks

The profit or loss for transactions in foreign currency-denominated contracts will be affected by fluctuations
in currency rates when there is a need to convert from the currency denomination of the contract into
another currency.

6.8. Trading facilities

Most open-outcry and electronic trading facilities are supported by computer-based component systems for
the orders/requests routing, execution, matching, registration or clearing of transactions. As with all facilities
and systems, they are vulnerable to temporary disruption or failure. The Client may ascertain losses and the
ability to recover certain losses may be subject to limits on liability imposed by the system provider, the
market, the clearing house and/or member firms.

6.9. Electronic trading

Trading on an electronic trading system may differ not only from trading in an open-outcry market but also
from trading on other electronic trading systems. If the Client undertakes transactions on an electronic
trading system, the Client will be exposed to risks associated with the specific electronic trading system
including the failure of hardware and software. The result of any system failure may be that the Client’s
orders/requests are either not executed according to the Client’s instructions or are not executed at all.

7. ACKNOWLEDGMENT
By signing this Risk Disclosure Statement, the Client understands that profits from trading are not guaranteed
and that past results do not assure future profitability, and the Client understands the high risks involved
with trading with Financial Instruments. The Client acknowledges and confirms that the Client has fully read
and understood the Risk Disclosure Statement.

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Common questions

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Accessing trading accounts via mobile devices carries risks related to error occurrences and potential unauthorized access due to compromised account credentials. Mobile trading services may have limited functionality and information availability, which could impact trading decisions. There is also the risk of failures or damages to device software and data confidentiality issues as mobile trading involves communication over possibly insecure networks .

Clients are required to be fully authorized and remain compliant with applicable laws, rules, and regulations when using online and mobile trading services. The client must also adhere to rules set by the company or service providers. Any updates to the terms of use are made available online, and client's acceptance of these changes by continuing to initiate transactions reinforces compliance. For mobile services, ensuring legal compatibility before use is the client's responsibility .

Leverage is defined as borrowed capital used to increase or decrease the potential return on an investment. It allows clients to control a larger position with a smaller amount of capital, thus amplifying both potential profits and losses. With higher leverage, the level of risk increases since a small price movement can result in significant gains or losses. The client acknowledges that marginal trading relies on the leverage applied, understanding that higher leverage means higher risk and potentially higher returns or losses .

If a bank or clearing broker becomes insolvent, the client may suffer losses of any margin deposits. The deposits could be directly or indirectly affected by bankruptcy, insolvency, or liquidation. The client's financial instruments and assets may be treated differently based on the domestic legal and regulatory regime of the entity holding them. As such, the client might not receive back their deposits or assets in a manner similar to if they were held under different jurisdictions .

Electronic trading facilities are vulnerable to disruptions because they are supported by computer-based systems for order-routing, execution, matching, registration, and clearing of trades. These systems could experience temporary failures or malfunctions, impacting a client's ability to recover losses. Additionally, these implications mean that clients should have alternative arrangements for transmitting and executing orders to mitigate such risks .

The company may limit the number of open positions or transactions the client can maintain, and is not obliged to execute transactions that would exceed these limits. The company retains the discretion to adjust leverage and limit positions, especially if the client deliberately exploits marginal trading to maximize potential returns while increasing risk exposure. Additionally, the company does not allow trading practices that might breach position limits set by contract markets or account types .

Jurisdiction plays a crucial role because the legal and regulatory regime of the entity holding the client's assets affects how these assets are treated in the event of insolvency. If the insolvency occurs in a jurisdiction with different legal provisions than where the client is located, the assets might be treated differently, potentially leading to less favorable outcomes for the client. Therefore, understanding the jurisdiction in which funds are held is important for assessing potential risks .

The company manages errors by reserving the right to cancel transactions made at manifestly incorrect prices or to correct such prices. If a price error occurs due to market circumstances or system malfunctions, the company is not bound by those transactions and can substantiate the error to the client. They can either cancel the transaction or modify the erroneous price, thus ensuring accuracy in pricing .

A company can liquidate a client's open positions if the client fails to maintain required margin, has passed away, is declared incompetent, is insolvent, or is under receivership. Additionally, liquidation can occur if a proceeding under bankruptcy legislation is filed, property deposited as collateral is deemed inadequate, or if the company deems it necessary for protection. This can be done without prior notice to the client .

If a client suspects unauthorized access to their trading accounts, they are responsible for promptly notifying the company. It is the client's duty to maintain the confidentiality of their username and password and to take reasonable steps to prevent fraudulent use. Failure to notify the company results in the client being liable for any such unauthorized access .

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