CFDS TRADING CLIENT AGREEMENT

Indication Investments Limited

CySEC License Number 164/12
Version 2.0

Regulated by CySEC License Number 164/12

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Contents
Introduction 4
1. DEFINITIONS AND INTERPRETATION OF TERMS 6
2. PARTIES TO THIS AGREEMENT 11
3. CLIENT CATEGORISATION 12
4. COMMENCEMENT AND EFFECT OF THE AGREEMENT 13
5. SERVICES 14
6. CFD TRADING PROCEDURES & ORDERS 15
7. THIRD-PARTY AUTHORISATION TO TRADE 18
8. OPERATION TIME 18
9. MARGIN REQUIREMENTS 18
10. ONLINE TRADING SYSTEMS, WEBSITE ACCESS AND INTELLECTUAL PROPERTY 19
11. SAFETY OF ACCESS DATA 21
12. REFUSAL TO EXECUTE ORDERS 22
13. CONFIRMATIONS AND CLIENT REPORTING 22
14. COMMUNICATION AND WRITTEN NOTICES 23
15. CONFIDENTIALITY AND DATA PROTECTION 24
16. ADVICE 25
17. MARKET COMMENTARY 25
18. CySEC RULES AND OTHER APPLICABLE LAWS AND REGULATIONS 25
19. FUNDING AND WITHDRAWALS OF THE ACCOUNT 26
20. ACCOUNT INACTIVITY FEES 27
21. CHARGES AND OTHER FEES 27
22. CLIENT MONEY 28
23. EVENTS OF DEFAULT 30
24. CURRENCY RATE CONVERSIONS 31
25. LANGUAGE 31
26. FORCE MAJEURE 31
27. TERM AND TERMINATION 33
28. AMENDMENTS 35
29. SEVERABILITY 36
30. COMPLAINTS AND QUERIES 36
31. APPLICABLE AND GOVERNING LAW AND JURISDICTION 37
32. NON-EXERCISE OF RIGHTS 37
33. INDEMNITY 37
34. LIMITATION OF LIABILITY 38
35. REPRESENTATIONS AND WARRANTIES 39
36. CLIENT ACKNOWLEDGEMENTS 40
37. CONFLICTS OF INTEREST 41

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38. CLIENT CONSENT 41
39. FINAL PROVISIONS 42

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 Introduction
Indication Investments Ltd is a Cyprus Investment Firm incorporated and registered under the Companies Law of the
Republic of Cyprus under Certificate of Registration No. HE 290930, having its registered office at 134 Agia Fylaxeos &
Amisou, Anissa Court, 4th floor, 3087, Limassol, Cyprus and its business address at 10 Agiou Athanasiou, Ksenos building,
6th and 7th floor, 4105, Limassol, Cyprus (hereinafter “Libertex” or “We” or “Us” or “Our” or “The Company”). The
Company has been granted a license to act as a Cyprus Investment Firm from the Cyprus Securities and Exchange
Commission (hereinafter “CySEC”) (with License No. 164/12). Under its license, it is allowed to provide the Investment
and/or Ancillary Services covered in this Client Agreement For CFD Trading.
This Client Agreement For CFD Trading, the policies mentioned in points (a) - (g) below and any Appendices added
thereto, the Legal Documents, Costs and Fees, and Contract Specifications, as amended from time to time, (hereinafter
together the “Agreement”) set out the terms upon which the Company will offer Services to the Client, the rights, and
obligations of each Party. By applying for our services, you are consenting to the terms and conditions of all the above-
mentioned documents which form the Agreement, and it means that in the event that you are accepted by us as our
Client (see paragraph 4 further below), you and we shall be bound by these terms and conditions.
In addition to the above documents, we would also like to bring to your attention the following documents found on our
Website:
a) Summary of the Conflicts of Interest Policy
b) Summary of the Best Interest and Order Execution Policy
c) Risk Disclosure and Warnings Notice
d) Client Categorisation Policy
e) Investor Compensation Fund
f) Complaints Procedure for Clients
g) Privacy and Cookies Policy
The documents/policies mentioned in points (a) to (g) above, along with the Agreement, include important information
which we are required as an authorised Cyprus Investment Firm to provide to our prospective Clients under Applicable
Laws and Regulations.
All these documents are important, and for this reason, you are advised to read carefully all documents mentioned
above, which are part of the legal documents available on the Company’s Website that form the Agreement and any
other letters or notices sent by us and make sure that you understand and agree with them before entering into an
agreement with us.
For your benefit and protection, please ensure you take sufficient time to read the Agreement, as well as any other
additional documentation and information available to you via the Company's website, prior to opening an account
and/or carrying out any activity with us. You should contact us for any further clarification or seek independent
professional advice (if necessary).
The Agreement shall be binding upon and shall inure to the benefit of the parties and their permitted successors and
assigns. In particular, if the Client is non-face-to-face and all communication with the Client is done through the website,
over the phone or via written correspondence (including e-mail), then the Distance Marketing of Financial Services Law
N.242(I)/2004 applies, which does not require the Agreement to be physically signed by either the Client or the Company
for both of the Parties to be legally bound by it. The terms contained in the Agreement shall apply to the initial, as well
as to any subsequent activity entered between the Company and the Client.
You hereby expressly acknowledge and agree that:
(a) By completing and submitting to the Company the Account Opening Application Form and/or by clicking on the
appropriate space or on the “I agree to the Terms and Conditions” statement or any similar buttons/confirmation
statements designated to show us your approval and acceptance of the Agreement; and/or

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(b) By accessing or using and/or by continuing to access or use the services provided by the Company
you fully agree to abide by and to be bound by all Terms and Conditions set out in the Agreement as they may apply to
you.
If your signature or acknowledgement is required/requested with respect to any documentation and you “click” in the
appropriate space or on the “Accept”/“Submit” buttons or any other similar buttons in this respect showing your
approval and acceptance thereof, you will be deemed to have “signed” and/or acknowledged the document to the same
extent and with the same effect as if you had signed the document manually. Further to this, to the extent permitted
under applicable mandatory law, you hereby waive any rights or requirements under the applicable laws/regulations of
any jurisdiction which require an original (non-electronic) signature or delivery or retention of non-electronic records.
Despite this, upon prior written notice to the Company, you have the right to withdraw your consent to the electronic
delivery and signature of documentation that we may provide to you. However, upon such withdrawal, the Company
may, at its sole discretion and without any obligation to provide any further explanations, restrict or terminate the
business relationship.
If the Client does not understand or have objections to any of these Terms and Conditions, or any part thereof, and/or if
the Client does not agree to be bound by these Terms and Conditions, he/she shall contact the Company in writing
immediately prior the opening of the account.
For the avoidance of any doubt, Libertex is the trading platform used by the Company.
THE COMPANY WILL OFFER ITS SERVICES STRICTLY UNDER THE FOLLOWING TERMS AND CONDITIONS, WHICH ARE NON-
NEGOTIABLE AND WILL BE AMENDED AT THE COMPANY’S DISCRETION AT ANYTIME.

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 1. DEFINITIONS AND INTERPRETATION OF TERMS

1.1. In this Client Agreement For CFD Trading, the following words shall have the corresponding meanings:
Abusive Trading: Any of the following actions such as, but not limited to Sniping; placing “buy stop” or “sell stop”
Orders prior to the release of news related to the Underlying Market/Asset; arbitrage; manipulations; a
combination of faster/slower feeds; abuse of the cancelation of trades feature available on the Online Trading
System(s); use (without the prior and written consent of the Company) of any robots, spiders or other automated
data entry system with the Online Trading System(s) (unless you receive express written consent by the Company
prior to activating the robot) or use of any software, which applies artificial intelligence analysis to the Online
Trading System(s) and/or Account; entering into transactions or combinations of transactions (voluntarily and/or
involuntarily) such as holding long and short positions in the same or similar Underlying Assets at similar times
either by the Client or by the Client acting in concert with others, possibly with connected accounts, which taken
together or separately are for the purpose of manipulating the Online Trading System(s) for gain.
Access Codes: Your login and password given to you by us in order to have access to our Online Trading System(s).
Access Data: Your Access Codes, your Phone Password, your Account Number and any information required to
place Orders with us.
Account: An account with a unique username and password used by you to access and use our services.
Abnormal Market Conditions: They include but are not limited to times of rapid price fluctuations of the price,
rises, or falls in one trading session to such an extent that, under the rules of the relevant exchange, trading is
suspended or restricted, or there is lack of liquidity, or this may occur at the opening of trading sessions.
Affiliate: An appointed by the Company natural or legal person who promotes the Company’s brand and
Investment services and might be remunerated based on CPA.
Agreement: This Client Agreement for CFD Trading, plus the following policies available on the Company’s website:
Client Categorisation Policy, Investor Compensation Fund, Conflicts of Interest Policy, Best Interest and Order
Execution Policy, Risk Disclosure and Warnings Notice, Complaints Handling Procedure, Cookies Policy and Privacy
Policy, as amended from time to time and any other policy available at the website.
Applicable Laws and Regulations: a) CySEC Rules or any other rules of a relevant regulatory authority; (b) the Rules
of the relevant Market; and (c) all other applicable laws, rules and regulations as in force from time to time in any
jurisdiction.
Account Opening Application Form: The application form/questionnaire completed by the Client in order to apply
for an account to receive and use the Company’s Services under this Agreement, via which form/questionnaire the
Company will obtain, among other things, information for the Client’s identification economic profile, risk
tolerance, investment objectives, appropriateness in accordance with the Applicable Laws and Regulations
Authorised Representative: The person who is expressly authorised by the client who is a legal entity to give
Instructions and/or orders to us or to handle any other matters related to this Agreement, provided that you have
notified us in writing and that this person is approved by us.
Balance: The total sum on your Account after the last Completed Transaction and depositing/withdrawal operation
made within any period of time.
Base currency: The first currency in the Currency Pair against which the Client buys or sells the Quote Currency.
Business Day: Any day other than a Saturday or a Sunday, 1 January or any other Cypriot or international holiday
to be announced on the Company’s Website.
CFDs: A Financial Instrument which is a Contract for Difference by reference to variations in the price of an

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Underlying Asset, such as Currencies (forex pairs), Commodities, Futures, Options, Forwards, Stocks, Bonds, etc.
All offered CFDs by the Company may be found on the Company’s Website.
Client: A natural person or legal entity who registers an account with the Company.
Client Money Rules: The rules relating to Client Money as set out by CySEC Rules.

Closed Position: The opposite of an Open Position.

Commission Fee: A fixed fee charged upon the opening of a Position, charged by the Company.

Completed Transaction: Two counter deals (opening a position and closing a position): buy then sell and vice versa.
Contract Specifications: Each Lot size or each type of Underlying Asset in a CFD as well as all necessary trading
information concerning Spreads, Swaps, Margin requirements etc., as defined by us from time to time on our
Website.
Currency of the Account: The currency that you choose when opening an Account with us.
Currency Pair: The quotation of two different currencies, where one is quoted against the other.
CySEC: The Cyprus Securities and Exchange Commission, which is the Company’s supervisory authority.

CySEC Rules: The Rules, Directives, Regulations, Guidelines and Guidance notes of the Cyprus Securities and
Exchange Commission in Cyprus.
Equity: The Balance plus or minus any Floating Profit or Loss that derives from an Open Position and shall be
calculated as Equity = Balance + Floating Profit - Floating Loss.
Essential Details: The required details in order for the Client to be able to place the Order, for example, but not
limited to the type of Underlying Asset, Direction (Buy or Sell), Opening price, Closing price, style of the Order, the
volume, if the Client places a Pending Order (limit or stop) the Client will indicate the intended price in which the
Order will go in the market and any Stop Loss and/or Take Profit, etc.
Event of Default: The events in paragraph 23.1 herein below.

Expert Advisor (EA): A mechanical online trading system designed to automate trading activities on an electronic
trading Online Trading System(s). It can be programmed to alert you of a trading opportunity and can also trade
your Account automatically, managing all aspects of trading operations from sending Orders directly to our Online
Trading System(s) to automatically adjusting stop loss, trailing stops and take profit levels. The Company does not
provide such features for clients, and any use shall be prior approved by the Company. EA also refers to
automatically copying trades from other traders, brokers and/or trading automatically via third-party Signal
Providers. The Company may, at its sole discretion, cancel and/or suspend any Client Account should the use of
any EA be suspected or identified without the Company’s prior approval.
Financial Instrument(s): The Financial Instruments under the Company’s CIF license, which can be found in the
document “Company Information” on our Main Website. It is understood that the Company does not necessarily
offer all the Financial Instruments which appear on its CIF license but only those marketed on its website from
time to time. This Agreement covers the Financial Instrument of CFDs.

Financial Markets: The places where individuals and firms trade assets such as stocks, bonds, commodities, and
derivatives. The prices of all investments are derived from the offers and bids different investors make for them in
markets.
Force Majeure Event: The Events as set out in paragraph 27.1 hereunder.

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Free Margin: The amount of funds available in the Account, which may be used to open a position or maintain an
Open Position. Free Margin shall be calculated as Equity less (minus) Necessary Margin [Free margin = Equity-
Necessary Margin].

Hedged Margin: The necessary margin required by the Company to open and maintain Matched Positions.

Inducement: Money, goods or services other than the standard commission or fee that the Company may receive
from a third party in relation to the Transaction that is or may be in conflict with the Client's interest.
Initial Margin: The necessary margin to open a position.

Investment Services: The Investment Services under the Company’s CIF license, which can be found in the
document “Company Information”.
Law: Investment Services Law 87(i)/2017
Leverage/ Multiplier: A ratio in respect of Transaction Size and Initial Margin. Example: A ratio of 1:100 means
that in order to open a position, the Initial Margin is one hundred times less than the Transactions Size. More
information regarding the Leverage per underlying asset of CFDs is available in the “Contract Specifications” and
“Online Trading System Trading & Conditions” sections of the Main Website.
Long Position: A buy position that appreciates in value if underlying market prices increase. For example, in respect
of Currency Pairs: buying the Base Currency against the Quote Currency.
Lot: A unit measuring the contract size specified for each Underlying Asset found in the “Contract Specifications”
section of the Website.
Lot Size: The Underlying Assets in one Lot in a CFD.

Margin: The necessary funds to open positions or to maintain Open Positions, as determined in the Contract
Specifications for each Underlying Asset in a CFD Transaction.
Margin Close-Out Protection: The automatic closing of all your open positions on the MT4 and MT5 Platforms,
which occurs when the amount in your trading account does not meet the Margin Requirement, and the closure
of your open position when your trade’s equity reaches 50% or less of minimum required margin on the Libertex
Platform.
Margin Call: The alert sent to a client to notify them that the required margin on trades has fallen below the
required margin.

Margin Level: The percentage of Equity to Necessary Margin ratio. It is calculated as Margin Level = (Equity /
Necessary Margin) x 100%.

Market Abuse: The notion consisting of insider dealing and/or market manipulation as defined by the Cyprus
Security and Exchange Commission in the Insider Dealing and Market Manipulation (Market Abuse) Law
102(Ι)/2016, as amended.
Market Order: The order is not guaranteed to execute at the specified price but rather at the best available market
price.

Matched Positions: Long and Short Positions of the same Transaction Size opened on the Account for the same
underlying asset of CFD.
Necessary Margin: The necessary margin required by the Company to maintain Open Positions.
Negative Balance Protection: This means that a client cannot lose more than the available balance on his/her

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account.
Online Trading System(s): Any Software used by us which includes the aggregate of our computer devices,
software, databases, telecommunication hardware, a trading Online Trading System, making it possible for you to
obtain information on markets in real-time, make technical analysis on the markets, enter into Transactions,
place/modify/delete Orders, receive notices from us and keep a record of Transactions.
Open Position: Any open position in relation to CFD trading that is not a Completed Transaction.

Order: An instruction by you to us as specified in paragraph 6.10 hereunder.

Parties: The parties to this Agreement – the Company and the Client.

Pending Order: An order to Buy or Sell CFD at a price different from the market price.

Phone Password: Your password given by you to us as VAC (Verification Access Code).

Position: Your position in relation to any CFD currently open on your Account

Professional Client: A “Professional Client” for the purposes of CySEC Rules, as specified in the document “Client
Categorisation Policy”.
Profit/Loss: The result of a trade/trades.

Quote: The information on the current price for a specific Underlying Asset.

Quote Currency: The second currency listed in the Currency Pair, which can be traded on CFDs.

Retail Client: A “Retail Client” for the purposes of the CySEC Rules, as specified in the document “Client
Categorisation Policy”.
Result: The result of a closed trade(s).
Registration Data: The information requested from the Client during the registration process in order to open an
account with the Company.

Short Position: A sell position that appreciates in value if underlying market prices fall. A Short Position is the
opposite of a Long Position.
Slippage: The difference between the expected price of a Transaction in a CFD and the price the Transaction is
actually executed at. Slippage often occurs during periods of higher volatility (for example, due to news events),
making an Order at a specific price impossible to execute, when market orders are used, and also when large
Orders are executed when there may not be enough interest at the desired price level to maintain the expected
price of trade.
Sniping: Executing trading strategies with the objective or as a result of exploiting misquotation(s). Misquotations
may occur as a result of the highly automated nature of offering tradable prices on the Online Trading System(s).
Spread: The difference between the “Buy” and “Sell” price of an underlying Asset in a CFD at the same moment.
Stop Loss: A Stop Loss order is a type of order which closes an open position at a predetermined price level you
specify.
Stop Out: Depending on the market volatility, the trade may automatically close when its loss is 50% or more of
the initial invested amount.
Swap or Rollover: The interest added or deducted for holding a position open overnight. The swaps are published

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 and are being updated periodically on the Website.
Swap Rates: The rate of the fixed portion of a swap at which the Swap will occur for one of the Parties entering
into a CFD.
Trade Confirmation: A message from us to you confirming the execution of your Order.

Trailing Stop: A stop-loss order set at a percentage level below the market price - for a long position. The trailing
stop price is adjusted as the price fluctuates. A sell trailing stop order sets the stop price at a fixed amount below
the market price with an attached “trailing” amount. As the market price rises, the stop price rises by the trail
amount, but if the pair price falls, the stop loss price doesn't change, and a market order is submitted when the
stop price is hit.

Transaction: A transaction of the Client in a CFD.

Transaction Size (Meta Trader Platform): Lot Size multiplied by the number of Lots.

Transaction Size (Libertex Platform): the invested amount multiplied by the leverage used.

Trading Platforms: Libertex, MetaTrader 4 and MetaTrader 5.

Trading Platform: This means the Client area on the Libertex Platform.
Underlying Asset: The underlying asset in a CFD, which may be Currencies, Stocks, Cryptocurrencies, Metals,
Indices, Commodities, Futures, or Options offered by the Company from time to time.
Website: www.libertex.com, www.libertex.de
Written Notice: The following methods of communication are considered a Written Notice from the Company to
the Client: e-mail, Online Trading System’s internal mail, facsimile transmission, post, commercial courier service,
air mail or the Company’s Website. The following methods of communication are considered a Written Notice
from the Client to the Company: e-mail, facsimile transmission, post, commercial courier service or air mail or
commercial courier.
You - He/She – His/Her - Him/Her: The Client.
Your Information: Any information that we receive from you or otherwise obtain which relates to you, your
Account or our provision or your use of our Services.

1.2. Words importing the singular shall import the plural and vice versa. Words importing the masculine shall import
the feminine and vice versa. Words denoting persons include corporations, partnerships, other unincorporated
bodies and all other legal entities and vice versa.

1.3. Paragraph headings are for ease of reference only.

1.4. Any reference to any Act or regulation or Law shall be that Act or regulation, or Law as amended, modified,
supplemented, consolidated, re-enacted, or replaced from time to time, all guidance notes, directives, statutory
instruments, regulations or orders made pursuant to such and any statutory provision of which that statutory
provision is a re-enactment, replacement or modification.

2. PARTIES TO THIS AGREEMENT

2.1. This Agreement is entered by and between the Company on the one part and the Client on the other part.

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2.2. You will open each Transaction with us as a principal and not as an agent for any person. This means that unless
we have otherwise agreed in writing, we will treat you as our client for all purposes, and you will be directly and
personally responsible for performing your obligations under each Transaction entered into by you. If you act in
connection with or on behalf of someone else, whether or not you identify that person to us or not, we will not
accept that person as a client of ours, and we will accept no obligation to them unless otherwise specifically agreed
in writing.

2.3. Where the Client comprises two or more persons, the liabilities and obligations under the Agreement with us shall
be joint and several. Any warning or other notice given to one of the persons who form the Client shall be deemed
to have been given to all the persons who form the Client.

2.4. Any order or instruction given by one of the persons who form the Client shall be deemed to have been given by
all the persons who form the Client.

2.5. You hereby acknowledge and declare that in respect of all transactions conducted by you on the Trading
Platform(s), you rely on your own judgment in opening, closing, or refraining from opening or closing a Transaction
and that we will not be liable for any losses (including, without limitation, indirect losses or loss of opportunity or
profits arising from any failure by you to make any anticipated profits), costs, expenses or damages suffered by you
arising from any inaccuracy or mistake in any information, given to you on a best endeavours basis, including,
information relating to any of your transactions with us. The information provided to you is for your convenience
only and does not constitute financial or investment advice. Subject to our right to void or close any transaction in
the specific circumstances set out in the Agreement, any transaction opened by you following such inaccuracy or
mistake will nonetheless remain valid and binding in all respects on both you and us.

2.6. Before you begin to trade with us, you acknowledge that you are aware of all spreads, fees, charges, swaps (as
displayed for each underlying asset in our Website and/or in the Trading Platform(s) and other charges for which
you will be liable under the Agreement. These charges will affect your trading account balance, your trading profits
(if any) or losses, as the case may be.

2.7. In the event of the death or mental incapacity of the Client, all funds held by the Company will be for the benefit
and at the order of the survivor(s) or its appointed representative, and all obligations and liabilities owed to the
Company will be owed by such survivor(s) or its appointed representative.

2.8. The Agreement shall take effect and commence upon acceptance by the Client during the Account Opening
Procedure or otherwise. Before depositing any funds and/or placing an Order, the Client can withdraw from the
present agreement at any time and without any cost. Should the Client wish not to utilise the Company’s Services
after depositing any funds but before placing an Order, the Client shall request by the Company to terminate the
present agreement and place a withdrawal request of any available funds in the Account. In such a case, all payment
and transfer charges of third parties will be borne by the Client, and the Company shall debit the relevant Client
Account for these charges. It shall be noted that in the cases described above, the Company might retain certain
details and information provided by the Clients during the Account Registration Form or otherwise, as required
and/or permitted by the Applicable Regulations and as provided hereunder. The exceptions offered under Section
11 of the Law on Distance Trading of Financial Services to Consumers of 2004 (Law 242 (I)/2004) (“the Law”) as this
has been amended, entitles the Company to note that the withdrawal right is not applicable to the services offered
to its clients. For the avoidance of doubt, the Company has no obligation to apply the right of withdrawal of Section
10 (1) of the Law without penalty and without giving any reason by virtue of the exception offered under Section
11 of the Law, and therefore, the Client will not be able to withdraw from the client agreement once the Trading
Account was funded and/or the first Order has been placed.

2.9. Affiliates

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2.9.1 In cases where the Client is introduced to the Company through a third party such as an Affiliate, the Client
acknowledges that the Company is not bound by any separate agreement(s) entered into between the Client and
the Affiliate. It is also made clear that the Affiliates are not authorised by us to bind the Company in any way, to
offer credit in our name, to offer guarantees against losses, to offer investment services or legal, investment or tax
advice in our name or collect your money.

2.9.2 All third-party Affiliates are paid according to a “Cost per Acquisition” (CPA) arrangement by the Company. Under
the CPA arrangement, the Affiliate receives a one-off fee for each referred Client. The applicable fee payable varies
per country and number of referred Clients. Further information and/or details for the introductory fees paid to
third-party Affiliates can be provided to the Client upon request via e-mail at [email protected].

3. CLIENT CATEGORISATION

3.1. According to CySEC Rules, the Company has to categorise its clients as Retail Clients, Professional Clients, or Eligible
Counterparty. For the purposes of the Agreement, you are by default categorised as a Retail Client. Retail Clients
are afforded the highest possible level of protection rights by the Law, as detailed in the Client Categorisation Policy.

3.2. Clients classified as Retail will be permitted to trade in CFDs with respective Leverage of the specific category of
underlying assets and will also be subject to a maximum leverage of 1:30 based on the underlying asset, as per
Applicable Laws and Regulations.

3.3. You retain the rights to request re-categorisation to other categories and more information about the categories
of Professional Clients, including Elective Professional Clients (i.e., Retail clients who opt up to a professional status
upon request) and/or Eligible Counterparties. You may request re-categorisation to an Elective Professional Client
by contacting us via the “Professional Trading” page on our Website. However, you will remain categorised as a
Retail Client so that you continue to be entitled to the highest possible level of protection under the Law until we
review your request along with supporting documentation. In case we are not able to accommodate your request
for re-categorisation, you will remain as a Retail client. For more information about Client categorisation and
protection rights, please refer to the Client Categorisation Policy available on the Website.

3.4. The Client accepts that when categorising the Client and dealing with him, the Company will rely on the accuracy,
completeness and correctness of the information provided by the Client in his/her Registration Data, and the Client
has the responsibility to immediately notify the Company in writing if such information changes at any time
thereafter.

3.5. The Company shall have the right to review the Client’s Categorisation according to Applicable Regulations and
inform the Client accordingly. However, if the Company becomes aware that the Client no longer fulfils the initial
conditions which made it eligible for professional status, the Company should take appropriate action without
providing the Client with a notice. The Client shall be treated as accepting the change on that date unless, before
then, the Client informs the Company that the Client wishes to terminate the Agreement and not accept the change.

3.6. The Company reserves the right to categorise the Client to Retail upon discretion without prior notice.

4. COMMENCEMENT AND EFFECT OF THE AGREEMENT

4.1. ASSESSING APPROPRIATENESS

Part of the Registration Data you provide allows us to assess whether our Investment Services and Financial

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 Instruments are appropriate for you in accordance with CySEC Rules.

We are entitled to rely on the information you provide us with unless we are aware that such information is
manifestly out of date, inaccurate or incomplete. We have no responsibility for the information which you provide
to us, and we may assess your knowledge, experience and appropriateness on the basis of the information you
provide to us.

You will be asked to provide information to allow us to assess appropriateness as part of the account opening
process. If we determine that our Investment Service and Financial Instruments are not appropriate for your level
of experience and/or knowledge, we will notify you, and we may not be able to offer you an Account with us.

If you elect not to provide the information required to allow us to assess your knowledge and experience, or if you
provide insufficient information, we may be unable to determine whether the Company’s Investment Services and
Financial Instruments are appropriate for you and, therefore we may decline your application to open an Account.

4.2. After the Client fills out and submits the Registration Data together with all the required identification
documentation required by the Company, the Client will receive an e-mail about whether his/her account
verification has been completed or rejected. The Agreement shall take effect and commence upon the acceptance
of the Company’s terms and conditions or the Client’s first deposit.

4.3. By continuing to place orders with us, you agree to continue to be bound by the Agreement, which supersedes all
other agreements and terms of business which may previously have been in place between you and the Company.

4.4. It is understood that the Company is not to be required (and may be unable under CySEC Rules) to approve a person
as its client until all documentation it requires has been received by the Company, properly and fully completed by
such person, and all internal Company checks (including without limitation anti-money laundering checks,
appropriateness or product governance tests as the case may be) have been satisfied. It is further understood that
the Company reserves the right upon discretion to impose additional due diligence requirements to accept Clients.

If the verification of the Client/beneficial owner’s identity has not been completed, the cumulative amount of
deposited funds of a Client/beneficial owner’ account should not exceed €2,000, irrespective of the number of
accounts the client/beneficial owner holds with the regulated entity.

Where the verification of the Client/beneficial owner’s identity has not been completed during the designated time
frame of 15 days, the commencement of a business relationship must be terminated on the date of the deadline’s
expiry, and your account will be blocked/terminated.

4.5. In the event we become aware of any illegal activity or impropriety in the Registration Data, we may suspend your
account. Should such an event occur, we may not be in a position to release funds and may not be able to take
subsequent instructions from you. We reserve the right to cancel trades and/or profits and/or losses should you be
in breach of this section.

4.6. The Client can hold only one account. Having multiple accounts under the same client is prohibited.

4.7. An account which is related to another account by one, all, or any combination of the following: full name and
surname, phone number, residential address, name on credit/debit card, credit/debit card number, name on
passport/identity card and document number, and any other form of identification information provided, his/her
account(s) is subject to the Company's review and might result in one or more account closure and termination
without prior notice.

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4.8. In the event of a violation of point (4.6) above, the Company reserves the right to terminate any and/or all accounts
of the same client without prior notice in line with section 28.3. of the Agreement.

5. SERVICES

5.1. Subject to the Client’s obligations under the Agreement being fulfilled, the Company may, at its discretion, offer
the following Investment Services to the Client:
a) Reception and transmission of Orders in any type of financial instrument offered by the Company; and
b) Execution of orders on behalf of the Client in any type of financial instrument offered by the Company.

5.2. Subject to the Client’s obligations under the Agreement being fulfilled, the Company may, at its discretion, offer
the following ancillary services to the Client:
a) Safeguarding and administration of financial instruments for the account of Clients, including custodianship
and related services such as cash/collateral management
b) Granting credits or loans to an investor to allow Him/her to carry out a transaction in one or more financial
instruments, where the firm granting the credit or loan is involved in the transaction
c) Foreign exchange services where these are connected to the provision of investment services; and
d) Investment research and financial analysis.

5.3. In regard to the investment services stated in points 5.1 and 5.2. provided by the Company, they relate to the
financial instrument of Contracts for Differences.

5.4. It is understood that the Company shall not provide physical delivery of the Underlying Asset to which the CFD is
referring.

5.5. The Company shall not have an obligation to provide any credit or loan to the Client unless specifically agreed
between the Parties.

6. CFD TRADING PROCEDURES & ORDERS

6.1. You or your Authorised Representative may place orders via means approved by us, including but not limited to
our Online Trading System(s) and your registered e-mail address.

6.2. Under certain circumstances, provided that we are satisfied with your identity's authenticity and the clarity of your
instructions, we may accept “close” orders via telephone subject to the Company’s discretion. If, for any reason,
you are unable to access the Online trading system to execute “close” orders to trade CFDs, you may do so by
contacting our Customer Support Department by telephone, which may transfer your call to our dealing
department. In this case, we'll need to verify your identity. “Close” orders via telephone will only be accepted in
our official language. It should be noted that the firm reserves the right to reject such verbal orders when the
dealing department operator is not satisfied with the Client's identity or the clarity of orders or for any other reason
the Company deems reasonable. The Client accepts that at times of excessive transaction flow, there might be a
delay in connecting over the phone with the dealing department operator, especially when there are important
market announcements.

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6.3. Where information has not been transmitted to the Company via approved means, or where the Client has
misinterpreted any instruction and/or information, it is the Client’s responsibility to make the necessary
amendments, and the Company will bear no responsibility for any loss, be it financial or of opportunity in
connection to said instruction.

6.4. Orders are executed according to the Best Interest and Order Execution Policy.

6.5. The Company will use reasonable efforts to execute an Order, but it is agreed and understood that despite the
Company’s reasonable efforts, transmission or execution may not always be achieved at all for reasons beyond the
control of the Company.

6.6. The Company bears no responsibility for any loss that arises as a result of delayed or unreceived communication
sent by the Company to the Client.

6.7. Any Order shall be conclusively deemed to be a valid Order from you to us if we believe it to be genuine. You are
responsible for any loss, claim or expense incurred by us for following or attempting to follow any of your Orders.
You accept that you will be liable for all Orders given through and under your Access Data, and any such orders
received by us will be considered as received by you. In cases where a third party is assigned as an Authorised
Representative to act on your behalf, you will be responsible for all orders given through and under your
representative’s Access Data. It is noted, however, that the Company applies for a negative balance protection
pursuant to which you may not lose more than the amount deposited in your account. In the event that a position
is closed at such a price, causing your equity to fall below zero, the Company shall waive its right to receive the
balance from you.

6.8. Except where the Trading Platform(s) permits, all orders to trade the CFDs the Company offers are final and cannot
be cancelled or deleted unless the Company expressly agrees to such cancellation or deletion and/or unless
otherwise provided in any of the Company’s legal documentation.

6.9. Model of Execution - In relation to each Transaction, the Company will execute the Client’s Orders on its own
account basis. Under this model of execution, the Company is a counterparty against the Client in each Transaction
and executes the Client Order as a principal to principal against the Client, i.e., the Company is itself the Execution
Venue. The Company executes Client Orders according to the Summary Best Interest and Order Execution Policy,
available on our website.

6.10. Order Types - The following types of Orders are available with us: Stop Loss, Take Profit, Buy Limit, Buy Stop, Sell
Limit, Sell Stop, Pending Orders, and Market Orders. Any other Orders not mentioned in 6.10 are not available and
are automatically rejected.

6.11. Trading Hours - Orders can be placed, executed, and (if allowed) changed or removed within the Trading Hours for
each underlying asset of CFD appearing on the Company’s Website, as amended by the Company from time to
time.

6.12. Pending Orders, not executed, shall remain effective through the next trading session (as applicable).

6.13. Orders shall be valid in accordance with the type and time of the given Order, as specified by the Client. If the time
of validity of the order is not specified, it shall be valid for an indefinite period. However, the Company may delete
one or all Pending Orders if the required margin is insufficient.

6.14. The confirmed Open or Closed Position cannot be cancelled or changed. The Client may delete or modify a Pending
Order before it is executed.

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6.15. It is not possible to change or remove Stop Loss, Take Profit and Limit Orders if the price has reached the level of
the Order Execution.

6.16. Negative and positive slippage applies to pending orders. The Client has the option to place the following pending
or entry orders: Stop Loss, Take Profit, Buy Limit, Buy Stop, Sell Limit, and Sell Stop, which are executed at the
declared price by the Client or the best available price in the underlying market. The Company reserves the right
not to execute orders and has the right to amend the opening/closing price of the transaction in case of technical
failure of the Online Trading System(s), reflected financial tools quotes feed, and also in the case of other technical
failures, whether being in-house or third party’s technologies. Orders may not be executed because there is not
enough volume to fill them, and they may be executed partially or be cancelled. Order is not guaranteed to execute
at the specified price but rather at the best available market price.

6.17. In the event that the Company is unable to proceed with an Order, with regard to price or size or other reason,
depending on the Order type, the Order may be rejected or partially filled.

6.18. The Company reserves the right not to accept any order or to enter into a Transaction with the Client, or the
proposed Transaction is of such a size (too small or too large) that the Company does not wish to accept that
Transaction.

6.19. Under certain trading conditions, it may be impossible to execute Orders (Stop Loss, Take Profit, Buy Limit, Buy
Stop, Sell Limit, Sell Stop, Pending Orders, and Market Orders) at the declared price. In this case, the Company has
the right to not execute orders and the right to change the opening/closing price of the transaction. This may occur,
for example, at times of low liquidity, high volatility/rapid price movements, or other situations where the
execution in the market is not possible (i.e., trading is suspended or restricted). Or this may occur in the trading
session start moments. As a result, placing a Stop Loss/Take Profit Order will not necessarily limit your losses/gains
to the intended amounts because market conditions may make it impossible to execute such an Order at the
stipulated price or at all.

6.20. The minimum level for placing Stop Loss, Take Profit and Limit Orders is found on our Website under Contract
Specifications.

6.21. We may establish cut-off times for instructions or Orders which may be earlier than the times established by the
particular Market involved in any Transaction, and you shall have no claims against us arising out of the fact that
an Order was not placed by you ahead of our cut- off time.

6.22. Swaps - In order to keep a position open overnight in some types of CFDs, the Client may be required to pay or
receive financing fees “Swap/Rollover”. Swaps are calculated when the position is kept open overnight at midnight
(22:00 GMT). From Friday to Monday, Swaps are calculated once. From Wednesday to Thursday, they are calculated
at triple size for currency pairs and spot metals, and on Friday are calculated at triple size for other instruments.
For Cryptocurrencies, Swaps can change daily depending on Financial Market conditions. There is a possibility that
some underlying assets may have negative rollover values on both sides (Long and Short positions) because the
Company charges its own interest based on the overnight interbank rate, and therefore, the positive and negative
values are adjusted accordingly. All prices and Swaps appear on the Online Trading System(s) and may change from
time to time without prior notice.

6.23. Lots - Information about the minimum volume of the transaction and the list of the leverage available for each
account type is available on the Website. For MT4 and MT5, the 1 (one) standard lot size is the measurement unit
that may be specified for each CFD. We have the right to change the Contract Specifications at any time, depending
on the market situation. You agree that it is your obligation to check the full specifications of the CFD before placing

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 any Order.

6.24. Trailing Stop, Expert Advisor and Stop Loss Orders - The Client agrees that trading operations using additional
functions of the Client Trading Platform, such as Trailing Stop and/or Expert Advisor (if available in the Trading
Platform), are executed completely under the Client’s responsibility, as they depend directly on his/her Trading
Platform and the Company bears no responsibility whatsoever.

6.25. Settlement
Upon completing a Transaction:
(a) You shall be liable for the difference if the Transaction is:
i. Sell, and the closing price of the Transaction is higher than the opening price of the Transaction; and/or
ii. Buy, and the closing price of the Transaction is lower than the opening price of the Transaction.
(b) You shall receive the Difference if the Transaction is:
iii. Sell, and the closing price of the Transaction is lower than the opening price of the Transaction; and/or
iv. Buy, and the closing price of the Transaction is higher than the opening price of the Transaction.

6.26. Unless we agree otherwise, all sums for which either Party is liable under paragraph 6.25 above are immediately
payable upon closing of the Transaction. You hereby authorise us to debit or credit your Account with the relevant
sums at the closing of each Transaction. It is understood that once you place an Order until such Order is executed
and the Transaction is closed, the Maintenance Margin shall be used as collateral and hence shall be unavailable
for withdrawal.

6.27. The Client understands and confirms that the Company has and reserves the right to introduce new Financial
Instruments and/or Underlying Assets and/or Market Hours for trading at the Trading Platform and/or suspend
and/or remove from the Trading Platform any Instrument and/or Underlying Assets and/or Market Hours at the
Company’s sole discretion without prior notice. Where the Company suspend and/or remove
a Financial Instrument and/or Underlying Assets and/or Market Hours for trading at the Trading Platform, any
product that the Client has previously opened a transaction, it is the Client's responsibility to cancel and/close such
transaction. Otherwise, the Company has the right to close the transaction at the last available price of the
relevant Financial Instrument and/or Underlying Asset.

7. THIRD-PARTY AUTHORISATION TO TRADE

7.1. A Client who is a legal entity has the right to authorise a third party to give Instructions and/or Orders to us or to
handle any other matters related to this Agreement, provided that you have notified us in writing of exercising such
a right and that this person is approved by us fulfilling all of our specifications for this.

7.2. Unless we receive a written notification from you for the termination of the authorisation of the Authorised
Representative, we will continue accepting instructions and/or Orders given by this person on your behalf, and you
will recognise such orders as valid and committed to you.

7.3. The written notification for the termination of the authorisation to a third party has to be received by us with at
least 1 Business Day’s notice prior to the termination date.

7.4. The Company has the right (but NOT an obligation to the Client) to refuse to accept Orders and/or other instructions
relating to the Client Account from the Authorised Representative in any of the following cases:
(a) If the Company reasonably suspects that the Authorised Representative is not legally allowed or properly
authorised to act as such

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 (b) An Event of Default occurred
(c) In order for the Company to ensure compliance with the relevant market rules and/or practices, Applicable
Regulations or other applicable laws
(d) In order to protect the interest of the Client.

8. OPERATION TIME

8.1. The Company’s working hours are Monday to Friday, 09:00 - 18:00 (GMT +2) on any Business Day.

8.2. The Client may trade during the Company’s normal trading hours for the specific underlying asset during which
the trading platform(s) generates prices and during which the Client may place orders to trade, as specified on the
Website from time to time. The Client will only be able to trade during these trading hours specified on the Website
for that relevant underlying asset only. It should be noted that certain underlying assets have specific trading time
frames, which can be found in the Specifications on the Website. The Client is responsible for looking on the
Website for further details prior to trading. The Client shall be notified of any Company holidays either through
the internal notification system or via other means that the Company may, from time to time, employ.

9. MARGIN REQUIREMENTS

9.1. In Order to open Positions and maintain Open Positions, the Client shall need to provide and maintain the Initial
Margin and/or Hedged Margin in such limits as the Company, at its sole discretion, may determine at any time
under the Contract Specifications for each type of CFD. Our Margin Requirements are set out on our Website under
the Contract Specifications. Margin requirements may not be called as such in the Trading Platform.

9.2. It is the Client’s responsibility to ensure that he/she understands how Margin requirements are calculated. The
Company has the right to change the Margin Requirements according to paragraph 29.5 herein below.

9.3. You agree to pay us on demand such sums by way of margin as are required from time to time under the Rules of
any relevant Market (if applicable) or as we may, at our discretion, reasonably require for the purpose of protecting
ourselves against loss or risk of loss on present, future or contemplated transactions under this Agreement.

9.4. We shall have the right, in addition to any other rights we may have under this Agreement, or under Cyprus law in
general, to close at market prices and/or limit the size of your Open Positions and to refuse to establish new Open
Positions in any of the following cases:
(a) The Company considers that there are abnormal trading conditions.
(b) The value of the Client’s margin falls below the minimum Margin requirement.
(c) At any time, Equity (current balance including open positions) is equal to or less than a specified percentage of
the margin (collateral) needed to keep the Open Position.
(d) In case of fraud or Abusive Trading of the Client.
(e) The system(s) of the Company rejects the Order due to trading limits imposed on the Account.
(f) When the Margin Level reaches the Stop Out Level (ratio of Equity to Margin in the Account), the Client
positions will start closing automatically at market prices, starting with the most losing Order, and the Company
has the right to refuse new Orders. Stop Out level is available on the Website.
(g) When the Client fails to take a measure of paragraph 9.6 below. However, it is understood that it is the Client’s
responsibility to monitor, at all times, the amount deposited in the Account against the amount of Maintenance
Margin required, and it is understood that the Company has the right to take the actions of this paragraph,
even if a Margin Call is not made under paragraph 9.6 below.
(h) When the Client is holding a position for CFD subject to expiry after the Company’s expiry date.

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9.5. The margin close-out will apply to a trade if the 50% margin value is equal to or less than the amount of funds
involved in this trade of the initial margin required. This includes positions with a stop-loss order. Margin close-out
ensures a buffer of margin in normal market conditions and is not applicable under extreme market conditions.

10. ONLINE TRADING SYSTEMS, WEBSITE ACCESS AND INTELLECTUAL PROPERTY

10.1. The Company provides you with a limited license, which is non-transferable, non-exclusive and fully recoverable,
to use the Online Trading System(s) (including the use of the Website and any associated downloadable software
available from time to time) in order to place Orders in CFDs. The Company may use different Online Trading
Systems. Hence, when your Account is enabled for trading, you are entitled to use your Access Codes within our
Online Trading Systems in order to be able to place Orders in CFDs.

10.2. The Company has the right to shut down the Online Trading System(s) at any time for maintenance purposes
without prior notice to the Client. This will be done only on weekends, unless not convenient or in urgent cases. In
these cases, the Online Trading System(s) will be inaccessible. The Company may upgrade or replace the Online
Trading System(s) from time to time without prior notice.

10.3. The Client is solely responsible for providing and maintaining the compatible equipment necessary to access and
use the Online Trading System(s), which includes at least a personal computer or mobile phone or tablet (as the
case may be), internet access by any means and telephone or another access line. Access to the internet is an
essential feature, and the Client shall be solely responsible for any fees necessary in order to connect to the
internet.

10.4. The Client represents and warrants that he/she has installed and implemented appropriate means of protection
relating to the security and integrity of his/her computer or mobile phone, or tablet and that he/she has taken
appropriate actions to protect his/her system from computer viruses or other similarly harmful or inappropriate
materials, devices, information or data that may potentially harm the Website, Online Trading System(s). The Client
further undertakes to protect the Company from any wrongful transmissions of computer viruses or other similarly
harmful or inappropriate material or devices to the Online Trading System(s) from his/her personal computer or
mobile phone, or tablet.

10.5. The Company will not be liable to the Client should his/her computer system or mobile phone, or tablet fail,
damage, destroy and/or format his/her records and data. Furthermore, if the Client incurs delays and any other
form of data integrity problems that are a result of his/her hardware configuration or mismanagement, the
Company shall not be liable.

10.6. You acknowledge that the internet may be subject to events which may affect your access to our Website and/or
Online Trading System(s), including but not limited to interruptions or transmission blackouts. We are not
responsible for any damages or losses resulting from such events which are beyond our control or for any other
losses, costs, liabilities, or expenses (including, but not limited to, loss of profit) which may result from your inability
to access our Website and/or Online Trading System(s) or delay or failure in sending Orders. The Company cannot
be responsible for not fulfilling any obligations under this Agreement because of internet connection failures or
public electricity network failures, or hacker attacks.

10.7. It is absolutely prohibited for the Client to take any of the following actions in relation to Online Trading System(s):
(a) Take and/or engage in any action with the purpose of manipulating the Company’s quoted prices
(b) Take and/or engage in any action with the purpose of manipulating the Company’s execution processes
(c) Take and/or engage in any action with the purpose of manipulating the Company’s Trading Platform(s)

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 (d) Place orders on the basis of privileged, confidential information (i.e., insider trading)
(e) Place orders on the basis of manipulated Prices as a result of system errors and/or system malfunctions
(f) Engage in coordinated transactions by related parties in order to take advantage of systems errors and/or
delays in systems updates
(g) Use, without the prior and written consent of the Company, of any software which applies artificial
intelligence analysis to the Online Trading System(s)
(h) Intercept, monitor, damage, or modify any communication which is not intended for him
(i) Use any type of spider, virus, worm, Trojan-horse, time bomb or any other codes or instructions that are
designed to distort, delete, damage or disassemble the Online Trading System(s) or the communication
system or any system of the Company
(j) Send any unsolicited commercial communication not permitted under Applicable Laws and Regulations
(k) Do anything that will or may violate the integrity of the Online Trading System(s) or cause such system(s) to
malfunction or stop their operation
(l) Unlawfully access or attempt to gain access, reverse engineer or otherwise circumvent any security measures
that the Company has applied to Online Trading System(s)
(m) Any action that could potentially allow the irregular or unauthorised access or use of the Online Trading
System(s)
(n) Send massive requests on the server, which may cause delays in the execution time
(o) Perform Abusive Trading
(p) Take and/or engage in any actions that will and/or may violate the integrity of the Company’s computer
system(s) and/or Platform(s) and/or cause such system(s) to malfunction and/or stop their operation
(q) Allow a third party that the Company has not been notified of as an Authorised person and who is not the
Account Holder to trade on the Client’s Account.

10.8. Should the Client engage in and/or take any of the actions listed in paragraph 10.7, or should the Company
determine at its sole discretion, that the Client has engaged in and/or attempted to engage in and/or has taken any
of the actions listed in paragraph 10.7, the Company reserves the right to take actions including but not limited to
the following:

(a) Restrict the Client’s access to trading

(b) Obtain from the Client Account any historic trading profits that the Client has gained through such abuse of
liquidity as determined by the Company at any time during the Company and Client’s trading relationship
(c) Reject an order or cancel a trade; and/or
(d) Immediately terminate any agreement between the Company and the Client

10.9. You are permitted to store, display, analyse, modify, reformat, and print the information made available to you
through the Website and/or Online Trading System(s), including documents, policies, text, graphics, video, audio,
software code, user interface design or logos. The Client is not permitted to alter, modify, publish, transmit,
distribute, or otherwise reproduce or commercially exploit that information, in whole or in part, in any format to
any third party without the Company’s express written consent.

10.10. The Online Trading System(s), all copyrights, trademarks, patents, service marks, trade names, software code,
icons, logos, characters, layouts, trade secrets, buttons, colour schemes, graphics and data names are the sole and
exclusive Intellectual Property (IP) of the Company or of third parties and are protected by local and international
intellectual property laws and treaties. This Agreement does not convey an interest in or to the Online Trading
System(s) but only a right to use the Online Trading System(s), according to the terms of this Agreement. Nothing
in this Agreement constitutes a waiver of the Company’s intellectual property rights.

10.11. Under no circumstances shall the Client obscure or remove any copyright, trademark, or any other notices from

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 any of the Company’s IP or Website or Online Trading System(s). The Company owns all the images displayed on
its Website, the Online Trading System(s) and downloadable software and material. The Client may not use these
images in any way other than the manner in which the Company provides them for.

11. SAFETY OF ACCESS DATA

11.1. You agree to keep private and not to disclose any Access Data to any person other than the authorised
representative to act on your behalf.

11.2. You should not write down your Access Codes. If you receive a written notification of your Access Codes, you must
destroy the notification immediately.

11.3. You agree to notify us immediately if you know or suspect that your Access Data has or may have been disclosed
to any unauthorised person. We will then take steps to prevent any further use of such Access Data and will issue
you with new Access Data. You will be unable to place any Orders until you receive the new Access Data.

11.4. You agree that you will collaborate with any investigation we may conduct into any misuse or suspected misuse of
your Access Data.

11.5. You acknowledge that we bear no responsibility if unauthorised third parties have access to information, including
electronic addresses, electronic communication and personal data, when the above are transmitted between us or
any other party, using the internet or other network communication facilities, post, telephone, or any other
electronic means.

11.6. If the Company is informed from a reliable source that the Access Data or Client Account Number may have been
received by unauthorised third parties, the Company may, at its discretion, without having an obligation to the
Client, deactivate and/or terminate the Account.

12. REFUSAL TO EXECUTE ORDERS

12.1. Without prejudice to any other provisions herein, you agree and understand that we have the right, at any time,
without giving any notice and/or explanation, to refuse, at our discretion, to execute an Order and that you have
no right to claim any damages, specific performance, or compensation whatsoever from us, in any of the following
cases:
(a) Whenever we deem that acceptance or execution of the Order affects or may affect in any manner the
reliability or smooth operation of the Online Trading System(s)
(b) Whenever there are no available cleared funds deposited in your Account to pay all the charges and required
Margin relating to the said Order
(c) There is an absence of Essential Details of the Order
(d) It is impossible to proceed with an Order regarding the size or price
(e) Your Order has more than one interpretation or is unclear
(f) It is impossible for the Order to be executed due to the condition of the market, customs of a trading volume
(g) If any doubt arises as to the genuineness of the Order
(h) A Force Majeure Event has occurred
(i) In an Event of Default of the Client

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 (j) The Company has sent a notice of Termination of the Agreement to the Client
(k) Under abnormal market conditions
(l) If the order affects the orderly function of the market
(m) If the order aims at manipulating the market of the underlying financial instrument
(n) If the order constitutes the exploitation of confidential information
(o) If the order affects the orderly operation of the trading platform; and
(p) If the order contributes to the legalisation of proceeds from illegal actions (e.g., money laundering).

13. CONFIRMATIONS AND CLIENT REPORTING

13.1. The Company shall provide the Client with adequate reporting on his/her Order(s). For this reason, the Company
will provide the Client with online access to his/her Client Account via the Platform(s) used by the Client, which will
provide Him/her with sufficient information in order to comply with CySEC Rules in regard to client orders’ reporting
requirements. The Client understands and agrees that such reports are deemed to be reports provided by the
Company to the Client in a durable medium.

13.2. If the Client has a reason to believe that the Confirmation is wrong or if the Client does not receive any Confirmation
when he/she should, the Client shall contact the Company within two business days from the date the Order was
sent or ought to have been sent (in the event that a Confirmation was not sent). If the Client expresses no objections
during this period, the content is considered as approved by Him/her and shall be deemed conclusive.

14. COMMUNICATION AND WRITTEN NOTICES

14.1. The Company will communicate with the client about any notice, instructions, authorisations, requests, termination
letters and complaints or any other communication via the Client’s registered e-mail, telephone or, where the Client
wishes to send a formal communication to Company in writing, via post to the Company shall be in English and in
writing and shall be sent to us at the address below (or to any other address which we may from time to time
specify to you for this purpose) by e-mail, facsimile or post. You may contact us at:
● Physical Address: 10 Agiou Athanasiou, Ksenos building, Floors 6 and 7, 4105, Limassol, Cyprus
● Telephone Number: +357 22 025 100
● Fax Number: +357 22 025 222
● E-mail: [email protected]

14.2. You may call us between the hours of 09:00 and 18:00 (GMT +2) on Business Days. If we need to contact you
urgently regarding your Account, we may contact you also outside business hours.

14.3. Faxed documents received by the Company may be electronically scanned, and reproduction of the scanned
version shall constitute evidence.

14.4. The Client accepts that the Company may contact the Client, from time to time, by telephone, fax, e-mail or post
for marketing purposes to bring to the Client’s attention products or services that may be of interest to Him/her or
to conduct market research. Marketing communications will be made only with the Client’s consent.

14.5. The Company bears no responsibility for any loss that arises as a result of delayed or un-received communication
sent to the Client by the Company.

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14.6. The Company is obliged to keep records of all services and activities they are providing as well as for all transactions
undertaken. The Company, therefore, records all communication, including any incoming and outgoing telephone
communication as well as all other electronic communications relating to any transactions concluded when dealing
on the Company’s account, providing services that relate to reception, transmission and execution of Client orders
as well as for quality monitoring, training and regulatory purposes. The Company will also record any other
communication between the Company and the Client, including chat messages, e-mails and other electronic
communications, even if those conversations or communications do not result in the conclusion of such
transactions or in the provision of Client order services. The Company reserves the right to use these records where
they deem it necessary, including, but not limited to, dispute resolution situations.

14.7. The Company may monitor and/or record any electronic communications between the Parties (including telephone
calls, e-mails, text (SMS) messages, etc.) to provide verification of instructions and maintain the quality of our
Investment Services and support for training purposes and to check compliance with this Agreement, our internal
policies and procedures and Applicable Regulations. All Instructions or Requests received by telephone will be
binding as if received in writing. Any recordings shall be and remain the sole property of the Company and will be
accepted by the Client as conclusive evidence of the Instructions/Requests or conversations so recorded. The Client
agrees that the Company may deliver copies of transcripts of such recordings to any court, regulatory or
government authority.

14.8. All records are stored by the Company in a durable medium, which allows them to replay or copy them and retain
such records in a form that does not allow the Company to alter or delete the original version. The Company may
provide copies of such recordings to regulatory authorities upon their request in order to comply with their
regulatory obligations without the Client’s consent.

14.9. The Company will keep copies of any such records for any period of time which is required by Applicable Regulation,
starting from the date on which the record is created.

14.10. The Client understands and accepts that he/she has been notified, in advance, with the present Agreement about
the recording of any telephone conversation or electronic communication between the Company and the Client.

15. CONFIDENTIALITY AND DATA PROTECTION

15.1. The Company is registered with the Personal Data Protection Commissioner’s Office for the purposes of personal
data processing. Therefore, the Client’s personal data is kept and handled in accordance with the Data Protection
Law 125(I)2018, as amended from time to time. The law was adopted for the effective implementation of certain
provisions of Regulation (EE) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the
protection of natural persons regarding the processing of personal data and on the free movement of such data,
and repealing Directive 95/46/EC (GDPR), which applies as of 25 May 2018.

15.2. By entering into this Agreement, the Client shall provide the Company consent to store and process the data he/she
provided during the registration process for the opening of his/her account and/or throughout the business
relationship. This includes any data which may be considered sensitive. The Client has the right to withdraw his/her
consent at any time by notifying the Company in writing. However, as the Company may not be able to provide the
Client with services should the Client choose to do so, the Company reserves the right to refuse to enter into or
terminate the Agreement. The Client shall understand that the Company is required to keep all records of his/her
data and dealings with the Client for as long as necessary under the Applicable Regulations.

15.3. The Company will not disclose and/or share any of the Client’s information to third parties without the Client’s

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 prior consent, except in the event the Company is required to do so by a Regulatory Authority under the applicable
jurisdictions, by Court, and/or enable the Company to provide the Client with its services as well as to improve
these from time to time. The latter includes, but is not limited to, marketing companies, business partners, IT
service providers and other financial institutions such as payment services providers and banks, any of which can
be located outside of the European Economic Area (EEA) Where the Company discloses and/or shares any of the
Client’s information as per this clause, the Company will take all reasonable steps to do so in a secured manner.

15.4. Where the Client has been introduced to the Company by an Affiliate, the Affiliate may have access to a certain
and limited extent to information about the Client’s dealings with the Company.

15.5. The Company will take all reasonable steps to keep the Client’s personal data safe. Nonetheless, the transmission
of information via the internet and/or other networks is not always completely secure. The Company will not be
liable for any transmission of data from the Client to the Company.

15.6. Under Applicable Regulations, the Company will keep records containing Client personal data, trading information,
account opening documents, communications, and anything else which relates to the Client for at least five years
after termination of the Agreement or for the period of time that Regulatory Authorities might request.

16. ADVICE

16.1. We will not advise you about the merits of a particular Transaction or give you any form of investment advice. You
acknowledge that the Investment Services does not include the provision of investment advice. You acknowledge
that you will make trading and other decisions based on your own judgment.

16.2. We will not be under any duty to provide you with any legal, tax or other advice relating to your Transaction. You
agree and acknowledge that you are solely responsible for any investment strategy, transaction or investment, the
composition of any account and taxation consequences, and you shall not rely for this purpose on the Company.

16.3. The Company is under no obligation to monitor and/or advise the Client on the status of any Transaction, to make
Margin Calls, or to close out any Client’s Open Positions in order to stop losses for the Client. It is the Client’s sole
responsibility to be aware of his/her positions at all times.

16.4. You may wish to seek independent advice before entering into a Transaction. In requesting us to enter into any
Transaction, you represent that you have been solely responsible for making your own independent appraisal and
investigation into the risks of the Transaction.

17. MARKET COMMENTARY

17.1. We may provide you with access to third-party trading recommendations, market commentary or other
information. Where we do so:
(a) It is provided solely to enable you to make your own investment decisions and does not constitute in any way
investment advice.
(b) If the document contains a restriction on the person or category of persons for whom that document is
intended or to whom it is distributed, you agree that you will not pass it on to any such person or category of
persons.
(c) We give no representation, warranty or guarantee as to the accuracy of completeness of such information or
as to the tax consequences of any Transaction.

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 (d) You accept that prior to dispatch, we may have acted upon it ourselves to make use of the information on
which it is based. We do not make representations as to the time of receipt by you and cannot guarantee that
you will receive such information at the same time as other Clients. Any published research reports or
recommendations may appear in one or more screen information services.
(e) Does not amount to unsolicited financial promotions to the Client. Market commentary, news, or other
information is subject to change and may be withdrawn at any time without notice.

18. CySEC RULES AND OTHER APPLICABLE LAWS AND REGULATIONS

18.1. Unless otherwise permitted by the CySEC Rules or any other Applicable Laws and Regulations, nothing in this
Agreement shall be taken to exclude or restrict our obligations under the CySEC laws, European laws and
regulations.

18.2. The Company is obliged to take any actions it considers necessary in its absolute discretion to ensure compliance
with the Regulatory Authorities, and such action shall be binding on the Client and shall not render the Company
or any of its Directors, Officers, Employees, or agents liable.

18.3. We are authorised to disclose information relating to you and/or your Transactions to CySEC and other regulatory
bodies as required by law and/or where we believe it is desirable for the proper management of your Account.

18.4. Under Applicable Regulations, we will keep Client Records for at least five years after the termination of the
Agreement.

18.5. The Company reserves the right to request any documentation and/or information during the business relationship.
The Client has an obligation to comply with such requests and is responsible for ensuring that the documentation
and/or information provided is correct and should inform the Company in writing of any change.

19. FUNDING AND WITHDRAWALS OF THE ACCOUNT

19.1. You may fund your Account by credit or debit card, wire transfers or other similar methods of money transfer
acceptable by the Company, from time to time, at its absolute discretion. Detailed information about deposit
options is shown on the Website. However, we do not guarantee that all the transfer methods are available in your
country of residence.

19.2. The Company shall have the right to request the Client at any time any documentation to confirm the payment
method or the source of funds deposited into the Account. In the event that any of the documents indicated above
are required to be submitted or updated, the Client is obliged to provide relevant documents. If the Client fails to
provide updated and valid documents, the Company has the right to suspend the provisions of Investment Services
under this Client Agreement without informing the Client. The Company shall have the right to reject a deposit of
the Client if the Company is not duly satisfied as to the legality of the source of funds and resend them back to the
sender. The Company does not accept third-party deposits or withdrawal requests.

19.3. If the Client makes a deposit, the Company shall credit the relevant Account with the relevant amount actually
received by the Company (until 13.00 CET) within one (1) Business Day following the day the amount is cleared in
the bank account of the Company. A minimum initial deposit may be applied, from time to time, depending on the
policy of the Company, so as to start trading. Where this applies, it shall appear in the Account description on our
Website.

19.4. The Client shall have the right to request withdrawal of his/her funds deposited to his/her Account and/or profit

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 gained through the transactions from his/her Accounts. Upon the Company receiving an instruction from the Client
to withdraw funds from the Account (until 13.00 CET), the Company shall pay the said amount if the following
requirements are met:
(a) The withdrawal instructions include all required information
(b) The instructions are to make a transfer to the originating account (whether that is a bank account, a payment
system account, a card etc.) from which the money was originally deposited in the Account or at the Client’s
request to a different destination than the originating, but which is on the name of the Client
(c) The account where the transfer is to be made is in the name of the Client
(d) At the moment of payment, the Client’s available Balance exceeds or is equal to the amount specified in the
withdrawal instruction, including all payment charges; and
(e) There is no Force Majeure event that prohibits the Company from effecting the withdrawal.

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

19.6. All third-party expenses for transfers of funds from or to the Account shall appear on our Website for each type of
transfer under the payment methods section. These shall be borne by the Client, and the Company shall debit the
relevant Account of the Client for these charges. The Company may, at its own discretion, share the costs of the
transfers. The Company does not charge extra deposit fees.

19.7. The Client is fully responsible for the payments’ details given to the Company, and the Company accepts no
responsibility for the Client’s funds if the details provided by the Client are wrong.

19.8. If the funds sent by the Client are not deposited in the Account when they were supposed to, the Client shall notify
the Company and request the Company to make a banking investigation of the transfer. The Client agrees that any
charges of the investigation shall be paid by the Client and deducted from his/her Account or paid directly to the
bank performing the investigation. The Client understands and agrees that in order to perform the investigation,
the Client shall have to provide the Company with the requested documents and certificates.

19.9. Mistakes made by the Company during the transfer of funds shall be refunded to the Client.

20. ACCOUNT INACTIVITY FEES

20.1. If the Client’s Account is inactive for 180 calendar days (i.e., there is no trading, no open position, no withdrawals
or deposits), the Company reserves the right to charge an account inactivity fee of 10 EUR per month (or 10 GBP,
10 CHF, and 50 PLN respectively) in order to maintain the Account open. An inactivity fee is charged only when the
account balance is less than 5000 EUR (4500 GBP, 5300 CHF, and 22,500 PLN, respectively)*.

The Client consents that if his/her trading account is inactive for 180 calendar days and its balance is less than 10
EUR (or 10 GBP, 10 CHF, and 50 PLN, respectively), the Company may, at its own discretion, disable the Account at
any time.

*An inactivity fee is charged only when the account balance is less than 5000 EUR (4500 GBP, 5300 CHF, and 22,500
PLN, respectively).

21. CHARGES AND OTHER FEES

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21.1. The provision of the Investment Services by the Company is subject to payment of fees such as Commissions,
Swaps/Rollover and other fees. These appear under the “Specification” on our Website.

One-off entry costs Commission charge We charge you a small % fee each time you open a CFD
Ongoing costs Daily swap cost A fee is charged to your account for each night that your position
is held. Swaps can change daily depending on Market conditions.
Other costs Rollover costs We charge you to roll over a futures contract into the next month
or quarter, equal to the spread to open and close a trade. Please
refer to the example available in the Specifics of Trading
Operations Execution document for more information.
Margin Adjustment Margin Adjustment will be charged only when the Client Trading
Account currency is different from the quoted currency of the
underlying asset. Margin Adjustment is up to a maximum of 0.3%,
and it will be applied on the closing of the transaction. The fee will
be realised and reflected once the transaction is closed.
Please refer to the example available in the Specifics of Trading
Operations Execution document for more information.

21.2. Any additional Company fees (such as withdrawal fees) appear under the “Payment methods” on our Website.

21.3. We may vary our Costs and Fees from time to time. We will notify you of any changes before they come into effect
by internal mail via our Online Trading System(s), by e-mail or by placing a notice on our website. The variation will
take effect from the date which we specify in our notification to you.

21.4. Taxes - It is agreed and understood that the Client shall be solely responsible for all filings, tax returns and reports
which should be made to any relevant authority, whether governmental or otherwise, and for payment of all taxes
(including but not limited to any transfer or value-added taxes), arising out of or in connection with his/her trading
activity with the Company. It is possible that other costs, including taxes, relating to transactions carried out on the
Online Trading System(s) may arise for which the Client is liable and which are neither paid via us nor imposed by
the Company.

22. CLIENT MONEY

22.1. The Company will promptly place any Client Money it receives into one or more segregated account(s) (denoted as
“clients’ accounts”) with reliable financial institutions within EEA, such as a credit institution or a bank in a third
country. It is understood that the Company may keep merchant accounts in its name with payment services
providers used to settle payment transactions of its Clients. However, for the avoidance of doubt, it is noted that
such merchant accounts are not used for safeguarding Client Money but only to effect settlements of payment
transactions. Client Money held in segregated bank account(s) may be exposed to obligations of the Company
connected with the positions of other Clients.

22.2. According to Applicable Laws and Regulations, the Company shall exercise due skill, care and diligence in the
selection and appointment and periodic review of the financial institution of paragraph 22.1 and the arrangements
for holding Client Money. The Company takes into account the expertise and market reputation of such institutions
with the view of ensuring the protection of Client’s rights, as well as any legal or regulatory requirements or market
practices related to holding Client Money that could adversely affect Client’s rights. The Company may use multiple
institutions to ensure diversification and allocate internal percentage limits for each such institution. The Company

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 will give instructions to the institutions(s) regarding the transfer and movement(s) of Clients’ money. Where you
have Open Position, we will offset any unrealised losses incurred against any of the Clients’ money held by the
Company in any account. This means that the Company may transfer any or part of any unrealised losses incurred
by you from the segregated account to an account(s) of the Company. Conversely, we may transfer any unrealised
profits incurred by you as a result of an open position from the Company’s account to the omnibus account.

22.3. According to Applicable Laws and Regulations, for the purposes of safeguarding Client Money, the Company shall:
(a) Keep such records and accounts as are necessary to distinguish Clients’ assets from its own and of other Clients’;
such records shall be accurate and correspond to the Client Money
(b) Conduct, on a regular basis, reconciliations between its internal accounts and records and those of any third
parties by whom those assets are held
(c) At all times, keep Client Money segregated from the Company’s own money
(d) Not use Client Money in the course of its own business
(e) Take the necessary steps to ensure that Client Money deposited with a financial institution (according to
paragraph 22.1) is held in an account(s) identified separately from any accounts used to hold funds of the
Company
(f) Introduce adequate organisational arrangements to minimize the risks of the loss or diminution of Client Money
as a result of misuse, fraud, poor administration, inadequate recordkeeping or negligence.

22.4. The Company has a duty to and shall exercise due skill, care and diligence in the selection of the financial institution
according to paragraph 22.2. However, it is understood that there are circumstances beyond the control of the
Company and hence the Company does not accept any liability or responsibility for any resulting losses to the Client
as a result of the insolvency or any other analogous proceedings or failure of the financial institution where Client
Money will be held.

22.5. The financial institution where Client Money will be held may be within or outside Cyprus or the EEA. It is
understood that the legal and regulatory regime applying to any such financial institution outside Cyprus or the
EEA will be different from that of Cyprus. Hence, in the event of the insolvency or any other equivalent failure or
preceding of that person, the Client’s money may be treated differently from the treatment which would apply if
the money was held in a Segregated Account in Cyprus.

22.6. The financial institution to which the Company will pass Client Money may hold it in a segregated account. Hence,
in the event of insolvency or any other analogous proceedings in relation to that financial institution, the Company
may only have an unsecured claim against the financial institution on behalf of the Client, and the Client will be
exposed to the risk that the money received by the Company from the financial institution is insufficient to satisfy
the claims of the Client.

22.7. It is understood that the Company may hold Client Money and the money of other clients in the same account
(omnibus account). In general, accounts held with financial institutions, including omnibus accounts, face various
risks. For instance, in the event of default, no single Client will have a claim against a specific sum in a specific
account in the event of insolvency or default of the institution. Only the Company has the right to claim against the
institution in the event of insolvency or default of the institution, including its bankruptcy. In the event of insolvency
or default of the Company, including its bankruptcy, no single Client will have a claim against the institution.

22.8. The Company is a member of the Investors Compensation Fund (ICF). To that end, depending on the classification,
the Client may be entitled to compensation from the ICF in the event that the Company is unable to meet its
obligations. More details are found in the Company’s document “Investor Compensation Fund” found on the
Website.

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22.9. The Company shall not pay to the Client any interest earned on Client Money (other than profit gained through
trading Transactions from his/her Account(s) under this Agreement), and the Client waives all rights to interest.

22.10. Lien - The Company shall have a general lien on all funds held by the Company or its Associates or its nominees on
the Client’s behalf until the satisfaction of his/her obligations under this Agreement.

22.11. Netting and Set-Off - If the aggregate amount payable by the Client is equal to the aggregate amount payable by
the Company, then the mutual obligations to make payment are automatically offset and cancel each other.

22.12. If the aggregate amount payable by one party exceeds the aggregate amount payable by the other party, then the
party with the larger aggregate amount shall pay the excess to the other party and all obligations to make payment
will be automatically satisfied and discharged.

23. EVENTS OF DEFAULT

23.1. Each of the following constitutes an “Event of Default”:

(a) The failure of the Client to perform any obligation due to the Company.
(b) If an application is made in respect of the Client pursuant to the Cyprus Bankruptcy Act or any equivalent act in
another Jurisdiction (if the Client is an individual), if a partnership, in respect of one or more of the partners, or
if a company, a receiver, trustee, administrative receiver or similar officer is appointed, or if the Client makes an
arrangement or composition with the Client’s creditors or any procedure which is similar or analogous to any of
the above is commenced in respect of the Client.
(c) The Client is unable to pay the Client’s debts when they fall due.
(d) Where any representation or warranty made by the Client in his/her Application Form or under this Agreement
is or becomes untrue.
(e) The Client (if the Client is an individual) dies or is declared absent or becomes of unsound mind.
(f) Any other circumstances where the Company reasonably believes that it is necessary or desirable to take any
action set out in paragraph 23.2 hereunder.
(g) An action set out in paragraph 23.2 hereunder is required by a competent regulatory authority or body or court.
(h) The Company reasonably considers that the Client involves the Company in any type of fraud or illegality or
breach of Applicable Regulations or the Company is placed at risk of being involved in any type of fraud or
illegality or breach of Applicable Regulations if it continues offering Services to the Client, even when this is not
due to the Client’s wrongdoing.
(i) The Company reasonably considers that there is a material violation by the Client of the requirements
established by the legislation of the Republic of Cyprus or other countries having jurisdiction over the Client or
his/her trading activities, such being materiality determined in good faith by the Company.
(j) If the Company suspects that the Client is engaged in money laundering activities or terrorist financing or card
fraud, or other criminal activities.
(k) The Company reasonably suspects that the Client performed Abusive Trading.
(l) The Company reasonably suspects that the Client opened the Client Account fraudulently.
(m) The Company reasonably suspects that the Client performed forgery or used a stolen card to fund his/her Client
Account.
(n) The Client’s IP sends massive requests to the server that may cause delays in the execution time.

23.2. If an Event of Default occurs, the Company may, at its absolute discretion, at any time and without prior Written
Notice, take one or more of the following actions:

(a) Terminate this Agreement immediately without prior notice to the Client.

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 (b) Cancel any Open Positions.
(c) Temporarily or permanently bar access to the Online Trading System(s) or suspend or prohibit any functions of
the Online Trading System(s).
(d) Reject any Order of the Client.
(e) Restrict the Client’s trading activity.
(f) In the case of fraud, reverse the funds back to the real owner or according to the instructions of the law
enforcement authorities of the relevant country or of the Payment Network/Institution or financial institution.
(g) Cancel or reverse any profits or trading benefits and bonuses gained through Abusive Trading. Losses resulting
from Abusive Trading of the Client cannot be reversed.
(h) Take legal action for any losses suffered by the Company.
(i) Block the IP address of the Client who sends massive requests on the server, which may cause delays in the
execution time.

24. CURRENCY RATE CONVERSIONS

24.1. Whenever we conduct currency conversions, we will do so at such a reasonable rate of exchange as we shall select.
We shall be entitled to charge and retain for our own account a markup on the exchange rates for arranging such
conversion as we may, from time to time, specify to you and publish on our Website.

25. LANGUAGE

25.1. You accept and understand that our official language is the English language, and you should always read and refer
to the Website for all information and disclosures about us and our activities. A translation or information provided
in languages other than English on our websites is for informational purposes only and does not bind us or have
any legal effect whatsoever nor responsibility or liability regarding the correctness of the information therein.

25.2. This Agreement can be translated into different languages. If there are any inconsistencies between different
language versions, the English language version shall prevail.

26. FORCE MAJEURE

26.1. Except as expressly provided in this Agreement, we will not be liable or have any responsibility for any type of loss
or damage arising out of any failure, interruption, or delay in performing our obligations under this Agreement
where such failure, interruption or delay is due to:
(a) Any act, event or occurrence (including, without limitation, any strike, riot or civil commotion, terrorism, war,
an act of God, accident, fire, flood, storm, interruption of power supply, electronic, communication equipment
or supplier failure, civil unrest, statutory provisions, lockouts) which, in Company’s reasonable opinion,
prevents Company from maintaining an orderly market in one or more of the Instruments
(b) The suspension, liquidation or closure of any market or the abandonment or failure of any event to which the
Company relates its Quotes or the imposition of limits or special or unusual terms on the trading in any such
market or on any such event
(c) Non-performance by a third party, destruction caused by man or any similar event which is outside the
Company’s reasonable control
(d) Instances of illegitimate actions, errors, failures, disruptions in the Company’s systems, technological or other
infrastructure (irrespective of whether it belongs to the Company or a third party) against the Company’s
servers

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 (e) Changes in the applicable legislation, any action of an official body or any other change in the Company’s legal
or regulatory obligations as a result of unforeseen events
(f) An act or omission by any financial or other institution that the Company is unable to predict and/or prevent
(g) Abnormal market conditions, such as significant volatility or instability in the markets, or the industry as a
whole, preventing the Company from providing its services in an orderly manner, including any instances
where it is unable to receive data and/or receive incorrect data from their service providers
(h) Any event that prevents the Platform or the systems from operating on an orderly or normal basis
(i) Government actions, the outbreak of war or hostilities, the threat of war, acts of terrorism, national
emergency, riot, civil disturbance, sabotage, requisition, or any other international calamity or political crisis
(j) An act of God, earthquake, hurricane, typhoon, flood, fire, epidemic or another natural disaster
(k) Labour disputes, not including disputes involving our workforce
(l) The suspension of trading on a Market, or the fixing of minimum or maximum prices for trading on a Market,
a regulatory ban on the activities of any party (unless we have caused that ban), decisions of state authorities,
governing bodies of self-regulating organisations, decisions of governing bodies of organised trading Online
Trading Systems
(m) A moratorium on financial services being declared by appropriate regulatory authorities or any other acts or
regulations of any regulatory, governmental, or supranational body or authority
(n) A breakdown, failure or malfunction of any electronic equipment, network and communication lines (not due
to the bad faith or wilful default of ourselves), hacker attacks and other illegal actions against our server and
Online Trading System(s)
(o) Any event, act or circumstance not reasonably within our control and the effect of that event(s) is such that
we are not in a position to take any reasonable action to cure the default
(p) Decisions by the legislative and/or other bodies of the Cyprus Republic (including the Central Bank, the Cyprus
Securities and Exchange Commission) and other countries that make it impossible for the Party to fulfil its
obligations under the Agreement
(q) The discontinuance or suspension of the operation of any Market
(r) The failure of communication for any reason with Market makers, mal-functioning and/or non-operation of
any computer transaction system due to defectiveness or failure of the mechanic equipment, fault or
stoppage in communication lines, any other problems in connection, breakdown or unavailability of access to
the internet or the Online Trading System(s)
(s) The suspension of trading on a market or the liquidation or closure of any market, or the fixing of minimum
or maximum prices for trading on a market to which the Company relates its Quotes, or the imposition of
limits or special or unusual terms on the trading in any such market or a regulatory ban on the activities of
any party (unless the Company has caused that ban), decisions of state authorities, governing bodies of self-
regulating organisations, decisions of governing bodies of organised trading Online Trading Systems
(t) Extreme volatility in the Underlying Asset/Market
(u) Any other event and/or circumstance which cannot be foreseen within reason

26.2. If the Company determines in its reasonable opinion that a Force Majeure Event exists (without prejudice to any
other rights under the Agreement), the Company may, without prior notice and at any time, take any or all of the
following steps, as applicable and necessary:
(a) Suspend or modify the application of any or all terms of the Agreement to the extent that the Force Majeure

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 Event makes it impossible or impractical for the Company to comply with them
(b) Take or omit to take all such other actions as the Company deems to be reasonably appropriate in the
circumstances with regard to the position of the Company, the Client and other clients
(c) Shut down the Online Trading System(s) in case of malfunction for maintenance or to avoid damage
(d) Cancel any Client Orders
(e) Refuse to accept Orders from Clients
(f) Inactivate the Account
(g) Increase Margin requirements without notice
(h) Increase the Stop Out Level without notice
(i) Close out any or all Open Positions at such prices as the Company considers in good faith to be appropriate
(j) Increase Spreads
(k) Decrease Leverage
(l) Close any open position(s) at the price available in the circumstances
(m) Cease trading
(n) Precluding the Client from accessing or using the Platform, Client’s Platform or any other system
(o) Make any necessary amendments to open trades
(p) Allow close-only functionality
(q) Reject or delay the processing of any withdrawal request from the Client Account(s)
(r) Impose special or different terms regarding any of the Client’s orders in relation to size, volatility and/or
liquidity of the instrument, amongst others
(s) Remove or temporarily suspend any products or change any contract specifications
(t) Exercise any right to which the Company is entitled under the Agreement and the Company’s Order Execution
Policy
(u) Amend or cancel any closed trade(s)

26.3. The Company will exercise all necessary endeavours to resume the orderly provision of the Investment services as
soon as reasonably possible. Where this is not possible at all, the Company will inform the Client of the necessary
actions to be taken in order to protect both their interests, where possible.

26.4. Where the Company is unable to perform any of the obligations to the Client under the Agreement due to a Force
Majeure event, the Company will not have breached the Agreement.

27. TERM AND TERMINATION

27.1. This Agreement shall be valid for an indefinite time period until its termination by virtue of the provisions of
paragraph 27 herein.

27.2. Without prejudice to the Company’s rights under paragraph 27.3 to terminate the Agreement immediately without
prior notice to the Client, each Party may terminate this Agreement by giving at least 2 Business Days Written
Notice to the other Party. You also have the right to terminate the Agreement according to paragraph 28 below.

27.3. We may terminate this Agreement immediately without prior notice upon the occurrence of any of the Events of
Default of paragraph 24.1 of this Agreement or any other action in the event of:
(a) A breach by any party of the Agreement by the Client
(b) Where the Company has reasonable grounds to believe that the Client has not acted in good faith, including,
but not limited to, where the Company determines that the Client has, willingly or not, abused the Company’s
Negative Balance Protection policy. This includes, but is not limited to, the Client trading (playing) the gap,
hedging their exposure using multiple trading Accounts either under the company or different company,
whether under the same profile or in connection with another Client

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 (c) The issuance of an application, order, resolution or another announcement in relation to bankruptcy or
winding-up procedures involving the Client
(d) The Client’s death or incapacity (please note that in the event of death, any funds available in the Client’s
Account shall form part of the Client’s estate
(e) A breach of any applicable law by the Client, including but not limited to any applicable anti-money laundering
laws and regulations
(f) The Client acted contrary to the Company’s “Best Interest and Order Execution Policy” or any other of the
Company’s policies or procedures
(g) We may, at our sole discretion, decide to close your account, whether or not you are in breach of this
Agreement, should we deem that appropriate

27.4. Termination of the Agreement shall not imply that any of the Client’s responsibilities cease to exist. The Client will
still be liable to pay the Company, and/or the Company will have the right to immediately deduct from the Client’s
Account:
(a) Any amount due to the Company
(b) Any expenses incurred by the Company as a result of the termination of this Agreement; or
(c) Any damage arising after an arrangement or settlement should be settled immediately. Unless both parties
agree in writing otherwise, any amount due or standing will be deducted and/or credited to the Client’s
Account.

27.5. Upon termination of this Agreement, the Company will transfer any amount available in the Client’s trading account
to the Client’s bank account, net of any outstanding amount that is due to the Company, except where the Company
is prohibited from doing so by law, or the transaction is unavailable to the payment service provider.

27.6. In the event the Company cannot proceed per paragraph 27.5 above and you have not withdrawn the remaining
balance from your account within two months from the termination date of the Agreement, we reserve the right
to charge you an account maintenance fee of 10 EUR per month (or 10 GBP, 10 CHF, and 50 PLN, respectively).

27.7. Termination by any Party will not affect any obligation which has already been incurred by either Party or any legal
rights or obligations which may already have arisen under the Agreement or any Transactions made hereunder.

27.8. Upon termination of this Agreement, all amounts payable by the Client to the Company will become immediately
due and payable, including, but not limited to, all outstanding costs and any other amounts payable to the
Company, any charges and additional expenses incurred or to be incurred by the Company as a result of the
termination of the Agreement.

27.9. Once notice of termination of this Agreement is sent and before the termination date:
(a) The Client will have an obligation to close all his/her Open Positions. If he/she fails to do so, upon termination,
the Company will close any Open Positions
(b) The Company will be entitled to cease to grant the Client access to the Online Trading System(s) or may limit
the functionalities the Client is allowed to use on the Online Trading System(s)
(c) The Company will be entitled to refuse to accept new Orders from the Client
(d) The Company will be entitled to refuse the Client to withdraw money from the Account, and the Company
reserves the right to keep the Client’s funds as necessary to close positions which have already been opened
and/or pay any pending obligations of the Client under the Agreement.

27.10. In the absence of illegal activity or suspected illegal activity or fraud of the Client or instructions from the relevant
authorities, if there is Balance in the Client’s favour, the Company will (after withholding such amounts that in the
Company’s absolute discretion considers appropriate in respect of future liabilities) pay such Balance to the Client
as soon as reasonably practicable and supply Him/her with a statement showing how that Balance was arrived at

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 and, where appropriate, instruct any Nominee or/and any Custodian to also pay any applicable amounts. Such
funds shall be delivered in accordance with the Client’s Instructions to the Client. It is understood that the Company
will affect payments only to an account in the name of the Client. The Company has the right to refuse, at its
discretion, to effect thirty-party payments.

27.11. As a Client of the Company, you agree that you will not behave in an inappropriate manner towards the Company
or any of its employees. Inappropriate behaviour can include but is not limited to Swearing, Abusive Language,
Racism, Discrimination, Harassment, Defamation, Abuse of the Chat/E-mail System, Misuse of Social Media
Channels and Spam. The Company reserves the right to terminate your Agreement in those circumstances with
immediate effect.

28. AMENDMENTS

28.1. Client Agreement For CFD Trading

The Company may unilaterally change any terms of this Agreement for any of the following reasons:
(a) Where the Company reasonably considers that:
● The change would make the terms of the Agreement easier to understand; or
● The change would not be to the disadvantage of the Client.
(b) To cover:
● The involvement of any service or facility the Company offers to the Client; or
● The introduction of a new service or facility; or
● The replacement of an existing service or facility with a new one; or
● The withdrawal of a service or facility which has become obsolete, or has ceased to be widely used, or has
not been used by the Client at any time in the previous year, or it has become very expensive for the
Company to offer.
(c) To enable the Company to make reasonable changes to the services offered to the Client as a result of changes
in:
● The banking, investment, or financial system; or
● Technology; or
● The systems or Online Trading System(s) used by the Company to run its business or offer the Services
hereunder.
(d) As a result of a request of CySEC or of any other authority or as a result of change or expected change in
Applicable Laws and Regulations.
(e) Where the Company finds that any term in the Agreement is inconsistent with Applicable Laws and
Regulations. In such a case, it will not rely on that term but treat it as if it did reflect the relevant Applicable
Laws and Regulations and shall update the Agreement to reflect the Applicable Laws and Regulations.

28.2. By using the Investment Services, the Client agrees to all the terms of service, as may be updated by the Company
from time to time. The Client should check this document regularly to take notice of any changes the Company may
have made to the Agreement. The Client acknowledges that a change which is made to reflect a change of
Applicable Laws and Regulations or a request of a supervisory body may, if necessary, take effect immediately
without prior notification to the Client. When the Company provides Written Notice, it shall tell the Client the date
it comes into effect. The Client shall be treated as accepting the change on that date unless, before then, the Client
informs the Company that the Client wishes to terminate the Agreement and not accept the change. The Client
shall not have to pay any charges as a result of terminating in this case, other than costs due and payable for

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 Services offered until the termination.

28.3. In relation to Clients who are natural persons, for any change in the Agreement where the Company elects to
provide Written Notice via a post on the Website, the Company shall also provide the said Written Notice with an
additional means of Written Notice.

28.4. Costs - The Company shall have the right to review its Fees and Costs schedule from time to time. Such changes
shall be effected on the Website, and the Client is responsible for checking for updates regularly. In the absence of
a Force Majeure event, the Company shall provide the Client with advance notice on its Website of at least 15
Business Days. The Client shall be treated as accepting the change on that date unless, before then, the Client
informs the Company that the Client wishes to terminate the Agreement and not accept the change. The Client
shall not have to pay any charges as a result of terminating in this case, other than costs due and payable for
Services offered until the termination.

28.5. Margin Requirements and Stop Out - Unless a Force Majeure Event has occurred, the Company has the right to
change the Margin Requirements and the Stop Out Level by providing at least 5 Business Days’ notice. Such changes
shall be effected on the Website and/or the Online Trading System(s), and the Client is responsible for checking for
updates regularly. The Company has the right to apply new Margin requirements to both new and already Open
Positions.

28.6. The Company has the right to change Margin requirements and the Stop Out Level without prior notice to the Client
in the case of a Force Majeure Event and especially when there are Abnormal Market Conditions and high volatility.
In this situation, the Company has the right to apply new Margin requirements to the new positions and the
positions which are already open.

28.7. Swaps - The Company has the right to change the Swaps on the Online Trading System(s) without prior notice, and
the Client is responsible for checking for updates regularly.

29. SEVERABILITY

29.1. Should any part of this Agreement be held by any Court of competent jurisdiction to be unenforceable or illegal or
contravene any rule, regulation or by the law of any Market or regulator, that part will be deemed to have been
excluded from this Agreement from the beginning, and this Agreement will be interpreted and enforced as though
the provision had never been included and the legality or enforceability of the remaining provisions of the
Agreement or the legality, validity or enforceability of this provision in accordance with the law and/or regulation
of any other jurisdiction, shall not be affected.

30. COMPLAINTS AND QUERIES

30.1. If you are dissatisfied with our services or if you have a query regarding your account or activity with us, you may
contact the Customer Support Department via live chat, e-mail or telephone. Our Customer Support department
will determine if your query can be resolved immediately or if it will require further investigation. If your query
cannot be resolved immediately, we remain committed to resolving it in a prompt manner (usually within 5
business days).

30.2. If you are not satisfied with the response to the query or grievance you received, then you may raise this further
with the Compliance Department following the process indicated in the “Official Complaints” section of the Clients
Complaints Procedure for Clients available on the Website.

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30.3. If the Client wishes to lodge a complaint, he/she must send an e-mail to the Compliance Department at
[email protected] in which the following information will need to be included:
● The Client’s first name and surname
● The Client’s Account Number
● The affected transaction number(s), if applicable
● The date and time that the issue arose; and
● An accurate description of the issue.

30.4. If a situation arises which is not expressly covered by a term of this Agreement, you and we agree to try to resolve
the matter on the basis of good faith and fairness and by taking such action as is consistent with market practices.

30.5. If you are unhappy with the service that you receive from us or if we have been unable to resolve the complaint to
your satisfaction, you may be entitled to refer the matter to the Financial Ombudsman Service (which provides
consumers with a free, independent service for resolving disputes with investment firms), as described in the
Complaints procedure for clients, available on the Website.

30.6. The Client’s right to take legal action remains unaffected by the existence or use of any complaints procedures
referred to above.

31. APPLICABLE AND GOVERNING LAW AND JURISDICTION

31.1. If a settlement is not reached by the means described in paragraph 31, all disputes and controversies arising out of
or in connection with the Agreement shall be finally settled in court in Cyprus.

31.2. This Agreement and all transactional relations between you and us are governed by the Laws of Cyprus.

31.3. All transactions on your behalf shall be subject to the Applicable Laws and Regulations. We shall be entitled to take
or omit to take any measures which we consider desirable in view of compliance with the Applicable Laws and
Regulations in force at the time. Any such measures shall be binding on you.

31.4. All rights and remedies provided to the Company under the Agreement are cumulative and are not exclusive of any
rights or remedies provided by law.

32. NON-EXERCISE OF RIGHTS

32.1. Either Party’s failure to seek redress for violations, or to insist upon strict performance of any condition or provision
of this Agreement or its failure to exercise any right or remedy to which we are entitled under this Agreement, shall
not constitute an implied waiver thereof.

33. INDEMNITY

33.1. The Client shall indemnify the Company on demand against all liabilities, costs, expenses, damages (including
reputational) and losses (including, but not limited to, any direct, indirect or consequential losses), and all interest,
penalties and professional costs and expenses (calculated on a full indemnity basis) incurred by as a result of:
● The Client’s breach of the Agreement
● The provision by the Client of any false or misleading information to the Company; and/or
● The enforcement of the Agreement.

33.2. In general, indemnity means a sum of money paid as compensation for losses suffered.

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33.3. You agree to indemnify us against any loss, liability, cost, claim, action, demand, or expense incurred or made
against us in connection with the proper performance of your obligations under this Agreement except where that
loss, liability, cost, claim, action, demand, or expense arises from our gross negligence, fraud or wilful default or
that of our employees.

34. LIMITATION OF LIABILITY

34.1. The Company shall not be liable for any loss suffered by the Client in connection with the Services it provides to the
Client under this Agreement unless such loss arises directly from the gross negligence, wilful default or fraud of the
Company.

34.2. Subject to the terms of this Agreement and Applicable Laws and Regulations, the Client agrees that the Company’s
maximum aggregate liability to the Client, whether in contract, tort (including negligence) or otherwise, shall not
exceed the higher of the amount that would be recoverable by the Company under the Company’s professional
indemnity insurance if the Client’s claim had been satisfied in full (less any amount, other than any excess payable
by the Company under the terms of such insurance, that the Company is unable to recover through no fault of the
Company).

34.3. It is provided that the Company shall not be liable to the Client or any other person for any consequential,
circumstantial, special or indirect damages (including without prejudice to the generality of the aforementioned,
loss of profit, loss of opportunity, commercial losses and damages) which are incurred by the Client in connection
with this Agreement.

34.4. The Company will not be held liable for any loss or damage, or expense or loss incurred by the Client in relation to,
or directly or indirectly arising from but not limited to:
(a) Any error, failure, interruption, disconnection in the operation of the Online Trading System(s), or any delay
caused by the Client Platform or Transactions made via the Client Platform, any technical problems, system
failures and malfunctions, communication line failures, equipment or software failures or malfunctions,
system access issues, system capacity issues, high internet traffic demand, security breaches and
unauthorised access, and other similar computer problems and defects.
(b) Any failure by the Company to perform any of its obligations under the Agreement as a result of a Force
Majeure Event or any other cause beyond its control.
(c) The acts, omissions, or negligence of any third party.
(d) Any person obtaining the Client’s Access Data that the Company has issued to the Client prior to the Client’s
reporting to the Company of the misuse of his/her Access Data.
(e) Unauthorised third parties having access to information, including electronic addresses, electronic
communication, personal data, and Access Data when the above are transmitted between the Parties or any
other party, using the internet or other network communication facilities, post, telephone, or any other
electronic means.
(f) Any of the risks from the Risks Disclosure and Warnings Notice materialises.
(g) Currency risk materialises.
(h) Any changes in tax rates.
(i) The occurrence of Slippage.
(j) The Client relies on functions such as Trailing Stop, Expert Advisor and Stop Loss Orders.

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 (k) Under abnormal Market Conditions.
(l) Any acts or omissions (including negligence and fraud) of the Client and/or his/her Authorised Representative.
(m) For the Client’s or his/her Authorised Representative’s trading decisions.
(n) All Orders given through and under the Client’s Access Data.
(o) The contents, correctness, accuracy, and completeness of any communication spread by the use of the Online
Trading System(s).
(p) In the event the Company provides information, recommendations, news, information relating to
transactions, market commentary or research to the Client (or in newsletters which it may post on its Website
or provide to subscribers via its Website or otherwise), the Company shall not, in the absence of its fraud,
wilful default or gross negligence, be liable for any losses, costs, expenses or damages suffered by the Client
arising from any inaccuracy or mistake in any such information given.
(q) Your trading decisions.

34.5. The Company shall not be liable for any loss or expense incurred by the Client in connection with, or directly or
indirectly arising from the acts, omissions or negligence of any third-party software including, but not limited to,
expert advisors, signal providers, social trading platforms, and virtual private network.

34.6. You hereby agree and acknowledge that in the event of downtime of the Trading Platform, you shall waive any
claims against Libertex of missed profits and/or claims that you would have executed an order on a specific price
during the downtime. You acknowledge that sometimes there may be technical issues or faults with the Trading
Platform.

35. REPRESENTATIONS AND WARRANTIES

35.1. By agreeing to be bound by this Agreement, and again on each occasion that you place an Order, you represent
and warrant to us as follows:

(a) You are placing the Order and entering into the Transaction as principal (that is on your own behalf and not
for any third party as agent or representative or trustee or custodian on behalf of someone else) unless you
have produced, to our satisfaction, a document and/or powers of attorney enabling you to act as
representative and/or trustee of any third party and relevant identification documents for such a third party.
(b) You are entering into the performance of the terms of this Agreement, and each Transaction does not breach,
conflict with or constitute a default under any law, regulation, rule, judgment, contract or another instrument
binding on you or any of your funds or assets.
(c) You are not subject to any restrictions in placing the Order or entering into the Transaction.
(d) You have not relied on any representation or information provided by us in reaching your decision to enter
into the Transaction.
(e) You are duly authorised to and have obtained all necessary power, authorisations and approval to enter into
this Agreement and to sign, and deliver to us, the Application Form and to enter into each trade, give Orders
and otherwise perform your obligations under this Agreement and the Application Form.
(f) All the information disclosed to us in your Application Form, the documentation provided and otherwise, is
true and accurate, and you undertake to inform us in writing should there be any changes to the information
provided.
(g) The documents handed over by you to us are valid and authentic, and to the best of your knowledge and
belief, the information provided in the Application Form and any other documentation supplied in connection
with the application form is correct, complete and not misleading, and you will inform us if any changes to

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 such details or information.
(h) Your funds are not in any direct or indirect way the proceeds of any illegal activity or used or intended to be
used for terrorist financing.
(i) You are over 18 years old and of sound mind, having no legal or other obstacle prohibiting you from entering
into this Agreement.
(j) You have provided us with those of your investment objectives which are relevant to our Investment Services,
for example, whether there are any restrictions on the markets or instruments in which any Transactions will
be sent for execution for you, depending on your nationality or religion.
(k) All actions performed under the Agreement will not violate any law or rule applicable to the Client or to the
jurisdiction in which the Client is a resident or any agreement by which the Client is bound or by which any of
the Client’s assets or funds are affected.
(l) The Client will not use the IP, the Online Trading System(s), or the Website in contravention of this Agreement
or for unauthorised or unlawful purposes, and he/she will use the IP, Online Trading System(s) and Website
only for the benefit of his/her Client Account and not on behalf of any other person.
(m) The Client has read and fully understood the terms of the Agreement, including the information in the
Appendices.
(n) The Client is not a Politically Exposed Person and does not have any relationship (for example, a relative or
business associate) with a person who holds or held in the last twelve months a prominent public position. If
the above statement is untrue and in the event that the Client has not disclosed this already in the Account
Opening Application Form, the Company might terminate the Client’s Account in accordance with paragraph
27.3 of this Agreement.

36. CLIENT ACKNOWLEDGEMENTS

36.1. CFDs are considered leveraged and complex products and bear high risk. To this extent, the Company offers
negative balance protection. Therefore the maximum loss that may be incurred by any Client is the amount of
his/her balance. To increase your protection, on the Libertex Platform, we are introducing negative balance
protection to the trade amount instead of the account balance.

36.2. You unreservedly acknowledge and accept that:

(a) You run a great risk of incurring losses and damages as a result of trading in CFDs, and accept and declare that
you are willing to undertake this risk. The damages may include the loss of all your money and also any
additional commissions and other expenses.
(b) CFDs carry a high degree of risk. The gearing or leverage often obtainable in CFDs trading means that a small
deposit or down payment can lead to large losses as well as gains. It also means that a relatively small
movement can lead to a proportionately larger movement in the value of your investment, and this can work
against you as well as for you. CFDs Transactions have a contingent liability, and you should be aware of the
implications of this, in particular, the margin requirements.
(c) When trading in CFDs, you are trading on the outcome of the price of an Underlying Asset (e.g., currency or
metal or commodity), and that trading does not occur on a Regulated Market but Over-The-Counter (OTC).
(d) You have chosen the particular type of Investment Service and Financial Instrument, taking your total financial
circumstances into consideration which you consider reasonable under such circumstances.
(e) You agree and understand that trading on an electronic Online Trading System(s) carries risks.
(f) You have read our Risk Disclosure and Warnings Notice, which is found on our Website.

36.3. We shall not be contractually committed with any legal or/and natural person wishing to become a retail or

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 professional Client of the Company until such time that the Company has confirmed to such person that it has
approved the Client and the Client has successfully initially funded such an Account.

36.4. The terms of this Agreement, as amended from time to time and as they are published in the Website of the
Company, override any previous, current or future representation, expressed or implied, made or to be made by
us and/or any of our representatives, and shall be the only legally enforceable mean that defines the relationship
between the Client and the Company.

36.5. The Client acknowledges that he/she has read, fully understood and accepted the contents of this Agreement
together with the Privacy and Cookies Policy, Summary of Conflicts of Interest Policy, Summary Best Interest and
Order Execution Policy, Risks Disclosure and Warning Notice, Client Categorisation Policy, Investors Compensation
Fund, Complaints Procedure for Clients and solely based on these contents he/she has willingly entered into a
legally binding agreement with the Company. For all the information about the Company and its activities, including
any other documentation referenced in this agreement, the Client should always refer to the legal documentation
posted on the website of the Company.

36.6. The Client accepts and understands that it is his/her full responsibility to monitor for updates of the applicable
Agreement in force as published on the Website of the Company from time to time. Any viewer or user of the
Website, whether Client or not, accepts and understands that the use of the website of the Company, or of any
form of access through this website of the information shown or of a service offered by the Company, constitutes
knowledge and acceptance of the Agreement and all its contents.

37. CONFLICTS OF INTEREST

37.1. The Client acknowledges and accepts that he/she has read and fully understands the Company’s Summary of the
Conflicts of Interest Policy.

37.2. The Company is required by law to take all necessary precautions in order to avoid conflicts of interest between
the Company and its Clients, and when they cannot be avoided, the Company shall ensure that the Clients are fairly
treated and their interests are protected at all times. The Company shall make all reasonable efforts to manage the
conflict of interest.

37.3. Should the Company pay or receive any fees or inducements to third parties, the Company shall disclose to the
Client the information required by the applicable regulations.

38. CLIENT CONSENT

38.1. You agree and understand that you will not be entitled to delivery of, or be required to deliver, the Underlying
Asset of the Financial Instrument, nor ownership thereof or any other interest therein.

38.2. You agree and understand that no interest shall be due on the money we hold in your Account.

38.3. You agree and understand that CFDs trading is not done in a regulated market.

38.4. You solemnly declare that you have carefully read and fully understood the entire text of this Agreement, the Fees
and Costs and the Contract Specifications (which form the Agreement between us) with which you fully agree.

38.5. You specifically consent to the provision of the Agreement and our various policies (of paragraph 40.5 above) and
any amendments thereto by means of our website, and you confirm that you have regular access to the internet in

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 order to refer to these at any time. It is understood that if you wish, you may request the same to be sent by post,
e-mail or facsimile.

38.6. You consent to us providing you with Trade Confirmations and Reports via our Online Trading System(s). It is
understood that you have the right to ask the Company for Reports to be sent by post, e-mail, or facsimile.

39. FINAL PROVISIONS

39.1. The Agreement overrides any other agreements, arrangements, express or implied statements made by the
Company.

39.2. Questions regarding the Agreement should be addressed to the Compliance Department via e-mail at
[email protected]

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