Client Account Agreement Windsor Brokers

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CLIENT ACCOUNT AGREEMENT

Windsor Brokers (BZ) Ltd


IFSC

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DISCLAIMER
This is a live document and should be read by the intended recipients, that
being the current and/or prospective clients of Windsor Brokers and/or
those individuals, natural and/or legal persons, which are authorised by
Windsor Brokers. The material and information provided within are
protected by copyright as a collective work under the Republic of Cyprus
copyright laws, owned by Windsor Brokers. Any reproduction,
retransmission, republication, or other use of all or part of any procedure
including but not limited to posting, linking, or otherwise modifying its
contents is expressly prohibited, unless prior written permission has been
granted by Windsor Brokers. Windsor Brokers, retains the right to alter
and/or amend any of its terms at its absolute discretion without first
obtaining the consent of the client. Except as required by law, Windsor
Brokers shall not accept any responsibility and/or be held liable for any
damages (direct, indirect, incidental, special, consequential, or exemplary),
resulting from unlawful and/or inappropriate use of information provided.
By this Client Account Agreement (the “Agreement”), Windsor Brokers (BZ) Ltd. (“Company”) agrees to
open and maintain for the undersigned (the “Client”) one or more accounts and to act as principal for the
Client for the execution and clearance of order/request(s) for transactions involving the purchase and sale
of Financial Instruments including but not limited to futures contracts; options; commodities and forward
contracts; foreign exchange transactions; contracts for differences; any other foreign currency -
denominated Financial Instruments and any other financial transaction (collectively referred to as
“Financial Instruments”), and in consideration thereof, the Client agrees to the following:

1. DEFINITIONS AND INTERPRETATIONS

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

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

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3. APPLICABLE RULES AND REGULATIONS
All order/requests entered into for the purpose of purchase/sale of Financial Instruments and all
transactions executed for the Client's account(s) shall be subject to the constitution, by-laws,
rules, regulations, customs and usages (collectively “rules”) where such transactions are
executed and to the rules and regulations promulgated there under (collectively “laws”). The
Company shall not be liable to the Client as a result of any action taken by the Company or its
agents in compliance with any of the foregoing rules or laws. This paragraph is solely for the
protection and benefit of the Company, and any failure by the Company or its agents to comply
with any of the foregoing rules or laws shall not relieve the Client of any obligation under this
Agreement nor be construed to create rights under this Agreement in favor of the Client against
the Company. In the event that any term of this Agreement be inconsistent with a requirement
set by regulatory authority and/or the law, after the production of this Agreement, the Company
will update terms and conditions of this Agreement, to comply with new regulatory requirement
and/or the law, while such changes will automatically be applicable to the relationship between
the Company and the Client.

The Company may also hold money on behalf of the Client in different bank(s) or entities from
the one used by the Client for transferring funds to the Company. In such cases, the legal and
regulatory regime applying to any such bank or entity will be applicable in the event of the
insolvency or any other analogous proceedings in relation to that bank or entity.
The Company will not be liable for the insolvency, acts or omissions of any third party referred
to in this Agreement , nor of any law imposed in any such given country at any such time where
the Company has no control over such and any acts of force majeure.

4. PROVISION OF INFORMATION AND REPORTING


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

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

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


The Client agrees and confirms paying:

(a) any fees, charges, commissions applicable to specific Financial Instruments(s) and account(s)
held by the Client, related to execution of position/transaction(s) ;
(b) such charge/cost(s) related to rolling over of Financial Instrument(s);
(c) such charge/cost(s) related to carrying open position/transaction(s) on specific Financial
Instrument(s);
(d) such charge/cost(s) related to inactive accounts;
(e) such transfer-related fees, including but not limited to charge/cost(s) applied on
deposits/withdrawals, returned withdrawals, issuing and returns of issued cheques;
(f) Spread, mark-up or mark-down when compared to prices that the Company receives or
expects to receive, when covering its transaction(s) with another counterparty;

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(g) Currency conversion related to trading costs and profits/losses occurred from trading
activities;
(h) Currency conversion related to amounts received in currencies different from the basic
currency used by the account(s);
(i) Such charge/cost(s) required by regulatory body and/or legal requirement;
(j) Such other taxes or costs that may exist that are not applied by the Company;
(k) the amount of any loss that may result from transactions made by the Company, on the
Client's behalf, including any deficit balance;
(l) Such interest on any deficit balance and on any other amounts payable to the Company
under this Agreement at the rate of three percent (3%) over the prime rate in effect from time to
time, as offered by London Interbank Offered Rate, or the maximum rate allowed by law,
whichever is less;
(m) Such relevant amount(s) related to subscription(s) of the Client to an exchange(s).

The Client further acknowledges:


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

6. RISK OF LOSS
All transactions effected for the Client's account(s) and all fluctuations in the market prices of
the Financial Instruments carried in the Client's account(s) are at the Client's sole risk and the
Client shall be solely liable under all circumstances at any given time. By execution of this
Agreement, the Client warrants that the Client is willing and financially able to sustain any such
losses. The Company is not responsible for the obligations of the person(s) with whom the
Client's transactions are affected, nor is the Company responsible for delays in transmission,
delivery or execution of the Client's order/request(s) due to malfunctions of communications
facilities or other causes. The Company shall not be liable to the Client for the loss of any margin
deposits which is the direct or indirect result of the bankruptcy, insolvency, liquidation,
receivership, custodianship or assignment for the benefit of creditors of any bank, another
clearing broker, exchange, clearing organization or similar entity.
The Client understands and agrees that the risk of loss in trading of Financial Instruments including but
not limited to stocks, options, futures, forex, foreign equities, bonds, contract for differences, can be
substantial. Trading of Financial Instruments involves a high degree of risk and are not suitable for all
investors; the amount the Client may lose may be greater than the initial investment. The Client

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understands and accepts that transactions on markets in other jurisdictions, including markets linked to
a domestic market, may expose the Client to additional risk. Such markets may be subject to regulation
which may offer different or diminished investor protection. The Client understands, before trading, that
the Client should enquire as to any rules relevant to the particular transaction(s).
The Client understands that most of the electronic trading facilities are supported by computer-based
component systems for the order-routing, execution, matching, registration and/or clearing of trades.
Facilities and systems may be vulnerable to temporary disruption or failure. The Client’s ability to recover
certain losses may be subject to limits on liability imposed by the system provider, the market, the clearing
house, and/or member firms.
The Client acknowledges and confirms that the Client is fully aware of all risks that may arise in the event
of adverse movement(s) of a currency and/or a pair of currencies. The Company warns the Client of the
high risk(s) involved in trading whereby the Client can sustain losses and/or damage(s) to some or all of
the capital/monies invested. All transaction(s) effected are at the Client’s sole risk and the Client is liable
under any given circumstances. Additionally, the Client understands and confirms that the Company will
not be held responsible for any delays in transmission(s), delivery or execution of request(s), due to force
majeure, malfunctions of communications facilities or other causes.
The Client understands and accepts that some of the investments may not be realizable if the market in
the Financial Instrument in concern is illiquid, therefore the identification of the risk to which the Client
may be exposed may be difficult to quantify. The price, value of, and income from any of the Financial
Instruments may fall as well as rise and clients may not receive back the amount invested or may be
required to pay more.

7. SAFEGUARDING OF CLIENT FINANCIAL INSTRUMENTS, ASSETS AND FUNDS


The Company may hold, on behalf of the Client, such client’s assets/property(s) and/or funds with
custodian(s) whereby the domestic legal and regulatory regime, may be applicable to any such entity.
Therefore, in the event of the insolvency or any other analogous proceedings, in relation to such entity(s),
the Client’s assets/property(s) and/or funds may be treated differently from the treatment which would
apply if the assets/property(s) and/or funds were held in other jurisdiction. The Company will not be liable
for the insolvency, acts or omissions of any third party, referred to in this paragraph, nor of any law
imposed in any such given country, at any such time where the Company has no control over.
The Client acknowledges that the Company has established adequate measures to ensure its
compliance with legal requirements in order to safeguard the Client’s Financial Instruments and
funds belonging to the Client. The Client understands that the Company, during the existence of
the business relationship with the Client, will keep records necessary for the Company to
distinguish Financial Instruments and funds held for the Client from the Financial Instruments
and funds held by the Company for other clients and from the Company’s Financial Instruments
and own funds.
The Client’s funds are segregated from the Company’s own funds and are not used for the
Company’s own account.

8. INDEMNIFICATION
The Client hereby agrees to indemnify the Company and hold the Company harmless from any liability,
cost and/or expense(s) (including attorneys' fees and expenses and any fines and/or penalties imposed
by any governmental agency, contract market, exchange, clearing organization or other regulatory or
self-regulatory body or institution) which the Company may incur or be subjected to, with respect to the
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Client's account(s) or any transaction or position therein. Without limiting the generality of the foregoing,
the Client agrees to reimburse the Company on demand for any cost of collection incurred by the
Company in collecting any sums owing by the Client under this Agreement and any cost incurred by the
Company, including legal action/proceeding(s), in defending against any claims asserted by the Client,
including all attorneys' fees, interest and expenses. The Client hereby agrees and acknowledges being
liable for the Client’s own costs and/or expenses, unless directed otherwise by any court of law and/or
regulatory body. The Client furthermore confirms and agrees that all information provided to the
Company for purposes of account opening is true and correct, the Client will provide all the relevant
information regarding Client’s knowledge and experience in the investment field relevant to product
and/or service as the case may be, and as requested by the Company. In the event that the Client provides
insufficient/false information regarding knowledge and experience as to any product and/or service, the
Client understands and agrees that such information will not allow the Company to determine whether
the investment service(s) and/or Financial Instrument(s) envisages is appropriate for the Client.
The Client understands and accepts that the Company does not provide financial, legal, tax or other
advice(s), nor should any investment or any other decisions be made solely based on the information
obtained from the Company, the Company recommends the Client to obtain advice on such matters from
specialists.
All information and opinions expressed by the Company is obtained from sources believed to be reliable
and in good faith, no representation or warranty, express or implied, is made as to its accuracy or
completeness. All material provided by the Company represents current views and is provided under
reasonable duty of care and the Company will have no liability for any direct or indirect damages arising
out of the use of information when accepted and/or used by the Client. The Client furthermore accepts
that any information on Financial Instruments, including but not limited to asset classes, asset allocations
and the like are only indicative, and the Company assumes no obligation to ensure that such information
are brought to the attention of any client.
The Company furthermore will not be held liable for any taxation assessed upon or payable directly or
indirectly by the Client or for any loss or expense suffered by the Client in connection with any such
assessment. If the Company is, at any time, assessed for taxation in respect of or in connection with the
Client’s assets, income, activities or residence, including without limitation any claim for recovery of
monies paid to or for the Client, in excess of the amounts which should properly have been paid, the
Client undertakes to indemnify the Company in respect of the relevant taxation, together with all
expenses, including but not limited to any legal fees. The Client is solely responsible for the management
of affairs for tax purposes, and the Company accepts no responsibility for any tax consequences of
anything carried out within scope of authority.
In addition, the Company will not be liable for any loss or expense suffered by the Client in connection
with the terms and conditions, including but not limited to the insolvency or other default of any
counterparty or custodian, unless such loss or expense arises from the Company negligence, willful
default or fraud. Without prejudice to the foregoing, the Client accepts to reimburse the Company of any
cost, loss, liability or expense whatsoever which may be suffered or incurred by the Company, whether
directly or indirectly, in connection with or as a result of the Client’s failure to perform or delay in
performing any obligations stemming from this Agreement.
The Company gives no warranty as to the performance or profitability of any Financial Instrument in order
for the Client to secure a level of income or capital gain.
The Company will not be responsible for any loss or loss of opportunity, whereby the value of the
Financial Instruments, assets and/or funds could have been increased, nor for any decline in the value of
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such, nor for any loss arising from errors of fact or judgment or any action taken or omitted to be taken,
however arising and whether direct, indirect, financial or consequential loss howsoever causes, except
to the extent that any such error, act or omission is caused by the Company negligence, willful default or
fraud.

9. RECORDING
The Client understands that all communication regarding the Client's account(s), order/request(s) for
acquiring Financial Instruments, between the Client and the Company, may be recorded by the Company,
and the Client irrevocably consents to such recordings and waives any right to object to the Company’s
use of such recordings in any proceeding or as the Company otherwise deems appropriate.
The Client agrees and consents that the Company, records telephone conversation(s) between the
Company and the Client. The Client agrees that such recording(s) remains the property of the Company
and may be used as a proof of evidence, legal and/or moral obligation(s).

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

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

10. FOREIGN CURRENCY


In cases where the transaction(s) for the Client's account(s) is effected through Online Trading Platform,
on any exchange or in any market on which transaction(s) are settled in a foreign currency, and the assets
and/or funds of the Client are displayed in the base currency of the account(s), any profit or loss arising,
as a result of a fluctuation in the rate of exchange between the traded currency and the base currency of
the account(s) shall be entirely for the Client's account(s) and at the Client's sole risk. The Company is
hereby authorized to convert funds in the Client's account(s) into and from such foreign currency, at such
currency conversion rate(s) based on the prevailing market rate plus/minus 1% up to 2%.
In cases where the fund(s) transactions for the Client’s account(s) is effected and settled in a foreign
currency, whereby the exchange is not performed by the Company, the Client hereby acknowledges and
agrees that the Company is not liable for such conversion.

11. MARGIN REQUIREMENTS


The margin requirement is considered a guarantee for each open position/transaction and is based on
the leverage applicable on the Client’s account(s). The Client agrees to maintain at all times, without
demand from the Company, margin requirements for the open positions/transactions held in the Client's
account(s). The Client will, at all times, maintain such margin or collateral for the Client's account(s), as
requested or notified from time to time by the Company either through the Online Trading Platform or
otherwise. Margin deposits shall be made by wire transfer of immediately available funds, or by such
other means as the Company may direct, and shall be deemed to have been available when received by
the Company. The Company’s failure at any time to call for a deposit of margin shall not constitute a
waiver of the Company’s rights to do so at any time thereafter, nor shall it create any liability of the
Company to the Client. The Client furthermore agrees and confirms that margin requirement may be
changed by the Company and that such change shall be applicable to the existing open
positions/transactions as well as the transactions that shall take place in the future. In cases where the
Client does not meet obligations towards the margin requirements, the Client’s account(s) becomes

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subject to stop out activity and consequently open positions/transactions may be partially or fully hedged
and/or closed/liquidated by the Company. The levels whereby the Company may hedge and/or liquidate
open positions/transactions are based on prevailing market price(s) and/or last available price(s) on the
specific Financial Instrument(s).

12. LEVERAGE
Leverage is defined as a borrowed capital, used to increase or reduce the potential return on an
investment. The Client agrees and acknowledges that marginal trading is based on the leverage applied
on the Client’s account(s). The higher leverage, the higher the level of risk and the higher possibility of a
profitable return or loss.
The leverage is subject to changes. The Company may, at any time, in its sole discretion, reduce the
leverage applied to the Client’s account(s) by notifying clients about such change(s).

13. LIQUIDATION OF POSITIONS/TRANSACTIONS


In the event that (a) the Client shall fail to timely deposit or maintain margin or any amount
hereunder; (b) the Client (if an individual) passes away, or be judicially declared incompetent, or
placed under curatorship or (if an entity) shall be dissolved or otherwise terminated or placed
under curatorship; (c) a proceeding under the Bankruptcy Act and/or any Legislation, an
assignment for the benefit of creditors, or an application for a receiver, custodian, or trustee
shall be filed or applied for by or against the Client; (d) attachment is levied against the Client's
account(s); (e) the property deposited as collateral is determined by the Company in its sole
discretion, regardless of current market quotations, to be inadequate to properly secure the
account(s); or (f) at any time the Company deems it necessary for its protection for any reason
whatsoever, the Company may, in the manner it deems appropriate, close out the Client's open
position/transaction(s) in whole or in part, sell any or all of the Client's property held by the
Company, buy any securities, Financial Instruments, or other property for the Client's account(s),
and may cancel any outstanding order/request(s) and commitments made by the Company for
the Client. Such sale, purchase or cancellation may be made at the Company's discretion without
advertising the same and without notice to the Client or his/her Business Introducer, agent
and/or representative and without prior tender, demand for margin or payment, or call of any
kind upon the Client. The Company may sell or purchase the whole or any part thereof free from
any right of redemption. It is understood that a prior demand or call or prior notice of the time
and place of such sale or purchase shall not be a waiver of the Company's right to sell or buy
without demand or notice as herein provided. Subject to applicable laws and rules, and in order
to prevent non-permitted trading in debit/deficit accounts, profits on any transactions executed
without the Company's express permission, for the Client’s account that is debit/deficit at the
time the order/request(s) is placed, shall be for the Company's account if the Company in its
discretion so elects. Losses on any such transactions shall be jointly and severally borne by the
Business Introducer, agent and/or representative if any, and the Client, decision made by the
Company in its sole discretion. The Client shall remain liable for and pay the Company the amount
of any deficiency in any of the Client’s account(s) held with the Company resulting from any
transaction described above. The Company’s determination of the current market value and the
amount of additional and/or variation margin shall be conclusive and shall not be challenged by
the Client.
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14. TRADING LIMITATIONS
The Client agrees and acknowledges that the Company at any time, in its sole discretion, may limit
the number of open positions/transactions which the Client may maintain or acquire with the
Company, and the Company is under no obligation to effect any transaction for the Client's
account(s) which would create positions/transactions in excess of the limit which the Company
has set. The Client agrees not to exceed the position/transaction limits established for any
contract market or type of account, whether acting alone and/or with others at any given time;
The Company, in its sole discretion, reserves the right to change the leverage applied to clients’
accounts, provided that, at the time of the conclusion of the transaction(s), the total number of
open positions/transactions, held by the Client’s account(s), has reached the preset limitation and/or in
cases where the Client has deliberately and/or systematically based on his/her trading strategy or
other probable behaviour with an attempt to exploit the ability of using marginal trading, with
the aim to increase the potential return of an investment, while such an activity automatically
increases the level of risk and the possibility of a loss.

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

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

In the above-mentioned cases the Company reserves the right to either 1) cancel the transaction
altogether, 2) correct/modify the erroneous price at which the transaction(s) was executed to
the price at which the Company hedged the transaction, 3) correct the erroneous price
alternatively to the fair market value of the price, as determined by the Company, in its sole
discretion, at the time such error occurred.

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

Mistype of a quote or misquote might be given by telephone and/or electronic means. In such
occasions, the Company will not be held liable for any resulting errors that may be displayed in
the Client’s account(s) and reserves the right to make necessary corrections or adjustments with
respect to the account(s) involved.
Any errors may adversely affect realised and unrealised gains and losses of account(s).

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

Trading strategies aimed at exploiting errors in prices and/or concluding transaction(s) prices that are not
representing the market value(s), are not permitted/accepted. The Company reserves the right to act
upon clients found to be using abusive trading strategies, whether by using sophisticated technology or
manual methods when such trading is based on errors. Clients’ trading account(s) found to be using the
abusive trading strategies, associated with algorithmic and high frequency trading are subject to
correction(s)/modification(s) and in cases may be subject to closure of the trading account(s), should the
Company find such an activity fit.
The Company is entitled to take one or more of the following counter measures:
a) adjust the price(s) provided to the Client;
b) adjust the price spreads offered to the Client;
c) change the trading conditions/limitations applied to the Client’s account(s);
d) cancel the transaction(s);
e) delay in price confirmation and/or re-quote the price(s) offered;
f) restrict the Client’s access to streaming, instantly tradable quotes, by providing manual quotation
only;
g) retrieve from the Client’s account(s) any historic trading profits, provided that the Company can
document that such trading profits have been made through exploiting of errors in price(s), at any time
during the relationship with the Client;
h) terminate the relationship with the Client immediately by the way of written notice;

Trading strategies where transaction(s) are executed within a short time scale, may be permitted by the
Company for as long as the trading strategy used by the Client is not considered abusive.
However, should the Client base the trading strategy for the purpose of abusing prices offered by the
Company, the Company is entitled to take one or more of the following counter measures:
a) adjust the price(s) provided to the Client;
b) adjust the price spreads offered to the Client;
c) change the trading conditions/limitations applied to the Client’s account(s);
d) cancel the transaction(s);
e) delay in price confirmation and/or re-quote the price(s) offered;
f) restrict the Client’s access to streaming, instantly tradable quotes, by providing manual quotation
only;
g) retrieve from the Client’s account(s) any historic trading profits provided that the Company can
document that such trading profits have been gained through such abuse of price(s), at any time during
the relationship with the Client;
h) terminate the relationship with the Client immediately by the way of written notice.

17. EXERCISES AND ASSIGNMENTS


With regard to options transactions, the Client understands that some exchange clearing houses
have established exercise requirements for the tender of exercise instructions and that option
will become worthless in the event that the Client does not deliver instructions by such
expiration times. At least two business days prior to the first notice day in the case of long
positions in futures or forward contracts, and at least two business days prior to the last trading
day in the case of short positions in open futures or forward contracts or long and short positions
in options, the Client agrees that the Client will either give the Company instructions to liquidate

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

18 SECURITY AGREEMENT
(a) Financial Instruments, funds, securities, and/or other property in the Client's account(s) or
elsewhere now or at any time in the future held by the Company for any purpose, including
safekeeping, are subject to a security interest and general lien in the Company's favor to secure
any indebtedness at any time owed by the Client to the Company, including any indebtedness
resulting from any guarantee of a transaction or of a account(s) of the Client or the Client's
assumption of joint responsibility for any transaction or of a account(s). From time to time and
without prior notice to the Client, the Company may transfer interchangeably between and
among accounts of the Client, held by the Company, any of the Client's funds (including
segregated funds), securities, commodities, Financial Instruments and/or other property for
purposes of margin, reduction or satisfaction of any debit balance, or any reason which the
Company deems appropriate. Within a reasonable time after any such transfer, the Company will
confirm the transfer in writing to the Client;
(b) The Client hereby grants to the Company the right to pledge, repledge, hypothecate, or
invest either separately or with the property of other clients, any securities or other property
held by the Company for the Client’s account(s) or as collateral therefore, including without
limitation to any exchange or clearing house through which transactions of the Client are
executed. The Company shall be under no obligation to pay to the Client or to his/her account(s)
for any interest income or benefit derived from such property and funds or to deliver the same
securities or other property deposited with or received by the Company for the Client. The
Company may deliver securities or other property of like or equivalent kind or amount; the
Company shall have the right to offset any amounts it holds for or owes to the Client against any
debts or other amounts owed by the Client to the Company.

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

20. INACTIVE ACCOUNTS


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

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

The Client acknowledges and agrees that inactive account(s) is further considered dormant
account(s) and removed from the system(s) accordingly.

21. NOTICES AND COMMUNICATIONS


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

22. PRINTED MEDIA STORAGE


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

23. SAFEGUARDING OF PERSONAL INFORMATION


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

24. REPRESENTATIONS
The Client represents that (a) (if an individual) is of the age of majority, of sound mind, and
authorized to open account(s) and enter into this Agreement and to effectuate transactions in
Financial Instruments as contemplated hereby; (b) (if an entity) the Client is validly existing and
empowered to enter into this Agreement and to effect transactions in Financial Instruments as
contemplated hereby; (c) the statements and financial information contained on the Client's
Account Application submitted herewith (including any financial statement therewith) are true
and correct; and (d) no person or entity has any interest in or control over the account(s) to
which this Agreement pertains except as disclosed within the Agreement. The Client further
represents that, except as heretofore disclosed to the Company in writing, the Client is not an
officer or employee of any exchange, board of trade, clearing house, or an employee or affiliate
14
of any futures commission merchant, or an introducing broker, or an officer, partner, director,
or employee of any securities broker or dealer, is not a person or entity who is resident of Belize
nor is a US person. The Client agrees to furnish appropriate financial statements to the Company,
to disclose to the Company any material changes in the financial position of the Client and to
furnish promptly such other information concerning the Client as the Company reasonably
requests.

25. INTRODUCERS
The Client, introduced to the Company through introducer(s), acknowledges and confirms that the
Company is not responsible for the conduct and/or representations of the introducer(s) or its associated
person(s) while representing the Client to the Company. The Client agrees to waive any claims the Client
may have against the Company, and to indemnify and hold the Company harmless for any action(s) or
omission(s) of the introducer(s) or its associated person(s). The Client acknowledges and confirms that
the Company does not bear responsibility for whatever agreements may be reached between the Client
and the Client’s introducer(s). The Client furthermore confirms and acknowledges that introducer(s) may
act only independently or as Agent(s) of the Client and that introducer(s) is not authorised to make
representations concerning the Company or its services nor is authorised to act on behalf of the Company.
The Client acknowledges and confirms that the Company has the right to provide the Client’s introducer(s)
and its associated person(s) with the information related to the transaction(s) of the Client’s account(s).
The Client acknowledges, agrees and confirms that additional costs, including but not limited to increased
spread, commission, fees etc, and may be applicable in cases where the Client is introduced to the
Company through introducer(s), since the Company may be required to pay commissions, fees or other
related costs to the introducer(s) and associated person(s). Costs related to transactions are provided to
clients prior to commencement of business relationship or during the business relationship in cases of
changes.
The Client acknowledges and confirms that, in cases where the Company is acting as principal, the Client’s
introducer(s) and associated persons may have ”View Only” access to one or more terminals, including
terminal access through internet browser, to electronically monitor the activities of the Clients' account(s)
introduced by the introducer(s) to the Company.

26. CONFLICTS OF INTEREST

The Company (directly or through its Service Provider(s)) may execute Financial Instruments for
the Client's account(s) either as principal or broker. As broker, the Company will execute
transaction similar to the Client's transaction with another market participant in the financial
market. As principal the Company may not execute transaction similar to the Client in the
financial market and hold the opposing transaction in the Company's inventory of Financial
Instruments. As a result of acting as principal the Client should realize that the Company may be
acting as the Client’s counter party and that the Company may be placed in such position that a
conflict of duty occurs. The Company, its Associates or other persons connected with the
Company may have an interest, relationship or arrangement that is material in relation to any
Financial Instruments affected under this Agreement. By entering into this Agreement the Client
agrees that the Company may transact such business without prior reference to the Client. In
addition, the Company may provide advice and other services to third parties whose interests
may be in conflict or competition with the Client's interests. The Company, its Associates and the
employees of any of them may take positions opposite to the Client or may be in competition
with the Client to acquire the same or a similar position. The Company will not deliberately favor

15
any person over the Client but will not be responsible for any loss which may result from such
competition. Upon the Client request, the Company shall provide further details of its conflict of
interest policy.

27. CREDIT CARDS


The Client hereby confirms and acknowledges that any payment(s) made by Credit Card(s), will
bear the Client’s name and will be credited into Client’s account(s) held with the Company. The
Client confirms and acknowledges that the sole purpose for such payments is in accordance with
the purpose of this Agreement signed with the Company. The Client further confirms and
acknowledges that the right of the Chargeback shall not be permitted in cases when the
Company has already executed a requested transaction. The Client hereby confirms and
acknowledges that the right of the Chargeback shall not be permitted if the Credit Card(s) has
been stolen taking into consideration the 3D secure policy, used by the Company, by which such
payment(s) are not approved. Additionally, the Client confirms and acknowledges that due to
the type of services and activities provided by the Company, the Client is not permitted to claim
that the performance did not correspond to a written description so as to cancel the services.
Should the Client request the Chargeback claiming that the performance did not correspond as
per the Client’s instruction, the Client confirms and acknowledge that the Company has the right
to provide any relevant entity/person, with the required documentation in regards to such
Client’s account(s), in order to prove any transactions/allegation.
The Client confirms and acknowledges that the Company will not be held responsible regarding
any delays that may occur in regards to Credit Card(s) transactions, caused by third parties,
during the process of such transactions, or due to any other laws/impediments given or made in
any jurisdiction at such given time of any such transactions.
In the event of a dispute related to the Chargeback, the Client agrees that the Company has the
right to withhold the Chargeback in a reserve until the dispute is finalized. The Client understands
and agrees that it may happen, as a consequence of the reserved Chargeback, that such
Chargeback may reflect on any of the transaction(s) of the Client’s account(s).
The Client shall be liable for all and any of the costs paid to the credit card processor or bank(s),
other third parties, attorneys' fees and other legal expenses, and the reasonable value of the
time that the Company spent on the matter, incurred during the process of the dispute
resolution.
To the extent permitted by law, the Company may set off against the Balances for any obligation
and liability of the Client, including without limitation any Chargeback amounts.

28. TRANSFERS
Transfers are made using the authorised transfer channels and in different currency(s) specifically in US
dollars, Euro, Pounds Sterling or any other currency stipulated by the Company to the Client.
The Client hereby agrees and acknowledges that the Company shall consider only the net amounts
received while costs related to transfer(s) shall be borne by the Client. Amounts received in currency(s)
other than designated account(s)’ currency(s) may be subject to foreign currency exchange. Regardless
of the payment method, funds are credited into clients’ account(s) unless the Company requires further
information/justification/clarification in regards to the transfer(s). The Company reserves the right to
return the funds to the sender should the originator of the funds not meet the requirements. The
Company shall not be held liable in cases where fund transfer(s) are aimed to support account(s) that are
on margin call while the funds are not received/confirmed by the Company.

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

b) the requested amount would be required to meet the Client’s current or future requirement(s) in
regards to carrying open position(s);

c)the requested amount would be affected by other account(s) held in the Client’s name;

d) there is a dispute between the Company and the Client related to transaction(s) performed within
account(s) held in the name of the Client or account(s) linked to the Client;

e) there is reasonable doubt regarding the request(s) for withdrawal(s) received by the Company;

f) there is reasonable doubt regarding the activities within the Client’s account(s);

g) the beneficiary is a third party;

h) the request for withdrawal is in currency(s) other than the designated account(s) currency;

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


method.

29. BINDING EFFECT OF AGREEMENT; MODIFICATIONS; TERMINATION


This Agreement shall be binding upon and inure to the benefit of the Company, its successors
and assigns, the Client’s heirs, executors, administrators, legatees, successors, personal
representatives and assigns. The Client acknowledges and accepts to be bound by the provisions
of this Agreement and any amendment or variation thereof. From time to time, as a result of
changes to the Client’s information, the Company requires to be updated with the relevant
changes, related to personal details, account(s) or otherwise. In some cases, the Company may
require to be provided with additional data/document(s) to justify the reasoning for the
change.In addition, the Client acknowledges and agrees that the first transaction in any of the
Client’s account(s) initiated by the Client, following a change to the terms and conditions of this
Agreement as abovementioned, shall constitute the Client’s acceptance of the change as of the
effective date of the amendment or variation and such initiation and the subsequent execution
of such transaction by the Company shall constitute reciprocal good consideration for the
variance or amendment. The Client understands that the terms and conditions of this
Agreement may be varied or amended from time to time, as case may be and notice of such
amendment of change will be provided to the Client by the Company either by posting such
change on the Company’s website or by sending a notification to the Client whereby such
amendment/variation will be applicable with immediate effect or as otherwise stated.
In the event of the incapacity/death of the Client, the Company will freeze the account(s) upon
receipt of legal notification of the incapacity/death of the Client. The Client acknowledges that
in the event of his/her incapacity/death, legal notification such as letters of
administration/executorships, and/or grant of probate and/or any other legal document, will
have to be provided to the Company, by respective relevant person(s) over the Client in order
for the Company to accept any instructions or take any action, over any account held in the
Client’s name. The Client acknowledges that the Company will not be held responsible for any

17
kind of losses or any charge/cost(s) in the Client’s account(s) during the period between the
Client’s incapacity/death and receipt by the Company of any legal notice to that effect.

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

The Client may terminate this Agreement at any time and for any reason by actual delivery of
notice confirmed by an officer of the Company of written notice received by the Company,
provided however that no termination will affect any existing liabilities or indebtedness to the
Company or any liabilities or indebtedness that may arise subsequent to such termination in
respect of any act or omission that took place prior to such termination.
In the event of termination of this Agreement, the Company will return any amount held by the
Client’s account(s) after deduction of any charge/cost(s) and fees or any other deductions
required by the law or in accordance with this Agreement.

30. FORCE MAJEURE EVENTS


The Company may, in its reasonable opinion, determine that an emergency or an exceptional
market condition exists (a "Force Majeure Event"). A Force Majeure Event shall include, but is
not limited to, the following:
• Any act, event or occurrence (including without limitation any strike, riot or commotion,
interruption or power supply or electronic or communication equipment failure) which, in
the Company’s opinion, prevents it from maintaining an orderly market in one or more of the
investments in respects of which the Company ordinarily deal in Financial Instruments;
• The suspension or closure of any market or the abandonment or failure of any event upon
which the Company base, or to which the Company in any way relate, or quote, or the
imposition of limits or special or unusual terms on the trading in any such market or in any
such event;
• The occurrence of an excessive movement in the level of any Financial Instrument and/or the
underlying market or the Company’s anticipation (acting reasonably) of the occurrence of
such movements.
If the Company determines that a Force Majeure Event exists the Company may in its absolute
discretion, without notice and at any time, take one or more of the following steps:
• Increase the Client’s account(s) margin requirements;

18
• Close any or all of the Client’s account(s) open position/transaction(s) in Financial
Instruments at such closing level as the Company reasonably believe to be appropriate;
• Suspend or modify the application of all or any of the terms of this Agreement to the extent
that the Force Majeure Event makes it impossible or impracticable for the Company to
comply with the term or terms in question; or
• Alter the time for trading of a particular Financial Instrument.

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

32. GOVERNING LAW


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

33. ACCEPTANCE OF AGREEMENT


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

34. MULTIPLE ACCOUNTS


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

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

36. CLIENT ACKNOWLEDGMENTS AND SIGNATURE


The Client hereby declares that the Client fully understands the consents of this Agreement and
agrees to all of the terms and conditions of this Agreement set forth above. The Client
acknowledges that trading with Financial Instruments is speculative, involves a high degree of
risk and is appropriate only for those who can assume risk of loss in excess of their margin
deposits.

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37. CONFIDENTIALITY
The Company acknowledges that confidential information regarding the Client's personal details
is of valuable, special and unique asset and as such belongs to the Client and that such
information will not be used to advance the interests of any person(s) other than the Client. The
Company procures that its employees, Service Providers, to whom the confidential information
is disclosed, are informed of such nature and the employees and the Company shall limit the
disclosure of the Client's personal information on a need to know basis only.
The Client's consent will not be required in the event where disclosure of confidential
information is required by any governmental authority or by any law or regulation(s) requesting
such disclosure. Furthermore, the Client's personal information may be submitted to cooperate
with regulatory authorities and entities to comply with any legal official request, and as
necessary to protect any of the Company’s legal obligations and/or rights. The Company will
protect the Client's rights regarding the privacy, confidentiality and anonymity of any
information furnished to the Company and all data so furnished will be processed fairly and
legally and will be collected for specified and legitimate purposes. Additionally the Client
consents that personal information may be given by the Company to relevant institutions should
such be required in order to perform the activities during the business relationship.
The Client understands and agrees that the Competent Authorities are empowered to exercise their
functions and powers either, a) directly, b) in collaboration with other authorities or with market
undertakings, c) under the competent authority’s own responsibility by delegation to such authorities or
to market undertakings or by d) the application to the competent judicial authorities, and that the
Competent Authority is empowered with supervisory and investigatory powers in order to fulfill their
duties.

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

38. ELECTRONIC SIGNATURE


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

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39. JOINT ACCOUNTS
In cases of Joint Accounts, the Client(s) will have equal power and authority, and be able to singly
and/or jointly including but not limited to: a) request information about account(s) so held, b)
request and execute transactions for account(s) so held, c) receive correspondence and
documents in respect to account(s) so held, d) transfer, receive or withdraw funds from
account(s) so held, e) request the change of information related to account(s) so held.
Notwithstanding the foregoing, the Company reserves the right to require joint action related
to account(s). Joint Account holders (the Clients) will be jointly and severally liable for all
account(s) so held. The Company may, in its sole and absolute discretion, require that, prior to
execution of an or an instruction/order(s) for transaction or any other activity related to account(s) held
jointly between two or more persons, request or demand that that such an instruction/order(s) is
requested or demanded by all account(s) holders.

40. TRADING TERMS & CONDITIONS


The Company anticipates offering price(s) to its clients that are reasonably related to price(s) offered by
other counterparties, such prices may, however, vary. The price(s) offered by the Company to the Client
may differ from those offered to the Company by other counterparties. However, the Company is under
no obligation to disclose price(s) obtained from the counterparty(s), to the Client. In the event that
counterpary(s), such as service provider(s), liquidity provider(s) etc, do not provide price(s), or provide
erroneous price(s), during a specific period, on a specific Financial Instrument, the Client understands and
accepts that the Company may not be in a position to provide price(s) and may therefore be obliged to
reject the Client’s request/order(s) and/or may delay the time of confirmation. The Client furthermore
acknowledges and confirms that spreads on Financial Instruments, offered during normal market
conditions, may differ in the events of volatile markets. During the volatile markets, it may happen that
the spreads offered are wider than the spreads otherwise offered. The Client understands and accepts
that the stop order(s), on all types of accounts, are considered the market orders, once alerted, and
therefore, the market level of the specific Financial Instrument, at the time of activation of the order, is
taken into consideration and not the level requested by the Client. It is further acknowledged and
confirmed by the Client that the levels requested by the Client, when placing stop orders, are not
guaranteed to be completed at the requested levels. The Company shall have no liability for failure to
execute order/request(s) and makes no representations, warranties or guarantees to the Client’s
order/request(s) priority, over the order/request(s) of other clients. The Client shall be directly and
personally responsible for performing obligations under every transaction entered into, whether the
Client is dealing as principal directly or through a designated agent, or representative or as an agent for
another person, or intermediary, and the Client indemnifies the Company in respect of all liabilities, losses,
expenses and/or costs of any kind or nature whatsoever which may be incurred as a direct or indirect
result of any failure by the Client to perform any obligation(s).

The Client should request/obtain a clear explanation of all trading terms & conditions, including any
applicable charges/costs, prior to trading. The Client acknowledges and consents that the Client has no
right to cancel this Agreement on the basis that it is a distance contract.
Existing trading conditions may be modified, altered, suspended or terminated or new conditions may be
imposed, which will become new applicable trading terms & conditions. Furthermore, the Company, as
principal, may at any time reject, cancel, or make any adjustment which it deems necessary, to any request
made by the Client when, the Company considers, at its sole discretion, that such request may breach or
may have breached the provision of the trading terms & conditions.

21
Liability of the Client under this Agreement shall not, in any circumstance, be limited or mitigated by any
failure of the Company to provide training, training material or updates, or notice of change to the
trading terms & conditions.

41. ABOUT US
Windsor Brokers (BZ) Ltd. is regulated by International Services Commission (“IFSC”) with the license
numbers IFSC/60/285/APM, IFSC/60/285/TS and IFSC/60/285/BCA.

Registered Office: 35 Barrack Road, third floor, Belize City, Belize, C.A

22
CLIENT ORDER AUTHORIZATION AND LIMITED POWER OF ATTORNEY

Client Name(s): ............................................................................................................ (the “Client”)


Account(s) Number: .....................................................................................................................
I/We the undersigned being the above Client of Windsor Brokers (BZ) Ltd. ("Company") hereby
authorise and appoint:
............................................................................................................................. ("Representative")
Situated in ...................................................... (City) .................................................. (Country),
as my/our representative and attorney in fact to give the Company Order/request(s) for
Transactions for my/our account(s) held with the Company in my/our name, on my/our behalf
and at my/our cost and risk.
1.I/We hereby authorise the Company to accept Order/request(s) from the Representative for
and in every aspect concerning Transactions for my/our Account(s) (without limiting the
Company's right to decline to accept particular Order/request(s) ) and my/our Representative is
authorised to act for me/us in giving Order/request(s) for Transactions for my/our Account(s) in
the same manner and with the same force and effect as I/we might or could do with respect to
such Order/request(s) for Transactions for such Account(s) in accordance with my/our Client
Account Agreement.

2. I/We hereby authorise the Company to communicate with the Representative for and in every
aspect concerning my/our Account(s) (without limiting the Company’s right to decline to accept
particular requests), including but not limiting to providing Client Account Agreement, account(s)
statements and/or any other required documentations requested by my/our Representative.
My/our Representative is authorized to act on my behalf in requesting such documentation for
my/our account(s) in the same manner and with the same force and effect as I/we might or could
request in respect of such documentation for such account(s).

3. My/our Representative shall have no authority to withdraw or give instructions for payment
of any sums payable or delivery of any property deliverable under or in respect of Transactions
on my/our account(s) to any person other than me/us or to vary the terms of my/our Client
Account Agreement or terminate my/our Client Account Agreement.

4. In the event that my/our Representative is a corporate entity, the Company may (acting
reasonably and in good faith) accept Order/request(s) for Transactions for my/our account(s)
given by any person who represents the corporate entity as being an officer, employee or sub-
representative of my/our Representative and whose name has been previously advised to the
Company by my/our Representative. Reference herein to my/our Representative shall include
any such person.

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5. I/We undertake with my/our Representative to ratify and confirm that any and all
Order/request(s) for Transactions given to and confirmed by the Company, through my/our
Representative, on my/our behalf, is in accordance herewith and indemnify the Company from
any loss or liability arising from my/our failing or refusing to do so.

6. I/We hereby accept that the Company may provide “View Only” access, to my/our
Representative to one or more terminals, including terminal access through internet browser
and to electronically monitor my/our account(s) activities.

7. The authorisation granted hereby are in addition to and do not limit or restrict any other
authorisation under my/our Client Account Agreement or any other agreement that may exist
between the Company and me/us. The authorisation granted hereby shall inure to the benefit of
the Company and any successors or assigns of the Company.

8. The authorisation granted hereby is of continuing effect and shall remain in full force and
effect unless and until revoked by me/us, by written notice to the Company. Such notice of
revocation shall not have effect until actual receipt and acknowledgement by the Company, at
its offices, at the above address or such other address, if any, as the Company may advise. Such
notice of revocation shall not affect any activity performed by my/our Representative (including
initiating any Order/request(s) for Transactions) prior to the Company's actual acknowledgment
of my/our notice of revocation, as aforesaid, and shall not relieve me/us from any obligation or
liabilities arising from or in respect thereof or in relation to Transactions or my/our account(s)
generally.
9. I/We represent and warrant to the Company that I/We have full legal capacity and (if a
corporation) corporate power and authority to enter into, grant and execute this Client Order
Authorisation and Limited Power of Attorney and that the same has been (if a corporation) duly
authorised and duly executed by me/us.
10. Order Authorisation and Limited Power of Attorney shall be governed by and construed in
accordance with Belize law and in the event of any dispute I/we shall submit to the non-exclusive
jurisdiction of the Belize Courts.
11. As used herein:
"Account(s)" means my/our account (or if more than one, all accounts) held with the Company,
particulars of which are set out above;
"Client Account Agreement" means the Client Account Agreement signed, between the
Company and me/us (including all documents forming part of the same) comprising or including
the terms and conditions on which the Company will open and/or maintain my/our Account(s)
and enter into Transactions with me/us for my/our Account(s) and risk and any amendment
addition or variation thereto applying from time to time;
"Order/request(s)" includes any order/request instruction agreement or other commitment to
the Company;

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"Order/request(s) for Transaction" means any Order/request or Orders/requests for any
Transactions (including without limitation for the close out, liquidation and settlement of open
position/transaction(s) and exercise or abandoning of any options), any instruction for the
payment of any sums or delivery of any property by the Company to me/us pursuant to any
Transactions and my/our Account(s) and my/our Client Account Agreement generally and
(subject as provided In Clause 3 hereof) any other directions, instructions, notices or agreements
I/we could give or make to or with the Company pursuant to my/our Client Account Agreement.
"Transaction" means any acquiring (including a short sale) of any Financial Instruments such as
commodities, financial or currency futures options or contracts for differences, bullion, precious
metals or foreign exchange or any options thereof or any securities and/or index, futures and
options contracts and whether traded on or off-exchange being of a kind or kinds from time to
time contemplated (whether generally or in particular) by my/our Client Account Agreement and
expressions importing the singular shall include the plural and vice versa.
Duly executed by the Client (and if a corporation in accordance with its constitutional documents)
on the date set out below.

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

1. LICENSE GRANT AND RIGHT OF USE


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

2. ACCESSES AND SECURITY


The Online Service may be used to transmit, order/request, receive and confirm execution of
order/request(s), subject to prevailing market conditions and applicable rules and regulations.
The Company consent to the Client’s access, in reliance with the safeguarding procedures,
adopted by the Client for preventing unauthorized access to and use of the Online Service, and
in any event, the Client agrees to any financial liability for transactions executed through the
Online Service. The Client acknowledges, represents and warrants that:
a- The Client has received a number, code or other sequence which provides access to the Online
Service (the "Password");
b- The Client is the sole and exclusive owner of the Password;
c- The Client is the sole and exclusive owner of any identification number or Account number or
Login number (the "Login"); and
d- The Client accepts full responsibility for use and protection of the Password and the Login as
well as for any transaction occurring in account(s) opened, held or accessed through the Login
and Password.
e- The Client agrees that the Company has the right to “reset” the Password, for security
purposes, if the account(s) has been inactive for a certain period of time.

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The Client accepts full responsibility for monitoring account(s) activities. The Client agrees to
immediately notify the Company in writing, should the Client become aware of any of the
following:
1- any loss, theft or unauthorized use of the Client’s Password and/or Login number; or
2- any failure by the Client to receive a message indicating that an order/request(s) was received
and/or executed; or
3- any failure by the Client to receive an accurate confirmation of an execution; or
4- any receipt of confirmation of an order/request and/or execution of an order/request which
the Client did not order/request; or
5- any failure to receive accurate information for the Client’s account(s) balances,
position/transaction(s), or transaction history
6- any other reason whatsoever.

3. MULTI-TERMINAL FUNCTION OF THE ONLINE SERVICE


Multi-Terminal shall mean one of the functions provided by one or more Online Trading
Platforms offered by the Company, through Online Service, which can be used by the Client for
simultaneous management of multiple accounts. The Multi-Terminal function of the Online
Trading Platform, offered through Online Service, is granted to clients in the Company’s sole
discretion.
In cases where the Company permits the Client to have access to the Multi-Terminal, the Client
agrees and acknowledges the following:
a) The Company reserves the right, if it is deemed necessary, to delay confirmation of
order/request(s) and/or transactions for the Client’s account(s);

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

c) The Company reserves the right, if it is deemed necessary, not to execute all
order/request(s) and/or transactions for the Clients’ account(s) in the same manner;

d) The Company reserves the right, if it is deemed necessary, to reverse any order/request(s)
and/or transactions for the Client’s account(s).

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

4. RISKS OF ONLINE TRADING


Access to the Online Service or any portion thereof, may be restricted or unavailable during
periods of peak demands, extreme market volatility, systems upgrades or any other reasons. The
Company or its Service Provider(s) makes no express or implied representations or warranties

27
to the Client regarding the usability, condition or operation thereof. The Company or its Service
Provider(s) does not warrant that access to or use of the Online Service will be uninterrupted or
error free or that the Online Service will meet any particular criteria of performance or quality.
The Company or anyone else involved in creating, producing, delivering or managing the Online
Service shall, under no circumstances including negligence, be liable for any direct, indirect,
incidental, special or consequential damages that result from the use of or inability to use the
Online Service, or out of any breach of any warranty, including, without limitation, those for
business interruption or loss of profits.
The Client expressly agrees that the use of the Online Service is at Client’s sole risk. The Client
acknowledges full responsibility and risk of loss that may result from use of, or materials
obtained through, the Online Service. Neither the Company nor any of the Company’s directors,
officers, employees, agents, contractors, affiliates, third party vendors, facilities, information
providers, licensors, exchanges, clearing organizations or other suppliers providing data,
information, or services, warrant that the Online Service will be uninterrupted or error free; nor
does the Company make any warranty as to the results that may be obtained from the use of the
Online Service or as to the timeliness, sequence, accuracy, completeness, reliability or content
of any information, service, or transaction provided through the Online Service.
In the events where the Client’s access to the Online Service, or any portion thereof, is restricted,
unavailable or delayed, the Client agrees to use other available means (if any), provided by the
Company, to place the Client’s order/request(s) for transaction(s) or to access information. The
Company is not liable for any losses, lost opportunities or increased costs, increased
commissions etc that may result from the Client’s inability to use the Online Service to place
order/request(s) for transactions, receive confirmation for transactions or access information.
By placing order/request(s) through the Online Service, the Client acknowledges that the Client
order/request(s) may not be reviewed by the Company prior to execution. The Client agrees that
the Company is not liable for any losses, lost opportunities or increased costs, increased
commissions/charges/costs etc that may result from the execution of order/request(s) made by
the Client.

5. MARKET DATA AND INFORMATION


Neither the Company nor any Service Provider shall be liable in any way to the Client or to any
other person for:
a- Any inaccuracy, error or delay in, or omission, non-performance, interruption of any such data,
information or message(s) or the transmission or delivery of any such data, information or
message(s); or
b- Any loss or damage arising from or occasioned by any such inaccuracy, error, delay, omission,
non-performance, interruption in any such data, information or message, due to either to any
negligent act or omission or to any condition of force majeure or any other cause, whether or
not within the Company or any Service Providers’ control.

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The Company shall not be deemed to have received any order/request(s) or communication
transmitted electronically by the Client, through Online Service, until the Company has actually
acknowledged such order/request(s) or communication.

6. ADDITIONAL IMPORTANT INFORMATION AND DISCLAIMERS REGARDING EXPERT


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

7. REPRESENTATIONS
The Client acknowledges that from time to time, and for any reason, the Online Service may not
be operational or may be otherwise unavailable for the Client’s use due to servicing, hardware
malfunction, software defect, service or transmission interruption or any other cause, and the
Client agrees to hold the Company and any Service Provider harmless from liability of any
damage(s) which may result from the unavailability of the Online Service. The Client
acknowledges that the Client has alternative arrangements which will remain in place for the
transmission and execution of the Client’s order/request(s), in the event that for any reason,
circumstances prevent the transmission and execution of all, or any portion of, the Client’s
order/request(s) through the Online Service.
The Client represents and warrants that the Client is fully authorized to enter into this Online
Agreement and is under no legal impediment which prevents the Client from trading, and that
the Client is and shall remain in compliance with all laws, rules and regulations applicable to the
Client’s business. The Client agrees that the Client is familiar with and will abide by any rules or
procedures adopted by the Company and any Service Provider in connection with use of the
Online Service. The Client further acknowledges to have obtained necessary training in its use.
The Client shall not (and shall not permit any third party) to copy, use analyze, modify, decompile,
disassemble, reverse engineer, translate or convert any software provided to the Client in
connection with use of the Online Service or distribute the software or the Online Service to any
other third party.

8. BINDING EFFECT OF ONLINE AGREEMENT; MODIFICATIONS


The Client acknowledges and accepts to be bound by the provisions of this Online Agreement
and any amendment or variation thereof duly effected in accordance with the provisions of this
clause 8. Unless otherwise provided for in this Online Agreement, the Company may change the

29
general terms and conditions of this Online Agreement at any time by updating the Online
Agreement on the Company’s website and the Client is required to inquire for any updates that
may be made to the Online Agreement during the business relationship with the Company.
Seven working days after publication of the update on the Company’s website, it will be deemed
that the Client has read and accepted the general terms and conditions included within the
Online Agreement, and that the same will applicable to the Client. The Client acknowledges and
agrees that the first transaction in any of the Client’s account(s), initiated by the Client, following
notification of a change to the terms and conditions of this Online Agreement, as
abovementioned, shall constitute the Client’s acceptance of the change as of that date, and such
initiation and the subsequent execution of such transaction by the Company shall constitute
reciprocal good consideration for the variance or amendment abovementioned, the sufficiency
of which is hereby acknowledged and agreed by the Client and the Company respectively. Unless
the context clearly indicates otherwise, a reference to this Online Agreement will include a
reference to this Online Agreement as varied or amended form time to time in accordance with
this clause 8. The Company may terminate this Online Agreement at any time by means of
written notice to that effect. The Client may terminate this Online Agreement at any time by a
written notice confirmed by the Company provided however that no termination will affect any
existing liabilities or indebtedness to the Company or any liabilities or indebtedness that may
arise subsequent to such termination in respect of any act or omission that took place prior to
such termination. Upon termination, any software license granted to the Client herein shall
automatically be terminated.

9. INDEMNITY
The Client agrees to indemnify and hold the Company harmless and each Service Provider and
their respective principles, affiliates and agents from and against all claims, demands,
proceedings, suits and actions and all losses (direct, indirect or otherwise), liabilities, costs and
expenses (including attorney fees and disbursements), paid in settlement, incurred or suffered
by the Company and/or Service Providers and/or the Company’s or their respective principals,
affiliates and agents arising from or relating to the Client’s use of the Online Service or the
transactions contemplated hereunder. This indemnity provision shall survive termination of this
Online Agreement.

10. MISCELLANEOUS
The Client shall not be permitted to amend the terms of this Online Agreement. The Company
may amend the general terms and conditions of this Online Agreement. By continued access to
and use of the Online Service, the Client agrees to any such amendments to this Online
Agreement.
This Online Agreement is the entire Agreement between the parties relating to the subject
hereof, and, except with respect to the Client Account Agreement between the parties, all prior
negotiations and understandings between the parties, whether written or oral, are hereby
merged into this Online Agreement. Nothing in this Online Agreement shall be deemed to
supersede or modify any party's rights and obligations under the Client Account Agreement.

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11. GOVERNING LAW
This Online Agreement shall be governed by the laws of Belize.

12. ACCEPTANCE OF ONLINE AGREEMENT


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

13. RECIPIENT ACKNOWLEDGMENTS AND SIGNATURE


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

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

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

1. GENERAL
By entering into and signing this MT Agreement, the Client agrees to use the Mobile Trading
Service solely for the purpose of accessing account(s) via the mobile devise. The Mobile Trading
Service is provided for specific mobile devises that can be viewed on the Company’s website.
The Client agrees to use the Mobile Trading Service strictly in accordance with the terms and
conditions set by The Company's Client Account Agreement and all other documents that
collectively form the agreement between the Company and the Client (“AOD”), as amended
from time to time. Client also agrees to be bound by any rules, procedures and conditions
established by the Company concerning the use of the Mobile Trading Service.
This MT Agreement shall be exclusively applied to the Client’s use of the Mobile Trading Services, in
addition to the terms set by the Company within Online Access Agreement. Unless separately
defined in the MT Agreement, expressions capitalized in the MT Agreement shall have the
meanings given to them in the AOD. In cases of any inconsistency between the provisions of the
MT Agreement and the provisions of AOD, insofar as it relates exclusively to the Client’s use of
Mobile Trading Service, the MT Agreement shall prevail.
The Client acknowledges that accessing account(s) using a mobile devise is at his/her own risk
and that such access will not be error free or always operate as expected.

2. ACCESS AND SECURITY


For using Mobile Trading Service, the Client should hold account(s) and have available access to
the Username/Login and Password. Mobile Trading Service may offer limited functionality and
information compared to the functionality and information available by accessing account(s),
using Online Service.
The functionality and information provided when accessing account(s) through Mobile Trading
Service are subject to change without prior notice.
The Client understands and accepts that the Mobile Trading Service may be provided through
Service Provider(s). All information shall be treated with confidentiality at all times, and
furthermore the Client undertakes to indemnify the Service Provider(s) and the Company against
any and/or all losses, expenses, damages, any inaccuracy, error or delay in, or omission, non-
performance, interruption of any such data, information or message(s) or the transmission or
32
delivery of any such data, information or message(s); and/or any loss(s) and/or damage(s) arising
from and/or occasioned by any such inaccuracy, error, delay, omission, non-performance,
interruption in any such data, information or message, due to either to any negligent act or
omission or to any condition of force majeure or any other cause, whether or not within the
Company or any Service Provider(s)’ control.
The Client acknowledges and agrees that the Mobile Trading Service is provided without any
representations or warranties, to the extent permitted by law, as to the compatibility, security
and accuracy of the Mobile Trading Service. Any material downloaded or otherwise obtained
through the use of the Mobile Trading Service is carried out at the Client’s own discretion and
risk.

3. RESPONSIBILITIES AND LIABILITIES


Mobile Trading Service is not directed at or intended to be used by any person in any jurisdiction
or country where such use and/or distribution would be contrary to local law and/or regulation.
It is the Client’s responsibility to ensure that using Mobile Trading Service would not be in a
breach with any local law or regulation to which the Client is a subject to.
The Client agree that the use of Mobile Trading Service shall not lead, in any way, to the
encouragement, procurement or carrying out of any criminal or unlawful activities. Furthermore,
the Client agree that the use of Mobile Trading Service will not cause damage to Mobile Trading
Service or our servers, systems or equipment or those of third parties, nor access or attempt to
access any users' data or to penetrate or attempt to penetrate Mobile Trading Service’s security
measures.
The Client is responsible for keeping the Username and Password of account(s) confidential at
all times ensuring that all reasonable steps are taken in order to prevent fraudulent use of this
information. Any access to account(s), using the Client’s Username and Password, will be
deemed to have been done by the Client. In cases where the Client suspects that the information
has been obtained by any other person without the Client’s consent, it is the Client’s
responsibility to notify the Company immediately. In failing to do so, the Client will be liable for
any such “unauthorized” access to account(s).
The Client hereby accepts any and all risks, including but not limited to, failure or damage to
hardware, software, and communication lines of systems while using Mobile Trading Service.
The Client further acknowledges full liability for any losses, costs, or expenses which may arise
directly or indirectly from the Client’s use of, or reliance on, the Information provided by the
Mobile Trading Service.
The Client is responsible to notify the Company in the event of a delay or defect in or failure of
the whole or any part of the Mobile Trading Service.

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

5. INDEMNITY
The indemnity provision in this clause applies exclusively to this MT Agreement and is separate
from and in addition to the indemnity provision set out within the AOD. In case of any conflict
between the indemnity provision of the MT Agreement and AOD to the extent where the
provisions relate to the subject matter of the MT Agreement, the provisions in the MT
Agreement will prevail.
The Company does not warrant that any software downloaded onto the Client’s mobile devise
will operate without interruption or be error free nor implicitly guarantee any level of service.
Additionally the Company does not guarantee as to the accuracy, suitability, reliability,
completeness, or performance of the Mobile Trading Service. The Mobile Trading Service may
be adversely affected by factors such as the limitations of the Client’s mobile device, network
performance and other factors which are beyond the Company’s control and may fail to operate
satisfactorily or at all. The Company will not be liable to any planned or unplanned downtime or
any outages on any mobile device network or in cases where the Client is not in an area of mobile
coverage, at any given time or place.
The Company will have no liability in relation to any loss or damage that may result due to any
delay or defect in or failure of the whole or any part of Mobile Trading Service, provided that the
occurrence of the delay, defect or failure was beyond the Company’s reasonable control.
However, in cases where any defect of failure of the Mobile Trading Service, which is beyond the
Company’s reasonable control, results in disagreement between records kept by the Company
and those of the Client, the version of events supported by the Company’s records will prevail.

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

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

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

9. TERMINATION
The Company reserves the right to suspend or terminate the Client’s access to or use of Mobile
Trading Service, in addition to the Client’s access to Online Trading Platform, if the Company
determines, in its sole discretion, that the Client has in any way breached the agreement
between the parties based on any of the terms and conditions so accepted by the Client.
The Company may terminate all or part of Mobile Trading Services at any time. The Company
shall not be liable to the Client or any other person if any or all Mobile Trading Service is modified
or terminated.

10. GOVERNING LAW


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

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Risk Disclosure Statement
This brief statement does not disclose all risks and other significant aspects related to trading
with Financial Instruments such as futures, options, commodities, contracts for differences,
foreign exchange and other instruments ("Financial Instruments"). In light of the risks, the Client
should undertake such transactions only if the Client understands the nature of the Financial
Instruments (and contractual relationships) into which the Client is entering and the extent of
the Client’s exposure to risk.
Trading with Financial Instruments is not suitable for many members of the public. The Client
should carefully consider whether trading is appropriate for the Client in the light of the Client’s
experience, objectives, financial resources and other relevant circumstances.

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

2. Risk-reducing order/request(s) or strategies


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

OPTIONS
Transactions in options carry a high degree of risk. Purchasers and sellers of options should
familiarize themselves with the type of option (i.e. “put” or “call”) which they contemplate
trading and the associated risks. The Client should calculate the extent to which the value of the
options must increase for the Client’s open position to become profitable, taking into account
the premium and all transaction costs. The purchaser of options may offset or exercise the
options or allow the options to expire. The exercise of an option results either in a cash
settlement or in the purchaser acquiring or delivering the underlying interest. If the option is on
a future contract, the purchaser will acquire a futures open position with associated liabilities for
margin (see the section on Futures above). If the purchased options expire worthless, the Client

36
will suffer a total loss of the Client’s investment which will consist of the option premium plus
transaction costs. If the Client is contemplating purchasing deep-out- of-the-money options, the
Client should be aware that the chance of such options becoming profitable ordinarily is remote.
Selling ("writing" or "granting") an option generally entails considerably greater risk than
purchasing options. Although the premium received by the seller is fixed, the seller may sustain
a loss well in excess of that amount. The seller will be liable for additional margin to maintain the
position if the market moves unfavorably. The seller will also be exposed to the risk of the
purchaser exercising the option and the seller will be obligated to either settle the option in cash
or to acquire or deliver the underlying interest. If the option is on a future, the seller will acquire
a position in a future with associated liabilities for margin (see the section on Futures above). If
the option is "covered" by the seller holding a corresponding position in the underlying interest
or a future contract or another option, the risk may be reduced. If the option is not covered, the
risk of loss can be unlimited. Certain exchanges in some jurisdictions permit deferred payment
of the option premium, exposing the purchaser to liability for margin payments not exceeding
the amount of the premium. The purchaser is still subject to the risk of losing the premium and
transaction costs. When the option is exercised or expires, the purchaser is responsible for any
unpaid premium outstanding at that time.

OFF EXCHANGE TRANSACTIONS / OTC


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

FOREIGN EXCHANGE
Foreign Exchange can be highly volatile and transactions therein carry a substantial risk of loss.
The high degree of “gearing” or “leverage” which is often obtainable in trading stems from the
payment of what is comparatively modest deposit or margin when compared with the overall
contact value. As a result, a relatively small market movement can, in addition to achieving
substantial gains, where the market is in the Client’s favor, result in substantial loss which may
exceed the Client’s original investment where there is an equally small market movement against
the Client .
The Client’s risk exposure increases if the Client’s transactions are denominated in a foreign
currency or in a basic currency.
The Client should get familiar with the execution venues related to specific types of
order/request(s) and Financial Instruments.

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

ADDITIONAL RISKS
I Terms and conditions of contracts
The Client should request from the Company to be provided with the terms and conditions for
trading with the specific Financial Instrument and type of account as well as associated
obligations (e.g. the circumstances under which the Client may become obligated to make or
take delivery of the underlying interest of a future contract and, in respect of options, expiration
dates and restrictions on the time for exercise). Under certain circumstances, the specifications
of outstanding contracts (including the exercise price of an option) may be modified by the
exchange or clearing house to reflect changes in the underlying interest.
II Suspension or restriction of trading and pricing relationships
Market conditions (e.g. liquidity) and/or the operation of the rules of certain markets (e.g. the
suspension of trading for any Financial Instrument, trading hours, dealing hours etc. may
increase the risk of loss by making it difficult or impossible to effect transactions or
liquidate/offset open position/transaction(s). If the Client has sold options, this may increase the
risk of loss. Further, normal pricing relationships between the underlying interest and the future,
and the underlying interest and the option may not exist. This can occur when, for example, the
futures contract underlying the option is subject to price limits while the option is not. The
absence of an underlying reference price may make it difficult to judge "fair" value to the
transaction. It may be difficult or impossible to liquidate an existing open position/transaction,
to assess the value, to determine a fair price or to assess the exposure to risk. For these reasons,
these transactions may involve increased risks. Market conditions are related to all types of
Financial Instruments.
III Deposited cash and property
The Client should get familiarized with the protections of the Client’s money or other property
deposited by the Client for trading with Financial Instruments, particularly in the event of a firm
insolvency or bankruptcy. The extent to which the Client may recover the Client’s money or other
property may be governed by specific legislation or local rules. In some jurisdictions property
which had been specifically identifiable as the Client’s own property will be appropriated in the
same manner as cash for purposes of distribution in the event of a shortfall.

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IV Commission and other charges/costs
Before the Client begins to trade, the Client should obtain a clear explanation of all commission,
fees and other charge/cost(s) for which the Client will be liable. These charge/cost(s) will affect
the Client’s net profit (if any) or increase the Client’s loss.
V Limiting losses
Where permitted, placing a stop-loss order/request(s) will not necessarily limit the Client’s losses
to the intended amounts, for market conditions may make it impossible to execute such
order/request(s) at the stipulated price. A spread; straddle or hedge position/transaction may be
risky as a simple long or short position/transaction and can be more complex.
VI Transactions
Transactions with Financial Instruments on specific markets may expose the Client to additional
risk. Such markets may be subject to regulation which may offer different or diminished investor
protection.
Before the Client begins to trade, the Client should enquire about any rules relevant to the
particular transaction(s) related to specific Financial Instruments. The Client’s local regulatory
authority will be unable to compel the enforcement of the rules of regulatory authorities or
markets in other jurisdictions where Client’s transactions have been effected.
VII Currency risks
The profit or loss for transactions in foreign currency-denominated contracts will be affected by
fluctuations in currency rates when there is a need to convert from the currency denomination
of the contract into another currency.
VIII Trading facilities
Most open-outcry and electronic trading facilities are supported by computer-based component
systems for the order/request(s) -routing, execution, matching, registration or clearing of
transactions. As with all facilities and systems, they are vulnerable to temporary disruption or
failure. The Client may ascertain losses and the ability to recover certain losses may be subject to
limits on liability imposed by the system provider, the market, the clearing house and/or member
firms.
IX Electronic trading
Trading on an electronic trading system may differ not only from trading in an open-outcry
market but also from trading on other electronic trading systems. If the Client undertakes
transactions on an electronic trading system, the Client will be exposed to risks associated with
the specific electronic trading system including the failure of hardware and software. The result
of any system failure may be that the Client’s order/request(s) are either not executed according
to the Client’s instructions or are not executed at all.

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

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