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Client Account Agreement: Windsor Brokers (SC) Limited

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CLIENT ACCOUNT AGREEMENT

Windsor Brokers (SC) Limited


FSA Seychelles

0821
DISCLAIMER
This is a live document and should be read by the intended recipients,
that being the current and/or prospective clients of Windsor Brokers
and/or those individuals, natural and/or legal persons, which are
authorised by Windsor Brokers. The material and information provided
within are protected by copyright owned by Windsor Brokers. Any
reproduction, retransmission, republication, or other use of all or part
of any procedure including but not limited to posting, linking, or
otherwise modifying its contents is expressly prohibited, unless prior
written permission has been granted by Windsor Brokers. Windsor
Brokers, retains the right to alter and/or amend any of its terms at its
absolute discretion without first obtaining the consent of the client.
Except as required by law, Windsor Brokers shall not accept any
responsibility and/or be held liable for any damages (direct, indirect,
incidental, special, consequential, or exemplary), resulting from
unlawful and/or inappropriate use of information provided.
Windsor Brokers (SC) Limited (the “Company” or “Windsor” or “us”) is a Seychelles Investment Firm
regulated by the Seychelles Financial Services Authority (“FSA”) with license number SD072. The
Company is incorporated and registered under the laws of Seychelles with registration number
8425783-1 and has its registered office at Suite 3, Global village, Jivan’s Complex, Mont Fleuri, Mahe,
Seychelles.

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

By accepting this Agreement, the Client hereby agrees that he/she has read, understood and
accepted the provisions included in this Agreement, including its Appendixes, and the various
documents included in the Company’s website.

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 accounts 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 and the Company as principal or agent as applicable in accordance
with the Company’s license. 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 prices 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 and makes no representations, warranties or guarantees of the Client’s
order/request’s priority over the order/request of other clients. The Client shall be directly and
personally responsible for performing obligations under every transaction entered into, with the
Company, and the Client indemnifies the Company in respect of all liabilities, losses, expenses

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and/or costs of any kind or nature whatsoever which may be incurred as a direct or indirect result
of any failure by the Client to perform any obligations.

3. APPLICABLE RULES AND REGULATIONS


All order/requests entered into for the purpose of purchase/sale of Financial Instruments and all
transactions executed for the Client's accounts shall be subject to the constitution, by-laws, rules,
regulations, customs and usages (collectively “rules”) where such transactions are executed and to
the rules and regulations promulgated there under (collectively “laws”). The Company shall not be
liable to the Client as a result of any action taken by the Company or its agents in compliance with
any 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 banks or entities from the
one used by the Client for transferring funds to the Company. In such cases, the legal and regulatory
regime applying to any such bank or entity will be applicable in the event of the insolvency or any
other analogous proceedings in relation to that bank or entity.
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 Instrumentss and accounts
held by the Client, related to execution of trades;
b. such charge/costs related to carrying open trades on specific Financial Instruments;

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c. such charge/costs related to rolling over of Financial Instruments;
d. such charge/costs related to inactive accounts;
e. such transfer-related fees, including but not limited to charge/costs applied on
deposits/withdrawals, returned withdrawals, issuing and returns of issued cheques;
The Company, may at its own discretion, apply the full transactional (deposit/withdrawal)
fee otherwise given to client should it think that the purpose of the deposit does not fulfill
or correspond to the purpose of the trading account.

f. Spread, mark-up or mark-down when compared to prices that the Company receives or
expects to receive, when covering its trades with another counterparty;
g. Currency conversion related to trading costs and profits/losses occurred from trading
activities;
h. Currency conversion related to amounts received in currencies different from the basic
currency used by the accounts;
i. Such charge/costs required by regulatory body and/or legal requirement;
j. Such other taxes or costs that may exist that are not applied by the Company;
k. the amount of any loss that may result from transactions made by the Company, on the
Client's behalf, including any deficit balance;
l. Such relevant amounts related to subscriptions of the Client to an exchange.

The Client further acknowledges:


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

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

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

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

6. RISK OF LOSS
All transactions effected for the Client's accounts and all fluctuations in the market prices of the
Financial Instruments carried in the Client's accounts are at the Client's sole risk and the Client shall
be solely liable under all circumstances at any given time. By execution of this Agreement, the Client
warrants that the Client is willing and financially able to sustain any such losses. The Company is not
responsible for the obligations of the persons with whom the Client's transactions are affected, nor
is the Company responsible for delays in transmission, delivery or execution of the Client's
order/request 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.
Such markets may be subject to regulation which may offer different or diminished investor
protection. The Client understands, before trading, that the Client should enquire as to any rules
relevant to the particular transactions.
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 movements of a currency and/or a pair of currencies. The Company warns the
Client of the high risks involved in trading whereby the Client can sustain losses and/or damages to
some or all of the capital/monies invested. All transactions effected are at the Client’s sole risk and
the Client is liable under any given circumstances. Additionally, the Client understands and confirms
that the Company will not be held responsible for any delays in transmissions, delivery or execution
of requests, due to force majeure, malfunctions of communications facilities or other causes.
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.

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7. SAFEGUARDING OF CLIENT FINANCIAL INSTRUMENTS, ASSETS AND FUNDS
The Company may hold, on behalf of the Client, such client’s assets/property and/or funds with
custodians whereby the domestic legal and regulatory regime, may be applicable to any such entity.
Therefore, in the event of the insolvency or any other analogous proceedings, in relation to such
entity, the Client’s assets/property and/or funds may be treated differently from the treatment
which would apply if the assets/property and/or funds were held in other jurisdiction. 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 expenses (including attorneys' fees and expenses and any fines and/or
penalties imposed by any governmental agency, contract market, exchange, clearing organization
or other regulatory or self-regulatory body or institution) which the Company may incur or be
subjected to, with respect to the Client's accounts or any transaction or position therein. Without
limiting the generality of the foregoing, the Client agrees to reimburse the Company on demand for
any cost of collection incurred by the Company in collecting any sums owing by the Client under this
Agreement and any cost incurred by the Company, including legal action/proceedings, in defending
against any claims asserted by the Client, including all attorneys' fees, interest and expenses. The
Client hereby agrees and acknowledges being liable for the Client’s own costs and/or expenses,
unless directed otherwise by any court of law and/or regulatory body. The Client furthermore
confirms and agrees that all information provided to the Company for purposes of account opening
is true and correct, the Client will provide all the relevant information regarding Client’s knowledge
and experience in the investment field relevant to product and/or service as the case may be, and
as requested by the Company. In the event that the Client provides insufficient/false information
regarding knowledge and experience as to any product and/or service, the Client understands and
agrees that such information will not allow the Company to determine whether the investment
services and/or Financial Instruments envisages is appropriate for the Client.
The Client understands and accepts that the Company does not provide financial, legal, tax or other
advice, nor should any investment or any other decisions be made solely based on the information
obtained from the Company, the Company recommends the Client to obtain advice on such matters
from specialists.

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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 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 accounts, order/request 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.

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

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

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

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 accounts. The Client agrees to maintain at all times,
without demand from the Company, margin requirements for the open positions/transactions held
in the Client's accounts. The Client will, at all times, maintain such margin or collateral for the Client's
accounts, as requested 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 accounts becomes subject to stop out activity and consequently
open positions/transactions may be partially or fully hedged and/or closed/liquidated by the
Company. The levels whereby the Company may hedge and/or liquidate open

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positions/transactions are based on prevailing market prices and/or last available prices on the
specific Financial Instruments.

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 accounts. 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 accounts by notifying clients about such changes.

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 accounts; (e) the property
deposited as collateral is determined by the Company in its sole discretion, regardless of current
market quotations, to be inadequate to properly secure the accounts; or (f) at any time the
Company deems it necessary for its protection for any reason whatsoever, the Company may, in the
manner it deems appropriate, close out the Client's open trades in whole or in part, sell any or all
of the Client's property held by the Company, buy any securities, Financial Instruments, or other
property for the Client's accounts, and may cancel any outstanding order/request and
commitments made by the Company for the Client. Such sale, purchase or cancellation may be
made at the Company's discretion without advertising the same and without notice to the Client or
his/her Business Introducer, agent and/or representative and without prior tender, demand for
margin or payment, or call of any kind upon the Client. The Company may sell or purchase the whole
or any part thereof free from any right of redemption. It is understood that a prior demand or call
or prior notice of the time and place of such sale or purchase shall not be a waiver of the Company's
right to sell or buy without demand or notice as herein provided. Subject to applicable laws and
rules, and in order to prevent non-permitted trading in debit/deficit accounts, profits on any
transactions executed without the Company's express permission, for the Client’s account that is
debit/deficit at the time the order/request is placed, shall be for the Company's account if the
Company in its discretion so elects. Losses on any such transactions shall be jointly and severally
borne by the Business Introducer, agent and/or representative if any, and the Client, decision made
by the Company in its sole discretion. The Client shall remain liable for and pay the Company the
amount of any deficiency in any of the Client’s account held with the Company resulting from any
transaction described above. The Company’s determination of the current market value and the
amount of additional and/or variation margin shall be conclusive and shall not be challenged by the
Client.

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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 accounts
which would create positions/transactions in excess of the limit which the Company has set. The
Client agrees not to exceed the position/transaction limits established for any contract market or
type of account, whether acting alone and/or with others at any given time.
The Company, in its sole discretion, reserves the right to change the leverage applied to clients’
accounts, provided that, at the time of the conclusion of the transactions, the total number of open
positions/transactions, held by the Client’s accounts, has reached the preset limitation and/or in
cases where the Client has deliberately and/or systematically based on his/her trading strategy or
other probable behaviour with an attempt to exploit the ability of using marginal trading, with the
aim to increase the potential return of an investment, while such an activity automatically increases
the level of risk and the possibility of a loss.

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:

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

In the above-mentioned cases the Company reserves the right to either

a. cancel the transaction altogether,


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

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

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

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Client’s accounts and reserves the right to make necessary corrections or adjustments with respect
to the accounts involved.
Any errors may adversely affect realised and unrealised gains and losses of accounts.

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 transactions prices that are
not representing the market value, 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 accounts found to be using the abusive trading strategies, associated with
algorithmic and high frequency trading are subject to corrections/modifications and in cases may
be subject to closure of the trading accounts, should the Company find such an activity fit.

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

a. adjust the prices provided to the Client;


b. adjust the price spreads offered to the Client;
c. change the trading conditions/limitations applied to the Client’s accounts;
d. cancel the transactions;
e. delay in price confirmation and/or re-quote the prices offered;
f. restrict the Client’s access to streaming, instantly tradable quotes, by providing manual
quotation only;
g. retrieve from the Client’s accounts any historic trading profits, provided that the
Company can;
h. document that such trading profits have been made through exploiting of errors in
prices, at any time during the relationship with the Client;
i. terminate the relationship with the Client immediately by the way of written notice;
j. Enter the values that may be the transactions that were applied under different trading
conditions and were not considered offensive at the time;
k. Reverse transactions.

Trading strategies where transactions are executed within a short time scale, may be permitted by
the Company for as long as the trading strategy used by the Client is not considered abusive.

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However, should the Client base the trading strategy for the purpose of abusing prices offered by
the Company, the Company is entitled to take one or more of the above mentioned counter
measures.

17. EXERCISES AND ASSIGNMENTS


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

18. SECURITY AGREEMENT


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

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 accounts of the Client, held by the
Company, or any exchange member through which the Company clears the Client’s transactions,
such excess funds, securities, commodities, commodity futures contracts, commodity options,
and/or other property or Financial Instruments of the Client as in the Company's sole judgment may
be required for margin in any other such accounts or to reduce or satisfy any debit balances in any
other accounts provided such transfer or transfers comply with relevant governmental and
exchange rules and regulations applicable to the same. The Company is further authorized to
transfer any property held in any such accounts of the Client whenever, in the Company's sole
judgment, such transfer is necessary in order to effectuate the above authorized action. Within a
reasonable time after making any such transfer, the Company will confirm same in writing to the
Client.

20. INACTIVE ACCOUNTS


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

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

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 an inactive account is further considered dormant account
and removed from the systems accordingly.

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

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

21. NOTICES AND COMMUNICATIONS


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

22. PRINTED MEDIA STORAGE


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

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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 Providers solely in the event of executing acts pursuant to and
originating from this Agreement and that the Client’s information will be further subject to
confidentiality between such parties. The Client furthermore indemnifies the Company and holds
the Company harmless from and against any and all liabilities, losses, costs, or expenses related to
the Client’s information in cases where Service Providers are used in the execution of their
obligations towards the Company and that of the Client. The personal information may be disclosed
to the Company’s affiliates or, if so required, to local or foreign regulatory authorities, fraud and
prevention agencies and other organizations involved in crime, fraud and money laundering
prevention, for assessment and statistical analysis of the Company’s business, without a prior notice
to the Client.

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 accounts
and enter into this Agreement and to effectuate transactions in Financial Instruments as
contemplated hereby;
b. (if an entity) the Client is validly existing and empowered to enter into this Agreement and
to effect transactions in Financial Instruments as contemplated hereby;
c. the statements and financial information contained on the Client's Account Application
submitted herewith (including any financial statement therewith) are true and correct; and
d. no person or entity has any interest in or control over the accounts to which this Agreement
pertains except as disclosed within the Agreement. 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 of any futures
commission merchant, or an introducing broker, or an officer, partner, director, or employee
of any securities broker or dealer, is not a US person. 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 an introducers, acknowledges and confirms that the
Company is not responsible for the conduct and/or representations of the introducers or its
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associated persons while representing the Client to the Company. The Client agrees to waive any
claims the Client may have against the Company, and to indemnify and hold the Company harmless
for any acts or omissions of the introducer or its associated persons. The Client acknowledges and
confirms that the Company does not bear responsibility for whatever agreements may be reached
between the Client and the Client’s introducer. The Client furthermore confirms and acknowledges
that an introducer may act only independently or as an Agent of the Client and that the introducer
is not authorised to make representations concerning the Company or its services nor is authorised
to act on behalf of the Company as as agent or otherwise.

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

26. CONFLICTS OF INTEREST

The Company (directly or through its Service Providers may execute Financial Instruments for the
Client's accounts either as principal or broker in accordance with it license. 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 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 payments made by Credit Card, will bear the
Client’s name and will be credited into Client’s accounts held with the Company. The Client confirms
and acknowledges that the sole purpose for such payments is in accordance with the purpose of
this Agreement signed with the Company. The Client further confirms and acknowledges that the

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

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

In the event of a dispute related to the Chargeback, the Client agrees that the Company has the
right to withhold the Chargeback in a reserve until the dispute is finalized. The Client understands
and agrees that it may happen, as a consequence of the reserved Chargeback, that such Chargeback
may reflect on any of the transactions of the Client’s accounts.
The Client shall be liable for all and any of the costs paid to the credit card processor or banks, other
third parties, attorneys' fees and other legal expenses, and the reasonable value of the time that
the Company spent on the matter, incurred during the process of the dispute resolution.
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 the available by the Comapny
currency, specifically in US dollars, Euro, Pounds Sterling, Jordanian dinars 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 transfers shall be
borne by the Client. Amounts received in a currency other than designated account’s currency may
be subject to foreign currency exchange. Regardless of the payment method, funds are credited
into clients’ accounts unless the Company requires further information/justification/clarification in
regards to the transfers. The Company reserves the right to return the funds to the sender should
the originator of the funds not meet the requirements. The Company shall not be held liable in cases
where fund transfers are aimed to support accounts that are on margin call while the funds are not
received/confirmed by the Company.

The Client acknowledges and agrees that request for withdrawals from the Client’s accounts must
be received by the Company in writing using authorised communication channels. Only amounts

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

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

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

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

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

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

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

g. the beneficiary is a third party;

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

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


payment method.

29. 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, accounts or otherwise. In some cases, the Company may require to be provided with
additional data/documents to justify the reasoning for the change.In addition, the Client
acknowledges and agrees that the first transaction in any of the Client’s accounts initiated by the
Client, following a change to the terms and conditions of this Agreement as abovementioned, shall
constitute the Client’s acceptance of the change as of the effective date of the amendment or
variation and such initiation and the subsequent execution of such transaction by the Company shall
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 accounts upon receipt
of legal notification of the incapacity/death of the Client. The Client acknowledges that in the event

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

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 client has not provided recent or up to date personal information;
d. The Company reasonably suspect that the accounts is used for an illegal purpose;
e. The Client has behaved in an abusive or threatening manner towards the Company’s staff;
f. The Company reasonably believes that the Client has changed physical location without
notifying the Company of such change;
g. The Company reasonably believes that the activities of the Client’s accounts are no longer in
accordance with the terms of this Agreement;
h. The Company reasonably determines that the Client is no longer eligible to perform the
activities in accounts;
i. A petition of bankruptcy/liquidation is presented to the Company against the Client;
j. Any other legal valid reason to take such action;
k. Accounts did not record any activities within the predefined period;
l. Legislative requirements.

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 accounts after deduction of any charge/costs 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

20
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 accounts margin requirements;


▪ Close any or all of the Client’s accounts open trades in Financial Instruments at such closing level
as the Company reasonably believe to be appropriate;
▪ 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 Seychelles. No action, regardless of form, arising
out of transactions under this Agreement may be brought by the Client after three months have
elapsed from the day that the cause of action arose.

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.
Further the Company may, at its absolute discretion, also terminate any of the Client's additional
accounts which the Company considers that are not being used. Furthermore, it is clarified that a

21
Client may open an additional account with the Company after a purpose for the account opening
is established and justified.

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 further
declares that he/she is the real beneficiary of the accounts and that the funds deposited in the
accounts come from legitimate sources. The Client acknowledges that trading with Financial
Instruments is speculative, involves a high degree of risk and is appropriate only for those who can
assume risk of loss in excess of their margin deposits.

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 persons other than the Client. The Company
procures that its employees, Service Providers, to whom the confidential information is disclosed,
are informed of such nature and the employees and the Company shall limit the disclosure of the
Client's personal information on a need to know basis only.

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

22
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.

39. JOINT ACCOUNTS


In cases of Joint Accounts, the Clients will have equal power and authority, and be able to singly
and/or jointly including but not limited to:

a. request information about accounts so held,


b. request and execute transactions for accounts so held,
c. receive correspondence and documents in respect to accounts so held,
d. transfer, receive or withdraw funds from accounts so held,
e. request the change of information related to account so held.

Notwithstanding the foregoing, the Company reserves the right to require joint action related to
accounts. Joint Account holders (the Clients) will be jointly and severally liable for all accounts so
held. The Company may, in its sole and absolute discretion, require that, prior to execution of an or
an instruction/order for transaction or any other activity related to accounts held jointly between
two or more persons, request or demand that that such an instruction/order is requested or
demanded by all account holders.

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

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

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.

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41. ABOUT US
Windsor Brokers (SC) Limited is regulated by Seychelles Financial Services Authority (“FSA”) with the
license number: SD072.

Registered Office: Suite 3, Global village, Jivan’s Complex, Mont Fleuri, Mahe, Seychelles.

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ONLINE ACCESS AGREEMENT
This Online Access Agreement (the “Online Agreement”) sets forth the terms and conditions under
which Windsor Brokers (SC) Limited (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.
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:

26
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 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

27
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.
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.

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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 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

29
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.

11. GOVERNING LAW


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

12. ACCEPTANCE OF ONLINE AGREEMENT


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

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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 (SC) 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 delivery of any such
data, information or message(s); and/or any loss(s) and/or damage(s) arising from and/or
32
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 Seychelles and subject to the jurisdiction of the Seychelles
courts. Thus, this Agreement has been thoroughly read, understood and accepted by the Client on
the signing of the MT Agreement.

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

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

36
acquiring or delivering the underlying interest. If the option is on a future contract, the purchaser
will acquire a futures open position with associated liabilities for margin (see the section on Futures
above). If the purchased options expire worthless, the Client will suffer a total loss of the Client’s
investment which will consist of the option premium plus transaction costs. If the Client is
contemplating purchasing deep-out- of-the-money options, the Client should be aware that the
chance of such options becoming profitable ordinarily is remote. Selling ("writing" or "granting") an
option generally entails considerably greater risk than purchasing options. Although the premium
received by the seller is 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.

38
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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