The Customer Acceptance Policy will ensure that the following aspects of the customer relationship;documentation and procedures are conducted.

•No account is opened in an anonymous or fictitious name(s).

•No account is opened where the Company is unable to apply appropriate customer due diligence measures.

•Risk in terms of the location of customer and mode of payments are duly checked.

•Documentation requirements and other information will be collected in respect of different risk

•Customer account must be opened only after ensuring that pre-account opening Know Your Customer (KYC) categories of customers.

•The volume of turnover, social and financial status, etc. will form the basis for categorization of customers into low, normal and high risk.Based on the defined criteria for acceptance and identification, customers will be categorized into low risk, normal risk, and high risk categories;

Low Risk Customers:

For the purpose of this CAP, low risk customers will be individuals and entities whose identities and sources of wealth can be easily identified. Low risk customers could be:

a. salaried applicant;

b. people belonging to government departments and/or working with government-ownedcompanies;

c. people belonging to the lower-income status of the society whose accounts showlimited balances;

d. people working with reputed public limited companies and multinational companies.

Normal Risk Customers:

Normal risk customers could be:

a. salaried applicants with variable income;

b. salaried applicants working with private limited companies;

c. self-employed professionals;

d. self-employed customers with a profitable track record for areasonable period;

e. high net worth individuals with an occupational track record.

High Risk Customers:

For the purpose of this CAP, high risk customers will be individuals and entities that are likely to pose a higher than average risk to the Company. High risk customers require higher due diligence. High risk customers could be:

a. non-resident customers;

b. non-face to face customers;

c. high net worth individuals, without an occupational track record;

d. politically exposed persons (PEPs);

e. firms having close family shareholding or beneficial ownership;

f. trusts, charities;

g. those with dubious suspicious and public information;

h. customers from countries that are considered by the FATF inadequately to apply theFATF 40+9 Recommendations ( Non-Cooperative Countries and Territories).

Customer identification is an essential element of KYC standards. For the purposes of this CAP , a customer includes; the person or entity that maintains an account with the FTD Limited, the beneficiaries of transactions conducted by professional intermediaries, any person or entity connected with a financial transaction who can pose a significant reputational or other risks to the Company.

The Company maintains a systematic procedure for identifying new customers and cannot enter into a service relationship until the identity of a new customer is satisfactorily verified. The best documents for verifying the identity of customers are those most difficult to obtain illicitly and to counterfeit. The Company pays special attention in the case of non-resident customers and in no case, short-circuit identity procedure is followed just because the new customer is unable to present enough documents and information to satisfy the KYC and due diligence procedures.

The customer identification process applies naturally at the outset of the relationship. To ensure that records remain up-to-date and relevant, the Company undertakes regular reviews of existing records. An appropriate time to do so is when a transaction of significance takes place when customer documentation standards change substantially, or when there is a material change in the way that the account is operated. However, if the Compliance Officer becomes aware at any time, through compliance and/or Anti-Money Laundering reviews, that it lacks sufficient information about an existing customer, takes immediate steps to ensure that all relevant information is obtained as quickly as possible.

The Company should not be exposed to reputational risk, and should, therefore, apply enhanced due diligence to such operations. High priority accounts, which by nature involve a large measure of confidentiality, can be opened in the name of an individual, a commercial business, a trust, an intermediary or a personalized investment company. In each case, the reputational risk may arise if the Company does not diligently follow established KYC procedures. All new customers and new accounts are approved by at least one person, the Finance or the Compliance Officer. In case of a new high-risk customer, the final decision is taken by the managing director. Particular safeguards have been put in place internally to protect the confidentiality of customers and their business. The company ensures that equivalent scrutiny and monitoring of these customers and their businesses is conducted, and also available to be reviewed by the Compliance Officer and the Internal Auditor.

The Company maintains clear standards and policies, on what records must be kept on customer identification and individual transactions. Such practice is essential to permit the Company to monitor its relationship with the customer, to understand the customer’s on-going business and, if necessary, to provide evidence in the event of disputes, legal action, or a financial investigation that could lead to criminal prosecution. As the starting point and natural follow-up of the identification process, the Company obtains customer identification papers and retain copies of them for at least five years after an account is closed. The company also retains all financial transaction records for at least five years from the date when the Company’s relationship with the customer was terminated or a transaction was completed.

General Identification Requirements

The Company obtains all information necessary to establish to its full satisfaction the identity of each new customer and the purpose and intended nature of the business relationship. The extent and nature of the information depend on the type of applicant and the expected size of the account.

When an account has been opened, but problems of verification arise in the service relationship, which cannot be resolved, the Company can close the account and return the money to the source from which it was received. While the transfer of an opening balance from an account in the customer’s name in another organization subject to the same KYC standard, it will be considered, however we will do our own KYC procedures because we should nevertheless consider the possibility that the previous account manager may have asked for the account to be removed because of a concern about dubious activities.

Naturally, customers have the right to move their business from one organization to another. However, if the Company has any reason to believe that an applicant is being refused service facilities by another organization, applies enhanced due diligence procedures to the customer.

The Company will never agree to open an account or conduct ongoing business with a customer who insists on anonymity or who gives a fictitious name. Nor should confidential numbered accounts function as anonymous accounts but they should be subject to exactly the same KYC procedures as all other customer accounts, even if the test is carried out by selected staff. Whereas a numbered account can offer additional protection for the identity of the account holder, the identity must be known to the sufficient number of staff to operate proper due diligence.

Information Collected From The Application Form

Potential customers of the Company have to submit completed and signed “Application Form”. This is an essential part of the trading account registration process, that apart from being used for the collection of information for AML purposes, it is also used to collect information about the investment experience and the financial status of the applicant.

FTD Limited back-office personnel should ensure that data entry fields of the application form are filled out accurately by the applicant and all necessary documentation is collected. All the answers provided on the form will be entered into the database of the Company by the back-office personnel. The Compliance Officer reviews the documents that have been submitted regarding the identity of the customer or the beneficial owner and examines the case within the risk categorisation principles. Upon completing the process, the Compliance Officer asks from the back-office personnel to open the account and notifies about the risk classification of the customer and the customer due diligence method.

Specific Customer Due Diligence Requirements

Customer identification must be carried out as soon as reasonably practicable after the first contact is made. Except its obligation to exercise due diligence and customer identification, the Company must confirm that the identity information which holds for its customers has to remain fully informed and updated with all necessary identification and information throughout their business relationship.

The Company reviews and monitors on a regular basis the validity and adequacy of customer identification information in its possession. Notwithstanding the above and taking into account the degree of risk, if realized at any time during the business relationship that company lacks sufficient or reliable evidence (data) and information on the identity and financial profile of an existing customer, the Company immediately takes all necessary actions using the identification procedures and measures to provide due diligence, in order to collect the missing data and information as quickly as possible and in order to determine the identity and create a comprehensive financial profile of the customer.

Further more, the Company monitors the adequacy of the information held and identity and economic portrait of its customers when and where one of the of the following events occur:

A significant change in the situation and the legal status of the customer, such as:

• change of directors;

• change of registered shareholders and/or actualbeneficiaries;

• change of registered office;

• change of trustees;

• change of corporate name and/or trade name;

• change of main trading partners and/or significant newbusiness.

Further more, the Company monitors the adequacy of the information held and identity and economic portrait of its customers when and where one of the of the following events occur:

A significant change in the situation and the legal status of the customer, such as:

• change of directors;

• change of registered shareholders and/or actualbeneficiaries;

• change of registered office;

• change of trustees;

• change of corporate name and/or trade name;

• change of main trading partners and/or significant newbusiness.

A significant change in the way and operating rules of the customer’s account, such as:

• change of persons authorized to handle its account;

• request for opening a new account in order to provide new investment services and/or financialinstruments

conduct of a significant transaction that appears to be unusual and/or significant than the usual type of trade and economic profile of the customer.

In case of customer transaction via internet, phone, fax or other electronic means where the customer is not present to verify the authenticity of his/her signature, or that is the person who actually owns the account, or is authorized to handle the account, the Company should establish reliable methods, procedures and practices to control access to electronic means to ensure that deals with the actual owner or authorized signatory of the account. Where the customer refuses or fails to provide the Company with the required documents and information for identification and creation of economic portrait, before entering into the business relationship, or during the execution of an individual transaction without adequate justification the Company will not proceed in a contractual relationship or will not execute the transaction and may also report it to dedicated AML Officer. This can lead to a suspicion that the customer is engaged in money laundering and/or terrorist financing. If during the business relationship the customer refuses or fails to submit all required documents and information, within a reasonable time, the Company has the right to terminate the business relationship and close the accounts of the customer. The compliance department also examines whether to report the case as an Anti- Money Laundering attempt.

FTD Limited will obtain sufficient customer identification for the legal health of its core business and compliance smoothly to regulatory checks. And also customer Identification procedures can only be carried out while establishing the relationship, carrying out a financial transaction or when the Company has a doubt about the adequacy of the previously obtained customer identification data.

If any new/ongoing customer fails or refuses to submit required verification data and information within a reasonable timeframe given , the Company reserves the right to terminate the business relationship and close all the accounts of the customer in question, while at the same time it shall examine whether it is justified under the circumstances to submit a report to the Financial Investigation Agency (the “FIA”).

The Company shall apply each of the customer due diligence measures and identification procedures set forth herein, but may determine the extent of such measures on a risk-sensitive basis depending on the type of customer or services offered; when so requested, the Company shall be able to demonstrate to the Financial Investigation Agency (the “FIA”) , and/or the BVI Financial Services Commission (the “FSC”) that the extent of the measures is appropriate in view of the risks of the use of its services for the purposes of money laundering and terrorist financing.

FTD is required to notify its customers, as per the BVI Regulation and relevant international standards, that they are being categorized as retail customers, professional customers, or eligible counterparties.

FTD shall inform its customers about provision of services and any limitations to the level of customer protection that a different categorization would entail.

A. CUSTOMER CLASSIFICATIONI.

RETAIL CUSTOMER:

A Retail customer is one who does not meet the requirements to be classified as either a professional customer or an eligible counterparty.

II. PROFESSIONAL CUSTOMER:

A professional customer is presumed to possess the experience, knowledge, and expertise to make its own investment decisions and properly assess the risks that it incurs. These are;

i. Entities which are required to be authorized or regulated to operate in the financial markets, including organizations such as credit institutions, investment firms, other authorized or regulated financial institutions, insurance companies, collective investment schemes and their management companies, pension funds and their management companies; commodity and commodity derivative dealers, locals, other institutional investors;

ii. Large entities that meet at least two of the following criteria on a company basis;

a. Its balance sheet is equal to or exceeds €20,000,000

b. Its net turnover is equal to or exceeds €40,000,000; or

c. Its own funds equals to or exceeds €2,000,000.

iii. Customers who possess the necessary knowledge and experience in trading complex financial instruments and specifically request Professional Client status may have their request favorably considered. This generally occurs if they meet two out of the following three criteria:

a. the customer has carried out transactions, in significant size, on the relevant market at an average frequency of 10 per quarter over the previous four quarters,

b. the size of the customer’s financial instrument portfolio, defined as including cash deposits and financial instruments exceeds €500 000,

c. the customer works or has worked in the financial sector for at least one year in a professional position, which requires knowledge of the transactions or services envisaged.

We may request independent documentary evidence to validate the mentioned criteria. If these conditions are not satisfied, we will not approve the customer as a professional customer.

Professional customers have the right to request to be classified as retail customer in order to obtain a higher level of regulatory protection, and also have the right to request to be classified as eligible counterparties.

III. ELIGIBLE COUNTERPARTY:

An eligible counterparty is a legal entity which, among professionals, operates in the financial sector and has all the necessary knowledge, experience and expertise in investment matters. Each of the following are considered as eligible counterparty; investment companies, credit institutions, insurance companies, collective investment schemes or their management companies, pension funds or their management companies, other financial institutions authorized or regulated under the law, central banks, supranational organizations.

In the event that legal entity customers make a request, they may be accepted and treated as eligible counterparty if deemed appropriate by FTD.

Eligible counterparties have the right to request to be classified as retail customer or professional customer in order to obtain a higher level of regulatory protection. FTD has no obligation to comply with such request. FTD will carefully consider each request for re-categorization. We will assess the customer’s financial background, experience, and current subscriptions to ensure they are suitable for the new category and the products and services they are using. Based on this review, we will make a decision on whether to approve the request.

B. THE DIFFERENCES IN PROTECTION

a. Retail customers are provided with the highest level of protection.

b. Where we treat you as a professional customer, you will be entitled to fewer protections under the Law, than you would be entitled to as a retail customer. In particular:

i. You will be given fewer information disclosures with regard to FTD Limited, its services, products and financial instruments such as Contracts for Difference (“CFDs”) (for example on costs, commissions, fees and charges, information on risks associated with CFDs or any other articular product);

ii. You will not be provided with the written Risk Warning and notices required for the retail customers;

iii. We shall be entitled to assume that you have the necessary experience and knowledge to understand the risks involved, and assume that you are able financially to bear any investment risks consistent with your investment objectives;

iv. Where we assess whether a product or service is appropriate for you, we can assume that you have the necessary level of knowledge and experience to understand the risks involved in it, including for CFDs the risks involved in trading with leverage / margin;

v. When providing you with Best Execution we are not required to prioritize the overall costs of the transaction as being the most important factor in achieving Best Execution for you;

vi. We do not need to inform you of material difficulties relevant to the proper carrying out of your order(s) promptly;

vii. Should we provide you with periodic statements, we are not required to provide them as frequently or as detailed as for retail customers;

viii. Where we are holding your customer money, we are not required to notify you of whether interest is payable on it.

c. Where we treat you as an eligible counterparty, you will be entitled to less protection under the law than you would receive as a professional customer in respect of the reception and transmission of orders, the execution of orders and/or any ancillary service directly related to such transactions. In addition to the above items that are not provided to the professional customer, where we treat you as an eligible counterparty, we are not required to:

i. Provide you with best execution for your orders;

ii. Disclose to you information regarding any fees or commissions that we pay or receive;

iii. Assess the appropriateness of a product or service provided to you;

iv. Furnish you with information concerning ourselves, our services, and the compensation arrangements in place;

v. Provide you with risk disclosures on the products or services you buy from us;

vi. Provide you with reports on the execution of your orders.

The following list predetermines the types of customers who are not acceptable for establishing a business relationship with the Company:

• Customers who fail or refuse to submit, the requisite data and information for the verification of their identity and the creation of their economic profile, without adequate justification,

• Shell companies,

• Residents of UK and USA, jurisdictions subject to a FATF call on its members as Iran/North Korea and jurisdictions with strategic AML/CFT deficiencies (Pakistan, Syria, Yemen etc.).

A politically exposed person (PEP) is an individual who is or has been entrusted with a prominent public function. Due to their position and influence, it is recognized that many PEPs are in positions that potentially can be abused for the purpose of committing money laundering (ML) offences and related predicate offences. The potential risks associated with PEPs justify the application of additional anti-money laundering / counter-terrorist financing (AML/CFT) preventive measures with respect to business relationships with PEPs.

Consistent with this objective, FTD has prepared appropriate risk management systems in place to determine whether customers or beneficial owners are PEPs, or related or connected to a PEP, and, if so, FTD will take additional measures beyond performing normal Customer Due Diligence (CDD) to determine if and when they are attempting to do business with the Company.

PEPs are categorized as foreign, domestic and international organization. Family members and close associates of PEPs also qualify as PEPs who are related either directly or professionally.

The following must be considered as indicators in establishing whether or not a customer is a PEP:

• The country of origin of the customer.

•The stability of the country of origin and whether it is prone to corruption and other criminal activities such as abduction and kidnapping for ransom.

•Whether the country of origin is cash based.

• Whether the country of origin has in place adequate AML/CFT measures, including “Know Your Customer” (KYC) requirements.

•Where large amounts are presented for establishing the business relationship, the form in which they arepresented.

•Whether the country of origin is under any established sanction, embargo or other restriction or whether any such sanction, embargo or restriction is specifically imposed on the customer.

In an instance where a customer is identified as a PEP, the necessary CDD measures will be applied. When considering whether to establish or continue a business relationship with a PEP, the focus should be on the level of ML/TF risk associated with the particular PEP, and decision should be taken on the basis of the customer due diligence process and with an understanding of the particular characteristics of the public functions that the PEP has been entrusted with. The decision to establish or continue a customer relationship with a PEP will be guided primarily by an assessment of ML/TF risks, even if other considerations, such as regulatory risk, reputational risk or commercial interests, are taken into account.

Before accepting a PEP as a customer, the company will identify him/her and confirm the sources of funds. A new customer may not qualify as a PEP, but may so qualify in the future and it is therefore important, through the information updates of customers or through other sources, to ensure compliance with the requirements of the Code as they relate to PEPs.

Foreign or domestic PEPs from high risk countries are always considered as high risk customers and require the application of enhanced due diligence measures. The decision to establish and/or continue business relations with PEPs would be taken at board level.

Ongoing monitoring is an essential element of effective KYC procedures. Risk can be effectively controlled and reduced only if an understanding of the normal and reasonable activity of the customer is available to identify transactions that fall outside the regular pattern of activity. However, the extent of monitoring shall depend on the risk sensitivity of the account. This should further lead to more proactive steps, in particular, to an increase in the monitoring of the business relationship, in order to determine whether those transactions or activities appear unusual or suspicious. To continue ongoing monitoring of the business relationship effectively, well-trained staff and effective information gathering are always required. FTD with the resources to implement electronic monitoring systems will be able to conduct automated monitoring on a relatively constant basis.

TRANSACTIONSIn the British Virgin Islands, reports on money laundering and terrorist financing activities are made to the Financial Investigation Agency (“FIA”) set up under the Financial Investigation Agency Act, 2003.

If, during the business relationship, a customer fails or refuses to submit the required verification information within a reasonable timeframe provided, FTD reserves the right to terminate the business relationship and close all the accounts of the customer in question, while at the same time the Company shall examine whether it is justified under the circumstances to submit a report to the BVI FIA.

If you have any questions and/or concerns regarding this Customer Acceptance Policy, please e-mail us at support@ftdsystem.com

Leveraged trading in futures, foreign currency contracts or other off-exchange products (CFDs) on margin carries a high level of risk and may not be suitable for everyone. We advise you to carefully consider whether trading is appropriate for you in light of your personal circumstances. You may lose more than you invest. If the price of the underlying financial product moves against your position, you may sustain a total loss of the Margin Requirement in respect of your account that you deposit with or pay to FTD to establish or maintain a position and, you may be required to pay substantial additional funds at short notice but if you fail to do so within the required time, your investment position may be liquidated at a loss to you and you will be liable for any remaining deficit in your trading account. The close out process is automatically triggered when the equity in your account falls below the Margin Close-Out Amount. The Margin Close-Out Rule is imposed on a per account basis. FTD recommend that you fully understand the risks involved before the start of margin trading. CFDs, MT5 hedging capabilities and leverage ratios exceeding up to 100:1 are not available at residents of countries where its distribution, or use by any person, would be contrary to local law or regulation.

Speculative trading is the trading of leveraged financial instruments, without the intention of actually obtaining the underlying asset. Traders buy or sell those contracts with the intention of closing their positions before the maturity date. They expect the price of related contract to move in their favor. Speculative trading in a financial instrument involves high risk, in expectation of significant returns. This type of trading is a challenging prospect, even to customers with wider market experience and an understanding of the investment risks involved. Only funds that a customer would allocate to high-risk investments should be used in margin trading.

The CFDs available for trading through the Company are non-deliverable spot transactions, giving an opportunity to make profit on changes in currency rates, indices and commodities. Prices could move rapidly and If the underlying instrument movement is in the Customer’s favor, the Customer can make a significant profit, but an equally small adverse market movement can quickly result in the loss of the Customer’s entire initial deposit. The Customer must not enter into CFDs unless he/she is willing to undertake the risk of losing all the money he/she has invested.

Trading in a Contract for Differences carries the same risks as trading in a future or an option contract and the Customer should be aware of the risks involved. Transactions in CFDs may also have a contingent liability and Customers should be aware of the implications of their outcomes.

CFDs on FX, indices and commodities are off-exchange transactions. The Customer acknowledges that the transactions entered in CFDs with the Company are not undertaken on a recognized exchange, rather, they are undertaken over the counter (OTC) and as such they may expose the Customer to greater risks than regulated exchange transactions. Despite some off- exchange markets are highly liquid, transactions in off-exchange or nontransferable derivatives may involve greater risk than investing in on- exchange derivatives. It may be impossible to liquidate an existing position, to assess the value of the position arising from an off-exchange transaction, or to assess the exposure to risk. So CFD trading does not have the same protection as trading in regulated exchange.

Before Customers begin to trade, they should make themselves aware of all commissions and other charges for which they will be held liable. If any charges are not expressed in monetary terms, the Customer should ensure that they understand the true monetary value of the charges. To open a position in some types of CFDs the Customer may be required to pay commission and/or swap fees, the amount of which is disclosed on the Company Website. The value of opened positions in some types of CFDs is increased or reduced by a daily swap rate throughout the life of the contract. Swap rates are based on prevailing market interest rates, which may vary over time.

Market volatility may affect the price, execution speed and volume of the trading instrument. Therefore, trading during volatile conditions, where unexpected economic events occur, or important news and data releases are made, is highly risky and since the best execution criteria might not apply. If prices move against you in a fast market, the Company may be unable to execute your instructions at the requested price. It is important to refer to slippage which can occur during periods of high volatility. As an industry standard, the execution pricing will always be provided at the first available price.

Market risk interest rate, inflation, natural disasters and political instability. refers to the overall economy, while specific risk that an investment may face due to fluctuations in the market. Some of such risks include currency, risks are not possible to foresee and may affect the value of your investments. Some market It should be noted that global events and other factors are not controllable by anyone can impact the value of your investments. Therefore, customers need to acknowledge and accept the potential uncontrollable market risks beforehand.

The Company places a significant importance on the speed of market execution of the Customer’s placed orders within the limitations of technology. There are certain risks due to the nature of internet-based trading. These may include but not be limited to, the failure of hardware, software, and Internet connection. Since the Company does not control internet providers, their equipment and technology, internet connection speed or reliability, configuration of customer equipment or reliability of its connection. FTD cannot be responsible for communication failures, public electricity network failures, distortions or delays when trading via the Internet.

Trading platforms software uses a sophisticated order entry mechanism and order tracking system. FTD and counterparties do their best to fill customer trade at the price requested. Internet trading, regardless of how convenient or efficient does not necessarily reduce risks associated with online trading.

The Customer also may give instructions to trading desk by telephone to modify or close a position. The Company is not responsible for disruption, failure or malfunction of telephone facilities and does not guarantee its telephone availability. For the avoidance of doubt, the Customer is aware that the Company may not be reachable by telephone at all times and thus the Customer can place his/her orders through online access to the Company’s Trading Platform. If the Customer undertakes transactions on a Trading Platform, the Company bears no responsibility for any loss that arises as a result of encrypted information sent to the Customer by the Company, that has been accessed via unauthorized means. Security of his/her account access data is customer’s sole responsibility and as it highlighted before he/she will be exposed to risks associated with the system, including the failure of hardware and software.

The Customer is responsible for any taxes and/or any other duty which may accrue in respect of his/her trades in any Financial Instruments including derivative instruments. In case of changes in legislation or customer’s personal circumstances, the Company does not warrant that no tax and/or any other stamp duty will be payable.

The funds that a Customer deposits in its FTD account are held in segregated accounts at such banks. Customer funds will be administered according to British Virgin Islands bankruptcy law in the event of the bankruptcy or insolvency of FTD.

The Company may transfer money or crypto currency received from the Customer to a third party (e.g. a bank, liquidity provider, intermediate broker, OTC counterparty,Cyripto platforms ) to hold or control in order to effect a transaction through or with that person, or to satisfy the Customer’s obligation to provide collateral (e.g. margin requirement) in respect of a transaction. The Company has no responsibility for any acts or omissions of any third party to whom it will pass money/crypto currency received from the Customer. The third party to whom the Company will pass money, may hold it in an omnibus account and it may not be possible to separate it from the Customer’s money, or the third party’s money. In the event of the insolvency or any other analogous proceedings in relation to that third party, the Company may only have an unsecured claim against the third party on behalf of the Customer, and the Customer will be exposed to the risk that the money received by the Company from the third party, is insufficient to satisfy the claims of the Customer with claims in respect of the relevant account. The Company does not accept any liability or responsibility for any resulting losses.

The spread is the gap between the bid and the ask prices of a financial instrument. The risk occurs when the Customer trades one or more financial instrument contracts and for the hedging purpose, purchases one or more to balances the effect of an opposite. It should be recognized, though, that the risk from a widening spread could be considered. An adverse widening or narrowing of the spread during a particular time period may exceed the change in the overall level of the Customer trading account. And it is possible to experience losses while those contracts put on risk to overall margin limits of the Customer. Even those are hedged position may cause risk. And also, trading by that way increases transaction costs because the Customer will be charged commissions (at some CFDs and Futures) and/or undertakes the risk of swap differences on each opened contract.

Customers trading at the FX, CFDs and Futures markets also undertake different types of risk. One of the most well-known risk is called as a weekend risk. There are several reasons not to leave a position open over a weekend in most markets. Various events may arise over a weekend (Friday from [10:00 p.m. GMT] till Sunday at [10:00 p.m. GMT]), or during a holiday when the financial markets generally close for trading, that may cause the markets to open at a significantly different price from where they closed and hence any stop loss would be ineffective.

FTD does not provide market recommendations and the Customer acknowledges that the Company services do not include the provision of investment advice in financial products. The Customer represents that he/she has been solely responsible for making his/her own independent appraisal and investigation into the risks of the Transaction. Web Site is solely for informational purposes and is not to be construed a The content published on th solicitation or any offer to buy or sell any FX transactions or derivatives. The Company does not represent or guarantee that any content on the Web Site is accurate, nor that such content is a complete statement or summary of the marketplace. Nothing contained in the Web Site is intended to constitute professional advice and the Customer should not rely on the data or other information for making financial decisions. The Customer should consult with an appropriate professional for specific investment advice.

The Customer agrees that the Company is not responsible for any liabilities, claims, damages, costs and expenses, including attorney’s fees, incurred in connection with the information in the Web Site provided by the Company.

The Company provides no guarantee of profit or of avoiding losses when trading. The Customer has received no such guarantees from the Company or from any of its representatives. The Customer must be aware of the risks inherent in trading and is financially able to bear such risks and withstand any losses incurred.

In case of a force majeure event as; acts of war, terrorist attacks, natural disasters, financial market trading stops, currency interventions, government decisions, instability on financial markets with rapid drops of liquidity, the Customer shall accept the risk of any loss arising.

1.1 Risk Warning Notice

i. The high degree of capital risk associated with investing in our products may not be suitablefor all investors. You should ensure you are aware of the risks by reading the risk warnings ineach Product Schedule and obtaining independent advice if required. Prices for our productsmay change quickly to your detriment. Trades made using the Products involve leverage andthis increases the risk of losing your deposit.

ii. In the event that you have been designated as a Retail Customer, your potential loss isrestricted solely to the extent of your invested capital. Countdowns are unavailable to RetailCustomers under these circumstances. However, if you are classified as a ProfessionalCustomer or an Eligible Counterparty, although an overall negative balance is not deemedacceptable, there exists the potential for the establishment of a credit line throughresolutions passed by the Board of Directors.

iii. FTD assumes that a Professional Customer and Eligible Counterparty have the necessaryknowledge and skills to understand the risks connected with the specific investment services,activities, or products for which the Customer has been designated as a ProfessionalCustomer and Eligible Counterparty. As a result, no assessment of suitability will beperformed for Professional Customers and Eligible Counterparty.

iv. All Trades will be conducted on a non-advised, principal-to-principal, and execution-only basisunless agreed upon otherwise in writing. This implies that neither party can act as an agent,trustee, attorney, or representative for any other individual without prior written agreement.Except for an Authorized Person designated for an Account according to clause 5.3, you arenot authorized to allow anyone to conduct business with us on your behalf. We do not offerinvestment, financial, legal, tax, regulatory, or similar advice. The information or features(including charts) provided to you must not be regarded as advice that is suitable for you orbased on your circumstances. We are not liable for any investment decisions made by you.

1.2 Scope of the Terms

i. This Agreement shall be considered as a part of the Customer Agreement between you (alsoreferred to as “our Customer” or “your) and FTD Limited (also referred to as “FTD”, “we”, “us”, “our”).

ii. Each Transaction that is now occurring between us is governed by this Agreement.

iii. These Terms, our Order Execution Policy, our Risk Warning Notice, and any other writtenterms and conditions you accept in connection with your Account or use of the Platformconstitute our agreement with you. The Agreement, which includes these documents. We willnotify you of any changes to the Agreement. You must ensure that you keep informed of thesechanges.

iv. On our website and through our platform, you can access informative supplementarydocuments and information that do not form a part of the Customer Agreement or thisAgreement.

v. You agree that nothing other than what is specifically stated in this Agreement has been reliedupon or used to convince you to enter into this Agreement.

vi. This Agreement contains all the terms and conditions that govern our relationship and youractivities carried on with us on or in relation to the Platform and supersedes any prior oral orwritten representations and/or agreements between you and us which relate to our Platform.

vii. The terms that are described in Section 4 under the title of “Definitions” are to have a specificmeaning unless otherwise stated and may be used in either the singular or plural depending onthe context.

viii. It is advised that you set aside enough time to properly understand the Agreement as well as allother papers and information available on our website and platform before applying for anAccount and/or putting any Orders in order to protect your benefit. It is advised that youconsult a qualified expert for guidance if you are unsure about any aspect of this Agreement.

ix. We are required to conduct our business and dealings with you by the Applicable Law.

i. The definitions in this Article are based on the UK Financial Conduct Authority (“FCA”) Rules. However, this does not mean that the FCA Rules shall apply or be applicable for the remainder of the Agreement.

ii. A Customer who is neither a professional Customer nor an eligible counterparty is referred to as a “Retail Customer”. Retail Customers have a right to the FTD’s highest level of protection and information.

iii. A Customer who has the experience, knowledge, and skills to make his/her own investment decisions and accurately estimate the risks it takes is referred to as a “Professional Customer.”

iv. “Eligible counterparties” are professional Customers of specified types who receive a lower degree of protection in respect of the transaction with the FTD or in respect of the ancillary service directly relating to the transaction in the course of execution of orders on behalf of Customers and/or dealing on own account and/or receiving and transmitting orders and ancillary services related to any of these investment services (if applicable).

v. All kinds of Customer criteria, determination, and scope are determined by FTD on a Customer-by-Customer basis at its sole discretion.

vi. For the purposes of the applicable law to be applied to our relationship, we shall consideryou to be a Retail Customer until we have specifically told you differently in writing. You mightnot be eligible for certain legal protections provided to retail Customers if we have classifiedyou as a professional Customer or an eligible counterparty (whether or not at your request).You are allowed to ask for a different customer classification. If you ask for a differentcustomer category, we’ll get in touch with you to clarify the procedure and any newrequirements that apply. (Please see our Customer Acceptance Policy for detailedinformation on customer categorisation, and the protections different categories ofcustomers are entitled to.)

i. In relation to anti-money laundering, sanctions, and financial crime prevention, you confirm and guarantee that you are currently in compliance with all applicable regulations, including those concerning bribery and corruption, financial crime prevention, and economic sanctions programs that apply to BVI and any jurisdiction in which you operate. We are obliged to comply with these regulations, which means that:

a. If we do not receive adequate proof of identification within a reasonable amount of time, we have the right to terminate operating with you.

b. We retain the right to end this Agreement immediately, decline to carry out any pending Orders, and prevent access to your Account and its assets if we have a reasonable belief that you may have violated the AML Laws, or if you refuse to furnish us with the necessary information about yourself during the Account opening process or at any other stage that we may require at our discretion. Additionally, if any of the warranties and representations made by you are found to be untrue, we may also take such actions.

c. We reserve the right to report and disclose any pertinent information to any person or authority that we consider necessary to comply with applicable regulations and may act upon their instructions in relation to you, your Transactions, your Account and any information which we have regarding you and your dealings with us.

d. We may decline to provide additional explanations for any actions taken, refusals, or failures to act if we determine that it is necessary to meet our obligations under applicable regulations,

e. We will not be responsible for any loss or damage you may suffer due to any action or refusal to act on our part, which we consider necessary for complying with the applicable regulations.

f. You agree to cooperate with us and promptly provide any requested information related tothe inquiry if a regulatory body or other authority requests information regarding any ofyour transactions.

g. By agreeing to this, you declare and guarantee that you have provided complete andtruthful information about all of your ultimate beneficial owners and anyone who holds asynthetic, economic, direct, or indirect interest in over 10% of your share capital oreconomic rights. You have also given us the necessary details to verify your identity,comprehend your business, financial and risk profile, and identify those in control andyour beneficiaries.

h. You guarantee and confirm that you, as a legal person, have provided or will provide uswith the information necessary to establish your identity, understand your business,financial and risk profile, including the sources of your wealth, and identify yourbeneficiaries and controlling persons (if you are a legal entity), as well as disclose thenature of your intentions. This information must be provided as directed by us and incompliance with the Applicable Law.

i. You guarantee and confirm that neither you nor any of your associates, including your ortheir directors, officers, employees, agents, or underlying Customers, are individuals orentities subject to financial crime sanctions, or are legally or beneficially owned orcontrolled by anyone subject to such sanctions.

j. By agreeing to this, you guarantee that you have fully and truthfully disclosed all of yourultimate beneficial owners and anyone who holds a synthetic, economic, direct or indirectinterest in more than 10% (or any other percentage deemed appropriate by us) of yourshare capital or economic rights (including the economic rights to transactions carried outthrough us). Additionally, you have provided or will provide us with the necessaryinformation (certified as per our requirements) to enable us to establish your identity,comprehend your business, economic and risk profile (including your sources of wealth),identify your beneficiaries and controlling persons (if you are a legal person), anddetermine the nature of your intentions while entering into this Agreement.

k. If you or any of your ultimate beneficial owners, directors, officers, employees, agents, orunderlying Customers for whom you might act under this Agreement are a PoliticallyExposed Person (“PEP”), you have made sufficient disclosure of this fact to us.Furthermore, if during the term of this Agreement, you or any of your ultimate beneficialowners, directors, officers, employees, agents, or underlying Customers for whom youmight act hereunder become a PEP, you will notify us immediately.

l. You confirm that if any information provided to us in respect of yourself changes in anymaterial respect, you will immediately notify us of such change. You understand that yourAccount and any assets thereon may be frozen or blocked at our sole discretion and anyservices provided hereunder may be suspended, pending collection by us of full andcorrect information regarding your status.

m. You warrant to us that your account is for your personal use only, and you acknowledgethat we may freeze or block your account and any associated assets at our discretion ifany of those assets are held with, transferred, or delivered to us on behalf of a third party.

n. You agree that all remittances in your account are the result of bona fide economicactivities that have been accurately reported to the applicable tax authorities and havenot been acquired through any means that may be regarded as acts of bribery orcorruption, money laundering activities, or any other financial crime.

Account shall mean any account for trading Trades that you hold with us.

Account Close-out shall mean that our Platform has the capability to close either a part or the entirety of your Trades and/or Positions through a certain process.

Account Currency shall mean the currency in which an Account is designated and in which all Deductions and Credits shall be made.

Account Value shall mean the sum of your Cash and any net Unrealised Profit or Loss (as applicable), where the net Unrealised Profit or Loss is calculated using the first Buy Price or Sell Price (as applicable) displayed on the price ladder on the Platform, that is displayed on our Platform and updated in real-time.

Applicable Law shall mean any laws, statutes, orders, rules, decisions, provisions, directives, regulations, requirements, conditions, standards, sanctions, guidelines, and industry codes having a legal effect in any jurisdiction, provided that such laws, statutes, orders, rules, decisions, provisions, directives, regulations, requirements, conditions, standards, sanctions, guidelines or industry codes are existing and in force from time to time and (where relevant in the context) are directly or indirectly applicable to us, you, the Customer Agreement, our Website, or our Platform.

Associate shall mean an organization that is a member of the same group as us, a representative that we or a company in the same group as us appoints, or any other individual that we have a connection to that may reasonably be considered to result in a shared interest.

Authorized Person shall mean individuals who may be appointed by you, either in accordance with section 5.3 to act and/or offer instructions on your behalf for the Agreement and the applicable Account, or as an introducing broker, money manager, agent, or intermediary who has been accepted by us as per agreement.

Available Cash shall mean the lower of your Cash or your Available Equity on an Account, which will be displayed on the Order ticket for any Countdown.

Available Equity refers to the Amount is calculated by subtracting any Margin requirements from your current Account Revaluation Amount.

Business Day shall mean any day (other than a Saturday or Sunday) on which banks are open for business in British Virgin Islands.

Cash shall mean for any Account, is the total of successfully received payments from you to us, credits from us to your Account, and Realized Profits, minus Deductions, Realized Losses (whether due or not), and any money you have withdrawn. It’s important to note that Cash does not always indicate the amount of money available for withdrawal. The maximum amount available for withdrawal is the lesser of your Available Equity and Cash.

CFD Margin Trade is a cash-settled contract entered into between you and us through our Platform on an Account which seeks to track an investment in the relevant underlying asset without the usual costs and rights associated with an investment in that underlying asset.

CFD shall mean a contract for difference, CFDs are financial derivatives that are traded on margin, transacted off-exchange (or OTC), and whose value depends on an underlying instrument. The underlying instrument may be a financial instrument such as a foreign exchange or another financial asset.

Circumstances Outside Our Control refers to situations or events that are either currently happening or may happen soon, which prevents us from fulfilling our obligations. These circumstances include, but are not limited to:

1. Changes in Applicable Law or actions taken by authorities
2. Events or circumstances that disrupt the normal functioning of our Platform, such as system errors, failures, or disruptions, including third-party infrastructure
3. Acts or omissions of third parties, where we are unable or find it impractical, despite reasonable efforts, to acquire, establish, re-establish, substitute, maintain, unwind, or dispose of a trade or asset to hedge our price risk related to Trades
4. Natural disasters, emergencies, or acts of God
5. Human-made emergencies such as fires, explosions, criminal acts, riots, war, armed conflicts, terrorist attacks, or imposition of sanctions
6. Volatility and/or liquidity changes in the underlying market that affect our ability to determine or continue to determine a fair and reasonable price for a Product
7. Any other extraordinary event or circumstance beyond our control.

Customer Agreement shall mean the agreement that comes into effect upon your signing of the Account opening form, whereby, by signing said form, you acknowledge and accept all attached documents, including the Customer Agreement, and receipt of notification from us that you have been accepted as our customer.

Customer Categorization Letter shall mean the Customer categorization letter sent to you that designates your Customer categorization as a Professional Customer or as an Eligible Counterparty for the purposes of FSC Rules.

Conflicts of Interest Policy shall mean a policy in place that outlines situations that may lead to a conflict of interest, the measures we will adopt, and the procedures we will follow to prevent or manage such conflicts. Despite our best efforts, if we are uncertain that our measures will prevent damage to your interests, we will inform you of the nature of the conflict and the steps taken to mitigate the risk before conducting any business with you. Our conflicts of interest policy is being updated, restated, or modified from time to time.

Countdown Opening Price refers to the reference price that pertains to a Countdown on our Platform and is determined based on its input, creation, and display.

Countdown shall mean a contract with limited risk, entered into between you and us, enabling you to speculate on whether the Price of a Product will increase or decrease within a predetermined timeframe. Your win or loss depends solely on whether your prediction aligns with the Settlement Price of the Product at the expiry of the Countdown, in relation to the Countdown Opening Price at its beginning.

Currency Conversion Rate refers to the currency exchange rate applicable at the relevant time, which we will use to convert values denominated in a Product Currency into the Account Currency.

Elements shall mean all Intellectual Property Rights in connection with our Platform and Website, including but not limited to software, algorithms, design, text, content, data (including market data owned by third parties and used by us to generate Prices), arrangement, organization, graphics, compilation, magnetic translation, digital conversion, equipment, and any other electronic, computer, technical, and information communication technology devices, networks, servers, applications, codes (It also contains all technical documentation and information required to use any of the foregoing.)

Insolvency Event refers to the occurrence of any of the following:

1. the appointment of a receiver, administrator, manager, administrative receiver or similar officer in relation to you;
2. the possession or sale of all or part of your assets or business by an encumbrancer;
3. you being unable to pay your debts as they fall due;
4. an interim order application, voluntary arrangement proposal, deed of arrangement, or bankruptcy petition being presented to the Court regarding you;
5. a resolution being passed or an order being made for your winding up, dissolution or administration if you are a body corporate; or
6. your bankruptcy or insolvency, or any event similar to those described in (i) to (v) happening to you.

For partnerships or Joint Accounts, if any of the events in (i) to (vi) happen to one partner or Joint Account holder, it will constitute an Insolvency Event.

Joint Account refers to an account owned jointly by two or more people.

Manual Order shall mean a type of Order that may only be placed by our Customer management team and is only available to Professional Customers and Eligible Counterparties that get additional services.

Manual Product shall mean a Product for which our Customer management team is the only channel through which we will accept Orders or permit you to engage in   Products that we offer.

Open Position shall mean a transaction which has not been closed in whole or in part under this Agreement.

Order Execution Policy refers to the policy for executing orders, which outlines the way we carry out orders, can be found on our website.

Order refers to an offer made by you or on your behalf through our Platform. This definition includes Orders for Manual Products, Manual Orders, and Pending Orders, unless otherwise stated or implied by the context.

Pending Order refers to an order that includes a designated price and has not yet been carried out.

Platform shall mean our electronic trading platform for Products which will be periodically updated.

Position means all Trades in a particular product provided by FTD Limited in an account at any given time.

Price refers to the Buy or Sell Price of a Product determined by our Platform or provided by our Customer management team, which can be referred to as “Price”, “FTD Price,” or similar variations. This price is calculated based on the Price Depth and may change from time to time. If you place an Order for any Product, the Price at which your Order is executed may be different from the Price displayed on our Platform or provided by our Customer management team at the time of Order submission due to market fluctuations. As a result, the execution price may not be as favorable to you.

Price Depth shall mean the function on our platform that presents various prices for a specific product, based on the size of the orders placed for that product, and which may be visible on our platform.

Pricing Error refers to a disruption related to the underlying asset of a Product that prevents our Platform from determining a Price.

Product shall mean instrument generated by us upon which or in relation to which you enter into trades. Details of all products on which we may accept orders are listed in the marketwatch of MT5.

Sell Price refers to the Price at which a buy Product is initiated and a sell the product is assessed and terminated.

Settlement Price means opening or closing price of any spesific position. When any position is opened by investor, this position will have two different settlement prices at the opening and closing. These prices are requested by Customer via using MT5 platform and executed by system immediately.

Trades shall mean all positions and transactions opened by investor at a particular products provided by FTD Limited.

General Information

1. Once we confirm in writing that we have accepted your application to open an Account, the Agreement will become legally binding between you and us. You have the right to cancel the Agreement within fourteen (14) calendar days of this date by giving us notice in writing, except as stated in clause 5.1(ii). If you do provide a valid notice of cancellation, we will return any money that you have transferred to us. However, if you have entered into Trade or Countdowns during this period and they have been affected by fluctuations in the financial markets, you will not have the right to cancel the Agreement within fourteen (14) calendar days of your Account opening. You may still close your Trade and your Account as per the Agreement.
2. We have the authority, at our sole discretion, to change the type of your Account and/or enable or disable (as appropriate) Account features.
3. The Products available may vary depending on the Account type and/or feature. Each product is specifically described in the Customer Agreement and this Agreement (with its annexes). On the Platform, you can also find product instructions and descriptions.

• Account Setup Procedure

1. We may use the information you provide on your application form to make any additional inquiries about you that we (in our sole discretion) believe are reasonable or required given the circumstances. Every relevant circumstance that could have an impact on your trading operations with FTD Limited should be disclosed to us. We reserve the right to conduct any further examinations or routine reviews that, in our sole discretion, the situation necessitates or warrants. You must cooperate with us and provide any information we request promptly.
2. We depend on the accuracy and truthfulness of the information you provide us during the Account opening process or at any other time. Unless you inform us otherwise in writing, we assume that the information is always correct and not misleading. We utilize any available information about you to evaluate whether investing in Products and/or maintaining an Account with us is suitable for you. If there are any changes to the details provided during the Account opening process or if your circumstances change afterward, please notify us promptly in writing.

• You accept and agree that we or agents operating on our behalf may do regular searches and inquiries about you and any linked party at credit reference agencies and your employers, if applicable, and examine any current and historical investment activity and gather information in connection therewith and provide information to other dealers, or investment managers who may be interested in you or your investments. This is done to assess your creditworthiness, manage credit risk, and prevent fraud (or other criminal behavior).

• Appointment of Authorised Person(s) / Representative

1. If you intended to designate someone to represent you in relation to this Agreement (referred to as an “Authorised Person”), you must inform us in writing. Both you and the Authorised Person will be required to complete any additional documentation that we reasonably request. We may ask for evidence to confirm that the Authorised Person has the necessary authority and suitability to act on your behalf.
2. We have the right to revoke or decline the appointment of an Authorised Person if we have knowledge or reasonable suspicion that their appointment could result in a violation of the Agreement and/or Applicable Law. If there are any changes to the appointment or authority of any Authorised Person, you must promptly notify us in writing.
3. We are entitled to act upon instructions or Orders received from any Authorised Person or any person who appears or claims to be an Authorised Person regarding your Account, even if it is later discovered that they were not actually authorised.
4. However, we are not obligated to accept any instructions or Orders from an Authorised Person if we have reasonable grounds to believe that the person is exceeding their authority. Any actions taken by an Authorised Person appointed by you, or anyone who appears or claims to be an Authorised Person, will be treated as if they were taken by you. Similarly, any information provided by us to an Authorised Person or anyone who appears or claims to be an Authorised Person will be considered as if it was provided to you.
5. If you appoint an Authorised Person who also represents other Customers of FTD Limited, that person may decide to place a combined order with us for a Product and allocate the order among you and their other Customers. We are not responsible for the aggregation and allocation of such orders, and you should consult your Authorised Person for further details regarding any order aggregation or allocation.

• Joint Account

If you open a joint account;

1. The joint account shall be opened with the written determination of the proportional shares of the joint account holders at the beginning of the Account opening process.
2. The term “you” in this Agreement refers to any other person whose name appears on the Joint Account. We have the right to enforce any rights or obligations outlined in this Agreement against any person named on the Joint Account, or who reasonably appears or purports to be named on the account.
3. All Joint Account Holders share joint and several liability for any financial obligations that arise from the Joint Account. This means that any money owed to us relating to the Agreement will be owed in full by all persons named on the Joint Account.
4. In the event of the death of any Joint Account Holder, the Joint Account will be closed, and the balance will be divided equally between the surviving Joint Account Holder and the estate of the deceased Joint Account Holder. This will be considered a Specified Event.
5. We may communicate any notice or communication to any or all persons named on the Joint Account, and any communication or notice given to one person will be deemed as having been given to all Joint Account Holders.
6. Once a Joint Account has been established, it is not possible to add or remove persons named on the account. If you need to change Joint Account Holders, you must close the Joint Account and open a new one.

• Security of Account

1. You are responsible for keeping each Username and Password provided to you secretly and ensuring that they are only used by the people or system for whom they were intended. You will be held liable for any misuse or abuse of any such Username and Password, and you shall follow any reasonable instructions we may offer you from time to time regarding any such Username and Password. You shall instantly notify us if you feel that the security or functioning of any Username and Password or Online Systems has been compromised.

Rules for Money Transferred to Us

1. If you have been categorized as a Retail Customer according to the applicable laws, we will keep and maintain an amount equal to your Account Value in a segregated Customer money bank account for each Account you have with us. If we consider it is appropriate, we may, at times and within our regulatory permissions, retain Customer money in segregated Customer money bank accounts with fixed-term deposits or notice periods. Such fixed term deposit accounts or notice periods will not affect your ability to deal with or withdraw your money in the ordinary course of business. In exceptional situations, it is possible that the extended notice period may cause a delay in returning all or a portion of your funds to you until the relevant fixed term or notice period expires.
2. If you have been categorized as a Professional Customer or Eligible Counterparty by considering the Applicable Laws, we would require a mutual agreement that releases us from the obligation of keeping received funds in a segregated Customer money bank account. By signing the Account Opening Application Form, you agree to be bound by this Terms of Business, and you have read, understood, and agree to the terms and conditions specified following:
3. any amounts received from you or credited to your Account will become our full property and ownership;
4. deposits made to us should be intended for securing or covering your present, future, actual, contingent, or prospective obligations to us;
5. such deposits do not qualify as Customer money under Applicable Law, and we may use them in our regular business activities; and
6. in the unfortunate event of our insolvency, you will be reimbursed.

• On each Business Day, we complete Customer money reconciliations based on our reports from the close of business of the previous Business Day to establish the correct amount of money which should be held and segregated in our Customer money bank accounts in accordance with Applicable Law. Following the reconciliation any required transfer to or from the Customer money bank account in respect of your Account will then be processed.

1. In case of prolonged inactivity on your Account, we reserve the right to apply dormant Account fees and deduct them from your Account as per the clause.
2. If there hasn’t been any action on your account for the last 5 years, we will make an effort to contact you regarding any Customer money that is still in there. If no activity is conducted within the specified period in the account, this situation can be reported to the regulator, and necessary actions will be taken in accordance with the instructions received from the regulator.
3. Trading with money that was mistakenly placed or credited to your Account is at your own risk, and we are not liable for any resulting loss or damage. We have the authority to deduct such funds from your Account without prior notice or your consent, as we see fit and at our sole discretion.

• We have the sole authority to determine the interest rate, payment method, and duration for which your Account may earn interest, if eligible. Where applicable, you agree not to rely on the payment of interest to prevent an Account Close-Out, satisfy any Margin Requirements, or set off any payment obligation that you may have under this Agreement.
• Trading with us incurs charges, which are detailed on our website, in our cost disclosure, on our platform, and in our terms. We have the right to amend or waive these fees at our discretion and without prior notification to you. We may utilize the funds in your account to minimize the amount of holding charges payable.

Payment and Withdrawal

1. You are required by the Agreement to make sure that any payments to us are made on time and in accordance with the terms of the Agreement. Any payment that does not follow our payment policies, which are available on our Platform or through our Customer management team upon request, will be refused by us.
2. It is advisable to leave some “headroom” when paying us during potentially volatile times, such as maintaining an Account Revaluation Amount greater than your total Margin requirements or the applicable Close-Out Level on any Account and having enough funds above your Margin requirements. The market volatility for the underlying asset, the time it takes to make additional payments of cleared funds, your Positions, CFD Margin Trades, Countdowns, Pending Orders, and any other pertinent elements should be taken into account.

• Only when our systems have verified the payment and it has been posted on our Platform payments made by you or any Authorized Persons on your behalf will be credited to your Account. We cannot guarantee how long this process will take, and we will not be held responsible for any losses brought on by delays in crediting any payment to your Account.

1. All costs and fees, including bank transfer fees, internet and telephone service provider fees, and any other costs that might not be incurred by us, are your responsibility when making any payment to your Account. In accordance with the Applicable Law, we may apply an administration fee to process payments made through a payment card or withdrawals from an Account.
2. Up to the lowest of your Available Equity or Cash, you may request a withdrawal from your account. On request, you can get more information about how to make these withdrawals from our Customer management team or through our website.
3. Unless we have agreed differently, we will only accept withdrawal requests from you or specific Authorized Persons to comply with Applicable Law. Except in cases where we have approved a modification to your payment information or you have designated a specific Authorized Person to receive the cash, withdrawals will only be made to accounts that are registered in your name.

• We may in our reasonable discretion refuse or delay giving effect to your request for a withdrawal of money (in whole or in part) from your Account, including as a result of any request to close that Account under clause 14.2(i). We will notify you as soon as reasonably practicable if we decide to refuse or delay giving effect to your request for a withdrawal and such circumstance shall be regarded as a Specified Event.

Deduction, Right to Set-Off, and Netting

1. We reserve the right to make a deduction by taking money out of the funds in your Account that is payable to us by the Agreement or as required by Applicable Law.
2. We reserve the right, without prior notice, to set off any positive cash balances in your account with us or our associates, as well as any money due to you by us, to offset any outstanding payments you owe us or our associates. A Currency Conversion Rate may also be used to convert any relevant cash balances or due amounts into the same currency.

• If, in relation to a specific account,

1. a) You and we owe each other an equal amount of money in the same currency, both our obligations will be automatically fulfilled and terminated, or
2. b) You and we owe each other different amounts of money in the same currency, the person who owes more may pay the difference to the other party, resulting in the fulfillment and discharge of both our obligations.

Currency

1. You must choose the Account Currency when opening an account from the alternatives we provide, and all payments made in connection with that account must be made in the chosen Account Currency.

Taxes

1. In the event that we are obligated to settle any withholding tax or other levies on your behalf, we retain the right to deduct such amounts from your Account or request payment or reimbursement from you for these payments. Regarding any Countdown, we will bear the responsibility for the payment of any relevant betting duty or levy.
2. We hold the authority, at our sole discretion, to deduct or withhold any tax required by Applicable Law from any payment or credit issued to your Account. The tax treatment regarding your CFD Margin Trades and/or Countdowns may vary depending on your circumstances. It is advisable to seek independent professional advice to understand your specific tax obligations in this regard.

• All charges will be inclusive of any applicable value added taxes or similar consumption taxes.

Introduced Business

1. This provision applies if a third party, such as an introducing broker or money manager, has introduced you to us, and you have agreed with that third party to pay fees, commission, or other compensation (“Third Party Fees”) for the introduction and related services provided by the third party. We will inform you in advance of the effective date of this provision, and it will come into effect on the specified date.
2. By entering into this Agreement, you authorize us to disclose information about you and your Account, including personal data and Account activity, to the third party mentioned in clause 6.6(i), as well as to the affiliates and subcontractors of that third party, as necessary for the provision of services to you.

• By entering into this Agreement with us, you authorize us to deduct any Third-Party Fees owed by you to the third party from the funds held in your Account and make the payment to the third party on your behalf. We will notify you in advance of the method for calculating these deductions.

1. Any deductions made will include all applicable taxes, duties, or levies, regardless of their designation or calculation, including value added taxes or similar taxes.
2. It is your responsibility to ensure that there are sufficient funds in your Account to cover any Third Party Fees owed to the third party in full.
3. We reserve the right to cease facilitating the payment of, or making deductions for, the Third Party Fees at any time without prior notice to you. In such cases, any outstanding Third Party Fees must be resolved directly between you and the third party.

• You have the option to withdraw or modify the authorization given to us under this provision to facilitate or make deductions for the Third Party Fees on your behalf. To do so, you must provide us with written notice at least one (1) Business Day in advance.

Platform Rules

1. Our Platform offers various information related to your Account, including real-time updates on the execution of Orders, notifications regarding changes in the value of Product, and current statements of your Positions and Account balance as required by law. It is your responsibility to regularly access and review this information to ensure accuracy.
2. It is your responsibility to regularly access and review the information set out in clause 7.1(i) to ensure that it corresponds with your own records. Subject to clause 7.3, this information will be conclusive unless we notify you of any mistake, error or inaccuracy or you notify us in writing of any mistake, error or inaccuracy and we agree with your notification.

• We are required to retain certain information for a specific period as required by law, and you may access this information through our Platform or upon request. After this period, we may choose to retain or destroy this information at our discretion without notice.

1. We will make every effort to have our Platform and Customer management team available for you as needed, but we cannot assure the uninterrupted availability. We are not accountable to you for any losses resulting from unavailability of Platform and Customer management team.
2. It is your responsibility to ensure that you can access our Platform when required. This entails having a device that can connect to our Platform, maintaining it in a safe, secure, and working condition, and having dependable internet connectivity.
3. If you are unable to access our Platform directly, you can contact our Customer management team via telephone or email for assistance, but this may take longer than direct access, and we cannot ensure their availability.

• Any links to third-party websites and resources provided on our Platform, Website, emails, or any other content generated by us are only for your information, and we do not take responsibility for them or any resulting losses or damages.

External Platforms

1. The following additional provisions apply to Customers utilizing our external platforms, including but not limited to MT5 platform (the “External Platform”). If you utilize the External Platform, you acknowledge and agree to the following additional terms and conditions and authorize us to act.
2. You wish to utilize the External Platform to execute trades and to direct trade orders and trade details to us. When you are utilizing the External Platform you will not be entering trade orders and trade details directly with us but rather will be entering trade orders and trade details via the External Platform through a third party. You hereby authorise and direct us to enter trades for your Account in accordance with trading signals generated and sent to us by the External Platform.

• You fully understand that trade orders and trade details are generated by the External Platform and not by us and that our responsibility is to use commercially reasonable efforts to enter orders pursuant to the trade orders and trade details generated by the External Platform as received by us. You confirm that we have not solicited, or in any other way recommended your participation on the External Platform. You have made your own inquiries and conducted research into the External Platform sufficient to make an informed investment decision. We cannot imply or guarantee that you will make any profits from the External Platform, and you agree that we will not be held responsible in any way for the External Platform’s performance, or any trading losses incurred on your Account as a result of trading pursuant to the External Platform.

1. We will enter trade orders for your Account in accordance with the trade orders and trade details generated by the External Platform. You understand that your trading access through the External Platform will be provided by the External Platform provided and not us.
2. We shall not be responsible for any error or malfunction of the External Platform, mechanical or communication failure, systems errors, data failure, or any other causes beyond our control. You acknowledge that we can accept and execute orders only if they are actually received or generated.
3. You understand that there is no trading system or recommendations service, including the External Platform that is free from risk of loss. We therefore do not imply or in any way guarantee that you will make a profit and you agree that neither we nor any of our Associates, officers, directors, employees, consultants, agents or Affiliates will be held responsible for the performance of the External Platform or trading losses on your Account.

• We may terminate the authorization over the External Platform at any time for any reason in our sole discretion and will provide you with notice of this as soon as reasonably possible. You shall be responsible for any Open Positions in your Account at the time the External Platform is terminated. You shall permit for us to execute offsetting order for any open position in your Account at the time this External Platform is terminated, or your termination of this Agreement.
• You agree that in the absence of gross negligence, willful default or fraud, neither we, nor any of our Associates, officers, directors, employees, consultants, agents or Affiliates will be held liable for any act or omission in the course of or in connection with your participating in the External Platform. You shall indemnify us, our principals, officers, directors, employees, agents, successors and/or assignees from all loses and/or liability (including reasonable attorney’s and or accountant’s fees) incurred or resulting from this authority granted to us under this provision, to utilise the External Platform, provided that there has been no judicial determination that such liability was the result of gross negligence, willful default or fraud by us, and further provided that the conduct that was the basis for such liability was not undertaken in the actual or reasonable belief that it was in your best interest.

Orders

1. You shall be completely liable to us for the settlement of any Transaction emanating from any Orders submitted on your behalf via Platform and/or External Platform.
2. We reserve the right to modify, cancel, or reject your orders and may refuse to accept instructions or allow trading on your account at our discretion. Additionally, for Manual Products, you must go through our Customer management team to place, modify, roll over, cancel, or close orders. You cannot perform these actions on Manual Products through the Platform. To enter an Order for a Manual Product, you must contact our Customer management team and provide the necessary information. The Order will be executed by the Customer management team.

Error

1. Occasionally, errors and omissions (referred to as an “Error”) may occur with your all Trades. These Errors may include but are not limited to, a Pricing Error, incorrect deductions or credits to your Account, incorrect Order handling, or the Platform displaying incorrect Prices due to a third-party supplier or system error.
2. If you or we suspect or become aware of an Error, you must notify us or we will notify you as soon as reasonably practicable. We will then investigate the matter to determine the cause and whether an Error has been occurred. In the event that an Error is confirmed, this will be considered a Specified Event and the relevant provisions of the clause 10 will apply. We will inform you of any actions we may have taken or may take in accordance with clause 10.3.

Assurances

1. Under this Agreement, when we provide services to you, we have the right to rely on the following statements and assurances, confirmed by you to be accurate and truthful:
   1. Your use of our Platform and/or services does not involve any Improper Use;
   2. If you are an individual, you are at least 18 years old unless the relevant regulations your country establish a higher age limit;
   3. If you are a body corporate, unincorporated association, trust or partnership, you are lawfully in existence in accordance with the Applicable Law, and you have obtained all necessary consents and authorizations under your constitutional or organizational documents;
   4. Unless we have agreed otherwise in writing, you act on your own behalf and not as an agent, attorney, trustee or representative of any other person;
   5. You are not located in, incorporated in, or a resident of the USA or any other jurisdiction where accessing our Platform or engaging in Products, (as applicable) may be unlawful;
   6. Your Orders and/or Products are not for the purposes of or related to any placing, issue, distribution, offer, take-over, merger, or other similar corporate finance type transaction;
   7. You have no connection with the issuer of any underlying asset of a Product in respect of which you have placed an Order, including as a director, employee, agent, contractor or professional adviser of such issuer;
   8. Subject to clause 8.1(i)(d), you fully own or, in the case of money received from an accepted joint bank account jointly own (legally and beneficially) all money you may transfer to us in accordance with the Agreement, including money received from an accepted joint bank account;

Your Obligations

1. If you have a belief or reasonable grounds to suspect that you have violated any provision of the Agreement, it is essential to promptly notify us in writing.
2. You will bear responsibility for any losses and/or expenses incurred by us as a direct consequence or as something that a reasonable individual would anticipate as a likely outcome, due to your or an Authorised Person’s negligence, fraudulent actions, or breaches of the Agreement or Applicable Law.

Our Liability and Limitations

1. Nothing in the Agreement excludes or limits our liability for any matter that cannot be excluded or limited under Applicable Law.
2. We shall not be held accountable for any losses incurred under the following circumstances:
3. Our adherence to Applicable Law or the Agreement, or the exercise of our rights in accordance with them.
4. Instances where the loss is a result of your negligence, fraudulent activities, or breaches of the Agreement or Applicable Law.
5. Occurrences classified as Specified Events or Circumstances Outside Our Control.
6. Errors arising from unclear or ambiguous instructions provided by you or an Authorised Person when placing an Order.
7. Delayed payments or errors in calculating and/or facilitating payment of Third Party Fees owed to a third party.
8. We shall not be held liable for any loss, except in cases where such loss arises directly and solely from our negligence or breach of the Agreement. In such instances, our liability will be limited to direct and verifiable losses resulting from our negligence or breach of the Agreement. It is important to note that we will not be held liable for any loss of profit or missed opportunities, regardless of the circumstances.
9. We will only be held liable for direct and actual loss resulting from our negligence or breach of the Agreement, but not for any loss of profit or opportunity. We also cannot be held responsible for delays, delivery failures, or transmission failures resulting from data transfer over networks outside our control.

• We provide any features, market data, or third-party content available on our Website, Platform, or e-mails “as is” and “if available.” We, along with our third-party providers, have taken reasonable measures to ensure their accuracy and completeness, but we exclude any warranties, undertakings, or representations (whether express or implied) related to them to the extent permitted by Applicable Law. This includes but is not limited to the following:

1. In regard to any third-party market data, similar information, features, or information provided to you through our Website, Platform, and/or services:
2. We and our third-party providers are not providing trading or investment advice.
3. We and our third-party providers are not liable if any market data, feature, or information is inadequate, inaccurate, or incomplete in any respect.
4. We and our third-party providers do not guarantee the timeliness of market data or similar information.
5. We and our third-party providers are not responsible for any actions you take or do not take based on any market data, feature, or information.
6. We provide market data or similar information for general purposes only, and it should not be the sole basis for any investment decision.
7. You will use market data, features, or information solely in compliance with Applicable Law
8. The information contained in the features or third-party content is indicative and may be outdated at any given time. All analyses, resulting conclusions, and observations are based on past performance, patterns, and data and may not reflect future performance.
9. Our third-party providers are not accountable for and have not been involved in setting our prices. They also disclaim all warranties, promises, or assurances (whether explicit or implied) regarding your usage of our Platform, Website, or Elements. It’s important to note that our third-party providers cannot be held responsible for any losses incurred, even if they are aware of the situation and the liability is based on a breach of contract, tort, or any other legal theory.
10. Unless we have acted negligently, intentionally or engaged in fraudulent activity, we will not be held responsible for any harm or loss resulting from the transmission of viruses, distributed denial-of-service attacks or other harmful technological material that could potentially infect your computer equipment, data, software, or any other proprietary material due to your use of our Platform or Website or your downloading of any material from our Website or any linked websites.
11. Unless otherwise explicitly stated in these Terms, we bear no responsibility for reminding or notifying you of any obligations or liabilities that you may have under this Agreement. Any reminders or alerts that we do provide to you are at our sole discretion and do not create any obligation or commitment on our part to continue providing such reminders or alerts in the future.

1. The Agreement and all communication pertaining to it will be conducted in English. By acknowledging this, you confirm that you possess sufficient knowledge and comprehensive understanding of the English language. The Platform, along with its features and information, will be available in English as the default language. However, you may have the option to choose another language for the Platform, its features, and information. It is crucial to note that you should only select an alternative language if you possess adequate knowledge and a complete understanding of that particular language. If you decide to opt for another language, you do so entirely at your own risk.
2. You provide consent for us to communicate with you through our Platform or any system operated by FTD Limited that we offer you periodically. These communications may occur via email, by posting information on our website, or through other methods agreed upon in writing. Additionally, you authorize us to contact you via letter, telephone, SMS, or email to discuss matters regarding your Account or to notify you of any operational changes to our Platform. Please be aware that we may record all such communications.

• If the Agreement specifies the need for written communication from you, you have the option to send us an email from the email address linked to your Account to…………….., contact us through our Application (if applicable), or send us a letter by postal mail.

Margin Arrangements: You agree to transfer to us such sums by way of margin (“Margin”) as determined pursuant to Annex 2 (Margining). Margin requirements may be set and varied from time to time at our discretion without prior notice to you including without limitation subsequent variation of any Margin rates set at the time that a Transaction is opened.

10.2.     Form of Margin: Unless otherwise agreed, Margin must be paid in cash. The currency of the cash Margin you pay to us shall be the currency of the relevant underlying Transaction (if applicable) or as we may in our discretion reasonably decide from time to time. As specified in Section 10.1 (Title Transfer of Funds), cash Margin is paid to us as an outright transfer of title, and you will not retain any interest in it. Cash Margin received by us will be recorded by us as a cash repayment obligation owed by us to you. You are always required to maintain in your Account sufficient Funds to meet all Margin requirements.

10.3.     Margin Call: We are not under an obligation to keep you informed of your Account balance and the Margin required as it is your responsibility to monitor any shortfalls. However, we may at any time notify you, that unless you deposit into your Account(s) such additional Margin to meet our Margin requirements, we may liquidate any or all Open Positions without further notice to you (“Margin Call”).

Once issued, you must immediately comply in full of the Margin Call by way of cleared, same day funds regardless of any currency value fluctuations and irrespective of any recovery in the market value of the subject Open Positions. You may not increase or establish any new Open Positions while any Margin Call remains unsatisfied. Notwithstanding the aforementioned, we are not obliged to make any Margin Call to you or within any specific time period.

10.4.     If you receive a Margin Call from us, it may be made at any time by telephone, telephone answering machine message, voice mail, letter, email, FTD Online Systems and/or External Platforms or any other means of electronic communication. Therefore, you must notify us immediately and provide alternate contact details to ensure that Margin Calls can be made if you will not be contactable at your usual contact details provided. Where we do make a Margin Call to you, in no way does this waive our rights to liquidate your Transactions as stipulated in Sections 10.6 and 10.7.

10.5.     Margin does not represent the total extent of your financial liability to us as you are liable for all losses in respect of any Transaction and any other costs or payments due under this Agreement. Furthermore, you acknowledge and agree that any waiver of Margin or failure to make a Margin Call cannot be relied upon, or treated as, an act, omission, or representation as to the current value of any of your Open Positions with us.

10.6.     Close-out: In the event there is insufficient Margin on your Account or if the deposited Margin is not sufficient to satisfy the required Margin, as determined by us and in accordance with Section 10.1 (Margin Arrangements), we may at our sole discretion choose to close or terminate any or all your Open Positions immediately without notice to you.

10.7.     As specified in Section 11.1 (Specified Events) and without prejudice to our rights pursuant to Section 10.3 (Margin Call) and Section 10.6 (Close-out) to liquidate, close or terminate your Open Positions immediately without notice:

10.7.1.    your failure to comply with a Margin Call will constitute a Specified Event after the expiry of the applicable grace period; and/or

10.7.2.    the entry into any Transaction with you which results in there being insufficient Margin to cover any actual or anticipated losses or liabilities in connection with your Account will constitute a Specified Event and we may at our discretion exercise our right in Section 11.1 (Specified Events), regardless of whether or not there has been a Margin Call.

10.8.     Non-Cash Margin: Where we agree to accept non-cash collateral, it must be in a form acceptable to us. The value of the non-cash collateral and the proportion of that value to be considered for Margin purposes shall be determined by us in our absolute discretion.

10.9.     Set-off on Default: If there is a Specified Event or this Agreement terminates, we may set-off the balance of cash Margin owed by us to you against your obligations (as reasonably valued by us) to us or to any of our Associates.

10.10.  Security Interest: As a continuing security for the performance of the Secured Obligations under or pursuant to this Agreement, you grant to us, with full title guarantee, a first fixed security interest in all non-cash Margin now or in the future provided by you to us or to our order or under our direction or control or that of a Market or otherwise standing to the credit of your Account under this Agreement or otherwise held by us or our Associates or our nominees on your behalf.

10.11.  Further Assurance: You agree to execute such further documents and to take such further steps as we may reasonably require perfecting our Security Interest over, be registered as owner of or obtain legal title to the Margin, secure further the Secured Obligations, enable us to exercise our rights or to satisfy any Market requirements.

10.12.  Substitution: You may not withdraw or substitute any property subject to our Security Interest without our consent.

10.13.  Negative Pledge: You undertake neither to create nor to have outstanding any Security Interest whatsoever, nor to agree to assign or transfer, any of the cash or non-cash Margin transferred to us, except a lien routinely imposed on all securities in a clearing system in which such securities may be held.

10.14.  Power to Charge: You agree that we may, to the extent that any of the Margin constitutes “financial collateral” and this Agreement and your obligations hereunder constitute a “security financial collateral arrangement” (in each case as defined in, and for the purposes of, the Financial Collateral Arrangements (No. 2) Regulations 2003 (SI 2003 No. 3226)) (the “Regulations”), free of any adverse interest of yours or any other person, grant a security interest over margin provided by you to cover any of our obligations to an intermediate broker or Market, including obligations owed by virtue of the positions held by us or another of our customers.

10.15.  Power of Sale: If a Specified Event occurs, we may exercise the power to sell all or part of the Margin. The restrictions contained in Sections 93 and 10 of the Law of Property Act 1925 shall not apply to this Agreement or to any exercise by us of our rights to consolidate mortgages or our power of sale. We shall be entitled to apply the proceeds of sale or other disposal in paying the costs of such sale or other disposal towards satisfaction of the Secured Obligations.

10.16.  Power of Appropriation: To the extent that any of the Margin constitutes “financial collateral” and this Agreement and your obligations hereunder constitute a “security financial collateral arrangement” under the Regulations, we shall have the right to appropriate all or any part of such financial collateral in or towards discharge of the Secured Obligations. For this purpose, you agree that the value of such financial collateral so appropriated shall be the amount of the Margin, together with any accrued but un-posted interest, at the time the right of the appropriation is exercised. The parties further agree that the method of valuation provided for in this Agreement shall constitute a commercially reasonable method of valuation for the purpose of the Regulations.

10.17.  General Lien: In addition, and without prejudice to any rights to which we may be entitled under this Agreement or any Applicable Regulations, we shall have a general lien on all property held by us or our Associates or our nominees on your behalf until the satisfaction of the Secured Obligations.

Specified Event

In case a Specified Event happens, is likely to happen, or we become aware of it, we reserve the right to take a Reserved Action, subject to it being fair and reasonable in the circumstances (see clause 8.3 and 10.3). A Specified Event includes situations such as (not limited):

1. You or any authorized person appointed by you are found guilty or at fault in any criminal proceedings or relevant investigation carried out by the appropriate authorities in any jurisdiction, involving dishonesty, financial crime, terrorist financing, or a similar offense.
2. You are subjected to an Insolvency Event.
3. You are an individual who dies, becomes of unsound mind, or your capacity relevant to the Agreement is impaired in any way.
4. You breach any term of the Agreement, including but not limited to Improper Use.
5. You fail to make any payment due to us under the Agreement or any other agreement in place between you and us or our associates.
6. Any of the declarations and assurances provided by you pursuant to clause 8.1 and 8.2 of these Terms become incorrect or misleading in any material respect, as determined by us.
7. An Error occurs.
8. Any other circumstance exists where we reasonably believe that it is necessary or desirable to protect you or us, including any breach or potential breach by you of Applicable Law or the Agreement or where you do not respond as reasonably required to any notice, communication or request for further information from us in relation to your Account.

Circumstances Outside Our Control

1. If any Circumstance Outside Our Control causes us to fail to perform our obligations under the Agreement, it will not be considered a breach of the Agreement.
2. If we determine that a Circumstance Outside Our Control exists, we will inform you of it as soon as reasonably practicable and in accordance with Applicable Law. We will make every effort to resume our provision of our Platform, services, and/or performance of our obligations under the Agreement as soon as reasonably possible. We may take an appropriate Reserved Action and/or take action in relation to any Pricing Error.

• Where we can resume providing our Platform, services, and/or performance of our other obligations under the Agreement following a Circumstance Outside Our Control:

1. The value of any Trade held immediately before the Circumstance Outside Our Control that remains open will be determined by the Price as at the time we can resume our provision of our Platform and/or services.
2. We may act on any instructions to transmit any Order in relation to a Product received immediately before the Circumstance Outside Our Control, provided it is possible to do so.
3. You are responsible for reinstating or cancelling any Orders affected by a Circumstance Outside Our Control.

Reserved Actions

                  i.       In the event that it is required by Applicable Law, or if there is a Specified Event or Circumstance Outside Our Control that has occurred or is reasonably expected to occur, or if we have valid reasons to do so, we reserve the right to take any action that is deemed fair and reasonable under the circumstances. These actions, referred to as Reserved Actions, may include:

1. Opening, combining, correcting, or closing any Trade, closing Countdowns, canceling or suspending any Orders on an Account.
2. Prohibiting your access to or usage of an Account.
3. Suspending, limiting, or restricting your ability to place Orders, any Trade or Countdowns, or declining to execute any instructions received from you regarding an Account.
4. Refusing or delaying the processing of your withdrawal request for funds from your Account.
5. Modifying Margins, spreads between Buy and Sell Prices for a Product, Attributes, Prices, and Rates, including those relevant to your Trades and/or Orders.
6. Canceling any Trades or Countdowns (as if they had never been initiated) and its impact on your Account.
7. Conducting Roll-Overs.
8. Imposing special terms for any Order, Trade, or Countdown that we consider abnormal based on the relevant Product’s size, volatility, or liquidity.
9. Closing an Account, designating an Account as unauthorized to trade, or setting an Account to reduce only.
10. Exercising rights of Set-Off, making Deductions or credits, or applying interest under the Agreement or Applicable Law.
11. Retaining any outstanding amounts owed by you to us or any of our Associates.
12. Temporarily suspending the generation and/or quotation of Prices and/or execution of Orders for any Product on our Platform.
13. Removing any Product from our Platform and/or restricting your ability to place any Trade or Countdowns on a specific Product within an Account.
14. If you have been classified as a Professional Customer or an Eligible Counterparty, completely restricting or removing any additional services from your Account, either temporarily or permanently.

Data Protection

1. This Agreement describes how we will handle any personal information you disclose to us, together with our Privacy and Security Policy, which is available on our website. You will be giving us personal information when you apply for an Account or communicate with us in any other way. This information may be kept in paper or electronic form. We understand the significance of handling this data correctly and appropriately in line with data protection laws as the data controller.
2. Data that can be used to identify you, such as your name, address, phone number, email, and financial information, is referred to as personal data. Information on a person’s ethnicity, political views, religious convictions, trade union membership, health, and sexual preferences is referred to as sensitive personal data.

• In order to perform this Agreement, to comply with legal requirements, or when we have a legitimate interest, we may only process your personal data with your consent. Sensitive personal data will only be processed when one of the requirements outlined in data protection laws is satisfied.

1. Upon completion of the application and entering into the Agreement, you provide your consent to us for processing your personal data (including sensitive personal data), which we will use for various purposes such as assessing your application, administration of the Platform, administering the relationship between you and us, carrying out our obligations under the Agreement, assessing our operational and financial risk to you, improving the Website and/or Platform and developing our products and services, providing third-party market data or similar information to you, seeking legal advice, dealing with auditors and other professional advisers, creating anonymized statistical data, Customer profiling (including but not limited to targeting advertisements and creating lookalike audiences), and disclosing your personal data to any authority as required by law.
2. We reserve the right to share your personal information with our associates, subcontractors, and service providers who handle your personal data on our behalf, as well as any joint account holders, authorized persons, introducing brokers, money managers, or other third-party intermediaries that we have mutually agreed to and accepted. We may also use your personal information for marketing purposes following your preferences; for the aforementioned reasons, we may transfer, store, and process your information. In each case, we will ensure that your information is handled securely and in accordance with this Agreement and applicable data protection laws.
3. You have the right to seek access to the information we have about you, and where permitted by law, we may charge a fee for this service. Additionally, we reserve the right to document any correspondence you have with us, including emails, chat messages, and phone calls. These recordings may be utilized for training, complaint investigations, or as proof in court cases. All phone conversations will be recorded and kept on file for the time frame required by law. If needed by law, we may also provide government entities with your information, including personal information that is shielded by data protection laws. Finally, you agree to maintain the privacy of any information pertaining to your account, including emails, letters, and promotions.

Intellectual Property

1. All Elements are wholly owned by us or our licensors. You have no rights, titles, or interests in our Platform, Website, or Elements unless otherwise stated in the Agreement.
2. By the terms of the Agreement, we do provide you with a personal, non-exclusive, non-commercial, revocable, and non-transferable license to access and use our platform and website. There are no additional rights you may have in connection with our platform or website. We may immediately terminate this license and the Agreement without further notice, and you will no longer have any rights to our Platform, Website, or Elements if we determine that you have violated any of the prohibited actions listed in clause 11.2(iii) or if we have good reason to believe that you have done so.

• According to the Agreement, you are strictly prohibited from engaging in various actions concerning our Platform, Website, and the Elements, unless expressly allowed. Specifically, you must not copy, reproduce, modify, reverse engineer, distribute, sell, make commercial use of, or develop a hyperlink or other weblink to our Platform or Website without our written consent. You must also refrain from downloading or copying any account information other than for personal use or when required by an official body, and must not use any data collection tools, software viruses, or other similar technologies that may harm or disable our Platform or any of the Elements. Additionally, you must not attempt to gain unauthorized access to our Platform or any of its servers or engage in any activity that we may consider improper use.

1. Any breach of these conditions may lead to immediate termination of the Agreement, and we reserve the right to take further action. Furthermore, we may conduct an audit of your use of market data and other information provided on the Platform to ensure compliance with the Agreement, and you are required to cooperate fully with us in this regard.

Outsourcing

1. External service providers may be used for company operations, including Associates or third parties, in accordance with applicable laws.

Validity

1. If any provision of the Agreement becomes illegal, invalid, or unenforceable under the law of any jurisdiction, all other provisions of the Agreement will remain valid and enforceable.

Transfer or delegation of rights and obligations

1. You may not transfer your rights or delegate your obligations under the Agreement without our prior written consent. You may not grant any use or benefit of any right to any person (including an Authorised Person or Joint Account Holder)
2. Under the Agreement, you are not allowed to grant anyone (including an authorized person) the use or benefit of any rights, including the right to money held by the company (whether by mortgage, charge, or otherwise).

• In accordance with Applicable Law, we have the option to transfer or delegate any of our rights and/or obligations under the Agreement to another party, including the transfer of any Customer money balance held on your behalf. We will make reasonable efforts to provide you with a notice period of at least thirty (30) calendar days before such transfer or delegation takes place. However, we reserve the right to carry out the transfer or delegation immediately, in which case we will notify you as soon as reasonably possible. When we transfer or delegate our rights or obligations to another party, we may share with them any relevant information about you that they may reasonably require.

Rights, Remedies, Delay or Inaction

1. The rights and remedies available under the Agreement are in addition to those provided by applicable laws.
2. Delay or failure to exercise a particular right or action under the Agreement or applicable laws does not prevent the right from being exercised later.

• Except for Associates, third parties are not entitled to enforce any terms of the Agreement, but the company’s claims against the customer can be assigned to third parties.

Governing Law and Dispute Resolution

1. The Agreement is governed by the laws of British Virgin Island that any disputes arising from it are subject to the jurisdiction of the courts of British Virgin Islands but the company may take legal action in other jurisdictions if permitted by applicable laws.

14. Unless we have agreed otherwise, any amendments to the Agreement that we notify you of will take effect on the date mentioned in our notice, which will be no later than ten (10) Business Days after we provide the notice to you. Nevertheless, if the changes are required to comply with Applicable Law or if you have explicitly consented to the changes in writing at our request, we may provide you fewer than ten (10) Business Days’ notice. If you do not agree to the modifications, you may close your Account and/or terminate the Agreement in accordance with article 14.2 before the modifications become effective.

Breaching of the Agreement

1. Any breach of these conditions may lead to immediate termination of the Agreement, and we reserve the right to take further action. Furthermore, we may conduct an audit of your use of market data and other information provided on the Platform to ensure compliance with the Agreement, and you are required to cooperate fully with us in this regard.

Closing your Account or terminating the Agreement

1. If you are a Retail Customer, you can close your Account through our Platform or by giving us written notice through the predetermined communication channels. The closure will usually take effect within one (1) Business Day after we receive the notice. If you are a Professional Customer, you can close your Account by giving us written notice, provided that we haven’t given you notice designating an Early Termination Date. The closure will usually take effect within one (1) Business Day after we receive the notice. If you don’t cancel any Pending Orders, close any position regarding any Product on the Account, or withdraw any money due to you before giving us the notice of termination, we will cancel any Pending Orders and close any position regarding any Product as soon as possible after we receive your notice. Then, we will attempt to return any money due to you, but there may be a delay in doing so.
2. We may close your Account by giving you written notice. Unless specified otherwise in the notice, the closure will take effect on the date specified in the notice, which will be no less than ten (10) Business Days after the date of the notice. If you receive notice of closure, you will have time to cancel any Pending Orders and/or close any Trades before the Account is due to close. If you don’t do this or it’s not possible to give you notice, we will cancel any Pending Orders and close any Trades on the Account. Then, we will attempt to return any money due to you.

• We may terminate the Agreement with less than ten (10) Business Days’ notice, including immediately, if we have serious grounds or valid reasons for doing so. If this happens, we will cancel any Pending Orders or set your Account to Reduce Only or Unauthorised to Trade and close any Trades on the Account in the manner specified in the notice.

6. Unless we have agreed otherwise, the Agreement will automatically terminate when all of your Accounts are closed by you or us. When an Account or the Agreement is closed, we may exercise any right we have under clause 6.3 to make a Deduction or to Set-Off.

This Order Execution Policy is applicable to all of our retail and professional customers, without making a distinction on whether the customer is resident and/or regardless of where the transaction is executed.

The financial instruments we offer as FX Contracts, Commodities Contracts and CFDs are margin traded products that carry a high degree of risk. They are not suitable for everyone who does not understand the nature of the transaction and the possibility of losing invested capital.

FTD applies this Policy upon acceptance of Trades and Orders to obtain the best result for the customer. We will act as a Matched Principal or as an Agent when executing the customer trades.

We offer trading services for our customers with access to prices displayed on our trading platforms. Customers decide to deal at the prices displayed and responsible for achieving their own Best Execution.

FTD will pass customer orders to a third party (which may be a Liquidity Provider or a Broker) to complete the order execution process. We have internal processes and procedures to review our choice of third-party Liquidity Providers and Brokers. FTD manages those Liquidity Providers to provide the best current price quotation for customer orders on a consistent basis.

FTD will take into consideration the Execution Factors when executing customer orders. In determining the relative importance of the Execution Factors, we will consider the following criterias listed below;

•  PRICE;

The best bid and ask prices that FTD displays in the trading platforms which we apply an algorithm to achieve our own market price. The underlying feed that we use may be from one source or exchange or from several Liquidity Providers.

• CUSTOMER CLASSIFICATION;

Categorizing the customer as a retail or professional. Professional customers may have different needs than retail customers.

• TYPE OF CUSTOMER ORDER;

The characteristics of the customer order, such as market, limit, stop, etc.

• TIME OF SUBMISSION OF THE ORDER;

All orders are executed at the prevailing price(s) at the time the order is received by FTD price server.

•  SPEED;

The time it takes to execute a customer transaction. The speed of customer internet connection and the performance of trading platforms may have an impact on execution time.

• TYPE OF FINANCIAL INSTRUMENT;

The type of instruments available on our platforms may change from time to time but the main products we offer are FX pairs, CFDs, Metals and Commodities. An instrument from one of these product groups will be the subject of customer order.

•  LIKELIHOOD OF EXECUTION;

All trades, Orders and margin closeouts are executed on an automated basis. As long as the customer has sufficient margin available on his/her account for the trade and so long as the trade size requested is equal to or under the maximum size permissible, customer trade will be executed at the level requested depending on liquidity in the particular market.

•  LIQUIDITY OF THE MARKET;

The depth of market customer receive from us will depend on the liquidity offered to us by Execution Venues at the time that the transaction is executed.

•  LIQUIDITY PROVIDERS TO WHICH CUSTOMER ORDERS CAN BE DIRECTED;

The characteristics of the Liquidity Provider.

• COSTS;

The transaction charges relating to execution.

•  SIZE OF THE ORDER;

The size of the transaction which can affect the price of execution. If the requested trade size is larger than FTD is able to fill in the “trading venues” then our execution methodology may differ from the way we execute a standard order.

•  PRICE LIMITS AND RESTRICTIONS;

As a part of the customer order acceptance process, we may apply a number of automatic controls, such as price check, limits on counterparty exposure, credit checks, availability of currency pairs, and other controls.

• OTHER RELEVANT CIRCUMSTANCES (AS APPLICABLE);

Any special objectives customer may have in relation to the execution of the order.

FTD executes orders on behalf of the customers either by acting as an agent or matched principal trading. We act as an agent for the customer either explicitly or implicitly. We receive an order from the customer and then work in the market on a matched principal basis.

‘Matched principal trading’ means a transaction where FTD interpose itself between the buyer and the seller to the transaction in such a way that the Company is never exposed to market risk throughout the execution of the transaction, with both sides executed simultaneously, and where the transaction is concluded at a price where the Company makes no profit or loss, other than a previously disclosed commission, fee or charge for the transaction.

When FTD executes orders on behalf of the customers, we deploy procedures and arrangements which provide for the prompt, fair and expeditious of the customer orders and will be prioritized in accordance with the time of their reception by FTD order management (Bridge) technology.

Where accessing markets electronically, FTD’s routing decisions, including those processed within our algorithms, are made by our Bridge technology. Orders which are routed through FTD’s bridge are managed by FTD algorithms, are considered agency trades and best execution will be provided accordingly. The primary objective of the FTD Bridge is to achieve the best possible outcome for our customers. FTD’s interactions with execution venues are guided by objectively observed and calculated parameters. The execution decision as to which order books, price levels or participation sizes to target will be taken based upon both the explicit instructions accompanying the relevant order from the customer and the Bridge’s programmed parameters. The FTD Bridge may break the customer orders into multiple “child orders” and send them to one or many execution venues, either in parallel or in sequence. Best execution obligations will be applicable to the child orders as well as on the overall original customer order.

FTD trading technology allows the customers to reach deep liquidity pools by using MT5 trading platform. Main order types of the trading platform are as follows;

MARKET ORDER

Market orders will be executed at the best market price of the liquidity providers once the order reaches the electronic trading system where it will be executed at the FTD technology. Thus, it may slip between the price that you see in the terminal and the price of execution. Moreover, such slippage can also be in your favour. Since the system can provide you with high liquidity, this slippage, under normal conditions, either does not exist at all or is immaterial. Under low liquidity or explosive volatility conditions, the slippage is generally higher than on a quiet market.

STOP ORDER

Once the price reaches the stop order level in the trading platform, a request for an order execution would be transmitted via the bridge to the trading system, where the order would be executed at the best market price of the liquidity providers at the moment the order reaches the system. Thus, in case of stop orders, as well as in case of execution of market orders, slippage between the stop price and price of an execution may occur.

LIMIT ORDER

Once the price reaches the limit order level in the trading platform, a request for the order execution is transmitted via the bridge to the trading system. Please note that a partial execution of the order is possible. Obviously, customers are likely to encounter partial execution only when dealing with the large volume transactions. Also, please note that if you use a limit order facility, you will never get a price worse than the one that was stated in your order. Customer will either get his/her order executed at the requested price or at a better price.

Customer orders are executed at the prevailing prices at the time the order is received by our price server. We may cancel or change the price of your executed order where technical problems with our trading platform or similar circumstances occur beyond our control and are unrelated to market price movements. Furthermore, as we exclusively utilize straight-through order processing (STP), we may cancel or adjust the price of your executed order where we entered into an identical but opposite transaction with a counterparty (creating an offsetting position for us),and this counterparty cancels or adjusts the price at which their order was executed with us.

We do not re-quote prices, nor does our pricing system have detrimental asymmetrical slippage parameters. It is designed to ensure that any slippage is based on real market conditions only.

FTD executes orders in Financial Instruments, we may use one or more of the following execution venues to enable us to obtain the best possible result on a consistent basis when executing an order on the customer’s behalf:

• Third-party brokers who may interact with us in a principal or agency capacity, including investment firms, market makers & liquidity providers, direct electronic access providers, or equivalent entities performing similar functio
• Regulated Market
• Other exchanges that are not Regulated Market
• Internal sources of liquidity (matching customer orders).

FTD regularly and independently review the execution venues in order to provide our customers with an additional and independent monitoring process to help ensure that we are taking all sufficient steps to deliver the best possible result for our customers.

The execution venues used by FTD Limited include the following;

• CFH Clearing Limited;
• Sucden Financial Limited;
• LMAX Limited;
• Swissquote Group Holding Limited; and
• Gain Capit

Our commitment to providing you with a competitive execution price does not mean that we owe you any additional responsibilities in respect of order execution over and above the specific regulatory obligations placed upon us or as may be otherwise contracted between us.

FTD will regularly monitor compliance and effectiveness of the Policy for relevant order execution arrangements to assess whether it enables us to continuously provide the best possible result for our customers. We will provide the details in relation to our execution practices via our website in accordance with the applicable regulation. If necessary, we will amend our policy and order execution arrangements. We will notify you in advance of any material changes.

Please note that this policy applies to all financial instruments offered by FTD. We are committed to acting honestly, fairly and professionally in accordance with the best interests of our customers in relation to all the business we conduct.

FTD Limited’s objective is to provide our customers with the greatest in value and customer service and to maximize their financial markets trading experience. Notwithstanding these objectives, the Company places legal and regulatory compliance above profits. In our business conduct, we must always be in compliance with applicable laws and regulations.

FTD Limited is authorized and regulated by the BVI Financial Services Commission.

Integrity

FTD Limited realizes that our success is based on the Company’s reputation for integrity along with the public trust and confidence. We respect the interests of our customers; we will honour our obligations, and are straightforward in promising only what we can deliver.

Honesty

FTD Limited requires that a person must not engage in dishonest conduct or conduct which is misleading or deceptive. FTD Limited believes that the truthfulness and honesty does not stem merely from the regulatory compliance; rather, it is due to our philosophy of increased customer protection. Accurate and complete information enables investors to make intelligent decisions and, therefore, our statements are designed not to confuse or mislead.

Fairness

FTD Limited is dedicated to treating those with whom we deal in the same manner that we expect to be treated by others. We apply this approach in a consistent, non-discriminatory manner; from our largest institutional investors to our smallest account holders.

We compete in persistence of our overall interests, yet we do so fairly, ethically, and in a manner that fully complies with all applicable laws, as well as the values and principles stated in this Code.

We endeavour to deal fairly with our customers, service providers, other firms, and individual colleagues. We oppose taking unfair advantage of anyone through any form of manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair practice.

Responsibility

To our customers, we are dedicated to providing our products and services in an effective and innovative manner consistent with their needs, and we offer a trading environment that is fast, reliable, convenient, and valuable in terms of price and quality. We maintain adequate financial resources, including capital resources as appropriate, taking into account the nature, scale, complexity and diversity of our business and the risks we face. To our staff, we offer challenging positions in a professional and collegial environment and equal opportunities for performance-based professional development. To our service providers, we seek to build mutually beneficial relationships, while promoting the Code’s principles in the process. To our governing authorities, we strive to strictly observe and comply with all relevant laws, and standards of good business practice. We do not sacrifice legal compliance for the sake of profits; rather, we offer the authorities our cooperation and assistance toward the shared goal of investor protection. We are dedicated to remaining a responsible, law-abiding corporate member of society.

Regulatory Compliance

FTD Limited is licensed by the Financial Services Commissions (“FSC”) in the British Virgin Islands. FTD Limited acknowledges the importance of all relevant laws, rules, regulations, policies and standards, whether internal or external. We are dedicated to strict management discipline and a first-class control and compliance environment.

Due Diligence

FTD Limited conducts due diligence so that we can know our customers, and conduct our transactions pursuant to all applicable laws. FTD Limited has adopted a Know Your Customer Policy, which documents our procedures on how we obtain, verify, and record the information of every individual who opens an account with FTD Limited. All employees are required to comply with the Know Your Customer policies and procedures.

Communication

It is our policy that the information in our communications should be full, fair, accurate, timely, and understandable. This policy applies to communications with government authorities, staff, and customers. All staff involved in our disclosure process (including upper-level management) are responsible for complying with this policy. In particular, these individuals are required to maintain familiarity with applicable disclosure requirements, and they are prohibited from knowingly misrepresenting, neglecting, or causing others to misrepresent or neglect, material facts to others, whether within or outside the Company, including our independent auditors.

Books & Records

All transactions and obligations on our customer accounts are recorded in a complete, accurate, and timely manner. We maintain systems of internal accounting controls designed to ensure the reliability and adequacy of our customer account records, and the reports they generate. We retain records for the requisite period mandated by laws and regulations.

Audits

FTD Limited is dedicated to an independent, strong internal and external audit process to supplement our operational processes. Regular audits help FTD Limited identify and address any relevant accounting, internal accounting controls, or auditing issues that may arise. FTD Limited’s managers cooperate fully with our auditors to reach and implement solutions in an efficient and timely manner.

Confidentiality

FTD Limited maintains appropriate instruments to control and monitor the transfer of confidential and sensitive information within and outside the Company. We do not deliberately disclose non-public information concerning our business, our customers or our staff, unless it is in connection to the delivery of services to our customers, upon request of our customers, or as required by law.

Transparency

FTD Limited endeavours to maintain an open and transparent dialogue with our customers and others, based on fairness, mutual respect, and professionalism.

Data Protection

Data protection is the fair and proper use of information about people. It’s part of the fundamental right to privacy. Collection, storage, use, holding, processing, transmission, provision, disclosure, deletion and transfer of Personal Data of customers and other relevant persons are regulated by the Data Protection and Privacy Policy of the Company.

FTD Limited ensures that in line with the provisions of The Data Protection Act, 2021 (the DPA) our customers’ information is

• used fairly, lawfully and transparently
• used for specified, explicit purposes
• used in a way that is adequate, relevant and limited to only what is necessary
• accurate and, where necessary, kept up to date
• kept for no longer than is necessary
• handled in a way that ensures appropriate security, including protection against unlawful or unauthorized processing, access, loss, destruction or damage.

Protecting our customers’ personal data and privacy is one of our company’s priorities. All company employees are aware of the need to process and protect their customers’ data in line with the principles specified in the DPA and the Data Protection and Privacy Policy of the Company, and utmost care is given in this regard.

Cyber Security

Cyber security is defined as the collection of tools, policies, security concepts, security safeguards, guidelines, risk management approaches, actions, training, best practices, assurance, and technologies that can be used to protect FTD Limited’s information assets against internal and external cyber threats.

Users are only to utilize FTD Limited information resources for business purposes for which they have been authorized. Excessive use of FTD Limited information systems and resources for personal use or use on behalf of a third party (i.e., personal client, family member, political, religious, charitable, school, etc.) is prohibited.

All computer data created, received, or transmitted using FTD Limited’s information technology resources is the property of FTD Limited and is not to be considered the private information of the user. FTD Limited reserves the right to examine all data for any reason and without notice, such as when violations of this Code or other Company policies or procedures are suspected. By using FTD Limited information technology resources, the users consent to this monitoring. When warranted, such data will be disclosed to appropriate authorities and/or law enforcement agencies.

Risk Management

FTD Limited advises customers to engage in conscious, disciplined, and intelligent risk taking. FTD Limited’s risk management policies are guided by the principle of adherence to the appropriate legal frameworks as well as the instruments, procedures, and managerial approval processes we apply to monitor, control, and manage the risks to which we are exposed.

Anti-Bribery and Corruption

FTD Limited strictly prohibits any form of bribery, kickback, payoff and any other improper payment, gift, contribution, benefit or any other inducement having a similar corruptive effect, whether in cash (including cash equivalent, cashable items or financial instruments of any kind) or not.

Each FTD Limited staff is obliged to not request or accept for yourself or others whether directly or indirectly any gifts, enticement or inappropriate entertainment or a promise for providing lawful or unlawful service.

Our staff refrains from offering or giving or accepting for themself or others, directly or indirectly, any bribe, kickback, payoff or any other improper payment, gift, contribution, benefit, promise, or inducement in trying to obtain or retain business or secure services for FTD Limited or to illegally influence any governmental decision or action.

Our honest working policies forbid to solicit or receive, directly or indirectly, any payment, loan, extension of credit, guarantee, gift, object of any value or any kind of preferential treatment from a third party in exchange for favourable treatment or consideration with regards to a transaction or dealing or engagement of any kind with FTD Limited.

Any Staff become aware such situations, or suspect that an attempt at bribery, kickback or corruption is being made, we courage them to report it immediately.

Anti-Money Laundering and Counter-Terrorism Financing

Money laundering is the process by which persons or businesses attempt to conceal the origin and ownership of the proceeds of illegal activity such as fraud, drug trafficking, or and other crimes. Money laundering may also involve the use of legitimately derived funds to finance terrorism. Various financial products and transactions, including those related to the foreign exchange market, may be involved in money laundering schemes or financing terrorism. Accordingly, we are aggressive in ensuring FTD Limited is not used as a vehicle for such action. Money laundering and financing terrorism are criminal offenses and can subject its perpetrators and/or facilitators to substantial criminal and civil sanctions, including imprisonment and fines.

FTD Limited is committed to comply with sanctions programs issued by the United Nations, Office of Foreign Asset Control (OFAC) of the United States, Her Majesty’s Treasury of the United Kingdom, European Union, and sanction programs placed by the local authorities where FTD Limited operates. The Company prohibits dealings with any jurisdiction or party targeted by applicable international sanctions. Our staff is committed to prevent, detect and where applicable report any dealings with sanctioned persons.

To ensure compliance with anti-money laundering and counter-terrorism financing laws and regulations, FTD Limited has implemented policies and procedures to detect, prevent, and report money laundering and other suspicious activity.

Staff Excellence & Equal Opportunity

FTD Limited targets to create and maintain a professional atmosphere designed to attract, develop, and retain outstanding people. We offer equal opportunities, irrespective of race, national origin, ancestry, gender, sexual orientation, religion, age, physical disability, medical condition, or pregnancy. We will not tolerate any form of unlawful discrimination, harassment, retaliation, or retribution.

Competitive Reward System

FTD Limited offers a performance-based culture, with a corresponding competitive reward system and periodic fair and objective evaluations that take into account personal contribution to our overall efforts, as well as adherence to the values and principles set forth in this Code. Our partners and managers maintain an open-door policy designed to give each and every staff easy access to management.

Violations

We assess whether violations of this Code have occurred and, if so, determine whether or not disciplinary measures should be taken against the violator and others involved in misconduct. Disciplinary measures may include, but are not limited to, counselling, oral or written reprimands, warnings, probation or suspension without pay, demotions, and reductions in compensation, termination of employment, restitution, and legal action.

We may waive application of the Code in certain limited situations. Any waivers of Code provisions may be granted only in extraordinary circumstances and only upon management review. An employee who believes that a waiver may be called for is instructed to discuss the matter with our Compliance Officer.

Compliance

Each FTD Limited staff is personally responsible to comply with all applicable laws, as well as the internal policies of FTD Limited, including the principles and values stated in this Code. These responsibilities include being familiar with the applicable laws, guidelines, manuals, and require the implementation of best business practices in accordance with their duties and performing them to the best of their capabilities.

Customer Focus

We actively endeavour to differentiate ourselves from other firms in the area of customer service. We expect and encourage our staff to foster a customer-focused approach, and to treat our customers with greatest courtesy, professionalism, and respect.

Teamwork

We expect our staff to embrace teamwork and to contribute their best efforts toward reaching common objectives.

Honesty

We expect our staff to act at all times in good faith, with due care, competence, honesty, credibility and diligence, and without any misrepresentation of material facts.

Confidentiality

During the course of their service, staff may be provided access to information regarding our customers, trade practices, systems, marketing or strategic plans, fees and revenues, and other knowledge considered proprietary by FTD Limited or our customers. staff are not allowed to disclose or use, either during or subsequent to their employment with FTD Limited, any such information they receive or develop, except for authorized business purposes or where legally mandated. This includes, but is not limited to, information stored on any computer system as well as proprietary software developed by FTD Limited.

Any staff who possess confidential information has a significant responsibility to keep that information confidential, and to disclose such information internally only on a need-to-know basis. staff must be discreet with confidential information and avoid communicating confidential matters in ways that are susceptible to interpretation or use by third parties.

Conflicts Of Interest

Personal conflicts of interest arise when staff face a choice between their personal interests (financial or otherwise) and those of the Company or customers. Conflicts of interest may call into question the Company’s integrity as a whole. Accordingly, a staff’s service to the Company may not be subordinated to personal gain or advantage. All employees are expected to act in the Company’s best interest. Any staff in a position where his or her objectivity may be questioned because of an individual interest or family or personal relationship should consult his or her supervisor or Compliance Officer. Similarly, any staff aware of a material transaction or relationship that could reasonably be expected to give rise to a personal conflict of interest should promptly discuss the matter with a supervisor and/or Compliance Officer.

Outside Employment

Employment and involvement in other activities outside the Company could interfere with an individual’s duties as an FTD Limited staff. Service by any staff as a director, trustee, or officer (paid, unpaid, elected, appointed, or otherwise) of any business other than FTD Limited requires written approval from the Compliance Officer. Unless given specific authorization, service by any staff on a board or in an advisory position with other firms in the financial market industry, and particularly with any of our customers, is forbidden.

REPORTING VIOLATIONS

All employees of the Company are encouraged to talk to their supervisors when in doubt about the best course of action in a particular situation. Any questions regarding the Code and its applicability may be directed to your supervisor or the Compliance Officer.

We encourage reporting of violations of laws, rules, regulations or the Code to be done directly to relevant supervisors and the Compliance Officer or, where appropriate, directly to higher levels of management. Reports by officers and staff may be made on a confidential, anonymous basis. In case of violations by directors, senior staff and officers, such reports should be made to the Compliance Officer.

All reports should be factual rather than speculative or conclusory, and should contain as much specific information as possible to allow for proper assessment. In addition, all reports should contain sufficient corroborating information to support the commencement of an investigation, including, for example, the names of individuals suspected of violations, the relevant facts of the violations, how the complainant became aware of the violations, any steps previously taken by the complainant, who may be harmed or affected by the violations, and, to the extent possible, an estimate of the misreporting or losses to the Company as a result of the violations.

The Company expressly prohibits retaliation against any director, officer or staff for reports made in good faith.

RELATIONSHIP WITH FINANCIAL SERVICES COMMISSION

On every step of our business, we endeavour to deal with the Commission in an open and cooperative manner. We encourage our employees to actively work with the Commission when necessary.

NOTIFICATION

I have read the FTD Limited’s Code of Conduct and understood it. I declare and promise that I will act in accordance with this code in all my transactions and business relations within the Company.

Employee’s Name Surname:…………………………….

Signature:

Position:…………………………….     

Date:…………………………….                                                                         

Cookies are small pieces of information stored by the website you visit on your device in order to allow you to perform certain functions on the website and to adjust the content of the website to your preference. They can store information on pages on which you have given key information ( e.g. when you provide a password), but only until you are requested and you agree to this information being stored. Cookies may be used to provide a more customized web browsing experience for website users on certain pages of the website; they are not used to identify the personal identity of anyone who only visits the website.

Session Cookies

These cookies are temporary cookies, because session cookies are deleted immediately after you close your browser, they are deleted. Session cookies are used to maintain the information that you give us while you are browsing through every page of our web site.

You may choose to decline session cookies through the privacy settings of your browser, but please remember that declining session cookies can effect your browsing experience negatively, especially if they are declined across all websites.

Analytical Cookies

Analytical cookies may include both temporary cookies and permanent cookies that we use to track how and for how long you use our website. Analytical cookies do not reveal any person-specific identity information, but they allow us to optimize how our content is delivered to you. Check the privacy settings of your browser to see if you can opt out of analytical cookies.

Functional Cookies

In order to deliver you a smooth experience through our website, functional cookies record your choices and save them for the next time you visit our website. For example functional cookies remember your language choice and every time you visit us. Check the urgent privacy settings of your browser on how to opt out of functional cookies.

Third Party Cookies

These are the cookies used by third parties, mostly by social media websites like Google+, Twitter or Facebook. Third party cookies enable us to provide you easy ways to share our content across your social media. You can disable the use of these cookies in the privacy settings of your browser, but please remember that this will deactivate all of the features mentioned above as well.

Our purpose of using cookies is to analyse how visitors use our website, as well as track and improve our website’s performance and function. By means of this we can quickly identify and fix any issues that may arise and provide a high quality customer experience. We can also improve our future advertising campaigns by tracking if you are

directed to our website from another website.

Cookies enable us to ensure the optimum functionality of our website and provide our content with respect to your personal preferences.

We respect your privacy and are committed to providing you with the information and tools you need to manage your cookies.

You can use your web browser’s settings to delete cookies at any time you want. You can also disable cookies from your web browser but as already mentioned above disabling cookies may impact the performance of our web sites’ and other web sites’ functioning.

As a regulated broker, we assure you that any personal information we collect, through any means, will not be shared with third-parties.

Please read our Privacy Policy for more detailed information on how we use your data. If you have further questions please do not hesitate to Contact us.

Trading foreign exchange on margin carries a high level of risk, and may not be suitable for all investors. The high
degree of leverage can work against you as well as for you. Before deciding to invest in foreign exchange you should
carefully consider your investment objectives, level of experience, and risk appetite.

Decisions to buy, sell, hold or trade in securities and other investments involve risk and are best made based on the
advice of qualified financial professionals. Any trading in securities or other investments involves a risk of substantial
losses. The practice of “Day Trading” involves particularly high risks and can cause you to lose substantial sums of
money. Before undertaking any trading program, you should consult a qualified financial professional. Please consider
carefully whether such trading is suitable for you in the light of your financial condition and ability to bear financial
risks.

Any fact, assessment, analysis, forecasts, opinion and other information (collectively “Information”) released by FTD
Limited whether provided on the FTD Limited’s website, on third party websites, in marketing materials, newsletters,
in individual e-mails and letters, individual conversations or in any other form of written or verbal communication
(collectively “Publications”) are provided for informational and/or marketing purposes only.

FTD Limited uses reasonable efforts to obtain information from reliable sources, but all Publications are provided on
an “as is” basis without representation or warranty of any kind. No information or opinion contained on this web site
should be taken as a solicitation or offer to buy or sell any currency, equity or other financial instruments or services.

FTD Limited disclaims liability towards any subscriber, customer, partner, supplier, counterparty and other recipients for:

• the accuracy of any market quotations,
• any delay, inaccuracy, error, interruption or omission in providing market quotations,
• any discontinuance of market quotations.

FTD Limited disclaims liability for any Publication not being complete, accurate, suitable and relevant for the recipient.

If a Publication becomes outdated the FTD Limited shall be under no obligation to:

• update the Publication,
• inform the recipients of a Publication,
• or perform any other action.

FTD Limited reserves the right at its sole discretion to withdraw or amend any Publication or Information provided at
any time without notice.

No information or opinion contained on FTD Limited’s website should be taken as a solicitation or offer to buy or
sell any currency, equity or other financial instruments or services.
Opinions expressed at FTD Limited’s website are those of the individual authors and do not necessarily represent
the opinion of FTD Limited or its management. FTD Limited has not verified the accuracy or basis-in-fact of
any claim or statement made by any independent author. Therefore, all Publications of the FTD Limited are,
unless otherwise specifically stated, intended for informational and/or marketing purposes only and should not
be construed as:

• business, financial, investment, hedging, legal, regulatory, tax or accounting advice,
• a recommendation or trading idea,
• any other type of encouragement to act, invest or divest in a particular manner

FTD Limited will not accept liability for any loss or damage, including without limitation to, any loss of profit,
which may arise directly or indirectly from use of or reliance on information contained on FTD Limited’s website

The FTD Limited’s Publications may be accessed worldwide. The Information provided in such Publications is
however only intended for use by recipients located in countries where such use does not constitute a violation of
applicable legislation or regulations. None of the products and services referred to in the Publications of the FTD
Limited are available to recipients residing in countries where the provision of such products and services would
constitute a violation of mandatory applicable legislation or regulations.

It is at your sole responsibility to comply with all applicable legislation or regulation.

Any use of the https://www.ftdsystem.com/ is subject to FTD Limited’s “Terms of Use” policy.

FTD Limited shall not be liable for any damage or injury arising out of any person’s or entity’s access to, or
inability to access, this web site. This limitation includes, but is not limited to;

• any damage to computer equipment and computer systems caused by virus,
• malware and any other harmful computer coding.

This Web site contains links to Web sites, which are not maintained by FTD Limited. Links to third-party Web
sites are provided for your convenience and information only. Third-party Web sites are not under FTD Limited’s
control and we are not responsible for the content or accuracy of those sites or the products or services offered
on or through those sites. The inclusion of a link in this Web site does not imply FTD Limited’s endorsement of the
third-party Web site.

When applying for an account with FTD Limited, each applicant will be subject to the relevant set of business
terms. All applicants and customers are deemed to have read and understood the terms and conditions and
related policies applicable to them and their relationship with the FTD Limited.

In order to prevent conflict of interest, FTD Limited has established appropriate business procedures and a
conflict of interest policy. FTD Limited shall take all reasonable measures for the identification, management,
prevention and/or disclosure any conflict of interest within its organization, with its Customers and between its
Customers, to avoid conflict of interest from adversely affecting the Customers’ interests.

If the FTD Limited at any time and for any reason, should become liable for the loss of any person and/or entity,
including without limitation, if any provision of this disclaimer is, or at any time becomes to any extent or in any
circumstances invalid, illegal or unenforceable for any reason, the liability of the FTD Limited shall be limited
to such person’s and/or entity’s duly documented direct loss, which for the avoidance of doubt, and without
limitation, shall not include damages for any incidental and consequential losses, damages for lost opportunity,
damages for lost profit, nominal damages, statutory damages, punitive damages, restitutionary or disgorgement
damages, damages for costs, including legal costs, and damages for any other indirect loss.

When signing up with us, FTD Limited will, for administrative, commercial and/or legal purposes, require and store
information about the user, including, but not limited to, name and address. Furthermore, the FTD Limited may
require some financial information as well as users’ e-mail address. Users’ e-mail addresses will not be passed on
to third parties, but may be used by the FTD Limited for the promotion of its products and services.
All personal data benefits from this full protection and will only be disclosed to third parties such as administrative
or judicial authorities if the FTD Limited is compelled to do so pursuant to the applicable law, or if the registered
has given its written consent to such disclosure. The registered may revoke such consent or modify its extent at
any time.

It is at your sole responsibility to maintain the confidentiality of your password. Contact us if you encounter or
hear about any suspicious activity related to the use of our services. FTD Limited will not be responsible for any
loss to you arising from unauthorized use of your data.

This disclaimer and any dispute arising from or in relation thereto, including disputes regarding its legality, validity,
binding effect (including adoption) and enforceability, shall be settled by the courts of BVI in accordance with and
subject exclusively to the laws of BVI. However, the FTD Limited reserves the right to initiate legal proceedings
wherever it deems fit.

FTD Limited is under the supervision of the British Virgin Islands Financial Services Commission.

Unless otherwise specified, the services provided to you through the web site are intended for your personal and non-commercial use.

• You undertake that you shall not use the Information in the web site for any unlawful or unauthorized purpose.
• The use and interpretation of the services requires skill and judgment, and you shall at all time exercise your own
judgement in the use of the services.
• You are responsible for all statements made and acts or omissions that occur while your user identification name
(or “User Name”) and passwords are being used. You are responsible for protecting and securing your User Name
and password from unauthorized use and disclosure. If you become aware of, or believe there has been, any breach
of security for any of your information stored on the FTD Limited’s website, such as the theft or unauthorized use of
your User Name, password, or any other information, you will notify FTD Limited immediately.
• The services and the software have been prepared for informational purposes only without regard to any particular
user’s investment objectives, financial situation, or means, and FTD Limited is not soliciting any action based upon
it. This material is not to be interpreted as a recommendation; or an offer to buy or sell; or the solicitation of an offer
to buy or sell any security, financial product, or instrument; or to participate in any particular trading strategy in any
jurisdiction in which such an offer or solicitation, or trading strategy would be illegal. Certain transactions, including
those involving complex financial instruments, give rise to substantial risk and are not suitable for all investors.
• Services made available or described may be discontinued or changed without notice and their associated costs,
charges, interest rates, volume or equity requirements may vary according to time, place and user qualifications and
may not be available in all locations or offered to all interested parties.
• You should not interpret any of the material contained herein as business, financial, investment, hedging, trading,
legal, regulatory, tax, or accounting advice.
• The web site and the services provided are not intended for distribution to, or use by, any person or entity in any
jurisdiction or country where such distribution or use would be contrary to local law or regulation

FTD Limited’s web sites may be unavailable, delayed, limited, slowed or otherwise unavailable at certain times.
In cases where access to FTD Limited’s website is unavailable, delayed or limited, instructions for transactions
and other matters may not be executed or may be executed in an inefficient manner and you may be unable to
access data on a timely basis. FTD Limited accepts no liability and you agree to hold FTD Limited harmless from
any loss, without limitation, that you may suffer as a result of the delay or inability to access the website or its
contents or associated services provided via the website.

The web site and all its components are protected by copyright law and international treaty provisions and may not be copied or imitated in whole or in part.

It is prohibited to use, store, reproduce, display, modify, sell, publish, transmit and distribute, or commercially
exploit the web site and the services without prior written permission of FTD Limited and/or any third-party
suppliers.

FTD Limited and/or any third-party suppliers reserve all rights to proprietary information (including, but not
limited to, all intellectual property rights such as; patents, trademarks, service marks, copyrights, database rights,
topography rights, industrial design, know-how, trade secrets, trade names, logos, designs, symbols, emblems,
insignia, slogans, drawings, plans and other identifying materials, in all forms whether or not registered or capable
of registration and any other rights relating to intellectual property in accordance with the applicable laws,)
relating to the Services.

The web site or associated services provided via the website and any content or software contained therein
or accessible therefrom are provided “as is” and “as available”. Except to the extent required by applicable law,
FTD Limited makes no representations or warranties of any kind regarding: (a) the up-to-dateness, accuracy,
timeliness or completeness of any information contained within or available through the use of the web site
or the services, including but not limited to any currency exchange rates; (b) the results obtained from the use
of the web site or services ; and (c) any information provided by third parties and accessible on or through the
use of the web site or services. Except to the extent required by applicable law, FTD Limited: (a) disclaims any
express or implied warranties and conditions, including without limitation, any warranties as to non-infringement,
merchantability or fitness for a particular purpose; and (b) does not warrant that the web site or the services or
any content therein will be uninterrupted or error free, or that defects will be corrected.

The use of the web site and the services is at your own risk, and you assume full responsibility and risk of
loss you may suffer as a result of using or accessing the web site or the services or downloading any content
thereon. Except to the extent that liability under any applicable law or regulation cannot be excluded, under no
circumstances shall FTD Limited or its officers, directors, employees, agents, vendors, suppliers or distributors be
liable to you or any third party for:

(a) loss or damage of any kind whatsoever arising as a result of information
or prices (including without limitation currency exchange information) published on or furnished through the
web site or the services or any errors or omissions of web site or the services;

(b) loss or damage of any kind
whatsoever arising from orders, investment decisions or purchases of third party goods or services (including
financial instruments and currency) based on information published on or furnished through the web site or
services;

(c) any indirect, special, incidental, punitive or consequential loss or damages; or

(d) any other similar
damages under any theory of liability (whether in contract, tort, strict liability or any other theory), that are
directly or indirectly attributable to the use of, or the inability to use, the web site, the services or any content
contained thereon, even if FTD Limited has been informed of the possibility there of. If you are dissatisfied with
any services, or any portion of the web site, or with any of these terms of use, your sole and exclusive remedy is
to discontinue use of the web site and the services.

The information contained on the FTD Limited’s web site and the services has no regard to the specific investment
objective, financial situation or particular needs of any specific beneficiary. FTD Limited does not endorse
or recommend any particular securities, currencies, or other financial products to its customers. The content
published on the web site and the services is solely for informational purposes and is not to be understood as
solicitation or any offer to buy or sell any spot currency transactions, financial instruments or other securities.

You agree to indemnify and hold FTD Limited, its subsidiaries, affiliates, suppliers, directors, officers and
employees, harmless from any claim, demand, or damage, including reasonable attorneys’ fees, asserted by any
third party or arising out of your use of, or conduct on, the web site or the services.

These Terms and Conditions shall be subject to any other agreements you have entered into with FTD Limited.
Any claims arising from this Agreement will be governed by and interpreted in accordance with the laws of British
Virgin Islands (BVI) and shall be subject to the exclusive jurisdiction of the BVI Courts.

• Information About Us. FTD Limited is a global online trading broker, whose registered office is at Kingston Chambers, PO Box 173, Road Town, Tortola, British Virgin Islands, and incorporated under the laws of the British Virgin Islands as a BVI Business Company with registration number 1944994, licensed and regulated by the BVI Financial Services Commission (FSC) under Investment Business License number SIBA/L/19/1123.

• Our Services. Subject to the terms and conditions of this Customer Agreement and acceptance of your application to open an Account with us, we will maintain one or more Accounts in your name and will provide execution-only brokerage services for spot Transactions in the international over-the-counter foreign exchange markets and effect Rolling Spot Forex Transactions, Commodity and CFD Transactions and provide brokerage services for Transactions in such other products as we may, in our sole discretion, determine from time to time in the future. Unless expressly stated otherwise in writing, all contracts and Transactions entered into between us shall be governed by the terms of this Customer Agreement, as amended from time to time.

• Our Capacity. We will deal with you as an agent, but we may also act as principal if we deem it necessary.

• Your Capacity. You will enter into Transactions as principal unless otherwise agreed in writing by us.

• Language of Communications. You may communicate with us in English. All FTD Limited standard documents will be available in English. If a document is translated into another language this will be for information purposes only and the English version will prevail.

• Commencement. By signing the Account Opening Application Form, you confirm that you have read, understood, and agree to be bound by this Customer Agreement. This Agreement shall not be deemed commenced or become a binding contract between the Customer and FTD Limited until we have approved the signed Account Opening Application Form. The Customer Agreement will take effect and begin on the date on which the Customer receives notification from us that they have been accepted as our customer.

• If you are an individual acting for purposes which are outside your business, trade or profession, you have a period of 14 calendar days from acceptance of this Customer Agreement to withdraw from this Customer Agreement without penalty and without giving any reason. This right of withdrawal shall not apply following any Transaction executed under this Customer Agreement which will thereafter remain binding upon you.

• We may amend this Customer Agreement by giving written notice to you by post or email. Each amendment will become effective on the date specified in the notice. Any amendment requested by you must be agreed in a formal amendment agreement by us. Unless expressly agreed otherwise, an amendment will not affect any outstanding Order or Transaction or any legal rights or obligations which may already have arisen. If you do not wish to accept any amendment made by us you may by notice to us close any of your open Transactions and your Account in accordance with this Customer Agreement.

• Duty to You. Nothing in this Customer Agreement purports to exclude or restrict any duty or liability owed by us to you under the Securities and Investment Business Act, 2010 or FSC Rules under which we are not permitted to exclude or restrict. If there is any conflict between this Customer Agreement and the FSC Rules, the FSC Rules will prevail.

• Duties and Responsibilities. We assume no greater responsibility or fiduciary duty than that imposed by the FSC Rules or the express terms of this Customer Agreement.

• All notices, instructions and other communications sent or given by us to you under or in connection with this Customer Agreement or any Transaction may be verbal or in writing and may be sent or given to your last known home address, place of work, telephone number (including by leaving messages on a telephone answering machine or voice mail system), e-mail address or other contact details.

• The language of communication shall be English, and you will receive documents and other information from us in English.

• All notices, instructions and other communications sent or given by you to FTD Limited under or in connection with this Customer Agreement or any Transaction must be sent or given in writing to our address specified on the cover page of this Customer Agreement (or any other address subsequently notified to you for such purpose), addressed to the attention of our Compliance Department.

• All telephone calls with you will be recorded to record your instructions, and for training and quality purposes. In the event of any dispute, the recording or transcript of our telephone conversation may be used as evidence.

• The customer must ensure that all information provided to us is accurate and up-to-date at all times. The customer must tell us of any changes by calling us, updating details in our Secure Website, or emailing us, as soon as practicable, and in any event within 7 (seven) days of the change. If this obligation is not fulfilled, this may impact the services that we can offer you, for example, we will continue to send messages to the registered email address of the customer which may result the customer to miss out on notifications.

• Where notice in writing is required under this Agreement, it may be sent by email. Email is deemed to be received when it was sent provided no message of non-delivery was received by the sender.

• When the Customer enters into this Agreement and each time the Customer places an order for a Transaction, enters into a Transaction or gives any other instruction, the Customer represents and warrants to FTD Limited that:

• if Customer is a natural person (Retail Customer),

• the Customer is of sound mind and memory, over eighteen (18) years of age, not disabled and able of having legal responsibility to the full extent under the applicable laws of his residing country;
• performance of this Agreement shall by no means result in breach of legal requirements applicable to the Customer, and of any other current obligations of the Customer to any third parties;
• performance of this Agreement shall by no means result in breach of orders of any decision of the competent court or administrative authority which is binding and valid in relation to the Customer;

• if the Customer is a corporate entity (legal entity):

• the Customer is properly incorporated and legally exists under the applicable laws of its registration country;
• performance of this Agreement shall by no means result in breach of legal requirements applicable to the Customer, and of any other current obligations of the Customer to any third parties;
• performance of this Agreement shall by no means result in breach of orders of any decision of the competent court or administrative authority which is binding and valid in relation to the Customer;
• if applicable, the Customer obtained all necessary corporate approvals related to conclusion and performance of this Agreement in a proper manner, as set out in the corporate rules and procedures accepted by the Customer;
• in performing this Agreement any party committing any other acts related to performance of this Agreement on behalf of the Customer is duly authorized by the latter to commit such acts and has no implied (implicit) limitations.

• All information and documents provided by the Customer to FTD Limited  in respect of financial position, domicile or other matters is true accurate and complete and not misleading in all material respects and the Customer shall immediately notify FTD Limited of any material change thereto;
• The customer acts as principal and sole beneficial owner (but not as trustee) in entering into this Agreement and each Transaction;
• The Customer understands and accepts that he is responsible for obtaining his own advice as to his own tax position and as to the suitability of any Transaction in light of his investment objectives and experience.

• The Customer is the full ultimate beneficial owner of all money deposited in the Account and no other person has or will have any interest in the Account. The Customer acknowledges and accepts that it cannot and will not grant any security interest in or over the Account to any third party;

• All funds deposited in the Account originate from lawful sources and are not the proceeds of any illegal or criminal activity under the laws of any applicable jurisdiction;

• The Customer is prepared and able, financially and otherwise, to assume the risk of loss inherent in trading in spot forex and CFD Transactions;

• The Customer has not and will not upload or transmit any Malicious Code to our Trading Platform or Website or otherwise use any electronic device, software, algorithm, and/or any dealing method or strategy that aims to manipulate any aspect of our Trading Platform or Website, including, but not limited to, the way in which we construct, provide or convey our price; and the Customer will use the Products and services offered by us pursuant to this Agreement honestly, fairly and in good faith.

• Customer is not now an employee of any exchange, any corporation in which any exchange owns a majority of the capital stock, any member of any exchange and/or firm registered on any exchange or any bank, trust, or insurance company, and in the event that Customer becomes so employed, customer will promptly notify us, in writing, of such employment.

• This Agreement covers the entire scope of services provided by FTD Limited including, but not limited to, use of the Website and downloadable material, trading services, data collection and storage, financial information published on the Website by FTD Limited or any affiliated party, electronic content, real-time information about the prices of Contracts, tools for executing trades in Contracts, social network applications, blogs, forums, and such other services FTD Limited may, in its sole discretion, make available to its Customers (collectively, “Services”). Subject to the terms and conditions of this Agreement and acceptance of Customer’s Application to open an Account with FTD Limited, FTD Limited will maintain one or more Accounts in Customer’s name and will make available multiple electronic trading interfaces (platforms) and end-to-end systems to Customer and will provide Services to Customer in connection with the purchase and sale of non-deliverable spot foreign exchange currency contracts and Contracts for Difference (collectively, “Contracts”), and such other products and Services as FTD Limited may, in its sole discretion, determine from time to time in the future. Unless expressly stated otherwise in writing, all Contracts and other transactions entered into between FTD Limited and Customer shall be governed by the terms of this Customer Agreement, as amended from time to time, including the FTD Limited Trading Policies and Procedures.

• FTD Limited has direct and/or indirect third party relationships with various liquidity providers, prime brokers, counterparties, market makers, trading principals, depositories, clearing systems and/or other intermediaries necessary in making the Services available to you (“Service Providers”). You understand and agree that FTD Limited may, without notice and in its sole discretion and as it deems appropriate, restrict your use of the Services in whole or in part and may place limits on such Services made available to you including, but not limited to, refusing to accept and/or transmit an order for its execution. You agree to use the Services only in accordance with the terms and conditions of the Agreement. You acknowledge and agree that FTD Limited is acting as an agent in the Transactions, -but FTD Limited may also act as principal if it is deemed necessary- as the case may be, that are the subject of this Agreement and, further, that FTD Limited and/or its Service Providers may deal simultaneously with other customers, parties, principals and counterparties regarding orders placed by and/or transmitted or executed for and on your behalf and that price quotes provided to you and at which Transactions are executed may vary from Customer to Customer. You understand and agree that executable prices made available by FTD Limited in spot Forex pairs, spot precious metals contracts and CFDs are not fixed and will fluctuate based on global market movement. You acknowledge that a Transaction may not be able to be executed in whole or in part or executed at a particular price or time and you expressly agree that neither FTD Limited nor our affiliates or Service Providers will have any liability with respect thereto.

• You further understand and agree that FTD Limited may refuse to accept an order, impose limits on your trading such as position size, number of open positions, margin requirements, leverage, trade size, and specific contracts traded. You further understand and agree that all Transactions are cash settled and that FTD Limited does not offer credit to you for any Transaction(s) without a specific written undertaking to that effect.

• You understand and agree that notwithstanding Retail Customer, Professional Customer and/or Eligible Counterparty account classification and standard account transactional settings for such classifications, FTD Limited may adjust, your leverage limits, liquidation levels, margin requirements and ticket (trade) sizes as mandated by its regulator (BVI Financial Services Commission “FSC”) and license conditions and/or as it deems appropriate from time to time based on, among other factors without exclusion, your trading style, Instruments traded, account equity levels, available liquidity and market volatility. FTD Limited will make commercially reasonable efforts to notify you prior to making such adjustments; however, FTD Limited reserves the right to exercise its right to make such adjustments without prior notice when FTD Limited, in our sole judgment, deem it necessary.

• The required documentation for opening an Account may be found on FTD Limited’s website: www.ftdsystem.com. You agree to inform us of any material changes in your personal information provided to us in connection with opening your Account as soon as you become aware of the changes. Should you not know whether a change is “material,” you agree to contact our compliance department for clarification by sending a query to compliance@ftdsystem.com.

• FTD Limited may refuse to open or keep open your Account in our sole discretion, without having to give reasons, including in (but not limited to) circumstances where, in our opinion, opening and/or maintaining the Account may result in a breach of any applicable rule, regulation or law; or any information and/or documents received in connection with the account are inadequate, insufficient, incomplete, not valid or effective, or contradictory.

• When providing any component of the Service, as further set forth below, involving the receipt of and/or transmission of orders or otherwise providing a benefit to you, FTD Limited determines whether the Services are appropriate for you based on information you provide FTD Limited or is otherwise provided to or obtained by FTD Limited, regarding your trading/investment knowledge and experience. Should FTD Limited determine that the Services are not appropriate for you, FTD Limited will warn you (this may be done by means of the Additional Risk Disclosure Statement). In case you do not provide the requested information, or you provide insufficient information, FTD Limited will advise you that your decision will not permit us to assess whether the Services are appropriate for you and, subsequently, FTD Limited may only provide the Services if and when you submit a specific written request for the Services in the format determined by FTD Limited. If you are classified as a Professional Customer, we will assume that you have the requisite experience and knowledge to understand and appreciate the risks involved in relation to the Transactions and Instruments for which you are classified as a Professional Customer.

• Upon acceptance of your account application, FTD Limited will open and maintain your Account for the purpose of entering into Contracts, engaging in Transactions and providing such other Services as provided for in this Agreement.

• We may accept, in our discretion, to open and operate one or more sub-accounts linked to your main account if requested in the manner determined by FTD Limited from time to time. Such additional sub-accounts will be subject to and operated according to the provisions of this Agreement. In the event that you request the opening of one or more sub-accounts linked to your main account, we will require you to complete a sub-account opening form. Upon its completion and submission to us and subsequent approval by our company, your sub-account will be established and made available for your use. We will treat each sub-account separately so your positions will not be netted across all your sub-accounts.

• In the event when there are fixed losses in the form of negative balance on one of your Accounts (or several of your Accounts) the Company shall unilaterally be entitled to compensate such losses at the cost of your positive balance Accounts. You acknowledge that FTD Limited may, in its sole discretion, limit the number of Accounts that you may open, hold, maintain or acquire, and accordingly close such additional Account(s) at our discretion and without further notice to you.

• You may fund your Account/s in accordance with this Agreement, and as explained in the Account approval notice or on FTD Limited’s website.

• You can transfer money to the account you have opened in our company through bank accounts as well as via cryptocurrenies. Likewise, you can make withdrawals from your account via cryptocurrency. However, in order to make transactions via cryptocurrency, the digital wallet you use must belong to you and you are allowed to use a maximum of two separate digital wallets. We remind you that if we detect any inconvenience regarding the use of cryptocurrency, we will immediately report suspicious transactions to the relevant authorities and therefore we will no longer provide services to you.

• FTD Limited will make available to you executable prices at which you may buy or sell Contracts. Prices quoted are subject to confirmation by us. We will exercise all due care and skill in the preparation of the on-screen price but, due to the nature and speed of movements in the Market, technological failures, communication delays, interruptions and breakdowns, lack of liquidity, extreme market volatility and other issues, the price indicated may not necessarily be the exact price available to open or close a trade. We will not be liable for any losses or costs which you may incur as a result of not being able to open or close a Trade at a particular on-screen price, unless as a result of our fraud or wilful default.

• We do not warrant that executable prices and liquidity will be available on a continuous basis either electronically, via the telephone or by any other means of communication.

• For the avoidance of doubt, when receiving and/or transmitting your order FTD Limited will be dealing as your agent, but FTD Limited may also act as principal if it is deemed necessary.

• You agree that FTD Limited is not liable for any loss or damage caused, directly or indirectly, by any events, actions or omissions beyond the reasonable control of FTD Limited, including, without limitation, loss or damage resulting, directly or indirectly, from delays or inaccuracies in the transmission of orders and/or information due to a breakdown or fault in or failure of any transmission or communication facilities or software interfaces and/or hardware systems. You agree that all orders, including but not limited to market orders, limit orders, stop orders, OCO orders and all other orders or instructions, transmitted and accepted by FTD Limited, are accepted and undertaken on a “best efforts basis.” You acknowledge and agree that if as a result of market conditions or other circumstances, FTD Limited and/or the Service Providers are unable to respectively transmit and/or execute your order at market or a specified level that neither we nor the Service Providers will bear any liability for failure to execute such orders. Orders placed over a weekend or holiday period when FTD Limited is closed will be executed by the Service Providers on a “best-efforts basis” when the market opens. Your further understand and agree that execution may not be immediate or at the price dictated by the opening level due to imbalances in orders, market conditions, market liquidity, gaps or other circumstances. FTD Limited shall have no responsibility or liability for delays in the transmission of orders due to disruption, market conditions, failure or malfunction of communications facilities and shall not be liable for any claims, losses, damages, costs or expenses, including lawyers’ fees, to any person or entity as a result thereof.

• FTD Limited undertakes to get the best possible result for you in all your Transactions, taking into consideration all matters relevant to and affecting execution, pursuant to the BVI FSC best execution regulations. However, if received, we will transmit your order based on your specific instructions. You acknowledge that your specific instructions may prevent FTD Limited from following the protocols designed to secure for you via the Service Providers the best execution in terms of price, fees, time of execution, execution venue, partial execution fills and other operational parameters that may affect the execution of your specific order. Your order may be aggregated with other customer orders and that may negatively affect the execution of your order. You agree that neither FTD Limited nor the Service Providers are liable for any negative affect on such order such as wire transfers for deposits/withdrawals.

• You agree to promptly reimburse us for any such expenses and you hereby irrevocably and unconditionally authorize us to withdraw any reimbursements payable and due to us or a Service Provider from Your Funds and to perform such acts as may be required in order to ensure such deductions or withdrawals can be effected. All such deductions will appear on your Account statement. We may, in our sole discretion and option, waive any or all of these charges from time to time.

• You understand and agree that it is your responsibility to keep your Account(s) adequately margined and that FTD Limited is not required to and will not make a margin call on you if your margin approaches the liquidation level.

• You also understand and agree that FTD Limited has the right, but not the obligation, to liquidate all open positions in your Account if the Account is not adequately margined. FTD Limited also has the right, but not the obligation, in its sole determination, to liquidate positions beginning with the largest losing position and moving to the position with the smallest unrealized loss, in an effort to bring your remaining positions into fully margined status. Further, FTD Limited may change margin requirements and/or available leverage and liquidate all open positions when your margin is inadequate as a result of such change. Should FTD Limited make a margin call to you as a courtesy, you agree that such a courtesy call does not constitute a waiver of FTD Limited’s right to immediately liquidate all open positions in under-margined accounts or prejudice its rights in that regard or establish a course of dealing that mandates such courtesy calls will be made in the future.

• You understand and agree that you will monitor the margin level in your account and if you have questions regarding margin levels and how they affect your account that you will contact FTD Limited prior to trading.

• All copyright, trademark, trade secrets and other intellectual property rights in the Trading Systems shall remain at all times the sole and exclusive property of FTD Limited and/or its third party service providers and you shall have no right or interest in the Trading Systems or the information contained therein except for the right to access and use the Trading Systems as specified herein. You acknowledge that the Trading Systems are confidential and have been developed through the expenditure of substantial skill, time, effort and money. You will protect the confidentiality of FTD Limited and/or its third party service providers by allowing access to the Trading Systems only by its employees and agents on a need to access basis. You will not publish, distribute, or otherwise make available to third parties any information derived from or relating to the Trading Systems.

• The Company shall not disseminate information related to its Customers. The Company shall also disclose information on the Customers to nobody other than its employees, agents and/or partners to the extent necessary for supporting business relations including bank and credit relations.

• The Company shall reserve the vested right to disclose information on the Customers or Transactions made by them to regulatory and/or law-enforcement authorities of the British Virgin Islands (regulating jurisdiction).

• Disclosure of information to authorities specified in paragraph 10.3 of this Agreement shall be performed only upon requests of the relevant authorities based on decisions of courts of the British Virgin Islands unless otherwise expressly provided for in laws of the British Virgin Islands.

• Conflicts of interest between you and us (including our directors, officers, managers, employees and any affiliates) and/or between you and other FTD Limited customers may arise from time to time in connection with the Services. These conflicts may arise from our relationships with, among others, the Service Providers or other third parties we use to provide the Services or with Introducing Brokers. For instance, various individuals may serve as directors, managers, officers or shareholders of these other companies. FTD Limited will take every commercially reasonable step to comport itself in line with applicable regulations and to prevent conflicts of interest from negatively affecting your interest. If we identify a conflict of interest with you we will undertake measures to keep any such conflict from negatively affecting your interest and when identified, such conflicts will be disclosed to you prior to our taking any actions that would negatively affect you.

• For further details, please refer to ANNEX IV of this Agreement – “Conflicts of Interest Policy” or feel free to contact our Compliance Department at compliance@ftdsystem.com

• By opening an Account with us and by placing orders and entering into transactions, you acknowledge that you will be providing personal information to us within the meaning of the Data Protection Act 2021 of the British Virgin Islands. You agree and consent that we can process, collect, use, and disclose the Personal Information for the purposes and in the manner as set out in our Data Protection and Privacy Policy. By entering into this Agreement, you acknowledge that you have read and understood our Data Protection and Privacy Policy which is accessible on FTD Limited Website.

• We will process as much personal data as necessary to provide the Services and as we may be obligated to or authorized to pursuant to applicable regulations, including but not limited to compliance with our licence conditions and with applicable prevention of money laundering and funding of terrorism legislation.

• You agree that, in the course of providing you with the services contemplated under this Agreement, FTD Limited may need to disclose some or all of your personal data, whether sensitive or otherwise, to and be processed by persons we authorize, including employees, investment institutions, Referral Agents/ Introducing Brokers, Trading Agents and their or our duly authorized agents and affiliates wherever located (including outside the BVI).

• You can request us to delete or destroy your personal data, to correct the wrong information held by us, and you can withdraw your consent for the processing of your personal information. However, we would like to remind you that in that case, we may not be able to provide the services we offer to you.

• General Exclusion: Neither we nor our directors, officers, employees, or agents shall be liable for any losses, damages, costs or expenses, whether arising out of negligence, breach of contract, misrepresentation or otherwise, incurred or suffered by you under this Agreement (including any Transaction or where we have declined to enter into a proposed Transaction) unless such loss is a reasonably foreseeable consequence or arises directly from our or their respective gross negligence, wilful default or fraud. In no circumstance, shall we have liability for losses suffered by you or any third party for any special or consequential damage, loss of profits, loss of goodwill or loss of business opportunity arising under or in connection with this Agreement, whether arising out of negligence, breach of contract, misrepresentation or otherwise.

• Tax implications: Without limitation, we do not accept liability for any adverse tax implications of any Transaction whatsoever.

• Changes in the market: Without limitation, we do not accept any liability by reason of any delay or change in market conditions before any particular Transaction is effected.

• Indemnity: You shall pay to us such sums as we may from time to time require in or towards satisfaction of any debit balance on any of your accounts with us and, on a full indemnity basis, any losses, liabilities, costs or expenses (including legal fees), taxes, imposts and levies which we may incur or be subjected to with respect to any of your accounts or any Transaction or any matching Transaction on a Market or with an intermediate broker or as a result of any misrepresentation by you or any violation by you of your obligations under this Agreement (including any Transaction) or by the enforcement of our rights.

• You use the Trading Platform at your own risk and FTD Limited is not liable for any use of the Trading Platform. The Trading Platform and its content are provided “as is” and FTD Limited does not represent the functionality or suitability of the Trading Platform for Customer, or that it will be interrupted or error free.

• Limitation of Liability: We shall not be liable to you for any partial or non-performance of our obligations hereunder by reason of any cause beyond our reasonable control, including without limitation any breakdown, delay, malfunction or failure of transmission, communication or computer facilities, industrial action, act of terrorism, act of God, acts and regulations of any governmental or supra national bodies or authorities or the failure by the relevant intermediate broker or agent or principal of our custodian, sub-custodian, dealer, Market, clearing house or regulatory or self-regulatory organisation, for any reason, to perform its obligations. Nothing in this Agreement will exclude or restrict any duty or liability we may have to you under the regulatory system (as defined in the FSC Rules), which may not be excluded or restricted thereunder.

• If more than one natural person enters this Customer Agreement as the Customer, all such natural persons agree to be jointly and severally liable for the obligations assumed in this Agreement.

• If this Agreement is entered into on behalf of a corporation, limited liability company, trust, partnership, unincorporated association or other non-natural person as the Customer, you as the authorized agent and the Customer hereby agree to jointly and severally indemnify, defend, save and hold us harmless for any losses, claims, costs, damages and expenses resulting directly or indirectly from breach of any fiduciary or similar duty or alleged breach thereof.

• If this Account(s) is held by more than one person, natural or non-natural, all of the joint holders are jointly and severally liable to us for any and all obligations arising out of Transactions in the Account and agree to be bound by all terms and conditions of this Agreement. You authorize us to accept Instructions without enquiry, and to send confirmations, notifications, documents and other information to any one of the joint holders. Each joint Account holder hereby further appoints the other joint holders as agent for any and all matters relating to or arising out of the joint Account, including but not limited to the receipt of confirmations, notifications, documents and other information and hereby waives all rights to receive the same otherwise. Any one or more of the joint holders has full authority for the joint account and risk in the said joint Account, including authority to: (i) trade for the Account; (ii) receive all correspondence, notices, documents and other information in respect of the Services; (iii) receive or withdraw funds from the Account; and (iv) execute Agreements and other documents relating to the Services.

• Customer understands, acknowledges and agrees that FTD Limited may amend or change this Agreement at any time. FTD Limited will provide notice to Customer of any such amendment or change by posting the amendment or change to the Website or by sending an e-mail message to Customer.

• In the event that Customer objects to any such change or amendment, Customer agrees to liquidate Customer’s Open Positions and instruct FTD Limited regarding the disposition of all assets in Customer’s Account within ten (10) Business Days after notice of the amendment or change has been posted to the Website or has been sent to Customer by e-mail. No waiver or amendment of this Agreement may be implied from any course of dealing between the parties or from any failure by FTD Limited or its agents to assert its rights under this Agreement on any occasion or series of occasions. No oral agreements or instructions to the contrary shall be recognized or enforceable.

• This Agreement is effective only after acceptance by FTD Limited (at our discretion) and will remain in full force and effect until either you or FTD Limited terminates it for cause or otherwise, by providing the non-terminating party with written notice.

• FTD Limited may, at our discretion, terminate the Agreement immediately without notice for cause or upon two (2) days written notice without cause. You agree to remain liable for any and all outstanding obligations, liquidated or un-liquidated, realized or unrealized after termination.

• This Agreement is not subject to a minimum duration and you have the right to terminate it, without incurring any penalty, by giving us two (2) days written notice via email to compliance@ftdsystem.com. You must indicate in your notice of withdrawal that you will close all open positions. FTD Limited accepts no liability, without limitation, for your failure to close your open positions.

• The termination of this Agreement will take effect on the date of the notice of termination given by either Party to the other Party, or a later date if one is specified in the notice (the “Termination Date”).

• Upon termination of the Agreement, you agree that we are entitled to receive all fees and other monies accrued and due up to and including the termination date. Without prejudice to any right or remedy that may be available to either of us in respect of the cause of termination, neither of us is entitled to compensation from the other solely by reason of the termination where the Agreement is terminated by the other Party in accordance with this Agreement.

• Upon termination (and not later than the Termination Date), you agree to cease using the Services (as further set forth below), to destroy all your Security Access Codes and pay any and all fees, expenses and liabilities due to us up to and including the Termination Date.

• Upon termination, we will liquidate all open positions; cancel all pending orders and any other commitments made by or on your behalf under this Agreement; and subject to appropriate set-off, return Your Funds to you.

• All representations, warranties, and covenants made in or pursuant to this Agreement will survive the termination of this Agreement.

• For the avoidance of doubt all clauses, terms and conditions of this Agreement which are expressly said or intended to apply or have effect and/or to continue to apply or have effect after the termination of this Agreement (for any reason whatsoever) will so apply or have effect or continue to apply or have effect after Termination. All indemnifications, representations, warranties and guarantees shall continue to have effect after the agreement is terminated.

• The Company has the right to suspend the Customer’s Trading Account at any time for any good reason with or without written notice to the Customer.
• In the event that a situation arises that is not covered under the Operative Agreements, the Company will resolve the matter on the basis of good faith and fairness and, where appropriate, by taking such action as is consistent with market practice.
• No single or partial exercise of, or failure or delay in exercising any right, power or remedy (under these  terms or at law) by the Company shall constitute a waiver by the Company of, or impair or preclude any  exercise or further exercise of, that or any other right, power or remedy arising under the Operative  Agreements or at law.
• Any liability of the Customer to the Company under the Operative Agreements may in whole or in part be  released, compounded, compromised or postponed by the Company in its absolute discretion without  affecting any rights in respect of that or any liability not so waived, released, compounded, compromised or  postponed. A waiver by the Company of a breach of any of the terms of the Operative Agreements or of a  default under these terms does not constitute a waiver of any other breach or default and shall not affect the  other terms. A waiver by the Company of a breach of any of the terms of the Operative Agreements or a  default under these terms will not prevent the Company from subsequently requiring compliance with the waived obligation.
• The rights and remedies provided to the Company under the Operative Agreements are cumulative and are not exclusive of any rights or remedies provided by law.
• If any term of the Operative Agreements (or any part of any term) shall be held by a court of competent jurisdiction to be unenforceable for any reason then such term shall, to that extent, be deemed severable and not form part of this Customer Agreement or the Terms of Business, but the enforceability of the remainder of Operative Agreements shall not be affected.

• The Customer may not assign, charge or otherwise transfer or purport to assign, charge or otherwise  transfer the Customer’s rights or obligations under the Operative Agreements without prior written consent  of the Company and any purported assignment, charge or transfer in violation of this term shall be void.

• This Agreement shall be interpreted and applied under the material and procedural law of the British Virgin Islands irrespective of the provisions of laws of other jurisdiction which can be involved in the course of performance of the Agreement.

• The Customer irrevocably

1. agrees that courts of the British Virgin Islands shall have the right to exclusive jurisdiction which determines any proceedings in relation to this Agreement;
2. submit to jurisdiction of courts of the British Virgin Islands;

• waives any objection in relation to legal proceedings in any of such courts;

1. agrees not to file claims that such legal proceedings are held in inconvenient forum or they are invalid in relation to the Customer;
2. Agrees that any decision of the court of the British Virgin Islands made in respect of this Agreement shall be final and binding for the Customer.

The accuracy of the statements you submit to us will be determined, and your application will be reviewed. Therefore, you acknowledge and agree that your account is not approved at the time this form is signed by you, and this agreement will become effective upon receiving notification from us that your account has been accepted.

Your signature in the Account Opening Application Form acknowledges that you have carefully read, in its entirety, and understood the Customer Agreement and its Annexes and that you agree to all of the provisions contained therein.

This Agreement warranties and certifies that the information provided by you in the Customer Account Application is correct and complete.

ANNEX 1. Terms of Business

ANNEX 2. Risk Disclosure Statement

ANNEX 3. The Order Execution Policy

ANNEX 4. The Customer Acceptance Policy

ANNEX 5. The Conflicts of Interest Policy

ANNEX 6. The Anti – Money Laundering (AML), Combating the Financing of   Terrorism (CFT) and Know-Your-Customer (KYC

ANNEX 7. Data Protection and Privacy Policy ,

ANNEX 8: Customer Privacy Notice