The financial services provided by this website carry a high level of
risk and can result in the loss of all of your funds. You should never
invest money that you cannot afford to lose. Please ensure you read our
terms and conditions before making any operation in our trading
platform. Under no circumstances the company has any liability to any
person or entity for any loss or damage cause by operations on this
website. Smart Trading FX nor its agents or partners are not registered and do
not provide any services on the USA territory.

The Website and Content may be available in multiple languages. The
English version is the original version and the only one binding on
Smart Trading FX; it shall prevail on any other version in case of
discrepancy. Smart Trading FX shall not be responsible for any erroneous,
inadequate, or misleading translations from the original version into
other languages.

Smart Trading FX as the Company, operated by Smart Trading FX – Via Ennio Quirino Visconti, 85, 00193 Roma RM, Italy ,
offers access to its web page and use related services by any
individual or corporate entity (hereinafter referred to as the Client)
according to the procedure and on the terms and conditions described in
this Agreement.

The Agreement becomes effective as of the date when the Client opened
a trading account and transferred funds to the Company”s account(s) to
ensure minimum trading deposit.

1. Payment Procedures

1.1. Client shall fund his trading account within 90 calendar days
from the date of its opening in an amount not less than define terms for
the type of account (minimum initial deposit).

1.2. The Company has the right to close/cancel an account with the
balance less than 1 cent (one-hundredth of a US dollar), if the above
account balance existed for more than 90 calendar days.

1.3. Client may request withdrawal of funds from his trading account
in the amount not used to cover the margin, but not more than current
balance, provided that all positions of the Client are closed, all sums
due to the Company have been paid.

1.4. Client places a funds withdrawal order using the Company
website”s interface. Company is not responsible for any third party
access to the Client personal information and withdrawal orders. Once an
order has been received, the withdrawal amount may be deducted from the
Client”s trading account.

1.5. In some cases, and considering that third parties, i.e., payment
service providers, are involved in funds transfer, e.g., payment
institutions, banks, card processing schemes etc., fund transfer
processing may take up to five banking days after receiving a Client”s
order. The security service of the company has the right to hold the
order up to 10 business days, previously having notified the Client.

1.6. The Client will be given the Company”s banking details to
transfer funds to his trading account via the Company”s website, or may
place an account funding order in electronic (placed using the Company
website”s interface) or written form.

1.7. When funding his account, the Client shall use the Company”s
current banking or electronic wallet details, received at the Company”s
website only and effective on the payment date. Current banking details
mean details received within 24 (twenty four) hours prior to payment.
The Company cannot be held responsible for the funds which the Client
transferred using banking details different from current, and does not
offer investigation and refund of Client”s payment and cannot credit
these funds to Client”s trading balance. Trading deposit funding orders
may be issued, and current banking details may be received in the
appropriate section of trader”s web entry on the payment day.

1.8. The Client agrees to pay Deposit/withdrawal fees, i.e., to pay
any banking or money transfer fees associated with any transfer,
settlement or movement of funds or assets on the Client”s behalf.

1.9.When the trading account balance is funded using online payment
systems, Client may order withdrawal only to the same payment system
which he has used to fund his trading account in the corresponding
currency or it’s equivalent. Trading profit may be withdrawn to any of
the payment systems (up to a Client”s wish).

1.10. When the trading account balance is funded using direct bank
transfer, funds will be credited within 1 working day (after the
transfer was actually credited to Company account). The minimum funding
amount is 5000 (EUR or USD). Clients who fund their account using direct
bank transfer may order withdrawal only to the account from which the
payment was done. An upfront bank transfer fee 50 USD will be applied
(for international bank transfer).

1.11. Company reserves the right to reject a request for withdrawal
in case of an explicit intention to exchange customer funds from one
payment system to another.

1.12. Account balance funding using a third person credit card is prohibited.

1.13. If case of funding by using Visa/Mastercard, withdrawals can be
done via bank transfer, or by using a specially issued Master card,
sent to client by ordered mail.

2. Customer and Company Responsibilities

2.1. Client is notified and agrees that the Company cannot be held
liable for Client”s actions or inactions during conversion operations.
Responsibility for trading account monitoring is the Client”s duty.

2.2. Company reserves the right to amend this Agreement notifying the
Client about it at least 2 business days prior to the effective date of
these amendments. Posting the relevant information on the main page of
the www.smarttradingfx.com website for the period of at least 3 days is also
considered as notification. The Client undertakes to consult and review
regularly the www.smarttradingfx.com website to be timely informed about
any changes in respect of this Agreement and the Services in particular.

2.3. All rights and obligations of the Company and the Client
represent a long-term commitment, which remains in force up until the
Company receives a Client”s notice of termination of this Agreement or
closing his trading account.

2.4. Company cannot be held responsible for non-fulfilment of any
obligations involving quality of online communication of information to
the Client terminal or use of information, software, and interfaces of
websites which do not belong to the Company.

2.5. Client realizes that any market recommendations and information
communicated to the Client by the Company, its representatives, or third
parties do not constitute as an offer to make operation/transaction.

2.6. Client realizes that

a) any payments which Client makes using the banking details received
earlier than 24 hours prior to the payment execution time or not at the
appropriate sections of the Company website, which differ from the
Company”s current banking details do not entail the Company”s liability
or obligations concerning investigation, refund or credit of this
payment to the Client”s trading balance.

b) any actions committed by the Client or third parties (by Client”s
fault or with Client”s participation), which destabilize the Company”s
business or performance of the Company”s services, equipment, or
software may result in the Company”s refusal (on the basis of private
law) of servicing the Client”s current trading account and cancellation
of all trading orders, with full refund of the remaining deposit.
Company must notify the Client about the reasons for the above decision.
Company also may reject such Client”s new registration in the future.

2.7. Persons under 18 years or under the age of majority, which is
legally allowed to participate in financial trading, can not use the
services of the Website.

2.8. The Client declares and guarantees that:

– he is sane,

– his age is minimum 18 years old,

– information which Client provided to the Company is true and correct,

– he shall notify the Company about any and all changes in this information within one day after the change took place,

– the e-mail address used by the Client is not in use by anyone else.
Any and all notices, requests, complaints, and information received
from this address are considered as sent by the Client.

2.9. Company may request from Client a confirmation of accuracy of
the personal account data for a due diligence and in the event of a
withdrawal request. Company may request a notarized copy of the Client”s
ID and the document proving his place of residence. Inability to
provide requested documents may result in the Company”s refusal (on the
basis of private law) of servicing the Client”s current trading account
and cancellation of all trading orders, with full refund of the
remaining deposit. Company must notify the Client about the reasons for
the above decision. Company also may reject such Client”s new
registration in the future.

2.10. Client agrees to provide all documents and notices, notarize
documents, and take all other actions which the Company may request in
accordance with the Anti Money Laundering Policy

2.11. In case of double registration of the same Client, the Company
has the right to cancel duplicated registrations, cancel opened
positions and withdrawal requests. All duplicated accounts will be
frozen for investigation purposes.

3. Customer risk notice

3.1. Client understands that the risk of suffering trading losses may
be quite significant. Client should analyze his financial capabilities
before engaging in trading operations.

3.2. Client realizes that he may completely lose his all initial funds and any additional funds used when trading on the market.

3.3. Client agrees that the company cannot be held responsible for
Client”s losses caused, directly or indirectly, by the government
restrictions, restrictions of foreign exchange or market rules,
suspension of trading, military operations, or other conditions usually
called the “force majeure circumstances” which lie beyond the company”s
control.

3.4. Client was informed about additional risks associated with the
specifics of functioning of e-trade systems and the problems of Internet
communication nodes.

3.5. Client bears full responsibility for the risks associated with
the storage of trading account access data, and must ensure that third
parties cannot access the trade terminals. Client”s losses and risks
associated with the restoration of access to the trading account imposes
no obligations on the Company, other than to provide new access data to
the Client after identification procedure.

4. Terms of transactions

4.1. Trade is executed at prices offered to the Client, which are shown in the window of Clients” trading terminal.

4.2. Company may decline the Clients” request to open a new position,
if the balance on his trading account is not sufficient to place a
minimal trade.

4.3. Company may suspend its operations or revise client”s trades for
the following reasons: failures on part of Internet access providers,
failures in information flows, hacker attacks, and other illegal actions
against the Company”s servers and equipment, force majeure
circumstances, and suspension of trading on financial markets which
concerns financial instruments used by the Company.

4.4. Company may revise (change) an executed trade upon discovery of
software malfunction within 5 trading sessions after malfunction was
discovered. In this case, Client will be provided by a market prices
history from at least 2 independent quotes sources.

4.5. The Company has the right to cancel Clients” trading orders and
reject service provision, if fraud attempts were done in order to make
profit using particularities of trading conditions and trading
equipment, including registrations in Smart Trading FX affiliate programs with
a purpose of getting an extra profit from trading activity, where
trading account holder and affiliate account holder is the same person,
or trading account and affiliate account is operated by the same person.

5. Disputes, complaints and inquiries

5.1. The parties will try to settle all disputes by negotiation. The
Company may accept Client”s complaints for review, if these complaints
were expressed in writing and received within three calendar days after
the dispute occurrence date.

5.2. Client”s inquiries will be considered as official and treated,
if these inquiries were placed and received by the Company via the
Company”s website interface, by e-mail sent to the addresses of the
Company”s corresponding services, or by regular mail. Inquiries placed
using online communication programs, such as Skype or similar, cannot be
considered as official.

5.3. The Company will review Client”s complaints within ten business
days after receiving from the Client all necessary and sufficient
information which concerns this complaint.

5.4. In the event of disagreements concerning Client”s operations or
the state of his trading account, the parties will review the protocols
of Client”s operations using Company”s data.

5.5. If the Client will breach any of the above paragraphs, the
Company reserves the right to restrict the Client access to its services
and make a refund of the Client”s available deposit. Termination of
service and refund of the deposit will come into effect upon expiration
of 5 banking days after the Client was sent a notice by e-mail provided
at the time of registration of trading account.

5.6. In case of failure to reach an agreement through negotiations
and correspondence within 3 (three) months from the date of the
initiation of a dispute its further consideration will be directed
towards the justifiability in accordance with the laws of the Republic
of Seychelles.

6. Know your customer

6.1. The Company has the right to request the customer to confirm his
identity and information provided upon registration. At any time Client
can be asked to provide an electronic copy, certified copy or notarized
copy of a passport (at the discretion of the Company).

6.2. If the Client has not received a request to provide the
documents, the procedure of enhanced verification is not mandatory, but
the Client can voluntarily send a copy of the passport or other proof of
identity.

6.3. In the case customer registration data (name, address or
telephone number) have changed, the customer shall immediately notify
the Company”s customer service asking to change the data.

6.4. All withdrawal requests should be processed to the same account, from where trading deposit was initially transferred.

6.5. Customer acknowledges that the registration data, referred to
him for opening an account can be used by the Company in the fight
against money laundering.

6.6. Customer is responsible for the authenticity of submitted
documents (copies) and recognizes the right of the Company, in case of
doubt about their authenticity, to contact authorities of the issuer of
the document to verify its authenticity and if it detects a
falsification of the document, Company has the right to place an account
on hold and conduct an investigation.

7. Communicating with Clients

7.1. The Company may communicate with the Client by using:

– E-mail address provided by the Client,

– Phone number provided by the Client,

– Postal address provided by the Client,

– Company Web site www.Smart Trading FX

The Company will use the details specified by the customer provided
upon registration. Client must immediately notify the Company of any
changes in contact information .

7.2. Any correspondence (documents, announcements, notifications,
confirmations, reports, etc.) will be considered as received by the
Client:

– after one hour after sending to Client”s e-mail address

– Immediately after sending the internal mail in the trading platform

– Immediately after the telephone conversation with the Client

– After one day after placing announcement in the Company Web site.

8. Termination of the agreement

8.1. Following agreement becomes effective as of its acceptance by the Client.

8.2. This agreement will be terminated if following occurs:

– In the case of expression of the wish by one of the parties to terminate this Agreement;

– In case of breach by the Client the terms specified in the
Agreement, the Company may terminate this Agreement unilaterally by
notifying the customer of such termination and returning to Client
remaining funds from his/her trading account at the time of termination.
Also, company reserves the rights to cancel all trading orders
previously done by the client.

8.3. If the Company terminates the activities under this Agreement:

– Company warns the Client one month prior to such termination;

– The Company pays the Client the Client”s funds, which are on the
account at the time of activity termination, as quickly as possible.

8.4. In case of death of the Client:

– The right to demand withdrawal of funds from the Client”s trading account transferred to the heirs;

– The right to use trading account and the right to conduct operations in the financial markets by heirs is not transmitted.

8.5. Customer agrees that the Company reserves the right at its sole
discretion, suspend or discontinue all or part of the Client”s access
the services by an appropriate notice by means of communication. In this
case, this Agreement shall be terminated and Company terminates
providing services to the Client.

9. Anti-Money Laundering Procedure

No person shall abuse this site for the purpose of money laundering.
Smart Trading FX may employ best-practice anti-money laundering (AML)
procedures. Smart Trading FX reserves the right to refuse to do business with,
to discontinue to do business with, and to reverse the transactions of,
clients who do not accept or conform to the following AML requirements
and policies:

� Clients must provide all requested information upon registration.

� Funds will only be paid to the individual who initially registered
to open a live account and specifically only to the originating credit
card or account on file

� When a client maintains an account by means of telegraphic
deposits, funds will only be distributed to the holder of the
originating bank account. When making deposits in this manner, it is the
responsibility of the client to ensure that the client”s account number
and registered name of the account owner accompany all transfers to
Smart Trading FX.

� When a client transfer funds to the account by means of
credit/debit card deposits, funds will only be distributed to the
individual whose name appears on the card used to make the deposit and
only be paid back to the same card.

� Only one account is allowed per person. No funds may be collected
on accounts opened in false names or on multiple accounts opened by the
same person.

� Smart Trading FX may, from time to time, at its sole discretion, require a
Client to provide additional proof of identity such as notarized copy
of passport or other means of identity verification as it deems required
under the circumstances and may at its sole discretion suspend an
account with cancelling of all previously done trading orders, until
such proof has been provided to its satisfaction.

Any suspicious or fraudulent transactions will be immediately reported to the relevant authorities.

10. Bonus Policy

Smart Trading FX offers a number of attractive reward features to its new
and subsisting clients. Bonuses and one time trading credits awarded to
clients are part of Smart Trading FX’s promotional programmes. These bonuses
are limited time offers and the terms and conditions associated with
bonus rewards are subject to change.

Smart Trading FX reserves the right to refuse, cancel or change the bonus
at any time without any prior notice. Any indication of fraud,
manipulation, cash-back arbitrage or other forms of deceitful or
fraudulent activity based on the provision of the bonus will render the
account inactive along with any and all profits or losses garnered.

Bonuses are optional and client is not required to take a bonus. During initial deposit, client may send a request to info@smarttradingfx.com to accept no bonus and therefore is exempt to any conditions pertaining
to bonuses, however the rest of the terms in this Agreement still
apply. Should client mistakenly accept a bonus, client must notify
customer support within 3 working days, and must place no trades. In
such an instance, Smart Trading FX will remove bonus from client account and
client shall not be held to the terms relating to bonuses, however all
terms and conditions will still apply.

When trading CFD, Bonus is used only as an additional margin for order volume increase, as a leverage and can”t be withdrawn.

11. Withdrawal Procedure and Fees

Smart Trading FX finance department handles all withdrawal requests
submitted. From the time the request is made, Smart Trading FX normally
process each withdrawal request within 1 hour. However, in case of
shortage of data on the client side, or delays on third-party side, the
processing time may be longer.

The Smart Trading FX finance team will determine the method of withdrawal.
Client cannot request to change a withdrawal method. All funds must be
returned to the source of the original deposit. However, in some cases,
this may not be possible (such as in cases where the original deposit
source was a MasterCard). Smart Trading FX’s finance department will venture
to find the optimalfastest method of processing of clients withdrawal.

Identification is required for all withdrawals, regardless of the
withdrawal amount. If the account is initially funded by credit or debit
card, or is at any point funded using a credit or debit card,
Smart Trading FX will require a copy of the front and back of the credit card
used, hiding sensitive authentication data, a government issued photo ID
(such as a driver’s license or passport) and a 3-months recent proof of
address (such a bank statement or utility bill), if needed. Mobile
phone bills and other general mail will not satisfy this requirement. If
the Smart Trading FX account has been funded using multiple credit or debit
cards, the Smart Trading FX finance department will require copies of all
cards used before a withdrawal is approved.

Notwithstanding the above, if the withdrawal amount and/or the
cumulative withdrawal amount, is or exceeds $1,800 or €1,800, no funds
shall be transferred until the client”s identity, and age have been
verified.

If the account is initially funded by wire transfer, or is at any
point funded by wire transfer, a copy of the bank statement from the
originating account showing the transfer will be required. Should the
name on the bank statement differ from the person named on the
Smart Trading FX account, further documentation showing the connection between
the user and the bank account will be required.

If the account is funded by an e-wallet (such as Qiwi), the client
will be required to submit a photo ID and proof of address (as described
above) where the address of the document submitted matches that on the
users account at Smart Trading FX.

When sending required documents, please follow these guidelines:

– Please always send colour copies, scans or photographs

– Please do not enlarge, shrink or otherwise manipulate the size of the subject matter

– When sending copies of cards, please conceal the middle 8 numbers
on the card. Please ensure the first and last four digits are visible.
Cards sent showing all digits will be deleted immediately.

– When sending bank statements, please ensure the name and address
information are visible, as well as the transfer sent to the company.
You should then conceal all other information.

If the withdrawal amount, or cumulative withdrawal amount on the
account, exceeds €1,800 or $1,800 (depending on account currency),
Smart Trading FX’s finance department will require certified copies of all
identification documents, regardless of whether uncertified copies have
previously been submitted.

Documents must be certified as true original copies by a notary public, or at the post office.

No withdrawals will be processed until such time as the Smart Trading FX
finance department has obtained all required identification and verified
their authenticity. Once identification has been obtained once (or in
the case of higher limit withdrawals, twice), ID will not need to be
provided again with the exception of if additional payment methods or
cards are used to fund the account, in which case copies of further
cards or bank statements will need to be provided.

Once the withdrawal has been approved, please allow an additional 5
to 6 working days for the funds to show in a client account. Please note
that larger withdrawal amounts may take additional time as they may be
subject to fraud checks by the processing and receiving banks. These
additional checks are not performed by, or at the request of, Smart Trading FX and we do not have control over this process.

Any withdrawal that must be completed by international wire transfer will be charged an upfront $50 transfer fee.

For funds, which were not active, i.e., with which Client has not
made 1x turnover, maintenance fee of 20% on each of the withdrawal
amounts apply, which shall be paid by the Client.

12. Deposits

In order to fund a trading account at Smart Trading FX, client can do so by
bank transfer, using an e-wallet (such as Qiwi) or by utilising one of
the following major credit or debit cards: Visa and MasterCard. Cash
deposits are strictly prohibited.

Smart Trading FX charges no fees to the client to deposit using any
approved deposit method, except deposits by Visa or Mastercard. Deposits
by Visa or Mastercard are subject to 5% commission.

Please also note that some card issuers may charge a fee to make a
deposit into your Smart Trading FX account. Please check the terms and
conditions of your card, or call your issuer directly, if you think your
issuer or bank may charge you a fee. Any charges issued by the bank or
issuer must be disputed directly with them, as Smart Trading FX has no say or
input on these fees.

Once a deposit request via bank transfer is submitted, it can take
Smart Trading FX up to 3 business days to process the request and verify the
funds have been received.

A deposit request via credit, debit card or via e-wallets into a
trading account will be processed within 3 hours. From time to time,
issuing banks may place security blocks on cards – clients may need to
call their bank to have these blocks removed.

The trader can impose self-deposit limits by contacting the Smart Trading FX support team via email info@smarttradingfx.com.

13. Fees and Charges

The amount that is displayed as client “Payout” is free from fees.
Accordingly, the “Payout” amount will be the exact amount credited into
your trading account.

Client may access all records of transactions on line at no charge.

There is no charge to open or maintain an account at Smart Trading FX.
However, if the client fails to transact at least one trade in any
calendar month, an account service fee of $10 per month will be levied.

In the case that no transaction has been recorded on a trader”s
account for twelve months, Smart Trading FX may remit the balance in that
account to the client.

In order for a client to claim funds from a dormant account, closed,
blocked or excluded account, one must contact Smart Trading FX by email.

Client expressly authorise Smart Trading FX to collect any account fees due
and owing pursuant to these terms and conditions by debiting the client
credit card on file, or by debited the client”s trading account.

14. “First 3 risk free trades” service

If the total of the first three transactions is negative, Smart Trading FX
will compensate the loss in the form of bonus and bonus rules will
apply. Compensation of risk free trades can not exceed the amount of
initial deposit. To use this service, you need to apply for it in
advance. Simply contact your account manager and negotiate details.

15. Cancellation Policy

Smart Trading FX reserves the right in its sole discretion, to refuse or
cancel services, and/or refuse to distribute profits to any person for
legitimate reasons, including, without limitation:

if Smart Trading FX has reason to believe that a person”s activities on the Site may be illegal;

if Smart Trading FX may be harmed by any fiscal or pecuniary damage due to anyone”s activities;

if Smart Trading FX consider that one or more operations on the Site were made in violation of this Agreement;

if client has failed to provide Smart Trading FX with the Know Your Client (KYC) documents.

Client can request cancellation of service at any time, in case if
there are no trading positions opened. If trading positions are opened,
client has to close it or wait till expiration . All withdrawal requests
has to be treated based on standard withdrawal conditions, described in
paragraph 1.

Terminology

Trade – purchase of the CFD.

CFD – object of trade based on a change in a price of an asset in a specified period of time.

Financial instruments – available for trading CFD types as currencies, indexes, stocks, commodities.

Opened position – purchased CFD under influence of a market risk.

DueDiligence – set of procedures to identify the Client and verify his personal information.

Equity – current account state, calculated by formula: balance + floatingprofit – floatingloss.

Balance – amount on the Clients or brokers trading account, not counting floatingprofit or floatingloss.

In the Agreement any reference to an individual person shall include
corporate entities, unincorporated associations, partnerships and
individuals.

Headings and notes in the Agreement are for reference only and shall
not affect the contents and interpretation of the Agreement.

In the Agreement references to any law shall include references to
any statutory modification or re-enactment thereof or to any regulation
or order made under such law, statute or enactment (or under such a
modification or re-enactment).

16. Terms for trading CFDs

General terms and bonuses
It”s not permitted to trade CFD, if total account loss is exceeding
total amount of deposits on the account.

When trading CFD, if balance drops to the level of bonus, an automatic
closing of all open trades takes place – Margin call.

Example: You deposited $1000 and got bonus of $1000. If the loss in
your account equals to $1000, bonus is automatically withdrawn and open
trades are closed.

Price: The price for a given contract is calculated
by reference to the price of the relevant underlying financial
instrument. For any given CFD, the Company will quote two prices: the
higher price (ASK) at which the Client can buy (go long) that CFD, and
the lower price (BID) at which the Client can sell (go short) that CFD.
Collectively, the ASK and BID prices are referred to as the Company”s
prices and can be found on the Company”s trading platform.

The difference between the lower and the higher price of a given CFD is the spread.

Prices will be obtained from reputable third-party price feeders and
provided by the Company. Prices are updated frequently as the
limitations of technology and communication links allow.

The Company ensures that the Client will receive the best price by
guaranteeing that the calculation of the quoted prices is made with
reference and compared to a range of underlying price providers and data
sources. The Company additionally ensures to monitor its Execution
Venue(s) on an ongoing basis and review their performance at least
annually to confirm that relevant and competitive pricing is offered.

Please note that despite taking reasonable steps to obtaining best
possible results for Clients, the Company is unable to guarantee, when
executing orders, that the prices offered will be more favourable that
prices that might be available elsewhere.

Under certain trading conditions, the Client should note that it may
be impossible to execute an Order at their requested price. In such
cases the Company reserves the right to execute the Order at the first
available price. Such instances may occur during times of high market
volatility and price fluctuations e.g. when the price of an asset rises
or falls in one trading session to such an extent that, under the rules
of the relevant exchange, trading is suspended or restricted.

Costs: In most circumstances, a spread is applied.
The spread is dynamic for certain Financial Instruments, and may take
into account such factors as liquidity in external markets for the
underlying financial instrument and competitive pricing. The Company
reserves the right to charge the Client a swap fee (of 0.07% of the face
value of the position) for keeping a position open overnight. This swap
fee can be subject to changes in the future. The swap fee is calculated
as the rounded result of the following formula: ((23%)/360) + Libor
rate.

The Company reserves the right to charge a commission for opening an
unleveraged Cryptocurrency CFD trading position which shall vary from 1%
to 2.5% of the transaction. For leveraged CFD cryptocurrency positions,
the Company will charge a commission fee of up to 5% of the
transaction.

In certain circumstances (such as increased volatility or illiquidity
in relation to the underlying market concerned) the Company reserves
the right to alter the spreads offered.

In other circumstances, clients may be charged overnight funding premiums.

The Company reserves the right to, at any time, apply such charges in
the future with prior notice to the Client. Such notice may be sent
personally to the Client and/or posted on the Company”s website in the
section General Fees. Should the Company at any period of time decide
not to charge any costs, it shall not be construed as a waiver of its
rights to apply them in the future.

 

Speed of Execution: The Company strives to offer a
high speed of execution however, in certain circumstances, for example
low internet speed or market volatility, the quoted price may no longer
be representative of the underlying market price and may result in the
Client placing his/her Order at a delay, this may result in orders being
executed at a better or worse prevailing price offered by the Company.

 

Likelihood of Execution: The Company arranges for
the execution of Client orders with the Execution Venue, as such,
execution may at times be difficult. The likelihood of execution depends
on the availability of the prices of the Execution Venue(s). In some
instances, it may not be possible to arrange an Order for execution
during abnormal market conditions. This can occur, but is not limited
to, the following examples: overnight, during news times, the opening of
trading sessions, volatile markets (where prices may move significantly
up or down and away from declared prices), where there is rapid price
movement, where there is insufficient liquidity for the execution of the
specific volume at the declared price or a force majeure event has
occurred.

In the event that the Company is unable to proceed with an Order in
relation to price or size or any reason, the Order will be executed at
the first available price or not executed at all. In addition, please
note, that the Company is entitled, at any time and at its discretion,
without giving any notice or explanation to the Client, to decline or
refuse to transmit or arrange for the execution of any Order or request
of the Client in circumstances explained in the Terms & Conditions.

The Company does not accept any orders outside of the market hours of the relevant underlying financial instrument.

Likelihood of Settlement: The Company shall proceed
to the settlement of all transactions upon execution of such
transactions. The CFDs offered by the Company do not involve the
delivery of the underlying asset, so they are not settled physically as
there would be for example if the Client had bought Shares. All CFDs are
cash settled.

The Company shall proceed with the settlement of all transactions
upon the execution and/or time of expiration of the specific
transaction.

Size of Order: All orders are placed in monetary
values. The Client is able to place an order as long as they have enough
balance in their trading account. The minimum size of an Order may be
different for each type of CFD, please refer to the Company”s trading
platform for the value of the minimum size of an Order in each CFD, as
well as the value of the maximum size of a single Order.

If the Client wishes to execute a large Order, in some cases the
price may become less favourable. The Company reserves the right to
decline an Order in case the size of the Order is large and cannot be
filled by the Company.

Market Impact: Some factors may rapidly affect the
price of the underlying instrument/product from which the Company”s
quoted price is derived and may also affect other factors listed herein.
The Company will take all reasonable steps to obtain the best possible
result for its Clients.

The Company does not consider the above list exhaustive and the order
in which the above factors are presented shall not be taken as priority
factor.

Different Types of CFDs: The Company offers the following types of CFDs on its platform:

• Forex: CFDs in currency pairs (FX)
• CFD stocks
• “Crypto”: CFDs in Cryptocurrencies

Types of Orders: The Client may give instruction to execute or initiate a trade with the Company by way of:

• Market Order: whereby the Client gives instructions to immediately buy or sell at the best available price.

17. Execution Practices in CFDs

Slippage: You are warned that Slippage may occur
when trading in CFDs. Slippage is the difference between the expected
price of an Order, and the price the Order is actually executed at. In
some situations, at the time an Order is presented for execution, the
specific price shown to the Client may not be available; therefore, the
Order will be executed close to or a number of pips away from the
Client”s requested price.

Slippage can occur at times of low liquidity or high volatility (e.g.
after economic events or news announcements) and is a normal element of
trading in CFDs.

Leverage (Multiplier): The use of the multiplier
tool in CFD trading enables the client to trade in the markets and
increase proportionally the returns of his/her invested amount, in
relation to the returns in the market. However, the maximum loss a
client can incur from a trade is limited to his/her original investment
amount meaning the remaining amount of his/her equity is secured. The
Company applies a maximum multiplier of 1:100 for all clients by
default, in line with relevant legislation.

E.g. (for long positions with 1:50 multiplier): A trader decides to
invest €1,000 (Investment Amount) on the upwards movement of EUR/USD.
He/she also chooses to use a multiplier of 50 for this trade. After one
day, the trader decides to close the position. At that moment, the price
of EUR/USD moved from 1.153250 (opening price) to 1.158000 (closing
price) or otherwise 0.41188%. The realised profit for the client will be
€205.94 or otherwise 20.594%. To better understand the calculations,
the invested capital increased by the percentage move in the market
multiplied by the multiplier (0.41188% x 50 = 20.594%).

(Closing Price / Opening Price -1) x Multiplier x Investment Amount = Profit/Loss

i.e. (1.158000 / 1.153250 -1) x 50 x 1000 = 205.93973553 or €205.94

For short positions: i.e (1-closing price / opening price) Multiplier Investment Amount = Profit/Loss.

Without the use of the multiplier tool the trader”s profit would have been 4.1187947106 or €4.12.

In the opposite scenario, if the market had moved against his/her
position, the realised losses would have been larger with the use of the
multiplier compared to a position opened without the use of it. To
demonstrate with the same example, if the market had moved 1% down from
the opening price of 1.153250, because of the use of the multiplier
tool, the invested capital will decrease by 50% (1% x 50).

i.e. 1% x 50 x 1000 = €500

Without the use of the multiplier tool, the trader”s losses would have been €10.

If the trader had used a lower multiplier both the profit and loss
amount in the examples above, would have been smaller as well.

E.g. Using a multiplier of 20, the realised profit in the first
example would be (1.158000 / 1.153250 -1) x 20 x 1000 = 82.374 or €82.40
and 1% x 20 x €1,000 = €200 for the second example.

As it will be explained more in Maintenance Margin section the trader
will never lose more that the investment amount of a position.

It should be noted that the Company may offer higher multipliers to
clients it considers to possess the necessary knowledge, experience and
understanding of the high risks involved with trading with leverage.
Leverage restrictions may apply to certain instruments and/or
jurisdictions.

Warning: Trading CFDs carries a high level of risk since the
multiplier tool (leverage) can work both in your advantage and
disadvantage. As a result, it may not be suitable for all investors
because you may lose all your invested capital.

Maintenance Margin: The Maintenance Margin is the
minimum amount of equity in a position required to maintain the open
position. Should this amount fall below 5% of the initial investment,
the Company will automatically close the position.

E.g. Using the data from the previous example with €1,000 investment
in EURUSD and using a multiplier of 50, the maintenance margin is
calculated as 5% x €1,000 = €50. Therefore, the maximum loss the trader
can occur, before their position is closed by the Company is 95% or €950
(If the trader has not already closed the position themselves).

The price when the position will be closed by the Company, and only
if the trader hasn”t decided to already close the position, is 1.131338.
At this price, the remaining amount of the investment will have reached
the maintenance margin.

To better understand the calculations the return in the market when
95% of the investment amount will be lost is 1.9% on the downside since
the position is long the EURUSD.

Maximum Loss / multiplier = return in market.

i.e. 95% / 50 = 1.9%*

For an opening price of 1.153250, a 1.9% decline will cause the price to move to 1.131338.

Opening Price x (1 – return in market) = price when position will be closed.

i.e. 1.153250 x (1-1.9%) = 1.131338

• In majority of situations, position will be automatically closed as
  soon as it declines by 95%. It can happen that the position will be
  closed in a range between 95% and 100%, such situations can occur at
  times of low liquidity or high volatility (e.g. after economic events or
  news announcements) and is a normal element of trading in CFDs.

In case of 100% loss, calculations will be like this:

Maximum Loss / multiplier = return in market

i.e. 100%/50 = 2%

For an opening price of 1.153250, a 1.9% decline will cause the price to move to 1.130185

Opening Price x (1 – return in market) = price when position will be closed

i.e. 1.153250 x (1-2%) = 1.130185

The Company assigns the following importance level to the Best Execution Factors:

Best Execution Factor	Level of Importance
Price	High
Costs	High
Speed of Execution	High
Likelihood of Execution	High
Likelihood of Settlement	Medium
Size of Order	Medium
Market Impact	Medium