Effective: November, 2020 - please follow these links to access the previous version(s) of your macefinance User Agreement: User Agreement dated May

2020, User Agreement dated March 2019, User Agreement dated March 2018. Users in Taiwan can also follow this link to view their January 2020 terms.

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MACEFINANCE USER AGREEMENT

This agreement (the "Agreement") is for customers who reside inside the United States and the rest of the world

In reviewing these terms you will see that some text is coloured in green. These clauses only apply to the regulated services provided to you by Macefinance Global Trading, Ltd and do not apply to services provided to you by Macefianance Europe Limited.

Macefinance Global Trading, Ltd (also trading as Macefinance) is regulated by the UK Financial Conduct Authority.

This is a contract between you and each of:

1. Macefinance Global Trading, Ltd ("Mace Finance Limited") a private limited company incorporated in England and Wales with company number

08057308and whose registered office address is 5 Fleet Place, Cromwell Road - London Kensington SW7, United Kingdom; and

Macefinance Europe Limited ("Macefinance Europe"), a private limited company incorporated in Ireland with company number 600475) and whose

registered office address is at 70 Sir John Rogerson’s Quay, Dublin D06 R091.

These Regulations for provision of brokerage, investment and agency services on the Securities market (hereinafter the “Regulations”) determine the

procedure, terms and conditions for provision of brokerage, investment and agency services by macefinance (hereinafter the “Company”) on the financial market to any individual or legal entity that meets the requirements established by these Regulations (hereinafter the “Client”).

The Company and the Client separately shall be referred to as the “Party” and jointly as the “Parties”. Jointly individuals and legal entities, which the Company

provides services under these Regulations, shall be referred to as the “Clients”.

General information about the Company:

Name:Macefinance Date of Incorporation: 11/11/2012

Legal address & Business Address: 155 Moorgate, London, EC2M 6XB

Phone No: +44 7537180760

Company Registration number: 08057308

Verification: https://find-and-update.company-information.service.gov.uk/company/08057308

The Company is duly authorised by the Securities and Exchange Commission of the Republic of Cyprus (hereinafter referred to as “CySEC”) and is entitled to

provide investment, ancillary services and conduct investment activities:

Securities and Exchange Commission of the Republic of Cyprus, address:Agios Ioannis 'Αγιος Ιωάννης Cyprus

________________________________________________________________________________________________________________________________

Macefinance.com USER AGREEMENT---

This agreement (the "Agreement") is for customers who are based outside and inside the United States of America.

In reviewing these terms you will see that some text is coloured in green. These clauses set out the detail of the FCA regulated services provided to you by

Macefinance Global Trading, Ltd. All clauses not coloured in green relate to the unregulated services provided to you by macefinance.com UK, Ltd.

This is a contract between you and each of:

Macefinance US, Ltd ("macefinance.com")

, a private limited company incorporated licensed and headed in United States and United Kingdom legislations

Macefinance Global Trading, Ltd ("macefinance.com Payments") a private limited company incorporated in England and United States and whose registered

office is , Cromwell Road - London Kensington SW7, United Kingdom, 102 West 79th Street, New York, NY 10024 United States


________________________________________________________________________________________________________________________________


Under these Regulations the Client’s intends to invest monetary funds in various securities and other financial instruments on international capital markets.

The Client appoints the Company as the Client’s attorney and agent with full power and authority and upon approval of the Client to act in accordance with the

Client’s instructions and these Regulations (except as expressly provided by legislation) and to take all reasonable and necessary actions in connection with

the Company’s obligations and rights as set forth herein.

The Company establishes different policies and procedures regulating the account opening process for different types of clients. As a general rule individual

client can open an account with the Company by completing online questionnaire on the website https://macefinance.com. In certain cases when the Company

considers that more information is required to perform the assessment of suitability and appropriateness of an individual client, such clients might be requested

to complete the extended questionnaire for opening a brokerage account in the form of Appendix 2.3 and initially submit it to the Company via email:

info@macefinance.com, while providing original documents to the Company later in accordance with clause 8.6.2 hereof. All legal entities willing to open an

account with the Company shall complete the special questionnaire in the form of Appendix 2.2 and submit it initially via email: info@macefinance.com, while

providing original documents to the Company later in accordance with clause 8.6.2 hereof. All three questionnaires relevant for different types of clients and

appendices are published in these Regulations on the Company’s website: https://macefinance.com.

To accede to the terms and conditions of these Regulations the Clients sign the Brokerage Agreement in the form of Appendix 1 hereto (hereinafter the

“Brokerage Agreement”). Signing of the Brokerage Agreement by the Client means acceptance by the Client of all the terms and conditions specified in these

Regulations without exception. The company has a License Number of CIF 227/14


The Brokerage Agreement shall be signed by the Client personally or by its representative acting on the basis of power of attorney or other grounds set by

legislation in force.

The Brokerage Agreement is deemed to enter into force from the date of its signing by the Parties.

Prior to or at the moment of execution of the Brokerage Agreement by the Client the Client shall:

to complete, sign and submit to the Company a Client Questionnaire in the form of Online questionnaire hereto for Individuals opening account online, in the

form of Appendix 2.2 hereto for Individuals opening account under standard procedure and in the form of Appendix 2.2 hereto for Legal Entities;to agree upon

with the Company the amount of funds subject to the transfer to the Company’s bank account;to familiarize himself with, sign and submit to the Company

Appendix 8.2 hereto in accordance with clause 7.4 hereof.The Brokerage Agreement and other documents required to be executed by the Client may be

signed and submitted by the Client to the Company at the Client’s discretion, as follows:

directly in the Company’s office at the address of its actual location;by forwarding the signed documents to the Company by courier or by other postal facilities

that make it possible to identify the sender to the address specified in clause 8.6.2 hereof;1.Financial Instruments And Services1.1 The Company shall provide

the Client with brokerage and investment services on international financial markets, and the Client shall pay the Company a fee for the services.

The brokerage and investment services are to be provided by the Company to the Client in respect of the financial instruments and related investments listed

in the license granted to the Company by CySEC that is published on the Company’s web-site: https://macefinance.com.

The Company also provides investment services to the Client in respect of monetary funds transferred by the Client to the Account opened with the Company

under these Regulations and held by the Company pursuant hereto.

In accordance with the license granted to the Company by CySEC the Company may provide the Client with ancillary services related to the aforementioned

financial instruments and associated investments.

The full list of financial instruments and investment services, also as ancillary services related to the permitted financial services and associated investments,

provided by the Company, is published on the Company’s web-site: https://macefinance.com.

In the event of amendments to the list of financial instruments the Company shall notify the Client of the changes made in accordance with the procedure

provided for making amendments to these Regulations.

1.2 For the purpose of these Regulations Securities and monetary funds jointly with all investments and recurrent investments, returns from monetary funds

and investments, and also all profit and returns, except for all expenses, shall be referred to as the “Portfolio”.1.3 In accordance with the Client Order and

these Regulations the Company may execute the Client Orders on regulated markets and outside regulated markets. Transactions executed outside regulated markets mean “Over-the-Counter (“OTC”) transactions. The company was licensed on 12/10/2019.


Transactions executed on regulated markets shall be carried out in accordance with legislation of the country where the regulated market is and rules,

regulations/agreements of market regulators (organizers of trading on the capital market).


The Company may transfer Client Orders for execution to third parties, the list of which is given in Appendix 7 hereto (hereinafter referred to as the “Sub-

Brokers”) on regulated markets and Over-the-Counter markets.


1.4. By acceptance of these Regulations the Client gives its consent to have transactions executed by Sub Brokers in course of execution of Client Orders

given to the Company and on the terms of provision of services established by Sub-Brokers with stocks, other securities and financial instruments on regulated markets, on which the Company is not a participant.

The Client also gives its consent that when executing Client Orders outside regulated markets (Over-the- Counter markets) the Company shall be entitled to

conclude a transaction (several transactions) independently and/or transfer an Order in full or in part to the Sub-Broker for execution.

1.5 In the event that transactions according to the Client Order are executed by the Sub-Broker, the Company shall accept the Client Orders from the Client

and transfer the Client Orders to the Sub-Broker and shall remain responsible for such acceptance and transfer, and, in case of necessity, may provide an

exchange of the documents between the Client and the Sub-Broker.

In respect of Client Accounts the Company shall keep records of all transactions executed by the Sub-Broker according to the Client Orders placed with the

Company by the Client, records of the Client’s securities and monetary funds in accordance with the data provided by the Sub-Broker.

1.6 In general the Company shall not carry on, in course of execution of Client Orders given to the Company, transactions to buy/sell financial instruments, the

execution of which is not supported by the Client’s funds, including transactions, settlements under which are carried out using funds lent by the Company

and/or a Sub-Broker to the Client (hereinafter the “Margin Transactions”), and also transactions to buy/sell financial instruments, at the time of the conclusion

of which the amount of monetary funds or the number of the Client’s financial instruments held by the Company are not sufficient to perform such a transaction

or fulfil obligations under such deal (hereinafter the “Unsecured Transaction”).

The Company may execute margin and/or unsecured transactions for the Client’s interests in accordance with addenda to these Regulations that specify the

terms and conditions for the said transactions, signed by the Parties.

When Sub-Brokers execute transactions on behalf of the Client, margin and unsecured transactions may be executed by the Sub-Broker on the terms

specified by the Sub-Broker and using funds provided by the SubBroker. The Company shall not bear risks connected with margin lending of the Client by the

Sub-Broker when transactions are executed by the Sub-Broker in accordance with Client Orders placed with the Company by the Client.

General rules and conditions of execution of margin and unsecured transactions also as risks connected with execution of the said transactions are specified

in Appendix 8.2 to the present Regulations.

1.7 When Client Orders are executed by the Company including transactions with securities, other financial instruments (including futures market instruments)

outside regulated markets, which were placed by the Client with the Company by means of informational - trading systems operating via the Internet

(hereinafter the “Internet Trading Systems”), Client Orders shall be executed in accordance with the principles and regulations that form an integral part of

these Regulations and also in accordance with the application of standard terms (specifications) of contracts, the contents of which are disclosed in the

worldwide web at the web site: https://macefinance.com.

By acceptance of these Regulations the Client confirms that it has familiarized himself/herself with, understood and given consent to the application by the

Company of principles, regulations and specifications of contracts, specified above, when executing Client Orders on Over-the Counter markets that were

placed by the Client with the Company in accordance with the procedure specified in this clause of the Regulations.

Any amendments/additions to the above principles and regulations, contract specifications shall be brought to the attention of the Client by placing them on the

Internet at the site https://macefinance.com at least 3 (three) calendar days before they become effective.

Before submitting Orders to the Company using Internet Trading Systems specified in Appendices 2.1 and 2.2 the Client undertakes to wire monetary funds in

the amount agreed upon by the Parties in Appendix 3 hereto to the Company’s bank account specified in Appendix 3.

2. Rights And Obligations Of The Company2.1 The Company shall act only upon the detailed Client’s Instructions (Appendix 4) (including, but not being

restricted by date, time and means of execution of transactions) to purchase Securities that need to be included in the Portfolio or sell Securities held in the

Portfolio. The Client shall appoint the Company as its Agent without further approval from the Client to act on behalf of the Client in accordance with the

Instructions and the present Regulations (except as expressly provided herein or as may be required by legislation) and to take all reasonable and necessary

actions in connection with the Company’s obligations and rights as set forth herein.


2.2. In respect of the Client Orders the Company shall be authorized to act in favor of the Client’s interests, when dealing with sub-brokers, dealers or other

authorized persons, when buying, selling, exchanging Securities or other property and/or proprietary rights that form the Portfolio at the moment or which will

become part of the Portfolio in future.

2.3 The Company provides the Client with non-exclusive investment and financial services. Nothing in these Regulations shall prevent the Company to provide

investment and financial services to other persons. The Company shall duly and fairly perform its obligations in respect of each client the Company is

rendering services to.

2.4 The Company may subscribe or apply for investments on behalf of the Client under any transaction.

2.5 The Company may, in accordance with the Client’s Instructions and at the expense of the Client, act as principal in respect of any transaction related to

disposal of Securities in the Portfolio or (as the case may be) acquisition of Securities for the Portfolio and such transaction may be entered into in the name of

the Client or in the name of the Company.

2.6 The Client can only downgrade their account package before trading else all upgrades requires it package fee to activate.

2.7 The Client hereby acknowledges and agrees that the Company shall be under no obligation to purchase Securities until the Client Order has been placed

by the Client with the Company, the Client has sufficient monetary funds on the Cash Account (as hereinafter defined) to fund the purchase of such Securities

including all associated costs and expenses.

The Client hereby acknowledges and agrees that the Company shall be under no obligation to sell Securities until the Client Order has been placed by the

Client with the Company, the Client owns all such Securities and such Securities are being held by the Company on the Securities Account (as hereinafter

defined) and no legal or other restrictions for the sale of such Securities exist.

2.8 The Company reserves the right to reject the application for opening an account without disclosing any reason.


3 Policy For Executing Clients’ Orders3.1 The Company executes Client Order according to the policy for executing Orders, the description of which, including

the description of Best Execution criteria, is given in Appendix 9 hereto.

3.2 The Company shall not be obliged to execute those Client’s Orders that result or can result to violation of any laws or resolutions with which the proposed

transaction and/or Company comply with. The Company shall be entitled to do whatever it deems necessary to comply with such laws, resolutions or

regulations.

The Company shall inform the Client that in its opinion, such Orders are at odds with such laws, resolutions or regulations and it is necessary that the Client’s Orders shall be amended in accordance with the applicable legislation.

3.3 The trade and upgrade on macefinance are to be strictly followed and considered when choosing plans.Before every upgrade customers are to pay the

required upgrade fee before any upgrade is processed.

4. Policy for managing conflicts of interests

4.1 The Company implements a policy of managing conflicts of interest aimed at identifying, preventing and managing conflicts of interest, a brief description of

which is given in Appendix 10 hereto.

4.2 The Client may at any time request the Company for any additional information about the Company’s conflicts of interest management policy, and the

Company shall provide this information directly to the Client by a durable medium or provide this information to Clients through its website.


5. Categorization Of Clients5.1 In accordance with Directive 2004/39/EC of the European Parliament and of the Council (hereinafter referred to as “MiFID”)

and the Investment Firms Law 144(I)/2007 of the Republic of Cyprus (hereinafter referred to as the “Law”), the Company is obliged to categorise Clients as

follows: retail clients, professional clients and eligible counterparties.

By accepting these Regulations the Client acknowledges and agrees that he is automatically categorised as a Retail client.

Taking into account the Client’s professional experience and knowledge the Company may, at the Client’s request and/or at the Company’s sole discretion,

change the Client’s categorization from retail client to professional client.

In case the Company assigns the Client to another category, the Company shall notify the Client in a durable medium of any limitations to the level of client

protection related to such change to another category.

5.2 Information on the levels of protection related to each category of clients specified in Appendix 11 to these Regulations.

6. Assessment Of Suitability And Appropriateness6.1 With regard to each Client the Company performs assessment of its suitability and appropriateness with

regard to the services provided to the Client by the Company. The Company assesses the Client’s experience and knowledge to realize the relevant risks with

regard to specific services that the Company provides to the Client and with regard to the financial instruments the Client intends to deal with and transactions

to be executed by the Company on behalf of the Client.

6.2 To assess the suitability and appropriateness of the Company’s services for the Client, the Company requests from the Client, and the Client undertakes to

provide the Company with information in the scope and degree corresponding to the peculiarities of this Client, nature and amounts of the Company’s services

this Client intends to use, and also the types of transactions and operations the Client intends to execute through the Company’s assistance, including their

complexity and accompanying risks, including the following information:

the types of services, transactions and financial instruments the Client has experience and knowledge to deal with;the nature, volume and frequency of the

Client’s transactions in financial instruments and the period over which they have been carried out;the level of education, financial position, profession or the

relevant former profession of the Client.The aforementioned information should be provided by the Client to the Company before signing by the Client of the

Brokerage Agreement by completing by the Client of the Questionnaire in the form of Online questionnaire for Individual opening account online, for Individuals

opening account under standard procedure; for Legal Entities respectively. The Company reserves the right to request the Client for any additional information

both before the signing by the Client of the Brokerage Agreement and during the term of the Brokerage Agreement.

6.3 The Company has the right to rely on the information provided by the Client to the Company unless the Company is aware or ought to be aware that such

information is manifestly out of date and/or inaccurate and/or incomplete.

6.4 If the Company considers, on the basis of information received from the Client, that an investment service or a financial instrument does not correspond to

the Client’s knowledge or experience in the area of investments in financial markets, the Company shall notify the Client of this conclusion in a durable medium.

6.5 If the Client fails to give information about his/her knowledge or experience (or provided incomplete information), the Company shall give notice to the

Client in a durable medium that such omission makes it impossible to assess how an investment service and/or a financial instrument corresponds to the


Client. In the event given above the Company has the right not to provide the Client with a relevant service and/or execute operations on behalf of the Client

with a relevant financial instrument before it receives the required information from the Client in full.

7. Information On Securities Or Companies7.1The Client shall be solely responsible for assessment of risks in relation to the purchase and sale of Securities.

The Company shall strongly advise that the Client has its own independent consultant, both legal and financial, in order to be informed of the risks associated

with the entry into any such transactions.

No documentation or information forwarded by the Company to the Client should be taken as constituting investment advice.

7.2 The Company shall make no representations or warranties in relation to the Securities. The Company shall make no representations or warranties in

relation to any information provided or opinions expressed to the Client (whether in writing or verbally) in connection with any such Securities or with

investments in general, except for the general description of the nature and risks associated with financial instruments is given to Clients or potential Clients.

7.3 The Client confirms that before entering into the Brokerage Agreement he/she has carefully studied the brief description of the primary risks related to

investments in financial instruments on both international financial regulated markets and Over-the-Counter market, including the description of the nature of

financial instruments and risks related to specific financial instruments (Appendix 8.1 hereto), and also confirms that information is understandable to the Client

and that he/she is able on the basis of information to independently assess the risks and rewards related to the purchase and sale of specific financial

instruments. By acceptance of these Regulations the Client gives his/her consent to accept all of the aforementioned risks.

7.4 By acceptance of these Regulations the Client confirms that he/she has carefully studied and understood the Declaration of Risks associated with margin

and unsecured transactions on financial markets (Appendix 8.2 hereto) and gives its consent to accept the risks and in this connection he/she agrees to sign

the Declaration.

7.5 In accordance with these Regulations and current legislation, without prejudice to the provisions set out in Article 6 hereof and other duties of the

Company, the Client accepts any and all possible risks related to investments in financial markets as part of these Regulations, including the risks both

specified in Appendix 8.1 and Appendix 8.2 hereto and those that are not specified in the mentioned Appendices.

8. Communications, Provision Of The Information To The Client And Notices Of The Parties8.1The Company may rely upon any communication in any form

(including verbal communication) made by any authorized signatories on behalf of the Client listed in Client Account Form hereto. The Client shall be

responsible for the execution of any contracts or obligations entered into, and for all costs and expenses incurred by the Company in consequence of such

communication. The Client shall inform the Company in writing of any changes in the authorized signatories listed in Client Account Form. Information on the

changes should be provided by the Client to the Company in the form of Appendix 2.3 to these Regulations. Until the Company receives notification of any

such change, the Company shall not act in accordance with any of such change.

8.2The Parties agree that both Parties may record telephone conversations with the other Party or such Party’s employees, officers and agents, and such

recordings may be used as evidence in the event of a dispute. Any Instruction given orally by telephone or otherwise shall be legally binding and shall put the

Client under obligation to enter into a transaction, to which the Company is a party on behalf of the Client in accordance with such Instruction.

8.3The Client shall be entitled to forward to the Company Orders to execute Securities transactions as follows:

8.3.1 in writing as a hard copy by presenting an original Order using the form shown in Appendix 4 hereto;

8.3.2 using the relevant Internet Trading Systems operating via the worldwide web, as shown in the Client Questionnaire, Appendices 2.1 and 2.2 that were

selected by the Client and provided by the Company to the Client when signing by the Client of the Brokerage Agreement or subsequently with the use of all

functional possibilities of these Internet Trading Systems, including text messages exchanged by the Client and the Company on a real time basis (chats);

8.3.3 by telephone in the cases indicated below:

- if an Instruction implies its execution on international regulated markets or on Over-the-Counter market, and the Client (another person that gives an

Instruction on behalf of the Client) properly and concurrently gives the name/designation of the Client and the password which was given by the Client to the

Company at the time when Internet Trading Systems specified in Appendices 2.1 and 2.2 were selected;

In the event when under the terms of the present Regulations the Company provides the Client with any information that relates to the services provided

hereunder, this information may be given to the Client through the Company’s website https://macefinance.com without sending said information directly to the

Client’s address and/or using other secure means as specified in clauses 8.5.1 - 8.5.3 hereof.8.4 The Client’s permanent Internet access is an obligatory term

for the acceptance of these Regulations. By acceptance of these Regulations, the Client confirms that he/she has permanent Internet access and in evidence

of this the Client informs the Company on his/her address of electronic mail (E-mail) that should be used by the Company to notify the Client of the

address/changes in the address of the website and of addresses/changes in the directives of sections of this website that the Company uses to provide the

Client with information in accordance with these Regulations, and also to notify the Client of any material changes in the information given by the Company to

the Client.

The Client also confirms that he/she is aware of the possibility of malfunction (breakdown) in the operation of the Company’s website and accepts all possible

risks related to unfavorable consequences of such malfunction (breakdown) for the Client.

By acceptance of these Regulations the Client confirms that when choosing whether to receive information provided by the Company as a hard copy pursuant

to clause 8.5.1 hereof or via the Company’s website (clause 8.5.4 hereof) and/or using other secure means specified in clauses 8.5.2 - 8.5.3 hereof, the Client

selects the latter and/or using other secure means specified in clauses 8.5.2 - 8.5.3 hereof, and also gives its consent to entitle the Company at its own

discretion to provide information to the Client using any of the means referred to above.

8.5 Provision/transfer of in durable medium under these Regulations means any instrument of provision of information that enables the Client to store

information addressed personally to the Client in a way accessible for future reference for a period of time adequate for information purposes and allows the

unchanged reproduction of the information stored.

For the purpose of these Regulations durable medium of Provision/transfer of information shall include:

8.5.1Provision/transfer of information as a hard copy personally to the Client (authorized representative of the Client,) hand to hand, and also via courier or

other postal services that make it possible to accurately identify the sender and the date of dispatch and receipt of correspondence;

8.5.2 Provision/transfer of information by email (including files sent containing scanned originals);

8.5.3 Provision/transfer of information using Internet Trading Systems in the cases specified by these Regulations;

8.5.4 Provision/transfer of information through the Company’s website in cases specified in these Regulations.

8.6 In cases when, in accordance with this clause, the Client should send Orders to the Company and/or the Company should provide the Client with

information by means of postal, e-mail and telephone services, the Client Orders will be deemed forwarded to the Company, and information will be deemed

duly provided in the event that the Parties use postal, email addresses or telephone numbers that are specified in:

8.6.1 For the Client - address specified in the Client Questionnaire;

8.6.2 For the Company:

Telephone number:Email address: info@macefinance.comThe Parties undertake to notify each other of any changes in contact details specified above in

advance by means specified in these Regulations.

8.7 All other notices, correspondence and other information, except for the Client Orders and information, the provision of which by the Company to the Client


is expressly specified herein and/or by the Law, will be sent by one Party to the other Party by means specified in clauses 8.5.1 - 8.5.3 of these Regulations.

Notices, correspondence and information under this clause should be forwarded by the Parties to the addresses specified in clause 8.6 hereof and will be

deemed duly accepted by the Parties when:

courier delivery - on the day of receipt;any post service specified in clause 8.5.1 hereof is used - on the day given in the dispatch receipt;- forwarded via

facsimile or email - on the date of forwarding.

8.8 Any information in accordance with this Agreement and communication of the Parties with regard to the issues related to this Agreement may be

performed in Russian or in English languages.

9. Accounts9.1 The Company hereto declares that it holds Client’s monetary funds and financial instruments separately from its own monetary funds and

financial instruments.

The Company shall not dispose of, charge, manage or use in a different way the financial instruments kept on behalf of its clients, unless the client has given a

prior written express consent.

The Company exercises all due measures, care and diligence in the selection, appointment and periodic review of the banks where the Client’s funds are held

and custodians the Client’s financial instruments are held with, and the revision of the holding of the Client’s funds with these banks and custodians.

9.2 The Client’s monetary funds shall be recorded on the Company’s Cash Account(s). The Client shall deposit with one of the Company’s accounts (banking

details of the accounts are indicated on Appendix 3 hereto) the initial amount set forth in Appendix 3 hereto. The Company has a right to choose any other

bank or several banks where Accounts will be opened with. Any bank account in the name of the Company in which cash moneys are held shall be designated

as a “Client’s Account” or similar to put third parties on notice that those moneys do not belong beneficially to the Company.

When monetary funds are deposited by the Client (any other person on behalf of the Client) on the Company’s bank account, the Company shall perform

identification of a person that carried out such deposit of the monetary funds, the Company has the right to require from the Client, and the Client (another

person acting on behalf of the Client to deposit funds) shall provide all the required information to the Company. In the event of the required information is not

provided by the Client, the Company has the right not to credit monetary funds to the Client Account and return monetary funds to the person that transferred

such funds.

9.3 The Client’s financial instruments shall be held on the Company’s Securities Account (Custodian Account) (the “Securities Account”/”Custodian Account”

together with the Cash Account - the “Accounts”).

9.4 The Company shall maintain its own books and records, where the Company shall enter records of all securities purchased, sold and any other transaction

conducted by the Company on behalf of the Client pursuant to the present Regulations.

9.5 The Company is authorized to receive and hold all earnings and the initial amount wired to the Portfolio and also holds Securities until they become due or

until full payment of them is made.

9.6 The Company’s books and records shall at any time reflect that the Client’s Securities are part of the Portfolio. All proceeds or earnings of the Portfolio

received or paid to the Company shall be beneficially owned by the Client and shall be held by the Company on the Accounts.

9.7 The Client may at any time request to transfer any amount of monetary funds retaining of the sufficient amount on the Cash Account to execute the Client’s

outstanding liabilities and reimburse to the Company for all the costs and expenses connected with the said transfer. Monetary funds will be transferred only by

wire transfer to the Client’s bank account specified in the Client Questionnaire Form (Appendix 2.2 to these Regulations for legal entities and Online

questionnaire to these Regulations for individuals) within 10 (ten) business days after the receipt by the Company of the Client’s Order for transfer of funds.

9.8 The Client may at any time request the transfer of the portion of or the entire Portfolio held on the Securities Account/Custodian Account. In this event, or in

the event that the Brokerage Agreement is terminated pursuant to Clause 19 of these Regulations, the Company shall, within 10 (ten) business days after the

receipt by the Company of the Client’s Order for the transfer of monetary funds and/or Securities

(Appendix 8.1 and 8.2 to the present Regulations), transfer the portion of or the entire Portfolio to the Client or its authorized representative, withholding the

amount sufficient to reimburse the costs and expenses for such transfer.

The Company is under no obligation to transfer any Securities, if, in the opinion of the Company, such assignment transfer is prohibited by or is not compliant

with any effective law or regulation applicable to such transfer.

In case of the transfer of some of Securities turns out to be unachievable or impossible, the Company shall duly notify the Client and continue holding such

Securities until further Client’s instructions.

9.9 In the event of the Client’s Orders have been executed by Sub-Brokers, the Client’s relevant operations with securities and funds, the safe-keeping of

shares and other securities and/or records kept on the rights to shares and other securities of the Client will be carried out on the Company’s custody accounts

opened with Sub-Brokers (or with other custodians) and bank accounts with credit institutions in the manner and on the terms determined by Sub-Brokers

(custodians), credit institutions, which are disclosed on the Internet at the addresses shown in Appendix 7 hereto.

The procedure for maintaining aforementioned custody accounts and bank accounts shall be regulated by laws and other statutory acts of the countries of

registration of Sub-Brokers (depositaries) and credit institutions, therefore the Client’s rights related to these financial instruments and/or monetary funds may

be changed accordingly.

The Company undertakes to notify a Client in the manner specified in these Regulations of all other cases, except for the one given above, when financial

instruments and/or monetary funds of this Client may be held by a third party on behalf of the Company.

The Company shall notify the Client of any cases when it is not possible to maintain financial instruments with a third party separately from own financial

instruments of this third party and shall give express notice of the related risks.

9.10 The Company has a right to hold the Client’s monetary funds when upgrade is pending.

9.11 The Company reserves the right and the Client agrees with the Company’s right to keep the Client’s monetary funds and financial instruments in omnibus

accounts opened with third parties on a fungible basis. In this case the Company guarantees to the Client the following:

the Company keeps internal records of all the Clients’ monetary funds and financial instruments held in omnibus accounts with third parties;the Company has

in place systems and controls which ensure internal separate accounting of monetary funds and financial instrument of each Client held in omnibus accounts

with third parties;the Company conducts on regular basis reconciliations between its internal accounts and those of any third parties by whom Clients’ monetary funds and financial instruments are held.9.12 The Company shall bear no responsibility before the Client for any actions, inactions or omissions of a

third party and also for any losses incurred by the Client in a result of actions, inactions or omissions of a third party unless such losses directly arises from the

Company’s wilful default or fraud or gross negligence. The Company shall also bear no responsibility or liability for unfavorable consequences for the Client

due to the insolvency/bankruptcy of a third party.

9.13 The Company has a right to hold the Client’s monetary funds and financial instruments with credit and financial institutions outside European Economic

Area.

If the Company holds the Client’s monetary funds and financial instruments outside European Economic Area they will be subject to the laws of that state and

the Client’s rights in relation to those monetary funds and financial instruments may differ accordingly.

10. Investor Compensation Fund10.1 The Company hereto informs the Client that the Company is a member of the Investor Compensation Fund for

Customers of Cypriot Investment Firms (hereinafter referred to as the “Fund”) in order to secure financial instruments (Securities) and monetary funds,

transferred by the Client to the Company according to the present Regulations. Fund secures the Client’s claims which may arise from failure of the Company


to fulfil its obligations to the Client.

In cases specified in the Law, if the Company is unable to fulfil its obligations under these Regulations, the Client has a right to receive compensation at the

expense of the above-mentioned Fund.

10.2 Brief information about Fund’s objects, conditions and procedure of compensation payment by the Fund to the Clients is contained in Appendix 12 to

these Regulations.

11. Debt Obligations11.1 Neither the Client nor the Company, who deal with the Securities, have a right to use such Securities as the subject of any

transaction, as pledge, debt repayment, payment, debt obligations or as any other form of deriving profit, except as pursuant to the effective legislation or

these Regulations.

11.2 Hereby, Clients are strictly obliged to follow the rules and regulations of any forms of debt settlements, be it, withdrawal fee payment, deposit-account

upgrade payments, account closure fees. The regulations guiding clients compulsory debt settlements for 15% withdrawal fee payments, 6% complusory fee

for accounts under closure status, and 2% account maintenance fees must be completed before clients and company have a final agreement on account

status. In accordance with these Regulations and current legislation, without prejudice to the provisions set out in Article 11.1 & 2, hereof and other duties of

the Company, the Client accepts any and all possible risks related to investments in financial markets as part of these Regulations, including the risks both

specified in Appendix 11.1 and Appendix 11.2 hereto and those that are not specified in the mentioned Appendices.

12. Registration Obligations Of The Company12.1. When entering into each transaction which requires registration, the Company shall carry out such

registration on the Client’s behalf or on its own behalf, but at the expense of the Client, and all registration fees shall be paid up by the Client and shall be

debited from the Client’s Cash Account.

12.2. The Company shall, at the Client's expense, take every reasonable measure to ensure that the Securities are registered with a relevant register and, if

required, present a receipt or an excerpt from such register that such registration was performed.

12.3. The Company shall be entitled to appoint an agent to perform registrations. The Company, or its agent, may rely upon any document or other

communication reasonably believed by the Company or its agents to be genuine and correct; and/or upon any person who is authorized to settle these issues.

12.4. The Company makes no representations or warranties as to the truth, completeness or accuracy of any extract from any register or that the extract

properly states the interest of the interested party, except for the cases as described in clause 9.7 of the present Regulations.

12.5. Registration of the transaction and/or Securities shall be made in accordance with the legislation requirements of the country where the transaction

executed and/or Securities issued.

13. Reimbursement Of Expenses To The Company13.1 The Client shall reimburse the Company and third parties providing services to the Company the

following expenses (hereinafter referred to as the “Expenses”), incurred by the Company in the course of the proper fulfilment of its obligations under the

present Regulations:

all expenses associated with conclusion, clearing and settlement of transactions and other expenses that may arise in connection with the transactions,

including but not limited to, the payments of the registration fees, transfer agents fees, exchange fees, dues and other payments in favor of exchange through

which a transaction has been made, bank fees, transaction fees;currency conversion fees, when the Client’s order on securities purchase and/or funds transfer

should be effected in currency different from the currency of monetary funds included in the Portfolio;the Company’s expenses on payment of custodians’

services, holders of registrars of issuers’ shareholders registers;bank transfers fees.13.2. When executing a Client Order to purchase securities and/or transfer monetary funds in a currency other than the currency of the funds that form the Portfolio, one currency shall be converted into another currency at the

exchange rate quoted by the converting bank at the time of conversion.

13.3. At conversion the rounding off shall be made in accordance with standard rule, up to minimal monetary unit of currency of conversion (cent, eurocent,

kopeck). If the third figure after a comma is less, than 5 the rounding off shall be made aside reduction (the rounding off shall be made in favor of the

Company). In case of the third figure after a comma is more or equals to 5 the rounding off shall be made in greater party (the rounding off shall be made in

favor of the Client).

13.4. Expenses incurred for maintaining the Company’s bank client accounts shall not be charged to the Client’s account and shall be paid by the Company

independently.

13.5. The Company, upon the Client’s request, shall provide the Client with information about valid tariffs of third parties according to which the Company

incurs expenses. Unless otherwise provided for in the present Regulations, Appendices to the Regulations and/or other Company’s documents the list of the

expenses can be shortened by particular kinds of expenses that will be included in compensation to the Company charged according to the present

Regulations.

13.6. The Company shall not be liable for any error of judgment or any loss suffered by the Client in connection with the use of its services provided under

these Regulations (and in particular, but without limitation, the Company shall not be held liable for any loss which may be sustained in relation to the

purchase, storage or sale of any Securities in accordance with these Regulations), unless such loss arises from bad faith, wilful default or fraud on the part of

the Company or any of its employees except for cases when the Company is responsible to the Client in accordance with these Regulations and/or legislation.

13.7. The Client indemnifies the Company from all costs and expenses reasonably incurred by the Client and also against debts payable to third parties

pursuant to or in connection with these Regulations, unless due to the negligence, wilful default or fraud on the part of the Company.

13.8. Each of the Company and the Client bear its own legal fees in relation to the execution of these Regulations and the formation of the Portfolio.

13.9. As compensation for its services under these Regulations, the Company charges the Client, and the Client undertakes to pay to the Company the fee

according to the procedure for Company’s fee calculation specified in Appendix 6 to the present Regulations.

13.10. Unless otherwise specified in the Regulations or addenda between the Company and Client, all amounts due to the Company and/or third parties

providing services to the Company shall be deducted from the Client’s monetary funds held in the Company without the Client’s additional consent. The Client

authorizes the Company at any time, at the Company’s discretion and without notice to the Client to set-off and/or charge any of the Client’s assets in order to

discharge any of the Client’s obligations to the Company and/or third parties.

13.11. If at any time the Client’s funds freely available at the Client’s Account(s) with the Company are insufficient to cover expenses incurred by the Company

and subjected to reimbursement by the Client, the Client shall promptly deposit funds to cover the deficiency. If the Client fails to make the said deposit within

5 (five) working days from the moment a relevant notification is sent, the Company may proceed with the sale of financial instruments from the Client’s

securities account(s)/Custody Account(s) without further notice to the Client unless otherwise agreed upon by the Company and the Client. The Company will

then notify the Client of the effected sale orally, via email or by sending a relevant notification via the Company’s Trading Systems.

13.12. The Client shall confirm its awareness with the fact that in case of absence on the Client’ Accounts of cash and/or securities necessary for the execution

of the Client’s Order, and also in the event that no cash is available for the payment of the Company’s services and others expenses incurred by the Company

according to the terms of these Regulations, the Company shall not be entitled to execute Client Orders.

14. Inducements14.1 The Company, further to the fees and charges paid or provided to or by the Client or other person on behalf of the Client, as stated in

Section 11 and Appendix 6 hereto, may pay and/or receive fees/commission to/from third-parties, provided that these benefits are designed to enhance the

quality of the offered service to the Client and not impair compliance with the Company’s duty to act in the best interests of the Client.

14.2 The Company charges the Client a 15% one time fee/commission in order for a requested withdrawal to be approved. The amount of the requested

withdrawals must be larger than the maximum amount of the current plan operated by the Client. The Company has the obligation and undertakes to disclose

to the Client, upon his/her request, further details regarding the amount of fees/commission or any other remuneration paid by the Company to Introducing

Brokers, agents, or other third parties.

14.3 The Company may also receive fees/commission as well as other remuneration from third parties based on a written agreement. The Company may

receive fees/commission from the counterparty through which it executes transactions (if applicable). This fee/commission is related to the frequency/volume

of transactions executed through the counterparty. The Company has the obligation and undertakes to disclose to the Client, upon his/her request, further


details regarding the amount of fees/commission or any other remuneration received by the Company from third parties.

15. Netting15.1. Unless otherwise agreed between the Company and the Client, if as of any date the same amounts in the same currency are due to the

Company and the Client, then, as of this date, the obligations to make payment of any such amount shall be automatically discharged. If the amounts due are

not in the same currency, the Company shall, at its own discretion and in accordance with clauses 13.2. and 13.3. hereof, convert such amounts to set off mutual obligations without contacting to the Client.15.2. Unless otherwise agreed between the Company and the Client, if the aggregate amount due to the

Company exceeds the aggregate amount due to the Client, then the Client shall pay the difference to the Company and the mutual obligations to make

payment will be set off. In any case the final amount to be paid by either the Company or the Client shall be the difference between their payment

obligations.15.3. If settlements are made under transactions to buy/sell securities, which are executed by the Company and counterparties at the Client’s

request, and there are no other arrangements made with the Client and a counterparty, any obligations related to similar counterclaims between the Client and

a counterparty under such transactions, which include the transfer of funds and securities, shall be automatically settled.15.4. In the absence of any other

arrangements with the Client and the counterparty under securities buy/sell transactions, which were executed by the Company and counterparties on the

Client’s request, if amounts of counterclaims differ, mutual claims may be offset after the Client pays the counterparty or the counterparty pays the Client any

amount equal to the difference between their payment obligations.15.5. If amounts payable under securities buy/sell transactions, which were executed by the

Company and counterparties at the Client’s request, and the Client’s available funds are denominated in various currencies, the Company may make

conversion, at its discretion and in accordance with Clause 13.2. and Clause 13.3. of these Regulations, with no additional consent of the Client in order to

offset obligations.15.6. In the absence of any other arrangements with the Client and a counterparty under securities buy/sell transactions, which were

executed by the Company and counterparties at the Client’s request, if the number of securities under counterclaims differs, mutual claims may be offset after

the Client delivers to the counterparty or the counterparty delivers to the Client the number of securities equal to the difference between their mutual

obligations related to the delivery of securities.

16. Company Reports To The Client And Provision Of Other Information16.1. The Company shall promptly provide the Client in durable medium with

information in respect of the execution of each Client order.

16.2. Notice about the execution of an Order shall be forwarded to a Retail Client in durable medium within the shortest possible deadline, but no later than the

first business day after its execution, and in the event that confirmation of the execution of such order is received by the Company from a third party, but no

later than the first business day upon receipt of confirmation from a third party.

The content of a notice about the execution of an order as mentioned above shall be determined in accordance with statutory acts of the Republic of Cyprus

and the European Union. The Company shall be entitled to provide the Client with information contained in such notice in the form of standard codes provided

that the Client is given explanations on how to interpret these codes.

The regulation specified in the first paragraph of this clause shall not apply in the event that the confirmation contains the same information as given in the

confirmation that is immediately forwarded by another person to a Retail Client.

16.3 The provisions of clause 16.1 and clause 16.2 hereof shall not apply in case when executed the Client’s Instructions relate to bond financing transactions

with mortgage loans with this Client. In this case a transaction statement shall be compiled at the same time as the approval of loan terms, but no later than

one month after a relevant Instruction is executed.

16.4 In addition to the presentation of statements in accordance with clause 16.1 and clause 16.2 hereof, at the Client’s request, the Company shall provide

the Client with information about the status of its Instruction.

16.5 In the event of execution of a Retail Client’s Instructions that relate to fund units or equity stakes in collective investment businesses that are executed

periodically, the Company shall provide the Client with a report in accordance with clause 16.2. hereof or shall be entitled to provide the Client with information

under said transactions no less than every six months.

16.6 Within the first 10 (ten) working days following the reporting month, and also in the event that the Company receives the Client’s notice about the

termination of the Brokerage Agreement, the Company shall provide the Client with a report on the Company’s performance in accordance with these

Regulations for the past calendar month, and also information about the Client’s monetary funds on the Cash Account and the status of the Securities

Account/Custodian Account through the Company’s website (for the Client to view information in the personal section (Review Your Account section) using the

login and the password that were given to the Client at the time when the Brokerage Agreement was signed) and/or in other durable medium.

The Client may express disagreement with information provided within 10 (ten) days after the Company submits/forwards this information.

The Parties hereby agree that if the Client does not express a disagreement with the information provided by the Company within the aforementioned

deadline, this shall imply the Client’s consent with respect to all information contained in the report and the report shall be deemed accepted by the Client

without remarks.

16.7 At the Client’s request, the Company shall also send the Client by fax or using other electronic means updated information related to the indicators of the

trading activity, net positions and the estimate of the market value of the Portfolio, as determined in good faith by the Company, and also a statement on movements of the Client’s cash on the Cash Account. The Client may express its disagreement with information presented within 10 (ten) working days after

such information is forwarded by the Company.

If within the aforementioned deadline the Client does not express a disagreement with the information provided by the Company, this shall mean the Client’s

consent with respect to all the information provided.

16.8 The Client and the Company hereby agree that with regard to transactions and other operations on the securities market, trading in which the Client

selected (uses) Internet Trading System(s), specified in Appendices 2.1 and 2.2, the Company’s reports to the Client and other information in accordance with

clauses 16.6 and 16.7 hereof shall not be provided. The Company’s reports to the Client and other information shall be provided to the Client using said Online

Trading System(s) in the format and to the extent envisaged by this (these) system(s) and/or through the Company’s website.

The Client confirms that when choosing whether to receive the Broker’s reports under these Regulations as a hard copy or through Online Trading System(s),

the Client shall select the latter.

16.9 The Company shall perform operations during normal business hours and within this period of time the Client shall have the right to receive all real

facilities, as well as assistance from other authorized representatives in order to verify and confirm the Company’s reports on investments and securities held

in the Portfolio.

17. Confidentiality

17.1. The Company shall, unless ithas been established by law or any other statutory and legal document; oris necessary for settlements; oris permitted in

writing by the Clientwarrant that any and all unofficial information related to the Portfolio shall be kept by the Company as strictly confidential. Notwithstanding

the foregoing, the Company’s consolidated records on transactions executed may include information related to the trading results of the Securities, which

form the Portfolio, with no indication of the Client’s name.17.2. Both Parties, including their representatives, agents, attorney.



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