Common use of Client Money Clause in Contracts

Client Money. 40.1 Any money received by us in respect of your account with us shall be treated as Client Money except where you separately agree with us to transfer full ownership of money to us for, amongst other things, the purpose of securing or otherwise covering present or future, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, in which circumstances such money will not be regarded as Client Money. 40.2 In relation to Client Money unless you notify us in writing, or otherwise, we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts and by entering into these Terms you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and of the arrangements for holding your money, in accordance with the CMA Regulations. We will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clients. Claimants to money held in pooled accounts have a claim to a rateable proportion of the money held in that pool. 40.5 We may pass money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) to hold or control in order to make a transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide margin) in respect of a transaction. 40.6 Although we will remain responsible for money received from you even if we pass it to a third party, you may be exposed to the additional risk that, in the event of an insolvency or similar in relation to that third party, the amount of money received by us from the third party may not be sufficient to satisfy your claims. We may transfer any money we hold for you as Client Money (after deduction of any amounts permitted by the provisions of these Terms) to another legal entity (including any of our Group Companies), where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Regulations. 40.7 You consent to us releasing any Client Money balances, for or on your behalf, from Client Money bank accounts and for us to treat as Client Money any unclaimed Client Money balance where: 40.7.1 we have determined that there has been no movement on your balance for a period of two years (notwithstanding any payments or receipts of charges, interest or similar items); and 40.7.2 we have written to you at your last known address and on a regular basis informing you of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to make a claim, provided we shall make and retain records of all balances released from our Client Money bank accounts in respect of your Client Money and undertake to make good any valid claims against any released balances.

Client Money. 40.1 Any 11.1 In accordance with the Applicable Rules and Regulations, we will hold all money received from you in accordance with the FCA’s Client Money Rules (the “Client Money Rules”). 11.2 Subject to Clause 11.3 below, any money transferred to us by you, will be held by us on trust for you and will be segregated from our own money. It may not be used by us for the purposes of our business. In the event of our insolvency, your money will be excluded from our assets. 11.3 We may hold client money on your behalf in respect of your an account with a bank or third party. Should the third party become insolvent, or suffer a similar failure, there is a risk that the client money will be subject to the insolvency proceedings of the third party. 11.4 We shall be responsible under the Applicable Rules and Regulations for the acts or omission of any third party in relation to your client money. Should such a third party become insolvent, you would still have recourse against us shall under the Applicable Rules and Regulations. 11.5 If you have been classified as a Professional Client or an Eligible Counterparty by us, we may agree, in accordance with the Applicable Rules and Regulations, that money we hold on your behalf may not be treated as client money and your money will not be held in accordance with the Client Money except where you separately agree with us to transfer Rules. We will acquire full ownership of any sums which are not treated as client money to us for, amongst other things, for the purpose of securing or otherwise covering present or your present, future, actual or actual, contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, in which circumstances such money will . Such sums may not be regarded as Client Money. 40.2 In relation to Client Money unless you notify us in writing, or otherwise, we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately segregated from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts our own account and by entering into these Terms you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and used by us for the purposes of the arrangements for holding your money, in accordance with the CMA Regulationsour business. We You will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) rank as a general creditor of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clients. Claimants to money held in pooled accounts have a claim to a rateable proportion of the money held in that pool. 40.5 We may pass money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) to hold or control in order to make a transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide margin) our firm only in respect of a transactionthis money in the unlikely event of our insolvency. 40.6 Although we will remain responsible for 11.6 We do not pay interest to clients on any client money received from you even if we pass it to a third party, you may be exposed to the additional risk that, in the event of an insolvency or similar in relation to that third party, the amount of money received by us from the third party may not be sufficient to satisfy your claims. We may transfer any money we hold for you as Client Money (after deduction of any amounts permitted by the provisions of these Terms) to another legal entity (including any of our Group Companies), where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Regulationsus. 40.7 11.7 You consent will not grant any security interest in or over your Account, or the money in it, to us releasing any Client Money balances, for or on your behalf, from Client Money bank accounts and for us to treat as Client Money any unclaimed Client Money balance where:person other than us. 40.7.1 we have determined that 11.8 If there has been no movement initiated by you in relation to your Account for a maximum period of six years, and we have been unable to trace you, through reasonable means, in relation to the balance on your balance for a period of two years (notwithstanding any payments or receipts of chargesAccount, interest or similar items); and 40.7.2 we have written you agree that such funds shall irrevocably be transferred to you at your last known address and on a regular basis informing you of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to make a claim, provided we shall make and retain records of all balances released from our us. In accordance with the FCA Client Money bank accounts in respect of Rules we will donate these funds to charity; either after the six-year period has elapsed or earlier with your Client Money and undertake authorisation if we are able to make good any valid claims against any released balancestrace you. We shall apply the principle to your funds known as “de minimis” on your Account.

Client Money. 40.1 Any 33.1 Unless otherwise agreed in writing, we will hold your money received in an account at a bank or other financial institution chosen by us in respect accordance with the Securities Industry Regulations and subject to and in accordance with this Agreement. 33.2 We may, subject to our legal and regulatory requirements, hold client money in a client money bank account located outside the jurisdiction of Bahamas. The legal and regulatory regime applying to any such bank will be different from that of the Bahamas and in the event of the insolvency or any other equivalent failure of that bank, your money may be treated differently from the treatment which would apply if the money was held with a bank in Bahamas. 33.3 Although we will take reasonable care in the selection of a bank or financial institution for the purposes of clauses 33.1 and 33.2, we accept no responsibility for the solvency of the bank or other financial institution and to the extent that part or all of your account with us shall money is lost by reason of the partial or complete failure of the bank or other financial institution the loss will be treated as Client Money except where you separately agree with us to transfer full ownership of borne by you, not us. 33.4 We may pass client money to us for, amongst other things, the purpose of securing or otherwise covering present or future, actual or contingent or prospective obligationsallow another third party, such as Margin posted an exchange, marketplace, a clearing house, an intermediate broker, a group company, to hold or control client money when: (i) it is for the purposes of clients’ Transactions, payments or withdrawals through or with relevant liquidity providers at an equivalent valuethat third party; or (ii) it is to meet clients’ obligations to provide collateral for Transactions. We accept no responsibility for the solvency of that third party and to the extent that part or all of your money is lost by reason of the partial or complete failure of that third party the loss will be borne by you, in which circumstances such money will not be regarded as Client Moneyus. 40.2 In relation 33.5 You acknowledge and accept that when your money is being treated as per clause 33.4 above you are exposed to Client Money unless market risk, and we shall not hold any responsibility or liability for such market risk held by you notify us in writing, or otherwiseherein. 33.6 If you are indebted with us, we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately may deduct such debt amount from any accounts used to hold other money belonging to us. Interest will not be paid on the your money held in Client Money bank accounts with us, and only to the extend reasonably necessary to cover the indebtedness. 33.7 We do not pay interest to you on any money that we hold and by entering into these Terms the Agreement you acknowledge that you waive are waiving any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and of the arrangements for holding your money, in accordance with the CMA Regulations. We will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clients. Claimants to money held in pooled accounts have a claim to a rateable proportion of the money held in that pool. 40.5 We may pass money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) to hold or control in order to make a transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide margin) in respect of a transaction. 40.6 Although we will remain responsible for money received from you even if we pass it to a third party, you may be exposed to the additional risk 33.8 You agree that, in the event of an insolvency or similar in relation to that third party, the amount of money received by us from the third party may not be sufficient to satisfy your claims. We may transfer any money we hold for you as Client Money (after deduction of any amounts permitted by the provisions of these Terms) to another legal entity (including any of our Group Companies), where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Regulations. 40.7 You consent to us releasing any Client Money balances, for or on your behalf, from Client Money bank accounts and for us to treat as Client Money any unclaimed Client Money balance where: 40.7.1 we have determined that there has been no movement on your balance account for a period of two at least six years (notwithstanding any payments or receipts apart from adjustments in respect of charges, interest or similar items); and 40.7.2 other items that do not stem from Transactions or cash payments made by you to us) and we have written are unable to trace you at despite having taken reasonable steps to do so, we may cease to treat your last known address and on money as client money and/or donate it to a regular basis informing you registered charity of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to make a claim, provided we shall make and retain records of all balances released from our Client Money bank accounts in respect of your Client Money and undertake to make good any valid claims against any released balanceschoice.

Client Money. 40.1 Any money received by us in respect of your account 11.1 In accordance with us shall be treated as Client Money except where you separately agree with us to transfer full ownership of money to us for, amongst other things, the purpose of securing or otherwise covering present or future, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, in which circumstances such money will not be regarded as Client Money. 40.2 In relation to Client Money unless you notify us in writing, or otherwiseApplicable Rules and Regulations, we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts and by entering into these Terms you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and of the arrangements for holding your money, in accordance with the CMA Regulations. We will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clients. Claimants to money held in pooled accounts have a claim to a rateable proportion of the money held in that pool. 40.5 We may pass money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) to hold or control in order to make a transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide margin) in respect of a transaction. 40.6 Although we will remain responsible for money received from you even if we pass it to a third party, you may be exposed to the additional risk that, in the event of an insolvency or similar in relation to that third party, the amount of money received by us from the third party may not be sufficient to satisfy your claims. We may transfer any money we hold for you as Client Money (after deduction of any amounts permitted by the provisions of these Terms) to another legal entity (including any of our Group Companies), where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Securities Industry Regulations. 40.7 You consent 11.2 Subject to Clause 11.3 below, any money transferred to us releasing any Client Money balancesby you, for or on your behalf, will be held by us on trust for you and will be segregated from Client Money our own money. In the event of our insolvency, your money will be excluded from our assets. 11.3 We may hold client money on your behalf in an account with a bank accounts or third party. Should the third party become insolvent, or suffer a similar failure, there is a risk that the client money will be subject to the insolvency proceedings of the third party. 11.4 We may hold client money on your behalf in an account with a bank or third party located outside of the Bahamas. Where the third party is subject to the charges of a jurisdiction other than that of the Bahamas, the legal and regulatory rights and protections which apply to your client money will be different to those applicable in the Bahamas. Should the third party become insolvent or suffer a similar failure, these rights and protections may not be as effective in protecting your money as the law of the Bahamas. 11.5 We shall be responsible under the Applicable Rules and Regulations for the acts or omission of any third party in relation to your client money. Should such third party become insolvent, you would still have recourse against us to treat as Client Money any unclaimed Client Money balance where:under the Applicable Rules and Regulations. 40.7.1 11.6 Unless we have determined that otherwise agreed, we will not pay interest on any money held by us. 11.7 You will not grant any security interest in or over your account, or the money in it, to any person other than us. 11.8 If there has been no movement on initiated by you in relation to your balance account for a period of two years (notwithstanding any payments or receipts of chargessix years, interest or similar items); and 40.7.2 and we have written been unable to trace you at in relation to the balance on your last known address and on a regular basis informing account, you of our intention of no longer treating agree that balance as Client Money, giving you Twenty- eight (28) Business Days such funds shall irrevocably be transferred to make a claim, provided we shall make and retain records of all balances released from our Client Money bank accounts in respect of your Client Money and undertake to make good any valid claims against any released balancesus.

Client Money. 40.1 ‌ 31.1 Any money received by us in respect of your account with us shall be treated as Client Money except where you separately agree with us to transfer full ownership of money to us for, amongst other things, the purpose of securing or otherwise covering present or future, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, and be held in which circumstances such money will not be regarded as Client Moneytrust. 40.2 31.2 In relation to Client Money unless you notify us in writing, writing or otherwise, otherwise we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in the Client Money bank accounts and by entering into these Terms this Agreement you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwisemoney. 40.3 31.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations diligence when selecting which third party bank banks and brokers to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank banks and brokers where your money is or may be deposited and of the arrangements for holding your money, in accordance with the CMA Regulations. We will not be responsible for any acts, omissions or default (including the insolvency, administration, judicial management, bankruptcy or similar event) of the third-third party bank banks or brokers for any resulting shortfall or loss in the return of your money. 40.4 31.4 The Client Money account accounts will be a pooled account accounts and holds the Client Money relating to a number of clients. Claimants to money held in pooled accounts have a claim to a rateable ratable proportion of the money held in that pool. 40.5 31.5 We may and/or our Group Companies uses only its own funds for hedging and does not pass client money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) to hold or control in order to make a transaction through or with that person hedging counterparties or to satisfy your obligation to provide a deposit (such any part of the business as an initial requirement that you provide margin) working capital. We and/or our Group Companies does not initiate speculative positions in respect of a transactionthe market. 40.6 Although we will remain responsible for money received from you even if we pass it to a third party, you may be exposed to the additional risk that, in the event of an insolvency or similar in relation to that third party, the amount of money received by us from the third party may not be sufficient to satisfy your claims. 31.6 We may transfer any money we hold for you as Client Money (after deduction of any amounts permitted by the provisions terms of these Terms) to another legal entity (including any of our Group Companies), ) where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, clause 31.6 we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Regulationsthis Agreement. 40.7 31.7 In the event that the account you hold with us is a joint account, we do exercise all due care and diligence to ensure that all withdrawals are paid back to its source and to the particular party that initiated the actual deposit. In case of profit payments and/or withdrawals, We and/or our Group Companies may initiate payments to any party to the joint account provided that it has received appropriate approval from the other party and it is satisfied pursuant to its due diligence verification and checks. 31.8 You consent to us releasing any Client Money balances, for or on your behalf, from Client Money bank accounts and for us to cease to treat as Client Money any unclaimed Client Money balance where: 40.7.1 31.8.1 it is permitted by law and consistent with the arrangements under which Client Money is held; 31.8.2 we have determined that there has been no movement on your balance for a period of two six years (notwithstanding any payments or receipts of charges, interest or similar items); 31.8.3 we have taken reasonable steps to trace you and to return the balance to you; and 40.7.2 31.8.4 we have written to you at your last known address and on a regular basis informing you of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to make a claim, provided we shall make and retain records of all balances released from our Client Money bank accounts in respect of your Client Money and undertake Money. All unclaimed money will be paid to make good any valid claims against any released balancesthe Registrar of Unclaimed Moneys in accordance with the Unclaimed Moneys Xxx 0000 [Act 370].

Client Money. 40.1 Any (1) We will treat money received from you or held by us on your behalf in accordance with the Client Money Rules. (2) Subject to Term 18(6) below, your money shall be held in pooled client bank accounts at selected third party banking institutions as determined by us in respect accordance with the Client Money Rules. We will keep and maintain books and records of the client money held on your behalf. We will provide you with statements of the client money that we hold on your behalf in accordance with the Client Money Rules. Subject to the Client Money Rules, you may request such a statement at any time subject to you agreeing that we may levy an administration charge to cover our costs in providing any such statement to you. We may place funds in notice or term deposit accounts with a notice period or term of up to 95 days. Placing client money in notice or term deposit accounts does not in itself affect your ability to deal with or withdraw funds from your account with us shall us, however in the unlikely event of insolvency of IG, such amounts may not be immediately available upon request. (3) We may hold client money in a client bank account with a bank located outside Saint Xxxxxxx and the Grenadines. The legal and regulatory regime applying to any such bank will be different from that of Saint Xxxxxxx and the Grenadines and in the event of the insolvency or any other equivalent failure of that bank, your money may be treated as Client Money except where you separately agree differently from the treatment which would apply if the money was held with us to transfer full ownership of money to us for, amongst other things, a bank in Saint Xxxxxxx and the purpose of securing or otherwise covering present or future, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, in which circumstances such money Grenadines. We will not be regarded as Client Moneyliable for the insolvency, acts or omissions of any bank or other third party holding money under Terms 18(1), 18(2) or 18(3). 40.2 In relation (4) It is not our policy to Client Money unless pay interest to you notify us in writing, or otherwise, on any client money that we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts your behalf and by entering into these Terms this Agreement you acknowledge that you therefore waive any entitlement to interest on such money under the CMA Regulations Client Money Rules or otherwise. 40.3 We will exercise all due skill, care and diligence, . In the event that we incur interest charges to hold client money on your behalf with third party banking institutions or qualifying money market funds in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or Client Money Rules, you agree that we may be deposited and of the arrangements charge you for holding client money on your money, behalf in accordance with the CMA Regulations. We will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The our Client Money account Interest Policy. You agree that we may cease to treat any money deducted in accordance with our Client Money Interest Policy as client money and that ownership of that money will be a pooled account and holds irrevocably transferred from you to us. Details of the Client Money relating to a number Interest Policy are available in the Product Details or from one of clients. Claimants to money held in pooled accounts have a claim to a rateable proportion of the money held in that poolour employees. 40.5 We may pass money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house5) to hold or control in order to make a transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide margin) in respect of a transaction. 40.6 Although we will remain responsible for money received from you even if we pass it to a third party, you may be exposed to the additional risk that, in In the event of an insolvency or similar in relation to that third party, the amount of money received by us from the third party may not be sufficient to satisfy your claims. We may transfer any money we hold for you as Client Money (after deduction of any amounts permitted by the provisions of these Terms) to another legal entity (including any of our Group Companies), where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Regulations. 40.7 You consent to us releasing any Client Money balances, for or on your behalf, from Client Money bank accounts and for us to treat as Client Money any unclaimed Client Money balance where: 40.7.1 we have determined that there has been no movement on your account balance for a period of two at least six years (notwithstanding any payments or receipts of charges, interest or similar items) and we are unable to trace you despite having taken reasonable steps to do so, you agree that we may cease to treat your money as client money and pay away the money to a registered charity. In such circumstances, we (or an Associated Company of ours) will unconditionally undertake to pay you a sum equal to the relevant client money balance paid away in the event that you seek to claim the client money balance in the future. (6) We may hold client money in a qualifying money market fund and notify you that such money will not be held as client money in accordance with the Client Money Rules and the units or shares in any qualifying money market fund will be held as safe custody assets in accordance with the provisions of the Client Money Rules that relate to the holding of assets in custody by investment firms like ourselves on behalf of clients. You explicitly consent that your client money may be held in such a fund. If you withdraw your consent by notifying us in accordance with Term 14(10); and, we will take steps to remove your money from any money market fund as soon as reasonably practicable, taking into account any restrictions that apply to the withdrawal of money from the relevant fund. 40.7.2 (7) In accordance with Term 27(3), you specifically agree that we have written may transfer client money to you at your last known address and on a regular basis informing you third party as part of a transfer of all or part of our intention business. Any sums transferred will be held by that third party either in accordance with the Client Money Rules, or if the sums will not be held in accordance with the Client Money Rules, we will exercise all due skill, care and diligence in assessing whether adequate measures will be applied by the third party to protect the sums. (8) This Term applies if you have been categorised as a Sophisticated Person. Following appropriate disclosure of the risks by us to you, you and we may agree that you do not require money which is transferred by you to us to be held in accordance with the Client Money Rules. Any such agreement must be in our agreed form and signed by you and may be provided to us by post or by scanned copy sent to us by email. Following such an agreement, we will treat any transfer of money by you to us as a transfer of full ownership of money to us for the purpose of securing or covering your present, future, actual, contingent or prospective obligations, and we will not hold such money in accordance with the Client Money Rules. Because title of the money has passed to us, you will no longer treating have a proprietary claim over money transferred to us and we can deal with it in our own right, and you will rank as a general creditor of ours. By placing money with us under a title transfer agreement, you agree that balance as Client Moneyall money you place on your account is done so in anticipation of a Transaction and therefore has the purpose of securing or covering your present, giving you Twenty- eight (28) Business Days future, actual, contingent or prospective obligations to make a claimus. You should not place any money with us that is not for the purpose of securing or covering your present, provided we shall make and retain records of all balances released from our Client Money bank accounts in respect of your Client Money and undertake future, actual, contingent or prospective obligations to make good any valid claims against any released balancesus.

Client Money. 40.1 Any a) We have categorized you as a private client and therefore in accordance with applicable law and subject to clauses 20.1b and 20.1c we will place an amount equal to your Total Equity (as displayed on the platform) into a client money received bank account. We will deal with your money in accordance with CIMA’s Client Money Rules and Statement of Guidance, which require us to hold it in a client bank account, separating your funds from ours. Such money may be held by us a bank with other clients’ money in respect of a pooled client account. b) We may hold Client Money on your behalf in an account with us shall an approved bank or third party which may be treated as Client Money except where located inside or outside the Cayman Islands. Any such account will be segregated from any account in which our own money or assets is held with the bank or third party but may be subject to set-off rights of the bank or third party. The legal and regulatory regime applying to any bank or third party located outside the Cayman Islands may be different from that of the Cayman Islands. You should consider taking independent legal advice if you separately agree with us to transfer full ownership are concerned by the implications of money to us forbeing held with an approved bank, amongst or third party as permitted by clause 20.1c, which may be located inside or outside of the Cayman Islands c) Where any bank or other things, the purpose of securing or otherwise covering present or future, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, in which circumstances such permitted third party holds money under this clause (a) we will not be regarded as Client Money. 40.2 In liable for the acts or omissions of, or failure or insolvency or any analogous event affecting, such entity; and (b) in the event of the insolvency or other analogous proceeding in relation to Client Money unless you notify us in writing, or otherwisesuch entity, we will promptly pay any Client Money received to may have only an unsecured claim against such entity on behalf of you and our Client Money bank accounts. Our Client Money accounts will be identified other clients, and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts and by entering into these Terms you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and of the arrangements for holding your money, in accordance with the CMA Regulations. We will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clients. Claimants to money held in pooled accounts have a claim to a rateable proportion of the money held in that pool. 40.5 We may pass money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) to hold or control in order to make a transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide margin) in respect of a transaction. 40.6 Although we will remain responsible for money received from you even if we pass it to a third party, you may be exposed to the additional risk that, in that the event of an insolvency or similar in relation to that third party, the amount of money received recovered by us from the third party may not be sufficient such entity is insufficient to satisfy the claims of you and all other clients with claims in respect of the relevant account. d) We will carry out reconciliations at the close of business on each Business Day between money required to be held in the client money bank account and money that may be held on our own account in accordance with CIMA Rules and Statement of Guidance, and any required transfer to or from the client money bank account in respect of your claimsAccount will take place on the following Business Day. We may transfer any money carry out such reconciliations and transfers more frequently, should we hold for you as Client Money (after deduction of any amounts permitted by the provisions of these Terms) reasonably consider that this is necessary to another legal entity (including any of protect our Group Companies), where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Regulationsinterests. 40.7 e) You consent agree that we may cease to us releasing any Client Money balances, for or treat money held on your behalfbehalf as client money and release it from our client money bank account(s), i. if you have no positions and have not placed a trade in the previous six (6) years, from Client Money bank accounts and for us to treat as Client Money any unclaimed Client Money balance where: 40.7.1 we have determined that there has been no movement on your balance for a period of two years (notwithstanding any payments or receipts of chargestaken reasonable steps but were unable to contact you. Such money will, interest or similar items); and 40.7.2 we have written however, remain owing to you at your last known address and on a regular basis informing you of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to make a claim, provided we shall will make and retain all records of all balances released from our Client Money client money bank accounts in respect of your Client Money under this clause and will undertake to make good any valid claims against any such released balances. ii. If any amounts owed by you to us under the Agreement are due and payable to us, in accordance with the Client Money Rules we shall cease to treat as Client Money so much of any Client Money held on your behalf as equals the those amounts. You agree that we may apply that money in or towards satisfaction of all or part of those amounts due and payable to us. For the purposes of this clause, any such amounts owed by you to us under this Agreement become immediately due and payable, without notice or demand by us, when incurred by you or on your behalf. f) We will not pay interest to you on any money held on your behalf or otherwise under clauses 20.1a, 20.1b, 20.1c or 20.1d. g) In this clause 20.1 “Client Money Rules” means the provisions of the Securities Investment Business (Conduct of Business) Regulations, 2003 of the Cayman Islands and associated Rules and Statements of Guidance, as amended and/or updated from time to time, relating to Client Money held by firms carrying out activities regulated under the SIBL.

Client Money. 40.1 Any Unless otherwise specifically stated in these Terms or as provided under Applicable Law, your money received by us in respect of your account with us shall will be treated held as Client Money except where you separately agree in accordance with us to transfer full ownership of money to us forthe FCA Rules which, amongst among other things, the purpose require us to hold your money in a client bank account which is free of securing or otherwise covering present or futurelien and set up with statutory trust status, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent valueApproved Bank or CRD Credit Institution. This means we will separate your funds from our own funds and we may hold your money with the money of other customers in a pooled account, in which circumstances such money will not be regarded has been named as Client Money. 40.2 In relation a client bank account. When selecting which third party bank to Client Money unless you notify us in writing, or otherwiseuse, we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts and by entering into these Terms you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We diligence and will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and of the arrangements for holding your money, in accordance with the CMA RegulationsFCA Rules. We will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clients. Claimants to money held in pooled accounts have a claim to a rateable proportion of the money held in that pool. 40.5 We may pass money received from you to a third party (e.g. a marketbank. If necessary, intermediate brokerwe may also allow another institution such as an exchange, OTC counterparty or clearing house) , overseas settlement agent or other intermediate broker to hold or control in order to make your money, but only if we transfer your money for the purpose of a transaction through or with that person or to satisfy your meet any obligation that you may have to provide a deposit collateral (such as an initial requirement that you provide for example, margin) in respect of for a transaction. 40.6 Although . If we do this and where required to do so under the FCA Rules, we will remain responsible endeavour to ensure your money is held as Client Money under the FCA Rules. In the event of our failure (for example due to our bankruptcy or insolvency), any money received held in a Client Money account by third parties will be segregated from you even if we pass it our assets and will not be available to a third party, you may be exposed to the additional risk thatour creditors. However, in the event of an insolvency or similar in relation to that failure of a third party, the amount there may be a number of consequences for your investment which may include: (a) UK bank accounts: if we place your money received by us from the in a UK account with a third party may not be sufficient to satisfy party, because your claims. We may transfer any money we hold for you as Client Money (after deduction of any amounts permitted by the provisions of these Terms) to another legal entity (including any of our Group Companies), where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Regulations. 40.7 You consent to us releasing any other customers’ Client Money balances, for or on your behalf, from in a pooled Client Money account, in the event that the third party credit institution or bank holding the money defaults and there is a shortfall, you will share proportionately in that shortfall with other creditors of the credit institution or bank; (b) Non-UK bank accounts: in addition to any shortfalls through the pooling of accounts as described above, where your money is required to be held in a bank located outside the UK, you should be aware that the legal and for us regulatory regimes (including any associated protections) that apply to treat as Client Money any unclaimed Client Money balance where: 40.7.1 we have determined that there has been no movement on the bank holding your balance for money may be different to those of the UK. In the event of the bank’s failure, your rights and obligations may differ and your money could be less secure and treated differently from the position which would apply if the money were held in a period of two years (notwithstanding any payments or receipts of charges, interest or similar items)customer bank account in the UK; and 40.7.2 we have written to you at your last known address and on a regular basis informing you of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to make a claim, provided we shall make and retain records of all balances released from our Client Money bank accounts in respect of your Client Money and undertake to make good any valid claims against any released balances.or

Client Money. 40.1 Any money received 16.1. Money held by us in respect of on your account with us shall behalf will be treated as Client Money except where you separately agree with us to transfer full ownership client money within the meaning of money to us for, amongst other things, the purpose of securing or otherwise covering present or future, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, in which circumstances such money will not be regarded as Client Money. 40.2 In relation to Client Money unless you notify us in writing, or otherwise, we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts and by entering into these Terms you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and of the arrangements for holding your money, in accordance with the CMA Regulations. We will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clientsRules. Claimants to Your money will be held in pooled accounts have a claim to a rateable proportion of the money held in that poolsegregated client account at our custodian bank. 40.5 16.2. We may pass money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) house to hold or control in order to make a transaction Transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide marginMargin) in respect of a transaction. 40.6 Transaction. Although we will remain responsible for money received from you even if we pass it to a third party, you may be exposed to the additional risk that, in the event of an insolvency or similar in relation to that third party, the amount of money received by us from the third party may not be sufficient to satisfy your claims. However, you may still be able to claim against us for any outstanding amounts. 16.3. We may transfer hold client money on your behalf outside the Bahamas. The legal and regulatory regime applying to any bank or person that holds your money we hold outside the Bahamas will be different from that of the Bahamas. As a result, should that bank go into insolvency or similar proceedings, your money may be treated differently than it would have been if the money was held with a bank in the Bahamas. We will not be liable for you as Client Money (after deduction the insolvency, acts or omissions of any amounts permitted by third party referred to in this sub-clause. 16.4. In the provisions event that funds need to be transferred between ActivTrades PLC (London parent entity) and ActivTrades Corp (Bahamas subsidiary) you give us the permission to do so. This will also apply to any current account(s) that you may have with ActivTrades PLC (London). The transfer will only take place from ActivTrades PLC to ActivTrades Corp and not the vice versa. Funds will only be transferred when necessary. We understand that the data being sent is sensitive, and will only be shared between ActivTrades PLC and ActivTrades Corp and is protected under the Data Protection Laws of these Terms) both jurisdictions and allows us to another legal entity (including any of our Group Companies), where we transfer all or part of our business to that entity and your Client comply with Anti-Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Laundering Regulations. 40.7 You 16.5. To avoid doubt, we will not pay interest on any amounts in your account, unless we have agreed to do so in writing. Unless we have agreed otherwise in writing, on signing this Agreement, you consent to us releasing the fact that no interest will be paid to you on any Client Money balancesamounts in your account(s) and that we will retain any such interest. 16.6. You agree that, for or on your behalf, from Client Money bank accounts and for us to treat as Client Money any unclaimed Client Money balance where: 40.7.1 we have determined in the event that there has been no movement on your account balance for a period of two at least six years (notwithstanding not with standing any payments or receipts of charges, interest charges or similar items); and) and we are unable to trace you and return your account balance to you, despite having taken all reasonable steps to do so, we may cease to treat your money as client money and accordingly release any client money balances from the segregated client account pursuant to any local regulatory protocols applicable to ‘dormant accounts’. 40.7.2 we have written to 16.7. If your trading account remains unused for at least one year, you at your last known address and on will be treated as a regular basis informing you dormant customer. This will attract an administration fee of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to make a claim, provided we shall make and retain records of all balances released from our Client Money bank accounts £10 in respect the currency of your Client Money and undertake account per calendar month to make good cover our costs of maintaining the dormant account. We reserve the right to amend such fees. You will be informed of any valid claims against any released balancessuch changes. Note that the administration fee cannot reduce the balance of your account(s) below zero.

Client Money. 40.1 Any 10.1. In accordance with the Applicable Rules and Regulations, we will hold all money received from you in accordance with the Financial Conduct Authority’s Client Money Rules (the “Client Money Rules”). Retail Clients 10.2. Subject to Clause 11.3 below, any money transferred to us by you, or on your behalf, will be held by us on trust for you and will be segregated from our own money. It may not be used by us for the purposes of our business. In the event of our insolvency, your money will be excluded from our assets. 10.3. We may hold client money on your behalf in respect of your an account with a bank or third party. Should the third party become insolvent, or suffer a similar failure, there is a risk that the client money will be subject to the insolvency proceedings of the third party. 10.4. We may hold client money on your behalf in an account with a bank or third party located outside of the European Economic Area (“EEA”). Where the third party is subject to the law of a jurisdiction other than that of an EEA State, the legal and regulatory rights and protections which apply to your client money will be different to those applicable in the EEA. Should the third party become insolvent or suffer a similar failure, these rights and protections may not be as effective in protecting your money as the law of an EEA State. 10.5. We shall be responsible under the Applicable Rules and Regulations for the acts or omission of any third party in relation to your client money. Should such third party become insolvent, you would still have recourse against us under the Applicable Rules and Regulations. Professional Clients and Eligible Counterparties 10.6. If you have been classified as a Professional Client or an Eligible Counterparty, we may agree, in accordance with the Applicable Rules and Regulations, that money we hold on your behalf shall not be treated as client money and your money will not be held in accordance with the Client Money except where you separately agree with us to transfer Rules. We will acquire full ownership of any sums which are not treated as client money to us for, amongst other things, for the purpose of securing or otherwise covering present or your present, future, actual or actual, contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, in which circumstances such money . Such sums will not be regarded as Client Money. 40.2 In relation to Client Money unless you notify us in writing, or otherwise, we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately segregated from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts our own account(s) and by entering into these Terms you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and used by us for the purposes of the arrangements for holding your money, in accordance with the CMA Regulationsour business. We You will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) rank as a general creditor of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clients. Claimants to money held in pooled accounts have a claim to a rateable proportion of the money held in that pool. 40.5 We may pass money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) to hold or control in order to make a transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide margin) our firm only in respect of a transaction. 40.6 Although we will remain responsible for this money received from you even if we pass it to a third party, you may be exposed to the additional risk that, in the event of an insolvency or similar in relation to that third party, the amount of money received by us from the third party may not be sufficient to satisfy your claimsour insolvency. General 10.7. We may transfer do not pay interest on any money we hold for you as Client Money (after deduction of any amounts permitted by the provisions of these Terms) to another legal entity (including any of our Group Companies), where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Regulationsus. 40.7 10.8. You consent will not grant any security interest in or over your account, or the money in it, to us releasing any Client Money balances, for or on your behalf, from Client Money bank accounts and for us to treat as Client Money any unclaimed Client Money balance where:person other than us. 40.7.1 we have determined that 10.9. If there has been no movement on initiated by you in relation to your balance account for a period of two years (notwithstanding any payments or receipts of chargessix years, interest or similar items); and 40.7.2 and we have written been unable to trace you at in relation to the balance on your last known address and on a regular basis informing account, you of our intention of no longer treating agree that balance as Client Money, giving you Twenty- eight (28) Business Days such funds shall irrevocably be transferred to make a claim, provided we shall make and retain records of all balances released from our Client Money bank accounts in respect of your Client Money and undertake to make good any valid claims against any released balancesus.

Client Money. 40.1 Any (1) We will treat money received from you or held by us on your behalf in accordance with the Client Money Rules. (2) Your money shall be held in pooled client bank accounts at selected third party banking institutions as determined by us in respect accordance with the Client Money Rules. We will keep and maintain books and records of the client money held on your behalf. We will provide you with Statements of the client money that we hold on your behalf in accordance with the Client Money Rules. Subject to the Client Money Rules, you may request such a Statement at any time subject to you agreeing that we may levy an administration charge to cover our costs in providing any such Statement to you. We may place funds in notice or term deposit accounts with a notice period or term of up to 95 days. Placing client money in notice or term deposit accounts does not in itself affect your ability to deal with or withdraw funds from your account with us shall us, however such amounts may not be immediately available upon request. (3) We may hold client money in a client bank account with a bank located in any country. The legal and regulatory regime applying to any such bank will be different from that of your home country, or of our country of registration, and in the event of insolvency or any other equivalent failure of that bank, your money may be treated as differently from the treatment which would apply if the money was held with a bank in your home country. We will not be liable for the insolvency, acts or omissions of any bank or other third party holding money. (4) It is not our policy to pay interest to you on any client money that we hold on your behalf and by entering into this Agreement you acknowledge that you therefore waive any entitlement to interest under the Client Money except where Rules or otherwise. In the event that we incur interest Charges to hold client money on your behalf with third party banking institutions or qualifying money market funds in accordance with the Client Money Rules, you separately agree with us that we may charge you for holding client money on your behalf. You agree that we may cease to transfer full treat any money deducted as client money and that ownership of that money will be irrevocably transferred from you to us. (5) In the event that there has been no movement on your account balance for a period of at least six years (notwithstanding any payments or receipts of Charges, interest or similar items) and we are unable to trace you despite having taken reasonable steps to do so, you agree that we may cease to treat your money as client money and pay away the money to us for, amongst other things, the purpose of securing or otherwise covering present or future, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, a registered charity. (6) We may hold client money in which circumstances a qualifying money market fund and notify you that such money will not be regarded held as Client Money. 40.2 In relation to client money in accordance with the Client Money unless Rules and the units or shares in any qualifying money market fund will be held as safe custody assets in accordance with the provisions of the FSA Rules that relate to the holding of assets in custody by investment firms like ourselves on behalf of clients. You explicitly consent that your client money may be held in such a fund. If you notify us in writing, or otherwisewithdraw your consent by notifying us, we will promptly pay take steps to remove your money from any money market fund as soon as reasonably practicable, considering any restrictions that apply to the withdrawal of money from the relevant fund. (7) You specifically agree that we may transfer client money to a third party as part of a transfer of all or part of our business. Any sums transferred will be held by that third party either in accordance with the Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately from any accounts used to hold other money belonging to us. Interest Rules, or if the sums will not be paid on the money held in accordance with the Client Money bank accounts and by entering into these Terms you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We Rules, we will exercise all due skill, care and diligencediligence in assessing whether adequate measures will be applied by the third party to protect the sums. (8) This term applies if you have been categorized as a Professional Client only. We will treat any transfer of money by you to us as a transfer of full ownership of money to us for the purpose of securing or covering your present, future, actual, contingent or prospective obligations, and we will not hold such money in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and of the arrangements for holding your money, in accordance with the CMA Regulations. We will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clientsRules. Claimants to money held in pooled accounts have a claim to a rateable proportion Because title of the money held has passed to us, you will no longer have a proprietary claim over money transferred to us and we can deal with it in our own right, and you will rank as a general creditor of ours. By placing money with us, you agree that pool. 40.5 We may pass all money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) to hold or control place on your account is done so in order to make a transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide margin) in respect anticipation of a transaction. 40.6 Although we will remain responsible for money received from you even if we pass it Transaction and therefore has the purpose of securing or covering your present, future, actual, contingent or prospective obligations to a third party, you may be exposed to the additional risk that, in the event of an insolvency or similar in relation to that third party, the amount of money received by us from the third party may us. You should not be sufficient to satisfy your claims. We may transfer place any money we hold with us that is not for you as Client Money (after deduction the purpose of any amounts permitted by the provisions of these Terms) securing or covering your present, future, actual, contingent or prospective obligations to another legal entity (including any of our Group Companies), where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Regulationsus. 40.7 You consent to us releasing any Client Money balances, for or on your behalf, from Client Money bank accounts and for us to treat as Client Money any unclaimed Client Money balance where: 40.7.1 we have determined that there has been no movement on your balance for a period of two years (notwithstanding any payments or receipts of charges, interest or similar items); and 40.7.2 we have written to you at your last known address and on a regular basis informing you of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to make a claim, provided we shall make and retain records of all balances released from our Client Money bank accounts in respect of your Client Money and undertake to make good any valid claims against any released balances.

Client Money. 40.1 Any a) We have categorized you as a private client and therefore in accordance with applicable law and subject to clauses 20.1b and 20.1c we will place an amount equal to your Total Equity (as displayed on the platform) into a client money received bank account. We will deal with your money in accordance with CIMA’s Client Money Rules and Statement of Guidance, which require us to hold it in a client bank account, separating your funds from ours. Such money may be held by us a bank with other clients’ money in respect of a pooled client account. b) b) We may hold Client Money on your behalf in an account with us shall an approved bank or third party which may be treated as Client Money except where located inside or outside the Cayman Islands. Any such account will be segregated from any account in which our own money or assets is held with the bank or third party but may be subject to set-off rights of the bank or third party. The legal and regulatory regime applying to any bank or third party located outside the Cayman Islands may be different from that of the Cayman Islands. You should consider taking independent legal advice if you separately agree with us to transfer full ownership are concerned by the implications of money to us forbeing held with an approved bank, amongst or third party as permitted by clause 20.1c, which may be located inside or outside of the Cayman Islands c) c) Where any bank or other things, the purpose of securing or otherwise covering present or future, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, in which circumstances such permitted third party holds money under this clause (a) we will not be regarded as Client Money. 40.2 In liable for the acts or omissions of, or failure or insolvency or any analogous event affecting, such entity; and (b) in the event of the insolvency or other analogous proceeding in relation to Client Money unless you notify us in writing, or otherwisesuch entity, we will promptly pay any Client Money received to may have only an unsecured claim against such entity on behalf of you and our Client Money bank accounts. Our Client Money accounts will be identified other clients, and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts and by entering into these Terms you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and of the arrangements for holding your money, in accordance with the CMA Regulations. We will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clients. Claimants to money held in pooled accounts have a claim to a rateable proportion of the money held in that pool. 40.5 We may pass money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) to hold or control in order to make a transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide margin) in respect of a transaction. 40.6 Although we will remain responsible for money received from you even if we pass it to a third party, you may be exposed to the additional risk that, in that the event of an insolvency or similar in relation to that third party, the amount of money received recovered by us from the third party may not be sufficient such entity is insufficient to satisfy the claims of you and all other clients with claims in respect of the relevant account. d) We will carry out reconciliations at the close of business on each Business Day between money required to be held in the client money bank account and money that may be held on our own account, and any required transfer to or from the client money bank account in respect of your claimsAccount will take place on the following Business Day. We may transfer any money carry out such reconciliations and transfers more frequently, should we hold for you as Client Money (after deduction of any amounts permitted by the provisions of these Terms) reasonably consider that this is necessary to another legal entity (including any of protect our Group Companies), where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Regulationsinterests. 40.7 e) You consent agree that we may cease to us releasing any Client Money balances, for or treat money held on your behalfbehalf as client money and release it from our client money bank account(s), (i) if you have no positions and have not placed a trade in the previous six (6) years, from Client Money bank accounts and for us to treat as Client Money any unclaimed Client Money balance where: 40.7.1 we have determined that there has been no movement on your balance for a period of two years (notwithstanding any payments or receipts of chargestaken reasonable steps but were unable to contact you. Such money will, interest or similar items); and 40.7.2 we have written however, remain owing to you at your last known address and on a regular basis informing you of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to make a claim, provided we shall will make and retain all records of all balances released from our Client Money client money bank accounts in respect of your Client Money under this clause and will undertake to make good any valid claims against any such released balances. (ii) If any amounts owed by you to us under the Agreement are due and payable to us, in accordance with the Client Money Rules we shall cease to treat as Client Money so much of any Client Money held on your behalf as equals those amounts. You agree that we may apply that money in or towards satisfaction of all or part of those amounts due and payable to us. For the purposes of this clause, any such amounts owed by you to us under this Agreement become immediately due and payable, without notice or demand by us, when incurred by you or on your behalf. f) We will not pay interest to you on any money held on your behalf or otherwise under clauses 20.1a, 20.1b, 20.1c or 20.1d. g) In this clause 20.1 “Client Money Rules” means the provisions of the Securities Investment Business (Conduct of Business) Regulations, as amended and/or updated from time to time, relating to Client Money held by regulated firms carrying out activities.

Client Money. 40.1 Any 10.1. Subject to Section 10.11 we shall treat money held by Xxxxxxxxx on your behalf as Client Money in accordance with the CySEC Rules. Under CySEC Rules, we keep and maintain books and accounting records of the Client Money held on behalf of our Clients. 10.2. The provisions in this Agreement related to Client Money, are subject to the terms and conditions of the banks and credit institutions with which such Client Money is held and through which such funds are transferred. 10.3. We co-operate with various credit institutions. A complete list of the credit institutions with which we co-operate can be found at our Website or, where applicable, at the relevant Online Systems. 10.4. We will endeavour to hold Client Money on your behalf with authorised regulated banks or credit institutions in the Republic of Cyprus and the European Union, however we may also hold your money outside the European Union. The Client Money will be kept in bank accounts denominated as Client Money and clearly segregated from Xxxxxxxxx’s own funds. Client Money deposited may be kept in one or more omnibus accounts with any authorised regulated bank or credit institution which we will specify from time to time and will be held in our name denominated as Client Money as set out above. The legal and regulatory regime applying to any such bank or payment processing company outside the European Union will be different from the legal and regulatory regime in Cyprus and the European Union and in the event of the insolvency or any other analogous proceedings in relation to that bank or payment processing company, your money may be treated differently from the treatment which would apply if the money was held with a bank in an account in Cyprus and the European Union. We will not be liable for the insolvency, acts or omissions of any third party referred to in this clause or for any loss suffered as a result of any shortfall in any omnibus account. 10.5. We deposit Client Money held on behalf of our clients in an account and/or accounts opened with a bank or receive funds through payment processing companies, provided that we have exercised all due care, skill and diligence in the selection, appointment and periodic review of such banks and payment processing companies and of the arrangements for the holding and safekeeping of Client Money which they have in place. With regards to the deposit of Client Money, in the event we do not deposit Client Money with a central bank, we exercise all due care, skill and diligence in the selection, appointment and periodic review of the credit institution, where the funds are placed and the arrangement for the holding of those funds. We shall take into account the expertise and reputation of the bank/credit institution as well as the legal and regulatory requirements or market practices related to the holding of Client Money that could adversely affect the protection afforded to the Client Money. 10.6. We shall take all necessary measures in order to ensure that any Client Money deposited with a bank are identifiable separately from the cash belonging to Magnasale by means of differently titled accounts on the books of the bank(s) or other equivalent measures that achieve the same level of protection. Similarly, as per the requirements of the Applicable Laws and Regulations, we, on receiving any Client Money, shall promptly place those funds into one or more accounts denoted as “clients’ accounts”. We apply the same principles for payment processing companies. 10.7. Where necessary, we shall apply diversification as to where clients’ money is held, through the maintenance of accounts with several third party banks. 10.8. Magnasale may hold Client Money in omnibus accounts with financial and credit institutions. In this respect, you are hereby warned that there is a risk of loss emanating from the use of omnibus accounts in financial or credit institutions. In such case it may not be possible to distinguish if the particular Client Money is held by a certain financial or credit institution. Omnibus accounts may also hold other types of risks including legal, liquidation risk, haircut risk, third party risk, etc. 10.9. We are not responsible for the insolvency, acts or omissions of any bank, although we will take reasonable care when choosing which bank to open a Client Money account. 10.10. In the event of insolvency or any other analogous proceedings in relation to a financial or credit institution (including payment processing company) where Client Money is held, Magnasale (on behalf of the client) and/or the Client may only have an unsecured claim against the financial or credit institution, and the Client will be exposed to the risk that the money received by us Xxxxxxxxx from the financial or credit institution, is insufficient to satisfy the claims of the Client with claims in respect of your account with the account. 10.11. Notwithstanding Sections 10.1 to 10.10 above, you and us shall be treated as may in a separate agreement establish that all the money you transfer to us (or part thereof) is not subject to the Client Money except where you separately agree with us to Rules, in which case: 10.11.1. we will treat such money as a transfer of full ownership of money to us for, amongst other things, for the purpose of securing or otherwise covering present or your present, future, actual or actual, contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, in which circumstances and we will not hold such money will not be regarded as Client Money. 40.2 In relation to Client Money unless you notify us in writing, or otherwise, we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts and by entering into these Terms you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and of the arrangements for holding your money, in accordance with the CMA Regulations. We will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clientsRules; 10.11.2. Claimants to money held in pooled accounts have a claim to a rateable proportion of the money held in that pool. 40.5 We may pass money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) to hold or control in order to make a transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide margin) in respect of a transaction. 40.6 Although we will remain responsible for money received from you even if we pass it to a third party, you may be exposed to the additional risk that, in the event of an insolvency or similar in relation to that third party, the amount of any money received by us from you for your Account under the third party may not be sufficient said agreement, subject to satisfy your claims. We may transfer any money we hold for you as Client Money (after deduction of any amounts permitted by the all other provisions of these Terms) this Agreement will be owed by us to another legal entity (including any you; 10.11.2.1. because full ownership of the money is transferred to us, you no longer have a proprietary claim over the money, and we can deal with it in our own right; 10.11.2.2. in the event of our Group Companies)insolvency you will rank as a general or unsecured creditor of Magnasale in respect of such money and you will have no rights or claim in relation to such money, where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity save for you those set out in accordance with the CMA Regulations. 40.7 You consent to us releasing any Client Money balances, for or on your behalf, from Client Money bank accounts and for us to treat as Client Money any unclaimed Client Money balance where: 40.7.1 we have determined that there has been no movement on your balance for a period of two years (notwithstanding any payments or receipts of charges, interest or similar items)applicable laws; and 40.7.2 10.11.2.3. if we have written closed all Accounts you have had with us and you have paid to us in full all amounts you owe us and have no further present or future obligations to us, we will transfer to you at an amount equal to any money you paid to us for your last known address Account that remains after all amounts you owe us (under this Agreement) have been paid and on a regular basis informing deducted (including in relation to all Accounts you of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to make a claim, provided we shall make and retain records of all balances released from our Client Money bank accounts in respect of your Client Money and undertake to make good any valid claims against any released balanceshave had with us).

Client Money. 40.1 Any money received 16.1. Money held by us in respect of on your account with us shall behalf will be treated as Client Money except where you separately agree with us to transfer full ownership client money within the meaning of money to us for, amongst other things, the purpose of securing or otherwise covering present or future, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, in which circumstances such money will not be regarded as Client Money. 40.2 In relation to Client Money unless you notify us in writing, or otherwise, we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts and by entering into these Terms you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and of the arrangements for holding your money, in accordance with the CMA Regulations. We will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clientsRules. Claimants to Your money will be held in pooled accounts have a claim to a rateable proportion of the money held in that poolsegregated client account at our custodian bank. 40.5 16.2. We may pass money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) house to hold or control in order to make a transaction Transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide marginMargin) in respect of a transaction. 40.6 Transaction. Although we will remain responsible for money received from you even if we pass it to a third party, you may be exposed to the additional risk that, in the event of an insolvency or similar in relation to that third party, the amount of money received by us from the third party may not be sufficient to satisfy your claims. However, you may still be able to claim against us for any outstanding amounts. 16.3. We may transfer hold client money on your behalf outside the Canada. The legal and regulatory regime applying to any bank or person that holds your money we hold outside the Canada will be different from that of the Canada. As a result, should that bank go into insolvency or similar proceedings, your money may be treated differently than it would have been if the money was held with a bank in the Canada. We will not be liable for you as Client Money (after deduction the insolvency, acts or omissions of any amounts permitted by third party referred to in this sub-clause. 16.4. In the provisions event that funds need to be transferred between INBASE HOLDING LIMITED (Toronto parent entity) and you give us the permission to do so. This will also apply to any current account(s) that you may have with INBASE HOLDING LIMITED (Toronto). The transfer will only take place from INBASE HOLDING LIMITED and not the vice versa. Funds will only be transferred when necessary. We understand that the data being sent is sensitive, and will only be shared between INBASE HOLDING LIMITED and is protected under the Data Protection Laws of these Terms) both jurisdictions and allows us to another legal entity (including any of our Group Companies), where we transfer all or part of our business to that entity and your Client comply with Anti-Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Laundering Regulations. 40.7 You 16.5. To avoid doubt, we will not pay interest on any amounts in your account, unless we have agreed to do so in writing. Unless we have agreed otherwise in writing, on signing this Agreement, you consent to us releasing the fact that no interest will be paid to you on any Client Money balancesamounts in your account(s) and that we will retain any such interest. 16.6. You agree that, for or on your behalf, from Client Money bank accounts and for us to treat as Client Money any unclaimed Client Money balance where: 40.7.1 we have determined in the event that there has been no movement on your account balance for a period of two at least six years (notwithstanding not with standing any payments or receipts of charges, interest charges or similar items); and) and we are unable to trace you and return your account balance to you, despite having taken all reasonable steps to do so, we may cease to treat your money as client money and accordingly release any client money balances from the segregated client account pursuant to any local regulatory protocols applicable to ‘dormant accounts’. 40.7.2 we have written to 16.7. If your trading account remains unused for at least one year, you at your last known address and on will be treated as a regular basis informing you dormant customer. This will attract an administration fee of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to make a claim, provided we shall make and retain records of all balances released from our Client Money bank accounts $10 in respect the currency of your Client Money and undertake account per calendar month to make good cover our costs of maintaining the dormant account. We reserve the right to amend such fees. You will be informed of any valid claims against any released balancessuch changes. Note that the administration fee cannot reduce the balance of your account(s) below zero.

Client Money. 40.1 Any money 10.1 Subject to clause 11, any cash received by us from you will be held in respect of your an account with us shall or with a bank approved by us and will be treated segregated from our own funds in accordance with the FCA Rules on “client money” (as defined in the FCA Rules) (Client Money except where you separately agree Money). Unless otherwise agreed in writing between us, your funds may be pooled with us to transfer full ownership the funds of money to us for, amongst other things, the purpose of securing or otherwise covering present or future, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, clients in which circumstances such money a general omnibus account. 10.2 We will not be regarded as Client Money. 40.2 In relation pay interest to Client Money unless you notify us in writing, or otherwise, on any of your money that we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts and by entering into these Terms this Agreement you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations FCA Rules or otherwise. 40.3 10.3 We may hold funds you pay to us with banks located outside the United Kingdom. The legal and regulatory regime applying to any such bank will exercise all due skillbe different from that of the United Kingdom and in the event of the insolvency or any other equivalent failure of the bank, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and of treated differently from the arrangements for holding your money, treatment which would apply if the money was held in accordance with the CMA RegulationsUnited Kingdom. We will not be responsible or liable to you for the solvency, acts or omissions of any bank or other third party holding money under this clause 10. 10.4 We are authorised to convert money in your account (including for Margin) into and from such foreign currency at a rate of exchange determined by us on the basis of the then prevailing money market rates. In such circumstances, we will not, subject to clause 12.3 if you are a Retail Client, be responsible or liable to you for any actsloss suffered by you as a result of such action (although, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account we will use reasonable endeavors to only convert such funds as may prudently be a pooled account and holds the Client Money relating required to a number of clients. Claimants to money held in pooled accounts have a claim to a rateable proportion of the money held in that pool. 40.5 We may pass money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) to hold or control in order to make a transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide margin) cover Liabilities in respect of a transactionrelevant transactions). 40.6 Although we will remain responsible for money received 10.5 Where any obligations owing to us from you even if we pass it are due and payable to a third party, you may be exposed to the additional risk that, in the event of an insolvency or similar in relation to that third party, the amount of money received by us from the third party may not be sufficient to satisfy your claims. We may transfer any money we hold for you as Client Money (after deduction of any amounts permitted by the provisions of these Terms) to another legal entity (including any of our Group Companies), where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6us, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Regulations. 40.7 You consent to us releasing any Client Money balances, for or on your behalf, from Client Money bank accounts and for us may cease to treat as Client Money so much of the money held on your behalf as equals the amount of those obligations in accordance with the FCA Rules relating to Client Money. You agree that we may apply that money in or towards satisfaction of all or part of those obligations due and payable to us. For the purposes of this clause 10, any unclaimed such obligations become immediately due and payable, without notice or demand by us, when incurred by you or on your behalf. 10.6 You agree that we will be entitled to apply money you hold with us in or towards satisfaction of all or any part of any Liabilities which are due and payable. 10.7 You agree that we may cease to treat your money as Client Money balance where: 40.7.1 we have determined that if there has been no movement on your balance for a period of two years (notwithstanding any payments or receipts of charges, interest or similar items); and 40.7.2 we have written at least six years. We will write to you at your last known address and on a regular basis informing you of our intention of no longer treating that your balance as Client Money, Money and giving you Twenty- eight (28) Business Days -days to make a claim, provided we shall make and retain records of all balances released from our Client Money bank accounts in respect of your Client Money and undertake to make good any valid claims against any released balances.

Client Money. 40.1 Any a) We have categorized you as a private client and therefore in accordance with applicable law and subject to clauses 20.1b and 20.1c we will place an amount equal to your Total Equity (as displayed on the platform) into a client money received bank account. We will deal with your money in accordance with XXXX’s Client Money Rules and Statement of Guidance, which require us to hold it in a client bank account, separating your funds from ours. Such money may be held by us a bank with other clients’ money in respect of a pooled client account. b) We may hold Client Money on your behalf in an account with us shall an approved bank or third party which may be treated as Client Money except where located inside or outside the Cayman Islands. Any such account will be segregated from any account in which our own money or assets is held with the bank or third party but may be subject to set-off rights of the bank or third party. The legal and regulatory regime applying to any bank or third party located outside the Cayman Islands may be different from that of the Cayman Islands. You should consider taking independent legal advice if you separately agree with us to transfer full ownership are concerned by the implications of money to us forbeing held with an approved bank, amongst or third party as permitted by clause 20.1c, which may be located inside or outside of the Cayman Islands c) Where any bank or other things, the purpose of securing or otherwise covering present or future, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent value, in which circumstances such permitted third party holds money under this clause (a) we will not be regarded as Client Money. 40.2 In liable for the acts or omissions of, or failure or insolvency or any analogous event affecting, such entity; and (b) in the event of the insolvency or other analogous proceeding in relation to Client Money unless you notify us in writing, or otherwisesuch entity, we will promptly pay any Client Money received to may have only an unsecured claim against such entity on behalf of you and our Client Money bank accounts. Our Client Money accounts will be identified other clients, and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts and by entering into these Terms you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and of the arrangements for holding your money, in accordance with the CMA Regulations. We will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clients. Claimants to money held in pooled accounts have a claim to a rateable proportion of the money held in that pool. 40.5 We may pass money received from you to a third party (e.g. a market, intermediate broker, OTC counterparty or clearing house) to hold or control in order to make a transaction through or with that person or to satisfy your obligation to provide a deposit (such as an initial requirement that you provide margin) in respect of a transaction. 40.6 Although we will remain responsible for money received from you even if we pass it to a third party, you may be exposed to the additional risk that, in that the event of an insolvency or similar in relation to that third party, the amount of money received recovered by us from the third party may not be sufficient such entity is insufficient to satisfy the claims of you and all other clients with claims in respect of the relevant account. d) We will carry out reconciliations at the close of business on each Business Day between money required to be held in the client money bank account and money that may be held on our own account in accordance with CIMA Rules and Statement of Guidance, and any required transfer to or from the client money bank account in respect of your claimsAccount will take place on the following Business Day. We may transfer any money carry out such reconciliations and transfers more frequently, should we hold for you as Client Money (after deduction of any amounts permitted by the provisions of these Terms) reasonably consider that this is necessary to another legal entity (including any of protect our Group Companies), where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Regulationsinterests. 40.7 e) You consent agree that we may cease to us releasing any Client Money balances, for or treat money held on your behalfbehalf as client money and release it from our client money bank account(s), i. if you have no positions and have not placed a trade in the previous six (6) years, from Client Money bank accounts and for us to treat as Client Money any unclaimed Client Money balance where: 40.7.1 we have determined that there has been no movement on your balance for a period of two years (notwithstanding any payments or receipts of chargestaken reasonable steps but were unable to contact you. Such money will, interest or similar items); and 40.7.2 we have written however, remain owing to you at your last known address and on a regular basis informing you of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to make a claim, provided we shall will make and retain all records of all balances released from our Client Money client money bank accounts in respect of your Client Money under this clause and will undertake to make good any valid claims against any such released balances. ii. If any amounts owed by you to us under the Agreement are due and payable to us, in accordance with the Client Money Rules we shall cease to treat as Client Money so much of any Client Money held on your behalf as equals the those amounts. You agree that we may apply that money in or towards satisfaction of all or part of those amounts due and payable to us. For the purposes of this clause, any such amounts owed by you to us under this Agreement become immediately due and payable, without notice or demand by us, when incurred by you or on your behalf. f) We will not pay interest to you on any money held on your behalf or otherwise under clauses 20.1a, 20.1b, 20.1c or 20.1d. g) In this clause 20.1 “Client Money Rules” means the provisions of the Securities Investment Business (Conduct of Business) Regulations, 2003 of the Cayman Islands and associated Rules and Statements of Guidance, as amended and/or updated from time to time, relating to Client Money held by firms carrying out activities regulated under the SIBL.

Client Money. 40.1 Any Unless otherwise specifically stated in these Terms or as provided under Applicable Law, your money received by us in respect of your account with us shall will be treated held as Client Money except where you separately agree in accordance with us to transfer full ownership of money to us forthe FCA Rules which, amongst among other things, the purpose require us to hold your money in a client bank account which is free of securing or otherwise covering present or futurelien and set up with statutory trust status, actual or contingent or prospective obligations, such as Margin posted with relevant liquidity providers at an equivalent valueApproved Bank or CRD Credit Institution. This means we will separate your funds from our own funds and we may hold your money with other clients’ money in a pooled account, in which circumstances such money will not be regarded has been named as Client Money. 40.2 In relation a client bank account. When selecting which third party bank to Client Money unless you notify us in writing, or otherwiseuse, we will promptly pay any Client Money received to our Client Money bank accounts. Our Client Money accounts will be identified and designated separately from any accounts used to hold other money belonging to us. Interest will not be paid on the money held in Client Money bank accounts and by entering into these Terms you acknowledge that you waive any entitlement to interest on such money under the CMA Regulations or otherwise. 40.3 We will exercise all due skill, care and diligence, in accordance with the CMA Regulations when selecting which third party bank to use. We diligence and will periodically (at least annually) review the adequacy and appropriateness of any bank where your money is or may be deposited and of the arrangements for holding your money, in accordance with the CMA RegulationsFCA Rules. We will not be responsible for any acts, omissions or default (including the insolvency, administration, bankruptcy or similar event) of the third-party bank or for any resulting shortfall or loss in the return of your money. 40.4 The Client Money account will be a pooled account and holds the Client Money relating to a number of clients. Claimants to money held in pooled accounts have a claim to a rateable proportion of the money held in that pool. 40.5 We may pass money received from you to a third party (e.g. a marketbank. If necessary, intermediate brokerwe may also allow another institution such as an exchange, OTC counterparty or clearing house) , overseas settlement agent or other intermediate broker to hold or control in order to make your money, but only if we transfer your money for the purpose of a transaction through or with that person or to satisfy your meet any obligation that you may have to provide a deposit collateral (such as an initial requirement that you provide for example, margin) in respect of for a transaction. 40.6 Although . If we do this and where required to do so under the FCA Rules, we will remain responsible endeavour to ensure your money is held as Client Money under the FCA Rules. In the event of our failure (for example due to our bankruptcy or insolvency), any money received held in a Client Money account by third parties will be segregated from you even if we pass it our assets and will not be available to a third party, you may be exposed to the additional risk thatour creditors. However, in the event of an insolvency or similar in relation to that failure of a third party, the amount there may be a number of consequences for your investment which may include: (a) UK bank accounts: if we place your money received by us from the in a UK account with a third party may not be sufficient to satisfy party, because your claims. We may transfer any money we hold for you as Client Money (after deduction of any amounts permitted by the provisions of these Terms) to another legal entity (including any of our Group Companies), where we transfer all or part of our business to that entity and your Client Money relates to the business transferred. Where we transfer your Client Money to another legal entity under this section 40.6, we shall ensure that such Client Money will be held by that entity for you in accordance with the CMA Regulations. 40.7 You consent to us releasing any other customers’ Client Money balances, for or on your behalf, from in a pooled Client Money account, in the event that the third party credit institution or bank holding the money defaults and there is a shortfall, you will share proportionately in that shortfall with other creditors of the credit institution or bank; (b) Non-UK bank accounts: in addition to any shortfalls through the pooling of accounts as described above, where your money is required to be held in a bank located outside the UK, you should be aware that the legal and for us regulatory regimes (including any associated protections) that apply to treat as Client Money any unclaimed Client Money balance where: 40.7.1 we have determined that there has been no movement on the bank holding your balance for money may be different to those of the UK. In the event of the bank’s failure, your rights and obligations may differ and your money could be less secure and treated differently from the position which would apply if the money were held in a period of two years (notwithstanding any payments or receipts of charges, interest or similar items); and 40.7.2 we have written to you at your last known address and on a regular basis informing you of our intention of no longer treating that balance as Client Money, giving you Twenty- eight (28) Business Days to make a claim, provided we shall make and retain records of all balances released from our Client Money customer bank accounts account in respect of your Client Money and undertake to make good any valid claims against any released balances.the UK;