Common use of Retail Clients only Clause in Contracts

Retail Clients only. 12.1.1. This clause applies to Retail Clients only. 12.1.2. Any money received by us in respect of your Account shall be treated as Client Money in accordance with the FCA's Client Money Rules. 12.1.3. Any money you transfer to us, or which is transferred to us on your behalf being Client Money will be held with a bank or third party nominated by us in our sole discretion, acting reasonably and considering the relevant provisions in CASS 7 and especially 7.12, which may from time to time be an authorised bank or third party registered outside of the UK or the EEA. Your money will be segregated from our own money in accordance with the requirements and in the event of our insolvency, it will be excluded from our assets subject at all times to the relevant legislation and regulatory provisions. 12.1.4. Where monies are held outside of the UK, the legal and regulatory regime applying to any such bank or third party may be different from that of the UK and in the event of the insolvency or any other equivalent failure of that bank or third party, your money may not be as effectively protected as if your money is held with an equivalent bank or third party in the UK. 12.1.5. We will not be liable for the failure or insolvency of any bank or third-party holding Client Money. However, if your money is held within another jurisdiction, a proportion of your cash balance may qualify for compensation arrangements, subject to the rules of that jurisdiction. 12.1.6. Your money may be held in a different currency from that of its receipt and will be adjusted each day to an amount at least equal to the original currency amount, translated at the previous day's closing spot exchange rate. 12.1.7. You will not be entitled to interest on any Client Money held with us. 12.1.8. We may pass on Client Money or allow another entity such as an exchange, a clearing house, or a liquidity provider, to hold Client Money where we transfer the Client Money: (a) For the purposes of a transaction for you through or with that person; or (b) To meet your obligations to provide Margin for a transaction.

Retail Clients only. 12.1.1. 12.1.1 This clause applies to Retail Clients only. 12.1.2. 12.1.2 Any money received by us in respect of your Account shall be treated as Client Money in accordance with the FCA's Client Money Rules. 12.1.3. 12.1.3 Any money you transfer to us, us or which is transferred to us on your behalf being Client Money will be held with a bank or third party nominated by us in our sole discretion, acting reasonably and considering in accordance with the relevant provisions in CASS 7 and especially 7.12Client Money Rules, which may from time to time be an authorised bank or third party registered outside of the UK or the EEA. Your money will be segregated from our own money in accordance with the requirements and of the Client Money Rules and, in the event of our insolvency, it will be excluded from our assets subject at all times to the relevant legislation and regulatory provisions. 12.1.4. 12.1.4 Where monies are held outside of the UK, the legal and regulatory regime applying to any such bank or third party may be different from that of the UK and in the event of the insolvency or any other equivalent failure of that bank or third party, your money may not be as effectively protected as if your money is held with an equivalent bank or third party in the UK. 12.1.5. 12.1.5 We will not be liable for the failure or insolvency of any bank or third-third party holding Client Money. HoweverMoney however, if your money is held within another jurisdictionan EEA country, a proportion of your cash balance may qualify for compensation arrangementsarrangements in that jurisdiction, subject to the rules of that jurisdiction. 12.1.6. 12.1.6 Your money may be held in a different currency from that of its receipt and will be adjusted each day to an amount at least equal to the original currency amount, translated at the previous day's closing spot exchange rate. 12.1.7. 12.1.7 You will not be entitled to interest on any Client Money held with us, unless we expressly agree otherwise with you in writing. 12.1.8. We 12.1.8 Unless you notify us in writing or otherwise, we may pass on Client Money or allow another entity person such as an exchange, a clearing house, house or a liquidity provideran intermediate broker, to hold or control Client Money where we transfer the Client Money: (a) For for the purposes of a transaction for you through or with that person; or (b) To to meet your obligations to provide Margin for a transaction. VARIANSE | Client Agreement Page 13 of 28 VARIANSE is a trading name of VDX Limited. VDX Limited is authorised and regulated by the Financial Conduct Authority (FCA) in the United Kingdom with FRN 802012. Address: Park house, 000 Xxxx Xxxxxx, Xxxxxxx, Xxxxxx, X0X 0XX, Email: xxxxxxx@xxxxxxxx.xxx. Tel: +00 (0) 000 000 0000. 12.1.9 You hereby agree to us releasing any Client Money balances, for or on your behalf, from client bank accounts and to us ceasing to treat any unclaimed Client Money in your Account as Client Money where: (a) we have determined, acting in our reasonable sole discretion, that there has been no movement on your balance for a period of six years (notwithstanding any payments or receipts of charges, interest or similar items); and (b) we have written to you at your last known address informing you of our intention of no longer treating that balance as Client Money, giving you 28 days to make a claim, provided we: (i) shall make and retain records of all balances released from your client bank account; and (ii) undertake to make good any valid claims against any released balances. 12.1.10 Your money will cease to be Client Money when it is paid: (a) to you or to one of your duly authorised representatives; (b) to a third party on your instructions; and (c) to us when money is due and payable to us.

Retail Clients only. 12.1.1. 12.1.1 This clause applies to Retail Clients only. 12.1.2. 12.1.2 Any money received by us in respect of your Account shall be treated as Client Money in accordance with the FCAFISD's Client Money Rules. 12.1.3. 12.1.3 Any money you transfer to us, us or which is transferred to us on your behalf being Client Money will be held with a bank or third party nominated by us in our sole discretion, acting reasonably and considering the relevant provisions in CASS 7 Rules 7.4.7 and especially 7.127.4.8 of the Client Money Rules, which may from time to time be an authorised bank or third party registered outside of the UK or the EEA. Your money will be segregated from our own money in accordance with the requirements of the Client Money Rules and in the event of our insolvency, it will be excluded from our assets subject at all times to the relevant legislation and regulatory provisions. 12.1.4. 12.1.4 Where monies are held outside of the UK, the legal and regulatory regime applying to any such bank or third party may be different from that of the UK and in the event of the insolvency or any other equivalent failure of that bank or third party, your money may not be as effectively protected as if your money is held with an equivalent bank or third party in the UK. 12.1.5. 12.1.5 We will not be liable for the failure or insolvency of any bank or third-third party holding Client Money. HoweverMoney however, if your money is held within another jurisdictionan EEA country, a proportion of your cash balance may qualify for compensation arrangementsarrangements in that jurisdiction, subject to the rules of that jurisdiction. 12.1.6. 12.1.6 Your money may be held in a different currency from that of its receipt and will be adjusted each day to an amount at least equal to the original currency amount, translated at the previous day's closing spot exchange rate. 12.1.7. 12.1.7 You will not be entitled to interest on any Client Money held with us, unless we expressly agree otherwise with you in writing. 12.1.8. We 12.1.8 Unless you notify us in writing or otherwise, we may pass on Client Money or allow another entity person such as an exchange, a clearing house, house or a liquidity provideran intermediate broker, to hold or control Client Money where we transfer the Client Money: (a) For the purposes of a transaction for you through or with that person; or (b) To meet your obligations to provide Margin for a transaction. 12.1.9 You hereby agree to us releasing any Client Money balances, for or on your behalf, from client bank accounts and to us ceasing to treat any unclaimed Client Money in your Account as Client Money where: (a) We have determined, acting in our reasonable sole discretion, that there has been no movement on your balance for a period of six years (notwithstanding any payments or receipts of charges, interest or similar items); and (b) We have written to you at your last known address informing you of our intention of no longer treating that balance as Client Money, giving you 28 days to make a claim, provided we: (i) Shall make and retain records of all balances released from your client bank account; and (ii) Undertake to make good any valid claims against any released balances. 12.1.10 Your money will cease to be Client Money when it is paid: (a) To you or to one of your duly authorised representatives; (b) To a third party on your instructions; and (c) To us when money is due and payable to us.

Retail Clients only. 12.1.1. 12.1.1 This clause applies to Retail Clients only. 12.1.2. 12.1.2 Any money received by us in respect of your Account shall be treated as Client Money in accordance with the FCA's Client Money Rules. 12.1.3. 12.1.3 Any money you transfer to us, us or which is transferred to us on your behalf being Client Money will be held with a bank or third party nominated by us in our sole discretion, acting reasonably and considering in accordance with the relevant provisions in CASS 7 and especially 7.12Client Money Rules, which may from time to time be an authorised bank or third party registered outside of the UK or the EEA. Your money will be segregated from our own money in accordance with the requirements and of the Client Money Rules and, in the event of our insolvency, it will be excluded from our assets subject at all times to the relevant legislation and regulatory provisions. 12.1.4. 12.1.4 Where monies are held outside of the UK, the legal and regulatory regime applying to any such bank or third party may be different from that of the UK and in the event of the insolvency or any other equivalent failure of that bank or third party, your money may not be as effectively protected as if your money is held with an equivalent bank or third party in the UK. 12.1.5. 12.1.5 We will not be liable for the failure or insolvency of any bank or third-third party holding Client Money. HoweverMoney however, if your money is held within another jurisdictionan EEA country, a proportion of your cash balance may qualify for compensation arrangementsarrangements in that jurisdiction, subject to the rules of that jurisdiction. 12.1.6. 12.1.6 Your money may be held in a different currency from that of its receipt and will be adjusted each day to an amount at least equal to the original currency amount, translated at the previous day's closing spot exchange rate. 12.1.7. 12.1.7 You will not be entitled to interest on any Client Money held with us, unless we expressly agree otherwise with you in writing. 12.1.8. We 12.1.8 Unless you notify us in writing or otherwise, we may pass on Client Money or allow another entity person such as an exchange, a clearing house, house or a liquidity provideran intermediate broker, to hold or control Client Money where we transfer the Client Money: (a) For for the purposes of a transaction for you through or with that person; or (b) To to meet your obligations to provide Margin for a transaction. VARIANSE | Client Agreement Page 13 of 28 VARIANSE is a trading name of VDX Limited. VDX Limited is authorised and regulated by the Financial Conduct Authority (FCA) in the United Kingdom with FRN 802012. Address: 0 Xxxxxxx Xxxxxx, Xxxx, Xxxxxx, XX0X 0XX, Email: xxxxxxx@xxxxxxxx.xxx. Tel: +00 (0) 000 000 0000. 12.1.9 You hereby agree to us releasing any Client Money balances, for or on your behalf, from client bank accounts and to us ceasing to treat any unclaimed Client Money in your Account as Client Money where: (a) we have determined, acting in our reasonable sole discretion, that there has been no movement on your balance for a period of six years (notwithstanding any payments or receipts of charges, interest or similar items); and (b) we have written to you at your last known address informing you of our intention of no longer treating that balance as Client Money, giving you 28 days to make a claim, provided we: (i) shall make and retain records of all balances released from your client bank account; and (ii) undertake to make good any valid claims against any released balances. 12.1.10 Your money will cease to be Client Money when it is paid: (a) to you or to one of your duly authorised representatives; (b) to a third party on your instructions; and (c) to us when money is due and payable to us.

Retail Clients only. 12.1.1. 12.1.1 This clause applies to Retail Clients only. 12.1.2. 12.1.2 Any money received by us in respect of your Account shall be treated as Client Money in accordance with the FCA's Client Money Rules. 12.1.3. 12.1.3 Any money you transfer to us, us or which is transferred to us on your behalf being Client Money will be held with a bank or third party nominated by us in our sole discretion, acting reasonably and considering the relevant provisions in CASS 7 Rules 7.4.7 and especially 7.127.4.8 of the Client Money Rules, which may from time to time be an authorised bank or third party registered outside of the UK or the EEA. Your money will be segregated from our own money in accordance with the requirements of the Client Money Rules and in the event of our insolvency, it will be excluded from our assets subject at all times to the relevant legislation and regulatory provisions. 12.1.4. 12.1.4 Where monies are held outside of the UK, the legal and regulatory regime applying to any such bank or third party may be different from that of the UK and in the event of the insolvency or any other equivalent failure of that bank or third party, your money may not be as effectively protected as if your money is held with an equivalent bank or third party in the UK. 12.1.5. 12.1.5 We will not be liable for the failure or insolvency of any bank or third-third party holding Client Money. HoweverMoney however, if your money is held within another jurisdictionan EEA country, a proportion of your cash balance may qualify for compensation arrangementsarrangements in that jurisdiction, subject to the rules of that jurisdiction. 12.1.6. 12.1.6 Your money may be held in a different currency from that of its receipt and will be adjusted each day to an amount at least equal to the original currency amount, translated at the previous day's closing spot exchange rate. 12.1.7. 12.1.7 You will not be entitled to interest on any Client Money held with us, unless we expressly agree otherwise with you in writing. 12.1.8. We 12.1.8 Unless you notify us in writing or otherwise, we may pass on Client Money or allow another entity person such as an exchange, a clearing house, house or a liquidity provideran intermediate broker, to hold or control Client Money where we transfer the Client Money: (a) For the purposes of a transaction for you through or with that person; or (b) To meet your obligations to provide Margin for a transaction. 12.1.9 You hereby agree to us releasing any Client Money balances, for or on your behalf, from client bank accounts and to us ceasing to treat any unclaimed Client Money in your Account as Client Money where: (a) We have determined, acting in our reasonable sole discretion, that there has been no movement on your balance for a period ofsix years (notwithstanding any paymentsor receipts ofcharges, interest or similar items); and (b) We have written to you at your last known address informing you of our intention of no longer treating that balance as Client Money, giving you 28 days to make a claim, provided we: (i) Shall make and retain records of all balances released from your client bank account; and (ii) Undertake to make good any valid claims against any released balances. 12.1.10 Your money will cease to be Client Money when it is paid: (a) To you or to one of your duly authorised representatives; (b) To a third party on your instructions; and (c) To us when money is due and payable to us.

Retail Clients only. 12.1.1. 12.1.1 This clause applies to Retail Clients only. 12.1.2. 12.1.2 Any money received by us in respect of your Account shall be treated as Client Money in accordance with the FCA's Client Money Rules. 12.1.3. 12.1.3 Any money you transfer to us, us or which is transferred to us on your behalf being Client Money will be held with a bank or third party nominated by us in our sole discretion, acting reasonably and considering the relevant provisions in CASS 7 Rules 7.4.7 and especially 7.127.4.8 of the Client Money Rules, which may from time to time be an authorised bank or third party registered outside of the UK or the EEA. Your money will be segregated from our own money in accordance with the requirements of the Client Money Rules and in the event of our insolvency, it will be excluded from our assets subject at all times to the relevant legislation and regulatory provisions. 12.1.4. 12.1.4 Where monies are held outside of the UK, the legal and regulatory regime applying to any such bank or third party may be different from that of the UK and in the event of the insolvency or any other equivalent failure of that bank or third party, your money may not be as effectively protected as if your money is held with an equivalent bank or third party in the UK. 12.1.5. 12.1.5 We will not be liable for the failure or insolvency of any bank or third-third party holding Client Money. However, if your money is held within another jurisdictionan EEA country, a proportion of your cash balance may qualify for compensation arrangementsarrangements in that jurisdiction, subject to the rules of that jurisdiction. 12.1.6. 12.1.6 Your money may be held in a different currency from that of its receipt and will be adjusted each day to an amount at least equal to the original currency amount, translated at the previous day's closing spot exchange rate. 12.1.7. 12.1.7 You will not be entitled to interest on any Client Money held with us, unless we expressly agree otherwise with you in writing. 12.1.8. We 12.1.8 Unless you notify us in writing or otherwise, we may pass on Client Money or allow another entity person such as an exchange, a clearing house, house or a liquidity provideran intermediate broker, to hold or control Client Money where we transfer the Client Money: (a) For the purposes of a transaction for you through or with that person; or (b) To meet your obligations to provide Margin for a transaction. 12.1.9 You hereby agree to us releasing any Client Money balances, for or on your behalf, from client bank accounts and to us ceasing to treat any unclaimed Client Money in your Account as Client Money where: (a) We have determined, acting in our reasonable sole discretion, that there has been no movement on your balance for a period of six years (notwithstanding any payments or receipts of charges, interest or similar items); and (b) We have written to you at your last known address informing you of our intention of no longer treating that balance as Client Money, giving you 28 days to make a claim, provided we: (i) Shall make and retain records of all balances released from your client bank account; and (ii) Undertake to make good any valid claims against any released balances. 12.1.10 Your money will cease to be Client Money when it is paid: (a) To you or to one of your duly authorised representatives; (b) To a third party on your instructions; and (c) To us when money is due and payable to us.

Retail Clients only. 12.1.1. 12.1.1 This clause applies to Retail Clients only. 12.1.2. 12.1.2 Any money received by us in respect of your Account shall be treated as Client Money in accordance with the FCA's Client Money Rules. 12.1.3. 12.1.3 Any money you transfer to us, us or which is transferred to us on your behalf being Client Money will be held with a bank or third party nominated by us in our sole discretion, acting reasonably and considering the relevant provisions in CASS 7 Rules 7.4.7 and especially 7.127.4.8 of the Client Money Rules, which may from time to time be an authorised bank or third party registered outside of the UK or the EEA. Your money will be segregated from our own money in accordance with the requirements of the Client Money Rules and in the event of our insolvency, it will be excluded from our assets subject at all times to the relevant legislation and regulatory provisions. 12.1.4. 12.1.4 Where monies are held outside of the UK, the legal and regulatory regime applying to any such bank or third party may be different from that of the UK and in the event of the insolvency or any other equivalent failure of that bank or third party, your money may not be as effectively protected as if your money is held with an equivalent bank or third party in the UK. 12.1.5. 12.1.5 We will not be liable for the failure or insolvency of any bank or third-third party holding Client Money. HoweverMoney however, if your money is held within another jurisdictionan EEA country, a proportion of your cash balance may qualify for compensation arrangementsarrangements in that jurisdiction, subject to the rules of that jurisdiction. 12.1.6. 12.1.6 Your money may be held in a different currency from that of its receipt and will be adjusted each day to an amount at least equal to the original currency amount, translated at the previous day's closing spot exchange rate. 12.1.7. 12.1.7 You will not be entitled to interest on any Client Money held with us, unless we expressly agree otherwise with you in writing. 12.1.8. We 12.1.8 Unless you notify us in writing or otherwise, we may pass on Client Money or allow another entity person such as an exchange, a clearing house, house or a liquidity provideran intermediate broker, to hold or control Client Money where we transfer the Client Money: (a) For the purposes of a transaction for you through or with that person; or (b) To meet your obligations to provide Margin for a transaction. 12.1.9 You hereby agree to us releasing any Client Money balances, for or on your behalf, from client bank accounts and to us ceasing to treat any unclaimed Client Money in your Account as Client Money where: (a) We have determined, acting in our reasonable sole discretion, that there has been no movement on your balance for a period of six years (notwithstanding anypayments or receipts of charges, interest or similar items); and (b) We have written to you at your last known address informing you of our intention of no longer treating that balance as Client Money, giving you 28 days to make a claim, provided we: (i) Shall make and retain records of all balances released from your client bank account; and (ii) Undertake to make good any valid claims against any released balances. 12.1.10 Your money will cease to be Client Money when it is paid: (a) To you or to one of your duly authorised representatives; (b) To a third party on your instructions; and (c) To us when money is due and payable to us.

Retail Clients only. 12.1.1. 12.1.1 This clause applies to Retail Clients only. 12.1.2. 12.1.2 Any money received by us in respect of your Account shall be treated as Client Money in accordance with the FCA's Client Money Rules. 12.1.3. 12.1.3 Any money you transfer to us, us or which is transferred to us on your behalf being Client Money will be held with a bank or third party nominated by us in our sole discretion, acting reasonably and considering the relevant provisions in CASS 7 Rules 7.4.7 and especially 7.127.4.8 of the Client Money Rules, which may from time to time be an authorised bank or third party registered outside of the UK or the EEA. Your money will be segregated from our own money in accordance with the requirements and in the event of our insolvency, it will be excluded from our assets subject at all times to the relevant legislation and regulatory provisions.the 12.1.4. 12.1.4 Where monies are held outside of the UK, the legal and regulatory regime applying to any such bank or third party may be different from that of the UK and in the event of the insolvency or any other equivalent failure of that bank or third party, your money may not be as effectively protected as if your money is held with an equivalent bank or third party in the UK. 12.1.5. 12.1.5 We will not be liable for the failure or insolvency of any bank or third-third party holding Client Money. HoweverMoney however, if your money is held within another jurisdictionan EEA country, a proportion of your cash balance may qualify for compensation arrangementsarrangements in that jurisdiction, subject to the rules of that jurisdiction. 12.1.6. 12.1.6 Your money may be held in a different currency from that of its receipt and will be adjusted each day to an amount at least equal to the original currency amount, translated at the previous day's closing spot exchange rate. 12.1.7. 12.1.7 You will not be entitled to interest on any Client Money held with us, unless we expressly agree otherwise with you in writing. 12.1.8. We 12.1.8 Unless you notify us in writing or otherwise, we may pass on Client Money or allow another entity person such as an exchange, a clearing house, house or a liquidity provideran intermediate broker, to hold or control Client Money where we transfer the Client Money: (a) For the purposes of a transaction for you through or with that person; or (b) To meet your obligations to provide Margin for a transaction. 12.1.9 You hereby agree to us releasing any Client Money balances, for or on your behalf, from client bank accounts and to us ceasing to treat any unclaimed Client Money in your Account as Client Money where: (a) We have determined, acting in our reasonable sole discretion, that there has been no movement on your balance for a period of six years (notwithstanding any payments or receipts of charges, interest or similar items); and (b) We have written to you at your last known address informing you of our intention of no longer treating that balance as Client Money, giving you 28 days to make a claim, provided we: (i) Shall make and retain records of all balances released from your client bank account; and (ii) Undertake to make good any valid claims against any released balances.

Retail Clients only. 12.1.1. 12.1.1 This clause applies to Retail Clients only. 12.1.2. 12.1.2 Any money received by us in respect of your Account shall be treated as Client Money in accordance with the FCA's Client Money Rules. 12.1.3. 12.1.3 Any money you transfer to us, us or which is transferred to us on your behalf being Client Money will be held with a bank or third party nominated by us in our sole discretion, acting reasonably and considering the relevant provisions in CASS 7 Rules 7.4.7 and especially 7.127.4.8 of the Client Money Rules, which may from time to time be an authorised bank or third party registered outside of the UK or the EEA. Your money will be segregated from our own money in accordance with the requirements of the Client Money Rules and in the event of our insolvency, it will be excluded from our assets subject at all times always to the relevant legislation and regulatory provisions. 12.1.4. 12.1.4 Where monies are held outside of the UK, the legal and regulatory regime applying to any such bank or third party may be different from that of the UK and in the event of the insolvency or any other equivalent failure of that bank or third party, your money may not be as effectively protected as if your money is held with an equivalent bank or third party in the UK. 12.1.5. 12.1.5 We will not be liable for the failure or insolvency of any bank or third-third party holding Client Money. HoweverMoney however, if your money is held within another jurisdictionan EEA country, a proportion of your cash balance may qualify for compensation arrangementsarrangements in that jurisdiction, subject to the rules of that jurisdiction. 12.1.6. 12.1.6 Your money may be held in a different currency from that of its receipt and will be adjusted each day to an amount at least equal to the original currency amount, translated at the previous day's closing spot exchange rate. 12.1.7. 12.1.7 You will not be entitled to interest on any Client Money held with us, unless we expressly agree otherwise with you in writing. 12.1.8. We 12.1.8 Unless you notify us in writing or otherwise, we may pass on Client Money or allow another entity person such as an exchange, a clearing house, house or a liquidity provideran intermediate broker, to hold or control Client Money where we transfer the Client Money: (a) For the purposes of a transaction for you through or with that person; or (b) To meet your obligations to provide Margin for a transaction. 12.1.9 You hereby agree to us releasing any Client Money balances, for or on your behalf, from client bank accounts and to us ceasing to treat any unclaimed Client Money in your Account as Client Money where: (a) We have determined, acting in our reasonable sole discretion, that there has been no movement on your balance for a period of six years (notwithstanding any payments or receipts of charges, interest or related items); and (b) We have written to you at your last known address informing you of our intention of no longer treating that balance as Client Money, giving you 28 days to make a claim, provided we: (i) Shall make and retain records of all balances released from your client bank account; and (ii) Undertake to make good any valid claims against any released balances. 12.1.10 Your money will cease to be Client Money when it is paid: (a) To you or to one of your duly authorised representatives; (b) To a third party on your instructions; and (c) To us when money is due and payable to us.

Retail Clients only. 12.1.1. 12.1.1 This clause applies to Retail Clients only. 12.1.2. 12.1.2 Any money received by us in respect of your Account shall be treated as Client Money in accordance with the FCA's Client Money Rules. 12.1.3. 12.1.3 Any money you transfer to us, us or which is transferred to us on your behalf being Client Money will be held with a bank or third party nominated by us in our sole discretion, acting reasonably and considering in accordance with the relevant provisions in CASS 7 and especially 7.12Client Money Rules, which may from time to time be an authorised bank or third party registered outside of the UK or the EEA. Your money will be segregated from our own money in accordance with the requirements and of the Client Money Rules and, in the event of our insolvency, it will be excluded from our assets subject at all times to the relevant legislation and regulatory provisions. 12.1.4. 12.1.4 Where monies are held outside of the UK, the legal and regulatory regime applying to any such bank or third party may be different from that of the UK and in the event of the insolvency or any other equivalent failure of that bank or third party, your money may not be as effectively protected as if your money is held with an equivalent bank or third party in the UK. 12.1.5. 12.1.5 We will not be liable for the failure or insolvency of any bank or third-third party holding Client Money. HoweverMoney however, if your money is held within another jurisdictionan EEA country, a proportion of your cash balance may qualify for compensation arrangementsarrangements in that jurisdiction, subject to the rules of that jurisdiction. 12.1.6. 12.1.6 Your money may be held in a different currency from that of its receipt and will be adjusted each day to an amount at least equal to the original currency amount, translated at the previous day's closing spot exchange rate. 12.1.7. 12.1.7 You will not be entitled to interest on any Client Money held with us, unless we expressly agree otherwise with you in writing. 12.1.8. We 12.1.8 Unless you notify us in writing or otherwise, we may pass on Client Money or allow another entity person such as an exchange, a clearing house, house or a liquidity provideran intermediate broker, to hold or control Client Money where we transfer the Client Money: (a) For for the purposes of a transaction for you through or with that person; or (b) To to meet your obligations to provide Margin for a transaction. VARIANSE | Client Agreement Page 14 of 29 VARIANSE is a trading name of VDX Limited. VDX Limited is authorised and regulated by the Financial Conduct Authority (FCA) in the United Kingdom with FRN 802012. Address: Park house, 000 Xxxx Xxxxxx, Xxxxxxx, Xxxxxx, X0X 0XX, Email: xxxxxxx@xxxxxxxx.xxx. Tel: +00 (0) 000 000 0000. 12.1.9 You hereby agree to us releasing any Client Money balances, for or on your behalf, from client bank accounts and to us ceasing to treat any unclaimed Client Money in your Account as Client Money where: (a) we have determined, acting in our reasonable sole discretion, that there has been no movement on your balance for a period of six years (notwithstanding any payments or receipts of charges, interest or similar items); and (b) we have written to you at your last known address informing you of our intention of no longer treating that balance as Client Money, giving you 28 days to make a claim, provided we: (i) shall make and retain records of all balances released from your client bank account; and (ii) undertake to make good any valid claims against any released balances. 12.1.10 Your money will cease to be Client Money when it is paid: (a) to you or to one of your duly authorised representatives; (b) to a third party on your instructions; and (c) to us when money is due and payable to us.

Retail Clients only. 12.1.1. 12.1.1 This clause applies to Retail Clients only. 12.1.2. 12.1.2 Any money received by us in respect of your Account shall be treated as Client Money in accordance with the FCA's Client Money Rules. 12.1.3. 12.1.3 Any money you transfer to us, us or which is transferred to us on your behalf being Client Money will be held with a bank or third party nominated by us in our sole discretion, acting reasonably and considering the relevant provisions in CASS 7 Rules 7.4.7 and especially 7.127.4.8 of the Client Money Rules, which may from time to time be an authorised bank or third party registered outside of the UK or the EEA. Your money will be segregated from our own money in accordance with the requirements and in the event of our insolvency, it will be excluded from our assets subject at all times to the relevant legislation and regulatory provisions.the 12.1.4. 12.1.4 Where monies are held outside of the UK, the legal and regulatory regime applying to any such bank or third party may be different from that of the UK and in the event of the insolvency or any other equivalent failure of that bank or third party, your money may not be as effectively protected as if your money is held with an equivalent bank or third party in the UK. 12.1.5. 12.1.5 We will not be liable for the failure or insolvency of any bank or third-third party holding Client Money. HoweverMoney however, if your money is held within another jurisdictionan EEA country, a proportion of your cash balance may qualify for compensation arrangementsarrangements in that jurisdiction, subject to the rules of that jurisdiction. 12.1.6. 12.1.6 Your money may be held in a different currency from that of its receipt and will be adjusted each day to an amount at least equal to the original currency amount, translated at the previous day's closing spot exchange rate. 12.1.7. 12.1.7 You will not be entitled to interest on any Client Money held with us, unless we expressly agree otherwise with you in writing. 12.1.8. We 12.1.8 Unless you notify us in writing or otherwise, we may pass on Client Money or allow another entity person such as an exchange, a clearing house, house or a liquidity provideran intermediate broker, to hold or control Client Money where we transfer the Client Money: (a) For the purposes of a transaction for you through or with that person; or (b) To meet your obligations to provide Margin for a transaction. 12.1.9 You hereby agree to us releasing any Client Money balances, for or on your behalf, from client bank accounts and to us ceasing to treat any unclaimed Client Money in your Account as Client Money where: (a) We have determined, acting in our reasonable sole discretion, that there has been no movement on your balance for a period of six years (notwithstanding any payments or receipts of charges, interest or similar items); and (b) We have written to you at your last known address informing you of our intention of no longer treating that balance as Client Money, giving you 28 days to make a claim, provided we: (i) Shall make and retain records of all balances released from your client bank account; and (ii) Undertake to make good any valid claims against any released balances. 12.1.10 Your money will cease to be Client Money when it is paid:

Retail Clients only. 12.1.1. This clause applies to Retail Clients only. 12.1.2. Any money received by us in respect of your Account shall be treated as Client Money in accordance with the FCA's Client Money Rules. 12.1.3. Any money you transfer to us, or which is transferred to us on your behalf being Client Money will be held with a bank or third party nominated by us in our sole discretion, acting reasonably and considering the relevant provisions in CASS 7 and especially 7.12, which may from time to time be an authorised bank or third party registered outside of the UK or the EEA. Your money will be segregated from our own money in accordance with the requirements and in the event of our insolvency, it will be excluded from our assets subject at all times to the relevant legislation and regulatory provisions. 12.1.4. Where monies are held outside of the UK, the legal and regulatory regime applying to any such bank or third party may be different from that of the UK and in the event of the insolvency or any other equivalent failure of that bank or third party, your money may not be as effectively protected as if your money is held with an equivalent bank or third party in the UK. 12.1.5. We will not be liable for the failure or insolvency of any bank or third-party third‐party holding Client Money. However, if your money is held within another jurisdiction, a proportion of your cash balance may qualify for compensation arrangements, subject to the rules of that jurisdiction. 12.1.6. Your money may be held in a different currency from that of its receipt and will be adjusted each day to an amount at least equal to the original currency amount, translated at the previous day's closing spot exchange rate. 12.1.7. You will not be entitled to interest on any Client Money held with us. 12.1.8. We may pass on Client Money or allow another entity such as an exchange, a clearing house, or a liquidity provider, to hold Client Money where we transfer the Client Money: (a) For the purposes of a transaction for you through or with that person; or (b) To meet your obligations to provide Margin for a transaction.

Retail Clients only. 12.1.1. 12.1.1 This clause applies to Retail Clients only. 12.1.2. 12.1.2 Any money received by us in respect of your Account shall be treated as Client Money in accordance with the FCA's Client Money Rules. 12.1.3. Any money you transfer to us, us or which is transferred to us on your behalf being Client Money will be held with a bank or third party nominated by us in our sole discretion, acting reasonably and considering the relevant provisions in CASS 7 Rules 7.4.7 and especially 7.127.4.8 of the Client Money Rules, which may from time to time be an an 12.1.3 authorised bank or third party registered outside of the UK or the EEA. Your money will be segregated from our own money in accordance with the requirements of the Client Money Rules and in the event of our insolvency, it will be excluded from our assets subject at all times to the relevant legislation and regulatory provisions. 12.1.4. 12.1.4 Where monies are held outside of the UK, the legal and regulatory regime applying to any such bank or third party may be different from that of the UK and in the event of the insolvency or any other equivalent failure of that bank or third party, your money may not be as effectively protected as if your money is held with an equivalent bank or third party in the UK. 12.1.5. 12.1.5 We will not be liable for the failure or insolvency of any bank or third-third party holding Client Money. HoweverMoney however, if your money is held within another jurisdictionan EEA country, a proportion of your cash balance may qualify for compensation arrangementsarrangements in that jurisdiction, subject to the rules of that jurisdiction. 12.1.6. 12.1.6 Your money may be held in a different currency from that of its receipt and will be adjusted each day to an amount at least equal to the original currency amount, translated at the previous day's closing spot exchange rate. 12.1.7. 12.1.7 You will not be entitled to interest on any Client Money held with us, unless we expressly agree otherwise with you in writing. 12.1.8. We 12.1.8 Unless you notify us in writing or otherwise, we may pass on Client Money or allow another entity person such as an exchange, a clearing house, house or a liquidity provideran intermediate broker, to hold or control Client Money where we transfer the Client Money: (a) For the purposes of a transaction for you through or with that person; or (b) To meet your obligations to provide Margin for a transaction. 12.1.9 You hereby agree to us releasing any Client Money balances, for or on your behalf, from client bank accounts and to us ceasing to treat any unclaimed Client Money in your Account as Client Money where: (a) We have determined, acting in our reasonable sole discretion, that there has been no movement on your balance for a period of six years (notwithstanding any payments or receipts of charges, interest or similar items); and (b) We have written to you at your last known address informing you of our intention of no longer treating that balance as Client Money, giving you 28 days to make a claim, provided we: (i) Shall make and retain records of all balances released from your client bank account; and (ii) Undertake to make good any valid claims against any released balances. 12.1.10 Your money will cease to be Client Money when it is paid: (a) To you or to one of your duly authorised representatives; (b) To a third party on your instructions; and (c) To us when money is due and payable to us.