Client
Agreement

1.2The Company is incorporated in Mauritius and licensed by the Financial Services Commission, Mauritius as an Investment Dealer (Full Service Dealer, excluding Underwriting), licence number GB25205368.

1.3The Company’s registered office is C/o MantaRay Management Limited, Suite 302A, 3rd Floor, The Catalyst Building, Plot 40, Silicon Avenue, Ebene, Mauritius, or any replacement registered office notified through an Approved Medium.

1.4The Agreement becomes binding when the Company confirms acceptance or activation of the Client’s Account after the Client has completed the required application, accepted the Operative Documents and satisfied the Company’s identity, due-diligence, appropriateness and other onboarding requirements.

1.5The Company may refuse an application, decline to activate an Account, impose reasonable conditions or request further information where required by Applicable Law, the Company’s risk appetite or legitimate operational requirements. Nothing in an application obliges the Company to accept the applicant.

Contents2DEFINITIONS AND INTERPRETATION

Account

each trading, wallet or other account maintained by the Company in the Client’s name.

Applicable Law

all statutes, regulations, rules, licence conditions, regulatory directions, sanctions, market rules and binding legal requirements applicable to the Company, Client, Account, Services or Transaction.

Approved Medium

the Client Portal, Trading Platform, Website, verified email, recorded telephone line or another channel approved by the Company.

Business Day

a day on which banks are open for normal business in Mauritius, excluding weekends and public holidays, unless the relevant market or product requires another calendar.

Client Money

money received from or held for the Client that is treated as client money under Applicable Law.

Contract Specifications

the current product and account specifications published through an Approved Medium, including trading hours, contract size, Margin, leverage, commissions, spreads, financing, stop-out levels and order limits.

Financial Instrument

a security, derivative, contract for difference, foreign-exchange product or other instrument the Company is authorised and has agreed to offer.

Force Majeure Event

an exceptional event described in clause 25 beyond the reasonable control of the affected party.

Margin

the amount required to open or maintain Positions, as calculated under the Contract Specifications.

Order

an instruction or request to enter into, modify or close a Transaction.

Policies

the client-facing policies incorporated into this Agreement, as amended in accordance with clause 29.

Position

an open exposure recorded in the Account.

Services

the execution-only dealing, transmission, custody-related or ancillary services expressly made available by the Company.

Trading Platform

any electronic system made available or approved by the Company for Account access or trading.

Transaction

a transaction in a Financial Instrument entered into or executed under this Agreement.

2.2Headings assist navigation only. References to a person include an individual, company, partnership, trust, authority or other legal body. The singular includes the plural and vice versa. “Including” means including without limitation. References to a document include its valid amendments.

3.2The Client must provide complete, accurate and current information and documents. The Client must promptly notify the Company of any material change, including changes to identity, address, contact details, tax residence, beneficial ownership, control, financial circumstances, source of funds, investment objectives or authority of representatives.

3.3The Company may classify the Client and assess whether Services or products are appropriate using information supplied by the Client. If information is incomplete, the Company may be unable to make an assessment and may restrict or refuse access. Any assessment is not investment advice and does not remove the Client’s responsibility for each decision.

3.4The Company does not offer Services where doing so would be unlawful or contrary to its licence, sanctions obligations, product-governance rules or risk controls. The Client is responsible for ensuring that accessing the Services is lawful in the Client’s country.

3.5The Company may rely on the information provided in the application and any subsequent assessment. The Client must not withhold information that would reasonably affect classification, appropriateness, product access, leverage or risk limits. If the Client declines to provide information, or the information is insufficient or inconsistent, the Company may decline the application, restrict products, reduce leverage, place the Account in close-only mode or terminate the Services.

3.6The Company may review and change a Client classification where required by Applicable Law or where the facts on which the original classification was based have changed. The Company will notify the Client of a material reclassification and any resulting change in protections, disclosures or available Services.

3.7Where the Company warns that a product or Service may not be appropriate, any decision to proceed remains the Client’s own decision and does not create a recommendation by the Company. The Company may nevertheless refuse access where it considers that refusal necessary to meet Applicable Law, product-governance obligations or its documented risk controls.

4.2The Company may offer only the Financial Instruments shown as available for the Client’s assigned Account. Availability may depend on residence, classification, account type, knowledge and experience, market access, liquidity and Applicable Law.

4.3The Company operates on an agency/straight-through-processing (STP) basis. The Company transmits Client Orders to one or more approved liquidity providers or execution counterparties for execution and does not act as principal, market maker or counterparty to the Client’s Transaction. Routing and execution are conducted in accordance with the Order Execution Policy, the relevant confirmation and Applicable Law.

4.4The agency/STP execution capacity described in clause 4.3 is limited to transmitting and routing Client Orders for execution. It does not create a fiduciary, trustee, partnership or broader agency relationship, except to the extent a specific duty is imposed by Applicable Law or expressly accepted by the Company in writing.

4.5Unless expressly stated otherwise for a particular Financial Instrument, Transactions are cash-settled and do not give the Client ownership, voting rights or delivery rights in the underlying asset. References to an underlying market or asset are used to explain pricing and economic exposure only.

4.6The Company is not obliged to accept every Order, maintain every Financial Instrument, provide continuous quotations, or keep a Service available indefinitely. It may introduce, suspend or withdraw a product or Service for regulatory, market, liquidity, counterparty, technology or risk-management reasons, subject to reasonable notice where practicable and appropriate treatment of existing Positions.

4.7Any market commentary, research, signals, education, news, analysis, calculator, model output or other general information is provided for information only, may be incomplete or delayed, and is not a personal recommendation. The Company does not warrant that such material is accurate, current or suitable for the Client and is not obliged to update or withdraw it.

4.8The Client retains sole responsibility for selecting Financial Instruments, deciding whether and when to trade, determining Order size and maintaining adequate diversification and risk controls. The Company has no duty to monitor the Account for loss, profitability, concentration, consistency with objectives or adverse market developments.

5.2The Client acts as principal and for the Client’s own benefit unless the Company has approved another capacity in writing. Funds and assets deposited must belong beneficially to the Client, unless a lawful and documented third-party arrangement is approved.

5.3The Company may rely on instructions that it reasonably believes originate from the Client or an authorised representative. The Client remains responsible for acts of authorised representatives until the Company has received and had reasonable time to process written revocation.

5.4The Client must keep credentials, devices, access codes and authentication factors secure; must not share them; and must notify the Company immediately of suspected compromise, unauthorised access or erroneous instructions. The Company may suspend access while investigating.

5.5Where a Client comprises more than one person, each person is jointly and severally liable, and the Company may act on the instruction rules recorded for the Account.

5.6The Company may require an authorised representative, director, signatory, trustee, partner or beneficial owner to complete identity and authority checks. A mandate is effective only after acceptance by the Company. The Company may reject, limit or suspend a mandate where authority is unclear, disputed, expired, inconsistent with the Account instructions or otherwise creates legal or operational risk.

5.7If the Company receives conflicting instructions, becomes aware of a dispute concerning ownership or authority, or reasonably doubts an instruction, it may decline to act, seek confirmation, restrict the Account or require a court order or other satisfactory evidence. The Company is not liable for a reasonable delay taken to verify authority.

5.8The Client must notify the Company immediately of death, incapacity, insolvency, dissolution, administration, receivership, loss of authority, change of control or any comparable event. Until satisfactory legal evidence is received and verified, the Company may restrict the Account, cancel pending Orders and take reasonable steps to preserve assets or reduce market exposure.

5.9Separate Accounts, sub-accounts and wallets maintained for the same Client may be treated individually for trading and reporting, but the Company may consider them together for compliance, exposure, credit, risk, set-off and default purposes to the extent permitted by Applicable Law. Notwithstanding the foregoing, negative-balance protection is determined separately for each Account in accordance with clause 9.6.

5.10The Account may be maintained in one or more supported currencies. The Client bears the risk and cost of currency conversion. The Company may convert an amount when reasonably required for Margin, settlement, fees, withdrawals, close-out or account administration, using a rate derived from an available market or service-provider rate plus any disclosed conversion charge.

6.2The Client is responsible for compatible equipment, connectivity, cybersecurity and verifying that an Order has been received and executed. An Order is not effective merely because the Client attempted to transmit it.

6.3The Client must not reverse engineer, interfere with, overload, scrape, manipulate or gain unauthorised access to the Trading Platform, pricing systems, market data or related infrastructure.

6.4Automated tools, Expert Advisors or application interfaces may be used only where permitted in the Contract Specifications and must not create abusive order traffic, exploit errors or impair systems. The Company may impose reasonable technical limits.

6.5The Company owns or licenses all rights in the Trading Platform, Website, software, interfaces, price feeds, market data, reports, logos, documentation and related content. Except for the limited right of use in clause 6.1, no intellectual-property right is transferred to the Client. The Client must comply with any third-party market-data or software licence notified by the Company.

6.6Market data may be indicative, delayed, derived or supplied by third parties. The Client must not redistribute, publish, commercialise or use it to create a competing product unless expressly authorised. An external price is not proof that the same price, liquidity or size was executable through the Company.

6.7The Client must maintain appropriate security controls, including supported software, malware protection and secure networks. The Client must log out after use and must not access the Services through a device or network that is known or reasonably suspected to be compromised.

6.8The Company may impose session, message, Order, connection, API or data limits and may disable a tool or connection that threatens stability, security, fair access or orderly execution. Where reasonably possible, the Company will distinguish between inadvertent technical activity and deliberate abuse before applying a permanent restriction.

6.9The Client acknowledges that electronic services may be unavailable, delayed or inaccurate. If the Trading Platform is unavailable, the Client may use another Approved Medium made available by the Company, but the Company does not guarantee that an alternative channel will always be available or that an instruction can be executed before the market moves.

7.2An Order becomes binding only when accepted and executed by the Company. The Company does not guarantee acceptance, execution, execution at a requested price, or cancellation of an Order already in process.

7.3Pending Orders are not guaranteed. Gaps, volatility, insufficient liquidity, market closure or disruption may cause execution at the first available price, partial execution, delay, rejection or cancellation.

7.4The Company may aggregate or split Orders where permitted and where it reasonably considers this unlikely to disadvantage the Client overall, although the effect for a particular Order may be less favourable.

7.5The Company’s electronic records, confirmations and platform logs are prima facie evidence of Orders and Transactions, subject to correction of proven error.

7.6The Company may refuse, cancel or delay an Order where the relevant market is closed or suspended; a quote is unavailable or stale; available liquidity is insufficient; the Order exceeds size, price, position or risk limits; Margin is insufficient; the instruction would breach Applicable Law; the Account is restricted; identity or authority cannot be verified; a technical or pricing error is suspected; or execution would be commercially impossible on the stated terms.

7.7A request to amend or cancel an Order is effective only when accepted and processed. The Company is not responsible where an Order is executed before an amendment or cancellation reaches the relevant system or venue.

7.8Limit, stop, stop-loss, take-profit, trailing-stop and other conditional Orders are subject to the functionality and rules stated in the Contract Specifications. A trigger instruction does not reserve liquidity and is not a guarantee of execution at the trigger or requested price.

7.9The Company may set minimum and maximum Order sizes, price-distance rules, expiry rules, position limits, concentration limits and maximum numbers of pending Orders. Orders outside those parameters may be rejected or cancelled.

7.10Telephone instructions may be accepted only after reasonable identity checks and are binding once accepted. Calls and electronic communications may be recorded. In the event of a discrepancy, the Company’s time-stamped platform, server, communication and transaction records will be considered together and will be rebuttable evidence, rather than conclusive evidence of an incorrect result.

7.11The Client must not assume that an instruction has been accepted merely because a message was sent or displayed. The Client must check the Account and confirmation. Duplicate instructions remain the Client’s responsibility unless caused by a proven Company system error.

8.2Quoted prices may be derived from liquidity providers, execution venues, reference markets and the Company’s pricing methodology. They may differ from prices displayed elsewhere. The bid-offer difference is the spread.

8.3Market execution may result in positive or negative slippage. Stop-loss, take-profit and other contingent Orders become executable when the applicable trigger is reached but are not guaranteed at the trigger price.

8.4Spreads, liquidity and execution conditions may change without prior notice during volatility, market openings or closures, news, low-liquidity periods or exceptional events.

8.5Additional execution provisions, venues, price sources and review arrangements are set out in the Order Execution Policy, which forms part of this Agreement.

8.6Execution quality is assessed in accordance with the Order Execution Policy. The Company may consider the total result, including price, spread, commission, financing, speed, likelihood of execution and settlement, size and nature of the Order. Price will ordinarily be an important factor, but another factor may take precedence where necessary to obtain the best possible result.

8.7Specific instructions from the Client may prevent the Company from applying its usual execution arrangements for the elements covered by those instructions. The Company may decline a specific instruction where it cannot be implemented lawfully or operationally.

8.8The Company may execute through one or more venues, liquidity providers, brokers, exchanges, market makers or counterparties, or outside a regulated market where permitted and disclosed. The Client consents to the execution arrangements described in the Order Execution Policy.

8.9An executed price may include the Company’s spread or mark-up and may reflect external price sources, available liquidity, Order size, market impact, hedging cost, credit and operational factors. The Company is not required to pass through the most favourable price visible on an unrelated venue where that price was not available to the Company for the relevant size and time.

8.10Where an Order is partially filled, each fill may occur at a different price and the remaining quantity may stay pending, be cancelled or be rejected according to the Order type and market conditions. Aggregation and allocation will be performed under the Order Execution Policy using an approach intended to be fair and orderly.

9.2The Company may change Margin or leverage prospectively where reasonably required by market conditions, concentration, volatility, liquidity, regulatory requirements or risk management. Where practicable, notice will be given; urgent changes may take immediate effect.

9.3The Company is not obliged to make a Margin Call. Platform indicators or communications are informational only. The Client remains responsible for monitoring the Account and maintaining Margin.

9.4If the Account reaches the applicable stop-out level or otherwise fails Margin requirements, the Company may close some or all Positions and cancel Orders without prior notice. The Company may choose the sequence of close-out reasonably, but does not guarantee the sequence or price.

9.5Hedged Positions may still require Margin and may be closed independently. Changes in spread, financing or leg availability can affect hedged Positions.

9.6Negative-balance protection applies to every Client on a per-Account basis. After all Positions in the relevant Account have been closed and all Transactions, charges and adjustments have been finally posted, an eligible negative balance will be restored to zero. Protection does not apply, and may be withheld or reversed to the extent permitted by Applicable Law, where the negative balance results from fraud, abusive trading, a Manifest Error or pricing error, unauthorised activity, or the Client’s material breach of this Agreement.

9.7Margin is calculated using the Company’s applicable prices, conversion rates and methodology. Unsettled profit, bonus or credit, hedged exposure and assets subject to restriction may be excluded or discounted when determining available Margin.

9.8The Company may apply higher Margin or lower leverage to a particular Financial Instrument, Account or group of related Accounts because of volatility, liquidity, concentration, event risk, credit risk, Client classification, unusual exposure or suspected abuse. A change may apply to new and, where necessary, existing Positions.

9.9A Margin Call, warning or notification—if provided—is a courtesy and does not waive the Company’s right to close Positions. Delayed or failed delivery of a warning does not prevent close-out and does not transfer responsibility for monitoring Margin to the Company.

9.10Automatic close-out may be affected by gaps, suspension, lack of liquidity, system latency or Force Majeure. The Account may therefore fall below the stop-out level before Positions are closed, and the final loss may exceed the level displayed when close-out began.

9.11The Company may close Positions individually or in groups and may consider liquidity, risk, market status, size and operational efficiency when choosing the sequence. It is not obliged to close the most or least profitable Position first.

9.12Subject to the per-Account negative-balance protection in clause 9.6, the Client must pay any valid debit balance that is not eligible for protection. Protection may be withheld or reversed only on a ground stated in clause 9.6 and only to the extent permitted by Applicable Law.

10.2Client Money may be held with approved banks, payment providers, custodians or other permitted institutions. Segregation does not eliminate bank, payment-provider, custodian, operational, legal or insolvency risk.

10.3The Client authorises the Company to transfer Client Money where reasonably required for settlement, Margin, execution, safeguarding or service provision, subject to Applicable Law and the Client Money rules.

10.4Deposits and withdrawals are governed by the Deposit and Withdrawal Policy. Payments generally must be made from and returned to an account in the Client’s name. The Company may reject or return third-party payments and conduct verification or enhanced due diligence before processing.

10.5The Company may delay or refuse a withdrawal to the extent reasonably necessary to comply with Applicable Law, investigate fraud or disputes, complete due diligence, preserve required Margin, satisfy valid obligations or follow payment-provider requirements.

10.6The Company may convert currency at a rate reasonably derived from its provider or market rate and may deduct disclosed conversion, intermediary and processing charges.

10.7Client Money may be held in one or more segregated client-money accounts with highly regulated banks, payment institutions or other safeguarding institutions located in jurisdictions in which the Company is authorised or otherwise lawfully permitted to maintain such accounts. Client Money may be held in USD, EUR, GBP or another currency accepted by the Company. No interest is payable or credited to the Client on Client Money unless required by Applicable Law. Where reasonably necessary for Margin, execution or settlement, Client Money may be transferred to an approved liquidity provider or execution counterparty in accordance with Applicable Law and the Company’s safeguarding arrangements. The Company will perform a complete reconciliation of Client Money records and balances on each Business Day.

10.8A deposit is treated as received only when cleared funds are credited to the relevant account and identified to the Client. The Company is not responsible for delay caused by a bank, card issuer, payment provider, blockchain or intermediary, or by incomplete or inaccurate payment information.

10.9The Company may return funds to their source, apply a withdrawal hierarchy or require withdrawal through the original funding method to comply with financial-crime controls and payment-provider rules. Profit or amounts exceeding the original funding may be paid by another verified method in the Client’s name.

10.10A withdrawal request does not reduce open exposure or reserve funds until approved and processed. The amount available for withdrawal may be reduced by Margin, pending charges, unsettled Transactions, chargeback exposure, disputed payments or other matured obligations.

10.11The Client must not initiate an unjustified chargeback, reversal or payment dispute. If a payment is reversed or dishonoured, the Company may suspend the Account, cancel a related credit, close Positions where necessary to prevent further loss, and recover the reversed amount and reasonable direct costs, subject to investigation and the Client’s right to dispute an error.

10.12Where a bank, payment provider or custodian fails or becomes insolvent, the Client may share proportionately in any shortfall attributable to pooled client funds, subject to Applicable Law and any available compensation or recovery rights. The Company remains responsible for its own breach of mandatory safeguarding duties.

10.13The Company will perform reconciliations and maintain records sufficient to identify the Client’s entitlement in accordance with Applicable Law. The Client must promptly report an apparent funding or withdrawal discrepancy.

10.14If an Account is inactive or dormant for the period stated in the fee schedule, the Company may apply disclosed administration charges, restrict the Account, return a small residual balance where practicable or close the Account after notice. No dormant-account rule permits the Company to appropriate Client Money contrary to Applicable Law.

11.2Charges may be debited from the Account when due. If the Account lacks funds, the Company may close Positions or recover the amount as a debt.

11.3The Client is responsible for taxes, duties and reporting arising from the Account or Transactions. The Company may withhold or report amounts where required by law.

11.4The Company may pay or receive commissions, rebates or other benefits connected with distribution, referral, execution or service providers only where lawful and managed under the Conflicts of Interest Policy. Material arrangements will be disclosed where required.

11.5Financing, swap, rollover or administration charges may be credited or debited when a Position remains open past the relevant cut-off time. Rates may vary by Financial Instrument, direction, day, market conditions and Account type, and a multi-day adjustment may apply before weekends or holidays as shown in the Contract Specifications.

11.6A swap-free or Islamic Account remains subject to its specific terms. The absence of conventional swap does not prevent a lawful and disclosed administration charge. The Company may review eligibility, request supporting information, convert the Account type or remove an improperly obtained benefit where the Account has been used contrary to those terms.

11.7The Company may amend fees prospectively by notice or through an updated fee schedule. Changes driven directly by an exchange, venue, tax authority, data supplier, payment provider or liquidity provider may take effect on shorter notice where reasonably necessary.

11.8The Company may deduct or withhold tax, levy or other amount where required by Applicable Law and may request tax forms, self-certifications or taxpayer identification information. The Client remains responsible for obtaining independent advice and making required filings.

12.2For expiring, rolling or deliverable-underlying products, the Company may close, roll, cash-settle or otherwise adjust Positions as described in the Contract Specifications.

12.3For corporate actions, market adjustments, index changes, suspensions, consolidations, splits, distributions, takeovers or similar events, the Company may make a fair and commercially reasonable adjustment, close-out or cancellation to preserve the economic effect of the Transaction as nearly as practicable.

12.4The Company may set a last trading date, close-only period, expiry time, rollover method or settlement price for a product. The Client is responsible for reviewing these terms and closing or adjusting a Position before any applicable deadline.

12.5A corporate action adjustment may include changes to quantity, price, contract size, cash balance, financing, pending Orders or other terms. The Company will use information reasonably available from the underlying market, issuer, venue or provider and will seek a commercially reasonable economic result; exact replication may be impossible for a derivative.

12.6Where an underlying instrument is suspended, delisted, cancelled, subject to takeover, declared worthless, converted or otherwise materially changed, the Company may suspend valuation, place the Position in close-only mode, cancel pending Orders, cash-settle, close or substitute the reference instrument on a fair and reasonable basis.

12.7Fractional entitlements arising from an adjustment may be rounded or cash-settled. Taxes, withholding and third-party charges attributable to a corporate action may be passed to the Client where disclosed or required.

13.2The Client must review confirmations, statements and Account activity promptly and notify the Company of a specific objection without undue delay and, in any event, within five (5) Business Days after the relevant record becomes available. This period does not prevent correction of a Manifest Error or affect any right that cannot lawfully be excluded.

13.3The Client may access current Account information through the Client Portal or Trading Platform. Availability online does not relieve the Company of mandatory reporting obligations.

13.4A confirmation or statement may be provided electronically and may identify the Financial Instrument, direction, quantity, price, time, charges and other material terms. The Company may correct an administrative or calculation error and will issue or make available a corrected record.

13.5An objection must identify the disputed Transaction or entry, the alleged error and the supporting facts. The Client must preserve relevant device, platform and communication records and cooperate reasonably with the investigation.

13.6Failure to object within the stated period may be evidence that the record was accepted, but it does not validate fraud, wilful misconduct, a Manifest Error or a liability that cannot lawfully be excluded.

14.2The Client confirms that funds and assets are from lawful sources, are not proceeds of crime, and are not subject to undisclosed third-party rights.

14.3The Client confirms that each trading decision is independent, informed and made without reliance on any representation not expressly included in the Agreement.

14.4The Client undertakes to cooperate with lawful identity, sanctions, tax, source-of-funds, source-of-wealth and transaction-monitoring requests and to provide documents within the requested reasonable period.

14.5A corporate Client undertakes to maintain all corporate authorisations and promptly disclose changes to directors, shareholders, beneficial owners, signatories, control or legal status.

14.6The Client represents that the Account will not be used for a person whose identity or beneficial ownership has not been disclosed and accepted, to evade a legal or contractual restriction, or to facilitate unlawful payments, market abuse, sanctions evasion or tax evasion.

14.7The Client represents that no insolvency, litigation, enforcement, attachment or other event exists that materially impairs the Client’s ability to perform this Agreement, except as disclosed in writing.

14.8The Client acknowledges that leverage magnifies losses, that market orders and protective Orders are not guaranteed, and that the Client has the knowledge, experience and financial capacity represented in the application. These representations are repeated whenever the Client places an Order.

14.9The Client must maintain adequate records and, if acting in a business capacity, appropriate systems and controls for authorisation, supervision, cybersecurity, sanctions, financial crime and tax compliance.

15.2The Company may refuse, delay, block, cancel or report an activity; restrict or suspend an Account; or retain funds where reasonably required or permitted by Applicable Law. The Company may be prohibited from explaining the reason.

15.3The Client must not use the Account as a banking or payment-transmission facility. Repeated funding and withdrawal without genuine trading activity may be investigated, restricted and charged the reasonable costs incurred.

15.4The Company may verify information using public records, credit or fraud databases, identity-verification services, banks, payment providers and other lawful sources. The Client authorises reasonable verification enquiries and understands that third parties may retain an enquiry record.

15.5The Company may establish source-of-funds, source-of-wealth, transaction, deposit, withdrawal, product, country and exposure limits. A limit does not create an obligation to process activity up to that amount.

15.6Where the Company is required to freeze, reject, block, return or report assets or activity, it will act in accordance with Applicable Law. No contractual deadline requires the Company to act in a way that would amount to tipping-off or breach a legal restriction.

16.2Prohibited conduct includes knowingly exploiting manifest pricing or technical errors; latency arbitrage; abusive high-frequency messaging; coordinated trading across related accounts to obtain an artificial benefit; unauthorised access; identity or payment fraud; market abuse; and abuse of swap-free, bonus, credit or referral arrangements.

16.3The Company may investigate objectively and may temporarily restrict affected trading or withdrawals while doing so. Remedies must be proportionate to the conduct and evidence and may include rejecting affected Orders, correcting erroneous Transactions, removing an improperly obtained benefit, closing Positions, terminating the Account and recovering direct loss.

16.4The Company will not cancel a legitimate profitable Transaction merely because it was profitable. Any correction will be based on a documented error, prohibited conduct, Applicable Law or another express contractual ground.

16.5Examples of relevant evidence include timing and pattern of Orders, price-source and latency data, related-account connections, device and network identifiers, payment links, communications, platform logs, market conditions, counterparty records and whether the strategy could reasonably have been executed in the underlying market.

16.6High-frequency, algorithmic, scalping, hedging, news or arbitrage strategies are not prohibited merely by label. They become prohibited only where they breach stated platform or product limits, exploit an error or delay, manipulate execution, create disorderly traffic, coordinate an artificial outcome or otherwise fall within clause 16.2.

16.7Before making a final adverse adjustment, the Company will ordinarily give the Client notice of the concern and a reasonable opportunity to respond, unless immediate action is required to prevent loss, preserve evidence, comply with law or protect system integrity.

16.8A remedy will be limited, so far as reasonably practicable, to affected Transactions, benefits or loss. The Company may recover its direct loss and reasonable investigation cost where the Client’s deliberate or reckless breach is established, but it will not impose an undisclosed penalty.

17.2Where a Manifest Error occurs, the Company may, acting fairly and reasonably, correct the price or terms to the level that would have applied absent the error, cancel the affected Transaction, or leave it unchanged. The Company will consider any Client loss or gain and will notify the Client with a reasonable explanation.

17.3This clause does not permit arbitrary retrospective repricing and does not limit rights that cannot lawfully be excluded.

17.4Relevant factors include the prevailing underlying-market price, executable liquidity, time and size of the Order, external price sources, spread, volatility, whether trading was suspended, the nature and duration of a system fault and whether the Client knew or should reasonably have known of the error.

17.5The Company may make corresponding balance, Margin, financing and Position adjustments required to give effect to a correction. It will keep an audit trail and, where requested, provide sufficient information to explain the basis without disclosing confidential third-party or security information.

17.6A correction request by the Client will be investigated under the same standards. The Client must notify the Company promptly after discovering an apparent error and must not knowingly seek to increase exposure or withdraw proceeds derived from it.

18.2The Company maintains arrangements to identify, prevent or manage conflicts and will disclose the general nature or source where its arrangements are insufficient to prevent a material risk of damage. Details are in the Conflicts of Interest Policy.

18.3The Company may have an economic interest different from the Client’s, including where it earns a spread or commission or has a commercial arrangement with a liquidity provider, execution counterparty or service provider. The Company does not act as principal or retain Client market exposure. The existence of another economic interest does not remove the Company’s obligations under Applicable Law, the Order Execution Policy or its conflict controls.

18.4Conflict controls may include organisational separation, access restrictions, remuneration controls, execution monitoring, product governance, personal-account dealing rules, disclosure and declining to act. The Client may request further information about a disclosed conflict, subject to confidentiality obligations.

19.2The Client acknowledges market, leverage, liquidity, gap, execution, counterparty, currency, financing, technology, legal, tax and force-majeure risks and confirms having read the Risk Disclosure Policy.

19.3Past performance, simulations, educational material, research, market commentary and third-party signals are not guarantees and do not constitute personal investment advice.

20.2On termination or default, Transactions may be closed and their values aggregated into one net amount payable by one party to the other, subject to insolvency law and mandatory client-money protections.

20.3No general lien or security interest over Client Money shall apply in a manner inconsistent with mandatory safeguarding rules.

20.4For close-out netting, the Company may determine the replacement or close-out value of each Transaction using available market quotations, provider prices, models, hedging costs and commercially reasonable estimates where a market price is unavailable. Amounts may be converted into the Account base currency and aggregated with unpaid fees and other matured obligations.

20.5If the same Client holds multiple Accounts or liabilities in different capacities, set-off or netting will apply only to the extent legally enforceable and consistent with the relevant capacity, trust, client-money and insolvency rules.

20.6A net amount becomes due when calculated and notified. A good-faith calculation is binding in the absence of manifest calculation error, but the Client may request supporting detail and challenge the result through the complaints and dispute process.

21.2An Event of Default also occurs where an authority, bank, provider or court takes action that materially prevents performance, or where the Company reasonably determines on objective grounds that immediate protective action is necessary to prevent material loss or legal breach.

21.3Additional Events of Default include an unauthorised chargeback; attachment or enforcement against material Account assets; failure to provide requested compliance information within a reasonable period; breach or termination of a guarantee or authority relevant to the Account; and a representation becoming materially untrue.

21.4For a corporate Client, merger, change of control, loss of licence, cessation of business or material deterioration in financial condition may constitute an Event of Default where it materially increases legal, credit or performance risk and the Company reasonably determines that continued service cannot be maintained on the existing terms.

21.5Where an Event of Default is capable of remedy and does not require urgent protective action, the Company will ordinarily provide reasonable notice and an opportunity to remedy. No cure period is required for fraud, illegality, insolvency, market abuse, security compromise or an immediate Margin failure.

22.2The Company will act in good faith and use commercially reasonable valuation methods. It will provide a statement of the resulting amount as soon as reasonably practicable.

22.3These rights are cumulative and do not limit any right available under law.

22.4Protective action may include placing the Account in close-only mode, refusing withdrawals, requiring additional Margin, reducing leverage, cancelling pending Orders, closing or hedging Positions, converting currency, enforcing a guarantee, retaining amounts otherwise payable and exercising termination or netting rights.

22.5The Company is not required to take the same action, or act at the same time, for every Account. It may consider product, liquidity, exposure, Client classification, legal restrictions and the urgency of the risk, provided its decision is not arbitrary or discriminatory.

22.6After close-out, the Company will credit any net amount owed to the Client or require payment of any net debit amount, subject to Client Money, sanctions, insolvency and other legal restrictions.

23.2The Company may terminate this Agreement by giving the Client not less than forty-eight (48) hours’ written notice. The Company may provide a longer notice period at its discretion, having regard to the circumstances of the Client, the Account and any operational or regulatory considerations. The Company may terminate immediately for an Event of Default, illegality, regulatory direction, a security threat, fraud, material risk or prolonged inactivity where permitted by Applicable Law.

23.3Termination does not affect accrued rights, outstanding Transactions, confidentiality, data retention, liability, netting, dispute or other provisions intended to survive.

23.4Suspension or close-only status does not terminate the Agreement and does not prevent financing, corporate-action adjustments, Margin requirements or other consequences from continuing on open Positions. The Client remains responsible for monitoring and, where permitted, reducing exposure.

23.5On ordinary termination, no new Orders may be accepted other than Orders needed to close or transfer existing Positions. If the Client does not close Positions within the notified period, the Company may close them at the available market price and deduct applicable costs.

23.6The Company may retain Account records and amounts required to meet unresolved Transactions, chargebacks, complaints, investigations, taxes, legal holds and regulatory obligations. Any undisputed balance will be returned through a verified payment method when those requirements are satisfied.

23.7Termination does not entitle either party to reverse a valid completed Transaction. Clauses concerning payment, netting, confidentiality, records, intellectual property, liability, indemnity, complaints, governing law and accrued rights survive.

24.2Subject to clause 24.1 and Applicable Law, the Company is not liable for indirect, incidental, special or consequential loss; loss of profit, opportunity, goodwill or data; or loss caused by market movement, execution risk, third-party systems, Client instructions, credential compromise attributable to the Client, or a Force Majeure Event.

24.3Nothing excludes liability that cannot lawfully be excluded, including any mandatory obligation concerning Client Money or regulatory duties.

24.4The Client indemnifies the Company against reasonable direct loss, liability and cost resulting from the Client’s material breach, fraud, unlawful conduct or unauthorised use, except to the extent caused by the Company’s own breach, negligence or misconduct.

24.5The Company does not guarantee uninterrupted access, exact transmission time, continuous pricing, execution at an external-market price or the performance or solvency of an independent bank, custodian, payment provider, venue, liquidity provider, software provider or network. This does not excuse the Company from reasonable care in selection, instruction and monitoring where such a duty applies.

24.6The Client must take reasonable steps to mitigate loss, including securing credentials, monitoring the Account, reporting discrepancies promptly and avoiding additional activity based on a suspected error. A failure to mitigate may reduce recoverable loss to the extent permitted by law.

24.7Any liability cap stated in an account-specific term will not apply to fraud, wilful misconduct, gross negligence, breach of mandatory Client Money duties, death or personal injury caused by negligence, or another liability that cannot lawfully be limited. No general monetary cap is inserted in this draft pending Mauritius legal review.

24.8The indemnity does not cover loss that is remote, punitive or caused by the Company’s own breach. The Company must provide reasonable details of an indemnified amount, and the Client may contest it through the complaints and dispute procedure.

25.2During such an event, the Company may take reasonable and proportionate steps including changing trading hours, Margin or leverage; restricting Orders; suspending pricing or trading; closing or valuing Positions; or delaying performance.

25.3The Company will notify affected Clients where reasonably practicable and will resume normal service when it is reasonably able.

25.4Other reasonable measures may include changing price sources, widening spreads, imposing position or Order limits, cancelling affected pending Orders, using an alternative valuation method, extending settlement time or closing a Position where continued maintenance is impossible or would create disproportionate risk.

25.5The Company will consider the interests of affected Clients and seek to avoid unnecessary prejudice, but may prioritise compliance with law, market integrity, system stability and protection of client assets. Similar positions may experience different outcomes because of timing, liquidity, size or venue.

25.6A Force Majeure Event does not excuse payment or delivery that became due before the event, except to the extent performance is legally prohibited or operationally impossible. The Company will keep a record of material decisions and review restrictions as conditions change.

26.2The Client must keep contact details current and monitor the Approved Media. Communications may be recorded and retained for quality, security, evidential and regulatory purposes.

26.3Official notices to the Company must be sent to [INSERT LEGAL-NOTICES EMAIL] or another address designated by the Company. Trading or withdrawal instructions must use the designated operational channels.

26.4The governing language is English. Translations are provided for convenience unless expressly stated otherwise.

26.5A communication sent to the latest contact details supplied by the Client may be treated as properly addressed. The Client bears the consequences of failing to update those details, except where the Company knew that delivery had failed and the communication concerned a material contractual change requiring notice.

26.6Electronic notices may include hyperlinks to durable documents. The Company will retain or make available the applicable version. The Client should download and retain confirmations, statements, policies and notices.

26.7The Company may communicate in another language as a convenience. If a translation conflicts with the English version, the English version prevails, subject to mandatory law. The Client must request clarification before trading if a communication is not understood.

26.8The Company will never request a password or full authentication code through an unofficial channel. The Client must verify unusual payment or credential requests using published contact details. The Company is not responsible for impersonation fraud it did not cause, but will cooperate reasonably with an investigation.

27.2Information may be shared with regulators, authorities, affiliates, banks, payment providers, liquidity providers, technology vendors, identity-verification providers, professional advisers and other recipients where lawful and necessary.

27.3Each party must keep non-public information confidential except where disclosure is authorised, necessary to perform the Agreement, required by law or made to professional advisers under confidentiality.

27.4The Company may retain applications, communications, recordings, Orders, Transactions and due-diligence records for the period required by Applicable Law.

27.5Personal data may be transferred internationally where necessary for the Services, compliance or administration, using safeguards required by applicable data-protection law. Further information on lawful bases, retention, rights and complaints appears in the Privacy Policy.

27.6The Company may record telephone, video, chat, email and platform communications and use recordings to verify instructions, monitor quality and conduct, resolve disputes, prevent fraud and meet legal obligations. Recordings remain the Company’s records, subject to applicable access rights.

27.7Confidentiality does not prevent disclosure to an affiliate, insurer, auditor, bank, provider, proposed assignee, professional adviser or authority where reasonably necessary and lawful, provided appropriate confidentiality or legal safeguards apply.

28.2The Company will acknowledge, investigate and issue a reasoned response within the periods stated in its Complaints Handling Policy and Applicable Law.

28.3If unresolved, the Client may use any escalation or regulatory route stated in the Complaints Handling Policy. Submitting a complaint does not prevent either party from seeking urgent relief or exercising non-excludable legal rights.

28.4The Client should complain promptly after becoming aware of the matter. A complaint does not suspend Margin, payment or risk-management obligations unless the Company confirms otherwise in writing.

28.5The Company may request further information, interview relevant personnel, examine platform and provider records and issue a final response stating its findings and any remedy. Complaints are handled independently of the employee or function principally responsible where reasonably practicable.

28.6Nothing in this clause shortens a mandatory limitation period or excludes access to the Financial Services Commission, Mauritius, a competent court or another mandatory external mechanism.

29.2Material amendments adverse to the Client will be notified reasonably in advance through an Approved Medium, except where immediate effect is required by law, a regulator, security, market conditions or a third-party dependency. The notice will explain the effective date.

29.3Continued use after the effective date constitutes acceptance where lawful. If the Client does not accept a material amendment, the Client may terminate before it takes effect after closing Positions and settling obligations.

29.4Changes to live market variables in the Contract Specifications may take effect as stated there and under clauses 8 and 9.

29.5An amendment will not retrospectively alter a completed Transaction except where required by law, a corporate action, a Manifest Error correction or another express provision applicable when the Transaction was entered.

29.6The Company will maintain version control and record the effective date of material documents. If consent is legally required rather than notice, the amendment will not bind the Client until valid consent is obtained.

30.2Subject to any mandatory complaint or dispute-resolution route, the courts of Mauritius have exclusive jurisdiction to settle any dispute arising out of or in connection with this Agreement. This does not prevent the Company from seeking urgent protective or interim relief, or enforcing a judgment or security, in another court of competent jurisdiction.

30.3Before commencing ordinary court proceedings, a party should first use the complaints procedure and may propose good-faith settlement discussions, unless urgent injunctive, protective or limitation-preserving action is required.

30.4A judgment or order may be enforced in any jurisdiction permitted by law. Service of proceedings must follow applicable procedural law and is not replaced by an ordinary trading or support communication.

31.2If a provision is unlawful or unenforceable, it will be modified to the minimum extent necessary or severed, without affecting the remainder.

31.3A delay or failure to exercise a right is not a waiver. A waiver must be in writing and applies only to the matter stated.

31.4The Agreement constitutes the entire agreement concerning its subject matter and replaces prior representations, without excluding liability for fraud.

31.5No person other than the parties and a permitted successor or assignee may enforce the Agreement, unless Applicable Law provides otherwise.

31.6The relationship is contractual. Nothing creates employment, partnership, joint venture, fiduciary status or authority for the Client to bind the Company. An introducing broker, affiliate, payment provider or marketing partner is not authorised to vary this Agreement or make a guarantee on the Company’s behalf unless expressly confirmed in writing.

31.7The Company may use affiliates and third-party providers to perform operational functions while remaining responsible to the extent required by Applicable Law. No outsourcing arrangement expands the Services promised to the Client.

31.8If a mandatory rule conflicts with this Agreement, that rule prevails to the extent of the conflict. The remaining terms continue in effect and must, where possible, be interpreted consistently with the Company’s licence and regulatory duties.

31.9No course of dealing, platform practice, delay or acceptance of a partial payment varies the Agreement. Rights and remedies are cumulative unless the Agreement or Applicable Law states otherwise.