Client Services
Agreement

Traders Trust Limited (hereafter the “Company”) is a limited liability company incorporated and registeredunder the laws of Seychelles, with Company number 8429440-1 and having its registered address at Room
B11, First Floor, Providence Complex, Providence, Mahe, Seychelles, authorized and regulated by the Financial
Services Authority (the “FSA”) as a Securities Dealer. The Company is authorized and regulated by the
Financial Services Authority in Seychelles (“FSA”) under the license number SD141 for the provision of theinvestment services specified in this Client Service Agreement (hereafter the "Agreement").
The Client is requested to read the Agreement and make sure it understands the following terms prioraccepting the Agreement and use the Company’s services.
Scope and Application: This Agreement governs the relationship between the Client and the Company andis electronically executed. The Client is required to accept these terms provided that it has read and agrees
with the terms of the Agreement by checking and/or clicking the respective acceptance checkbox during theOnline Account Opening Procedure which is further explained below.
For the avoidance of any doubt, this Agreement has the same legal effect and confers the same legal rights
upon the parties as if it had been signed. The Client hereby acknowledges and agrees that by completingand submitting the account opening documentation forms of the Company fully agrees to be abide by andbound by the terms set out in this Agreement.

Definitions
1. "Account" shall mean a trading account maintained by the Client with the Company;
2. "Applicable Regulations" means the rules of any relevant regulatory authority, the rules of any relevant
exchange, and all other applicable laws and rules in force from time to time including among others the
Securities Act 2007 as amended, the Securities (Conduct of Business) Regulations 2008, the Securities(Financial Statements) Regulations 2008, the Securities (Advertisements) Regulations 2008, the Securities(Forms and Fees) Regulations 2008, the Securities (Substantial Activity Requirement) Regulations 2018, theFinancial Services Authority Act 2013, the Anti-Money Laundering Act of 2006 as amended and thePrevention of Terrorism Act 2004 etc.
3. "Authorised Third Party-Representative" shall mean an individual person or legal entity undertaking atransaction on behalf of another individual person i.e. the Client or legal entity but in his/its own name;
4. "Company’s Website" shall mean the Company’s Website https://traders-trust.com/;
5. "CFD Contract" or "CFD" shall mean a contract which is a contract for difference by reference tofluctuations in the price of the relevant security or index;
6. "Client" shall mean the individual person, legal entity or firm being a customer of Traders Trust Limited;
7. "Company" shall mean Traders Trust Limited a limited liability company incorporated and registeredunder the laws of Seychelles, with Company number 8429440-1. The Company is authorized and regulatedby the Financial Services Authority in Seychelles (“FSA”) under the license number SD141 with registeredaddress at B11, First Floor, Providence Complex, Providence, Mahe;
8. "Equity" shall mean the aggregate of (i) the Balance; and (ii) unrealized profit or loss on open positions(after deduction of any Charges and the application of any Spread on closing of a position);
9. "Financial Instruments" shall mean Contracts for Differences (CFD) on spot Forex, spot precious metals,
futures, shares or any other commodities available for trading;
10. "Margin" shall mean the necessary funds so as to open or maintain open positions in a CFD Transaction;
11. "Margin Level" shall mean (Equity/ Margin) * 100; it determines the conditions of the Client’s Account.
12. "MTF" means a multilateral system operated by an investment firm or market operator, which brings
together multiple third-party buying and selling interests in financial instruments in the system, in
accordance with non-discretionary rules, in a way that results in a contract.
13. "Quote" shall mean the bid and ask prices at which a Financial Instrument can be bought and sold;
14. "Underlying Asset" means property of any description (including a currency or currency pair) or an index
or other factor designated in a CFD Transaction to which reference is made to fluctuations in the value or
price for the purpose of determining profits or losses under the CFD Transaction;
15. "Services" shall mean the services to be provided by the Company under this the Agreement;
16. "Spread" means the difference between the lower bid price and higher offer price of a quoted two-way
price for a Financial Instrument;
17. "Regulated Market" shall mean a Regulated Market (RM) is a multilateral system that is operated or
managed by a market operator and that brings together or facilitates the bringing together of multiple
third-party buying and selling interests in financial instruments within the system.
18. "Trading Platform" shall mean any online trading platform made available by the Company under the
Agreement;1. Services
1.1 The Company shall carry on business as dealing in securities, whether acting as principal or agent for thefollowing:a. To make or offer to make an agreement with another legal person to enter into or offer to enter into anagreement, for or with a view to acquiring, disposing of, subscribing for or underwriting securities or in any
way that effects or causes to effect a securities transaction.
b. b. Without limiting the generality of the above point, to cause any sale or disposition of or other dealingor any solicitation in respect of securities for valuable consideration, whether the terms of payment be on
margin, instalment or otherwise or any attempt to do any of the foregoing.
c. c. To participates as a securities dealer in any transaction in a security occurring upon a securities
exchange.
d. d. To receive as a securities dealer an order to buy or sell a security which is executed.
e. e. To manage a portfolio of securities for another Company on terms under which the first mentioned
Company may hold property of the other.
1.2 The services of paragraph 1.1 shall involve transactions in Financial Instruments not admitted to trading inRegulated Markets or an MTF and are over the counter ("OTC") traded instruments such as CFDs or any otherfinancial instruments or commodities.
1.3 Notwithstanding the above, the Company may outsource some functions to its related entities namely ABS
Advanced BackOffice Services Limited and/or TTCM Traders Trust Capital Markets Ltd. The related entities may
be acting as payment processors on behalf of the Company and execute agreements with third parties for the
purpose of processing or facilitating transactions on behalf of the Company. For this purpose, the Company
may also share information with the related entities or any other company in the same group in the event suchinformation is reasonably required in order to provide the products or services to its clients.
1.4 ABS Advanced BackOffice Services Limited, which is a related entity established in Cyprus with registeredaddress at 62 Kremastis Rodou, floor 1, Flat 101, Episkopi 4620 Limassol, Cyprus for the provision of support
functions through a Service Level Agreement. ABS Advanced BackOffice Services Limited may also serve as apayment processor on behalf of the Company and execute agreements with third parties for the purpose ofprocessing or facilitating transactions on behalf of the Company.
1.5 TTCM Traders Trust Capital Markets Ltd, also a related entity established in Cyprus with registered address
3 Thalia Street, Office Number 310-318, 3rd Floor, 3011, Limassol, Cyprus, is authorized and regulated by the
Cyprus Securities and Exchange Commission (the “CySEC”) with License Number 107/09. TTCM Traders Trust
Capital Markets Ltd may also serve as a payment processor on behalf of the Company and executeagreements with third parties for the purpose of processing or facilitating transactions on behalf of the Company.

2. Risk Disclosure & Acknowledgment
2.1 It is important for the Client to understand the risks involved before deciding to enter into a trading relationship with the Company. If the Client chooses to enter into a trading relationship with the Company, he should
remain aware of the risks involved and be able to have adequate financial resources to bear such risks.
2.2 The financial instruments offered by the Company are high-risk products that are traded on margin andcarry a risk of losing all Client’s initial deposit. These kinds of products can fluctuate significantly and present
a high risk of capital loss, therefore these products may not be appropriate or suitable for all clients and theClient should seek independent advice should he is not able to understand the risks involved.
2.3 General Risks and Acknowledgements: The Client acknowledges, understands, agrees and accepts therisks including but not limited:a. The Company does not and cannot guarantee that funds deposited in the Client’s Account for trading will
not be lost as a result of the Client’s transactions.
b. The Client acknowledges that, regardless of any information which may be offered by the Company, thevalue of any investment in Financial Instruments may fluctuate downwards or upwards and it is even probable that the investment may become of no value.
c. The Client acknowledges that he/she runs a great risk of incurring losses and damages as a result of thepurchase and/or sale of any Financial Instrument and accepts that he/she is willing to undertake this risk.
d. The use of historical data does not constitute a binding or safe forecast as to the corresponding future
performance of the Financial Instruments to which the said Information refers.
e. The Client is hereby advised that the transactions undertaken through the dealing services of the Company
may be of speculative nature. Large losses may occur in a short period of time and may be equal to thetotal value of funds deposited with the Company.
f. Some Financial Instruments may not become immediately liquid, for example, as a result of reduced
demand and the Client may not be in a position to sell them or easily obtain information on the value ofthese Financial Instruments or the extent of the associated risks.
g. When a Financial Instrument is traded in a currency other than the currency of the Client’s country ofresidence, any changes in the exchange rates may have a negative effect on its value, price and performance.
h. A Financial Instrument on foreign markets may entail risks different to the usual risks of the markets in the
Client’s country of residence. In some cases, these risks may be greater. The prospect of profit or loss fromtransactions on foreign markets is also affected by exchange rate fluctuations.
i. The Client should not purchase a Financial Instrument unless he/she is willing to undertake the risks oflosing entirely all the money which he has invested and also any additional commissions and otherexpenses incurred.
j. Under certain market conditions (for example but not limited to the following situations: force majeure
event, technical failure, communications network failure, poor or no liquidity, market news or announcements etc.) it may be difficult or impossible to execute an order.

k. Should the Equity of the Client be insufficient to hold current positions open, the Client may be called upon
to deposit additional funds at short notice or reduce exposure. Failure to do so within the required time may
result in the liquidation of positions at a loss and the Client will be liable for any resulting deficit.
m. Trading on-line, no matter how convenient or efficient, does not necessarily reduce risks associated withcurrency trading.
n. There is a risk that the Client’s trades in Financial Instruments may be or become subject to tax and/or any
other stamp duty, for example, because of changes in legislation or his/her personal circumstances. The Company does not warrant that no tax and/or any other stamp duty will be payable. The Client should be responsible for any taxes and/or any other duty which may accrue in respect of his/her trades.
o. Before the Client begins to trade, he/she should obtain details of all commissions and other charges forwhich the Client will be liable. If any changes are not expressed in money terms (but for example a spread),the Client should ask for a written explanation, including appropriate examples, to establish what suchcharges are likely to mean in specific money terms.
p. There may be situations, movements and/or conditions occurring at the weekend, at the beginning of theweek or intra-day after the release of the significant macroeconomic figures, economic or political news thatmake currency markets to open with price levels that substantially differ from previous prices. In this case, there
exists a significant risk that orders issued to protect open positions and open new positions may be executedat prices significantly different from those designated.

3. Account Opening Procedure
3.1 Before opening a new account, the Company provides to the Client via its Website or through an email orin person with the required information regarding the Company and a copy of this Agreement. After logging
on the website of the Company, the Client will complete and/or receive the application package which
consists of the following: a) account application form, b) relevant information/documents of the client, c) Client
Services Agreement.
3.2 The Company is obligated by the Applicable Regulations to perform KYC and due diligence proceduresin order to verify the identity of each person who registers online via the Company’s Website. For this purpose,
the Company will collect information about the Client such as name, surname, address, telephone number,email, nationality, date of birth and other details.
3.3 When the Company receives the Client’s completed online application form, it may use the information to
conduct any further enquiries about the Client as the Company determines under the circumstances and its
internal policies and procedures. The Company also carries out additional checks or periodic reviews. The
Client will need to co-operate with the Company and supply the information requested promptly. The Company
relies on the information that it is provided by the Client in the online application form or otherwise as being
correct and not misleading at all times, unless you notify us otherwise in writing. In particular, the Client must
notify the Company as soon as possible in writing if any of the details provided to us in your application form
or if your circumstances have subsequently changed.

3.4 The Company is not to be required (and may be unable under Applicable Regulations) to accept a person
as its Client until all documentation it requires has been received by properly and fully completed by such
person and all internal checks (including without limitation all anti-money laundering customer identificationand due diligence checks) have been duly satisfied. It is further understood that Company reserves the rightto impose additional due diligence requirements to accept Clients residing in certain countries where the riskof money laundering may be higher. During the customer identification and due diligence checks the Company
shall apply processes to verify the Client’s identity for which (amongst other things) photo identification information will be required by the Client. In certain circumstances we may require this information to be authenticated by an appropriate third party. The Company requires as minimum a government issued Photo identity
documents such as a passport, driving license and/or identity card containing your full name, personal photo,and date of birth, ID number and expiry date as well as evidence of your residential address, such as a utility
bill or bank statement, for the verification process. The information in these documents should agree with thedetails submitted in Client’s application.
3.5 The Company will assess the information received by the Client during the Account Opening Procedure inorder to determine whether the Client is eligible or not in investing and/or operating a trading account with
the Company. In the event that, the Client does not fully satisfy the Company’s required KYC and due diligenceprocedure within the time period set by the Company, the Company reserves the right to return any funds
deposited back to their origin and/or close the Client Account and/or to proceed to any other action deemednecessary.
3.6 The Client’s trading account will be considered opened only when the trading account is activated, whichmeans the trading account is not on a read only status and the Client can place his/her order for execution(i.e. the commencement of the business relationship between the Client and the Company). It is understoodthat the Client needs to pass the assessment and completion of the KYC and due diligence procedures of theCompany prior the activation of the Client’s trading account.

4. Fees and Charges
4.1 The Client shall be required to pay the charges as agreed from time to time, any fees or other charges
imposed by third parties during the execution of the services. The Company may charge the client for the
charges listed in clause 4.4 and/or other fees where applicable. In addition, in case of any inactivity (i.e. no
trading activity on the specific trading account) or the Client adopted any kind of trading strategy, which isdeemed abusive, the Company reserves the right to charge the Client all fees related to the Client’s specificdeposit and withdrawal, irrespective of the payment method used, which have been suffered by the Company.
4.2 By accepting this Agreement, the Client acknowledges that he has read, understood and is in agreementwith the fees and charges uploaded on the Company’s website. The Client further agrees that the Company
is entitled to change its charges without notifying or getting prior consent from the Client.

4.3 The Company is compensated for its services through the Buy/Sell (Ask/Bid) spread, so when you open a
position in a specific instrument, you essentially “pay” the spread. The spread rates per instrument can beviewed by the Client at any time on the Company’s website.
4.4 Subject to the Financial Instruments traded by the Client, the following charges may be incurred:
SpreadA spread is the difference between the bid (buy) and the ask (sell) price on the specific instrument you trade.
This cost is realised every time the Client opens and closes a trade.
Commission (applicable only to CFDs on futures and CFDs on shares)
This is the commission the Client pays when he buys and sells a Financial Instrument.
Currency conversion
This is the cost incurred when converting realised profits and losses as well as any costs and charges that are
denominated in a currency other than the base currency of the Client’s Account.
Overnight Funding /Swap (Financing Fee)
This is the swap cost for keeping your position open overnight. The swap cost can be positive or negative
depending of the instrument to be traded. An overnight funding amount is either added to or subtracted fromthe Client’s account when holding a position after a certain time.
Trading inactivity
The Client’s account is associated with the cost of maintenance and other regulatory or compliance requirements so if there are no transactions by the Client for a period of 12 months, the Company has the right toclaim the applicable inactivity fee as notified to the Client from time to time and the Company may deduct
such fee from the Client’s Account. The inactivity fee will be up to USD 10 and the Company reserves the rightto charge the said fee annually if there are no transactions by the Client the preceding 12 months.
Payment Providers Fees
The Company reserves the right to charge the Client and/or debit the Client’s Account with the relevant
payment provider fees that correspond to the Client’s deposits and withdrawals. The said fees should beapplicable per region and payment provider.

4.5 All payments to the Company under this Agreement shall be made in such currency as the Company fromtime to time specify to the bank account designated by the Company for such purposes.
4.6 The Company may share charges with third parties, like Introducing brokers or affiliates, for services
carried out on your behalf in the form of commission, mark-up, mark-down or other remuneration. Details ofsuch remuneration or sharing arrangements may be available to the Client upon request.

5. Islamic/Swap-Free Accounts
5.1 The Company may offer swap free trading accounts to clients who cannot use swaps due to their religious
beliefs. Islamic/swap free accounts, imply no swap or rollover interest on overnight positions, which is against
the Islamic faith. The Company reserves the right to require supporting documentation to verify the opening ofa swap free account.
5.2 Other than the above Islamic/Swap free accounts have exactly the same trading conditions and terms asother Company’s trading account types. Furthermore, clause 9.11 for swap free trading applies.

6. Confict of Interest
6.1 The Company will take all reasonable steps to identify and manage conflicts of interest between itself,
including its managers and employees or other relevant persons as well as any person directly or indirectly
linked to them by control, and their clients or between one client and another, that arise in the course ofproviding any of the Services under this Agreement, and to organize and control their internal affairs
responsibly and effectively.
6.2 The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its
employees and between its customers and to organise and control their internal affairs responsibly andeffectively in accordance with its Conflict of Interest policy which is enclosed in this Agreement as Annex 1.

7. Inducements
7.1 The Company shall take reasonable steps to ensure that neither it nor any of its employees or agents either
offers or gives, or solicits or accepts, any inducement that is likely to conflict with any duties owed to its clients.
For this purpose, the Company does not receive or pay any fees, commissions or non-monetary benefits inrelation to the provision of the services to or by any third party, except Client, subject to clause 6.2.
7.2 The Company, may pay and/or receive fees/commission to/from third parties, provided that these benefits
are designed to enhance the quality of the offered service to the Client and not impair compliance with theCompany’ duty to act in the best interests of the Client. An indicative list of fees/commission to/from third
parties which are designed to enhance the quality of the offered service to the Client and not impair compliance with the Company’ duty to act in the best interests of the Client may be regulatory levies, legal fees, bankand payment provider fees, liquidity providers’ fees, platform fees etc.
7.3 A fee, commission or non-monetary benefit should only be paid or received where:a. It is justified by the provision of an additional or higher level service to the relevant client, proportional
to the level of inducements received
b. It does not directly benefit the recipient firm, its shareholders or employees without a tangible benefit
to the clientc. It is justified by the provision of an on-going benefit to the relevant client in relation to an on-going
inducement

7.4 The Company shall keep records evidencing the fees, commissions or non-monetary benefits paid or
received by the Company which are designed to enhance the quality of the relevant service to the client.

8. Client Money and Transfer of funds
8.1 The Company ensures to promptly place any Client money segregated from the Company’s own accounts
and opened with an approved bank and/or a payment provider that has been assessed by the Company
and/or approved by the Company’s Management. Any Client’s money shall be paid into a segregated clientbank account denoted as "Client" bank account.
8.2 Unless the Client notifies the Company in writing or otherwise, the Company may pass on Client money orallow another person, such as an exchange, a clearing house or an intermediate broker, to hold or control
Client money where the Company transfers the Client money (a) for the purposes of a transaction for the Client
through or with that person; or (b) to meet the Client’s obligations to provide collateral for a transaction (e.g.
a margin requirement for a derivative transaction). By accepting this Agreement, the Client gives his consent
and authorizes the Company, where applicable, to transfer/hold his funds in other parties or business partners
i.e. liquidity providers for settlement purposes. The Company shall not be liable for the solvency, acts or omissions of any institution with which Client money are held.
8.3 The third party to whom the Company will pass money may hold it in an omnibus account and it may not
be possible to separate it from the Client’s money, or the third party’s money in which case the Client will nothave any claim against a specific sum in a specific account in the event of insolvency. The Company does not
accept any liability or responsibility for any resulting losses.
8.4 By entering into this Agreement the Client agrees that the Company will not pay the Client interest on Clientmoney or any other unencumbered funds.
8.5 Any amounts transferred by the Client to the Client’s bank account will be deposited in the Client’s Accountat the “value date” of the received payment and net of any deduction/charges by the Client’s bank accountproviders. In case the Client’s account reaches a stop-out during the processing period of the deposit, theCompany bears no responsibility for any losses suffered.
8.6 The Company acts in accordance with international anti-money laundering regulations and local anti-money laundering rules thus the transfer of funds and transactions are done based on these rules. For this purpose,
Client’s withdrawals should be made using the same method used by the Client to fund his Client Account andto the same remitter. The Company reserves the right to decline a withdrawal with a specific payment method
and will suggest another payment method where the Client needs to proceed with a new withdrawal request,or request further documentation while processing the withdrawal request. Where applicable, if the Company
is not satisfied with any documentation provided by the Client or if the company has reasonable grounds for
suspecting that a Client violates Applicable regulations, then the Company will reverse the withdrawal transaction and deposit the amount back to the Client’s Account and the Client will suffer the relevant Client’s bankaccount provider’s charges.

8.7 By accepting this Agreement, the Client gives his consent and authorizes the Company to make deposits
and withdrawals from the Client’s bank account on the Client’s behalf, including but not limited to, thesettlement of transactions performed by or on behalf of the Client, for payment of all amounts due by or on
behalf of the Client to the Company or any other person.
8.8 The Client acknowledges that in case where a Client’s bank account is frozen for any given period and forany given reason the Company assumes no responsibility and Client’s funds will also be frozen.

9. Client’s Orders/Instructions & Execution of Orders
9.1 Execution of Orders: It is the Company’s approach to take all sufficient steps to obtain the best possible
result on behalf of its Clients when executing Client orders on Financial Instruments offered by the Company
or receiving and transmitting orders for execution. The Client understands and acknowledges that theCompany will enter into transactions with the Client either as principal (counterparty) or an agent. The
Company will be the contractual counterparty to the Client.
9.2 The Company, when executing orders, will obtain the best possible result for Clients, taking into accountfactors like price, costs, speed, likelihood of execution and settlement, size, market impact or any otherconsideration relevant to the execution of the order. Where the Company executes an order on behalf of a
Client, the best possible result shall be determined in terms of the total consideration, representing the priceof the financial instrument and the costs relating to execution, which shall include all expenses incurred by the
Client which directly relate to the execution of the order.
9.3 For determining the importance of the execution factors indicated above, the following criteria are also
taken into account:▪ The characteristics of the Client▪ The characteristics of the Client order;▪ The characteristics of Financial Instruments that are the subject of that order;▪ The characteristics of the execution venues to which that order can be directed.
9.4 The Client understands and confirms that all orders received by the Company from the Client are orders
for execution outside a Regulated Market or MTF.
9.5 Client’s Orders/Instructions: Orders may be placed with the Company once the Client gets access to theCompany’s Trading Platform. The Company will be entitled to rely and act on any Order placed on the Trading
Platform without any further enquiry to the Client and any such Orders will be binding upon the Client.
9.6 The Company’s Buy/ Sell prices for a given CFD are calculated by reference to the price of the relevant
Underlying Asset. Third party reputable external resources (i.e. feed providers) obtain prices (Buy/Sell prices)of the Underlying Asset for a given CFD. The Company then uses the prices given by the feed providers to
calculate their own tradable prices for a given CFD.

The Company adjusts the Spread (i.e. the difference between the Buy/Sell prices), hence the prices it quotes
to Clients compared to the prices it obtains from third party external reference sources may differ, as they
include a Spread adjustment. The Company provides Quotes by taking into account the Underlying Assetprice. The Client acknowledges that such Quotes will be set by the Company at its absolute discretion.
9.7 Orders can be placed, executed and changed or removed within the trading hours for each CFD showedon the Company’s Website, as amended from the Company from time to time and if they are not executed
they shall remain effective through the next trading session (as applicable). The Company shall not be obliged
to arrange for the execution of the Client’s orders in respect of any CFD out of normal trading hours whichappear on the Company’s Website.
9.8 If any tradable instrument becomes subject to possible adjustments, the Company will determine theappropriate adjustment, if any, to be made to the opening/closing price, size, value and/or quantity of thecorresponding transaction. The determination of any adjustment or amendment to the opening/closing price,
size, value and/or quantity of the Transaction (and/or the level or size of any order) shall be at the Company’ssole discretion and shall be conclusive and binding upon the Client. For the avoidance of any doubt, where
the Client opens positions on the ex-dividend day, the Company has the right to close such positions at the last
price of the previous trading day and open the equivalent volume of tradable instrument at the first available
price on the ex-dividend day. The Company shall inform the Client of any adjustment or amendment via its
internal mail as soon as is reasonably practicable.
9.9 During the occurrence of a manifest error i.e. a manifest or obvious misquote by the Company, or any
market, liquidity provider or official price source on which the Company has relied in connection with any transaction, having regard to the current market conditions at the time an order is placed as the Company may
reasonably determine, the Company may amend the details of affected transactions to reflect what the Company reasonably determines as correct and fair and/or declare any or all affected transactions as void.
9.10 During periods of abnormal Market (Volatile) Conditions, during news announcements, on opening gaps
(trading session starts), or on possible gaps where the Reference Asset has been suspended or restricted ona particular market, Buy/Sell Stop and Stop Loss orders may not be filled at requested/declared price but
instead at the next best available price. In such case, Take Profit orders below/above Buy Stop/Sell Stoporders or Stop Loss orders above/below Buy Stop/Sell Stop orders during activation will be removed. The
same applies when a trading strategy is deemed as abusive, because it is aiming towards potential risklessprofit or another strategy deemed by the Company to be abusive. Accordingly, placing a Stop Loss order will
not necessarily limit the Client’s losses at the intended amount.
9.11 The Company may amend the level of swap rate on a financial instrument at its discretion, for instance,
where the Client holds a position for a period of 10 calendar days or more. Furthermore, the Company may
offer the possibility to the Clients for swap free trading, however it reserves the right to enable or disable swap
free trading at its discretion and/or reverse any cumulative profits generated from such trading and/or charge
retrospectively fees that should have been incurred if swap free trading was disabled.

This may happen when the Client engages in trading strategies that rely on arbitrage opportunities and/or
riskless arbitrage and/or swap abuse i.e. hedging aiming at riskless profit and/or in cases where the Company considers this as necessary. Notwithstanding the above, a storage amount may apply for swap freeaccounts, where applicable.
9.12 The Company prohibits and/or has the right to not allow trading strategies aimed at exploiting errors inprices by taking advantage of internet, connectivity delays and price feed errors i.e. arbitrage, internal hedging in coordination with other parties, fraud, manipulation, abuse of negative protection rule and/or any otherfraudulent activity. The Company reserves the right, at its sole discretion, to revoke any transactions based on
fraudulent trading strategies, to make all necessary corrections or adjustments such as to adjust the pricespread available to the Client where applicable and/or remove any profit/loss generated. In addition, theCompany reserves the right to charge the Client, in case he/she applied any fraudulent activity, with an administration fee up to 10% of the initial deposit and with a maximum charge at $1,500 for covering any administration fees as well as any transaction fees imposed by the payment institutions on processing the Client’s
deposit(s) and withdrawal(s). Furthermore, the Company reserves the right to terminate the Account without
notice as per the provisions of this agreement.

10. Margin/Leverage Level
10.1 The Margin/leverage levels applicable to the different products offered by the Company can be foundon the Company’s Website at https://traders-trust.com/ . If at any time the Equity falls below a certain percentage of the required Margin, specified on the Website, the Company has the right to close any or all of the
Client’s open positions without the Client’s consent or any prior written notice to him.
The Client is responsible to monitor its account balance and keep sufficient funds in its Account in order for its
open positions to remain unaffected. The Company shall have the right, but not the obligation, to start closing
Client’s open positions starting from the most unprofitable, when the Margin is less than 100% of the Margin
requirement. In the case where the Margin up to 20% of the Margin requirement, then Client’s positions shallbe automatically closed, starting from the most unprofitable, at the prevailing market price.
10.2 Margin or leverage Level may be set and varied without prior notice from time to time in the Company’ssole and absolute discretion in order to cover any realised or unrealised losses arising from or in connection
with transactions, including subsequent variation of any Margin rates set at the time transactions are opened.
The Client can request to change his account leverage at any time by contacting the Company.
10.3 On every Friday and between the hours of 21:00 till 24:00 (GMT+3) and occasionally before the releaseof major economic news, the Company may maintain a maximum leverage on remaining instruments otherthan FX for any new positions opened during such period which such requirement, if any, will be disclosed in
the Company’s website.

11. Decline of Client’s Orders and Instructions
11.1 The Company is entitled to decline or refuse to transmit or arrange for the execution of any order in anyof the following cases as applicable:
a. under abnormal market conditions;b. If the Client’s free Margin is less than the required Margin or there are no available cleared funds
deposited in the Client Account to pay all the charges of the particular order;c. it is impossible to proceed with an order regarding the size or price or the proposed Transaction is ofsuch a size (too small or too large), that the Company does not wish to accept that order or the Company believes that it will not be able to hedge the proposed transaction or it is impossible for theorder to be executed due to condition of the relevant market;
d. where the Company suspects that the Client is engaged in money laundering activities or terrorist
financing or other criminal acts;
e. in consequence of request of regulatory or supervisory authorities or a court order;
f. where the legality or genuineness of the order is under doubt;
g. there is absence of essential detail of the order or the order is not clear or has more than one interpretation;h. a Quote is not obtained from the Company or the Quote obtained by the Company is an indicative
Quote or the Quote is the result of manifest error or Quote is an error Quote;i. internet connection or communications are disrupted;
j. a Force Majeure Event has occurred;k. the Company has sent a notice of termination of this Agreement to the Client;l. the Client has failed to meet the minimum Margin requirement;

12. Transaction Settlements and Confirmations
12.1 The Company will proceed with transaction settlements upon execution, in accordance with the normal
practice for the Financial Instrument or the relevant market rules. The Company will provide the Client with an
online access to his Client Account via the Trading Platform, which will provide him with sufficient informationon among others order(s) status.
12.2 The Client understands that transaction confirmations are available via the Trading Platform and he will
be able to access account information through the Trading Platform. Through the Trading Platform the Client
may view its balance as well as all of its account activity. The Client will also be able to generate daily, monthly and yearly reports of account activity as well as a report of each executed trade. Updated account information will be available no later than 24 hours after any activity takes place on the Client’s Account. At all times,
Client’s account information will include, and is not limited to, trade confirmations with ticket numbers,purchase and sales rates, Margin, amount available for trading as well as current open and pending
positions.

13. Trading Platform usage13.1 The Client shall enter his user ID and password ("Codes") registered during the online account opening
procedure when logging on to the Company’s Trading Platform. The Client should notify the Company without
undue delay on becoming aware of unauthorized use of the Trading Platform, or if the Client suspects that the
password has been misappropriated by a third party.
13.2 The Client shall take all necessary precautions to ensure the confidentiality of all information, including,but not limited to, the Codes to the electronic systems, Transaction activities, account balances, as well as allother information and all orders. The Client shall be solely responsible for all orders and the accuracy of all
information sent via the internet using its Codes. The Client acknowledges that the Company bears no responsibility in the case that the Codes are used in an unauthorized manner by any third party.
13.3 The Company shall not be responsible for losses resulting from the Client's installation and use of thecomputer programs used on the Trading Platform, unless such liability follows from indispensable rules of law.
Where the Trading Platform is used by the Client, it shall be responsible for ensuring that the Trading Platform
is adequately insured against direct and indirect losses which may result from the installation and use of thecomputer programs in the Client's computer system. Furthermore, the Client shall be obliged to make backup
copies of data which, should such data be lost, might result in losses for the Client.
13.4 When using the Company’s platform, the Client shall:- run such tests and provide such information to us as we shall reasonably consider necessary to establish- ensure that the system and/or hardware equipment used by the Client satisfies the requirements
notified by us to you from time to time;- carry out virus checks on a regular basis;- inform us immediately of any unauthorized access to its system or instruction which the Client know ofor suspect and, if within its control, cause such unauthorized use to cease; and- not at any time leave the terminal from which the Client have accessed the trading platform or letanyone else use the terminal until he has logged off the trading platform.
13.5 To the extent permitted by Applicable Regulations, the Company shall not be liable for:a. any loss, expense, cost or liability (including consequential loss) suffered or incurred by the Client asa result of instructions being given, or any other communication being made via the internet or otherelectronic media; the Client shall be solely responsible for all orders, and for the accuracy of all information, sent via such electronic media; andb. any loss or damage that may be caused to any equipment or software due to any viruses, defects ormalfunctions in connection with the access to, or use of, the electronic systems.

13.6 If the Client wants to use a third-party software application to provide trading signals or advice or othertrading assistance like an “expert advisor” or a hosting environment allowing for real-time access to the
Client’s Account, the Company and its third-party suppliers or licensors make no warranties or representationsof any kind, whether expressed or implied for the service it is providing. The Company and its third-party
suppliers or licensors also disclaim any warranty of merchantability or fitness for any particular purpose andwill not be responsible for any damages that may be suffered by the Client, including loss of funds, data,
non-deliveries or service interruptions by any cause or errors or omissions by the Client. The Client’s use of any
information obtained by way of an expert advisor used in conjunction with a hosting environment or otherwise
is at the Client’s own risk, and the Company and its third-party suppliers specifically disclaim any responsibility
for the accuracy or quality of information obtained through its services. Connection speed represents the
speed of an end-to-end connection. The Company and its third party suppliers or licensors do not represent
or guarantee the speed or availability of end-to-end connections. The Company and its third party suppliers
or licensors shall not be subject to any damages or liability for any errors, omissions or delays therein including unavailability. The licensed products and all components thereof are provided on an “as is” basis and areseparate and distinct from the services provided under this Agreement. Where the Company believes that a
Client is using additional functionalities /plug-ins where it affects the reliability and/or smooth and/or orderly
operation of the electronic systems the Company has the right to suspend or terminate the Client’s Account.
13.7 The Company makes every effort to deliver high quality products. However, we do not guarantee that our
products are free from defects. Our software is provided “as is” and the Client uses the web platform at his
own risk. The Company makes no warranties as to performance, fitness for a particular purpose, or any otherwarranties whether expressed or implied. No oral or written communication from or information provided by
the Company shall create a warranty. Under no circumstances shall the Company be liable for direct, indirect,
special, incidental, or consequential damages resulting from the use, misuse, or inability to use this software,even if the Company has been advised of the possibility of such damages.
13.8 The Client understands that the use of the Trading Platform including each Transaction the Client complete
thereto will not violate any law, ordinance, charter, by-law or rule applicable to him or any agreement bywhich the Client is bound or by which any of the Client’s assets are affected;

14. Market Abuse
14.1 The Client acknowledges that he will not enter into any transaction which falls within the definition ofmarket abuses of Seychelles Securities Act 2007 as amended. This rule applies to all forms of market abusesuch as insider trading (an abusive exploitation of privileged confidential information), the misuse of information and directors trading in shares of their own companies;
14.2 If the Company suspects or has reasonable grounds to believe that the Client has been engaged into an
abusive behavior as indicated above the Company reserves the rights to void and/or cancel part or all
Client’s abusive trading transactions, close all and any of the Client’s trading accounts and terminate thisAgreement under s.21.

15. Third Party Authorisation
15.1 The Client has the right to use a power of attorney to authorise a third person "Representative" to act onbehalf of the Client in all business relationships with the Company as defined in this Agreement. The power ofattorney should be provided to the Company accompanied by all identification documents of therepresentative and/or any other documentation requested by the Company. If there is no expiry date, thepower of attorney will be considered valid until the written termination by the Client.
15.2 The Client further ratifies and accepts full responsibility and liability for all instructions given to theCompany by the Representative (and for all transactions that may be entered into as a result) and will
indemnify (fully compensate or reimburse) the Company and keep the Company indemnified against any loss,
damage or expense incurred as a result of acting on such instructions. This indemnity shall be effective
irrespective of the circumstances giving rise to such loss, damage or expense, and irrespective of any
knowledge, acts or omissions of the Company in relation to any other account held by any other person or
body with the Company.
15.3 The Client agrees to further indemnify the Company (fully compensate and reimburse) for any loss,
damage or expense incurred as a result of the Company acting on instructions of the Representative outside
the scope of the Representative authority or the Representative’s breach of any term of their appointment.

16. Introducing Brokers and Affiliates
16.1 The Client may have been recommended by an introducing broker or an affiliate based on a writtenagreement with the Company subject to the Applicable regulations.
16.2 The Company may pay a fee/commission to introducing brokers and/or affiliates based on a writtenagreement. The Company has the obligation and undertakes to disclose to the Client, upon his request, further
details regarding the amount of fees/commission or any other remuneration paid by the Company tointroducing brokers or affiliates.
16.3 The Company shall not be liable for any type of agreement that may exist between the Client and theintroducing broker or affiliate or for any additional costs as a result of this Agreement.
16.4 The Client acknowledges that the introducing broker or affiliate is not a representative of the Company.

17. Privacy and Data Protection rules17.1 The Company is committed to protecting the privacy of all personal information that it obtains from the
Client and hereby lists how and why the Company collects, use, disclose and protect the Client’s personal
information.

17.2 Purpose of data collection: The Company Collects Client’s personal information in order to provide the
Client with its products and services and to establish and manage the Client’s account. By collecting Client’s
information, the Company will be able to monitor and improve the services it offers to its existing and potential
clients.
17.3 The Company will collect and process the following personal information about the Client:--

Personal information provided during account opening procedure when the Client fills the applicationor other forms on the Company’s website. The information may include the Client’s name, address,
contact details, financial information about your income and wealth, professional and employment
details, trading history and other personal information.
Information about the Client’s use of this website and the Company’s platform. This information may
include site areas visited, pages viewed, frequency and duration of visits
Subject to Applicable Regulations, the Company will monitor and record the Client’s calls, emails, text
messages and other communication for regulatory compliance, crime prevention and detection, toprotect the security of communications systems and procedures, for quality control and staff training
etc. The Company will also monitor activities on the Client’ account where necessary for these reasonsand this is justified by the Company’s legitimate interests or legal obligations.

17.4 Usage of Information: The Company may use information for the following purposes (list not exhaustive):-

Provision of the Services under this Agreement
For KYC and due diligence purposes i.e verification of identity
For maintenance and management of the Client’s account as well as administration of the services
provided to the Client
Communication with the Client when necessary or appropriate
Compliance with legal and regulatory requirements

17.5 Share of Information: The Company may share Client’s personal information with business partners andsuppliers with whom the Company may have outsourced certain of business functions or cooperating with.
Personal data collected by the Company may be transferred or disclosed to third party contractors, subcontractors, for the purposes for which the Client has submitted the information i.e agreements with Service Providers.
17.6 It is the Company’s policy to disclose information to third parties under the following circumstances:-

As required by Applicable Regulations, statute, rule, regulation or professional standard, search
warrant or other legal process
For regulatory compliance purposes
When explicitly requested by the Client
Or otherwise as set out in this section

17.7 In order for the Company to provide services to its Clients, the Company may be required to transfer the
Client’s personal information to parties located in countries which may not have an equivalent level of dataprotection laws as in the Seychelles. Where this is the case we will take reasonable steps to ensure the privacyof the information. The Client acknowledges and understands that by submitting its personal information to theCompany agrees to the aforesaid transfer, storage and processing of the information.
17.8 If the Client wishes to withdraw its consent to the use of information, rectify a personal information orrequest the provision or deletion of information held by the Company related to itself, he may submit its
request at the email address compliance-sc@ttcm.com.

18. Force Majeure18.1 In case of a force majeure event as listed below (list not exhaustive), the Company shall not be liable forany failure to provide the Services under this Agreement, beyond its control:a. Government actions, war or hostilities, acts of terrorism, national emergency,b. Act of God, earthquake, tsunami, hurricane, typhoon, accident, storm, flood, fire, epidemic or othernatural disasters;c. Labour disputes and lock-out which affect the operations of the Company;
d. Suspension of trading on a Market, or the fixing of minimum or maximum prices for trading on aMarket, a regulatory ban on the activities of any party (unless the Company has caused that ban),decisions of state authorities, governing bodies of self-regulating organizations, decisions of governing
bodies of organized trading platforms;
e. Breakdown, failure or malfunction of any electronic, network and communication lines (not due to thebad faith or wilful default of the company and hacker attacks;
f. Any event, act or circumstances not reasonably within the Company’s control and the effect of thatevent(s) is such that the Company is not in a position to take any reasonable action to cure the default;
g. The suspension, liquidation or closure of any market or the abandonment or failure of any event towhich the Company relates its Quotes, or the imposition of limits or special or unusual terms on the
trading in any such market or on any such event;h. The failure of any relevant supplier, financial institution intermediate broker, liquidity provider, agent or
principal of the Company, custodian, sub-custodian, dealer, exchange, clearing house or regulatory or
self-regulatory organisation, for any reason, to perform its obligations.

18.2 If the Company determines reasonably that a force majeure event exists (without prejudice to any otherrights under the Agreement) the Company may without prior notice and at any time proceed with the following
actions:a. increase Margin requirements without notice;b. decrease leverage;c. close out any or all open positions at such prices as the Company considers in good faith to beappropriate;d. refuse to accept orders from Clients;
e. determine at its discretion the quotes and spreads that are executable through the Company’s Trading
Platform;
f. suspend or modify the application of any or all terms of the Agreement to the extent that the force
majeure event makes it impossible or impractical for the Company to comply with them;g. take or omit to take all such other actions as the Company deems to be reasonably appropriate in thecircumstances with regard to the position of the Company, the Client and other clients;

19. Complaints Procedure
19.1 If the Client has any cause for complaint in relation to the services provided by the Company, he should
file a complaint as per the Company’s Complaint Handling policy which is available on the Company’s
website.
19.2 The Client may register a complaint by completing the Complaint Form using any of thefollowing options:- Email: complaints-sc@ttcm.com- Postal Address: Room B11, First Floor, Providence Complex, Providence, Mahe, Seychelles
19.3 The Company’s Complaints Handling Policy accompanied with the relevant complaint form which has tobe filed by the Client in case he has a complaint with the Company is enclosed as Annex 2 in thisAgreement.

20. Representations and Warranties
20.1 The Client represents and warrants to the Company the following:a. The Client is over 18 years’ old;b. The information provided by the Client to the Company in the account opening application form andat any time thereafter is true, accurate and complete, and at any time there is a change to the Client
personal data, the client will ensure that this data is updated and accurate, and the documents arevalid and authentic;c. The Client is duly authorised to enter into this Agreement and has the capacity;d. Any actions conducted by the Client under this Agreement will not violate any law or rule applicableto the Client or to the jurisdiction in which the Client is resident, or any agreement by which the Client
is bound or by which any of the Client’s assets or funds are affected;
e. The Client has read and fully understood and undertakes to comply with the terms of this Agreement;
f. The Client funds are not in any direct or indirect way the proceeds of any illegal activity or used orintended to be used for terrorist financing;g. There is no pending or, to the best of the Client’s knowledge, any legal proceeding before any court,
arbitration court, governmental body, agency or official likely to affect, the legality, validity or enforceability against him of this Agreement;
h. Any information which the Client provides to the Company will not be misleading and will be true andaccurate in all material respects;
i. There are no restrictions, conditions or restraints by Central Banks or any governmental, regulatory or
supervisory bodies, regulating Client’s activities, which could prevent or otherwise inhibit the Client
entering into, or performing in accordance with this Agreement and/or under any transaction which
may arise under them;j. The Client is not entering into any transaction unless he has a full understanding of all of the terms,
conditions and risks involved;

21. Communication and Notices
21.1 Any notice, instruction, request or other communication to be given to the Company by the Client underthe Agreement shall be in writing and shall be sent to the Company’s email address at
support-sc@ttcm.com.

22. Account Closing Procedure
22.1 Account Closing Procedure: Either party can terminate this Agreement by giving seven (7) business days’
written notice to the other party. Following the notice, the Client should close all open positions. In the casewhere the Client has open positions during the termination notice period, then the Company reserves the rightnot to accept any new Transaction orders and the Company shall have the right to close all of the Client's open
positions on expiry of the notice period to the extent the Client has not already done so. Upon termination ofthis Agreement, the Company shall be entitled to cease the access of the Client to the Trading Platform.

22.2 The Company is entitled to close all open positions and terminate this Agreement immediately without
giving prior written notice in the following cases:--

The Client fails to comply with any obligation to make any payment when due under this Agreement;
There are reasonable grounds to believe that the Client is in breach of this Agreement;
The Client activity might be a violation of any Applicable Regulations;
The Client dies, becomes or is adjudged to be of unsound mind, is or becomes unable to pay his debts
as they fall due, is or becomes bankrupt or insolvent within the meaning of any insolvency law or any
suit, action or proceeding is commenced for any execution of all or any part of the property,
undertaking or assets of the Client;
The Client commences a voluntary case or other procedure, or there is an involuntary case or otherprocedure or other similar procedure under any insolvency law.

22.3 The Company may terminate this Agreement immediately without giving prior written notice, and theCompany have the right to reverse and/or cancel all previous Transactions on a Client’s account, in the following cases:-

The Client involves the Company directly or indirectly in any type of fraud, in which it places theinterests of Company and/or the Company’s clients at risk prior to terminating this Agreement.
The Client’s trading activity adversely affects in any manner the reliability and/or smooth operation
and/or orderly functioning of the Trading Platform.

22.4 Following termination, the Company and the Client undertake to fulfil and complete all obligations
derived from this Agreement and this Agreement shall continue to bind both parties in regards to the existingcommitments or any contractual commitments which were intended to remain in force. The Company is entitledto deduct all amounts due to it before transferring any credit balances on any Account to the Client. If there
are no amounts due to the Company by the Client, the Company shall immediately transfer to the Client the
Client’s funds in its possession, providing that the Company shall be entitled to keep such Client’s assets asnecessary, to pay any actual, pending or contingent obligations or liabilities of the Client.

23. Cancellation Procedure
23.1 The Client has a period of 14 calendar days from acceptance of this Agreement to withdraw from thisAgreement provided that the Client has not been engaged or involved in any transaction with the Company.
This right of withdrawal or cancellation shall not apply following any transaction executed under thisAgreement which will thereafter remain binding upon the Client and the procedure indicated in clause 21
above applies.

24. Refund Policy
24.1 In certain cases, the Company may refund payments made by credit cards. The Client has the right toclose the trading account subject to the Company’s Account Closing (Clause 21) and Cancellation procedure(Clause 22). In the case where the Client is eligible to a refund, the Company maintains a refund policy where
the refund will be done on the same card used for the payment. The Client will be eligible to a refund provided
that there are no amounts due to the Company by the Client, the trading account(s) has not been suspended
in any way due to violation of this Agreement and/or due to any other abuse detected by the Client. The
Company does not have to perform any refund in case the loss occurred due to a trading performed in the
Client’s trading account. The Client further acknowledges that the processing of refund requests can takeabout 2-3 weeks’ till reaching the Client’s bank account but it is always subject to the terms of business of each
Client’s bank or credit card provider. All other requests will be treated as normal withdrawals and will beprocessed as per Company's policies and procedures.

25. Company Liability
25.1 Nothing in this Agreement excludes or limits the Company’s liability for any matter that cannot be excluded or limited under Applicable Regulations.
25.2 The Company will not be liable to the Client for any loss which arises as a result of:a. The Company’s compliance with, or the exercising of any of the Company’s rights in accordance with,
Applicable Regulations or this Agreement;b. The Client’s negligence, fraud or breach of this Agreement or Applicable Regulations;c. Any abnormal market condition or force majeure event;d. any delays, delivery failures, or failures in transmission of any order or any other communication or any
other loss or damage resulting from the transfer of data over mobile or other communications networks
and facilities outside of the Company’s control.
e. Any features, market data or third party content available on the Company’s Website, Platform or
e-mails, are provided on an "as is" and "if available" basis.
25.3 Neither the Company nor the directors, officers, servants, agents or representatives of the Company shallbe liable to the Client (except in the case of fraud) for any consequential, indirect, special, incidental, punitive
or exemplary loss, liability or cost which the Client may suffer or incur arising from the act of omissions of theCompany under this Agreement regardless of how such loss, liability or cost was caused and regardless ofwhether it was foreseeable or not. For the purposes of this paragraph, a loss, liability or cost includes any loss,
liability or cost (as appropriate) arising from the Client being unable to sell Financial Instruments where theprice is falling, or from not being able to purchase Financial Instruments where the price is rising, or from being
unable to enter into or complete another trade which requires him to have disposed of or purchased the Financial Instruments or any other loss, liability or cost arising as a result of loss of business, profits, goodwill or data
and any indirect, special, incidental, consequential, punitive or exemplary loss, liability or cost, whether arisingfrom negligence, breach of contract or otherwise and whether foreseeable or not.

25.4 For the avoidance of doubt, the Company’s third-party providers are not responsible for and have notparticipated in the determination of the Company’s prices and they exclude all warranties, undertakings or
representations (either express or implied) relating to the Client’s use of the Company’s Platform or the Company’s Website. Without limiting the foregoing, in no event whatsoever shall the Company’s third-party providers be liable for any loss, regardless of whether they are aware of such loss and whether such liability is basedon breach of contract, tort or otherwise.
25.5 Save in the event of the Company’s negligence, willful default or fraud, the Company will not be liable forany loss or damage caused by a hacker’s attack, viruses or other technologically harmful material that may
infect your computer equipment, computer programs, data or other proprietary material due to your use of theCompany’s Platform or Website or to the Client’s downloading of any material posted on it, or on any website(including our Website) linked to it.

26. Severability
26.1 Should any part of this Agreement be held by any court of competent jurisdiction to be unenforceable orillegal or contravene any of the Applicable Regulations, that part will be deemed to have been excluded fromthis Agreement and this Agreement will be interpreted and enforced as though the provision had never been
included and the legality or enforceability of the remaining provisions of the Agreement shall remain
unaffected.

27. Miscellaneous
27.1 The Company may at any time and without notice to the Client set-off any liability under this Agreement
or any other agreement entered into between the parties and between any account(s) of the client (whether
actual or contingent, present or future). The Company can off-set any owed amounts using any account the
Client maintains with the Company to the extent permissible.
27.2 This Agreement may be amended from time to time and after the relevant changes are approved by the
FSA the Company shall notify the Client of the relevant amendment or about the updated Agreement either inwriting or through the Company’s Website.
27.3 In the event of the death or mental incapacity of one of the persons who form the Client, all funds heldby the Company or its Nominee, will be for the benefit and at the order of the survivor(s) and all obligations
and liabilities owed to the Company will be owed by such survivor(s).

28.

Governing Law and Jurisdiction

28.1 This Agreement is governed by the Laws of Seychelles.
28.2 The Competent Courts for all disputes and controversies arising out of or in connection with theAgreement shall be the Courts of Seychelles.

Annex 1- Conflictsof Interest Policy

Introduction
The purpose of this Conflicts of Interest Policy (“the Policy”) is to outline a suitable approach and response to
the identification and management of conflicts of interest. Traders Trust Limited (the “Company") will take allreasonable steps to identify conflicts of interest between itself, including its managers, employees or any
person directly or indirectly linked to the Company by control and its clients or between one client and anotherthat arise in the course of providing any investment or ancillary services, or combinations thereof.
The Company maintains and operates effective organisational and administrative arrangements to preventand manage conflicts of interest that may arise during the provision of any investment or ancillary services,from adversely affecting the interests of its clients. In case where, the aforementioned arrangements are notsufficient to ensure, with reasonable confidence, that the risks of damage to the interests of the clients will be
prevented, the Company shall clearly proceed with the disclosure of such conflict. The said disclosure shall bedone in a durable medium indicating the general nature and source of conflicts of interest, the risks to theclient with sufficient details so as to allow the client to take an informed decision with the regards to its investment as well as the steps taken to mitigate such risks.
The Company has the right to amend the current Policy at its discretion and at any time it considers is suitable
and appropriate. The Company shall review and amend the current policy at least on an annual basis to takeaccount of changes to operations or practices and, further, to make sure it remains appropriate to any changes in law, technology and the general business environment.

Identification of potential conflicts of interest
To adequately manage conflicts of interest, the Company shall identify all relevant conflicts timeously. The
Company will employ different mechanisms to ensure that all conflicts are identified.

The Company shall identify all conflicts of interest, their severity and document controls to mitigate theconflicts. It is not possible to list all situations which could constitute a conflict. The facts of each situation will
determine whether the interest in question is such as to bring it within the area of potential conflict.
All employees, including management, will be responsible for identifying specific instances of conflict andrequired to notify the Compliance function of any conflicts they become aware of. The
Compliance Officer (CO) will assess the implications of the conflict and how the conflict should be managed
in conjunction with the board. In the case where a specific incident to be reported concerns the CO, thenotification shall be made to the Company’s Representative Officer.
For the purposes of identifying the types of conflicts of interest that arise in the course of providing investment
and ancillary services or a combination thereof and whose existence may damage the interests of a client,
the Company takes into account, by way of minimum criteria, the question of whether the Company or a
relevant person, or a person directly or indirectly linked by control to the Company, is in any of the following
situations, whether as a result of providing investment or ancillary services or investment activities:--

The Company or a relevant person is likely to make a financial gain, or avoid a financial loss, at theexpense of the client;
The Company or a relevant person has an interest in the outcome of a service provided to the client
or of a transaction carried out on behalf of the client, which is distinct from the client's interest in thatoutcome;
The Company or a relevant person has a financial or other incentive to favour the interest of anotherclient or group of clients over the interests of the client;
The Company or a relevant person carries on the same business as the client;
The Company or a relevant person receives or will receive from a person other than the client, an
inducement in relation to a service provided to the client, in the form of monies, goods or services,other than the standard commission or fee for that service;

For the purpose of this Policy, a “relevant person”, in relation to the Company means any of the following:--a director, partner or equivalent, manager, or tied agent of the Company;a director, partner or equivalent, or manager of any tied agent of the Company;
an employee of the Company or of a tied agent of the Company, as well as any other natural person
whose services are placed at the disposal and under the control of the Company or a tied agent of
the Company and who is involved in the provision by the Company of investment services and activities;a natural person who is directly involved in the provision of services to the Company or tied agent
under an outsourcing arrangement for the purpose of the provision by the Company of investment
services and activities.

Managing conflicts of interest
The Company has established suitable and adequate internal procedures for minimising any potential
conflicts of interest. The Company maintains a compliance department that is an independent unit within the
Company. Among the duties of the Compliance Officer is to monitor any possible deviation from the Company’s internal policies and procedures as well as identifying and managing any possible conflicts of interest.
Once a conflict has been identified it needs to be appropriately and adequately managed. The Compliancefunction will assess each conflict and determine if the conflict is actual or perceived and what the value of theconflict or exposure is and the potential reputational risk. Compliance will then decide whether it is viable togo ahead with the transaction or if the conflict is too severe. If Compliance decides that the particular conflictcan be mitigated, then controls to manage the conflict should be put in place and documented.
The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its
employees and between its customers and to organise and control their internal affairs responsibly and effectively.
The Company and its employees should act as per the principle of placing clients’ interests before self-interests and Company’s interests in order to avoid conflicts of interest in the fulfilment of professional activities on
the securities market. To ensure client’s fair treatment, the Company will introduce the following procedures:
-

-

-

-

The Company shall avoid any conflict of interest with clients and, where such a conflict unavoidably
arises, ensure fair treatment to the client by complete disclosure or by declining to act.
Employees are also prohibited to keep investor accounts in other Brokers without Company’s priorauthorization and are obliged to bring this to Company’s attention. They are also obliged to authorize
the Company to directly request transaction reports from the other Brokers.
If the Company has a material interest in a transaction to be entered into with or for a client, or a
relationship which gives rise to a conflict of interest in relation to the transaction, the Company shallnot knowingly either advise, or deal in the exercise of discretion, in relation to that transaction. The only
exception is when the Company has fairly disclosed that material interest or relationship, as the casemay be, to the client or the client has taken reasonable steps to ensure that neither the material interest nor relationship adversely affect the interests of the client.
There is a clear distinction between the different departments’ operations as these are described in
the Company’s IOM.
The Company shall be informed promptly of any personal transaction entered into by a relevant
person, either by notification of that transaction or by other procedures enabling the Company to identify such transactions. In the case of outsourcing arrangements, the Company shall ensure that theCompany to which the activity is outsourced maintains a record of personal transactions entered into
by any relevant person and provides that information to the Company promptly on request.
A person shall be replaced by another person in his/her duties only prior consent of the Compliance
Officer and approval by the Representative Officer. Such a consent will be given by the Compliance
Officer after all issues of possible conflict of interest have been reviewed.

--The security features of the Company’s software prevents unauthorized access to sensitive informationin order to benefit the Company over its clients or one client over another.
The Company’s employees are prohibited from investing in securities for which they have access to
non-public or confidential information.
Transactions by the Company’s employees are neither performed nor executed by themselves, but byanother member of staff of the Company concerning account opened with the Company.
A record shall be kept of the personal transaction notified to the Company or identified by it, including
any authorization or prohibition in connection with such a transaction.
The Company must take reasonable steps to ensure that neither it nor any of its employees or agentseither offers or gives, or solicits or accepts, any inducement that is likely to conflict with any duties
owed to its clients.
No employee shall either knowingly or recklessly make a statement, promise or forecast that ismisleading, false or deceptive to any customer or conceal material facts at any time.

More specifically, the Company states some of the policies and procedures that it has implemented for managing possible conflicts of interest below:
-

-

-

-

Effective procedures to prevent or limit any person from exercising inappropriate influence over theway in which a relevant person carries out investment or ancillary services or activities.
The separate supervision of relevant persons whose principal functions involve carrying out activities
on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent
different interests that may conflict, including those of the Company.
Measures to prevent or control the simultaneous or sequential involvement of a relevant person in
separate investment or ancillary services or activities where such involvement may impair the proper
management of the conflicts of interest.
The removal of any direct link between the remuneration of relevant persons principally engaged in
one activity and the remuneration of, or revenues generated by, different relevant persons principally
engaged in another activity, where a conflict of interest may arise in relation to those activities.
Measures to prevent or control the exchange of information between relevant persons engaged in
activities involving a risk of a conflict of interest where the exchange of that information may harm theinterests of one or more clients.

The procedures followed and measures adopted in the Policy include the following, as are necessary andappropriate for the Company to ensure the requisite degree of independence:-

No relevant person may purchase or sell a security or cause the purchase or sale of a security for any
account while in possession of inside information relating to that security.
No relevant person may recommend or solicit the purchase or sale of any security while in possessionof inside information relating to that security.

-

-

-

-

No relevant person may purchase or sell or cause the purchase or sale of a security for an employee
or employee-related account or a proprietary account of the Company or an account over which an
employee exercises investment discretion, while in possession of proprietary information concerning acontemplated block transaction in the security or for a customer account when such customer has been
provided such information by any relevant person.
Procedures set for regular review and monitoring of the execution arrangements with the execution
venue, hedging/ liquidity or price providers as well as on a continuous basis.
Procedures in regards to the monitoring of access to electronic data.
Relevant persons engaged in research activities should not discuss unreleased information, opinions,recommendations, or research analysis in progress with Company associated persons engaged insales activities, or any person within or outside the Company who does not have a valid business needto know the information.
Establishment of an ongoing monitoring program based on which regular checks are conducted forthe assessment of the Company’s procedures, policies and internal controls.
The Company may distribute marketing communication to its clients, only if the said communication isreviewed and approved by the Compliance Officer prior to distribution. The Compliance Officer also
ensures that such communication have the appropriate disclosure statement as well as meeting therelevant definition of marketing communication.
The four-eye principle is implemented to avoid any abuse of position.
In order to minimize the relevant person’s own transactions personal account dealing restrictions arein place.

The Company is committed to having an effective and appropriate compliance culture to enable it to deal withany new potential conflicts of interest which may arise in the future. The Company’s employees are therefore
required to monitor any new circumstances giving rise to potential conflicts of interest and to implement
appropriate measures to address these.
For the purpose of this Policy, a “personal transaction” is considered a trade in a financial instrument effectedby or on behalf of a relevant person, where at least one of the following criteria are met:
- the relevant person is acting outside the scope of the activities he carries out in his professional
capacity;- the trade is carried out for the account of any of the following persons:- the relevant person;- any person with whom he has a family relationship, or with whom he has close links;- a person in respect of whom the relevant person has a direct or indirect material interest in theoutcome of the trade, other than obtaining a fee or commission for the execution of the trade.

Segregation of Company’s assets from clients’ assets
The Company shall maintain separate accounting records between its own assets and those of its clients tofacilitate the protection of clients’ assets and the prevention of the use of customer assets by the Company orby other third parties so as to minimize the risk of the loss or diminution of client assets, or of rights inconnection with those assets, as a result of misuse of the assets, fraud, poor administration, inadequate
record-keeping or negligence. In addition, the Company has legally secure segregation of clients’ assets fromthe Company’s assets in case the Company becomes bankrupt. For this purpose, the Company maintains
separate books and accounting records for each client.

Forbidden Business Practices
The Company shall prohibit those business practices which in the regular course of events might give rise toconflicts of interest. The following business practices shall indicatively be forbidden:---

The provision to clients of investment services for the purpose of influencing the price of financial
instruments for the benefit of the Company or for the benefit of any relevant persons, or of Company’sclients in general, especially with regard to transactions that the Company or relevant persons intend
to carry out prior to or after the provision of the service.
The use by the Company or by its relevant persons of information regarding client transactions, for the
benefit of the Company, and the disclosure of such information to third parties.
Dealing by the Company itself or by any relevant persons in financial instruments in respect of which
the Company has drawn analysis reports or has made research findings prior to the publication of therespective reports and findings.
The preferential treatment of relevant persons to the detriment of its clients in the course of theprovision to them of investment or ancillary services.
The carrying out of transactions by relevant persons for their own account or for the account of persons
related with them on the basis of confidential information that the above persons have obtained in thecourse of their employment with the Company.

All employees must be aware of the above forbidden business practices and shall have the responsibility of
informing the Compliance Officer immediately in case they monitor any violation of the above provisions.
Should you have any questions in relation to the Company’s Conflicts of Interest Policy, please contact theCompliance department of the Company.

Disclosure of conflicts of interest
In case where, the organisational and administrative arrangements established by the Company to prevent ormanage a conflict are not sufficient to ensure, with reasonable confidence, that the risks of damage to theinterests of the clients will be prevented, the Company shall clearly proceed with the disclosure of suchconflict.
Prior to carry out a transaction or provide an investment or an ancillary service to a client, the Company should
disclose any actual or potential conflict of interest to the client provided that the measures taken by theCompany are not sufficient to ensure that the risks of damage to the interests of the client will be avoided.

The above disclosure shall include sufficient detail, taking into account the nature of the client, source of
conflicts of interest, the risks to the client to enable him to take an informed decision with respect to theinvestment or ancillary service in the context of which the conflict of interest arises. The Company reserves theright not to proceed with the transaction or matter giving rise to the conflict if such disclosure is not sufficient
to manage a conflict.
The Management and employees of the Company should disclose the following information to theCompliance Officer:-

Opening and closing personal accounts at any other Broker for own investments purposes
All personal transaction performed. Notification should be provided within 24 hours
Securities held by the employee
Transactions executed by the Company in which the employee may have an interest or a conflictAnnex 2 - Complaints
Handling Policy

Complaint handling policy
Traders Trust Limited (hereinafter the “Company”) aims to provide superior services to all of its Clients.
The Company has appointed a Compliance Officer to efficiently handle any complaints from the Clients. This
is to allow the Company to resolve and apply mandatory measures to avoid any recurring issues.

Definition
The Company classifies a complaint as any objection and/or dissatisfaction that the Client may have withregards to the provision of the services provided by the Company. A complaint form is enclosed at the end of
this Policy.

Procedure
The Compliance Officer shall be responsible for handling Client complaints, except in the case where thecomplaint involves the Compliance Officer, whereby the complaint shall be handled by the Representative
Officer.
The Client may register a complaint by completing the complaint form, using any of the following options:-

Email: complaints-sc@ttcm.com
Postal Address: Room B11, First Floor, Providence Complex, Providence, Mahe, Seychelles

1. When the Compliance Officer receives the Client’s complaint then a written acknowledgement will besent to the Client within 7 business days;
2. The Company will attempt a final response within 30 business days, however in case we are still not
in a position to resolve the issue then the Compliance Officer will notify you in writing stating thereasons for the delay and indicate an estimated time to resolve the issue;
3. A final response should be provided to the Client within 60 business days the latest from the date hesubmitted his complaint;
4. In the case where the complainant is still not satisfied with the Company’s final response, then thecomplainant can refer his complaint with a copy of the Company’s final response to the Financial
Services Authority (FSA) in Seychelles for further examination.

The contact details for the Financial Services Authority (FSA) in Seychelles
are set out below:
Address:

Phone:
Fax:
Email:PO Box 991
Bois de Rose Avenue
Roche Caiman Victoria, Mahe, Republic of Seychelles(+248) 438 08 00(+248) 438 08 88
complaints@fsaseychelles.sc

Website:http://fsaseychelles.sc/index.php/contact-us

Client Records
The Client should provide all relevant documentation as well as any additional information requested by theCompliance Officer in order to ensure all records are collected and the complaint is properly resolved on time.
All records will be kept safe as per local requirements and for a period of seven (7) years.
The complaint form can be found in the next page

A. Client Information:
Name:

Account Number:

Address:

Telephone Number:

B. Brief Summary of the Complaint:
Please describe the product or service you are complaining about (description, evidence, amount andsuggested way to be solved):-

Please enclose any other relevant documentation that may help us to handle the complaint.
Possible documentation to be provided (client statement, correspondence with the Company as well as
any other supporting documentation to be requested by the Compliance Officer which is relevant to the
Client’s complaint)

Date and place

Client Signature

For internal use only
Complaint received by:Date:

Acknowledgement sent to Client:

Yes -

No

Informed Client of initial action:

Yes -

No

Final response provided to Client:

Yes -

No

Holding response provided to Client:

Yes -

No -

Signature of Compliance Officer:

Date:

N/A