Terms and Conditions – Client Agreement

Xtrade International LTD

Xtrade International Ltd.
Terms and Conditions – Client Agreement

January 2024

Proprietary Restriction:
This controlled document is property of XTrade International Ltd.
any disclosure, reproduction or transmission to unauthorizedparties without the prior written permission of XTrade International Ltd is prohibited

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

1. Introduction
1.1. This Agreement is entered by and between Xtrade International Ltd(hereinafter called the “Company” or “we” or “us”), on the one part, and the Client(“Client” or “you” or “user”), on the other part.
Xtrade International Ltd (address 35 New Road, 2nd floor flat, Belize City,
Belize) is authorized and regulated by the International Financial Services
Commission in Belize (000281/20) and provides financial services undercompany’s scope of activity. Xtrade International Ltd client transactions arebeing processed by Reituca Marketing Ltd with registration no. HE231803
registered at 17 Stasinou, floor 11-12, 1060 Nicosia, Cyprus.
If you decide to download our software to use the trading demonstration, thenyour obligations hereunder contained within this Client Agreement (to the extent
relevant) apply to you as well even if you do not become our Client after all.
1.2. This Client Agreement together with any Appendices added thereto and thefollowing documents, as amended from time to time: “Conflicts of Interest
Policy”, “Summary of Best Interest and Order Execution Policy” and “Risk
Disclosure and Warnings Notice” (together, the “Agreement”) set out the terms
upon which the Company will offer Services to the Client and also include
important information which we are required as an authorised Belize Investment
Firm to provide to our prospective Clients. By registering as a user, you areconsenting to the terms and conditions of all the above mentioned documents
and it means that in the event that you are accepted by us as our Client you
shall be bound by these terms and conditions. For this reason, you are advised
to read all the above mentioned documents which form the Agreement and anyother letters or notices sent by the Company carefully, as well as the various
documents found on our Website such as the “Privacy Policy” and “Terms andConditions for the use of the Website” and make sure that you understand andagree with them.
1.3. The Agreement overrides any other agreements, arrangements, express or
implied statements made by the Company or any Introducer(s).
1.4. The Agreement shall be binding upon and shall inure to the benefit of theParties and their permitted successors and assigns.
PART ONE – THE PLATFORM
2. Restrictions on the Users
2.1. Without prejudice to the Company’s right to refuse to provide Services
hereunder or make its Platform available to any person, the Platform is notintended for use by a person:

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD(a) who is under the age of 18 years old or is not of legal competence or ofsound mind;(b) who resides in any country where such use would be contrary to local
law or regulation or religion. The Platform and our Service hereunder are
not intended to persons residing in any country where CFD trading
activity or other such services would be contrary to local law or
regulation or religion. It is your responsibility to comply with any local law
or regulation to which you are subject to;(c) who is a US Reportable Person, in accordance with FATCA;(d) who is an employee, director, associate, agent, affiliate, relative, orotherwise connected to the Company or any affiliate thereto.

3. License and Provision of Platform
3.1. Subject to the Client’s obligations under the Agreement being fulfilled, theCompany hereby grants the Client a limited license, which is personal, nontransferable, non-exclusive and fully recoverable, to use the Platform(s)(including the use the Website and any associated downloadable software
available on our Website from time to time), solely for personal use and benefit
in order to place Orders in a particular Financial Instrument(s) in accordancewith the terms of this Agreement. Should the Agreement be terminated for any
reason, the license will automatically be revoked and the Platform software mustno longer be used by the Client.
3.2. If any third party software is included within the Platform, then such third
party software shall be provided subject to the terms of this Agreement. The
Client shall fully comply with the terms of any third party software licenses that
the Company may provide him with from time to time.
3.3. The Company reserves any and all rights to the Platform not expressly
granted to the Client by this Agreement. Rights to the Platform are licensed to
the Client by the Company and not sold. All rights to the Platform shall remain
the property of the Company.
3.4. The Company has the right to shut down the Platform(s) at any time formaintenance purposes without prior notice to the Client. This will be done only
in weekends, unless not convenient or in urgent cases. In these cases, thePlatform(s) will be inaccessible.
3.5. From time to time, acting reasonably, the Company shall have the right to
add to, modify, or remove any of the Platform or parts of it without liability under
this Agreement. In such a case, it shall use reasonable endeavours to replace
any part of the Platform with an equivalent where practicable.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

4. Intellectual Property
4.1. The Platform(s), all copyrights, trademarks, patents, service marks, trade
names, software code, icons, logos, characters, layouts, trade secrets, buttons,
colour scheme, graphics and data names are the sole and exclusive Intellectual
Property (IP) of the Company or of third parties and are protected by local andinternational intellectual property laws and treaties. This Agreement does notconvey an interest in or to the Platform(s) but only a right to use the Platform(s)according to the terms of this Agreement. Nothing in this Agreement constitutes
a waiver of the Company’s IP rights.
4.2. Under no circumstances shall the Client obscure or remove any copyright,
trademark or any other notices from any of the Company’s IP or Website or
Platform(s).
4.3. It is understood that the Company may offer its Services under different
trademarks and websites. The Company owns all the images displayed on its
websites, the Platform(s) and downloadable software and material. The Client
may not use these images in any way other than the manner which theCompany provides them for.
4.4. The Client is permitted to store and print the information made available tohim through the Company’s Website or Platform(s) including documents,
policies, text, graphics, video, audio, software code, user interface design or
logos. The Client is not permitted to alter, modify, publish, transmit, distribute,otherwise reproduce commercially exploit that information, in whole or in part,in any format to any third party without the Company’s express written consent.
5. Use of the Platform
5.1. The Client agrees that he:(a) may only use the Platform for so long as he is authorised to do so under
the terms of the license granted hereunder;(b) will use the Platform only for lawful purposes;(c) may not use the Platform for any purpose other than for the purpose forwhich it has been provided under this Client Agreement;(d) is responsible for all transactions effected on his Client Account via the
Platform and the use of the Platform (including the Access Data); (e)will logout from the Platform should his access terminal be left
unattended, to prevent unauthorised access to his Client Account.
5.2. It is absolutely prohibited for the Client to take any of the following actions
in relation to the Platform(s):(a) Use any software, which applies artificial intelligence analysis to theCompany’s systems and/or Platform(s).

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD(b) Intercept, monitor, damage or modify any communication which is
not intended for him.
(c) Use any type of spider, virus, worm, Trojan-horse, time bomb or any
other codes or instructions that are designed to distort, delete,damage or disassemble the Platform(s) or the communication
system or any system of the Company.
(d) Send any unsolicited commercial communication not permitted underapplicable law or Applicable Regulations.
(e) Do anything that will or may violate the integrity of the Company
computer system or Platform(s) or cause such system(s) tomalfunction or stop their operation.
(f) Unlawfully access or attempt to gain access, reverse engineer orotherwise circumvent any security measures that the Company has
applied to the Platform(s).
(g) Perform any action that could potentially allow the irregular or
unauthorised access or use of the Platform(s).
(h) Curry out any commercial business on the Platform, unlessspecifically allowed by us in writing.
5.3. Should the Company reasonably suspect that the Client has violated theterms of paragraph 5.2., it is entitled to take one or more of the countermeasures of paragraph 14.2. of this Client Agreement.
5.4. The Client is solely responsible for providing and maintaining thecompatible equipment necessary to access and use the Platform(s), which
includes at least a personal computer or mobile phone or tablet (dependingon the Platform used), internet access by any means and telephone or otheraccess line. Access to the internet is an essential feature and the Client
shall be solely responsible for any fees necessary in order to connect to theinternet.
5.5. The Client represents and warrants that he has installed and implemented
appropriate means of protection relating to the security and integrity of his
computer or mobile phone or tablet and that he has taken appropriate
actions to protect his system from computer viruses or other similar harmful
or inappropriate materials, devices, information or data that may potentiallyharm the Website, the Platform(s) or other systems of the Company. The
Client further undertakes to protect the Company from any wrongfultransmissions of computer virus or other similarly harmful or inappropriatematerial or device to the Platform(s) from his personal computer or mobile
phone or tablet.

5.6. The Company makes no express or implied representations:(a) that the Platform will be available for access all the time, or at any time
on a continuous uninterrupted basis. Access to the Platform may beaffected, for example, by routine maintenance, repairs, reconfigurations
or upgrades;
Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD(b) as to the operation, quality or functionality of the Platform;(c) that the Platform will be free of errors or defects;(d) that the Platform is free from viruses or anything else that has
contaminating or destructive properties including where such results inloss of or corruption to Client data or other property.
The Company will not be liable to the Client should his computer system ormobile phone or tablet fail, damage, destroy and/or format his records and data.
Furthermore, if the Client incurs delays and any other form of data integrity
problems that are a result of his hardware configuration or mismanagement, theCompany shall not be liable.
5.7.
The Company will not be liable for any such disruptions or delays or
problem in any communication experienced by the Client when using the
Platform(s).
5.8.
The Company agrees to hold harmless the Client from losses on his
Client Account in the event that the Platform is ‘hacked’, or any unauthoriseduse of a Client Account’s Access Data occurs which is due to the negligence of
the Company. Likewise, the Client shall hold harmless the Company fromlosses in the event that his Client Account is hacked or associated unauthoriseduse of his Access Data occurs due to his negligence.
6. Safety
6.1. When you first access the Platform you will be asked to enter your Access
Data, which are confidential and you agree to keep confidential and not todisclose to any third person.
6.2. The Client agrees to notify the Company immediately if he knows orsuspects that his Access Data or Client Account number have or may have been
disclosed to any unauthorised person. The Company will then take steps toprevent any further use of such Access Data and will issue replacement Access
Data. The Client will be unable to place any Orders until he receives thereplacement Access Data.
6.3. The Client agrees that he will co-operate with any investigation the
Company may conduct into any misuse or suspected misuse of his Access
Data.
6.4. The Client acknowledges that the Company has no responsibility if
unauthorised third persons gain access to information, including electronic
addresses, electronic communication, personal data and Access Data when theabove are transmitted between the Parties using the internet or other network
communication facilities, post, telephone, or any other electronic means.
6.5. If the Company is informed from a reliable source that the Access Data of
the Client may have been received by unauthorised third parties,
Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

the Company may, at its discretion without having an obligation to the Client,
deactivate the Client Account.
PART TWO – CLIENT ACCEPTANCE AND INVESTMENT SERVICES
7. Application and Commencement
7.1. After the Client fills in and submits the Account Opening Application Form
together with all the required identification documentation required by theCompany for its own internal checks, the Company will send him a notice
informing him whether he has been accepted as a Client of the Company. It is
understood that 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 the Company, properly and fully completed bysuch person and all internal Company checks (including without limitation antimoney laundering checks, appropriateness or suitability tests as the case maybe) have been satisfied. It is further understood that the Company reserves theright to impose additional due diligence requirements to accept Clients residing
in certain countries due to the requirement under Applicable Regulations for an
Investment Firm (IF) to take a risk based approach when performing due
diligence on Clients.
7.2. The Agreement shall take effect and commence upon the receipt by the
Client of a notice sent by the Company informing the Client that he has been
accepted as the Company’s Client or that a Client Account has been opened
for him.
8. Client Classification
8.1. According to Applicable Regulations, IFs must classify their Clients in oneof the following categories: Retail Client, Professional Client or Eligible
Counterparty. It is noted that the Company treats all of its Clients as Retail
Clients.
8.2. Where an IF treats a Client as a Retail Client, the Client is entitled to more
protections under the Law, than if the Client was treated as a Professional
Client. In summary, these protections are as follows (the list may not be
exhaustive):(a) A Retail Client will be given more information disclosures with regards to theCompany, its services, its financial instruments and their performance, thenature and risks of financial instruments, its costs, commissions, fees andcharges and the safeguarding of Client financial instruments and Client funds,
including summary details of any relevant investor compensation or deposit
guarantee scheme, as applicable.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD(b) Where the Company is providing the services of Reception & Transmission oforders and/or Execution of Client orders (the Company shall ask a Retail Client
to provide information regarding his knowledge and experience in theinvestment field relevant to the specific type of product or service offered or
demanded, so as to enable the Company to assess whether the investment
service or product envisaged is appropriate for the Client. In case theCompany considers, on the basis of the information received, that the productor service is not appropriate to a Retail Client, it shall warn the Client
accordingly. Please note that the Company is not required to assess
appropriateness in certain cases specified by the Law (for example but notlimited to the situation where on an execution only basis the financial
instrument concerned is not complex).
On the other hand, the Company shall be entitled to assume that a
Professional Client has the necessary experience and knowledge in order tounderstand the risks involved in relation to those particular investment services
or transactions, or types of transaction or product, for which the Client isclassified as a Professional Client. Consequently, and unlike the situation witha Retail Client, the Company should not generally need to obtain additional
information from the Client for the purposes of the assessment ofappropriateness for those products and services for which they have beenclassified as a Professional Client.
(c) When executing Client orders, the Company must take all reasonable steps toachieve what is called “best execution” of the Client’s orders, that is to obtain
the best possible result for its Clients.
Where the Company executes an order of a Retail Client, the best possible
result shall be determined in terms of the total consideration, representing theprice of the financial instrument and the costs related to execution, which shall
include all expenses incurred by the Client which are directly related to the
execution of the order, including execution venue fees, clearing and settlement
fees and any other fees paid to third parties involved in the execution of theorder. The Company shall also send a notice to a Retail Client confirming
execution of the order as soon as possible and no later than the first business
day following execution or, if the confirmation is received by the Company froma third party, no later than the first business day following receipt of theconfirmation from the third party, as applicable.
Professional Clients are also entitled to a confirmation for the execution of theirorders however there is no specific timeframe involved as to when theProfessional Client will receive this information. Nevertheless, this confirmation
shall be provided promptly.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD(d) The Company must inform Retail Clients of material difficulties relevant to theproper carrying out of their order(s) promptly upon becoming aware of the
difficulty.
(e) The Company is required to provide Retail Clients with more information than
Professional Clients as regards the execution of their orders.
(f) The Company is obliged to enter into a written basic agreement with the retail
Client, setting out the essential rights and obligation of both parties.
8.3. It is understood that under the Law, the Company has the right to change
its policy and accept other categories of Clients as well and hence review the
Client’s Classification and change his Classification if this is deemed necessary(subject to Applicable Regulations and appropriate notification to the Client).
9. Assessment
9.1. In providing execution of Client Orders services to the Client, the Company
is obliged under Applicable Regulations to seek information from a Client or
potential Client regarding his knowledge and experience in the investment field
relevant to the specific type of service or Financial Instrument offered or
demanded, so as to enable the Company to assess whether the service or
Financial Instrument is appropriate for the Client. Where the Client or potential
Client elects not to provide the information regarding his knowledge andexperience, or where he provides insufficient information regarding his
knowledge and experience, the Company will not be able to determine whether
the service or Financial Instrument is appropriate for him. The Company shallassume that information about his knowledge and experience provided from the
Client to the Company is accurate and complete and the Company shall haveno responsibility to the Client if such information is incomplete or misleading orchanges or becomes inaccurate and the Company will be deemed to have
performed its obligations under Applicable Regulations, unless the Client has
informed the Company of such changes.
10. Services
10.1. Trading with the Company involves the provision of the following
investment and ancillary services from the Company to the Client, subject to the
Client’s obligations under the Agreement being fulfilled:(a) The Investment service of Execution of Orders on an own account basis.
(b) Cash/collateral management, according to PART THREE below.
(c) Foreign Currency Services provided they are associated with theprovision of the services of paragraph 10.1.(a) and (b).
10.2. It is understood that when trading in CFDs, the Company shall not holdany Financial Instruments of the Client and shall not be providing safekeeping

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

and administration of Financial Instruments for the account of Client or
custodianship.
11. Advice and Commentary
11.1. The Company will not advise the Client about the merits of a particular
Order or give him any form of investment advice and the Client acknowledges
that the Services do not include the provision of investment advice in Financial
Instruments or the Underlying Markets or Assets. The Client alone will decide
how to handle his Client Account and place Orders and take relevant decisions
based on his own judgement.
11.2. The Company will not be under any duty to provide the Client with any
legal, tax or other advice relating to any Transaction. The Client may wish toseek independent advice before entering into a Transaction.
11.3. The Company may, from time to time and at its discretion, provide the
Client (or in newsletters which it may post on its Website or provide to
subscribers via its Website or otherwise) with information, news, market
commentary or other information but not as part of its Services to the Client.
Where it does so:(a) The Company will not be responsible for such information.
(b) The Company gives no representation, warranty or guarantee as to theaccuracy, correctness or completeness of such information or as to thetax or legal consequences of any related Transaction.
(c) This information is provided solely to enable the Client to make his own
investment decisions and does not amount to investment advice or
unsolicited financial promotions to the Client.
(d) If the document contains a restriction on the person or category of
persons for whom that document is intended or to whom it is distributed,
the Client agrees that he will not pass it on to any such person or categoryof persons.
(e) The Client accepts that prior to dispatch, the Company may have acted
upon it itself to made use of the information on which it is based. The
Company does not make representations as to the time of receipt by the
Client and cannot guarantee that he will receive such information at thesame time as other clients.
11.4. It is understood that market commentary, news, or other information
provided or made available by the Company are subject to change and may be
withdrawn at any time without notice.
12. Placement and Execution of Orders
12.1. The Company may from time to time accept Client Orders in different ways
such as on the Platform, via telephone call, facsimile transmission and any othermethods in the Company’s discretion. Orders placed via facsimile transmission
will be accepted only if this is specifically agreed between the Parties.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

12.2. The Client may place Orders with the Company on the Platform and via
telephone call, by using his Access Data and provided all the Essential Details
are given in both cases. Orders via facsimile transmission need to bring thesignature of the Client or of the Client’s Authorised Representative and all
Essential Details.
12.3. The Company will be entitled to rely and act on any Order placed on the
Platform(s) or via telephone call by using the Access Data or placed by facsimiletransmission having the signature of the Client (or of the Authorised
Representative), without any further enquiry to the Client and any such Orders
will be binding upon the Client.
12.4. Orders are executed according to the “Summary Best Interest and Order
Execution Policy”, which is binding on the Client.
12.5. The Company will use reasonable efforts to execute an Order, but it isagreed and understood that despite the Company’s reasonable efforts
transmission or execution may not always be achieved at all for reasons beyond
the control of the Company.
12.6. The Client hereby acknowledges and agrees that the Company may, in its
sole discretion, add, remove or suspend from the Platform, any Financial
Instrument, on any type of Underlying Asset or Market, from time to time in theevent of a stock transformation event (for example as the result of a takeover,share consolidation/split, merger, spinoff, nationalisation, de-listing, etc.) or if no
Client Positions are held in a particular Financial Instrument at that time.

12.7. Orders may be placed within the normal trading hours of the Company,
available on the Platform and/or the Website, as amended from time to time.
13. Decline of Client’s Orders
13.1. Without prejudice to any other provisions herein, the Company is entitled,
at any time and at its discretion, without giving any notice or explanation to the
Client to restrict the Client’s trading activity, to cancel Orders, to decline or
refuse to transmit or execute any Order of the Client, and the Client has no rightto claim any damages, specific performance or compensation whatsoever fromthe Company, in any of the following cases:(a) Internet connection or communications are disrupted.
(b) In consequence of request of regulatory or supervisory authorities of
Belize or a court order or antifraud or anti-money laundering authorities.
(c) Where the legality or genuineness of the Order is under doubt.
(d) A Force Majeure Event has occurred, according to paragraph 27.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD(e) In an Event of Default of the Client as described in paragraph 14.1 below.
(f) The Company has sent a notice of Termination of the Agreement to the
Client.
(g) The system of the Company rejects the Order due to trading limits
imposed.
(h) Under abnormal market conditions.
(i) The Client does not hold adequate funds in his Balance for the specificOrder or the Balance goes below zero.
(j) Benefits – Takeovers and Transformations (including events such as
share consolidations/splits, mergers, takeovers, spinoffs, MBOs, delistings, etc.). Depending on the circumstances of each event, theCompany may close out any Open Positions at the market priceimmediately prior to such an event taking place.
14. Events of Default
14.1. Each of the following constitutes an “Event of Default”:(a) The failure of the Client to perform any obligation due to the Company.
(b) If an application is made in respect of the Client pursuant to the Belize
Bankruptcy Act or any equivalent act in another Jurisdiction (if the Clientis an individual), if a partnership, in respect of one or more of the partners,
or if a company, a receiver, trustee, administrative receiver or similar
officer is appointed, or if the Client makes an arrangement or composition
with the Client’s creditors or any procedure which is similar or analogous
to any of the above is commenced in respect of the Client.
(c) The Client is unable to pay the Client’s debts when they fall due.
(d) Where any representation or warranty made by the Client in paragraph
29 is or becomes untrue.
(e) The Client (if the Client is an individual) dies or is declared absent or
becomes of unsound mind.
(f) Any other circumstance where the Company reasonably believes that itis necessary or desirable to take any action set out in paragraph 14.2.
(g) An action set out in paragraph 14.2 is required by a competent regulatory
authority or body or court.
(h) The Company reasonably considers that the Client involves theCompany in any type of fraud or illegality or breach of Applicable
Regulations or the Company is placed at risk of being involved in any

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

type of fraud or illegality or breach of Applicable Regulations if it
continues offering Services to the Client, even when this is not due to the
Client’s wrongdoing.
(i) The Company reasonably considers that there is a material violation by
the Client of the requirements established by legislation of the Republicof Belize or other countries having jurisdiction over the Client or his
trading activities, such being materiality determined in good faith by theCompany.
(j) If the Company suspects that the Client is engaged into money
laundering activities or terrorist financing or card fraud or other criminal
activities.
(k) The Company reasonably suspects that the Client performed aprohibited action as set out in paragraph 5.2.
(l) The Company reasonably suspects that the Client performed abusive
trading such as, but not limited to, Snipping, Scalping, Pip-hunting,Hedging, placing “buy stop” or “sell stop” Orders prior to the release offinancial data, arbitrage, manipulations or a combination of faster/slower
feeds.
(m)The Company reasonably suspects that the Client opened the Client
Account fraudulently.
(n) The Company reasonably suspects that the Client performed forgery or
used a stolen card to fund his Client Account.
14.2. If an Event of Default occurs the Company may, at its absolute
discretion, at any time and without prior Written Notice, take one or more of
the following actions as deemed appropriate under the circumstances:(a) Terminate this Agreement immediately without prior notice to the Client.
(b) Cancel any Open Positions.
(c) Temporarily or permanently bar access to the Platform(s) or suspend or
prohibit any functions of the Platform(s) until the Company canreasonably determine that an Event of Default occurred.
(d) Reject or Decline or refuse to transmit or execute any Order of the Client
until the Company can reasonably determine that an Event of Default
occurred.
(e) Restrict the Client’s trading activity until the Company can reasonably
determine that an Event of Default occurred.
(f) In the case of fraud, forgery or use of stolen cards reverse the funds backto real owner or according to the instructions of the law enforcement
authorities of the relevant country, or of the credit card company or ofanother financial institution.
(g) Cancel or reverse any profits gained through abusive trading ofparagraph 14.1. (k) and (l) or the application of artificial intelligence on
the Client Account or in case of the use of stolen cards, forgery, fraud or
when the Client engaged into a criminal activity or money laundering.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD(h) Take legal action for any losses suffered by the Company.
(i) Cancel or revoke any Bonuses awarded.

15. Trade Confirmations
15.1. The Company shall provide the Client with adequate reporting on his
Orders. For this reason, the Company will provide the Client with an online
access to his Client Account via the Platform(s), which will provide him with
sufficient information in order to comply with IFSC Rules in regards to Client
reporting requirements.
15.2. If the Client has a reason to believe that the Confirmation is wrong or if the
Client does not receive any Confirmation when he should, the Client shallcontact the Company Ten Business Days from the date the Company Orderwas sent or ought to have been sent (in the event that a Conformation
was not sent). If the Client expresses no objections during this period, thecontent is considered as approved by him and shall be deemed conclusive.
PART THREE – CLIENT MONEY AND CIENT ACCOUNT
16. Client Money Handling Rules
16.1. The Company will promptly place any Client money it receives into one ormore segregated account(s) with reliable financial institutions (for example abank) and the Client funds will be segregated from the Company’s own money
and cannot be used in the course of its business.
16.2. The Company may hold Client money and the money of other clients inthe same account (omnibus account).
16.3. The Company shall not pay to the Client any interest earned on Clientmoney (other than profit gained through trading Transactions from his Client
Account(s) under this Agreement) and the Client waives all right to interest.
16.4. The Company may deposit Client money in overnight deposits and will beallowed to keep any interest.
16.5. Client money may be held on the Client’s behalf a bank located within or
outside Belize. The legal and regulatory regime applying to any such person
outside Belize will be different from that of Belize and in the event of theinsolvency or any other equivalent failure of that person, the Client’s money may
be treated differently from the treatment which would apply if the money washeld in a Segregated Account in Belize. The Company will not be liable for thesolvency, acts or omissions of any third party referred to in this paragraph.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

16.6. In the event of the insolvency or any other analogous proceedings inrelation to that third party, the Company may only have an unsecured claim
against the third party on behalf of the Client, and the Client will be exposed to
the risk that the money received by the Company from the third party is
insufficient to satisfy the claims of the Client with claims in respect of the relevant
account. The Company does not accept any liability or responsibility for any
resulting losses.
16.7. It is agreed that the Company shall have the right to transfer the Client
Money to successors or assignees or transferees or buyers, with 15 Business
Days Prior Written Notice to the Client for the purposes of paragraph 34.2. of
the Client Agreement.
16.8. The Company shall have a general lien on all funds held by the Company
or its Associates or its nominees on the Client’s behalf until the satisfaction of
his obligations.
17. Client Accounts, Deposits and Withdrawals
17.1. The Company shall open one or more a Client Account(s) for the Client toallow him to place Orders in particular Financial Instruments.
17.2. It is understood that the types of the different Client Accounts offered by
the Company and the characteristics of such Client Accounts are found on theWebsite and are subject to change at the Company’s discretion and according
to paragraph 25 hereunder.
17.3. The Client Account shall be activated upon the Client depositing theminimum initial deposit, as determined and mended by the Company in its
discretion from time to time. The minimum initial deposit may vary according to
the type of Client Account offered to the Client and is found on the Website.
17.4. The Client may deposit funds into the Client Account at any time during
the course of this Agreement. Deposits will be made via the methods and in thecurrencies accepted by the Company from time to time. The detailed information
about deposit options is shown on the Website.
17.5. The Company shall have the right to request the Client at any time any
documentation to confirm the source of funds deposited into the Client Account.
The Company shall have the right to reject a deposit of the Client and/or block
the Client Account in any of the following cases:(a)if the Company is not duly satisfied as to the legality of the source offunds;(b)
if the Client fails to provide the Company with any relevant documents
it requests from the Client for client identification purposes or for any otherreason;(c)
if the Company reasonably suspects or has concerns that the submitted
documents may be false or fake;

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD(d)if the Company reasonably suspects that the Client is involved in illegal
or fraudulent activity;(e)
if the Company is informed that the credit or debit card (or any otherpayment method used by the Client) has been lost or stolen;(f)where the Company reasonably considers that there is a chargebackrisk for any other reason; or(g)when the Client deposits $10,000 or more (in one or more separate
deposits) and the Company is unable to verify the source,(h)when the acquiring bank, issuer bank or any third party processor or
payment service provider rejected the transaction.
17.6. If the funds sent by the Client are not deposited in the Client Accountwhen they were supposed to, the Client shall notify the Company and requestfrom the Company to make a banking investigation of the transfer. The Client
agrees that any charges of the investigation shall be paid by the Client anddeducted from his Client Account or paid directly to the bank performing theinvestigation. The Client understands and aggress that in order to perform theinvestigation the Client shall have to provide the Company with the requested
documents and certificates.
17.7. The Company shall make withdrawals of Client funds upon the
Company receiving a relevant request from the Client by fax or email or in any
other method accepted by the Company from time to time.
17.9. Upon the Company receiving an instruction from the Client to withdraw
funds from the Client Account, after the Client completed the withdrawal
process, the Company shall pay the said amount within one to five Business
Days, if the following requirements are met:(a)the withdrawal instruction includes all required information andidentification details of the Client as may be required by the Company;(b)
the instruction is to make a transfer to the originating account(whether that is a bank account, a payment system account etc) from which
the money was originally deposited in the Client Account or at the
Client’s request to a bank account belonging to the Client;(c)the account where the transfer is to be made belongs to the
Client;(d)
at the moment of payment, the Client’s Balance exceeds theamount specified in the withdrawal instruction including all payment charges;(e)there is no Force Majeure event which prohibiting the Company
from effecting the withdrawal;(f)the Client does not have any Open Positions or in the case if any
Open Positions the remaining Balance in the Client Account shall be at least
double the necessary Maintenance Margin required to keep the positions
open;g) the Client sends the withdrawal instruction in a signed form by fax oremail or in any other approved method by the Company from time to time.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

17.10. It is agreed and understood that the Company will not accept third partyor anonymous payments in the Client Account and will not to make withdrawals
to any other third party or anonymous account.
17.11. The Company reserves the right to reasonably decline a withdrawal
request of the Client asking for a specific transfer method and the Company has
the right to suggest an alternative.
17.12. All payment and transfer charges of third parties will be borne by the
Client and the Company shall debit the relevant Client Account for thesecharges.
17.13. The Client may send the request for internal transfer of funds to another
Client Account held by him with the Company. Internal transfers shall be subject
to the Company’s policy from time to time.
17.14. Mistakes made by the Company during transfer of funds shall be
refunded to the Client. It is understood that should the Client provide wrong
instructions for a transfer, the Company may be unable to correct the mistakeand the Client may have to suffer the loss. It is further understood that theCompany shall not be liable for any mistakes of third party payment service
providers.

18. Currency Conversions
18.1. In the event that the Client deposits money in a different currency of thatof the Currency of the Client Account then the Company shall convert the sum
deposited into the Currency of the Client Account. The Company shall do thisat reasonable market rate and/or rate of exchange and/or bank that it considers
appropriate. The Company shall be entitled to charge the Client for currency
conversion or retain a mark-up from the exchange rates for arranging such
conversion as the Company may from time to time specify to the Client andpublish on the Platform and/or the Website. The Company shall be entitled tocharge to the Client and obtain from the Client Account or from the deposited
amount the expenses incurred with regard to currency conversions for the
Client, including commissions to banks, money transfer fees, commissions tointermediaries.
18.2. Depending on the currency used to deposit money in the Client Account,
the Company may charge an amount in the form of a percentage (as a fixed
spread) of the amount deposited. If the Client pays in his card currency, theCompany will be allowed to charge a fixed spread of 3% for not like/likecurrencies, or so called exotic currencies. In relation to what is called Like/likecurrencies (GBP, USD, EUR, CHF, JPY, CAD, DKK, AUD), the Company does
not charge any conversion fees when the Client pays in these currencies.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

18.3. In the event of currency fluctuations, the Company will have no liability for
any losses or damages incurred on the Client.
19. Inactive and Dormant Client Accounts
19.1. If the Client Account is inactive for three months or more (i.e. there is no
trading, no open positions, no withdrawals or deposits), it will be charged amonthly maintenance fee (the sum is available on the Website and/or the
Platform), which may be different for different types of Client Accounts or
Financial Instrument.
19.2. If the Client Account is inactive for one year or more, and after notifying
the Client in its last known address, the Company reserves the right to close the
Client Account and render it dormant. Money in the dormant account shallremain owing to the Client and the Company shall make and retain records andreturn such funds upon request by the Client at any time thereafter. The
Company may charge a fee during the period when the Account is dormant;such a fee shall be notified to the Client according to paragraph 25.8. hereunder.

20. Netting and Set-Off
20.1. If the aggregate amount payable by the Client is equal to the aggregate
amount payable by the Company, then automatically the mutual obligations tomake payment are set-off and cancel each other.

20.2. If the aggregate amount payable by one party exceeds the aggregate
amount payable by the other party, then the party with the larger aggregate
amount shall pay the excess to the other party and all obligations to makepayment will be automatically satisfied and discharged.
20.3. The Company has the right to combine all or any Client Accounts openedin the Client name and to consolidate the Balances in such Client Accounts andto set-off such Balances in the event of Termination of the Agreement.
PART FOUR – GENERAL TERMS ABOUT OUR RELATIONSHIP
21. Language
21.1. The Company’s official language is the English language and the Client
should always read and refer to the main Website for all information anddisclosures about the Company and its activities. Translation or information
provided in languages other than English is for informational purposes only anddo not bind the Company or have any legal effect whatsoever, the Company
having no responsibility or liability regarding the correctness of the information
therein.
Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

22. Communications and Written Notices
22.1. The Client shall be able to call the Company within its normal working
hours. The Company may contact the Client outside its normal working
hours.
22.2. In order to communicate with the Company, the Client may use the contact
details of the Company available on its Website or notified to the Client in any
other way.
22.3. In order to communicate with the Client the Company will use the contact
details provided by the Client whilst opening the Client, Account or as updated
latter on. Hence, the Client has an obligation to notify the Company immediatelyof any change in the Client’s contact details. Should the Client fail to do so, theCompany shall have no liability should any important notices or cheques issued
in his name are lost when sent by the Company at his last know details.
22.4. The following methods of communication are considered as Written Noticefrom the Company to the Client: email, Platform’s internal mail, facsimiletransmission, post, commercial courier service, air mail or the Company’s
Website. The following methods of communication are considered as Written
Notice from the Client to the Company: email, facsimile transmission, post,commersial courier service or air mail or commercial courier.
22.5. Without prejudice to paragraph 23.6., any communications sent to either
Party, as applicable, (documents, notices, confirmations, statements, reportsetc.) are deemed received:(a)
If sent by email, within one hour after emailing it and provided
the email has left from the sender’s outlook.
(b)
it.

If sent by the Platform’s internal mail, immediately after sending(c)
If sent by facsimile transmission, upon receipt by the sender of atransmission report from its facsimile machine confirming receipt of themessage by recipient’s facsimile machine.
(d)
If sent by telephone call, once the telephone conversation has
been finished.
(e) If sent by post, seven calendar days after posting it.
(f) If sent via commercial courier service, at the date of signing of the
document on receipt of such notice.
(g) If sent by air mail, eight Business Days after the date of their dispatch.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD(h) If posted on the Company Webpage, within one hour after it has beenposted.
22.6. Any Written Notices sent to the Company shall have to be received
within the working hours of the Company. Notwithstanding paragraph 23.5., any
Notices received outside the normal working hours shall be treated as being
received the following Business Day.
22.7. Faxed documents received by the Company may be electronicallyscanned and reproduction of the scanned version shall constitute conclusive
evidence of such faxed instructions.
23. Personal Data, Confidentiality, Recording of Telephone Calls andRecords
23.1. The Company may collect Client information directly from the Client (in hiscompleted Account Opening Application Form or otherwise) or from otherpersons including, for example, the credit reference agencies, fraud prevention
agencies, banks, other financial institutions, third authentication service
providers and the providers of public registers.
23.2. Client information which the Company holds is to be treated by theCompany as confidential and will not be used for any purpose other than inconnection with the provision, administration and improvement of the Services,anti-money laundering and due diligence checks, for research and statistical
purposes and for marketing purposes. Information already in the public domain,or already possessed by the Company without a duty of confidentiality will not
be regarded as confidential.
23.3. The Company has the right to disclose Client information (including
recordings and documents of a confidential nature, card details) in the following
circumstances:(a) Where required by law or a court order by a competent Court.
(b) Where requested by IFSC or any other regulatory authority having
control or jurisdiction over the Company or the Client or their associates
or in whose territory the Company has Clients.
(c) To relevant authorities to investigate or prevent fraud, money launderingor other illegal activity.
(d) To such an extent as reasonably required so as to execute Orders andfor purposes ancillary to the provision of the Services.
(e) To credit reference and fraud prevention agencies, third authentication
service providers, banks and other financial institutions for credit
checking, credit card checks, fraud prevention, anti-money laundering
purposes, identification or due diligence checks of the Client. To do sothey may check the details the Client supplied against any particulars on
any database (public or otherwise) to which they have access. They may
also use Client details in the future to assist other companies forverification purposes. A record of the search will be retained by theCompany
Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
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Terms and Conditions – Client Agreement

Xtrade International LTD(f) To the Company’s professional advisors provided that in each case therelevant professional shall be informed about the confidential nature ofsuch information and commit to the confidentiality herein obligations aswell.
(g) To other service providers who create, maintain or process databases(whether electronic or not), offer record keeping services, emailtransmission services, messaging services or similar services which aim
to assist the Company collect, storage, process and use Client
information or get in touch with the Client or improve the provision of theServices under this Agreement.
(h) To other service providers for statistical purposes in order to improve theCompany’s marketing, in such a case the data will be provided in an
aggregate form.
(i) To market research call centers that provide telephone or email surveys
with the purpose to improve the services of the Company, in such a caseonly the contact details data will be provided.
(j) Where necessary in order for the Company to defend or exercise its legal
rights to any court or tribunal or arbitrator or Ombudsman orgovernmental authority.
(k) At the Client’s request or with the Client’s consent.
(l) To an Affiliate of the Company or any other company in the same groupof the Company.
(m)To successors or assignees or transferees or buyers, with ten Business
Days Prior Written Notice to the Client, and for the purposes of paragraph34.2. of the Client Agreement.
(n) Client Information is disclosed in relation to US taxpayers to the Inland
Revenue in Belize, which will in turn report this information to the IRS of
the US according to the Foreign Account Tax Compliance Act (FATCA)
of the USA and the relevant intergovernmental agreement between
Belize and the US.
23.4. If the Client is a natural person, the Company will use, store, process
and handle personal information provided by the Client in connection with theprovision of the Services, in accordance the Processing of Personal Data
(Protection of the Individual) Law of 2001 and the Company is obliged to supply
the Client, on request, with a copy of personal data which it holds about the
Client (if any), provided that the Client pays an administrative fee.
23.5. Telephone conversations between the Client and the Company may berecorded and kept by the Company and recordings will be the sole property of
the Company. The Client accepts such recordings as conclusive evidence of
the Orders or conversations so recorded.
23.6. The Client accepts that the Company may, for the purpose ofadministering the terms of the Agreement, from time to time, make direct contact
with the Client by telephone, sms, fax, email, or post.
Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

23.7. The Client accepts that the Company or any Affiliate of the Company or
any other company in the same group of the Company may make contact with
the Client, from time to time, by telephone, fax, email or post for marketing
purposes to bring to the Client’s attention products or services that may be ofinterest to him or to conduct market research. This right is exercised in relation
to Clients who are natural persons only when they provide their specific consent
to that effect.
23.8. Under Applicable Regulations, the Company will keep records
containing Client personal data, trading information, Client Account opening
documents, communications and anything else which relates to the Client for atleast five years after termination of the Agreement.
24. Amendments
24.1. The Company may upgrade the Client Account, convert Client Accounttype, upgrade or replace the Platform or enhance the services offered to the
Client if it reasonably considers this is to the Clients advantage and there is no
increased cost to the Client.
Amendments of the Agreement
24.2. The Company may also change any terms of the Agreement for any of thefollowing reasons:(a) Where the Company reasonably considers that:· the change would make the terms of the Agreement easier tounderstand or are more complete; or·the change would not be to the disadvantage of the Client.
(b) To cover:·the involvement of any service or facility the Company offers to the
Client; or·the introduction of a new service or facility; or·
the replacement of an existing service or facility with a new one; or· The withdrawal of a service or facility which has become obsolete, or hasceased to be widely used, or has not been used by the Client at any time in
the previous year, or it has become very expensive for the Company to offer.
(c) To enable the Company to make reasonable changes to the services
offered to the Client as a result of changes in:·the banking, investment or financial system; or·technology; or· the systems or Platform used by the Company to run its business or offer
the Services hereunder.
(d) As a result of a request of IFSC or of any other authority or as a resultof change or expected change in Applicable Regulations.
(e) Where the Company finds that any term in the Agreement isinconsistent with Applicable Regulations. In such a case, it will not rely on thatterm but treat it as if it did reflect the relevant Applicable Regulations and shallupdate the Agreement to reflect the Applicable Regulations.
Xtrade International Ltd is authorized and regulated by the Financial Services Commission withlicense number 000281/20

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Terms and Conditions – Client Agreement

Xtrade International LTD

24.3. The Company may change any of the terms of the Agreement for any
serious reason not listed under paragraph 25.2. Where the Client is a natural
person he shall have the right to object to the change.
Natural Person
24.4. Where the Client is a natural person, for any change made underparagraphs 25.2. and 25.3., the Company shall provide the Client with advancenotice of at least 10 Business Days. However, the Client acknowledges that achange which is made to reflect a change of Applicable Regulations may, if
necessary, take effect immediately.
24.5. Where the Client is a natural person, for any change made under (a), (d)and (e) of paragraph 25.2., the notice of the Company shall be a Written Noticeincluding a post on the Company’s Website. For any other change of the Client
Agreement the Company, where the Company elects to provide such Written
Notice via a post on the Website, the Company shall also provide the said
Written Notice with an additional means of Written Notice.
24.6. When the Company provides Written Notice to Clients who are natural
persons of changes under paragraphs 25.2. and 25.3. it shall tell the Client thedate it comes into effect. The Client shall be treated as accepting the changeon that date unless, before then, the Client informs the Company that hewishes to object the change. Client shall not have to pay any charges as aresult of terminating in this case, other than costs due and payable for Services
offered until the termination.
Legal Entity
24.7. Where the Client is a legal entity the Company shall have the right toamend any terms of the Agreement for any reason by providing at least fiveBusiness Days notice to such Client. Notice shall not have to be personal but
may be posted on the Website.
Review of Costs
24.8. Unless differently provided for elsewhere in this Agreement, the Company
shall have the right to review its costs, fees, charges and commissions), fromtime to time, in its discretion. Such changes shall be effected on the Platform
and/or the Website and the Client is responsible to check for updates regularly.
In the absence of a Force Majeure event, the Company shall be providing the
Client with advance notice on its Website of at least ten Business Days where
the Client is natural person and five Business Days when the Client is a legal
person. Premiums may be changed without prior notice.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

Review of Classification
24.9. The Company shall have the right to review the Client’s Classificationaccording to Applicable Regulations and inform the Client accordingly of thechange before it comes into effect by providing the Client with advance noticeof at least ten Business Days. Notwithstanding paragraph 25.1, changing the
Client’s Classification may also mean changing the type of Client Account of the
Client. The Client shall be treated as accepting the change on that date unless,before then, the Client informs the Company that the Client wishes to terminate
the Agreement and not accept the change.
25. Termination and Results of Termination
25.1. The Client may terminate this Agreement with Written Notice to theCompany at any time. Without prejudice to the Company’s rights under thisAgreement to terminate it immediately without prior notice to the Client, theCompany may terminate the Agreement by giving at least 15 Business Days
Written Notice to the other Party.
25.2. Termination by any Party will not affect any obligation which has alreadybeen incurred by either Party or any legal rights or obligations which may
already have arisen under the Agreement or any Transactions made hereunder.
25.3. Upon termination of this Agreement, all amounts payable by the Client to
the Company will become immediately due and payable including (but without
limitation) all outstanding costs and any other amounts payable to the Company,
any charges and additional expenses incurred or to be incurred by the Company
as a result of the termination of the Agreement.
25.4. Once notice of termination of this Agreement is sent and before thetermination date:(a)the Client will have an obligation close all his Open Positions. If
he fails to do so, upon termination, the Company will close any Open
Positions at current prices;(b)
the Company will be entitled to cease to grant the Client accessto the Platform(s) or may limit the functionalities the Client is allowed to useon the Platform(s);(c)
the Company will be entitled to refuse to accept new Orders fromthe Client;(d)the Company will be entitled to refuse to the Client to withdraw
money from the Client Account and the Company reserves the right to keep
Client’s funds as necessary to close positions which have already been
opened and/or pay any pending obligations of the Client under the
Agreement.
25.5. Upon Termination any or all the following may apply:

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD(a)
The Company has the right to combine any Client Accounts of
the Client, to consolidate the Balances in such Client Accounts and to set off
those Balances;(b)
The Company has the right to close the Client Account(s);(c)
The Company has the right to convert any currency;(d)
The Company has the right to close out the Client’s Open
Positions at current prices;(e)
In absence of illegal activity or suspected illegal activity or fraudof the Client or instructions from the relevant authorities, if there is Balancein the Client’s favour, the Company will (after withholding such amounts thatin the Company’s absolute discretion considers appropriate in respect of
future liabilities) pay such Balance to the Client as soon as reasonably
practicable and supply him with a statement showing how that Balance wasarrived at and, where appropriate, instruct any Nominee or/and any
Custodian to also pay any applicable amounts. Such funds shall be deliveredin accordance to the Client’s Instructions to the Client. It is understood that
the Company will effect payments only to an account in the name of the
Client. The Company has the right to refuse, at its discretion, to effect thirty
party payments.
26. Force Majeure26.1. A Force Majeure Event includes without limitation each of the following:(a) Government actions, the outbreak of war or hostilities, the threat of war,
acts of terrorism, national emergency, riot, civil disturbance, sabotage,requisition, or any other international calamity, economic or political crisis
that, in the Company’s opinion, prevents it from maintaining an orderly
market in one or more of the Financial Instruments in respect of which it
deals on the Platform;(b) Act of God, earthquake, tsunami, hurricane, typhoon, accident, storm,
flood, fire, epidemic or other natural disaster making it impossible for theCompany to offer its Services;.
(c) Labour disputes and lock-out which affect the operations of theCompany;(d) Suspension of trading on a market or the liquidation or closure of any
market, or the fixing of minimum or maximum prices for trading on amarket to which the Company relates its Quotes, or the imposition oflimits or special or unusual terms on the trading in any such market or aregulatory ban on the activities of any party (unless the Company hascaused that ban), decisions of state authorities, governing bodies of selfregulating organizations, decisions of governing bodies of organizedtrading platforms;(e) A financial services moratorium having been declared by appropriate
regulatory authorities or any other acts or regulations of any regulatory,
governmental, supervisory, regulatory or supranational body or authority;(f) Breakdown, failure or malfunction of any electronic, network andcommunication lines (not due to the bad faith or wilful default of theCompany);
Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
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Terms and Conditions – Client Agreement

Xtrade International LTD(g) Any event, act or circumstances not reasonably within the Company’scontrol and the effect of that event(s) is such that the Company is not ina position to take any reasonable action to cure the default;(h) The occurrence of an excessive movement in the level of any transaction
and/or Underlying Asset or Market or the Company’s anticipation (acting
reasonably) of the occurrence of such a movement;(i) 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 selfregulatory organisation, for any reason, to perform its obligations.
26.2. If the Company determines in its reasonable opinion that a Force Majeure
Event exists (without prejudice to any other rights under the Agreement) the
Company may without prior notice and at any time take any or all of the following
steps:(a) 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.
(b) Take or omit to take all such other actions as the Company deems to bereasonably appropriate in the circumstances with regard to the position of
the Company, the Client and other clients;(c) Shut down the Platform(s) in case of malfunction for maintenance or to
avoid damage;(d) Cancel any Client Orders and Refuse to accept Orders from Clients to theextent that the Force Majeure Event makes it impossible or impractical for
the Company to comply with them or to avoid losses to the Client;(e) Inactivate the Client Account to avoid damage;(f) Close out any or all Open Positions at such prices as the Company
considers in good faith to be appropriate to avoid losses for the Client;(g) Increase Spreads, increase Margin requirements, decrease Leverage
without notice to avoid damages.
26.3. Except as expressly provided in this Agreement, the Company will not beliable or have any responsibility for any type of loss or damage arising outof any failure, interruption, or delay in performing its obligations under thisAgreement where such failure, interruption or delay is due to a Force Majeure
event.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license number
000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

27. Limitations of Liability and Indemnity
27.1. In the event the Company provides information, recommendations, news,
information relating to transactions, market commentary or research to the
Client (or in newsletters which it may post on its Website or provide to
subscribers via its Website or otherwise), the Company shall not, in the absenceof its fraud, wilful default or gross negligence, be liable for any losses, costs,
expenses or damages suffered by the Client arising from any inaccuracy or
mistake in any such information given.
27.2. The Company will not be held liable for any loss or damage or expense
or loss incurred by the Client in relation to, or directly or indirectly arising frombut not limited to:(a) Any error or failure or interruption or disconnection in the operation of the
Platform(s), or any delay caused by the Client Terminal or Transactions
made via the Client Terminal, any technical problems, system failures andmalfunctions, communication line failures, equipment or software failures
or malfunctions, system access issues, system capacity issues, highinternet traffic demand, security breaches and unauthorised access, andother similar computer problems and defects;(b) Any failure by the Company to perform any of its obligations under the
Agreement as a result of Force Majeure Event or any other cause beyond
its control;(c) The acts, omissions or negligence of any third party;(d) Any person obtaining the Client’s Access Data that the Company has
issued to the Client prior to the Client’s reporting to the Company of themisuse of his Access Data;(e) Unauthorised third persons having access to information, including
electronic addresses, electronic communication, personal data andAccess Data when the above are transmitted between the Parties or any
other party, using the internet or other network communication facilities,
post, telephone, or any other electronic means;(f) Any of the risks of the Risks Disclosure and Warnings Notice;(g) Currency risk materialiasing(h) Any changes in the rates of tax;(i) The occurrence of Slippage(j) The Client relying on functions such as Trailing Stop, Agent Advisor andStop Loss Orders;

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Terms and Conditions – Client Agreement

Xtrade International LTD(k) Under abnormal Market Conditions;(l) Any actions or representations of the Introducer;(m)Any acts or omissions (including negligence and fraud) of the Client and/or
his Authorised Representative;(n) For the Client’s or his Authorised Representative’s trading decisions;(o) All Orders given through and under the Client’s Access Data;(p) The contents, correctness, accuracy and completeness of any
communication spread by the use of the Platform(s);(q) As a result of the Client engaging in social trading, under which the client
is automatically following other traders Orders;(r) The solvency, acts or omissions of any third party referred to in paragraph
16.5.
(s) A situation of paragraph 16.6. arises.
27.3. If the Company, its Directors, Officers, employees, Affiliates, or Agentsincur any claims, damage, liability, costs or expenses, which may arise inrelation to the execution or as a result of the execution of the Agreement and/or
in relation to the provision of the Services and/or in relation to the use of the
Platform(s), that the Company, its Directors, Officers, employees, Affiliates, orAgents bear no responsibility whatsoever, it is the Client’s responsibility to
indemnify the Company for such.
27.4. The Company shall in no circumstances be liable to the Client for any
consequential, special, incidental or indirect losses, damages, loss of profits,
loss of opportunity (including in relation to subsequent market movements),
costs or expenses the Client may suffer in relation to the Agreement, theprovision of the Services or the use of the Platform(s).
27.5. The Company’s cumulative liability to the Client shall not exceed thefees paid to the Company under this Agreement in relation to the particular
Client for the Provision of the Services and use of the Platform(s).
28. Representations and Warranties
28.1. The Client represents and warrants to the Company the following:(a) The Client is at least 18 years old, or the age of legal consent forengaging in financial investment activities under the laws of any
jurisdiction that applies to him;(b)
The Client is of sound mind and capable of taking decisions forhis own actions;(c)There are no restrictions on the markets or financial instruments
in which any Transactions will be sent for execution, depending on the
Client’s nationality or religion;

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Terms and Conditions – Client Agreement

Xtrade International LTD(d) All actions performed under the Agreement will not violate any law or rule
applicable to 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 will not use the IP or the Platform or Website in contravention
to this Agreement, or for unauthorized or unlawful purposes and that hewill use the IP, Platform and Website only for the benefit of his Client
Account and not on behalf of any other person;(f) The Client is duly authorised to enter into the Agreement, to give Orders
and to perform its obligations hereunder;(g) The Client is the individual who has completed the Account Opening
Application Form or, if the Client is a company, the person who hascompleted Account Opening Application Form on the Client’s behalf isduly authorised to do so;(h) The Client is acting as a principal and not as agent or representative ortrustee or custodian on behalf of someone else. The Client may act onbehalf of someone else only if the Company specifically consents to thisin writing and provided all the documents required by the Company forthis purpose are received;(i) The information provided by the Client to the Company in the AccountOpening Application Form and at any time thereafter is true, accurate
and complete and the documents handed over by the Client are valid
and authentic.
(j) The Client has read and fully understood the terms of the Agreement;(k) The Client funds used for trading are not in any direct or indirect way theproceeds of any illegal activity or used or intended to be used for terrorist
financing;(l) The Client is not a Politically Exposed Person and does not have any
relationship (for example relative or business associate) with a person
who holds or held in the last twelve months a prominent public position.
If the above statement is untrue and in the event that the Client has notdisclosed this already in the Account Opening Application Form, he will
inform the Company as soon as possible will notify the Company if at any
stage during the course of this Agreement he becomes a Politically
Exposed Person;(m)The Client is not from the USA, Cuba, Iran, Syria, Democratic People’s
Republic of Korea, Algeria, Indonesia, Myanmar, Hong Kong. The
Company does not accept Clients from these regions;(n) He has read and understands the “Risks Disclosure and Warnings
Notice” found on the Website;(o) The Client consents to the provision of the information of the Agreement
by means of a Website or email;(p) The Client confirms that he has regular access to the internet andconsents to the Company providing him with information, including,
without limitation, information about amendments to the terms andconditions, costs, fees, this Agreements, policies and information about
the nature and risks of investments by posting such information on the

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20

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Xtrade International LTD

Website or email. Should the Client wish, he may request for these to besent by post or fax.
29. Complaints and Disputes
29.1. If the Client wishes to report a complaint, he must send an email tocompliance@xtrade.com .The Company will try to resolve it without undue
delay and according to the Company’s Complaints Procedure for Clients,
available on the Company’s Website.
29.2. If a situation arises which is not expressly covered by this Agreement,
the Parties agree to try to resolve the matter on the basis of good faith andfairness and by taking such action as is consistent with market practice.
29.3. It is noted that the Client, depending on the amount of the compliant, may
have the right under Applicable Regulations, to make a complaint at the
Financial Ombudsman of Belize, once it is activated.
29.4. The Client’s right to take legal action remains unaffected by the existenceor use of any complaints procedures referred to above.
30. Applicable and Governing Law and Applicable Regulations
30.1. If a settlement is not reached by the means described in paragraph 30, alldisputes and controversies arising out of or in connection with the Agreement
shall be finally settled in court in Belize.
30.2. This Agreement is governed by the Laws of Belize.
30.3. All transactions on behalf of the Client shall be subject to Applicable
Regulations and any other public authorities which govern the operation of theBelize Investment Firms, as they are amended or modified from time to time.
The Company shall be entitled to take or omit to take any measures which it
considers necessary to ensure compliance with the Applicable Regulations, therelevant market rules. Any such measures as may be taken shall be binding on
the Client.
30.4. All rights and remedies provided to the Company under the Agreement
are cumulative and are not exclusive of any rights or remedies provided by law.
31. Severability
31.1. Should any part of this Agreement be held by any Court of competentjurisdiction to be unenforceable or illegal or contravene any rule, regulation or
by law of any Market or regulator, that part will be deemed to have been
excluded from this Agreement from the beginning, and this Agreement will be

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Xtrade International LTD

interpreted and enforced as though the provision had never been included andthe legality or enforceability of the remaining provisions of the Agreement or thelegality, validity or enforceability of this provision in accordance with the law
and/or regulation of any other jurisdiction, shall not be affected.
32. Non-Exercise of Rights
32.1. Either Party’s failure to seek redress for violations, or to insist upon strict
performance, of any condition or provision of this Agreement, or its failure to
exercise any or part of any of right or remedy to which that Party is entitled under
this Agreement, shall not constitute an implied waiver thereof.

33. Assignment
33.1. The Company may at any time sell, transfer, assign or novate to a third
party any or all of its rights, benefits or obligations under this Agreement or the
performance of the entire Agreement subject to providing 15 Business Daysprior Written Notice to the Client. This may be done without limitation in theevent of merger or acquisition of the Company with a third party, reorganisationof the Company, winding up of the Company, lapse of its IF license or sale ortransfer of all or part of the business or the assets of the Company to a third
party.
33.2. It is agreed and understood that in the event of transfer, assignment or
novation described in paragraph 34.1 above, the Company shall have the rightto disclose and/or transfer all Client Information (including without limitation
personal data, recording, correspondence, due diligence and client
identification documents, files and records, the Client trading history) transfer
the Client Account and the Client Money as required, subject to providing 15
Business Days prior Written Notice to the Client.
33.3. The Client may not transfer, assign, charge, novate or otherwise transfer
or purport to do so the Client’s rights or obligations under the Agreement.
34. Introducer
34.1. In cases where the Client is introduced to the Company through a third
person such as a business introducer or associate or affiliate (“Introducer”), theClient acknowledges that the Company is not responsible or accountable for the
conduct, representations or the accuracy, completeness or correctness of thecontents of any promotions or marketing material of the Introducer or any otherthird party, even if these are given or appear to be given in the name of theCompany, and the Company is not bound by any separate agreements enteredinto between the Client and the Introducer.

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Xtrade International LTD

34.2. The Client acknowledges and confirms that his agreement or relationshipwith the Introducer may result in additional costs, since the Company may be
obliged to pay commission fees or charges to the Introducer. If such apply they
will be disclosed to the Client as provided under Applicable Regulations.
35. Authorised Representative
35.1. The Company may in certain cases accept an Authorised Representativeon behalf of the Client to place Orders to the Company or to handle any othermatters related to the Client Account or this Agreement, provided the Client
notifies the Company in writing of the appointment of an Authorised
Representative and this person is approved by the Company fulfilling all of theCompany specifications for this.
35.2. Unless the Company receives a written notification from the Client for thetermination of the authorisation of Authorised Representative, the Company,
without prejudice to paragraph 36.4 herein below, has the right to continue
accepting Orders and/ or other instructions relating to the Client Account by the
Authorised Representative on the Client’s behalf and the Client will recognize
such orders as valid and committing to him.
35.3. The written notification for the termination of the authorization of the
Authorised Representative has to be received by the Company with at least 5days’ notice prior the termination of the authorization date.
35.4. The Company has the right (but NOT an obligation to the Client) to refuse
to accept Orders and/ or other instructions relating to the Client Account fromthe Authorised Representative in any of the following cases:(a) if the Company reasonably suspects that the Authorised
Representative is not legally allowed or properly authorised to act assuch;(b) an Event of Default occurred;(c) in order for the Company to ensure compliance with the relevantmarket rules and or practices, Applicable Regulations or otherapplicable laws; or(d) in order to protect the interest of the Client.
36. Multiple Account Holders
36.1. Where the Client comprises two or more persons, the liabilities andobligations under the Agreement shall be joint and several. Any warning or othernotice given to one of the persons which form the Client shall be deemed tohave been given to all the persons who form the Client. Any Order given by oneof the persons who form the Client shall be deemed to have been given by all
the persons who form the Client.
36.2. In the event of the death or mental incapacity of one of the persons whoform the Client, all funds held by the Company or its Nominee, will be for the

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Xtrade International LTD

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).
37. Fees, Taxes and Inducements
37.1. The provision of the Services by the Company is subject to payment offees found on the Company’s fee schedule on the Platform and/or the Website(as the case may be).
37.2. It is agreed and understood that the Client shall be solely responsible for
all filings, tax returns and reports which should be made to any relevant
authority, whether governmental or otherwise, and for payment of all taxes(including but not limited to any transfer or value added taxes), arising out of orin connection with his trading activity with the Company hereunder.
37.3. The Client undertakes to pay all applicable stamp expenses relating to thisAgreement and any documentation which may be required for the currying outof the transactions under this Agreement.
37.4. Should the Company pay or receive any fees or inducements for the
introduction of the Client, it shall notify the Client according to Applicable
Regulations.
38. Bonus
38.1. Any bonus or similar benefits provided by the Company from time to timeshould only be used for trading purposes and may not be exchanged for cash.
38.2. Bonuses are subject to their own specific terms and conditions.
38.3. Bonuses are subject to withdrawal at any time.
In the event of a withdrawal, either for full or partial amount of the total deposit
be requested without meeting the redeemable terms, the following actions willtake place:
38.3.1 The bonus or any benefits will be subject to cancellation immediately
38.3.2 In the case that withdrawal of funds has been removed from the trading
account, further trading actions that have taken place, will result in the following
actions:• Any losses shell be held liable by the client (account holder)• Any profits shell be deducted from client’s account balance• Note: If the required turnover is not met when making a withdrawal
request – the withdrawal request will be automatically cancelled.
38.4. Without prejudice to the Company’s right to block or close the Client
Account, any improper or abusive trading or prohibited action hereunder, not inaccordance with this Agreement, will result in cancellation or revocation of
bonuses awarded.

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38.5. The decision whether to offer a bonus to a prospective/potential client isclearly and indisputably at the company’s absolute and unreserved discretion.
38.6. Any bonuses, promotions and benefits that are provided by thecompany or any trading account can be viewed in the trading account for moredetails.
38.7. Clients are expected to utilize Xrade bonus in a rightful and justified
manner, according to the terms and provisions of this agreement.
38.8. Should the company under any circumstance suspect any wrongdoing
or deception, the company reserves the right to cancel bonuses, promotions or
benefits that have been provided or are supposed to be provided to thespecified trading account.
38.9. The Company reserves the right to revoke or change the offers at any
time without prior notice.
39. Duty for the Overview of Claims
Xtrade International Ltd shall be responsible for the overview and determinationof any client claims that may arise from time to time.
Xtrade International Ltd will have the unequivocal right to dispute and/or
argue such claims via written notifications and provide opinions to the Clientsof the Company where it considers that such claims are or may beconsidered in its best opinion, estimations, views, and/or judgment as
groundless, unjustified, unsupported and/or unfounded. Following such written
notifications, the Clients of the Company shall need to proceed with otheractions as those described within clause 30 in order to resolve any disputes
or controversies they have with the Company.

PART FIVE – DEFINITIONS
40. Interpretation of Terms
40.1. In this Agreement:“Access Data” shall mean the Login and Password of the Client, which arerequired so as to have access on and use the Platform(s) and the telephone
password and Client Account number, which are required so as to place
Orders via phone and any other secret codes issued by the Company to the
Client.
“Account Opening Application Form” shall mean the application
form/questionnaire completed by the Client in order to apply for theCompany’s Services under this Agreement and a Client Account, via which

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
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Terms and Conditions – Client Agreement

Xtrade International LTD

form/questionnaire the Company will obtain amongst other things information
for the Client’s identification and due diligence, his categorization andappropriateness or suitability (as applicable) in accordance with theApplicable Regulations.
“Affiliate” shall mean in relation to the Company, any entity which directly or
indirectly controls or is controlled by the Company, or any entity directly or
indirectly under common control with the Company; and “control” means thepower to direct or the presence of ground to manage the affairs of theCompany or entity.
“Agreement” shall mean this “Client Agreement” together with its Appendix 1
and any other Appendices added thereto and the “Conflicts of Interest
Policy”, “Summary Best Interest and Order Execution Policy” and “Risk
Disclosure and Warnings Notice”, as amended from time to time.
“Applicable Regulations” shall mean (a) IFSC Rules or any other rules of a
relevant regulatory authority having powers over the Company; (b) the Rulesof the relevant Market; and (c) all other applicable laws, rules and regulationsof Belize.
“Ask” shall mean the higher price in a Quote at which the price the Client may
buy.
“Authorised Representative” shall mean the person of paragraph 36.1. of the
Client Agreement.
“Balance” shall mean the total financial result in the Client Account after thelast Completed Transaction and depositing/withdrawal operation at any
period of time.
“Base Currency” shall mean the first currency in the Currency Pair against which
the Client buys or sells the Quote Currency.
“Bid” shall mean the lower price in a Quote at which the Client may sell.
“Business Day” shall mean any day, other than a Saturday or a Sunday, or
the 25th of December, or the 1st of January or any other Belize orinternational holidays to be announced on the Company’s Website.
“Client Account” shall mean the unique personalised account of the Clientconsisting of all Completed Transactions, Open Positions and Orders in the
Platform, the Balance of the Client money and deposit/withdrawal
transactions of the Client money. Our Website and communication may use
the term trading account or account, which mean Client Account.
“Closed Position” shall mean the opposite of an Open Position.

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Terms and Conditions – Client Agreement

Xtrade International LTD“Completed Transaction” in a CFD shall mean two counter deals of the same
size (opening a position and closing a position): buy then sell and vice versa.
“Contract for Differences” (“CFD”) shall mean a contract, which is a contractfor differences by reference to variations in the price of an Underlying Asset.
A CFD is a Financial Instrument under the Law.
“Contract Specifications” shall mean the principal trading terms in CFDS (forexample Spread, Premiums, Lot Size, Initial Margin, Necessary Margin,
Hedged Margin, the minimum level for placing Stop Loss, Take Profit andLimit Orders, financing charges, charges etc) for each type of CFD as
determined by the Company from time to time and found on our Website
and/or Platform.
“Currency of the Client Account” shall mean the currency that the Client Accountis denominated in.
“Currency Pair” shall mean the object or Underlying Asset of a CFD Transaction
based on the change in the value of one currency against the other. A Currency
Pair consists of two currencies (the Quote Currency and the Base Currency)
and shows how much of the Quote currency is needed to purchase one unit of
the Base Currency“IFSC Rules” shall mean the Rules, Directives, Regulations, Guidance notes,
opinions or recommendations of IFSC.
“Equity” shall mean the Balance plus or minus any Floating Profit or Loss thatderives from an Open Position and shall be calculated as: Equity = Balance +Floating Profit - Floating Loss.
“Essential Details” shall mean the required details in order for the Company tobe able to place the Order for example but not limited to Opening
Position/Closing Position/Cancelling/Amending, the Underlying Asset,
style/name of the Order, volume, market direction, price, validity, Stop
Loss/Take Profit (if desired).
“Event of Default” shall have the meaning given in paragraph 14.1. of the
Client Agreement.
“Expert Advisor” shall mean a mechanical online trading system designed toautomate trading activities on an electronic trading platform such as theCompany’s Platform. It can be programmed to alert the Client of a trading
opportunity and can also trade his Client Account automatically managing all
aspects of trading operations from sending orders directly to the Platform toautomatically adjusting stop loss, trailing stops and take profit levels.

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Terms and Conditions – Client Agreement

Xtrade International LTD“Financial Instrument” shall mean the Financial Instruments under theCompany’s IF license which can be found on our Website.
“Floating Profit/Loss” in a CFD shall mean current profit/loss on Open Positions
calculated at the current Quotes (added any commissions or fees if applicable).
“Force Majeure Event” shall have the meaning as set out in paragraph 27.1.
of the Client Agreement.
“Free Margin” shall mean the amount of funds available in the Client Account,which may be used to open a position or maintain an Open Position. Free
Margin shall be calculated as: Equity less (minus) Necessary Margin [Freemargin = Equity- Necessary Margin].
“Hedged Margin” for CFD trading shall mean the necessary margin requiredby the Company so as to open and maintain Matched Positions.
“Initial Margin” for CFD trading shall mean the necessary margin required by theCompany so as to open a position.
“Introducer” shall have the meaning as set put in paragraph 35.1. of the Client
Agreement.
“Investment Services” shall mean the Investment Services under theCompany’s IF license which can be found on our Website“Leverage” for CFD trading shall mean a ratio in respect of Transaction Sizeand Initial Margin. 1:100 ratio means that in order to open a position, the Initial
Margin is one hundred times less than the Transactions Size.
“Long Position” for CFD trading shall mean a buy position that appreciates invalue if underlying market prices increase. For example, in respect of Currency
Pairs: buying the Base Currency against the Quote Currency.
“Lot” shall mean a unit measuring the Transaction amount specified for each
Underlying Asset of a CFD.
“Lot Size” shall mean the number Underlying Assets in one Lot in a CFD.
“Margin” shall mean the necessary guarantee funds so as to open or maintain
Open Positions in a CFD Transaction.
“Margin Call” shall mean the situation when the Company informs the Client todeposit additional Margin when the Client does not have enough Margin to open
or maintain open positions.

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Terms and Conditions – Client Agreement

Xtrade International LTD“Маrgin Level” for CFD trading shall mean the percentage of Equity to
Necessary Margin ratio. It is calculated as: Margin Level = (Equity / Necessary
Margin) x 100%.
“Margin Trading” for CFD trading shall mean Leverage trading when the Client
may make Transactions having less funds on the Client Account in comparison
with the Transaction Size.
“Matched Positions” for CFD trading shall mean Long and Short Positions of thesame Transaction Size opened on the Client Account for the same CFD.
“Necessary Margin” for CFD trading shall mean the necessary margin requiredby the Company so as to maintain Open Positions.
“Normal Market Size” for CFD trading shall mean the maximum number of unitsof the Underlying Asset that are transmitted by the Company for execution.
“Open Position” shall mean any open contract (call and / or put) which has notbeen closed. In relation to CFD trading this may be a Long Position or a Short
Position which is not a Completed Transaction.
“Order” shall mean an instruction from the Client to trade in CFDs.
“Parties” shall mean the parties to this Client Agreement – i.e. the Company andthe Client.
“Pip Hunting” shall mean the situation when the Client opens a position andcloses it in a very short time (once there is a profit of one pip).
“Platform” shall mean the electronic mechanism operated and maintained by
the Company consisting of a trading platform, computer devices, software,
databases, telecommunication hardware, programs and technical facilities,
which facilitates trading activity of the Client in Financial Instruments via the
Client Account. It is understood that the Company may use different Platforms
depending on the Financial Instrument.
“Politically Exposed Persons” shall mean:A)natural persons who are or have been entrusted with prominent public
functions, which means: heads of State, heads of government, ministers anddeputy or assistant ministers; members of parliaments; members of supreme
courts, of constitutional courts or of other high-level judicial bodies whose
decisions are not subject to further appeal, except in exceptional circumstances;members of courts of auditors or of the boards of central banks; ambassadors,
chargés d’affaires and high-ranking officers in the armed forces; members of
the administrative, management or supervisory bodies of State-owned
enterprises. None of the categories set out in the above shall be understood ascovering middle ranking or more junior officials. Further, where a person has

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Terms and Conditions – Client Agreement

Xtrade International LTD

ceased to be entrusted with a prominent public function within the meaning of
the above definition for a period of at least one year in any country, such persons
shall not be considered a Politically Exposed Person.
B)
The immediate family members of such persons as set out under
definition A, which means: the spouse; any partner considered by national law
as equivalent to the spouse; the children and their spouses or partners; and theparents.
C)
Persons known to be close associates of such persons as set out under
definition A, which means: any natural person who is known to have joint
beneficial ownership of legal entities or legal arrangements, or any other closebusiness relations, with a person referred to in definition A; any natural person
who has sole beneficial ownership of a legal entity or legal arrangement which
is known to have been set up for the benefit de facto of the person referred toin definition A.
“Professional Client” shall mean a “Professional Client” for the purposes of IFSC
Rules.
“Order Level” for CFD trading shall mean the price indicated in the Order.
“Quote” shall mean the information of the current price for a specific Underlying
Asset, in the form of the Bid and Ask prices.
“Quote Currency” shall mean the second currency in the Currency Pair which
can be bought or sold by the Client for the Base Currency.
“Quotes Base” in relation to CFD trading shall mean Quotes Flow information
stored on the Server.
“Quotes Flow” shall mean the stream of Quotes in the Platform for each CFD.
“Retail Client” shall mean a “Retail Client” for the purposes of the IFSC Rules.
“Scalping” shall mean the situation where the Client opens too many positions
at the same time and closes them in a very short time (for example up to threeminutes) or buying at Bid price and selling at Ask price, so as to gain the Bid/Ask
difference.
“Services” shall mean the services to be offered by the Company to the Client
under this Agreement, as set out in paragraph 10.1. of the Client Agreement.
“Short Position” for CFD trading shall mean a sell position that appreciates invalue if underlying market prices fall. For example, in respect of Currency Pairs:
selling the Base Currency against the Quote Currency. Short Position is the
opposite of a Long Position.
“Slippage” shall mean the difference between the expected price of aTransaction in a CFD, and the price the Transaction is actually executed at. At

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the time that an Order is presented for execution, the specific price requestedby the Client may not be available; therefore, the Order will be executed close
to or a number of pips away from the Client’s requested price. If the execution
price is better than the price requested by the Client, this is referred to as
positive slippage. If the executed price is worse than the price requested by the
Client, this is referred to as negative slippage. Slippage often occurs during
periods of higher volatility (for example due to due to news events) making an
Order at a specific price impossible to execute, when market orders are used,
and also when large Orders are executed when there may not be enoughinterest at the desired price level to maintain the expected price of trade.
“Spread” for CFD trading shall mean the difference between Ask and Bid of an
Underlying Asset in a CFD at that same moment.
“Premium or Rollover” for CFD trading shall mean the interest added or
deducted for holding a position open overnight.
“Premium Free Client Account” is a type of Client Account available for CFD
trading and shall have the meaning set out in paragraph 10 of Appendix 1.
“Trailing Stop” in CFD trading shall mean a stop-loss order set at a percentage
level below the market price - for a long position. The trailing stop price isadjusted as the price fluctuates. A sell trailing stop order sets the stop price ata fixed amount below the market price with an attached "trailing" amount. As
the market price rises, the stop price rises by the trail amount, but if the pairprice falls, the stop loss price doesn't change, and a market order is submitted
when the stop price is hit.
“Transaction” shall mean transaction of the Client in a CFD.
“Transaction Size” for CFD trading shall mean Lot Size multiplied by number of
Lots.
“Underlying Asset” shall mean the object or underlying asset in a CFD may be
Currency Pairs, Forwards, Futures, Options, Metals, Equity Indices,
Commodities, Shares or as determined by the Company from time to time andmade available on its on the Platform or the Website.
“Underlying Market” shall mean the relevant market where the Underlying Assetof a CFD is traded.
“Website” shall mean the Company’s website at www.xtrade.com such otherwebsite as the Company may maintain from time to time.
“Written Notice” shall have the meaning set out in paragraph 23.4. of the
Client Agreement.
40.2. Words importing the singular shall import the plural and vice versa. Words
importing the masculine shall import the feminine and vice versa. Words

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denoting persons include corporations, partnerships, other unincorporated
bodies and all other legal entities and vice versa.
40.3. Paragraph headings are for ease of reference only.
40.4. Any reference to any act or regulation or Law shall be that act or regulationor Law as amended, modified, supplemented, consolidated, re-enacted or
replaced from time to time, all guidance noted, directives, statutory instruments,
regulations or orders made pursuant to such and any statutory provision ofwhich that statutory provision is a re-enactment, replacement or modification.
APPENDIX ONE - CFD TRADING TERMS
1. Scope
1.1. This Appendix is applicable only to those Clients trading in the Financial
Instruments of CFDs.
2. Types of CFD Orders
2.1. The following CFD Orders may be placed with the Company: market orders
and pending orders.
3. Execution of Orders
3.1. In order to open a position on the Platform, the Client must either open a
Buy or a Sell, at the price quoted on the Platform at the time of such Transaction.
In order to close a position, the Client must either offer to Sell (in the case of aBuy), or purchase (in the case of a Sell), the Underlying Asset covered by such
Open Position, at the price quoted on the Platform at the time of such closing.
It is understood that every time the Client places an Order, the Company
executes such an Order itself as a counterparty.
However, the Company has the right to hedge Client Orders with another third
party.
3.2. The Platform provides a Buy quote and a Sell quote for each Underlying
Asset traded on the Platform. The Client acknowledges that upon opening a
Buy or closing a Sell (or vice versa), he may only do so at the price quoted on
the Platform to purchase such Underlying Asset.
3.3. Orders can be placed and (if allowed) changed within the Trading Hours foreach type of Underlying Asset appearing on the Platform and/or the Website,
as amended from the Company from time to time
3.4. On the Platform, the Client shall be entitled to make an offer to open a
Position at the best available price on the Platform (“Market Order”) at the timeof opening such a position, unless the Client specifies a particular price in which

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to make an offer to open a position (“Limit Order”). With respect to a Market
Order, the price at which a Transaction is completed may not always be at theexact rate displayed when the Order is placed. The Client agree that his offer toopen a Market Order may be accepted at a lower price or higher price than theprice indicated by him in his Market Order, within a certain range as specified
on the Platform from time to time. If the Client chooses to open a Market Order,
his offer will be accepted at the best possible price offered on the Platform.
3.5. With respect to a Limit Order, the price at which a Transaction is completed
may not always be at the exact price displayed when the Order is placed. The
Client agrees that his offer to open a Limit Order may be accepted at a lower
price if a Buy, or higher price if a Sell, than the price indicated by him in his Limit
Order as specified on the Platform from time to time. If the Client offers to open
a Limit Order, his offer may be accepted at the price indicated by him in his
offer. At any time prior to acceptance of a Limit Order, the Client may cancel the
Limit Order without any further liability. If the Client open a Limit Order, his offer
will be accepted at the best possible price offered on the Platform.
3.6. The Client agrees that the Company may hedge or otherwise offset any
Transaction with other third parties in order to offset any liability or risk
associated with any of the Client’s Transaction(s). In the event that theCompany is unable to hedge the Client’s Transactions with other third parties,
the Company reserves the right to amend the content or terms of a CFD Order
including the expiry date, the trading hours or any other parameters in the
instrument details tab.
3.7. Pending Orders, not executed, shall remain effective through the next
trading session (as applicable).
3.8. Market Orders not executed because there is not enough volume to fill
them, will not remain effective and will be cancelled.
3.9. All open spot positions will be rolled over to the next Business Day at theclose of business in the relevant Underlying Market, subject to the Company’s
rights to close the open spot position. Any open forward positions will be rolled
over at the expiry of the relevant period into the next relevant period subject to
the Company’s rights to close the open forward position.
3.10. Orders shall be valid in accordance with the type and time of the given
Order, as specified by the Client. If the time of validity of the Order is not
specified, it shall be valid for an indefinite period. However, the Company may
delete one or all Pending Orders if the Client Account Equity reaches zero.
3.11. The Orders cannot be removed once placed. Pending Orders may bedeleted or modified before they are executed.
3.12. The Client may change the expiration date of Pending Orders before it isexecuted by cancelling it and placing a new Order.

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number 000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

3.13. Stop loss and Take Profit orders may be changed as long as they arehigher in distance than a specific level (depending on the trading symbol).
3.14. For an open CFD position that the Client holds in relation to a particular
Underlying Asset and then subsequently closes partially, this position will beclosed on First in, First out basis (commonly known as FIFO) in relation to themultiple trades undertaken to build the particular position.
3.15. The Company is under no obligation, unless otherwise agreed in theAgreement, to monitor or advise the Client on the status of any Transaction or
to close out any Client’s Open Positions. When the Company decides to do so,
this will be done on a discretionary basis and will not be considered anundertaking of an obligation to continue. It is the Client’s responsibility to beaware of his positions at all times.
4. Quotes
4.1. In the event that the Company is unable to proceed with an Order, withregard to price or size or other reason, depending in the type of the Client
Account, the Company will send a re-quote. The number of re-quotes appearson the Platform.
4.2. The Quotes appearing on the Client’s terminal are indicative and are basedon the relevant Underlying Markets. However, if there is high volatility in the
Underlying Market the execution of the Order may change and the Client may
obtain the first price that will be available in the market and not the market herequested.
4.3. The Company provides Quotes by taking into account the Underlying Assetprice, but this does not mean that these Quotes are within any specificpercentage of the Underlying Asset price. When the relevant Underlying Market
is closed, the Quotes provided by the Company will reflect what the Company
thinks to be the current Bid and Ask price of the relevant Underlying
Asset at that time. The Client acknowledges that such Quotes will be set by
the Company at its absolute discretion.
5. Stop Loss Orders, Trailing Stop and Expert Advisor
5.1. The Client agrees that trading operations using additional functions of the
Client Trading Terminal such as Trailing Stop and/or Expert Advisor are
executed completely under the Client’s responsibility, as they depend directly
on his trading terminal and the Company bears no responsibility whatsoever.
5.2. The Client agrees that placing a Stop Loss Order will not necessarily limit
losses to the intended amounts, because market conditions may make it

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

impossible to execute such an Order at the stipulated price and the Company
bears no responsibility whatsoever.
5.3. The Client may add “Close at Loss” price or “Close at Profit” at any stage
when the position is Open.
5.4. Upon the Client placing a limit Order, the Client authorizes the Company toclose the Transaction at the Close at Loss price or Close at Profit price, asapplicable, and as agreed in the Order, without further instruction from or
notification to the Client. The Company may close the Transaction when theprice quoted by the Company on the Trading Platform equals or exceeds theprice accepted by it for such an Order.
5.5. The Client acknowledges that the original price level set forth in a Close at
Loss may be amended as the market on the Platform moves in his favour. Whilst
his trailing Close at Loss is still in effect, the Client agrees that each change inthe market by at least one hundredth of a percentage point (referred to as "Pips"on the Platform) in his favour shall constitute a new offer by the Client to raise
the level of his trailing “Close at Loss” by one hundredth of one percentage
point. Changes in a Pip will be rounded to the nearest absolute value in the
Currency of the Client Account.
5.6. The Client acknowledges and agrees that due to market volatility andfactors beyond the Company’s control, the Company cannot guarantee that an
Order will be executed at the level specified in the Client Order, for example, an
Order may be closed at a worse price than as originally specified by the Clientin such an Order. In such an event, the Company will close the Transaction at
the next best price. For example, with respect to a Close at Loss, in the case ofa Buy to close, the price of an Underlying Asset may suddenly increase above
the Close at Loss price, without ever reaching such price. In the case of a Sell
to close, the price of an Underlying Asset may suddenly decrease below the
Close at Loss price, without ever reaching such price.
5.7. With respect to a Close at Profit where the price for an Underlying Assetmoves to the Client’s advantage (for example, if the price goes down as the
Client Buys or the price goes up as the Client Sells), the Client agrees that theCompany can pass such price improvement on to the Client.
5.8. Guaranteed Stop Orders are only available on certain Underlying Assets,
as indicated in the instrument details tab. If the Client places a Guaranteed Stopon a new Order the Company guarantees that when its bid or offer quoted pricereaches or goes beyond the close at loss price specified by the Client, it willclose the position at exactly the price the Client specified in the Guarantee Stop
Order. An open position can be closed in accordance with this Agreement prior
to reaching the Guaranteed Stop Order price level.
5.9. A Guaranteed Stop Order is subject to the following additional conditions:

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD(a)
A Guaranteed Stop Order can be requested only on a new Order andis only available on close at loss conditions;(b)
A Guaranteed Stop Order can be activated or edited only when there is
trading and an eligible Underlying Asset is available on the Platform;(c)Once a Guaranteed Stop Order is accepted by us it cannot be removed- only the price can be changed;(d)A Guaranteed Stop Order must be placed a minimum distance (asdetermined by the Company) away from the current Underlying Asset pricebeing quoted by the Company;(e)
As the Company guarantees to close out price, the spread is adjusted
for the additional charge when placing the Guaranteed Stop Order. The
adjusted spread is displayed in the Underlying Asset details tab for each eligible
Instrument at the time the Guaranteed Stop Order is placed.
6. Expiry
6.1. The Company may set an Expiry Date and time for a specific Underlying
Asset. Such shall be displayed on the Platform. The Client agrees that it his
responsibility to check for the Expiry Date and time.
6.2. If the Client does not close an open Position with respect to an Underlying
Asset which has an Expiry Date, prior to such Expiry Date, the Open Position
shall automatically close upon the Expiry Date. The Open Position shall close
at a price which will be the last price quoted on the Platform immediately prior
to the applicable Expiry Date and time.
6.3. The Client acknowledges that certain Underlying Markets may become
volatile or illiquid without warning. In such circumstances it may not be possible
to execute Client Orders, particularly in the period shortly before an expiry.
7. Premiums
7.1. Any Open Position at the end of the trading day or over the weekend, shall
automatically be rolled over to the next business day to avoid an automatic closeand settlement of the Transaction. The Client acknowledges
that when rolling such Transactions to the next business day, a Premium will
be either added or subtracted from his Client Account with respect to such
Open Position. Information concerning the Premium for each Underlying
Asset is displayed on the Platform. In deciding whether to open a position,
the Client acknowledges that he is aware of the Premium.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

7.2. The premium is charged daily on the Client Account. The operation isconducted at 23.59 (server time) and can take several minutes.
7.3. The Client authorises the Company to add or subtract the premium feesto or from the Client Account for any open Transactions that have accruedsuch a fee, in accordance with the applicable rate thereto, each day at thetime of collection specified on the Platform for each Underlying Asset, asapplicable.

7.4. The Company has the right to amend in its discretion from time-to-time
the calculation days or percentages of Premiums. Such changes shall beeffected on the Platform and/or the Website and the Client is responsible tocheck for updates regularly.
8. Spreads
8.1. All CFDs available with the Company have spreads which appear on
the Platform and/or the Website. The Company has the right to amend its
spreads in its discretion from time to time. Such changes shall be effectedon the Platform and/or the Website and the Client is responsible to check for
updates regularly.
9. Margin Requirements
9.1. The Client shall provide and maintain the Initial Margin and/or Hedged
Margin in such limits as the Company, at its sole discretion, may determine
at any time under the Contract Specifications for each type of CFD.
9.2. It is the Client’s responsibility to ensure that he understands how Margin
requirements are calculated.
9.3. Unless a Force Majeure Event has occurred, the Company has the rightto change the Margin requirements, giving to the Client ten (5) Business
Days Written Notice prior to these amendments for open positions. For new
positions the Company may amend the Margin Requirements with one
Business Day Written Notice. All changes shall be effected on the Platform
and/or the Website and the Client is responsible to check for dates.
9.4. The Company has the right to change Margin requirements without priornotice to the Client in the case of Force Majeure Event. In this situation the
Company has the right to apply new Margin requirements to the newpositions and to the positions which are already open.
9.5. Without prejudice to paragraph 13.1. of the Client Agreement, theCompany has the right to close and or limit the size of Client open positions(New or Gross) and to refuse Client orders to establish new positions in anyof the following cases:

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD(a)
The value of Client collateral falls below the minimum margin
requirement.
(b)
At any time equity (current balance including open positions) isequal to or less than a specified percentage of the margin (collateral)needed to keep the open position.
(c)
The Company makes a Margin Call and the Client fails to meetit.
9.6. The Company shall make Margin Calls to the Client automatically via
the Platform when the Margin in his Client Account has reached a certain
percentage. When the Platform warns the Client that it reached a certain
percentage of the Margin in the Client Account, the Client should take any
or any of the three options to deal with the situation:(a)Limit his exposure (close trades); or(b)
Hedge his positions (open counter positions to the ones he has
right now) while re-evaluating the situation; or(c)
Deposit more money in his Client Account.
9.7.
If the Client fails to take action according to paragraph 9.6 or when
the Client reaches 15% of the Margin in the Client Account, his positions will
start closing automatically (Stop Out level of 15%) starting with the mostlosing Order and the Company has the right to refuse a new Orders.
9.8.
Margin shall be paid in monetary funds in the Currency of the Client
Account. Should the client deposit money in a different currency theCompany shall make a conversion into the Currency of the Client Accountaccording to paragraph 38 of the Client Agreement.
9.9.
The Client undertakes neither to create nor to have outstanding any
security interest whatsoever over, nor to agree to assign or transfer, any of
the Margin transferred to the Company.
9.10. If the Client has more one Client Account with the Company, any
credit in one Client Account (including amounts deposited as Margin) will notdischarge the Client liabilities in respect of any other Client Account, unlessa termination tales place. It is the Client’s responsibility to ensure therequired level of Margin exists for each Client Account separately.
10. Deal Protection Feature
By enabling the feature “Deal Protection”, the client agrees to the following
conditions which are applicable upon clicking the SELL or BUY button.
10.1 The fee paid for the Deal protection feature is non-refundable.
10.2 Premium fee cannot be more than the available balance.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

10.3 The premium fee paid only covers the duration specified when the deal
was opened and cannot be extended.
10.4 The premium fee calculation is based on the realised volatility of theselected product.
10.5 Deal protection cover cannot be renewed and/or amended once it isexpired or exercised.
10.6 The client must choose one of the following trade time (hereinafterreferred to as "expiry time"):
a.
b.
c.

1 hour3 hours
6 hours

10.7 The above mentioned three different expiry times will vary on theircharges.
10.8 The Deal protection choices may vary based on instrument selected.
10.9 A deal covered with Deal protection can be closed at any time before
the expiration time.
10.10 A deal will end at one of the following occasions and/or events, except
if any unauthorized activity is observed:
a)
b)
c)
d)

"Closing Deal" initiated by the client;
Margin Call.
Stop loss
Take Profit

10.11A deal will be cancelled if closed for any reason, at a negative P&L while
it is covered by Deal protection feature. This includes if the deal is closed bya Stop Loss.
10.12If a deal is charged a rolling fee, this fee will not be refunded if the dealis cancelled with Deal protection.
10.13Deal protection can only be used from the Xtrade trading platform.
10.14Deal protection can only be purchased at the time the deal is opened.
10.15Deal protection and/or cancellation cover cannot be transferred to otherdeals and/or to other accounts.
10.16When a deal is closed before the expiration of Deal protection, thesystem shall refund 100% from the loss of the specific deal and this amountwill be added to the balance of the account.
10.17Deal protection is available for demo trading and live trading.
10.18The Company retains the right to disable the feature at its discretion at
any time without prior notice.
At any time, without prejudice to the Company’s right, the Company retains theright to amend these terms and conditions.
1. Premium Free Client Accounts

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20

Terms and Conditions – Client Agreement

Xtrade International LTD

11.1 The Company may from time to time offer Premium Free Client Accountfor CFD trading, subject to the Company’s internal requirements being
fulfilled.
11.2 Should the Client wish to change from a normal Client Account into a
Premium Free Client Account must close all their Open Positions first
11.3 The rest of the provisions herein in this entire Agreement shall also apply
to Premium Free Client Accounts save any mentions to Premiums.
11.4 If the Client has a Premium Free Client Account, no Premiums or rollover charges will be applied to trading positions overnight. Any charges
applicable to Premium Free Client Accounts appear in the Contract
Specifications found on the Platform and/or the Website.
11.5 The Client who has a Premium Free Client Account may not hold his
floating positions for a long period of time. In such an event, the Client mustclose the floating positions and Premiums will be applied retroactively.
11.6 Hedging a position by its corresponding CFD contract in a PremiumFree Account is forbidden. In such an event, the Client must close thehedges immediately and Premiums will be applied retroactively.
11.7 All the Open Position in a Premium Free Account will be closed on
Friday an hour before the market is closed and may be opened again by
the Client.

Xtrade International Ltd is authorized and regulated by the Financial Services Commission with license
number 000281/20