OANDA GLOBAL MARKETS LIMITED
Retail Clients Terms of BusinessThis Terms of Business effective from 24th April 2022
For the terms immediately prior to this date click here - https://pages.oanda.com/2021-ogm-terms
This document is important. It sets out the terms and conditions on which we will conduct business withyou, including limits on our liability to you in paragraph 24. Please read this document carefully. You
should contact us if anything is unclear. Defined terms are set forth in Annex I.
1.

INTRODUCTION

1.1 This agreement sets out the legally binding terms and conditions between you and us, OANDA Global
Markets Limited, which apply when you use our services. This agreement replaces any previous termsof business between you and us.
1.2 OANDA Global Markets Limited provides online trading platforms (including its own and third party platforms,
such as MT4 and MT5), which allow you to trade investment products known as contracts for difference(our "Products" or "CFDs"). We allow you to trade our Products in various underlying Instruments,
including foreign exchange, indices, commodities, equities, shares, metals, bonds andcryptocurrencies, and other Instruments from time to time which may be displayed on our Trading
Platform. Trading Platform is defined in Annex 1, and different products may be traded on different
platforms (and which may from time to time be governed by a supplemental agreement). The technicaloperation of our Products, including but not limited to cryptocurrencies, are available on our Website.
The full extent of the services we provide and the risks involved are set out below.
1.3 Trading our Products is high risk and can result in losses that exceed the total sum you have invested. All
negative balances are payable.
1.4 By registering to use our Trading Platforms or Software, you agree to the terms and conditions in thisagreement, our Privacy Policy and Terms of Use. We refer to these documents collectively as the"Agreement". You should read the Agreement carefully before using our services. A copy of theAgreement, and other relevant documents relating to our services, are available from your online
Account and may be found on our Website.
1.5 OANDA Global Markets Limited is authorised and regulated by the British Virgin Island (BVI) Financial
Services Commission (FSC). You can contact the FSC in the following ways:
Telephone+1 (284) 494-1324+1 (284) 494-4190+1 (284) 347-4001

Websitewww.bvifsc.vg

Post

18 Pasea Estate Road
Road Town, TORTOLA, VG1110
BRITISH VIRGIN ISLANDS

1.6 When we refer to "you" and "your" in this Agreement, we mean a registered user of our Trading Platform,
as well as any Authorised Person authorised to operate your Account.
1.7 Certain words or phrases that are capitalised in this Agreement have a specific meaning. Annex 1 explains
the meaning of these words or phrases. You should refer to these definitions as you read thisAgreement.

2.

WHO WE ARE AND HOW YOU CAN CONTACT US

2.1 OANDA Global Markets Limited is a private limited company registered in the British Virgin Islands (company
registration number 2026433). Our registered address is: MCS BVI,
Kingston Chambers, PO Box 173, Road Town, Tortola, British Virgin Islands. We refer to OANDA
Global Markets Limited in this Agreement as "OANDA", "We", "Our" and "Us".
2.2 You can contact us in the following ways:
Telephone+ 1 855 257 7413
Our telephone lines are open during regular business hours on Business Days.

3.

Email

frontdesk@oanda.com

Post

OANDA Global Markets Limited
MCS BVI, Kingston Chambers
PO Box 173
Road Town, Tortola, British Virgin Islands

COMMUNICATING WITH YOU

3.1 We may communicate with you by telephone, letter, email, text message, social media messaging
applications or by posting a message on the Trading Platform. We will use the contact details you gave
us when you opened your Account or such other contact details as you may subsequently notify to us.
3.2 We will send all notices and statements relating to your Account to you by email and/or by posting them on
the Trading Platform, unless you request otherwise and we agree to such request.
3.3 You agree that all Transactions will be entered into electronically and that such Transactions will be bindingon you in accordance with this Agreement.

4.

THE SERVICES WE PROVIDE

4.1 We provide you with the ability to trade our Products through our Trading Platform.
4.2 We allow you to trade using leverage, which can magnify your profits but also your losses. You can find out
more about the risks associated with trading on leverage in paragraph 6, and on our Website.
4.3 We will act as either principal or your agent when entering into Transactions. This means you are either
entering into contracts directly with us to buy and sell financial instruments or we are entering into
contracts with another person on your behalf.
4.4 You will enter into all Transactions with us on an execution only basis. An "execution only basis" means
you will be solely responsible for all investment decisions and actions on your Account. You must
therefore rely on your own judgment in respect of all dealings relating to your Account. This includes,
but is not limited to, opening, closing, or not opening or closing, a Transaction.
4.5 When you enter into a Transaction with us, you are trading a derivative contract. A derivative is a contract
which derives its price from an underlying asset. This underlying asset could (for example) be a sharein a company, a commodity such as gold or the change in the exchange rate of currencies. You are
therefore trading on potential price movementsin the underlying asset. However, you will not have any interest in, or be entitled to, delivery of theunderlying asset and, with respect to share CFDs, you will have no voting right, title or interest in any
underlying asset or entitlement or right to acquire, receive, hold, vote, deliver, dispose of or participate
directly in any corporate action of any underlying asset.
4.6 It is your responsibility to ensure that you are aware of all the rules governing a particular Transaction before
you open it. In this regard, you should ensure that you familiarise yourself with the information on our2Website, and the information that is disclosed about the instrument that you wish to trade on the trading
platform immediately prior to providing your trading instructions.
4.7 In the event of a conflict between the terms of this Agreement and any other document, the terms in thisAgreement shall prevail.

5.

WE DO NOT PROVIDE ADVICE AND ARE NOT AN INVESTMENT EXCHANGE

5.1 We will not make personal recommendations to you or give you any advice or recommendations including,for the avoidance of doubt, any tax related advice. Therefore, any information or explanation we may
provide as to the terms of a Transaction or its performance characteristics will not amount to advice.
5.2 It is your responsibility to evaluate each Transaction and ensure that it meets your requirements andinvestment preferences.
5.3 Our Trading Platform is not an Exchange or a market. This means you can only enter into Transactions withus on the Trading Platform and all Transactions opened on our Trading Platform must be closed on our
Trading Platform, and cannot be closed with any other entity. Accordingly, we are responsible for the
prices quoted on the Trading Platform.

6.

WHAT ARE THE KEY RISKS OF USING OUR SERVICES?

6.1

Trading our Products carries a higher degree of risk than ordinary share or foreign exchange dealing
and will not be appropriate for everyone.

6.2

Trading using leverage can result in losses. Trading with leverage magnifies your gains and losses,
and so small price changes in the underlying asset can result in large losses or gains.

6.3

Leverage is a form of borrowing. Trading using leverage allows you to trade without paying ordepositing the full value of your Position in advance. We take a form of security (or deposit) against
any losses you may incur when you trade using leverage. This is known as Margin (see paragraph 9).

6.4

We set the prescribed limits on the amount of leverage that a client may be exposed to on our Products.
The leverage levels available to clients are available on our Website.

6.5

We set leverage levels and thereby the amount of Margin required to both open and maintain Positions,and can make alterations for any reason. There may be occasions where it is not possible to provide
you with any advance notice due to underlying market conditions.

6.6

The value of your investments may go up or down.

6.7

Past performance is not a guide to future performance.

6.8

We may perform a Margin Closeout if the markets move against you, and/or to comply with Applicable
Law, as detailed further in paragraph 9. A Margin Closeout will result in us closing some or all of yourOpen Positions. This would realise any losses or gains on your Open Positions. We do not need togive you advance notice or time to respond to a Margin Closeout. This is detailed further in paragraph
9 below. We may also close any or all of your Open Positions if you exceed the limits applicable toyour Account, including any trading account. This is detailed further in paragraph 10.11 below.

6.9

Trading our Products does not give you any right to the underlying Instrument of the Transaction. Our
Products represent a notional value only.

6.10

The spread we offer is not fixed. This means the prices and spreads we offer may vary at any time.
Our spreads are discussed in more detail in paragraph 10 below.

6.11

You should ensure you fully understand the risks involved before using our services and takeappropriate investment, financial, legal, tax and other necessary professional, independent advice.

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6.12

7.

You will be responsible for the payment of all negative balances.

CONFLICTS OF INTEREST

7.1 We are required to act in your best interests when providing our services, but there may be instances where
your interests conflict with ours or those of another customer of ours. For example, we or people
connected to us (such as our group companies):(a)may enter into Transactions with you in which we or people connected to us have a materialinterest;(b)

may execute hedging Transactions before or after entering into a Transaction with you tomanage our risk in relation to the Transaction, which may impact the price you pay or receive
for such Transaction, and we will retain any profits generated by such hedging; and(c)may enter into arrangements with third parties to or from whom we make or receive payments
based on your trading activity.

7.2

Further, you trade against us (and no third parties) and we are responsible for setting the underlying
prices. This could give rise to conflicts which we manage through our internal controls and policies.

7.3

We are not under any obligation to account to you for any profit, commission or remuneration we
receive from such activities, other than as and if required by Applicable Law.

7.4

We will not disclose any conflict of interest to you provided we have managed such conflicts. If wecannot manage the conflict sufficiently, we will notify you of the conflict and the steps we have taken
to mitigate the risk arising from such conflict so you can decide how to proceed.

7.5

You consent to us dealing with you despite your awareness of these possible conflicts.

8.

OPENING AN ACCOUNT

8.1 If we open an Account for you, it will initially comprise of a landing account (also known as a wallet) and a
trading account which will automatically be created when you make your first deposit.
8.2 You may then:(a)open multiple landing accounts (on which trades cannot be placed) denominated in different
currencies, only one per available currency, that you wish to deposit or withdraw funds in; and(b)

open multiple trading accounts, denominated in different or the same currencies, or perhaps
linked to different technologies offered through our Trading Platform. We may limit the types
and number of trading accounts that you can open at our discretion.

8.3

Your Account comprises of all your landing accounts and trading accounts.

8.4

You are only permitted to have one Account relationship with us. If we reasonably suspect you havemore than one Account relationship, including by having multiple Connected Accounts, then we may
close one of those Accounts and their associated landing and trading accounts without notice.

8.5

Additionally, funds may be deposited direct to a trading account, however, withdrawals can only bemade from a landing account to ensure that they are unencumbered funds.

8.6

We will treat each trading account separately so your Positions will not be netted across all your trading
accounts; except for purposes of imposing and monitoring the limits set forth in paragraph 10.11,
below.

8.7

We retain a right of set off between balances held on landing and trading accounts, in the event of anegative balance on one or more trading account.
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8.8

You need to provide us with certain information about yourself before we can open an Account for you.
This will include details of your personal and financial circumstances. We refer to this information as"Registration Data".

8.9

The Registration Data you provide to us must be complete, accurate and not misleading. We will relyon the Registration Data you provide to us unless we are aware that such information is manifestly outof date, inaccurate, misleading or incomplete.

8.10

You must notify us of any material changes to the Registration Data. We may ask you to update orconfirm the Registration Data you previously provided to us from time to time. We may terminate thisAgreement or suspend your Account if you fail to provide such information to us or if we believe thatsuch information is not accurate. We will only take such steps if it is reasonable to do so.

8.11

From time to time, we may add to, modify or remove certain Account or landing or trading accounttypes or the functionally of such accounts. This may result in changes to your Account, and/or landing
accounts and/or trading accounts. We will try to minimise disruption to you if we do this. We will give
you prior written notice where we believe our actions may result in detriment to you.

8.12

We may carry out credit and other checks (including but not limited to verification of identity, fraud
prevention checks and checks into your current and past investment activities) from time to time as wedeem appropriate. Your Registration Data or other information may be used in the prevention of money
laundering as well as for the management of your Account. You authorise us to use your Registration
Data and other information in this way. We will use your data in accordance with our Privacy Policy,
which is available on our Website, and outlined in paragraph 28.

8.13

In electronically submitting the Account application form you are authorising us to make such searches
as we see fit to certify that the information that you have supplied is complete and accurate. Suchsearches will include, but may not be restricted to, information from the electoral register and credit
reference agencies. We may undertake searches with credit reference agencies, such as but notlimited to: Equifax, Experian and GB Group for the purposes of verifying your identity. To do so thecredit reference agency may check the details you supply against any particulars on any database(public or otherwise) to which they have access.

8.14

We may refuse to open an Account for you for any reason. We are under no obligation to tell you why
we have refused your application.

8.15

If you act in connection with or on behalf of someone else, whether or not you identify that person tous, we will not accept that person as an indirect customer of ours and we will not owe any obligationor duty to them unless otherwise specifically agreed in writing. Failure to inform us that another person(other than an Authorised Person) is operating your Account may result in us terminating thisAgreement, suspending your Account and/or closing any open Transactions you may have with us.

9.

MARGIN AND DEPOSIT REQUIREMENTS

9.1 For each Transaction, we require you to have certain funds (which includes any bonuses and trading credits)available on your trading account, this is known as Margin. Margin protects us against negative pricemovements, which can result in you having trading losses on your Open Positions and can lead to you
owing us money if any of your Open Positions were closed. Margin protects us in case you are notable to pay any money you owe us when Transactions are closed out.
9.2 When you enter into a Transaction, we require you to have sufficient funds (which includes any bonuses andtrading credits) available to cover Margin in relation to the Positions to be opened on your trading
account. We set the amount of Margin needed for clients, and can alter it for any reason. We apply
different margin rates for different sizes of Positions, ie: tiered margin. Margin rates for different
Instruments are available on our Website.
9.3 In order to keep a Position open, you are required to maintain a minimum amount of money (which includes
any bonuses and trading credits) in your trading account, this is known as the "Margin Requirement".
9.4 You must maintain sufficient funds (which includes any bonuses and trading credits) in your trading accountat all times to meet the Margin Requirement on your Open Position(s). We may close any Open5

Position(s) on your account when the funds on your account (including all unrealised losses and profits
as well as any bonuses and trading credit(s)) falls to or below 50% of the Margin needed to place theTransactions.
9.5 We may require you to deposit additional funds at short notice to ensure that your Margin Requirement is
met to maintain your Open Position(s). This is known as a "Margin Call". We are not obliged to makea Margin Call in any circumstances. If we do not make a Margin Call, we reserve the right but not the
obligation, to close Open Positions. If we do not make a Margin Call and allow you to continue to tradeor to keep your Open Positions open, you may incur further losses. In these circumstances we will not
be responsible for such losses.
9.6 If we make a Margin Call, the only actions you will be able to take on your trading account are:(a)

Depositing or transferring further funds to meet the Margin Requirement; or(b)either closing Positions or reducing the size of your Positions to reduce the Margin Requirement.

9.7

We may use any money we hold on your behalf, or close out some or all of your Open Positions startingwith the largest Position held on an open market, in order to meet a Margin Call. We will not be
responsible for any actions or inaction on our part in relation to a Margin Call where we act inaccordance with this Agreement, including where we do not notify you that you are on a Margin Call.
It is your responsibility, at all times, to monitor your Open Position(s) and to ensure that you havesufficient funds (which includes any bonuses and trading credits) on your trading account to cover the
Margin Requirement.

9.8

We will close out one or more of your Open Positions when you do not have sufficient funds (which
includes any bonuses and trading credits) available on your trading account to cover the Margin
Requirement, ie: the available funds fall to below 50% of the Margin needed to open the Positions.
Where we do this, we will close your Open Positions at the current market price and this may result inyou incurring a loss on the Transaction(s). You will be responsible for any losses you incur as a result.

9.9

Where any loss or profit is in a currency other than your trading account's Base Currency, we will
convert such loss or profit into your trading account's Base Currency at our prevailing currency
exchange rate at the time that we close out such a Transaction. You acknowledge and agree to bear
any exchange rate risk or other market movements that may result from such and/or the exercise by
us of our rights under this Agreement.

10.

ENTERING INTO TRANSACTIONS ON THE TRADING PLATFORM

10.1 You must access our Trading Platform using your Access Code, which is the password emailed on the
successful completion of the Account opening process, or when you requested to change yourpassword, and your account number.
10.2 You may enter into a Transaction at any time during Trading Hours. If you place an Order outside Trading
Hours, we may not be able to execute the Order at the specified price if the market is not trading at
the price you specified once Trading Hours commence.
10.3 You enter into a new Transaction by opening a new Position or closing all or part of an existing Position.
10.4 For each Position, you will choose whether to buy or sell (this is also known as going "long" (buy) or "short"(sell)). We quote both a buy and sell price for each Instrument. The difference between these prices
is known as the spread. The spread we offer can vary at any time and may be different when you open
and close a Position. The spread widens and narrows based on changes in the underlying market.
This is known as a dynamic spread.
10.5 For each Transaction you enter into, you make us an offer to enter into a Transaction (either to open or toclose a Position) at the price available on the Trading Platform when we execute your Transaction.
10.6 The price we quote on the Trading Platform may move rapidly due to changing market conditions. As such,the quote at which you offered to enter into the Transaction may not remain valid by the time we
6execute the Transaction. You agree that we may still execute your Order at a different price to thatquoted on our Trading Platform when you offered to enter into the Transaction. There is no restriction
to the extent that you could benefit from such price movement or the extent to which you could sufferfrom such price movement.
10.7 We are under no obligation to accept your offer to enter into any Transaction.
10.8 You will have opened or closed a Position when we have accepted your offer, and when opening a Position
you have sufficient funds (which includes any bonuses and trading credits) on your trading account tocover the Margin needed to open the Position (see paragraph 9).
10.9 You must place all Transactions through the Trading Platform. If any other person (other than an Authorised
Person) performs actions in relation to your Account, we may take any action we deem necessary(including to comply with Applicable Law). This may involve terminating the Agreement, suspending
your Account and/or closing or reversing Transactions.
10.10 We will not accept any form of written offer to open or close a Transaction, including offers sent by fax,
email or text message, or offers made by telephone, unless we have expressly stated in writing via an
emergency notification.
10.11 We may establish trading and leverage limits on your Account at our sole discretion, or to comply with
Applicable Law, with or without notice. Such limits may include, but are not limited to, limits on theamount of leverage that you may be exposed to on our Products, limits to the number of trading
accounts available for trading, limits on the size of any Transaction or series of Transactions which
together create a large size Open Position, limits on the size of any Open Positions in your Accountand/or the number of Transactions permitted within a set period of time. Such limits may be imposedon your Account, including on all trading accounts on an aggregate basis, or on any individual trading
account, in our reasonable discretion. In the event that you breach any such limits, we reserve theright to close any or all Open Positions in your Account in our reasonable discretion. In dealing withlarge size Transactions or a series of large size Transactions, we may, in our reasonable discretion,enter into them or close them out at a price or prices that are different from the price or prices quoted
on the Trading Platform.
10.12 We may establish maximum exposure limits per client, with or without notice, including, without limitation,
the right but not the obligation to enforce the closure of Positions to bring the exposure on your open
Transactions within the prescribed limits.
10.13 We may take reasonable corrective action for Invalid Transactions, including, without limitation, the rightto reverse or amend:(a)any Transaction constituting an Invalid Transaction; or(b)any or all Transactions executed after an Invalid Transaction and prior to our corrective action.

If we do not reverse or amend such Transaction(s), we may credit your Account for the portion of therealised loss, or debit your Account for the portion of the realised profit, in each case attributable toany such Transaction(s). Any Open Positions that, due to such Transaction(s), are either reduced orclosed shall remain reduced or closed. It shall be your sole responsibility to monitor the remaining
Open Positions in your Account and take any action you deem prudent with respect to such Positions.
The fact that we have confirmed any Transaction(s) shall not prevent us from taking such corrective
action.
10.14 We reserve the right to aggregate a Transaction of yours with one or more Transactions of our otherclients, including clients of OANDA Related Entities, and with Transactions relating to the proprietary
trading and hedging activity of the OANDA Group, if to do so does not negatively impact OANDAGroup clients as a whole. This also applies to our execution of Pending Orders. Where we do so, theaggregate opening or closing level for your Transactions may differ from your specified offer level orfrom the price that would have been attained if your order had been executed as a single Transaction
or not aggregated with Transactions of our other clients.

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11.

SPECIFIC TRADING INSTRUCTIONS YOU CAN GIVE

11.1 When you make an offer to enter into a Transaction you can either:(a)open a Transaction at the best available price on the Trading Platform at the time of openingthat Transaction, this is called a "Market Order"; or(b)offer to open a Transaction at a particular target price set by you, this is called a "Pending
Order".

11.2

We may also, from time to time, offer trading features which you can utilise when you place an Order.

11.3

We execute all Transactions at the best price available at the time in accordance with our execution
policy.

11.4

When you place an Order with us, you expressly acknowledge and agree that you fully understand all
the terms and conditions attached to such Order.
Market Order11.5 When you place a Market Order, the price at which we execute the Transaction may not be the same pricewhich was displayed on the Trading Platform when you submitted the Order, as prices are subject tocontinual movement. Your offer to open a Market Order may be accepted at a lower or higher pricethan the price indicated by you in your Market Order. There is no restriction as to the extent that yourMarket Order could be executed at a beneficial price for you or at a worse price for you.
11.6 If you choose to open a Market Order, your offer will be accepted at the best possible price offered on the
Trading Platform at the time you place your Order, in accordance with our execution policy.
Pending Order11.7 When you specify a target price for a Pending Order, the price at which we execute the Transaction may
not be the price you specified when you placed your Order. This may be due to volatile market
conditions outside our control. You agree that we may execute a Pending Order at a different price tothe price you indicated in your Pending Order.
11.8 There may be occasions when we are unable to execute a Pending Order at the level you specified, despite
our reasonable efforts to do so. This could be due to market volatility and factors beyond ourreasonable control, such as, but not limited to, liquidity available in the market and time taken for an
Order to reach the market due to the number of intermediaries. For example, an Order may be closed
at a worse price than you specified because the market moved too quickly for us to execute sooner.
Where this happens, we will close the Transaction at the next best price. This is referred to as slippage.
There can be slippage on both opening and closing Orders
11.9 You may cancel a Pending Order at any time prior to its execution without any liability.

Trading Features
11.10 We may add, remove or otherwise make available to clients certain operational and trading features fromtime to time, descriptions of which will be available on our Website.

12.

FEES AND CHARGES

12.1 Details of all charges, spreads and commissions applicable to your trading activity can be found on our
Website.
12.2 Where you hold a Transaction that exposes you to the payment of a dividend, we shall be entitled to makea reasonable dividend cash adjustment to your Account. You should contact us for details of dividend
8cash adjustments if you are unsure of the impact that this will have on your Account. Information is
also available on our Website.
Transactions may be subject, depending upon the underlying Instrument, to a “Financing Charge” or“Financing Credit”, to reflect the cost of funding your Position (in relation to the margin utilised). The
Financing Cost is calculated on a per Position basis and may be a charge or a credit, depending onwhether the Position is a buy/long Position or a sell/short
Position, and after also taking into consideration the impact of our admin fee. Further
information on Financing Costs and funding rates is available on our Website. Financing
Costs do not apply to ‘Swap Free’ accounts, further information available on the Website.
12.3 When a Transaction is closed out:
(a)

(b)

you will have to pay the Difference (this is the Difference in price between the opening of aTransaction and the closing of a Transaction, plus or minus any Premium payable), where theTransaction is:(i)a Sell, and the closing price of the Transaction is higher than the opening price of theTransaction; or(ii)

a Buy, and the closing price of the Transaction is lower than the opening price of theTransaction; andyou will receive the Difference where the Transaction is:(i)a Sell, and the closing price of the Transaction is lower than the opening price of theTransaction; or(ii)

a Buy, and the closing price of the Transaction is higher than the opening price of theTransaction.

12.4

We may use (and/or transfer) any funds in your Account to settle your payment obligations under thisAgreement.

12.5

Unless we agree otherwise, all sums due under this Agreement are due immediately upon the
conclusion of a Transaction.

12.6

You will be liable for all taxes, fees and assessments for any Transaction you complete on the Trading
Platform, now or in the future. You will reimburse us if we pay any applicable taxes on your behalf.

12.7

You will be liable for all taxes, fees and assessments associated with share CFD Positions, including,but not limited to, dividend equivalent cash payments.

12.8

You will be liable to cover the cost of any taxes paid by liquidity providers with regards to share CFDs,
which will appear as an entry on your Account marked ‘tax-equivalent’, however, this is not an actual
tax charge as you will not own the underlying Instrument.

12.9

We may charge you for Market Data or any other ancillary services we make available to you.

12.10

We may deduct from any payments due to you such amounts as are required to be deducted inaccordance with Applicable Law.

12.11

If there are no Transactions on your Account for a period of at least 12 months, your Account may besubject to a monthly inactivity fee for each month the Account remains inactive. The levying of an
inactivity fee will not result in a negative balance on your Account. Further information on inactivity
fees is available on our Website.

13.

GENERAL RULES OF TRADING

913.1 All prices shown on the Trading Platform are indicative only, relate to Normal Market Size and are subject
to constant change as the market changes.
13.2 The prices we quote will be in accordance with our execution protocols and will be valid at the time wequote them. However, they may be withdrawn or modified at any time thereafter. A Transaction will be
initiated by you by offering to open or close a Transaction
with us on an Instrument at the level quoted by us. We may accept or reject your offer to open or closea Transaction at any time until the Transaction has been executed or we have acknowledged that youroffer has been withdrawn. A Transaction will be deemed to have been opened or closed only whenyour offer has been received and accepted by us.
13.3 In respect of each Instrument we quote that is based on the price of a share that is traded on a recognised
Exchange, there is a corresponding Exchange Market Size for Transactions in that Instrument. It is
important that you familiarise yourself with any Exchange Market Size that is applicable to a
Transaction before you open it, as a Transaction that is in excess of Exchange Market Size may be
dealt with differently from a Transaction that is within Exchange Market Size.
13.4 Any price that we quote is valid only for a Transaction equivalent in size to the quotes available to us in theunderlying market on which they were based.
13.5 If you offer to open a Transaction that is larger than Exchange Market Size, rather than accepting your offer
as a whole, we reserve the right to accept your offer as a series of smaller Transactions, eachTransaction having a different (bid/offer) price.
13.6 You accept that there may be a delay in our offering you a quote to close a Transaction that is in excess offour times (4x) the Exchange Market Size, or where any number of Transactions taken together are inexcess of four times (4x) the Exchange Market Size. This is particularly likely to be the case where theInstrument in respect of which the Transaction is made is illiquid. Depending on the circumstances,the delay could be one of hours, days, weeks or even months, and might involve our quoting you aseries of prices for closing the Transaction in tranches rather than at one time and a single price. If
this happens the level of the Instrument may move against you during the period of delay. You shouldbear these potential consequences in mind prior to opening a Transaction in excess of Exchange
Market Size (or accumulating a Position in excess of Exchange Market Size by placing a number ofTransactions) and should only open such a Transaction (or accumulate such a Position) if you areprepared to accept the risks associated in doing so.
13.7 In the event that you open a Transaction that is in relation to an Instrument that is a share and the underlying
share is or becomes unborrowable so that we are unable to hedge against losses that we may incurin relation to that Transaction, we may close the Transaction in question. For the avoidance of doubt,
this provision will apply whether the share was unborrowable from the outset or our brokers or agentsrecall from us a share that we have already borrowed against.
13.8 You must comply with any reasonable restrictions that we notify you of from time to time with respect toyour activities on the Trading Platform, including limitations on, and the size of, Transactions andresultant Positions, or other conditions that may apply to our quote.
13.9 Each Transaction opened or completed by you will be binding upon you even where, for example, in opening
the Transaction you may have exceeded any credit and/or other limit applicable to you or in respect ofyour dealings with us, unless prohibited by Applicable Law.
13.10 We may monitor the status of any Transaction; make Margin Calls or advise you that you are in breach of
any Margin Requirements or limits, or close any Transaction that you have opened; but we are notunder any obligation, unless required by Applicable Law, to take such action and will not be
responsible for any losses you incur as a result of our action or inaction.
13.11 We may provide a quote and accept (and therefore act on) your offer to open or close a Transaction
outside of the Trading Hours for an Instrument. Transactions can (and will) only be executed during
the time when the relevant Exchange is open for business. It is your responsibility to ensure you areaware of the trading hours for the Instruments you trade in.
13.12 Trading strategies which involve the use of ultra-high speed or mass data entry must not be deployed
without our prior written consent, which we may withhold at our discretion.
1013.13 We may reject your offer to open or close a Transaction, or unwind or close any Open Positions without
notice, if we reasonably believe:(a)your offer to open or close the Transaction is given while the quote is no longer valid;(b)

our quote contains a Manifest Error;(c)the Transaction exceeds the maximum Order amount;(d)the Order is placed in reliance on price latency opportunities including any Orders placed using
API, or by attempting to game or abuse the system;(e)

you have insufficient funds (which includes any bonuses and trading credits) available on yourtrading account to cover the Margin associated with an opening Transaction or maintaining anOpen Position, or you would breach any other limit placed on your dealings by us or requiredof us by Applicable Law;(f)you have benefitted from an unfair advantage or acted in an unfair or abusive manner inrespect of our systems, platforms or Accounts, for example:
(i)
(ii)
(iv)

(g)

using any electronic device, software, algorithm or any trading strategy that aims tomanipulate or take unfair advantage;
exploiting a fault, loophole or error in our software, system or platforms; (iii) collusion;orusing trading strategies designed to return profits by taking advantage of latencies in aplatform, delayed prices or through high volumes of Transactions opened and closed
within an unusually short period of time as compared to the ‘average’ client and/or
targeting tick fluctuations rather than movements reflecting the correct underlying
prices; or

it is reasonable for us to do so in order to protect us or the Trading Platform, provided we act
reasonably.

13.14

To the extent you are a MiFID investment firm and are required to do so, we will not transaction reporton your behalf.

13.15

If you are a legal entity, you agree that we may in certain circumstances obtain a Legal Entity Identifier(LEI) on your behalf. We may do this if we consider it necessary in order to allow you to enter into
Transactions with us. We may pass on to you any charge we incur to obtain an LEI on your behalf andwe may charge you an administration fee to cover our costs.

13.16

Where a situation arises that is not contemplated by this Agreement you and we will resolve the matter
using principles of good faith and fairness, guided both by normal market practices and the approachtaken by our hedging counterparty with whom we have hedged our risk exposure to you for the relevant
Transaction or Transactions.

14.

ACCOUNT STATEMENTS AND INFORMATION

14.1 All information on your trading activities is available online in your Account.
14.2 You can generate daily, monthly, yearly and ad hoc reports, by setting your own date range, of all yourexecuted trades, trading and funding activities. Your Account will be updated no later than 24 hours
after any activity takes place.
14.3 We will keep records of your Transactions to comply with our own record keeping obligations, and we may
disclose such records as may be required as evidence in any legal or regulatory proceedings. We do
not keep records on your behalf.

15.

YOUR MONEY
11

15.1 We will treat any money we hold on your behalf as Client Money, and therefore hold your money in asegregated Client Money bank account.
15.2 We will hold your (and other customers') Client Money in a pooled client bank account with one or more
third party bank or credit institutions, the identity of which is available on our Website. We will not be
responsible for the acts or omissions of any third-party bank or credit institution holding your money.
We may place funds in notice or term deposit accounts with a notice period or term of up to 95 days.
Placing client money in notice or term deposit accounts does not in itself affect your ability to deal withor withdraw funds from your Account with us, however in the unlikely event of insolvency of OANDA
Global Markets Limited, such amounts may not be immediately available upon request.
15.3 We will not pay interest on any Client Money that we hold on your behalf and by entering into this agreement
you acknowledge that you therefore waive any entitlement to interest.
15.4 You agree that we may transfer Client Money to a third party as part of a transfer of all or part of ourbusiness.
16.

MONEY OWING TO YOU

16.1 Any money standing to the credit of your landing account(s) (which excludes any bonuses or trading
credits) will be transferred to you upon request, subject to you satisfying relevant Margin Requirements
and there being no outstanding sums due from you under these terms.
16.2 Withdrawals from your landing account(s) should be made to the same account you used to fund yourAccount. If you have sent funds to us from more than one bank account, we will, at our discretion, pay
any amounts withdrawn from your landing account(s) to one of the bank accounts from which suchfunds were received. We reserve the right to decline or cancel a withdrawal request using a specificpayment method and suggest an alternative payment method for which you will need to proceed withany new withdrawal request. In doing so, we may request you to supply further supporting
documentation for our internal checks and proper processing of the withdrawal request; in particular,
where you wish to change bank accounts or when the bank account from which the funds wereoriginally received no longer exists.
16.3 Withdrawals from your Account are generally carried out within a minimum of 3 Business Days and up to 7
Business Days upon receipt of the withdrawal request, except in extraordinary circumstances.
Withdrawals to a bank account via bank transfer may be subject to further delays. Following receipt ofa withdrawal instruction, we process the request and the requested withdrawal amount will be deductedfrom your landing account(s) balance. You or we can cancel the withdrawal request at any time until
the withdrawal request is fully processed and settled, and the withdrawal amount requested can beused to satisfy your liabilities for any Transactions completed during such time.
16.4 Where applicable we will return money to your credit/debit card in the form of card refunds. This means thatyour withdrawal request may be split into multiple payments in order to refund each of your individual
deposit transactions.
16.5 We reserve the right to refuse: deposits to your Account, including without limitation, deposits made fromthird party sources; and withdrawals from your Account which are directed to third party recipients.
16.6 All landing account withdrawal requests are subject to a minimum withdrawal amount, which is the lesser
of USD50 (or equivalent) and your available balance.
16.7 We may charge you if you exceed the maximum number of monthly withdrawals from your landing
account(s), as detailed on our Website.
17.
THE TRADING PLATFORM
Access to the Trading Platform
17.1 We grant you a licence to install and use the downloadable, web and app version of the Trading Platform
Software, for example MT4 software. This licence is personal to you. You cannot allow others to use
the Trading Platform Software or sub-licence the Software in any way. When this Agreement ends, we
automatically revoke the licence and you must no longer use the Trading Platform.
1217.2 You must comply with the terms of any Third Party Software Licences that we provide you with from time
to time. We do not provide support for Third Party Software nor make any warranty or representation
as to its quality or performance. You acknowledge that there are important differences when using
Third Party Software to access your Account.
17.3 It is your responsibility to ensure you can access the Trading Platform Software, and you are responsible
for any charges you incur as result of accessing our Trading Platform through any device (such asdata charges from your mobile operator or internet access charges from your internet service provider,for example).
17.4 The use of and access to the Trading Platform may not be permitted (or may be blocked) in some countries
and jurisdictions. It is your responsibility to verify that you are permitted to use and access the Trading
Platform in the country in which you are located.
17.5 From time to time, we may add to, modify, or remove any part of the Trading Platform or Software. We will
try to minimise disruption to you if we do this and replace any part of the Trading Platform with anequivalent part to the extent practicable. We will give you prior written notice where we believe ouractions may result in detriment to you.
17.6 We may allow you to use our services and access our Trading Platform through various digital means,including through our Website or a mobile or tablet application. Accessing the Trading Platform throughour digital channels may not allow the same functionality, access to information and services which
are available when using the web version of the Trading Platform.
17.7 We do not promise our Trading Platform or Software will be uninterrupted, error-free or free from viruses.
For example, there may be occasions where you cannot place Transactions; where information(including prices and quotes) is incorrect; where you cannot receive any messages from us; or where
Orders are not correctly completed. We will not be responsible for any such interruption or errors andour records will determine the obligations of either party.

17.8 We take no responsibility for any communications transmitted over the internet, including any failures,
disruptions, distortions, errors or delays. There can be no assurance that such communications willremain confidential or intact. Any communications transmitted to or from you through the Trading
Platform, email, instant messaging or other forms of electronic communication through the internet areat your own risk.
17.9 We will not be responsible for any loss or damage you suffer (including damage to your devices) throughaccess to or use of the Trading Platform or through any failure by us (or a third party) to provide youaccess to the Trading Platform or through any incompatibility of the Trading Platform with any of yourdevices.
17.10 We make no warranty or representation, either express or implied, with respect to Third Party Software,
including its quality, performance, merchantability, fitness for a particular purpose or that it is error free.
You acknowledge that there are important differences when using Third Party Software to access yourAccount. You assume full responsibility and risk of loss you may suffer as a result of using, oraccessing, Third Party Software. In no event
will we be liable to you or any third party for any claims; losses; costs or expenses (including attorneys’fees); or direct, indirect, special, incidental, punitive or consequential damages arising out of the useof or inability to use Third Party Software, even if advised of the possibility of such damages.
Access Code
17.11

You must:(a)take all reasonable steps to keep your Access Code credentials confidential and ensure it
cannot be used by any person other than you or an Authorised person; and

13

(b)

notify us as soon as possible by telephone or in writing if you discover that any of your Access
Code or other security information or devices have been lost or stolen, or that someone else
has used (or attempted to use) them.

17.12

When we receive any form of communication (including but not limited to instructions for Transactions)through our Trading Platform from any device or medium that uses your Access Code, we will assume
the communication has been transmitted by you or by an Authorised Person. We will rely on that
communication as a valid and authentic communication from you and, where applicable, as authority
to enter into Transactions with you.

17.13

We are under no obligation to confirm any communication using your Access Code is valid, accurate
or complete before we act or rely on the communication. We may act or decline to act on any
communications if we consider them to be unclear, incomplete or suspicious and will not be
responsible for any such actions or inactions.

17.14

You must immediately inform us if you are aware or suspect that a third party has had access to yourAccount.

17.15

We will not be responsible for any losses or damage you suffer as a result of any such unauthorised
access to your Account, where you have acted fraudulently or have intentionally or negligently
disclosed your Access Code.

17.16

We may suspend your access to the Trading Platform and require you to change your Access Codeat any time.

17.17

If we receive conflicting or ambiguous instructions, we may in our reasonable discretion and without
any liability to you or any other person, act or decline to act as we think fit, but will endeavour to contact
you to clarify your instructions as soon as reasonably possible.

18.

JOINT ACCOUNT

18.1 No joint accounts are available.

19.

POWER OF ATTORNEY

19.1 If you want to permit a third party (an "Attorney") to operate your Account, you must send us a copy of ourPower-of-Attorney document (available on our Website) duly signed by you, the Attorney and an
appropriate witness, before permitting the Attorney to operate the Account.
19.2 We have no responsibility to review your choice of Attorney, nor to advise you of such Attorney's reputation,
operating methods or trading record. You provide your Attorney with authority and control over yourAccount at your own risk.
19.3 We will follow the instructions of your Attorney, as if such instructions had originated from you. We will not
be required to confirm such instructions with you.
19.4 You retain the right to vary or cancel the appointment of an Attorney at any time by notifying us in writing.
19.5 We will not be responsible for any loss or damage you may suffer from the acts or omissions of an Attorney,or as a result of us following the instructions of an Attorney.

20.

CHANGING THESE TERMS

20.1 We may change these terms at any time for any reason, including (without limitation):(a)to comply with or reflect a change in Applicable Law or a decision by a relevant ombudsman
or regulator;
14

(b)

to make them more favourable to you or to correct a mistake or oversight (provided that any
correction would not be detrimental to your rights);(c)to provide for the introduction of new systems, services, procedures, processes and/or
products or to incorporate such changes in technology as we deem necessary(provided in each case any change would not be detrimental to your rights); or(d)to remove an existing service, provided we have given you appropriate notice its removal inaccordance with this Agreement.

20.2

We will notify you in writing before the changes take effect. You will be deemed to accept and agree
to the changes unless you notify us to the contrary within five Business Days of the date of our written
notice to you. If you object to the changes, the changes will not be binding on you, but your Accountwill be suspended and you will be required to close your Account as soon as is reasonably practicable.
Any change to this Agreement will come into effect on the date specified by us which will, in mostcases, be at least five Business Days after you are deemed to have received notice of the amendment
in accordance with paragraph 32.3 (unless it is impractical in the circumstances to give five Business
Days' notice).

20.3

If, as a result of changes we propose to make, you wish to terminate the Agreement, you may do soin accordance with paragraph 21. We will not make a charge for transferring any money we hold foryou if you terminate the Agreement for this reason.

20.4

An up-to-date copy of these terms is always available on our Website.

21.

TERM, TERMINATION AND CANCELLATION

21.1 You may terminate this Agreement only in accordance with this paragraph 21.
21.2 Either you or we may terminate this Agreement, at any time, by giving the other party at least three (3)Business Days written notice.
21.3 If you terminate this Agreement, you must close all your open Positions as soon as is reasonably practicableand in any event within 21 days of you giving us written notice to terminate this Agreement. Any losses
incurred on your trading account prior to its closure will become immediately payable by you. We will
not accept any Orders to open new or increase existing Positions after we receive such written noticefrom you to terminate this Agreement. We will only close your Account if you have fully satisfied anddischarged any amounts owed to us in respect of your Account.
21.4 We may terminate this Agreement immediately upon an Event of Default, as set out in paragraph 23, or
upon a Force Majeure Event, as set out in paragraph 26. If we terminate this Agreement for thesereasons:(a)

we will notify you in advance unless we are unable to do so under Applicable Law; and(b)

we may close out or cancel any or all of your open Positions without notice on the basis of theprice available on the Trading Platform or, where the market is closed, at the next available
price on the opening of the market, or as required otherwise by Applicable Law.

21.5

No penalty, fee or charge will be payable by either party upon cancellation or termination of thisAgreement under this paragraph 21.

21.6

Where this Agreement comes to an end, we will endeavour to return to you, within 5 Business Days,
the net balance of any monies remaining on your Account.

21.7

We will forward any net balances in your Account as directed by you. In the event that you fail toprovide instructions we will forward such funds to the account from which you transferred funds from.

15

21.8

The amount to be remitted to you pursuant to paragraph 21.6 shall be the net balance of your Accountless (i) any and all monies due to us from you pursuant to the Agreement; and (ii) any and all taxes
and other sums that we are required to withhold from such remittance in accordance with Applicable
Law.

22.

ASSIGNMENT

22.1 You may only assign or transfer, or grant any security in respect of, your rights or obligations under thisAgreement to another person if we agree to this in writing. We would not agree to such transfer to aperson who is a Prohibited Customer, for whom we do not consider our services to be appropriate or
who we do not consider could comply with the terms of this Agreement, for example.
22.2 We may assign our rights or obligations under this Agreement to another organisation. We will tell you in
writing at least 30 days before this happens. You can terminate this Agreement at any time before theend of this 30-day period if you are not happy with this assignment.
23.

EVENTS OF DEFAULT AND THEIR EFFECT

23.1 Each of the following will constitute an "Event of Default":(a)you fail to satisfy any material provision of this Agreement and such failure continues for morethan 3 Business Days after we have given you the relevant notice of non- performance;(b)

you fail to perform a material obligation under this Agreement and such failure is reasonably
likely to expose us to the risk of a loss such that it is not possible for us, acting reasonably, togive you notice of non-performance;(c)

you fail to provide us with any information or notice required pursuant to thisAgreement or provide false, incomplete or misleading information;(d)

you die or become of unsound mind;(e)

we consider it reasonably necessary to prevent what we reasonably consider to be or might
be a violation of any Applicable Law (including but not limited to, Market Abuse, gaming thesystem, or Scalping);(f)

you withdraw your consent to conduct business electronically at any time by providing noticein accordance with this Agreement;(g)

you enter into liquidation or bankruptcy, whether compulsorily or voluntarily, or a procedure iscommenced against you seeking or proposing liquidation or bankruptcy, or you are generally
unable to pay your debts as they become due (or you admit so in writing);(h)you become subject to an administration order or have a receiver or similar appointment ororder are made or proceedings commenced in respect of any of your assets in consequenceof debt;(i)

we reasonably believe you have acted in an unfair or abusive manner, for example, but notlimited to, using any ultra-high speed trading; automated or mass data entry system; orScalping with or on the Trading Platform;(j)

you make any misrepresentation or breach of warranty under this Agreement including but notlimited to any misrepresentation or breach of warranty under paragraph 27.1; or(k)

we have reason to believe that any of the foregoing is likely to occur imminently or any othercircumstances where we reasonably believe that it is necessary or desirable to take any action
set out in paragraph 23.2.

23.2 If an Event of Default occurs, unless otherwise prescribed by Applicable Law, we may, in our absolute
discretion, at any time and without prior notice, take one or more of the following steps:
16

(a)

close out all or any of your Open Positions at current quotes;(b)debit (or credit) your Account for amounts which are due to us (or you);(c)close your Account, including any or all landing or trading accounts; or(d)refuse to open new Positions, landing accounts or trading accounts for you.

23.3

In the case of an Event of Default under paragraph 23.1(f), any communications between us and you
during the period before the withdrawal of your consent to do business electronically, will be valid andbinding on both you and us.

23.4

In the case of an Event of Default under paragraph 23.1(j), you agree to accept the risk and liability for
any resulting financial loss and any negative balances, on a Transaction, which will become
immediately due and payable.

23.5

If we, in our sole discretion, believe that your Account has been involved in any fraud or crime orviolation of laws or regulations, or has been accessed unlawfully, or is otherwise involved in any
suspicious activity (whether victim or perpetrator or otherwise), we may suspend or freeze the Accountor any privileges of the Account, may freeze or liquidate funds or Positions, or may avail ourselves ofany of the remedies for an "Event of Default" in this Agreement.

23.6

Our rights and remedies under this Agreement are cumulative, and our exercise or waiver of any rightor remedy will not preclude or inhibit the exercise of any additional right or remedy. Our failure to
enforce or exercise any right under this Agreement will not amount to a waiver or bar to enforcementof that right.

24.

OUR LIABILITY TO YOU

24.1 We (including our directors, officers and agents) shall not be responsible to you or any third party for:(a)any loss, expense, cost or damages (together "Loss") you suffer or incur as a result of our/theiracts or omissions unless and to the extent that such Loss is suffered or incurred as a result of
our/their fraud, negligence or wilful default;(b)

any Loss which is not a foreseeable result of us breaching this Agreement, including but notlimited to, loss of future profit, loss of business, loss of goodwill or reputation, loss or corruptionof data or loss of opportunity;(c)

any Loss you suffer or incur as a result of any error in any Order or instruction which is, orappears to be, made using your Access Code;(d)any Loss you suffer as a result of your use of or inability to use Third Party Software;(e)any decline in the value of your investments;(f)

any delay or change in market conditions before any Transaction is effected;(g)

the solvency, acts or omissions of any third party (except where we have been negligent inappointing that third party);(h)any delay, failure or error by you in implementing any reasonable instruction we have provided
to you;(i)

any inaccurate or incomplete instructions received from you;(j)

any losses you suffer as a result of any other person, whether authorised or unauthorised byyou, gaining access to your Account using your Access Code or by any other means;
17

(k)

inaccessibility or disruption to, or errors or defects with, or viruses, worms or software bombs
spreading from, the Trading Platform unless due to our fraud, negligence or wilful default;(l)

any interruption or destruction to the Trading Platform due to circumstances beyond ourreasonable control;(m)

our refusal to execute any Transaction;(n)

any Account Adjustment (including without limitation, the reversal or amendment of any
Transaction);(o)any failure, delay or error in executing or confirming any Transaction; or(p)

us exercising or failing to exercise our rights under this Agreement (including, without limitation,in the circumstances set out in paragraph 13.13).

24.2

Nothing in this Agreement excludes or restricts any duty or liability we owe you under any Applicable
Law, and if there is any conflict between this Agreement and the provisions of any Applicable Law, theprovisions of the Applicable Law shall prevail.

24.3

Nothing in this Agreement or otherwise shall oblige us to do anything we believe to be contrary to
Applicable Law.

25.

YOUR RESPONSIBILITY FOR LOSSES
You are responsible for, and shall refund to us, any liabilities, losses or costs we may incur if you failto perform any of your obligations under this Agreement, in relation to any Transaction or in relation to
any false information or declaration made either to us or to any third party, or arising out of any act oromission by any person obtaining access to your Account by using your Access Code, whether or not
you authorised such access. This responsibility extends to our legal and administrative costs andexpenses incurred in respect of taking any legal or investigatory action against you, or instructing any
debt collection agency, to recover monies owed by you to us. However, this responsibility does notextend to situations where we have acted negligently, fraudulently or with wilful default.

26.

EXCEPTIONAL EVENTS

26.1 We will not be liable to you for any delay in performance, or for the non-performance of any of our obligations
under this Agreement by reason of any cause that is beyond our reasonable control, a "Force Majeure
Event".
26.2 A Force Majeure Event will include, but is not limited to, the following:(a)

any act, event or occurrence (including without limitation any strike, riot or civil commotion, actof terrorism, war, industrial action, acts and regulations of any governmental or supra national
bodies or authorities) that, in our opinion, prevents us from maintaining an orderly market in
one or more of the Instruments in respect of which we ordinarily deal in Transactions;(b)the suspension or closure of any market or the abandonment or failure of any event on which
we base, or to which we in any way relate, our quote, or the imposition of limits or special or
unusual terms on the trading in any such market or on any such event;(c)the occurrence of an excessive movement in the level of any Transaction and/or the Underlying
Market or our anticipation (acting reasonably) of the occurrence of such a movement;(d)any breakdown or failure of transmission, communication or computer facilities, interruption of
power supply, or electronic or communications equipment failure;

18

(e)

failure of any relevant supplier, intermediate broker, agent or principal of ours, custodian, subcustodian, dealer, Exchange, clearing house or regulatory or self- regulatory organisation, for
any reason, to perform its obligations; or(f)the occurrence or continuation of any abnormal trading conditions.

26.3 If we determine in our reasonable opinion that a Force Majeure Event has occurred or is occurring, and wedeem such action necessary in our reasonable discretion to protect our interests or those of our clientsand other customers, we may at any time and without notice:(a)Reduce leverage rates and thereby increase margin rates on both new and existing Positions;(b)treat any or all Transactions that are then outstanding as having been cancelled andterminated;(c)sell or otherwise convert any Position under our control into monies in such manner as we
reasonably consider necessary or appropriate; and/or
close out, replace or reverse any or all Transactions, enter into any other Transaction or take,or refrain from taking, such other action at such times and in such manner as we consider
necessary or appropriate to cover, reduce or eliminate our loss or liability under or in respectof any contracts, Positions or commitments.

(d)

26.4

Upon the occurrence of a Force Majeure Event we will use commercially reasonable efforts to resume
normal performance of the Trading Platform and will use our reasonable efforts to give you written
notice that a Force Majeure Event has occurred.

26.5

In the case of a Force Majeure Event, you accept the risk of financial losses and will be liable fornegative balances, which will become immediately due and payable.

27.

MARKET ABUSE AND OTHER UNLAWFUL CONDUCT

27.1 We frequently hedge our liability to clients by opening analogous Positions with other institutions. The resultof our doing this is that, when you open a Position in relation to an Instrument with us, the Positioncan, through our hedging, exert a distorting influence on the underlying market for that Instrument, in
addition to the impact that it might have on our own prices. This could amount to Market Abuse. You
therefore represent and warrant to us and agree that each such representation and warranty is deemed
repeated each time you open or close a Position, that:
(a)

(b)

(c)

(d)

You will not place and have not placed a Transaction with us in connection with (i) a placing,issue, distribution or other analogous event; or (ii) an offer, take-over, merger or otheranalogous event in which you or an associate of yours is involved or otherwise interested or in
relation to which you are in possession of inside information which, if made public, could affectthe price of the relevant Instrument.
You will not place and have not placed a Transaction that contravenes any primary or
secondary legislation or other law, regulation or rule against Market Abuse or otherwise. For
the purposes of this clause, you agree that we may proceed on the basis that when you open
or close a Position with us in relation to a share or other Instrument you may be treated as
dealing in securities within the meaning of Part V of the UK Criminal Justice Act 1993 or any
other applicable legislation.
In accordance with operational guidelines that may apply to publicly listed companies in the
United Kingdom or the European Union, such as The Takeover Panel Guidelines, you may
have to report declarable interests during a bid period if trading a Product whose underlying
Instrument is or relates to any such company. Please ensure that you are aware of yourresponsibilities in this regard.
In the event that you place any Transaction in breach of the representations and warranties
given above, or we have grounds for suspecting that you have done so, we may at our absolute
discretion and without being under any obligation to do so or to inform you of our reason for
doing so, close that Position and any other Positions that you may have open at the time related
to any Instrument and also at our absolute discretion we may:- (i) enforce the Position or19

Positions against you if it is a Position or Positions under which you have lost money to us; or(ii) treat all your Positions closed under this clause as void if they are Positions under which
we would otherwise be obliged to pay money to you, unless and until you produce conclusive
evidence that you have in fact not committed the breach of warranty and/ or misrepresentation
the suspicion of which was the ground for closing your Position. For the avoidance of doubt if
you do not produce such evidence within the period of six months all such Positions will befinally null and void as between us.
27.2

Any misrepresentation made by you under this paragraph and/or breach by you of the warranties given
by virtue of this paragraph will be an Event of Default.

27.3

We will not transfer voting rights relating to an underlying share to you or otherwise allow you to
influence the exercise of voting rights held by us or on our behalf.

28.

REPRESENTATIONS AND WARRANTIES

28.1 It is a condition of this Agreement that you agree with the confirmations ("representations") and statements("warranties") below as we provide services to you in reliance on them. You must notify us
immediately if any of them cease to be correct for as long as this Agreement remains in place andprior to each Transaction.
28.2 You make the following general representations and warranties to us:(a)your Registration Data is accurate, up-to-date and does not omit any important information ofwhich we should be aware;(b)

you are of sound mind and legal competence;(c)this Agreement (and each Transaction) has been validly entered into and is legally binding on
you;

(d)

you are not a Prohibited Customer;(e)

you are and will continue to comply with the terms of this Agreement and Applicable Law;(f)

any money or assets you supply to us for any purpose are unencumbered;(g)

you will not take any action which interrupts, or may interrupt, the provision of the Trading
Platform, or enter or seek to enter into Transactions that we consider to amount to any form ofmarket abuse, market manipulation or manipulation of our Trading Platform;(h)you will not enter into any Transaction to exploit any temporal and/or minor inaccuracy in any
price or Quote; and(i)you have not and will not grant a security interest in the Account or its assets to any entity or
person without our prior written consent.

28.3 We make the following general representations and warranties to you:

29.

(a)

we will exercise all reasonable care and skill in providing the agreed services to you; and(b)

we have obtained and will maintain all necessary consents, authorisations, approvals or
licences and will take all necessary steps to comply with all Applicable Law and the terms ofthis Agreement.

HOW WE MAY USE YOUR PERSONAL AND SENSITIVE PERSONAL DATA

29.1 We collect and use information about you while providing the services to you. This may include personal
data and sensitive personal data each as defined in the United Kingdom Data Protection Act 2018.
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29.2 We will be the data controller of such personal data and will process your personal data in accordance with
our Privacy Policy which is available on our Website. The Privacy Policy will form part of yourAgreement with us.
29.3 You are entitled to receive information about the processing of personal data concerning you. We will, on
your request or may on our own initiative, rectify any error detected. For more information about yourrights and to control the way in which we use your personal data please review our Privacy Policy,
which is available on our Website.
29.4 We may hold and retain information about you in order to comply with regulatory and legal obligations.
29.5 We may transmit your personal data to OANDA Related Entities and third parties in connection with ourbusiness (including, without limitation, such entities or persons located in countries without dataprotection safeguards that would be deemed adequate under UK standards), including, without
limitation, for the purposes of:(a)meeting obligations and disclosure requirements of any governmental entity or regulatory
authority, brokers or other intermediaries or counterparties;(b)

managing and administering the relationship between you and us;(c)complying with Applicable Law, including, without limitation, anti-money laundering and antiterrorism laws and regulations and fighting crime;(d)assigning or sub-contracting, procuring goods or services for, or outsourcing any part of the
our normal business functions to third parties;(e)monitoring our services, whether provided by ourselves or a third party; and(f)communicating with credit reference and information agencies.

29.6

We may do anything or disclose any matters without notice to you which:(a)we consider to be required by, or desirable in respect of, any Applicable Law, or requested byany competent government entity or regulatory authority; or(b)

are required to enable any service under this Agreement to be provided.

29.7

We may monitor and record all our communications with you without the use of a warning tone or othernotification.

29.8

The client confidentiality obligations set out in this Agreement and in our Privacy Policy do not and will
not apply to, and in respect of, any confidential information required to be disclosed (by us or you)pursuant to any Applicable Law, or the lawful request of any court of competent jurisdiction,
government agency, or regulatory body, provided in each case you (or we) notify and consult with us(or you) in advance and as to the timing and content of such disclosure, except where Applicable Law
prohibits us (or you) from doing so.

30.

OUR RIGHTS IN THE TRADING PLATFORM – INTELLECTUAL PROPERTY AND MARKET DATA

30.1 We (or our licensors) own all the Intellectual Property Rights in the Trading Platform and all derivatives of
the Trading Platform. We do not grant you any right or interest in the Trading
Platform other than the licence granted in paragraph 17.1, and in accordance with the terms of that
section.
30.2 You confirm that:(a)you will not copy, record, translate or amend the whole or any part of the Trading Platform;(b)

you will not attempt to derive any source code for the Trading Platform;
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31.

(c)

you will use your best efforts to protect our Intellectual Property Rights from being infringed by
you or any person acting on your behalf;(d)you will immediately notify us in writing if you become aware that the Trading platform is being
used in a manner not authorised by this Agreement; and(e)you understand that we have a proprietary interest in all Market Data and that we reserve theright to disseminate or transmit such Market Data to any OANDA Related Entity, or to any third
party with which we have a written agreement, provided that to the extent any suchdissemination or transmission is made for commercial purposes, such Market Data shall havebeen aggregated and anonymized such that its dissemination or transmission does not identify
that you are the specific source of such Market Data or other information.

YOUR RIGHTS
Reporting errors

31.1 If you think your Transaction History is wrong or contains an error, or if you need more information about
any Transaction listed in your Transaction History, we must hear from you no later than 30 days after
the date on which the problem or error first appeared in your Transaction History. When you contact
us you must:(a)provide your name and account number; and(b)describe the error, or Transaction you are unsure about, and explain as clearly as you can why
you believe it is an error or why you need information.

31.2 If you provide this information orally, we may require that you send your complaint or question in writing
within ten Business Days. We will determine whether an error occurred within ten Business Days after
hearing from you and will correct any error promptly. If more time is needed, we may take up to 45
calendar days to investigate your complaint or question, although in extenuating circumstances wemay take longer (in which case we will keep you fully informed). If we ask you to put your complaint orquestion in writing and we do not receive it within ten Business Days, we will conclude that theTransaction in question is correct and no error was reported. If we decide that there is no error, we will
send you a written explanation.
Complaints
31.3 We aim to provide you with the highest standard of service. However, we recognise that you may on
occasion be dissatisfied with some parts of our service. If you would like to make a complaint about
our service, you should email: ogmdisputes@oanda.com or write to: Compliance Department, OANDA
Global Markets Limited, MCS BVI, Kingston Chambers, PO Box 173, Road Town, Tortola, British
Virgin Islands. Details of our complaints handling procedures are available on our Website.

32.

ADJUSTMENTS AND TAKEOVERS

32.1 If any Instrument becomes subject to possible adjustment as a result of a “corporate action” (as defined inparagraph 32.4) affecting a related Instrument, except for forward and reverse stock splits, we will in oursole discretion determine the appropriate cash adjustment, if any, to be made to or from your Account toaccount for the diluting or concentrating effect necessary to preserve the economic equivalence of therights and obligations of the parties in relation to the related Position immediately prior to that corporate
action or event.
32.2 In the event that a cash adjustment results in a negative balance on your account you will be liable for paymentof any negative balance which will become immediately due and payable.
32.3 In the event that a cash adjustment results in insufficient funds being available on your account to meet the
Margin Requirement to maintain any open Positions, the open Positions may be subject to a Margin
Closeout.
2232.4 The events constituting a corporate action (as referenced in paragraph 32.1) include the declaration by theissuer of an Instrument (or, if the Instrument is itself a derivative, the issuer of the security underlying that
Instrument) of the rules of any of the following:(a)a subdivision, consolidation or reclassification of shares, a share buy-back or cancellation, or afree distribution of shares to existing shareholders by way of a bonus, capitalisation or similar
issue;(b)a distribution to existing holders of the underlying shares of additional shares, other share capitalor securities granting the right to payment of dividends and/or proceeds of liquidation of the issuer
equally proportionately with such payments to holders of the underlying shares, or securities,
rights or warrants granting the right to a distribution of shares or to purchase, subscribe or receive
shares, in any case for payment (in cash or otherwise) at less than the prevailing market priceper share as determined by us;(c)any other event in respect of the shares analogous to any of the above events or otherwise having
a diluting or concentrating effect on the market value of the shares; or(d)any event analogous to any of the foregoing events or otherwise having a diluting or concentrating
effect on the market value of any Instrument not based on shares.
32.5

In the event of certain corporate actions, Pending Orders on the related Instrument may be cancelled.
Details are available on our Website.

32.6

All cash adjustments will be determined reasonably and will be conclusive and binding upon you. We will
inform you of all such cash adjustments via transaction comments on your Account.
Cash adjustments on Buy Positions will be net of any applicable taxes and charges, and on Sell Positions
will be paid gross. Details are available on our Website.

32.7

32.8

Forward and reverse stock splits, whereby the issuer of an Instrument (or, if the Instrument is itself aderivative, the issuer of the security underlying that Instrument) increases and reduces, respectively, thenumber of shares in the market at a certain stated ratio based on the size of current holdings, are subject
to the following actions:a)Forward stock splits: for both Buy and Sell Positions, the size of your Position will be increased inaccordance with the ratio, with any fractional element being passed as a cash adjustment to yourAccount.

b)

Reverse stock splits: for both Buy and Sell Positions, the size of your Position will be reduced inaccordance with the ratio, with any fractional element being passed as a cash adjustment to yourAccount.

32.9

If at any time a take-over or merger offer is made in respect of a company, then at any time prior to theclosing date of such offer we may give notice to you of our intention to close a Position in respect of thatcompany’s securities. The date of such notice will be the closing date and the closing level will be suchprice as we notify to you. References to ‘’offer’’, ‘’takeover’’, “merger” and ‘’closing date’’ in this provision
have the meaning given to them in the UK City Code on Take-overs and Mergers, as amended from time
to time. These expressions will, to the extent necessary, be applied by us (using our reasonablediscretion) to analogous events on any non-UK stock exchange.

32.10

In the event that there is declared, or paid in respect of any Instrument, a special dividend or a dividend
that is unusually large or payable by reference to an ex-dividend date that is unusually early or late (ineach case, having regard to dividend payments in previous years in respect of that same Instrument), we
may make an appropriate cash adjustment (including a retrospective adjustment) by debit or credit toyour Account.

32.11

For more complex corporate actions or events we will inform, by email, holders of impacted Positions
how their Positions will be affected and any associated cash adjustments.

32.12

Debit and credit cash adjustments to your Account, which will be made in your Base Currency, will beannotated with appropriate descriptions to show the impacted Position and type of adjustment that has
been made. Details are available on our Website.

33.

SUSPENSION AND INSOLVENCY
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33.1 If at any time trading is suspended in any Instrument that forms the subject of a Position, the Position inquestion will also be suspended from trading. The value of the Position, unless revalued by us as set out
in this paragraph, will be based on the price quoted by the relevant Exchange at the time of suspension.
33.2 Irrespective of any instructions given by you (including an instruction to close) or any Pending Orders given
by you in place on your Account, a Position on a suspended Instrument will remain open but suspended
until such time as either the suspension is (a) lifted or (b) the stock is delisted and can be settled
accordingly.
(a)Upon the lifting of suspension and the recommencement of trading, any Orders that are
attached to the Position that have been triggered on the next last price will be executed as soon
as is reasonable in the circumstances, having regard to the liquidity in the underlying market
and any hedging transactions that we may need to execute with a third party in order to hedge
our exposure to you. Due to the potential volatility upon the recommencement of trading, wecannot guarantee that Pending Orders will be executed at the first available underlying price.
(b)
Where the Position relates to the price of shares in a company that has been delisted from theunderlying Exchange, gone into liquidation or otherwise become insolvent or has been
dissolved, we will close your Position in accordance with paragraph 33.3.
33.3 If a company, whose shares represent all or part of the subject-matter of a Position, goes into liquidation orotherwise becomes insolvent, or is otherwise dissolved or de-listed by the underlying market by reasonof the length of its suspension, the day on which the company goes into liquidation, or otherwise becomesinsolvent, or is otherwise dissolved or de-listed will be the closure date of that Position. We will deal withyour Position in the following manner, unless we are treated in an alternative manner by our liquidity
provider, in which case such treatment as is reasonable will be applied to your affected Position:(a)
If you hold a Buy Position, the closing level of the Position will be zero. If a company makes a
distribution to shareholders, an amount equalling the distribution will be credited to your Account.
(b)
If you hold a Sell Position, the closing level of the Position will be zero. If a company makes a
distribution to shareholders, an amount equalling the distribution will be debited from yourAccount. We reserve the right to require you to maintain Margin on this Position, which could be,
for the avoidance of doubt, as much as the difference between the suspension price and zero.

33.4 Notwithstanding the above, if a company, whose shares represent all or part of the subjectmatter of a Position,
is delisted from the exchange to which the Position relates, but at the time of delisting such company has
not gone into liquidation or otherwise become insolvent, then we will take such action to the Position as
is fair, taking into account the circumstances regarding the delisting and any hedging arrangements wehave with our brokers. Examples of actions we may take include but are not limited to:(a)closing the Position at a price that is based on our fair and reasonable assessment of the valueof the underlying Instrument to which the Position relates;(b)changing the Exchange to which the Position refers;(c)closing the Position at zero, as per the above provision;(d)maintaining the suspension of the Position until the company makes a distribution toshareholders of the underlying security, at which point if possible and taking into account ourown hedging arrangements, we will reflect the distribution on your Position by way of a cash
adjustment to your Account.
33.5 We reserve the right at all times during the term of a Position where the underlying Instrument is suspended
to both:a)revalue such Position at such price and/ or to change the Margin rate, in both cases as isreasonable in the circumstances and to require payment of Margin accordingly; andb)cancel any Pending Orders on the related Instrument.

If the Position remains open until such time as the suspension is terminated, which, for the avoidance of
doubt, can occur without warning or notice to us, any remaining Pending Orders that you may have given
us with respect to that Position will be executed as soon as is reasonable in the circumstances. We
cannot guarantee that a Pending Order will be executed at the first available underlying market price.

34.

SHORT SELLING
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34.1 Funding Charges. In certain instances, short sales of share CFDs may be allowed depending on theunderlying product, as well as regulatory restrictions, stock loan and borrow market conditions and otherfactors. When you hold a Sell Position (i.e., you are shorting a stock) you may incur a Funding Charge,
as defined herein. For stocks that can be shorted in the underlying market, this funding charge will be
the applicable rate in the underlying market from time to time plus a reasonable charge (the “Funding
Charge”). If there is no underlying funding available in the stock, we may still allow you to place a sell
Transaction against our overall long book exposure if we judge that we have sufficient customers who
are long. In such a case, the cost of funding will be higher to reflect the lack of availability in the underlying
market and we will be entitled to charge any rate that is not commercially unreasonable. Please notehowever, that Funding Charges relating to open Positions may vary with little or no notice as theunderlying market rate changes and/or our overall book changes. To determine whether a Funding
Charge applies to your Sell Position please refer to the information available on both the trading platform
and on our Website.
34.2 Stock Call Back. We will be entitled to close your open Sell Position at the prevailing market price if ourunderlying short hedge is forcibly closed by our brokers or counterparty.
34.3 We will also be entitled to close your open Sell Position if we have hedged your Position internally and the
makeup of our book alters with the result that we no longer have sufficient clients who are long to enable
us to maintain such a hedge. It will be for us to judge in our absolute discretion whether any alteration in
the makeup of our book has led to this result.

35.

TELEPHONE RECORDINGS
You agree that we may record any telephone conversations between you and us and that any suchrecordings may be submitted in evidence in any proceedings relating to this Agreement or any
Transaction.

36.

NOTICES36.1 All notices given by us to you will be given by e-mail from an @oanda.com email address or by post to theaddress provided by you when applying for your Account or subsequently updated on your Account.
36.2 You can submit notices to us by email or post using the details in paragraph 2.
36.3 Communication will be considered to be received by us or you as follows:

37.

(a)

if hand delivered, upon delivery;(b)

if by email, on the next business day after transmission;(c)

if sent by overnight courier, upon receipt and a signature will be proof of delivery; and(d)if sent by certified mail, the business day after the date of delivery indicated on the receipt
issued by the relevant postal service

GENERAL LEGAL TERMS
Exercising of Rights

37.1 You must comply with the terms of this Agreement even if we do not insist that you do something you arerequired to do under this Agreement, or if we delay in taking steps against you for breach of thisAgreement.
Action by Us25

37.2 We are entitled, at any time and without notice to you, to take or not take any action to ensure compliancewith Applicable Law. If there is any conflict between the provisions of this Agreement and the Applicable
Law, the Applicable Law shall prevail.
Severability
37.3 If any court or relevant authority finds any part of this Agreement to be invalid or unenforceable, the remaining
parts of this Agreement will remain in full force and effect.
Third Party Rights
37.4 The Agreement is between you and us. Except as expressly provided elsewhere in the Agreement, nobody
else shall have any rights to enforce any of its terms.
Governing Law and Jurisdiction
37.5 The Agreement is governed by English law and the courts of England and Wales will have non-exclusive
jurisdiction to settle any disputes.

ANNEX 1 - DEFINITIONS"Account"means your Account with us and comprises of your landing account(s)and trading account(s) (for trading on the Trading Platform)"Account Adjustment"

means any debit or credit which we make to your Account, as a result of,without limitation, any deposit or withdrawal of funds, realised profits,
realised losses, Service Charges,
Financing Costs (Financing charges of Financing credits), or Invalid
Transactions"Access Code"means your account number and the unique password you use to accessand use the Trading Platform“Agreement”

has the meaning given to it under paragraph 1.4"Applicable Law"means BVI Financial Services Commission rules or any other rules of a
relevant regulatory authority and all other applicable laws, rules andregulations as in force from time to time

"Authorised Person"means you or any of your authorised officers, partners, principals or
employees"Attorney"

has the meaning given to it under paragraph 19 (Power of Attorney)"Base Currency"

means the currency in which your trading account is denominated"Buy"means a Position that is opened by offering to buy a specific quantity ofa certain Instrument, and may also be referred to as a "long" or "longPosition" in our dealings with you, and always concluded on and inaccordance with the terms of the Trading Platform"Business Days"

means any day other than a Saturday or Sunday or public holiday where
the banks are open for general commercial business in Tortola, BVI

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"CFD"

means a contract for difference, being a contract that you enter into withus, for the Difference between the value of an Instrument as specified on
the Trading Platform at the time of opening a Position, and the value ofsuch Instrument at the time of closing the Position"Client Money"means money of any currency that we receive or hold for you, or on yourbehalf, in the course of or in connection with, the business contemplatedby the Agreement other than money which is due and payable by you to
us or any third party"Connected Account"means a customer Account which is related to other customer Accounts
by any one or more of the following similar criteria: IP address; name,address; country of registration; password; machine identity; remittancesource"Difference"means the difference in price upon the opening of a Position and theclosing of such Position, plus or minus the spread, as applicable"Event of Default"

means any of the events set forth in paragraph 23.1

"Exchange(s)"means securities or futures exchanges, clearing houses, selfregulatoryorganisations, multilateral trading facilities oralternative trading systems for Instruments“Exchange Market
Size”

A number of shares that are traded on a recognised exchange, that istreated as financially equivalent to the exchange market size intransactions of the underlying share as defined in the rules of theexchange"Financial Data"

means any financial and Market Data, price quotes, news, analyst
opinions, research reports, graphs or any other data or information
whatsoever available through the Trading Platform"Force Majeure Event"has the meaning given to it under paragraph 26"Financing Cost”

means either “Financing Charge” or “Financing Credit”, and reflects thecost of funding an open Position (in relation to the margin utilised). The
Financing Cost is calculated on a per Position basis and may be acharge or a credit, depending on whether the Position is a buy/long
Position or a sell/short Position, and the impact of our admin fee. Does
not apply to ‘Swap Free’ Accounts(“Financing Charge” and“Financing Credit”)"Instrument"

means any stocks, shares, commodities, base or precious metals,
exchange rates, indices, or other financial instruments or security,
which form the underlying
Instruments of the Products offered through the Trading Platform"Intellectual Property
Rights"means patents, trademarks, service marks, logos, get-up, trade names,
internet domain names, rights in designs, copyright (including rights incomputer Software), database rights, semi- conductor topographyrights, utility models, rights in know-how and other intellectual property
rights, in each case whether registered or unregistered and including
applications for registration, and all other rights or forms of protection
having equivalent or similar effect anywhere in the world

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"Invalid Transaction"means any Trade which we reasonably determine was executed:using an erroneous or otherwise incorrect price; in violation of any
Applicable Law; to exploit any temporal and/or minor inaccuracy in,
and/or any delay in the display of, any price; as a result of, or to takeadvantage of, any operator error or error in the Trading Platform
Software; or in violation of any of our rules or regulations publishedon our Website"Manifest Error"

means any error that we reasonably believe to be obvious or palpable,
including without limitation, offers to execute Transactions for
exaggerated volumes of Instruments or at manifestly incorrect market
price quotes or prices at a clear loss

"Margin"means the minimum amount of available money needed on your trading
account in order to execute a Transaction, as specified on the Trading
Platform from time to time for each specific Instrument"Margin Call"has the meaning given to it under paragraph 9.5"Margin Closeout"means the automatic closing of all your Open Positions by the Trading
Platform, which occurs when the amount in your trading account does
not meet the Margin Requirement“Market Abuse”

unlawful behaviour in financial markets including insider dealing,
unlawful disclosure of inside information and market manipulation“Market Data”

means any information entered into and/or created or displayed on the
Trading Platform, including without limitation price, size, date and timeof entry of each Order submitted to the Trading Platform, date and timeof execution of each Transaction executed on the Trading Platform, andany information that can be derived from the foregoing“Market Order”

has the meaning given to it under paragraph 11"Margin Requirement"

has the meaning given to it under paragraph 9.3"Normal Market Size"means the maximum number of units of an Instrument that we believe an
Exchange trading in such an Instrument can comfortably handle, having
regard, if appropriate, to the normal market size set by such an
Exchange or any other equivalent or analogous level set by the
Exchange on which the Instrument is traded“OANDA Group”"Order"means OANDA Global Markets Limited together with all OANDA Related
Entities
means a legal entity that at any time directly or indirectly controls or iscontrolled by or is under common control with OANDA Global Markets
Limitedmeans a Market Order or a Pending Order"Pending Order"

has the meaning given to it under paragraph 11"Position" or "Open
Position"means your Position in relation to any of our Products currently open on
your Account"Privacy Policy"“Product”

means our privacy policy which can be found on our Website
means any type of CFD offered for trading on the Trading Platform"Prohibited Customer"

means a person or entity who is subject to any sanctions or a person towhom we are legally prohibited from providing our services“OANDA Related
Entity”

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"Registration Data"

has the meaning given to it under paragraph 8.8"Scalping"means a trading strategy based on the premise that the client opens alarger than average number of Positions and closes them usually withina two minute timeframe in order to accumulate quick profits from small
price changes"Sell"

means a Position that is opened by offering to sell a specific quantity ofa certain Instrument, and may also be referred to as a "short" or "short
Position" in our dealings with you, and always concluded on and inaccordance with the terms of theTrading
Platform"Service Charge"means any incidental charge payable by you on your Account pursuant
to our policies in place from time to time, including without limitation any
banking charge or wire/ bank transfer charge"Software" or "Trading
Platform Software"means the software we provide which you may download in order to use
the Trading Platform“Stock Call Back”

The circumstance where a lender of stock to us that we have used tohedge a short Position of yours calls the stock back, with the result that
our hedge comes to an endmeans software provided by third parties embedded or used in the
Trading Platform"Third Party Software""Third Party Software
Licences"means licences from third parties governing Third Party Software
embedded or used in the Trading Platform"Trade"means an Order executed by us"Trading Hours"means the hours of trading, as displayed on the Trading Platform andWebsite, for a particular Instrument"Trading Platform"

means the proprietary OANDA fxTrade electronic trading platform
facility, MT4, MT5 or any other trading platform offered by OANDA (which
may from time to time be governed by a supplemental agreement)(together with any other programs, tools, services, upgrades, bug fixes
and updates if any, and its underlying code) however you access it(including via our Website or by downloading our app)

"Transaction"refers to either the opening or closing of either a Buy or Sell Position for
a Product or an Instrument on the Trading
Platform, in accordance with the terms of this Agreement"Transaction History"means the online history of Transactions occurring on your Account,accessible to you via the Trading Platform and your portal"Website"means www.oanda.com

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