Risk Disclosure and Warnings Notice
Version 6, May 2023

1. Introduction

1.1 This Risk Disclosure and Warning Notice (the ‘Notice’) is provided to you
(hereinafter the “Client” or the “Prospective Client”) in compliance with the
Investment Services and Activities and Regulated Markets Law of 2017, as
subsequently amended from time to time (hereinafter the “Law”), which is
applicable to Key Way Investments Ltd (hereinafter the “Company”).

1.2 All Clients and Prospective Clients should read carefully the following risk
disclosure and warnings contained in this Notice, before applying to the
Company for a trading account and before they begin to trade with the
Company. However, it is noted that this document cannot and does not disclose
or explain all the risks and other significant aspects involved in dealing in
financial instruments and how these relate to the Client’s personal
circumstances. The Notice was designed to explain in general terms the nature
of the risks involved when dealing in financial instruments on a fair and nonmisleading basis.

1.3 By agreeing to the Company’s Terms & Conditions when opening a trading
account with the Company, the Client also declares that they understand the
risks involved as these are presented in this Notice. It is important that the Client
remains aware of the risks involved, that they have adequate financial resources
to bear such risks and that they monitor their positions carefully.

1.4 The Company provides investment services in relation to the following Financial
Instruments:

a) Financial contracts for differences. (“CFDs”) in stocks, commodities,
indices and currency pairs (FX), etc., and;
b) Transferable Securities (hereinafter the “Securities”)
c) Units in Collective Investment Undertakings (hereinafter the “ETFs”)
For the purposes of this Notice, CFDs, Securities and EFTs may be referred to jointly
as ‘Financial Instruments’. However, the risks the Client may be exposed to vary,
depending on the types of Financial Instruments they invest in. We note that the
Company only offers UCITS ETFs.

2. Charges and taxes

2.1 The Provision of Services by the Company to the Client is subject to fees and
charges; more information is available on the Company’s website. Before the
Client begins to trade or accept any services from the Company, he should
obtain details of all fees, commissions, charges and taxes for which the Client
will be liable. The Company reserves the right to amend its fees, commissions
and charges at any time, and the client shall be notified of such amendments
accordingly. However, it is advisable that the Client should check on random
basis if any changes were implemented on the Company’s Policies.

2.2 The Company may change its charges at any time, according to the provisions
of the Client Agreement found on the Company’s website.

2.3 There is a risk that the Client’s trades in any Financial Instruments may be or
become subject to tax and/or any other duty for example because of changes
in legislation or his personal circumstances. The Company does not warrant
that no tax and/or any other stamp duty will be payable. The Company does not
offer tax advice and recommends the Client to seek advice from a competent
tax professional if the Client has any questions.

2.4 The Client is responsible for any taxes and/or any other duty which may accrue
in respect of his trades.

2.5 It is noted that taxes are subject to change without notice.

2.6 If required by applicable Law, the Company shall deduct at source from any
payments due to the Client such amounts as are required by the tax authorities
to be deducted in accordance with applicable Law.

2.7 It is possible that other costs, including taxes, relating to Clients’ transactions in
Financial Instruments carried out on the Trading Platform to arise, for which the
Client is liable and which are neither paid via us nor imposed by the Company.
Although it is the Client’s sole and entire responsibility to account for tax due
and without derogating from this, the Client agrees that the Company may
deduct tax, as may be required by the applicable law, with respect to his trading
activity on the Trading Platform. The Client is aware that the Company has a
right of set-off against any amounts in the Client’s Trading Account with respect
to such tax deductions.

2.8 It is noted that the Company’s prices in relation to CFDs trading are set/quoted
in accordance with the Company’s Best Interest and Order Execution Policy
which is available on the Company’s website It is noted that the Company’s
prices may be different from the prices reported elsewhere. The prices
displayed on the Company’s Trading Platform reflects the last known available
price at the moment, prior to placing any Order, however, the actual execution
price of the Order may differ, in accordance with the Company’s Best Interest
and Order Execution Policy and Client Agreement. As such, the price that the
Client receives when he opens or closes a position may not directly correspond
to real time market levels at the point in time at which the sale of the CFD occurs
or reflect the prices of third-party brokers/providers.

2.9 All prices quoted by the Company in relation to Securities and ETFs are
provided by Safecap Investments Ltd and are indicative of the market price at
which the Clients’ Orders will be executed. Clients’ orders on Securities and
ETFs will be received by the Company and transmitted for execution to a thirdparty Execution Broker, EXT Ltd. Consequently, the Client runs the risk of the
price at which their order on a Security/ETFs is executed, deviates significantly
from the required/expected price quoted by the Company.

2.10 Moreover, regulatory changes could give rise to unexpected and material price
adjustments that could impact the Client’s potential profits or losses. This may
apply for certain jurisdictions more than others, it may affect the Client’s
investment in certain securities more than others.

3. Third Party Risks

3.1 It is understood that the Company will promptly place any Client money it
receives into one or more segregated account(s) (denoted as ‘clients’ accounts’)
with reliable financial institutions (within or outside Cyprus or the EEA) such as
a credit institution or a bank authorized in a third country. Although the Company
shall exercise due skill, care, and diligence in the selection of the financial
institution according to Applicable Regulations, it is understood that there are
circumstances beyond the control of the Company and hence the Company
does not accept any liability or responsibility for any resulting losses to the Client
as a result of the insolvency or any other analogous proceedings or failure of
the financial institution where the Client’s money will be held.

3.2 The financial institution (of paragraph 3.1.) where the Client’s money will be held
may be within or outside Cyprus or the EEA. It is understood that the legal and
regulatory regime applying to any such financial institution outside Cyprus or
the EEA will be different from that of Cyprus. Hence, in the event of the
insolvency or any other equivalent failure or proceeding of that person, the
Client’s money may be treated differently from the treatment which would apply
if the money was held in a Segregated Account in Cyprus.

3.3 The financial institution to which the Company will pass Client money (as per
paragraph 3.1.) may hold it in an omnibus account. Hence, in the event of the
insolvency or any other analogous proceedings in relation to that financial
institution, the Company may only have an unsecured claim against the financial
institution on behalf of the Client and the Client will be exposed to the risk that
the money received by the Company from a financial institution is insufficient to
satisfy the claims of the Client.

3.4 The Company places orders for execution to a third-party Execution Venue i.e.,
the Company is not the Execution Venue for the execution of the Client’s Orders.
The Company transmits Client Orders or arranges for their execution with a third
party/(ies) known as Straight Through Process (STP and is explained in the
“Summary Best Interest and Order Execution Policy” found at Best Execution
Policy). In the event of a lack of liquidity of the Liquidity Provider after a
successful Order for the Client, the Company will not be in a position to settle
the transaction for the Client (i.e., pay the Client the Difference of his successful
trade).

3.5 With respect to trading in Securities and ETFs, these shall be purchased and
held by the Company in an account under the Company’s name, on behalf of
the Client.

3.6 The Clients’ Securities and ETFs will be pooled together with other Clients’
Securities and ETFs in the account under the Company’s name, with its thirdparty Execution Broker. It may not be possible to separate one Client’s
Securities and ETFs from those of other Clients. Hence, in a Corporate Event,
that causes changes to one or more financial instruments (e.g. share
consolidations, share splits, re-organisations, mergers, take-over offers (and
similar), name changes and rebranding, dividend distributions, insolvency, delistings and changes to applicable Law or regulation) the Company will use
reasonable endeavours to make the necessary adjustments in Clients’ accounts
in a way that is fair and aligns with market practice. However, the Company may
be required to close out open positions impacted by a Corporate Event. When
Corporate Events (such as partial redemptions) affect some but not all of the
investments held in the account under the Company’s name, the Company may
allocate the investments so affected to particular clients in such fair and
equitable manner as the Company considers appropriate (which may without
limitation involve pro-rata allocation).

4. Insolvency

4.1 The Company’s insolvency or default or the third-party Execution Broker’s
insolvency of default, may lead to positions being liquidated or closed out
without the Client’s consent. The third-party Execution Broker’s liquidation or
default, Clients’ orders in Financial Instruments may be transferred to another
broker.

4.2 In relation to trading in Securities and ETFs, and more specifically in shares of
listed entities, the Client runs the risk of insolvency of the specific listed entity,
which may drastically reduce the value of the Client’s investment. The Client
may potentially lose their entire capital invested.

5. Investor Compensation Fund

5.1 The Company participates in the Investor Compensation Fund for clients of
Investment Firms regulated in the Republic of Cyprus. Claims of the covered
Clients against the Company may be compensated by the Investor
Compensation Fund where the Company is unable, due to its financial
circumstances. Compensation shall not exceed twenty thousand Euro (EUR
20,000) for each entitled Client. For more details, please refer to the “Investor
Compensation Fund” found on our website at Investor Compensation Policy.

6. Technical risks

6.1 The Client and not the Company shall be responsible for the risks of financial
losses caused by failure, malfunction, interruption, disconnection or malicious
actions of information, communication, electricity, electronic or other systems,
which are not the result of gross negligence or willful default of the Company.

6.2 If the Client undertakes transactions on an electronic system, he will be exposed
to risks associated with the system including the failure of hardware, software,
servers, communication lines and internet failure. The result of any such failure
may be that his order is either not executed according to his instructions or it is
not executed at all. The Company does not accept any liability in the case of
such a failure, not owed to the Company’s gross negligence or willful default.
The Company strives on a best effort basis to provide the Client with a secure
and smooth online experience. However, the Client acknowledges the risk that
should third parties (hackers) launch a coordinated attack against the Company
systems that there may be a disruption of services that may result in Client
losses. The Company does not accept any liability resulting from such attacks
to the extent that the Company has taken all reasonable measures on a best
effort basis to fend off such malicious actions.

6.3 The Client acknowledges that the unencrypted information transmitted by
e-mail is not protected from any unauthorized access.

6.4 At times of excessive deal flow the Client may have some difficulties to be
connected over the phone or the Company’s Platform(s)/system(s), especially
in fast Market (for example, when key macroeconomic indicators are released).

6.5 The Client acknowledges that the internet may be subject to events which may
affect his access to the Company’s Website and/or the Company’s trading
Platform(s)/system(s), including but not limited to interruptions or transmission
blackouts, software and hardware failure, internet disconnection, public
electricity network failures or hacker attacks. The Company is not responsible
for any damages or losses resulting from such events which are beyond its
control or for any other losses, costs, liabilities, or expenses (including, without
limitation, loss of profit) which may result from the Client’s inability to access the
Company’s Website and/or Trading System, or delay, or failure, in sending
orders or Transactions, not owed to the Company’s gross negligence or willful
default.

6.6 In connection with the use of computer equipment and data and voice
communication networks, the Client bears the following risks amongst other
risks in which cases the Company has no liability for any resulting loss:

a. power cut of the equipment on the side of the Client or the provider, or
communication operator (including voice communication) that serves the
Client;
b. physical damage (or destruction) of the communication channels used to link
the Client and provider (communication operator), provider, and the trading or
information server of the Client;
c. outage (unacceptably low quality) of communication via the channels used by
the Client, or the Company or the channels used by the provider, or
communication operator (including voice communication) that are used by the
Client or the Company;
d. wrong or inconsistent with requirements settings of the Client Terminal;
e. untimely update of the Client Terminal;
f. the use of communication channels, hardware and software, generate the risk
of non-reception of a message (including text messages) by the Client from
the Company;
malfunction or inoperability of the Platform, which also includes the Client
Terminal.

6.7 The Client may suffer financial losses caused by the materialization of the above
risks, the Company accepting no responsibility or liability in the case of such a
risk materializing and the Client shall be responsible for all related losses he
may suffer, to the extent that these are not owed to the Company’s gross
negligence or willful default.

7. Trading Platform

7.1 The Client is warned that when trading in an electronic platform he assumes the
risk of financial loss which may be a consequence of amongst other things:

a. failure of Client’s devices, software and poor quality of connection;
b. the Company’s or Client’s hardware or software failure, malfunction or misuse;
c. improper work of the Client’s equipment;
d. wrong setting of Client’s Terminal;
e. delayed updates of Client’s Terminal

7.2 The Client acknowledges that only one Instruction is allowed to be in the queue
at one time. Once the Client has sent an Instruction, any further Instructions
sent by the Client are ignored and the “orders is locked” message appears until
the first Instruction is executed.

7.3 It is understood that the connection between the Client Terminal and the
Company’s Server may be disrupted at some point and some of the Quotes
may not reach the Client Terminal.

7.4 The Client acknowledges that when the Client closes the order placing/ deleting
window or the position opening/closing window, the Instruction, which has been
sent to the Server, shall not be cancelled.

7.5 Orders may be executed one at a time while being in the queue. Multiple orders
from the same Client Account in the same time may not be executed.

7.6 The Client acknowledges that when the Client closes the Order, it shall not be
cancelled.

7.7 In case the Client has not received the result of the execution of the previously
sent Order but decides to repeat the Order, the Client shall accept the risk of
making two Transactions instead of one.

7.8 The Client acknowledges that if the Pending Order has already been executed
but the Client sends an instruction to modify its level, the only instruction, which
will be executed, is the instruction to modify Stop Loss and/or Take Profit levels
on the position opened when the Pending Order triggered.

8. Communication between the Client and the Company

8.1 The Client shall accept the risk of any financial losses caused by the fact that
the Client has received with delay or has not received at all any notice from the
Company.

8.2 The Client acknowledges that the unencrypted information transmitted by
e-mail is not protected from any unauthorized access.

8.3 The Company has no responsibility if unauthorized third persons have access
to information, including electronic addresses, electronic communication and
personal data, access data when the above are transmitted between the
Company and the Client or when using the internet or other network
communication facilities, telephone, or any other electronic means.

8.4 The Client is fully responsible for the risks in respect of undelivered Company
Online Trading System internal e-mail messages sent to the Client by the
Company as they are automatically deleted within 3 (three) calendar days.

9. Force Majeure Events

9.1 In case of a Force Majeure Event the Company may not be in a position to
arrange for the execution of Client Orders or fulfil its obligations under the
agreement with the Client found at Terms and Conditions. As a result, the Client
may suffer financial loss.

9.2 The Company will not be liable or have any responsibility for any type of loss or
damage arising out of any failure, interruption, or delay in performing its
obligations under this Agreement where such failure, interruption or delay is due
to a Force Majeure event.

10. Abnormal Market Conditions

10.1 The Client acknowledges that under Abnormal Market Conditions the period
during which the Orders are executed may be extended or it may be impossible
for Orders to be executed at declared prices or may not be executed at all.

10.2 Abnormal Market Conditions include but not limited to times of rapid price
fluctuations of the price, rises or falls in one trading session to such an extent
that, under the rules of the relevant exchange, trading is suspended or
restricted, or there is lack of liquidity, or this may occur at the opening of trading
sessions.

11. Protection Rights

11.1 When a Financial Instrument is traded in a currency other than the currency of
the Client’s country of residence, any changes in the exchange rates may have
a negative effect on its value, price and performance and may lead to losses for
the Client.

12. Conflicts of interest

12.1 When the Company deals with the Client, the Company, an associate, a
relevant person or some other person connected with the Company may have
an interest, relationship or arrangement that is material in relation to the
Transaction/Order concerned or that it conflicts with the Client’s interest.
The following includes the major circumstances which constitute or may give
rise to a conflict of interest entailing a material risk of damage to the interests of
one or more Clients, as a result of providing investment services:

a) the Company’s bonus scheme may award its employees based on the
trading volume etc.;
b) the Company may receive or pay inducements to or from third parties
due to the referral of new Clients or Clients’ trading.

12.2 For more information about the conflicts of interest and the procedures and
controls that the Company follows to manage the identified conflicts of interest,
please refer to the Company’s Summary Conflicts of Interest Policy found on
the Company’s website at Conflict of interest Policy.

13. Appropriateness

13.1 The Company requires the Client to pass through an appropriateness test
during the application process and warns the Client if trading in Financial
Instruments is not appropriate for him, based on the information provided. Any
decision whether or not to open a Trading Account, and or whether or not you
understand the risks lies with you.

13.2 Unlike CFDs, Securities and more particularly shares of listed entities, and
UCITS ETFs are considered ‘non-complex’ financial instruments. These are not
appropriate for short-term investors. Nevertheless, as with any investment in
financial instruments, the Client needs to understand the risks involved, of losing
their entire investment.

14. Information on risks associated with trading in Securities or ETFs
The price or value of an investment in Securities and ETFs will depend on
fluctuations in the financial markets. Past performance is no indicator of future
performance. Investment risks in Securities include country risk, risks
emanating from the specific characteristics of a Security and ETF including the
location or domicile of the issuer and underwriter, nature of corporate rights that
are associated with a Security etc.
Trading Securities and ETFs is only appropriate for those customers who fully
understand the risks and, ideally, have previous trading experience. If unsure,
it is advisable to seek independent advice.
An indicative analysis of the risks is provided below:
Liquidity risk: The liquidity of a Security is directly affected by the supply and
demand for that Security and also indirectly by other factors, including market
disruptions or infrastructure issues, such as a lack of sophistication or disruption
in the securities settlement process. Under certain trading conditions, it may be
difficult or impossible to liquidate or acquire a position. This may occur, for
example, at times of rapid price movement if the price rises or falls to such an
extent that under the rules of the relevant exchange trading is suspended or
restricted. Placing a stop-loss order will not necessarily limit your losses to
intended amounts, but market conditions may make it impossible to execute
such an order at the stipulated price.
The liquidity of ETFs is determined through the interplay of share creation and
redemption, market-making and secondary market trading, including trading
and hedging activity in related markets. Disruptions to ETF liquidity could arise
through a trading halt in an underlying security. Additionally, market conditions
(e.g. extreme volatility), could increase the costs for providing liquidity. As such,
increase of bid-ask spreads and increase of the cost for clients to exit the
market.
Credit Risk: The risk that the issuer or guarantor of a Security is not able,
usually for financial reasons, to repay principal and/or interest in relation to the
product or to meet its financial obligations in relation to the product, with
resulting loss to the investor.
Market Risk: Market volatility may result in the price of a Security moving
significantly from the time of receipt of a client order to the time of order
execution. Clients should be aware that there are risks associated with volatile
markets, especially at or near the open or close of the standard trading session
and these risks include, but are not limited to:
• Execution at a substantially different price from the last reported price at
the time of Order entry, as well as partial executions or execution of large
orders in several transactions at different prices;
• Delays in executing orders for Securities that our Execution Broker must
send to exchanges and/or manually routed or manually executed orders;
• Opening prices that may differ substantially from the previous day’s
close;
• Locked (the Bid equals the Ask) and crossed (the Bid is higher than the
Ask) markets, which may prevent the execution of Client orders;
Market volatility may result in the price of an ETF moving significantly from the
time of receipt of a client order to the time of order execution. The value of an
ETF and thus the portfolio that holds an ETF may fluctuate with the value of the
underlying securities. As such, ETF prices can be volatile. The overall market
may fall, or the ETFs the client may choose to invest in may perform
undesirably. The company notes that past performance is no indication of future
performance.
Price volatility: is one factor that can affect order execution. When there is a
high volume of Orders in the market, order imbalances and backlogs can occur.
This implies that more time is needed to execute the pending orders. Such
delays are usually caused by the occurrence of different factors:

a. the number and size of orders to be processed;
b. the speed at which current quotations (or last-sale information) are
provided to the Execution Broker and other brokerage firms; and
c. the system capacity constraints applicable to the given exchange, as well
as to the Execution Broker and other firms.
Currency Risk: Where the Securities the Client chooses to trade in are
denominated in currencies other than the default currency of the Client/s
Account (e.g. EUR), fluctuations in foreign exchange rates may impact the
Client’s potential profits and losses.
Operational Risk: Operational risk, such as breakdowns or malfunctioning of
essential systems and controls, including IT systems, can have an impact on
the Client’s trading.
Business risk: risks relating to the business performance of entities the Client
chooses to invest in by trading in certain Securities or ETFs, which include the
businesses of such entities being run poorly; it is noted that corporate decisions
affecting a business’ personnel, organization, operations et al. can have a
serious impact on the value of the Client’s investment.
Voting Rights: Clients may not have voting rights for any of the Securities they
invest in, (these include voting rights with respect to corporate actions such as
tender offers, rights offerings etc.). Furthermore the Client may not have the
opportunity to exercise any voting rights attached to the Securities and ETFs
they invest in.
Dividends: The payment of dividends by a company is not guaranteed.
Furthermore, in case of stock dividends ( i.e. dividends paid in stock rather than
cash), dividends might be received either in the form of shares or in the cash
equivalent. of the value to the number of Shares to which the position will be
entitled. Additionally, Clients’ Securities and ETFs might be subject to corporate
actions such as stock splits.

15. Information on risks associated exclusively with trading in ETFs
Index Risk: ETFs are designed to match an index and are usually passive
investments. Since ETFs are not actively managed, they will not sell an
underlying product if the underlying product’s issuer is in financial trouble,
unless the said product is removed from the index. This means that the ETF’s
price will move in accordance with the index. As such, the performance of the
ETF investment is dependent on the performance of the index.
Counterparty Risk: ETFs do not always hold the physical assets. If the
provider fails, the ETF will lose part or all of the money it has invested. Physical
ETFs that lend securities from their portfolios also expose their investors to
counterparty risk. In this case, investors might suffer losses if a borrower
defaults on its obligations.
Tracking Error Risk: Tracking error represents the difference between the
performance, or return, of the ETF’s portfolio and the underlying index. Tracking
error occurs for a number of reasons. The main is that an ETF has expenses
that an index does not have, because it incurs costs when it buys and sells
securities. The frequency of these transactions, such as how often an ETF
rebalances its portfolio, can increase the costs that increase tracking error and
diminish an ETF’s performance.
The Company notes that the above list is not exhaustive but it contains some of
the main risks the Clients may be exposed to.

16.Information on risks associated with complex financial instruments over
the counter (OTC)

16.1Trading CFDs can put Client’s capital at risk as CFDs are categorized as high
risk complex Financial Instruments and Clients may lose more than the
capital/margin used to open one position, such losses may extend to the loss of
the Client’s entire deposited amount held by the Company. Trading CFDs may
not be suitable for all investors (refer to section 13).
The investment decisions made by the Clients are subject to various markets,
currencies, economic, political or business risks etc., and will not necessarily be
profitable.
The Client acknowledges and without any reservation accepts that,
notwithstanding any general information which may have been given by the
Company, the value of any investment in Financial Instruments may fluctuate
either upwards or downwards. The Client acknowledges and without any
reservation accepts the existence of a substantial risk of incurring losses and
damages as a result of buying or selling any Financial Instrument and
acknowledges his willingness to take such risk.
Set out below is an outline of the major risks and other significant aspects of
CFDs trading.

a) Trading in CFD is VERY SPECULATIVE AND HIGHLY RISKY and is not
suitable for all members of the general public but only for those investors
who:
a. understand and are willing to assume the economic, legal and
other risks involved;
b. taking into account their personal financial circumstances,
financial resources, lifestyle and obligations are financially able to
assume the loss of their entire investment;
c. have the knowledge to understand CFDs trading and the
Underlying assets and Markets.
b) The Company will not provide the Client with any advice relating to CFDs
the Underlying Assets and Markets or make investment
recommendations including occasions where the Client shall request
such advice and/or recommendation. However, the Company may
provide the Client with information and tools produced by third parties on
an “as is” basis (i.e. the Company does not approve, or endorse, or affect
the said information and or tools), which may be indicative of trading
trends or trading opportunities. The Client accepts and understands that
taking any actions based on the information and/or tools provided by third
parties may result in losses and/or general reduction of the value of the
Client’s assets. The Company does not accept liability for any such
losses resulting from actions taken by the Client on the basis of
information and or tools produced by third parties.
c) CFDs are derivative financial instruments deriving their value from the
prices of the underlying assets/markets in which they refer to (for
example currency, equity indices, stocks, metals, indices futures,
forwards etc.). It is important therefore that the Client understands the
risks associated with trading in the relevant underlying asset/ market
because fluctuations in the price of the underlying asset/ market will
affect the profitability of his trade. For more information regarding the
Company’s pricing policy, please refer to the Company’s Summary Best
Interest and Order Execution Policy found at Best Interest and Order
Execution
d) Information on the previous performance of CFDs the Underlying Assets
and Markets does not guarantee its current and/or future performance.
The use of historical data does not constitute a binding or safe forecast
as to the corresponding future performance of the CFDs to which the said
information refers.
e) Volatility:
Some Financial Instruments trade within wide intraday ranges with
volatile price movements. Therefore, the Client must carefully consider
that there is a high risk of losses. The price of a Financial Instrument is
derived from the price of the Underlying Asset in which the Financial
Instruments refers to. Financial Instruments and related Underlying
Markets can be highly volatile. The prices of Financial Instruments and
the Underlying Asset may fluctuate rapidly and over wide ranges and
may reflect unforeseeable events or changes in conditions, none of
which can be controlled by the Client or the Company. Under certain
market conditions it may be impossible for a Client Order to be executed
at declared prices leading to losses. The prices of Financial Instruments
and the Underlying Assets will be influenced by, among other things,
changing the supply and demand relationships, governmental,
agricultural, commercial and trade programs and policies, national and
international political and economic events and the prevailing
psychological characteristics of the relevant marketplace.
f) Liquidity:
Liquidity risk refers to the capacity to readily monetize assets without
suffering a significant discount in their prices. The Client accepts and
acknowledges that the Underlying Instruments on some Derivative
Products on offer by the Company may be inherently illiquid or
sometimes face persistent liquidity strains due to adverse market
conditions. Illiquid Underlying Assets may exhibit high levels of volatility
in their prices and consequently a higher degree of risk, this typically
leads to larger gaps in ASK and BID prices for an Underlying Instrument
than would otherwise prevail under liquid market conditions. These large
gaps may be reflected on the prices of the Derivative Product that the
Company offers.
g) Off-exchange transactions in Derivative Financial Instruments:
CFDs offered by the Company are off-exchange transactions (i.e. overthe-counter).

The trading conditions are set by us (in line with the trading
conditions received by our liquidity providers), subject to any obligations
we have to provide the best execution, to act reasonably and in
accordance with our Client Agreement and with our Best Interest and
Order Execution Policy. Each CFD trade that the Client opens through
our Trading Platform results in the entering of an Order with the
Company; such Orders can only be closed with the Company and are
not transferable to any other person.
While some off-exchange markets are highly liquid, transactions in
off-exchange or non-transferable derivatives may involve greater risk
than investing in on-exchange derivatives because there is no exchange
market on which to close out an Open Position. It may be impossible to
liquidate an existing position, to assess the value of the position arising
from an
off-exchange transaction or to assess the exposure to risk. Prices need
not be quoted, and, even where they are, they will be established by
dealers in these instruments and consequently it may be difficult to
establish what a fair price is.
The Company is using an Online Trading System for transactions in
CFDs which does not fall into the definition of a Regulated Market or
Multilateral Trading Facility and as such does not have the same
protection.
h) No Clearing House protection:
The Transactions in the Financial Instruments offered by the Company
are not currently subject to exchange or clearing house requirements
/obligations.
i) No Delivery:
It is understood that the Client has no rights or obligations in respect to
the Underlying Assets/Instruments relating to the CFDs he is trading.
There is no delivery of the Underlying Asset and all CFD contracts are
settled in cash.
j) Suspensions of Trading:
Under certain trading conditions it may be difficult or impossible to
liquidate a position. This may occur, for example, at times of rapid price
movement if the price rises or falls in one trading session to such an
extent that under the rules of the relevant exchange trading is suspended
or restricted. Placing a Stop Loss will not necessarily limit the Client’s
losses to the intended amounts, because market conditions may make it
impossible to execute such an Order at the stipulated price. In addition,
under certain market conditions the execution of a Stop Loss Order may
be worse than its stipulated price and the realized losses can be larger
than expected.
k) Slippage:
Slippage is the difference between the expected price of a Transaction
in a CFD or, and the price the Transaction is actually executed at.
Slippage often occurs during periods of higher volatility (for example due
to news events) making an Order at a specific price impossible to
execute and also when large Orders are executed when there may not
be enough interest at the desired price level to maintain the expected
price of trade.
l) Leverage and Gearing:
In order to place a CFD Order, the Client is required to maintain a margin.
The Margin is usually a relatively modest proportion of the overall
contract value. This means that the Client will be trading using “leverage”
or “gearing”. This means a relatively small market movement can lead to
a proportionately much larger movement in the value of the Client’s
position, and this can work either against the Client or for the Client.
At all times during which the Client opens trades, they must maintain
enough equity, consider all running profits and losses, for meeting the
margin requirements. If the market moves against the Client’s position
and/or Margin requirements are increased, the Client may be called upon
to deposit additional funds on short notice to maintain his position. Failing
to comply with a request for a deposit of additional funds, may result in a
closure of his position(s) by the Company on his behalf.
It is important that you monitor your positions closely because the effect
of leverage and gearing speed the occurrence of profits or losses. It is
your responsibility to monitor your trades and while you have open trades
you should always be in a position to do so.
m) Margin:
The Client acknowledges and accepts that, regardless of any information
which may be offered by the Company, the value of CFDs may fluctuate
downwards or upwards and it is even probable that the investment may
become of no value. This is owed to the margining system applicable to
such trades, which generally involves a comparatively modest deposit or
margin in terms of the overall contract value, so that a relatively small
movement in the Underlying Market can have a disproportionately
dramatic effect on the Client’s trade. If the Underlying Market movement
is in the Client’s favour, the Client may achieve a good profit, but an
equally small adverse market movement may result in the loss of the
Client’s entire deposit.
The Company may change its Margin requirements, according to the
provisions of the Client Agreement found on the Company’s website at
Terms and Conditions.
n) Contingent Liability Investment Transactions:
Contingent liabilities are potential obligations that may be assumed by
the Client depending on the outcome of an event that was beyond any
person’s control and/or expectations. For example, in case whereby due
to the extreme volatility of the underlying instrument the Client has
sustained losses that exceeded his balance with the Company (i.e. he
has generated a negative balance with the Company), the Client may be
then called to pay an amount equal to these losses.
o) Risk-reducing Orders or Strategies
The Company makes available certain Orders (e.g. “stop-loss” orders,
where permitted under local law, or “stop-limit” Orders), which are
intended to limit losses to certain amounts. Such Orders may not be
adequate given that markets conditions make it impossible to execute
such Orders, e.g. due to illiquidity in the market. We aim to deal with such
Orders fairly and promptly but the time taken to fill the Order and level at
which the Order is filled depends upon the underlying market. In fastmoving markets a price for the level of your Order might not be available,
or the market might move quickly and significantly away from the stop
level before we fill it.
Strategies using combinations of positions, such as “spread” and
“straddle”‘ positions may be as risky as taking simple “long” or “short”
positions. Therefore, Stop Limit and Stop Loss Orders cannot guarantee
the limit of loss.
p) Swap Values
If a Client holds any positions overnight then an applicable swap charge
will apply. The swap values are clearly stated on the Company’s website
and Platform and accepted by the Client during the account registration
process as they are described in the Company’s Agreement.
The swap rate is mainly dependent on the level of interest rates as well
as the Company’s fee for having an open position overnight. The
Company has the discretion to change the level of the swap rate on each
CFD at any given time and the Client acknowledges that he will be
informed by the Company’s websites. The Client further acknowledges
that he is responsible for reviewing the CFDs specifications located on
the Company’s websites for being updated on the level of swap value
prior to placing any order with the Company.

17. Advice and Recommendation

16.1 When placing Orders with the Company, the Company will not advise the Client
about the merits of a particular Transaction or give him any form of investment
advice and the Client acknowledges that the Services do not include the
provision of investment advice in any of the Financial Instruments provided by
the Company. The Client alone will enter into Transactions and take relevant
decisions based on his own judgment. In asking the Company to enter into any
Transaction, the Client represents that he has been solely responsible for
making his own independent appraisal and investigation into the risks of the
Transaction. He represents that he has sufficient knowledge, market
sophistication, professional advice and experience to make his own evaluation
of the merits and risks of any Transaction. The Company gives no warranty as
to the suitability of the products traded under this Agreement and assumes no
fiduciary duty in its relations with the Client.
16.2 The Company will not be under any duty to provide the Client with any legal, tax
or other advice relating to any Transaction. The Client should seek independent
expert advice if he is in any doubt as to whether he may incur any tax liabilities.
The Client is hereby warned that tax laws are subject to change from time to
time.

16.3 The Company may, from time to time, and at its discretion, to provide the Client
(or in newsletters which it may post on its Website or provide to subscribers via
its Website or the Trading Platform or otherwise) with information,
recommendations, news, market commentary or other information but not as a
service.
Where it does so:

a. the Company will not be responsible for such information;
b. the Company gives no representation, warranty or guarantee as to the
accuracy, correctness or completeness of such information or as to the tax
or legal consequences of any related Transaction;
c. this information is provided solely to enable the Client to make his own
investment decisions and does not amount to investment advice or
unsolicited financial promotions to the Client;
d. if the document contains a restriction on the person or category of persons
for whom that document is intended or to whom it is distributed, the Client
agrees that he will not pass it on to any such person or category of persons;
e. the Client accepts that prior to dispatch, the Company may have acted upon
it itself to make use of the information on which it is based. The Company
does not make representations as to the time of receipt by the Client and
cannot guarantee that he will receive such information at the same time as
other clients.

16.4 It is understood that market commentary, news, or other information provided
or made available by the Company are subject to change and may be withdrawn
at any time without notice.

18.No Guarantees of Profit

18.1 The Company provides no guarantees of profit nor of avoiding losses when
trading in Financial Instruments. The Company cannot guarantee the future
performance of the Client’s Τrading Αccount, promise any specific level of
performance, or promise that the Client’s investment decisions or strategies, will
be successful/profitable. The Customer has received no such guarantees from
the Company or from any of its representatives. The Customer is aware of the
risks inherent in trading in Financial Instruments and is financially able to bear
such risks and withstand any losses incurred. The Client acknowledges and
accepts that there may be other additional risks apart from those mentioned
above.