1. ABOUT ACG MARKETS LTD

ACG Markets Ltd is a Company incorporated and registered under the laws of Seychelles with Company number 8434915-1. The Company is licensed and regulated as a securities dealer by the Financial Services Authority under license number SD182.

2. APPLICABLE REGULATORY FRAMEWORK AND PURPOSE OF THIS POLICY

The formulation and adoption of this Policy is required under the Financial Consumer Protection Act of 2022. The FCPA 2022 came into force with the aim of strengthening consumer protection and confidence when accessing financial services and products in Seychelles.

The purpose of this Conflicts of Interest Policy (the “Policy”) is to outline a suitable approach and response to the identification and management of conflicts of interest. Specifically, through this policy the Company’s board should ensure that there is no collusion or unfair practices in terms of arrangements.

3. SCOPE AND APPLICABILITY OF THIS POLICY

The Company will take all reasonable steps to identify conflicts of interest between itself, including its managers, employees or any person directly or indirectly linked to the Company by control and its clients or between one client and another that arise in the course of providing the Company’s services.

The Company maintains and operates effective organizational and administrative arrangements to prevent and manage conflicts of interest that may arise during the provision of any services, from adversely affecting the interests of its clients. In case where, the aforementioned arrangements are not sufficient to ensure, with reasonable confidence, that the risks of damage to the interests of the clients will be prevented, the Company shall clearly proceed with the disclosure of such conflict. The said disclosure shall be done in a durable medium indicating the general nature and source of conflicts of interest, the risks to the client with sufficient details so as to allow the client to take an informed decision with the regards to its investment as well as the steps taken to mitigate such risks.

The Company has the right to amend the current Policy at its discretion and at any time it considers is suitable and appropriate. The Company shall review and amend the current policy at least on an annual basis to take account of changes to operations or practices and, further, to make sure it remains appropriate to any changes in law, technology and the general business environment. In case of any amendment, the Company shall notify the Financial Services Authority prior to any changes made within the Policy.

4. IDENTIFICATION OF POTENTIAL CONFLICTS OF INTEREST

To adequately manage conflicts of interest, the Company shall identify all relevant conflicts promptly. The Company will employ different mechanisms to ensure that all conflicts are identified. The Company shall identify all conflicts of interest, their severity and document controls to mitigate the conflicts. It is not possible to list all situations which could constitute a conflict. The facts of each situation will determine whether the interest in question is such as to bring it within the area of potential conflict.

All employees, including management, will be responsible for identifying specific instances of conflict and are required to notify the Compliance function of any conflicts they become aware of. The Compliance Officer (CO) will assess the implications of the conflict and how the conflict should be managed in conjunction with the board. In the case where a specific incident to be reported concerns the CO, the notification shall be made to the Company’s Representative Officer.

For the purposes of identifying the types of conflicts of interest that arise in the course of providing services and whose existence may damage the interests of a client, the Company takes into account, by way of minimum criteria, the question of whether the Company or a relevant person, or a person directly or indirectly linked by control to the Company, is in any of the following situations, whether as a result of providing services or activities:

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

For the purpose of this Policy, a “relevant person”, in relation to the Company means any of the following:

• a director, partner or equivalent, manager, or agent of the Company;
• a director, partner or equivalent, or manager of any agent of the Company;
• an employee of the Company or of an agent of the Company, as well as any other natural person whose services are placed at the disposal and under the control of the Company or an agent of the Company and who is involved in the provision by the Company of services and activities;
• a natural person who is directly involved in the provision of services to the Company or agent under an outsourcing arrangement for the purpose of the provision by the Company of services and activities.

5. MANAGING CONFLICTS OF INTEREST

The Company has established suitable and adequate internal procedures for minimising any potential conflicts of interest. The Company maintains a compliance department that is an independent unit within the Company. Among the duties of the CO is to monitor any possible deviation from the Company’s internal policies and procedures as well as identifying and managing any possible conflicts of interest. Once a conflict has been identified it needs to be appropriately and adequately managed. The Compliance function will assess each conflict and determine if the conflict is actual or perceived and what the value of the conflict or exposure is and the potential reputational risk. Compliance will then decide whether it is viable to go ahead with the transaction or if the conflict is too severe. If Compliance decides that the particular conflict can be mitigated, then controls to manage the conflict should be put in place and documented.

The Company will manage conflicts of interest fairly, between itself and its clients, between itself and its employees and between its customers and organise and control their internal affairs responsibly and effectively.

The Company and its employees should act as per the principle of placing clients’ interests before self-interests and Company’s interests in order to avoid conflicts of interest in the fulfilment of professional activities on the securities market. To ensure client’s fair treatment, the Company will introduce the following procedures:

• The Company shall avoid any conflict of interest with clients and, where such a conflict unavoidably arises, ensure fair treatment of the client by complete disclosure or by declining to act.
• If the Company has a material interest in a transaction to be entered into with or for a client, or a relationship which gives rise to a conflict of interest in relation to the transaction, the Company shall not knowingly either advise, or deal in the exercise of discretion, in relation to that transaction. The only exception is when the Company has fairly disclosed that material interest or relationship, as the case may be, to the client or the client has taken reasonable steps to ensure that neither the material interest nor relationship adversely affect the interests of the client.
• There is a clear distinction between the different departments’ operations as these are described in the Company’s IOM.
• The Company shall be informed promptly of any personal transaction entered into by a relevant person, either by notification of that transaction or by other procedures enabling the Company to identify such transactions. In the case of outsourcing arrangements, the Company shall ensure that the Company to which the activity is outsourced maintains a record of personal transactions entered into by any relevant person and provides that information to the Company promptly on request.
• A person shall be replaced by another person in his/her duties only with prior consent of the CO and approval by the Representative Officer. Such consent will be given by the CO after all issues of possible conflict of interest have been reviewed.
• The security features of the Company’s software prevents unauthorized access to sensitive information in order to benefit the Company over its clients or one client over another.
• The Company’s employees are prohibited from investing in securities for which they have access to non-public or confidential information.
• Transactions by the Company’s employees are neither performed nor executed by themselves, but by another member of staff of the Company concerning account opened with the Company.
• A record shall be kept of the personal transaction notified to the Company or identified by it, including any authorisation or prohibition in connection with such a transaction.
• The Company must take reasonable steps to ensure that neither it nor any of its employees or agents either offers or gives, or solicits or accepts, any inducement that is likely to conflict with any duties owed to its clients.
• No employee shall either knowingly or recklessly make a statement, promise or forecast that is misleading, false or deceptive to any customer or conceal material facts at any time.

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

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

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

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

The Company is committed to having an effective and appropriate compliance culture to enable it to deal with any new potential conflicts of interest which may arise in the future. The Company’s employees are therefore required to monitor any new circumstances giving rise to potential conflicts of interest and to implement appropriate measures to address these.

For the purpose of this Policy, a “personal transaction” is considered a trade in a financial instrument effected by or on behalf of a relevant person, where at least one of the following criteria are met:

• the relevant person is acting outside the scope of the activities he carries out in his professional capacity;
• the trade is carried out for the account of any of the following persons:
• the relevant person;
• any person with whom he has a family relationship, or with whom he has close links;
• a person in respect of whom the relevant person has a direct or indirect material interest in the outcome of the trade, other than obtaining a fee or commission for the execution of the trade.

Segregation of Company’s assets from clients’ assets

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

Forbidden Business Practices

The Company shall prohibit those business practices which in the regular course of events might give rise to conflicts of interest. The following business practices shall indicatively be forbidden:

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

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

6. DISCLOSURE OF CONFLICTS OF INTEREST

In case where, the organisational and administrative arrangements established by the Company to prevent or manage a conflict are not sufficient to ensure, with reasonable confidence, that the risks of damage to the interests of the clients will be prevented, the Company shall clearly proceed with the disclosure of such conflict.

Prior to carry out a transaction or provide a service to a client, the Company should disclose any actual or potential conflict of interest to the client provided that the measures taken by the Company are not sufficient to ensure that the risks of damage to the interests of the client will be avoided.

The above disclosure shall include sufficient detail, taking into account the nature of the client, source of conflicts of interest, the risks to the client to enable him to take an informed decision with respect to the service in the context of which the conflict of interest arises. The Company reserves the right not to proceed with the transaction or matter giving rise to the conflict if such disclosure is not sufficient to manage a conflict.

The Management and employees of the Company should disclose the following information to the CO:

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

Purpose of this Document:

The Key Facts Statement provides aspects of material significance about this investment product. The provision of this information to clients is required by section 18(5)(c) of the Financial Consumer Protection Act 2022, to help you understand the nature, risks, costs, potential gains and losses of this product. While you may use this document to compare this investment product with other investment products, this document does not constitute and/or should not be regarded as marketing material.

Product Description:

The Key Facts Statement provides aspects of material significance about this investment product. The provision of this information to clients is required by section 18(5)(c) of the Financial Consumer Protection Act 2022, to help you understand the nature, risks, costs, potential gains and losses of this product. While you may use this document to compare this investment product with other investment products, this document does not constitute and/or should not be regarded as marketing material.

A CFD is a leveraged product, which means you only pay a margin (collateral), which corresponds to a fraction of the actual position value. When opening a CFD position, you decide if you want to invest in rising or falling prices for the underlying asset. Once you close and open a CFD position, the price change will be determined. At closing, the difference between the price at the opening of the position and the price at the closing of the position will be calculated. The difference multiplied by your traded volume determines your profit or loss, depending on if it has been set for falling or rising.

Objectives

The objective of trading CFDs is to speculate on the price movement generally over a short-term trading period. Investors can have a leveraged exposure to an underlying instrument without the need to buy (or own) the actual instrument. The leveraged nature of CFD trading enables investors to deposit only a portion of the notional value of the contract traded as initial margin. There is no pre-determined or recommended holding period for the contract. The investor should decide when to open and close a CFD trade. Investors trading in CFD’s should have sufficient funds in their account, and if needed, deposit additional funds, to avoid any closures on open positions.

Trading can lead to high returns as well as high losses in a short period of time and shall be in a position to understand the difference and risk/reward profile between CFD trading and trading of traditional shares or underlying assets.

Performance Scenarios

The Key Facts statement applies to any CFD instrument. For each trade, you will be responsible for choosing the instrument, when you open and close, the trade size and whether to use any risk mitigation features (such as stop loss orders). Each instrument has different characteristics such as lot sizes (number of units i.e. CFD on currency pairs are traded on 100,000 units) or pip value (price move).

Assumptions Used:

CFD on Currency Pair
Opening Price	OP	1.1150
Trade size (per CFD)	TS	1
Lots size	LS	100,000
Margin on 1:500 (%)	M	0.20%
Margin Requirement (USD)	MR = OP x TS x M x LS	$223.01
Notional Value of the Trade (USD)	N	$111,500
Equity	E	$20,000

Assumptions Used:

Associated Costs:

Depending on the product you trade, you may incur some or all of the following costs:

This table shows the different types of costs related to trading CFDs
One-off entry or exit costs	Spread	Applicable to all instruments	A spread is the difference between the bid (buy) and the ask (sell) price on the specific instrument you trade. This cost is realised every time you open and close a trade.
	Commission	Applicable only on some products	This is the commission you pay when you buy and sell an instrument. Check our product pages for current details www.acg-markets.com
	Currency conversion	Applicable to all instruments	This is the cost for converting realised profits and losses as well as any costs and charges that are denominated in a currency other than the base currency of your trading account.
Ongoing costs	Swap (Financing Fee)	Applicable to all instruments	This is the swap cost for keeping your position open overnight. The swap cost can be positive or negative depending on the instrument to be traded.

More specific details on the costs and charges can be found on the Company’s website www.acg-markets.com.

Other relevant information:

Other relevant information and documentation, such as Client’s Services Agreement, Complaint Handling policy and Conflict of Interest policy can be found on the Company’s website section concerning legal documentation www.acg-markets.com. It is important for you to read and understand these documents before opening an account and start trading with the Company.

ABOUT ACG MARKETS LTD

ACG Markets Ltd is a Company incorporated and registered under the laws of Seychelles with Company number 8434915-1. The Company is licensed and regulated as a securities dealer by the Financial Services Authority under license number SD182.

APPLICABLE REGULATORY FRAMEWORK AND PURPOSE OF THIS POLICY

The formulation and adoption of this Policy is required under section 18(5)(a)(vi) of the Financial Consumer Protection Act of 2022, according to which the Company shall, before a purchase is made, provide the financial consumer in writing with a summary of the Company’s privacy policy.

The FCPA 2022 came into force with the aim of strengthening consumer protection and confidence when accessing financial services and products in Seychelles.

The policy’s purpose is to provide a summary of the policies adopted in terms of disclosure of any consumer information received from consumers as part of any contractual arrangement that a consumer intends to enter into or enters into with the Company.

The Company is responsible for the protection of privacy and the safeguarding of clients’ personal and financial information.

By opening a trading account with the Company, the client hereby gives its consent to such collection, processing, storage and use of personal information as explained below.

COLLECTION OF PERSONAL DATA

During the account opening process for a demo or a trading account, the client is requested to provide the Company some personal information.

The provision of the information submitted by the Client will enable the Company to evaluate the application pursuant to the applicable laws and regulations governing the provision of the services.

The same information will also be used by the Company to contact the client regarding the offered services.

USE OF PERSONAL DATA

The Company collects and process personal data which are required for the evaluation, establishment and maintenance of the contractual relationship between the Company and the Client.

In some cases, the Company may also process the client’s personal data to pursue its legitimate interests or those of third parties, provided that the Clients’ interests and fundamental rights are not overridden by those of the Company or the third party.

In view of the above, the Company may use client’s personal information for one or more of the following purposes:

• to confirm/verify the identity of a consumer
• to process transactions
• trading account management
• for internal business as well as record keeping purposes
• to analyse statistical data
• to identify, assess, mitigate, prevent and investigate fraudulent activity of any kind that is forbidden by the relevant legislation
• to defend possible legal claims and/or comply with court orders, judicial processes and or any other requirements of a competent authority

The Company also needs to comply with the Anti-Money Laundering regulations therefore there are documents that must be kept to enable the Company to demonstrate to the authorities that we have acted in accordance with the legislation.

If there is no lawful basis for the usage of client’s personal data as indicated above, the client’s consent will be required.

SHARING AND TRANSFER OF PERSONAL INFORMATION

The Company may share client information with business partners and suppliers with whom it may have outsourced certain of the Company’s business functions or cooperating with.

In order to provide services to the client the Company may be required to transfer client’s personal information to parties located outside of Seychelles i.e. in the European Economic Area or in countries which may not have an equivalent level of data protection laws as in the Seychelles.

Where this is the case the Company will take reasonable steps to ensure the privacy of the client’s information. By submitting personal information, the client agrees to the aforesaid transfer, storage and processing of the client’s information.

The Company may also share information with affiliates or any other company in the same group of the Company in the event such information is reasonably required in order to provide the products or services to its clients.

The Company may share information with partners, affiliates and associates in order to offer additional similar products and services that meet clients’ needs and which are delivered in a manner that is useful and relevant only where clients have authorized the Company to do so.

In cases where clients have been introduced by a third party such as a Business Introducer, such Business Introducer may have access to clients’ information. Hence, clients hereby consent to the sharing of information with such Business Introducer.

All third parties with which the Company shares personal information are required to protect such personal information in accordance with all relevant legislation and in a manner similar to the way the Company protects the same.

The Company will not share personal information with third parties which it considers will not provide its clients the required level of protection.

The Disclosure of consumer data should be in line with Section 9 of the Confidentiality policy of the Company.

Any client that has established a business relationship with the Company voluntarily consents to the disclosure of their non-public consumer data electronically in the form of a general agreement through the acceptance of the client services agreement at the stage of creating their account.

COOKIES

The Company uses cookies to gather information about the client’s access to the Company’s website www.acg-markets.com and other services the Company provides to the client.

The Company may share web site usage statistics with reputable advertising companies and with its affiliated companies.

It is noted that the information collected by such companies is not personally identifiable.

To administer and improve the services offered by the Company’s website, the Company may use third parties to track and analyse usage and statistical volume information.

The third party may use cookies to track behaviour and may set cookies on behalf of the Company. These cookies do not contain any personally identifiable information.

Most internet browsers are set up to accept cookies.

If the client does not wish to receive cookies, he/she may be able to change the settings of the browser to refuse cookies or have the choice whether to accept a cookie or not.

However, it is strongly recommended that the client allows cookies on the Company’s website to ensure he/she has the best possible experience.

Turning off cookies may result in reduced performance of the website and trading platform and may also impair the quality of the services that the Company provides in relation to the client’s trading account.

AMENDMENTS TO POLICY

The Company reserves the right to make changes to this Privacy Policy from time to time for any reason and the client will be notified of such changes by posting an updated version of this Privacy Policy on the website.

The client is responsible for regularly reviewing this Privacy Policy and the use of the website after any such changes are published.

LEGAL DISCLAIMER

The Company will not be liable for misuse or loss of personal information resulting from cookies on the Company’s site(s) that the Company does not have access to or control over.

The Company will not be liable for unlawful or unauthorized use of client’s personal information due to misuse or misplacement of any passwords, negligent or malicious.

COMMUNICATION WITH THE COMPANY

Further information on the Company’s Privacy Policy is available upon request.

The Company’s contact details are:

Email: support@acg-markets.com
Address: CT House, Office 9A, Providence, Mahe, Seychelles

INTRODUCTION

ACG Markets Ltd is a Company incorporated and registered under the laws of Seychelles with Company number 8434915-1. The Company is licensed and regulated as a securities dealer by the Financial Services Authority under license number SD182.

The products we offer are high risk and it is important that all clients understand and acknowledge the risks before trading. It is possible for adverse market movements to result in the loss of your account balance in full or even more

The following risks are highlighted for clarity and each client acknowledges, understands, agrees and accepts the risks as part of the online onboarding process.

This document does not disclose all the associated risks or other important aspects of CFDs, and it should not be considered as investment advice or recommendation for the provision of any service or investment in any financial instrument. The Client should not carry out any transaction in CFDs or in any other financial instruments unless he is fully aware of their nature, the risks involved and the extent of his exposure in these risks.

SPECIFIC RISKS ASSOCIATED WITH CFD TRADING

Leverage

Leverage is a distinct feature of CFDs. The effect of leverage makes investing in CFDs riskier than investing directly in the underlying asset. Trading on margin means a relatively small price movement in the underlying asset can have a disproportional impact on a Client’s trade.

A small price movement in the Client’s favour can provide a high return on the deposit, however, a small price movement against the Client may quickly result in significant losses.

Gapping

Gapping is a risk that arises as a result of market volatility. Gapping occurs when the prices of CFDs suddenly shift from one level to another, without passing through the level in between.

There may not always be an opportunity for the Client to place an order between the two price levels.

Stop Loss Orders

The Company offers you the opportunity to choose Stop Loss Orders to limit the potential losses you can incur from an open position. This option automatically closes your position when it reaches a certain price limit.

However, the price at which your order will be executed is not guaranteed and you may still be subject to losses on your trade.

Liquidation

To keep CFD positions open, the Client needs to have enough funds in his account to cover his margin obligations. When the Client’s margin obligations are no longer covered, the Client must immediately deposit additional cleared funds or close positions so that the funds in his account cover the margin.

Margin shortages can arise quickly as market values change. Unless the Client has sufficient funds in his account to cover these situations, there is a risk of having to close positions when the Client may prefer not to.

The value of the Client’s account must always remain above the liquidation, or close out, level. If it falls below this level, the Client’s CFD trades are at risk of being liquidated.

To prevent liquidation of the Client’s CFD positions, the Client must make sure he has deposited enough funds to keep his account value above the liquidation level.

If the Client’s trade does not go as he expects, the Client may be required to deposit additional funds in order to hold his position.

No guarantee of profit.

There are no guarantees of profit nor of avoiding losses when trading CFDs. The Client is responsible for all trading profit and loss and must be financially able to bear such risks and withstand any losses incurred.

GENERAL RISKS

Market Risk

Market risk Is the risk that the value of a portfolio will decrease due to the change in value of the market factors such as stock prices, interest rates, exchange rates and commodity prices.

In case of a negative fluctuation in prices, the Client runs the risk of losing part or all of his invested capital

Systemic risk

Systemic risk Is the risk of collapse of the entire market or the entire financial system. It refers to the risks imposed by interdependencies in a system or market, where the failure of a single entity or cluster of entities can cause a cascading negative effect, which could potentially bring down the entire system or market.

IT Risk

Faults in electronic equipment used to perform margin trading and investment operations may lead to unexpected and unpredictable results and therefore to losses on the Client’s operations in the international exchange market (FOREX).

At the carrying out of transactions via an electronic trading system, the Client runs the risk related with possible faults in the system, including equipment and software failures.

Operational Risk

Operational risk Is the risk of business operations failing due to human error. Operational risk will change from industry to industry and is an important consideration to make when looking at potential investment decisions.

Industries with lower human interaction are likely to have lower operational risk.

Foreign Exchange Risk

The risk of an investment’s value being affected by changes in exchange rates.

Legal and Regulatory Risk

A change in laws or regulations made by the government or a regulatory body may increase the costs of operating a business, reduce the attractiveness of an investment and/or change the competitive landscape and by such materially alter the overall profit potential of your investment.

This risk is unpredictable and may vary depending on the market for the underlying asset of a given CFD.

ACG Markets LTD

ACG Markets Ltd (hereafter the “Company”) is a limited liability company incorporated and registered
under the laws of Seychelles, with Company number 8434915-1 and a registered address at CT
House, Office 9A, Providence, Mahe, Seychelles. The Company is authorized and regulated by the
Financial Services Authority in Seychelles (“FSA”) under the license number SD182 for the provision of
the investment services specified in this Client Service Agreement (hereafter the "Agreement").
The Client is requested to read the Agreement and make sure it understands the following terms prior
to accepting the Agreement and using the Company’s services.

Scope and Application

This Agreement governs the relationship between the Client and the Company
and is electronically executed. The Client is required to accept these terms provided that it has read
and agrees with the terms of the Agreement by checking and/or clicking the respective acceptance
checkbox during the Online Account Opening Procedure which is further explained below.
For the avoidance of any doubt, this Agreement has the same legal effect and confers the same legal
rights upon the parties as if it had been signed. The Client hereby acknowledges and agrees that by
completing and submitting the account opening documentation forms of the Company fully agrees to
be abide by and bound by the terms set out in this Agreement.

Definitions

1. "Account" shall mean a trading account maintained by the Client with the Company;
2. "Applicable Regulations" means the rules of any relevant regulatory authority, the rules of any
relevant exchange, and all other applicable laws and rules in force from time to time including
among others the Securities Act 2007 as amended, the Securities (Conduct of Business)
Regulations 2008, the Securities (Financial Statements) Regulations 2008, the Securities
(Advertisements) Regulations 2008, the Securities (Forms and Fees) Regulations 2008, the
Securities (Substantial Activity Requirement) Regulations 2018, the Financial Services
Authority Act 2013, the Anti Money Laundering Act of 2020 as amended and the Prevention of
Terrorism Act 2004 etc.
3. "Authorised Third Party-Representative" shall mean an individual person or legal entity
undertaking a transaction on behalf of another individual person i.e. the Client or legal entity
but in his/its own name;
4. "Company’s Website" shall mean the Company’s Website www.acg-markets.com
5. "CFD Contract" or "CFD" shall mean a contract which is a contract for difference by reference
to fluctuations in the price of the relevant security or index;
6. "Client" shall mean the individual person, legal entity or firm being a customer of ACG Markets
Ltd;
7. "Company" shall mean ACG Markets Ltd, a limited liability company incorporated and
registered under the laws of Seychelles, with Company number 8434915-1. The Company is
authorized and regulated by the Financial Services Authority in Seychelles (“FSA”) under the
license number SD182 with registered address at CT House Office 9A, Providence, Mahe,
Seychelles.
8. "Equity" shall mean the aggregate of (i) the Balance; and (ii) unrealized profit or loss on open
positions (after deduction of any Charges and the application of any Spread on closing of a
position);
9. "Financial Instruments" shall mean Forex and Contracts for Differences (CFD) on currency
pairs, on commodities, on shares, on indices, on metals, on cryptocurrencies or any other
commodities available for trading;
10. "Margin" shall mean the necessary funds so as to open or maintain open positions in a CFD
Transaction;
11. "Margin Level" shall mean (Equity/ Margin) * 100; it determines the conditions of the Client’s
Account.
12. "MTF" means a multilateral system operated by an investment firm or market operator, which
brings together multiple third party buying and selling interests in financial instruments in the
system, in accordance with non discretionary rules, in a way that results in a contract.
13. "Quote" shall mean the bid and ask prices at which a Financial Instrument can be bought and
sold;
14. "Underlying Asset" means property of any description (including a currency or currency pair)
or an index or other factor designated in a CFD Transaction to which reference is made to
fluctuations in the value or price for the purpose of determining profits or losses under the
CFD Transaction;
15. "Services" shall mean the services to be provided by the Company under this the Agreement;
16. "Spread" means the difference between the lower bid price and higher offer price of a quoted
two-way price for a Financial Instrument;
17. "Regulated Market" shall mean a Regulated Market (RM) is a multilateral system that is
operated or managed by a market operator and that brings together or facilitates the bringing
together of multiple third-party buying and selling interests in financial instruments within the
system.
18. "Trading Platform" shall mean any online trading platform made available by the Company
under the Agreement;

1. Services

1.1 The Company shall carry on business as dealing in securities, whether acting as principal or agent
for the following:
a. To make or offer to make an agreement with another legal person to enter into or offer to enter
into an agreement, for or with a view to acquiring, disposing of, subscribing for or underwriting
securities or in any way that effects or causes to effect a securities transaction.
b. Without limiting the generality of the above point, to cause any sale or disposition of or other
dealing or any solicitation in respect of securities for valuable consideration, whether the terms
of payment be on margin, instalment or otherwise or any attempt to do any of the foregoing.
c. To receive as a securities dealer an order to buy or sell a security which is executed.
1.2 The services of paragraph 1.1 shall involve transactions in Financial Instruments not admitted to
trading in Regulated Markets or an MTF and are over the counter (“OTC”) traded instruments such as
CFDs or any other financial instruments or commodities.

2. Risk Disclosure & Acknowledgment

2.1 It is important for the Client to understand the risks involved before deciding to enter into a trading
relationship with the Company. If the Client chooses to enter into a trading relationship with the
Company, he should remain aware of the risks involved and be able to have adequate financial
resources to bear such risks.
2.2 The financial instruments offered by the Company are high-risk products that are traded on margin
and carry a risk of losing all Client’s initial deposit. These kind of products can fluctuate significantly
and present a high risk of capital loss, therefore these products may not be appropriate or suitable for
all clients and the Client should seek independent advice should he is not able to understand the risks
involved.
2.3 The Client acknowledges, understands, agrees and
accepts the risks including but not limited:

General Risks and Acknowledgements

a. The Company does not and cannot guarantee that funds deposited in the Client’s Account for
trading will not be lost as a result of the Client’s transactions.
b. The Client acknowledges that, regardless of any information which may be offered by the
Company, the value of any investment in Financial Instruments may fluctuate downwards or
upwards and it is even probable that the investment may become of no value.
c. The Client acknowledges that he/she runs a great risk of incurring losses and damages as a
result of the purchase and/or sale of any Financial Instrument and accepts that he/she is willing
to undertake this risk.
d. The use of historical data does not constitute a binding or safe forecast as to the corresponding
future performance of the Financial Instruments to which the said Information refers.
e. The Client is hereby advised that the transactions undertaken through the dealing services of
the Company may be of speculative nature. Large losses may occur in a short period of time and
may be equal to the total value of funds deposited with the Company.
f. Some Financial Instruments may not become immediately liquid, for example, as a result of
reduced demand and the Client may not be in a position to sell them or easily obtain information
on the value of these Financial Instruments or the extent of the associated risks.
g. When a Financial Instrument is traded in a currency other than the currency of the Client’s
country of residence, any changes in the exchange rates may have a negative effect on its
value, price and performance.
h. A Financial Instrument on foreign markets may entail risks different to the usual risks of the
markets in the Client’s country of residence. In some cases, these risks may be greater. The
prospect of profit or loss from transactions on foreign markets is also affected by exchange rate
fluctuations.

i. The Client should not purchase a Financial Instrument unless he/she is willing to undertake the
risks of losing entirely all the money which he has invested and also any additional commissions
and other expenses incurred.
j. Under certain market conditions (for example but not limited to the following situations: force
majeure event, technical failure, communications network failure, poor or no liquidity, market
news or announcements etc.) it may be difficult or impossible to execute an order.
k. Should the Equity of the Client be insufficient to hold current positions open, the Client may be
called upon to deposit additional funds at short notice or reduce exposure. Failure to do so
within the required time may result in the liquidation of positions at a loss and the Client will be
liable for any resulting deficit.
l. Trading on-line, no matter how convenient or efficient, does not necessarily reduce risks
associated with currency trading.
m. There is a risk that the Client’s trades in Financial Instruments may be or become subject to tax
and/or any other stamp duty, for example, because of changes in legislation or his/her personal
circumstances. The Company does not warrant that no tax and/or any other stamp duty will be
payable. The Client should be responsible for any taxes and/or any other duty which may
accrue in respect of his/her trades.
n. Before the Client begins to trade, he/she should obtain details of all commissions and other
charges for which the Client will be liable. If any changes are not expressed in money terms (but
for example a spread), the Client should ask for a written explanation, including appropriate
examples, to establish what such charges are likely to mean in specific money terms.
o. The Company will not provide the Client with investment advice relating to investments or
possible transactions in investments or make investment recommendations of any kind
specifically to meet the Client’s investment profile. Note that the Company may provide generic
research or information that is contained in the Company’s website or material which shall be of
a general nature and for information purposes only and does not constitute advice or
recommendation to perform any actions with financial products or instruments, or to participate
in any particular trading strategy as well as cannot guarantee any profits. Furthermore, it does
not take into account the Client’s personal circumstances, financial situation or needs therefore
the Client shall seek professional advice, as required. In addition, any past performance is not a
reliable indicator of future performance.
p. There may be situations, movements and/or conditions occurring at the weekend, at the
beginning of the week or intra-day after the release of the significant macroeconomic figures,
economic or political news that make currency markets to open with price levels that
substantially differ from previous prices. In this case, there exists a significant risk that orders
issued to protect open positions and open new positions may be executed at prices significantly
different from those designated.

3. Account Opening Procedure

3.1 Before opening a new account, the Company provides to the Client via its Website or through an
email or in person with the required information regarding the Company and a copy of this Agreement.
After accessing the website of the Company, the Client will complete and/or receive the application
package which consists of the following: a) account application form, b) relevant information/
documents of the client, c) Client Services Agreement.
3.2 The Company is obligated by the Applicable Regulations to perform KYC and due diligence
procedures in order to verify the identity of each person who registers online via the Company’s
Website. For this purpose, the Company will collect information about the Client such as name,
surname, address, telephone number, email, nationality, date of birth and other details.
3.3 When the Company receives the Client’s completed online application form, it may use the
information to conduct any further enquiries about the Client as the Company determines under the
circumstances and its internal policies and procedures. The Company also carries out additional
checks or periodic reviews. The Client will need to co-operate with the Company and supply the
information requested promptly. The Company relies on the information that it is provided by the Client
in the online application form or otherwise as being correct and not misleading at all times, unless you
notify us otherwise in writing. In particular, the Client must notify the Company as soon as possible in
writing if any of the details provided to us in your application form or if your circumstances have
subsequently changed.
3.4 The Company is not to be required (and may be unable under Applicable Regulations) to accept a
person as its Client until all documentation it requires has been received properly and fully completed
by such person and all internal checks (including without limitation all anti-money laundering customer
identification and due diligence checks) have been duly satisfied. It is further understood that
Company reserves the right to impose additional due diligence requirements to accept Clients residing
in certain countries where the risk of money laundering may be higher. During the customer
identification and due diligence checks the Company shall apply processes to verify the Client’s
identity for which (amongst other things) photo identification information will be required by the Client.
In certain circumstances we may require this information to be authenticated by an appropriate third
party. The Company requires as minimum a government issued Photo identity documents such as a
passport, driving license and/or identity card containing your full name, personal photo, and date of
birth, ID number and expiry date as well as evidence of your residential address, such as a utility bill or
bank statement, for the verification process. The information in these documents should agree with
the details submitted in Client’s application.
3.5 The Company will assess the information received by the Client during the Account Opening
Procedure in order to determine whether the Client is eligible or not in investing and/or operating a
trading account with the Company. The Client’s trading account will be opened following the
assessment and completion of the KYC and due diligence procedure

4. Fees and Charges

4.1 The Client shall be required to pay the charges as agreed from time to time, any fees or other
charges imposed by third parties during the execution of the services. The Company’s current charges
including spreads, charges, interest and other fees are published on the Company’s website and any
alteration to charges will be notified to the Client via the Company’s website or via the trading platform
terminal or via an email sent to the client’s registered address used during the registration process. By
accepting this Agreement, the Client acknowledges that he has read, understood and is in agreement
with the fees and charges uploaded on the Company’s website. The Client further agrees that the
Company is entitled to change its charges without any consultation or prior consent from the Client.
4.2 The Company is compensated for its services through the Buy/Sell (Ask/Bid) spread, so when you
open a position in a specific instrument, you essentially “pay” the spread. The spread rates per
instrument can be viewed by the Client at any time on the Company’s website.
4.3 Subject to the Financial Instruments traded by the Client, the following charges may be incurred:

Spread

A spread is the difference between the bid (buy) and the ask (sell) price on the specific instrument
you trade. This cost is realised every time the Client opens and closes a trade.

Commission

This is the commission the Client pays when he buys and sells a Financial Instrument.

Currency conversion

This is the cost incurred when converting realised profits and losses as well as any costs and
charges that are denominated in a currency other than the base currency of the Client’s Account.

Overnight Funding /Swap (Financing Fee)

This is the swap charge for keeping your position open overnight. The swap cost can be positive or
negative depending on the instrument to be traded. An overnight funding amount is either added to
or subtracted from the Client’s account when holding a position after a certain time.

Trading inactivity

The Client’s account is associated with the cost of maintenance and other regulatory or compliance
requirements so if there are no transactions by the Client for a period of 12 months, the Company
has the right to claim the applicable inactivity fee as notified to the Client from time to time and the
Company may deduct such fee from the Client’s Account. The inactivity fee will be up to USD 10
and the Company reserves the right to charge the said fee annually if there are no transactions by
the Client the preceding 12 months.
4.4 All payments to the Company under this Agreement shall be made in such currency as the
Company from time to time specify to the bank account designated by the Company for such
purposes.
4.5 The Company may share charges with third parties, like Introducing brokers or affiliates, for
services carried out on your behalf in the form of commission, mark up, mark down or other
remuneration. Details of such remuneration or sharing arrangements may be available to the Client
upon request.

5. Conflict of Interest

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

Conflict of Interest policy

as Annex 1.

6. Inducements

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

7. Client Money and Transfer of funds

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

8. Client’s Orders/Instructions & Execution of Orders

8.1 Execution of Orders: It is the Company’s approach to take all sufficient steps to obtain the best
possible result on behalf of its Clients when executing Client orders on Financial Instruments offered by
the Company or receiving and transmitting orders for execution. The Client understands and
acknowledges that the Company will enter into transactions with the Client either as principal
(counterparty) or as agent. The Company will be the contractual counterparty to the Client.
8.2 The Company, when executing orders, will obtain the best possible result for Clients, taking into
account factors like price, costs, speed, likelihood of execution and settlement, size, market impact or
any other consideration relevant to the execution of the order. Where the Company executes an order
on behalf of a Client, the best possible result shall be determined in terms of the total consideration,
representing the price of the financial instrument and the costs relating to execution, which shall
include all expenses incurred by the Client which directly relate to the execution of the order.
8.3 For determining the importance of the execution factors indicated above, the following criteria are
also taken into account:

The characteristics of the Client

The characteristics of the Client order;
The characteristics of Financial Instruments that are the subject of that order;
The characteristics of the execution venues to which that order can be directed.

8.4 The Client understands and confirms that all orders received by the Company from the Client are
orders for execution outside a Regulated Market or MTF.
8.5 Orders may be placed with the Company once the Client gets access
to the Company’s Trading Platform. The Company will be entitled to rely and act on any Order placed
on the Trading Platform without any further enquiry to the Client and any such Orders will be binding
upon the Client.

Client’s Orders/Instructions

8.6 The Company’s Buy/ Sell prices for a given CFD are calculated by reference to the price of the
relevant Underlying Asset. Third party reputable external resources (i.e. feed providers) obtain prices
(Buy/Sell prices) of the Underlying Asset for a given CFD. The Company then uses the prices given by
the feed providers to calculate their own tradable prices for a given CFD. The Company adjusts the
Spread (i.e. the difference between the Buy/Sell prices), hence the prices it quotes to Clients
compared to the prices it obtains from third party external reference sources may differ, as they
include a Spread adjustment. The Company provides Quotes by taking into account the Underlying
Asset price. The Client acknowledges that such Quotes will be set by the Company at its absolute
discretion.
8.7 Orders can be placed, executed and changed or removed within the trading hours for each CFD
showed on the Company’s Website, as amended from the Company from time to time and if they are
not executed they shall remain effective through the next trading session (as applicable). The
Company shall not be obliged to arrange for the execution of the Client’s orders in respect of any CFD
out of normal trading hours which appear on the Company’s Website.
8.8 If any tradable instrument becomes subject to possible adjustments, the Company will determine
the appropriate adjustment, if any, to be made to the opening/closing price, size, value and/or quantity
of the corresponding transaction. The determination of any adjustment or amendment to the opening/
closing price, size, value and/or quantity of the Transaction (and/or the level or size of any order) shall
be at the Company’s sole discretion and shall be conclusive and binding upon the Client. The Company
shall inform the Client of any adjustment or amendment via its internal mail as soon as is reasonably
practicable.
8.9 During the occurrence of a manifest error i.e. a manifest or obvious misquote by the Company, or
any market, liquidity provider or official price source on which the Company has relied in connection
with any transaction, having regard to the current market conditions at the time an order is placed as
the Company may reasonably determine, the Company may amend the details of affected transactions
to reflect what the Company reasonably determines as correct and fair and/or declare any or all
affected transactions as void.
8.10 During periods of abnormal Market (Volatile) Conditions, during news announcements, on opening
gaps (trading session starts), or on possible gaps where the Reference Asset has been suspended or
restricted on a particular market, Buy/Sell Stop and Stop Loss orders may not be filled at requested/
declared price but instead at the next best available price. In such case, Take Profit orders below/
above Buy Stop/Sell Stop orders or Stop Loss orders above/below Buy Stop/Sell Stop orders during
activation will be removed. The same applies when a trading strategy is deemed as abusive, because it
is aiming towards potential riskless profit or another strategy deemed by the Company to be abusive.
Accordingly, placing a Stop Loss order will not necessarily limit the Client’s losses at the intended
amount.

9. Margin/Leverage Level

9.1 The Margin/leverage levels applicable to the different products offered by the Company can be
found on the Company’s Website at . If at any time the Equity falls below a
certain percentage of the required Margin, specified on the Website, the Company has the right to
close any or all of the Client’s open positions without the Client’s consent or any prior written notice to
him. The Client will be informed about the closure of its position through electronic means should the
equity falls below the required margin.
www.acg-markets.com

The Client is responsible to monitor its account balance and keep sufficient funds in its Account in
order for its open positions to remain unaffected. The Company shall have the right, but not the
obligation, to start closing Client’s open positions starting from the most unprofitable, when the Margin
is less than 100% of the Margin requirement. In the case where the Margin is equal to or less than 50%
of the Margin requirement, then Client’s positions shall be automatically closed, starting from the most
unprofitable, at the prevailing market price.
9.2 Margin or leverage Level may be set and varied without prior notice from time to time in the
Company’s sole and absolute discretion in order to cover any realised or unrealised losses arising from
or in connection with transactions, including subsequent variation of any Margin rates set at the time
transactions are opened. The Client can request to change his account leverage at any time by
contacting the Company.
9.3 On every Friday and between the hours of 21:00 till 24:00 (GMT+3) and occasionally before the
release of major economic news, the Company may maintain a maximum leverage on remaining
instruments other than FX for any new positions opened during such period which such requirement, if
any, will be disclosed in the Company’s website.

10. Decline of Client’s Orders and Instructions

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

11. Transaction Settlements and Confirmations

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

12. Trading Platform usage

12.1 The Client shall enter his user ID and password ("Codes") registered during the online account
opening procedure when logging on to the Company’s Trading Platform. The Client should notify the
Company without undue delay on becoming aware of unauthorized use of the Trading Platform, or if
the Client suspects that the password has been misappropriated by a third party.
12.2 The Client shall take all necessary precautions to ensure the confidentiality of all information,
including, but not limited to, the Codes to the electronic systems, Transaction activities, account
balances, as well as all other information and all orders. The Client shall be solely responsible for all
orders and the accuracy of all information sent via the internet using its Codes. The Client
acknowledges that the Company bears no responsibility in the case that the Codes are used in an
unauthorized manner by any third party.
12.3 The Company shall not be responsible for losses resulting from the Client's installation and use of
the computer programs used on the Trading Platform, unless such liability follows from indispensable
rules of law. Where the Trading Platform is used by the Client, it shall be responsible for ensuring that
the Trading Platform is adequately insured against direct and indirect losses which may result from the
installation and use of the computer programs in the Client's computer system. Furthermore, the Client
shall be obliged to make backup copies of data which, should such data be lost, might result in losses
for the Client.

12.4 When using the Company’s platform, the Client shall:

run such tests and provide such information to us as we shall reasonably consider necessary
to establish
ensure that the system and/or hardware equipment used by the Client satisfies the
requirements notified by us to you from time to time;
carry out virus checks on a regular basis;
inform us immediately of any unauthorized access to its system or instruction which the
Client know of or suspect and, if within its control, cause such unauthorized use to cease;
and
not at any time leave the terminal from which the Client has accessed the trading platform or
let anyone else use the terminal until he has logged off the trading platform.

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

13. Market Abuse

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

14. Third Party Authorisation

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

15. Introducing Brokers and Affiliates

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

16. Privacy and Data Protection rules

16.1 The Company is committed to protecting the privacy of all personal information that it obtains from
the Client and hereby lists how and why the Company collects, use, disclose and protect the Client’s
personal information.
16.2 The Company Collects Client’s personal information in order to
provide the Client with its products and services and to establish and manage the Client’s account. By
collecting Client’s information, the Company will be able to monitor and improve the services it offers
to its existing and potential clients.

Purpose of data collection

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

16.4 The Company may use information for the following purposes (list not
exhaustive):

Usage of Information

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

16.5 The Company may share Client’s personal information with business
partners and suppliers with whom the Company may have outsourced certain of business functions or
cooperating with. Personal data collected by the Company may be transferred or disclosed to third
party contractors, subcontractors, for the purposes for which the Client has submitted the information
i.e agreements with Service Providers.

Share of Information

16.6 It is the Company’s policy to disclose information to third parties under the following
circumstances:
As required by Applicable Regulations, statute, rule, regulation or professional standard,
search warrant or other legal process
For regulatory compliance purposes
When explicitly requested by the Client
Or otherwise as set out in this section
16.7 In order for the Company to provide services to its Clients, the Company may be required to
transfer the Client’s personal information to parties located in countries which may not have an
equivalent level of data protection laws as in the Seychelles. Where this is the case we will take
reasonable steps to ensure the privacy of the information. The Client acknowledges and understands
that by submitting its personal information to the Company agrees to the aforesaid transfer, storage
and processing of the information.
16.8 If the Client wishes to withdraw its consent to the use of information, rectify a personal
information or request the provision or deletion of information held by the Company related to itself, he
may submit its request at the email address / Support@acg-markets.com

17. Force Majeure

17.1 In case of a force majeure event as listed below (list not exhaustive), the Company shall not be
liable for any failure to provide the Services under this Agreement, beyond its control:
a. Government actions, war or hostilities, acts of terrorism, national emergency,
b. Act of God, earthquake, tsunami, hurricane, typhoon, accident, storm, flood, fire, epidemic or
other natural disasters;
c. Labour disputes and lock-out which affect the operations of the Company;
d. Suspension of trading on a Market, or the fixing of minimum or maximum prices for trading on a
Market, a regulatory ban on the activities of any party (unless the Company has caused that
ban), decisions of state authorities, governing bodies of self- regulating organizations, decisions
of governing bodies of organized trading platforms;
e. Breakdown, failure or malfunction of any electronic, network and communication lines (not due
to the bad faith or wilful default of the company and hacker attacks;
f. Any event, act or circumstances not reasonably within the Company’s control and the effect of
that event(s) is such that the Company is not in a position to take any reasonable action to cure
the default;
g. The suspension, liquidation or closure of any market or the abandonment or failure of any event
to which the Company relates its Quotes, or the imposition of limits or special or unusual terms
on the trading in any such market or on any such event;
h. The failure of any relevant supplier, financial institution intermediate broker, liquidity provider,
agent or principal of the Company, custodian, sub-custodian, dealer, exchange, clearing house
or regulatory or self-regulatory organisation, for any reason, to perform its obligations.
17.2 If the Company determines reasonably that a force majeure event exists (without prejudice to any
other rights under the Agreement) the Company may without prior notice and at any time proceed with
the following actions:
a. increase Margin requirements without notice;
b. decrease leverage;
c. close out any or all open positions at such prices as the Company considers in good faith to be
appropriate;
d. refuse to accept orders from Clients;
e. determine at its discretion the quotes and spreads that are executable through the Company’s
Trading Platform;
f. suspend or modify the application of any or all terms of the Agreement to the extent that the
force majeure event makes it impossible or impractical for the Company to comply with them;
g. take or omit to take all such other actions as the Company deems to be reasonably appropriate
in the circumstances with regard to the position of the Company, the Client and other clients;

18. Complaints Procedure

18.1 If the Client has any cause for complaint in relation to the services provided by the Company, he
should file a complaint as per the Company’s Complaint Handling policy which is available on the
Company’s website.
18.2 The Client may register a complaint by completing the Complaint Form using any of the following
options:
Email: support@acg-markets.com
Postal Address: ACG MARKETS LTD
CT House, Office 9A, Providence, Mahe, Seychelles

18.3 The Company’s accompanied with the relevant complaint form which
has to be filed by the Client in case he has a complaint with the Company is enclosed as in
this Agreement.

Complaints Handling Policy

Annex 2

19. Representations and Warranties

19.1 The Client represents and warrants to the Company the following:
a. The Client is over 18 years’ old;
b. The information provided by the Client to the Company in the account opening application form
and at any time thereafter is true, accurate and complete, and at any time there is a change to
the Client personal data, the client will ensure that this data is updated and accurate, and the
documents are valid and authentic;
c. The Client is duly authorised to enter into this Agreement;
d. Any actions conducted by the Client under this Agreement will not violate any law or rule
applicable to the Client or to the jurisdiction in which the Client is resident, or any agreement by
which the Client is bound or by which any of the Client’s assets or funds are affected;
e. The Client has read and fully understood and undertakes to comply with the terms of this
Agreement;
f. The Client funds are not in any direct or indirect way the proceeds of any illegal activity or used
or intended to be used for terrorist financing;
g. There is no pending or, to the best of the Client’s knowledge, any legal proceeding before any
court, arbitration court, governmental body, agency or official likely to affect, the legality,
validity or enforceability against him of this Agreement;
h. Any information which the

Complaint Received By:
Date:
Acknowledgement sent to Client:
Yes
-
No
Informed Client of initial action:
Yes
-
No
Final response provided to Client:
Yes
-
No
Holding response provided to Client:
Yes
-
No
-
N/A