Customer Agreement

This agreement (“Agreement”) sets forth the terms and conditions governing your Account at Finpartners LTD, (“Finpartners LTD”), and all CFDs (as defined below) and other transactions in this Account. In this Agreement, the undersigned customer is referred to as “Customer” or “You”.

1. Application

Terms capitalized but not defined in this Agreement can be found on Finpartners LTD website finpartnersltd.com.

2. Services provided

Subject to the terms and conditions of this Agreement and acceptance of Customer's application to open an Account with Finpartners LTD, Finpartners LTD will maintain one or more Accounts in Customer's name and will effect cash settled transactions with and for the Customer in international over the counter markets for contracts for difference on instruments such as currencies, equities, debt securities, indices and commodities (“CFDs”) on a spot basis, and provide such other services and products as Finpartners LTD may, in its sole discretion, determine from time to time in the future. Unless expressly stated otherwise in writing, all CFDs and other transactions entered into between Finpartners LTD and Customer shall be governed by the terms of this Agreement, as amended from time to time (including, without limitation, Finpartners LTD Trading Policies and Procedures attached as an Annex hereto).

3. Representations and warranties

As of the date hereof, the date of each CFD and other transaction in Customer's Account and any date on which Finpartners LTD Risk Disclosure Statement or Trading Policies and Procedures are revised, updated or amended, Customer represents and warrants to Finpartners LTD and agrees for the benefit of Finpartners LTD that:

3.1 If Customer is a natural person, Customer is of sound mind, legal age (18 years old) and legal competence.

3.2 If Customer is not a natural person, (i) Customer is duly organized and validly existing under the applicable laws of the jurisdiction of its organization; (ii) execution and delivery of this Agreement and all CFDs and other transactions contemplated hereunder and performance of all obligations con­ templated under this Agreement and all CFDs and other transactions contemplated hereunder have been duly authorized by Customer; and (iii) each person executing and delivering this Agreement and all CFDs and other transactions contemplated hereunder on behalf of Customer performing.

3.3 Execution and delivery by Customer of this Agreement and all CFDs and other transactions contemplated hereunder, and performance of all of Customer's obligations contemplated under this Agreement and any CFDs and other transaction contemplated hereunder, will not violate any statute, rule, regulation, ordinance, charter, bylaw or policy applicable to Customer.

3.4 Customer has full beneficial ownership of Customer's Account. Customer has not granted and will not grant a security interest in Customer's Account with Finpartners LTD (other than the security interest granted to Finpartners LTD hereunder) to any person without Finpartners LTD prior written consent. Customer has full beneficial ownership of all collateral and will not grant any security interest in any Collateral to any person (other than the security interest granted to Finpartners LTD hereunder) without Finpartners LTD prior written consent. For the purposes of a funding or withdrawal transaction, the name on the Finpartners LTD trading account must be an exact match with the name on the account of the other financial institution.

3.5 Customer will execute and deliver all documents, give all notices, make all filings and take such other actions as Finpartners LTD, in its sole discretion, deems necessary or desirable to evidence or perfect any security interest in favor of Finpartners LTD or to protect Finpartners LTD interests with respect to any Collateral.

3.6 Customer has read and understands the provisions contained in this Agreement, including, without limitation, Finpartners LTD Risk Disclosure Statement and Trading Policies and Procedures, Customer will review the Agreement each time it is amended. Customer will not affect any Opening Transaction in Customer's Account unless Customer understands Finpartners LTD revised Agreement, and Customer agrees that in effecting any Opening Transaction it is deemed to represent that it has read and understands Finpartners LTD revised Agreement as in effect at the time of such Opening Transaction.

3.7 Customer agrees to trade on Demo Trading System available to him/her on the website, and acknowledges that Finpartners LTD may, in its sole discretion, decline to permit any real trades to be effected in Customer's Account until Customer has, in Finpartners LTD sole judgment, satisfactorily traded on the Demo Trading System.

3.8 Customer agrees to comply with all applicable law. Customer may not use its personal account with Finpartners LTD for any illegal activity.

3.9 Customer is not a citizen or resident of the countries, listed on the website in the Country Restrictions section.

3.10 All information provided by the Customer to Finpartners LTD, including information regarding Customer's trading experience and investment sophistication, is true, correct and complete, and Customer will notify Finpartners LTD promptly of any changes in such information.

3.11 If the Company discovers that the Client's personal data provided earlier is incorrect or misleading, the Company has the right to suspend all trading and/or non-trading operations on the Client's trading accounts and wallet until the correct data is provided. In addition, the Company reserves the right to temporarily block the Clients access to the Personal Area until the verification process is completed.

3.12 In the event that the Client's access to the Personal Area is blocked, the Client undertakes to take all the necessary actions to eliminate the reasons that caused the account blocking. If the Client does not take the necessary actions within 30 (thirty) days from the moment of blocking, the Company has the right to write off all the Clients funds from their trading accounts and/or wallet. If the Client provides all the documents necessary to unblock the Personal Area after the thirty (30)-day period, the Company has the right in its sole discretion to return the previously deducted funds to the Clients trading accounts and/or wallet.

3.13 The risk capital provided as part of the Customer Application will be immediately amended upward upon the Customer depositing funds in excess of the risk capital initially provided.

3.14 The Company is not a tax agent. The Customer calculates and pays all applicable taxes by himself.

4. Regulatory documents

The following regulatory documents shall form an integral part of this Agreement:

5. Margin requirements

Customer shall provide to and maintain with Finpartners LTD Margin in such amounts, in cash or other such forms, and within such limits as Finpartners LTD, in its sole discretion, may from time to time require. Customer's Account will be under the control of Finpartners LTD. Finpartners LTD may change Margin requirements at any time, without prior notice to Customer, and may call for additional Margin (“Margin Call”) at (x) any time Customer's Margin Balance falls below Finpartners LTD's Minimum Margin Requirement as applied to that Account; and (y) any time Finpartners LTD, in its sole discretion, believes that it is prudent to do so. Finpartners LTD may at any time liquidate Customer's Account in accordance with Paragraph 8. Finpartners LTD may withdraw funds from the Customer's account without notice: (x) to ensure that Posted Margin equals or exceeds Required Margin; and (y) to satisfy any payment obligation to Finpartners LTD, including commissions, fees and charges in respect of Customer's Account. In the event that Customer directs Finpartners LTD to sell any Margin, Collateral, CFD or other property and Finpartners LTD is unable to deliver such Margin, Collateral, CFD or other property to a purchaser because Customer fails to deliver it to Finpartners LTD, Finpartners LTD may borrow or purchase any Margin, Collateral, CFD or property necessary to make such delivery, and Customer hereby agrees to guarantee and hold Finpartners LTD harmless against any liability, claim, loss, damage, cost or expense, including attorneys' fees that Finpartners LTD may sustain.

In the event that signs of affiliation are found between accounts belonging to different clients, namely, an identical trading strategy and/or matching IP addresses, the Company reserves the right to interpret the trading accounts of such clients as a single account and change the margin requirements in accordance with the total amount of funds in these accounts and the Company's trading conditions.

6. Security agreement

In order to secure any indebtedness or other obligations at any time owing from Customer to Finpartners LTD, including, without limitation, (i) indebtedness or other obligations under any Account, CFD or other transaction with Finpartners LTD; or (ii) any indebtedness or other obligations resulting from any guarantee by Customer of any Account, CFD or other transaction with Finpartners LTD, Customer hereby assigns, pledges and grants to Finpartners LTD a security interest in and right of setoff against:

(i) all of Customer's Accounts with Finpartners LTD; (ii) all Contracts, cash, securities and other property in Customer's Account at Finpartners LTD or delivered or otherwise provided by Customer to secure its indebtedness or other obligations to Finpartners LTD or in Finpartners LTD's possession or control for any purpose (including safekeeping); and (iii) all products and proceeds of the foregoing (collectively, (i), (ii) and (iii) are referred to as “Collateral”). At any time, in Finpartners LTD's sole discretion and without prior demand or notice, Finpartners LTD may apply any or all cash (or sell or buy in any such CFDs, securities or other property and apply the proceeds there from) to any such indebtedness or other obligations, notwithstanding that such indebtedness or other obligations arise in an Account other than the Account in which the cash, CFDs, securities or other property were held or generated­. Finpartners LTD shall have the right to sell, pledge, rehypothecate, assign, invest, commingle and otherwise use any Collateral it holds (including, but not limited to, using the CFDs as collateral for a loan to Finpartners LTD) free from any claim or right of any nature whatsoever of the Customer, including­ any equity or right of redemption by the Customer and to register any Collateral in the name of Finpartners LTD, its custodian or a nominee for either. Any failure by Finpartners LTD to enforce its rights hereunder­ shall not be deemed a future waiver of such rights by Finpartners LTD. Finpartners LTD is irrevocably ap­pointed as attorney in fact for Customer and is authorized, without notice to Customer, to execute and deliver any documents, give any notice and to take any actions on behalf of Customer, including the execution, delivery and filing of financing statements, that Finpartners LTD deems necessary or desirable to evidence or to protect Finpartners LTD's interest with respect to any Collateral. In the event that the Collateral deemed acceptable to Finpartners LTD is at any time insufficient to satisfy Customer's indebtedness­ or other obligations to Finpartners LTD, including obligations to provide Margin in accordance with Paragraph 5 hereof, Customer shall promptly pay upon demand the entire amount of such deficit.

7. Settlement date; Rollovers; Delivery

In cases where transactions are executed for cash delivery, instructions on the settlement of Open Positions must be given to Finpartners LTD at least two (2) Business Days prior to the Value Date. In the absence of instructions from Customer directing Finpartners LTD to deliver, offset, or roll over Open Positions, Finpartners LTD is authorized, in Finpartners LTD's sole discretion, to deliver, roll over or offset all or any portion of the Open Positions in Customer's Account at Customer's risk.

Delivery of monetary funds shall be made to the bank specified by the purchaser in a major city in the country in which such monetary funds are the legal tender. Unless otherwise agreed by Finpartners LTD and Customer in writing, any monterary funds shall be deliverable by wire transfer. Finpartners LTD may require payment of amounts due from Customer to Finpartners LTD prior to 12:30 GMT on any day prior to payment of amounts due and payable by Finpartners LTD to Customer on that day. Finpartners LTD and Customer shall exchange, make use of, and periodically update and confirm any standing payment instructions. Sufficient funds to take delivery or the necessary delivery documents must be in the possession of Finpartners LTD. If instructions,­ funds and documents are not received by Finpartners LTD by the specified time, Finpartners LTD may, in its sole discretion and without notice to Customer, offset Customer's Open Positions, roll over Customer's Open Positions into the next settlement time period, or make or receive delivery on behalf of Customer upon any terms and by any methods deemed reasonable by Finpartners LTD, in its sole discretion. Terms and/or methods for delivering, offsetting, or rolling over Customers' Open Positions may differ on a Customer by Customer basis relative to the current balance in the Customer's Account.

8. Liquidation of accounts and deficit balances

In the event of: (a) an Event of Default; (b) insufficient Margin, or Finpartners LTD's determination that any Collateral deposited to protect Customer's Account is inadequate, regardless of current market quotations, to secure Customer's Account; or (c) any other circumstances or developments that Finpartners LTD, in its sole discretion, deems appropriate for its protection, Finpartners LTD may, in its sole discretion, take one or more, or any portion, of the following actions: (1) satisfy any obligation Customer may have to Finpartners LTD (either directly or by way of guarantee or suretyship) out of any of Customer's funds or property in the custody or control Finpartners LTD; (2) sell or purchase any or all CFDs and any securities or other property held or carried for Customer; and (3) cancel any or all outstanding Orders or CFDs or other transactions or commitments made by or on behalf of Customer.

Any of the above actions may be taken without demand for Margin or additional Margin, without prior notice of sale or purchase or other notice to Customer, Customer's legal representatives, heirs, executor, administrator, trustee, legatee, successors or assigns and regardless of whether the ownership interest is held individually or jointly with others. Any prior demand or notice of sale or purchase shall not be considered a waiver of Finpartners LTD's right to sell or buy at any time in the future without demand or notice as provided above. In liquidation of Customer's Long Positions and Short Posi­tions, Finpartners LTD may, in its sole discretion, offset in the same settlement or it may initiate new Long Positions or Short Positions in order to establish a spread or straddle that in Finpartners LTD sole judgment may be advisable to protect or reduce existing positions in Customer's Account.

Any sales or purchases may be made according to Finpartners LTD judgment and in its sole discretion in any inter­ bank, Over the Counter or other exchange market where such business is then usually transacted or at a public auction or private sale, and Finpartners LTD may purchase the whole or any part thereof free from any right of redemption. Customer shall only be liable for the payment of any deficit balance in Customer's Account upon demand by Finpartners LTD where such deficits are the result of a mark to market after a weekend or holiday. In such cases, Customer shall be liable for any deficiency remain­ ing in Customer's Account in the event of the liquidation thereof in whole or in part by Finpartners LTD or by Customer. In the event the proceeds realized pursuant to liquidation are insufficient for the payment of all liabilities of Customer due to Finpartners LTD, Customer shall promptly pay upon demand the entire amount of any such deficit, together with all other deficits and all unpaid liabilities of Customer, including, but not limited to, all costs of enforcement and collection, such as, but not limited to, attorneys' fees, witness fees and travel expenses, interest on any such deficit and liabilities at a rate equal to three (3) percentage points above the then prevailing prime rate at Finpartners LTD principal bank or the maximum interest rate allowed by law, whichever is lower. In the event Finpartners LTD incurs expenses other than for the collection of deficits, with respect to Customer's Account, Customer agrees to pay such expenses.

9. Charges

Finpartners LTD is compensated for its services through the bid/ask spread and/or commissions. Finpartners LTD may charge brokerage commission and additional bank fees such as wire transfers, deposit/withdrawal commission. Finpartners LTD reserves the right to change its fee structure at any time without notice. Fees do not currently include but may in the future include statement charges, order cancellation charges, account transfer charges, telephone order charges or fees imposed by any interbank agency, bank, contract, market or other regulatory or self-regulatory organization arising out of Finpartners LTD' provision of services hereunder. Customer may incur additional charges for the purchase of optional, value-added services offered by Finpartners LTD. Additional­ commission or spread markups may be applied to client accounts that are introduced by Introducing Brokers.

10. Introducing brokers

If Customer's Account has been introduced to Finpartners LTD by an Introducing Broker, Customer understands and acknowledges that Finpartners LTD may compensate Introducing Broker for introducing Customer to Finpartners LTD and that such compensation may be on a per trade or other basis. The fol­lowing is an allocation of responsibilities for each entity. It is intended to be a general disclosure and not a definitive enumeration of each and every responsibility. The Introducing Broker shall have the following responsibilities with respect to Customer's Account:

  • Contacting, soliciting and/or communicating with Customer regarding investment opportunities and objectives;
  • Complying with all laws, rules and regulations applicable to any arrangement or understan­ ding that Introducing Broker and Customer may have;
  • Determining any commissions and fees, whether on a per trade basis or other basis, to be charged for Customer's transactions, in addition to Finpartners LTD standard commissions and fees.

As the clearing firm for Customer's account, Finpartners LTD shall have responsibility for performing the following services:

  • Opening, approving and servicing Customer's Account(s), including obtaining and verifying new account information as required by law and regulation;
  • Maintaining account records on Customer's behalf;
  • Accepting and executing transactions in Customer's Account(s);
  • Determining margin, rolling over of open positions, liquidating under margin positions, and supervising rehypothecation of any funds in Customer's Account(s);
  • Debiting from Customer's account any commissions or fees owed to Introducing Broker or other third party;
  • Preparing and transmitting to Customer monthly or, if appropriate, quarterly account statements electronically;
  • Responding to inquiries or complaints regarding Customer's Account.

11. Trade confirmations

Trades executed online will be confirmed online at the time of the trade and trades entered into by telephone will be confirmed verbally and online by 21:30 GMT on the day of execution.

12. Communications

Reports, statements, notices and any other communications from Finpartners LTD may be transmitted to Customer by placement on Finpartners LTD Website, email or mail or other delivery service to Customer's current address as reflected on Finpartners LTD records. Customer shall notify Finpartners LTD immediately of any change in Customer's address by e-mail to [email protected]. All communications sent by Finpartners LTD shall be deemed effective when deposited by Finpartners LTD in the mail or with another delivery service, or when received by a transmitting agent (such as an Internet service provider) for transmission to Customer, whether actually received by Customer or not. All communications sent by Customer shall not be deemed effective until accepted by Finpartners LTD.

13. Force majeur

Finpartners LTD shall not be liable to Customer for any claims, losses, damages, costs or expenses, in­ cluding attorneys' fees, caused, directly or indirectly, by any events, actions or omissions, including, without limitation, claims, losses, damages, costs or expenses, including attorneys' fees, resulting from civil unrest, war, insurrection, international intervention, governmental action (including, without limitation, exchange controls, forfeitures, nationalizations, devaluations), natural disasters, acts of God, market conditions, inability to communicate with any relevant person or any delay, disruption, failure or malfunction of any transmission or communication system or computer facility, whether belonging to Finpartners LTD, Customer, any market, or any settlement or clearing system.

14. Intellectual property and confidentiality

All copyright, trademark, trade secret and other intellectual property rights in the Finpartners LTD Online Trading System (“Trading System”) shall remain at all times the sole and exclusive property of Finpartners LTD and/or its third party service providers and Customers shall have no right or interest in the Trading System(s) except for the right to access and use the Trading System(s) as specified herein­. Customer acknowledges that the Trading System(s) are confidential and have been developed through the expenditure of substantial skill, time, effort and money. The Customer will protect the confidentiality of Finpartners LTD and/or its third party service providers by allowing access to the Trading System(s) only by its employees and agents on a need to access basis. Customer will not publish, distribute, or otherwise make information available to third parties any information derived from or relating to the Trading System(s). Customer will not copy, modify, de compile, reverse engineer, and make derivative works of the Trading System(s) or in the manner in which it operates.

15. Indemnification

Customer agrees to indemnify and hold Finpartners LTD, its affiliates, employees, agents, successors and assigns harmless from and against any and all liabilities, claims, losses, damages, costs and expenses, including attorneys' fees, incurred by Finpartners LTD arising out of: (i) Customer's failure to fully and timely perform its obligations hereunder; and (ii) any of Customer's representations and warranties made that may at any time be untrue or incorrect. Customer also agrees to pay promptly to Finpartners LTD any and all claims, losses, damages, costs and expenses, including attorneys' fees, incurred by Finpartners LTD in the enforcement of any of the provisions of this Agreement, any CFDs and other transactions hereunder, and any other agreements between Finpartners LTD and Customer and the collection of any amounts due hereunder and thereunder. These expenses and losses may be withheld from the Client's accounts and/or from the third-party accounts, if an appropriate investigation conducted by the Company reveals that these third-party accounts also belong to the Client.

16. Disclosure of customer information

Finpartners LTD will not share or sell information regarding its Customers and/or prospective Customers, except to its employees, agents, partners, and associates as required in the ordinary course of Finpartners LTD business conducted on behalf of Customers, including, but not limited to, Finpartners LTD banking­ or credit relationships in accordance with Finpartners LTD privacy policy. Finpartners LTD may also disclose to federal or state regulatory agencies and law enforcement authorities' information regarding Customer and Customer's transactions in response to a request for such information or in response to a court order or subpoena.

17. Joint accounts and/or trust accounts

If more than one natural person executes this Agreement as Customer, all such natural persons agree to be jointly and severally liable for the obligations assumed in this Agreement. If this Agree­ ment is executed by a trust, unincorporated association, partnership, custodian or other fiduciary, such Customer hereby agrees to indemnify, defend, save and hold free and harmless Finpartners LTD for any liabilities, claims, losses, damages costs and expenses, including attorneys' fees, resulting directly or indirectly from breach of any fiduciary or similar duty or obligation or any allegation thereof, including attorneys' fees.

18. Amendments

Customer understands, acknowledges and agrees that Finpartners LTD may amend or change this Agree­ ment at any time. Finpartners LTD will provide notice to Customer of any such amendment or change by posting the amendment or change to the website or by sending an e-mail message to Customer. Customer agrees to be bound by the terms of such amendment or change on the earlier of: ten (10) days after Finpartners LTD has posted notice of such amendment or change to the Corporate website; or (y) on the date of the entry of any Order other than a Liquidating Order. In the event that Customer objects to any such change or amendment, Customer agrees to liquidate Customer's Open Positions and instruct Finpartners LTD regarding the disposition of all assets in Customer's Account within ten (10) Business Days after notice of the amendment or change has been posted to the Corporate website. No waiver or amendment of this Agreement may be implied from any course of dealing between the parties or from any failure by Finpartners LTD or its agents to assert its rights under this Agreement on any occasion or series of occasions. No oral agreements or instructions to the contrary shall be recognized or enforceable.

19. Termination

This Agreement shall continue and be in effect until termination by Customer or Finpartners LTD. Cus­tomer may terminate this Agreement if: (i) Customer has no open positions and no liabilities held by or owed to Finpartners LTD; and (ii) Customer has provided three (3) days' written notice to Finpartners LTD by e-mail to [email protected] to Finpartners LTD; and (iii) Finpartners LTD has accepted the notice as provided in Section 13 hereof. Finpartners LTD may, in its sole discretion, terminate this Agreement at any time, effective as of the close of business on the day notice is sent to Customer. If the Client violates the terms of the Customer Agreement, including its integral parts listed in clause 4.1, including the Client's refusal to undergo the necessary verification, the Company has the right, in addition to terminating this Agreement, to cancel any of the Client's transactions and liquidate some or all existing positions on the Client's trading accounts at its own discretion. Any violation of the terms of this Agreement by the Client deprives the Client of the right to demand payment or refund from the Company. Termination by either party shall not affect any Contracts or other transactions previously entered into as part of this Agreement and shall not relieve either party of any obligations set out in this Agreement, nor shall it relieve Customer of any obligations arising out of any deficit balance.

20. Entire agreement

This Agreement together with the Customer Account Application constitutes the entire agreement between Finpartners LTD and the Customer superseding any and all prior written and oral agreements.

21. Recordings

Customer acknowledges and agrees that any and all conversations between Customer and Finpartners LTD principals, agents, employees or associates, including Finpartners LTD Trading Desk and customer service and operations desks may, at the option and in the sole discretion of Finpartners LTD, be recorded­ electronically with or without the use of an automatic tone warning device. Customer further agrees to the use of such recordings and transcripts thereof as evidence by either party in connection with any dispute or proceeding (including any proceedings held by The Financial Commission) that may arise involving Customer or Finpartners LTD.

22. Binding effect

This Agreement shall be continuous and shall cover, individually and collectively, all Accounts of Customer at any time opened or reopened with Finpartners LTD, irrespective of any change or changes at any time in the personnel of Finpartners LTD or its successors, assigns, or affiliates. This Agreement, including all authorizations, shall inure to the benefit of Finpartners LTD and its successors and assigns, whether by merger, consolidation, or otherwise and shall be binding upon Customer and/or the personal­ representatives, heirs, executor, administrator, trustee, legatees, legal representative, successors­ and assigns of Customer. If any court or competent authority finds that any provision of this Agreement (or part of any provision) is invalid, illegal or unenforceable, that provision or part provision shall, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Agreement shall not be affect. If any invalid, unenforceable or illegal provision of this Agreement would be valid, enforceable and legal if some part of it were deleted, the parties shall negotiate in good faith to amend such provision­ such that, as amended, it is legal valid and enforceable, and to the greatest extent possible, achieves the parties' original commercial intention.

23. Law and jurisdiction; severability

This Agreement shall be governed and construed in accordance with the laws of Cook Islands. Any disputes and misunderstanding between Finpartners LTD and the Customer shall be settled by means of negotiations between the parties. In the event the parties fail to reach an agreement, they agree to resolve disputes through The Financial Commission (www.financialcommission.org) (“The Financial Commission”). The Customer may bring no action arising out of the Agreement, regardless of form, more than 45 days after the cause of such action.

This is a legally binding contract.

Do not press “I agree” button until you have carefully read all of the foregoing completely and completed the customer account application.

Your acceptance below by pressing “I Agree” button acknowledges that you have carefully read, in its entirety, and understood the Customer Agreement, Authorization to Transfer Funds, Consent to Electronic Statements, Agreement to Use Collateral, Risk Disclosure Statement, Secondary Risk Disclosure­ (High Risk Investment), and Trading Policies and Procedures, and that you agree to all of the provisions contained therein. Your acceptance below by pressing “I Agree” button further represents, warrants and certifies that the information provided by you in the Customer Account Application is correct and complete. By clicking on “I agree” you accept the terms of this Customer Agreement.

Annex A

Consent to electronic transmission of account statements

Customer hereby consents to receive account statements online. Customer will be able to generate daily, monthly and annual account statements detailing transaction activity, profit and loss state­ ments, open positions, margin balances, account credits and debits, etc. Statements are deemed received when made available to Customer by Finpartners LTD, regardless of whether Customer actually accessed the statement. Customer is responsible for alerting Finpartners LTD to any change in his/her e-mail address.

Annex B

Authorization to transfer funds

Customer hereby agrees that Finpartners LTD may, at any time and from time to time, in the sole discre­ tion of Finpartners LTD, apply and transfer from any of Customer's Accounts with Finpartners LTD to any of Customer's other accounts, whether held at Finpartners LTD or other approved financial institutions, any of the CFDs, currencies, securities or other property of Customer held either individually or jointly with others to another account.

Payments sent to any one of Finpartners LTD' Bank accounts or accounts held by Finpartners LTD with third-party Payment Service Providers (PSP) will be credited on receipt of cleared funds. Finpartners LTD can not be held liable if payments remitted to such accounts are not received or otherwise not credited to us no matter if the cause is technical in nature, due to some compliance related issues, or if it involves fraud on part of the bank or PSP where the funds were sent. Finpartners LTD will always act in the best interest of it's clients, and look to assit you in locating and reversing any such payments, however, it is your responsibility, as the remitter of the payment in question, to do whatever is necessary to recover your funds from either the bank or PSP where they were remitted.

Annex C

Agreement to use collateral

Customer authorizes Finpartners LTD to sell, pledge, rehypothecate, assign, invest, commingle and other­ wise use any Collateral held by Finpartners LTD, including, but not limited to, using the CFDs as collateral­ for a loan to Finpartners LTD, and, further dealing with the Collateral, as provided in the Customer Agreement (including, but not limited to Paragraph 6 thereof). Where Customer's Account consists of more than one Account, this authorization shall apply to all of Customer's Accounts with Finpartners LTD This Agreement to Use Collateral shall remain in effect so long as Customer's Account with Finpartners LTD remains open or Customer has any obligations of any kind to Finpartners LTD, under the Customer Agreement.

Annex D

Risk disclosure statement

Consideration of Finpartners LTD agreeing to enter into contracts for difference on instruments such as currencies, equities, debt securities, indicies and commodities (“CFDs”) with the Customer, Customer acknowledges, understands­ and agrees that:

1. Trading Is Very Speculative and Risky CFDs is highly speculative and is suitable only for those customers who (a) understand and are willing to assume the economic, legal and other risks in­volved, and (b) are financially able to assume losses significantly in excess of Margin or deposits. CFDs is not an appropriate investment for retirement funds. Customer represents, warrants and agrees that Customer understands these risks; that Customer­ is willing and able, financially and otherwise, to assume the risks of CFDs and that loss of Customer's entire Account Balance will not change Customer's­ life style.

2. High Leverage And Low Margin Can Lead To Quick Losses The high leverage and low Margin associated with CFDs. Customers must maintain the Minimum Margin Requirement on their Open Positions at all times. It is the Customer's responsibility to monitor his/her Account Balance.

Finpartners LTD has the right to liquidate any or all Open Positions whenever the Minimum Margin Re­ quirement is not maintained. Increasing leverage increases risk.

3. Prices, Margin And Valuations Are Set By Finpartners LTD And May Be Different From Prices Reported Elsewhere Finpartners LTD will provide prices to be used in trading, valuation of Customer positions and determination of Margin requirements. Although Finpartners LTD expects that these prices will be reasonably related­ to prices available in the interbank market, prices reported by Finpartners LTD may vary from prices available to banks and other participants in what is known as the interbank market. Finpartners LTD will exercise considerable discretion in setting and collecting Margin. Finpartners LTD is authorized to convert funds in Customer's Account for Margin into and from such Foreign Currency at a rate of exchange determined by Finpartners LTD in its sole discretion on the basis of then prevailing money market rates.

4. Telephone Orders And Immediate Execution Market Orders executed through the Finpartners LTD Trading Desk are completed when Finpartners LTD says “deal” or “done.” At that point Customer has bought or sold and cannot cancel the Market Order. By placing Market Orders through the Finpartners LTD Trading Desk, Customer agrees to such immediate execution and accepts the risk of this immediate execution feature.

5. Market Recommendations Are Informational, Customer Makes Independent Decisions, And Finpartners LTD Is Not An Adviser Or A Fiduciary To Customer The market recommendations provided by Finpartners LTD do not constitute an offer to buy or sell, or the solicitation of an offer to buy or sell, any CFDs. Each decision by Customer to enter into a CFD or other transaction with Finpartners LTD and each decision whether a CFD or other transaction is appropriate­ or proper for Customer is an independent decision by Customer. Finpartners LTD is not acting as an advisor or serving as a fiduciary to Customer. Customer agrees that Finpartners LTD has no fiduciary duty to Customer and no liability in connection with and is not responsible for any liabilities, claims, damages,­ costs and expenses, including attorneys' fees, incurred in connection with Customer following Finpartners LTD trading recommendations or taking or not taking any action based upon any recommenda­tion or information provided by Finpartners LTD.

6. Recommendations Are Based On Personal Judgments And Are Not Guaranteed The market recommendations of Finpartners LTD are based solely on the judgment of Finpartners LTD per­ sonnel. These market recommendations may or may not be consistent with the market positions or intentions of Finpartners LTD, its affiliates and employees. The market recommendations of Finpartners LTD are based upon information believed to be reliable, but Finpartners LTD cannot and does not guarantee the accuracy or completeness thereof or represent that following such recommendations will reduce or eliminate the risk inherent in CFDs.

7. There is no Central Market or Clearinghouse Guarantee of Payment Each CFD is a contract directly between Finpartners LTD and the Customer. There is no clearing house and no guarantee by any other party of Finpartners LTD payment obligations to the Customer. Customer­ must look only to Finpartners LTD for performance on all CFD in Customer's Account and for return of any Margin or Collateral.

8. No Guarantees of Profit There are no guarantees of profit or freedom from loss in CFDs. Customer has received no such guarantees from Finpartners LTD or from any of its representatives­. Customer is aware of the risks inherent in CFDs and is financially able to bear such risks and withstand any losses incurred.

9. Customer May Not Be Able To Close Open Positions Due to market conditions or other circumstances Finpartners LTD may be unable to close out Customer's position at the level specified by Customer, and Customer agrees Finpartners LTD will bear no liability for failure to do so.

10. Trading Ahead and Along Finpartners LTD its personnel and affiliates and various other parties may execute orders at the same or better prices ahead of a Customer Order.

11. Third Party Agents In the event that Customer grants trading authority or control over Customer's Account to a third party (the “Trading Agent”), whether on a discretionary or non discretionary basis, Finpartners LTD shall in no way be responsible for reviewing Customer's choice of such Trading Agent or for making any recommendations with respect thereto. Finpartners LTD makes no representations or warranties concern­ing any Trading Agent; Finpartners LTD shall not be responsible for any loss to Customer occasioned by the actions of the Trading Agent; and Finpartners LTD does not, by implication or otherwise, endorse or approve of the operating methods of the Trading Agent. If Customer gives the Trading Agent authority­ to exercise any of its rights over its Account, Customer does so at Customer's risk. Even though the undersigned grants authority to Trading Agent, client should be diligent and closely scrutinize all account activity.

12. Internet Trading Since Finpartners LTD does not control signal power, its reception or routing via Internet, configuration of Customer's equipment or reliability of its connection, Finpartners LTD shall not be liable for any claims, losses, damages, costs or expenses, including attorneys' fees, caused, directly or indirectly, by any breakdown or failure of any transmission or communication system or computer facility or trading software, whether belonging to Finpartners LTD, Customer, any market, or any settlement or clearing system­ when Customer trades online (via Internet).

13. Telephone Orders Finpartners LTD is not responsible for disruption, failure or malfunction of telephone lines (if such service is available and offered by Finpartners LTD).

14. Quoting Errors Should a quoting error occur due to a mistype of a quote or a misquote given by telephone and/or electronic means (including responses to Customer requests), Finpartners LTD is not liable for any resulting­ errors in Account Balances and reserves the right to make necessary corrections or adjustments on the Account involved. Any dispute arising from such quoting errors will be resolved on the basis of the fair market value, as determined by Finpartners LTD, in its sole discretion, of the relevant Currency at the time such an error occurred. In cases where the prevailing market represents prices different from the prices Finpartners LTD has posted on our screen, Finpartners LTD will attempt, on a best efforts basis, to execute trades on or close to the prevailing market prices. These prevailing market prices will be the prices, which are ultimately reflected on the Customer statements. This may or may not adversely affect customer realized and unrealized gains and losses.

Annex E

Trading policies and procedures

1. Introduction
Finpartners LTD Trading Policies and Procedures are an integral part of your Customer Agreement. It is your responsibility as Customer to carefully read these Trading Policies and Procedures and to inform Finpartners LTD of any questions or objections that you may have regarding them before entering each and every trading Order. In entering your trading Orders with Finpartners LTD you agree, represent, warrant and certify that you understand and accept these Trading Policies and Procedures, as they are set forth here and as may be amended from time to time by Finpartners LTD, in its sole discretion, and you agree to comply with these Trading Policies and Procedures as currently in effect at any time.

2. Trading hours
All references to Finpartners LTD hours of trading are in Greenwich Mean Time (“GMT”) using a 24 hour format. Finpartners LTD normally provides access for CFDs on the website from 21:00 GMT on Sunday to 21:00 GMT on Friday, but Finpartners LTD reserves the right to suspend or modify its trading hours at any time and on such an event will inform clients in advance on a best efforts basis of any changes in its operating hours. OTC CFDs operate 24 hours a day. Following submission of an Order to trade, it is the sole responsibility­ of Customer to remain available for Order and Fill confirmations, and other communications regarding Customer's Finpartners LTD Account until all open Orders are completed. Thereafter, Customer must monitor Customer's Account frequently when Customer has Open Positions in the Account.

3. Customer accounts; initial deposits; demo trading systems

3.1 Documents Before you can place an Order with Finpartners LTD, you must complete the Customer Account Application­ and read the Customer Agreement, including the Risk Disclosure Statement, Secondary Risk Disclosure Statement and these Trading Policies and Procedures and all applicable addenda. You must deposit sufficient funds in your Account.

3.2 Currency for Rendering Accounts All initial deposits to Customer Accounts will be accepted only in U.S. Dollars, and, unless settlement­ and delivery of a Foreign Currency have taken place, all Account Balances will be computed and reported only in U.S. Dollars.

3.3 Recognition of Deposits No deposit shall be recognized until the wire or check has been fully cleared and collected by Finpartners LTD's bank or depository institution. You will be notified via online account management system once your funds have been received by Finpartners LTD and are available for trading.

3.4 Demo trading account
The Company provides the Client with free access to a demo trading account for the purpose of practicing and developing trading skills. The Client acknowledges and agrees that a demo trading account is registered for personal use only. The registration or use of a demo account for commercial purposes is strictly prohibited.

4. Margin requirements
Customer shall provide and maintain with Finpartners LTD margin in such amounts and in such form that Finpartners LTD, in it is sole discretion may require. Finpartners LTD does not require Customers to pay the full price of CFDs Customer may buy and sell. Instead, Customer is required to post a small percentage of the full amount which Customer is obligated to pay to Finpartners LTD under the CFD, to secure Customer's obligations to Finpartners LTD Margin includes Required Margin for Open Positions, which is based on (i) the Opening Margin Requirement; (ii) the Minimum Margin Requirement; (iii) the market value of Open Positions; and (iv) any additional amount as Finpartners LTD, in its sole discretion, believes is prudent to require. Customer must maintain the Minimum Margin Requirement on their Open Positions at all times. Finpartners LTD has the right to liquidate any or all Open Positions when­ ever the Minimum Margin Requirement is not maintained, according to paragraph 5 hereof. Margin requirements are subject to change at any time in Finpartners LTD's sole discretion and without prior notice. No previous margin requirement shall preclude Finpartners LTD from increasing that requirement without prior notice. Finpartners LTD may, in its sole discretion, elect to impose on a disclosed on undis­ closed basis limitations on the maximum number of Open Positions allowed at any time.

5. Liquidation level
Subject to all additional rights of Finpartners LTD under the Customer Agreement, in the event that, in the sole opinion of Finpartners LTD and in accordance with Finpartners LTD's reasonable best estimate of then prevailing obtainable market Spot Rates, and regardless of whether or not prior Margin Calls have been issued or met, if the Margin Balance should at any time equal or fall below the Minimum Margin Requirement for Customer's Account in the aggregate, Finpartners LTD will have the right but not the obligation to liquidate any part of or all Open Positions in Customer's Account. Customers are responsible for placing their own Stop Loss Orders to minimize losses. Any failure by Finpartners LTD to enforce its rights hereunder shall not be deemed a future waiver of such rights by Finpartners LTD.

6. Margin calls
Finpartners LTD does not make margin calls in the ordinary course of business. Finpartners LTD maintains the right to liquidate customer positions as described above. However, Finpartners LTD may from time to time and in its sole discretion, call Customer and request that Customer deposit additional Collateral to secure Customer's obligations to Finpartners LTD, over and above the balance in Customer's Account. Any call for additional margin without exercising the rights to liquidate Customer positions shall not be deemed precedent for future calls nor future waiver of such liquidation rights by Finpartners LTD.

7. Withdrawals
To make a withdrawal from a Customer account, it is necessary to submit a withdrawal request through the Finpartners LTD website. The Customer must provide all the required withdrawal information. Upon receipt of the withdrawal request, Finpartners LTD will notify the Customer. Withdrawal requests may take up to two (2) business days to process once received.

The Company reserves the right to increase the withdrawal processing time in case of temporary unavailability of the payment method for technical, legal, operational, force majeure, or other reasons. In such circumstances, the Customer has the right to cancel the withdrawal through the selected payment method and choose an alternative one from the payment options available in the Personal area.

8. Minimum balance requirement
In the event the remaining balance on the trading account falls below $0.01, it will be written off the account.

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registered in the Cook Islands with registration number

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