About - OWM

Oriental Wealth Markets Limited

About OWM

Registered with Vanuatu Brokers, VFSC Regulatory 40299

Introduce OWM

OWM offers investors upwards of 100 foreign exchange and other financial derivatives, including foreign exchange, spot and futures, stock indices, and stocks. Provides investors with an MT4 trading software platform, to achieve one-stop trading, and support for ECN trading. In addition OWM also provides a variety of trading aids to help investors improve their ability to win in the market.

OWM (Oriental Wealth Markets Limited) was founded in 2017 in the capital of Vanuatu (Port Vila) by professionals in the field of finance, and experts in the field of e-commerce, and over the last 4 years has grown rapidly into a well-known forex trader. Over the years, OWM’s mission is to improve the online trading experience for traders by providing competitive spreads, superior trading platforms, and a level trading playing field. Our journey: the company was founded in 2017, established a Hong Kong office in 2018, the Jakarta office in 2019, and the Kuala Lumpur office in 2020. In four years we have grown by leaps and bounds and have served investors in over a dozen countries. All along OWM has been committed to providing investors with a stable and secure trading platform, competitive spreads, convenient access experience, and a professional customer service team, enabling customers to enjoy an excellent trading environment. We present the most realistic market quotes to customers and stand alongside our customers when they make their orders in the market. Over the past four years, OWM has repeatedly won international trader awards for its good business reputation and professional services and has been favored by more and more investors.

Why Choose Us

Fund Segregation

The safety of investor funds is a key element of OWM's business. We keep all client funds related to trading segregated in a separate security account, and each fund is identified by a corresponding number to protect client assets. The security account is separate from the company's operating account and is audited annually by a professional accounting firm. The company only uses its own funds to bear business risks and does not use clients' funds for any nominal profit, ensuring the safety of clients' funds.

Insurance protection

We comply with the Vanuatu Financial Commission regulations and OWM works with reputable international insurance companies. We have a high level of commercial insurance for our investors. This protects investors in the event of a company going bankrupt, with up to $50,000 in compensation.

No Negative Balance Guarantee

OWM offers its clients a "No Negative Balance Guarantee" to ensure maximum control of trading risks and to ensure that clients do not have negative balances in their accounts and have to pay additional fees.

Client privacy and confidentiality

OWM strictly abides by all privacy and legal regulations and has established a strict system of client information confidentiality to ensure that private information is not disclosed to any third-party organizations or individuals. OWM will not disclose any non-public information to anyone except as approved by law and regulation.

OWM puts integrity and service at the forefront of our mission and business development.

Announcement

CRM Successful Upgrade Notice

Dear customers : Your CRM

10/03/2021

2021 Notice of Adjustment of Deposit and Withdrawal Transaction Hours on National Day Holiday

Dear OWM customers, Hello

09/29/2021

Notice of CRM Upgrade

Dear customers, To enhanc

09/28/2021

2021 Notice of Adjustment of Deposit and Withdrawal Transactions Hours on Mid-Autumn Festival Holiday

Dear OWM customers, Hello

09/17/2021

Terms

If you have any questions or need more information, please fill out the form below.

We will contact you as soon as possible. Looking forward to cooperating with you, Thank you.

Oriental Wealth Markets Limited

Products

Services

Post

Education

Oriental Wealth Markets Limited (OWM or OWMFX) is regulated by the Vanuatu Monetary Commission under its securities dealer license number 40299.

Risk Warning: Trading derivatives may pose a very high risk to your capital, please only trade with money that is within your loss tolerance. Trading derivatives may not be suitable for all investors. Please ensure that you fully understand the risks involved and seek independent advice if necessary. Please ensure that you have read and fully understand our Risk Disclosure Statement.

Restricted Territories: Not intended for residents of the United States, Hong Kong, Japan and the Islamic Republic of Iran who apply, and is not intended for distribution to or use by any person in any country or jurisdiction where such distribution or use would be contrary to local laws and regulations.

OWM is an OTC derivatives issuer that trades on a principal-to-principal basis. Its issuances are also not traded through a stock exchange.

Client Agreement

Trade Responsibly: Contracts for Differences (‘CFDs’) and Spread Bets are derivative financial products that are traded on margin (‘Leveraged Products’). Trading on margin carries a significant level of risk since leverage can magnify your profits as well as your losses. Thus, Leveraged Products may not be suitable for you as you may lose all your invested capital. You should not risk more than you are prepared to lose. If you are unsure about trading, you may wish to seek independent advice first. Please read carefully our Risk Disclosure Notice for further details on the risks of trading Leveraged Products.

1.INTRODUCTION

1.1This Client Agreement (the ‘Agreement’), including the Schedules as amended from time to time, is the document which governs the relationship between you (also referred to as ‘Client。 ‘Customer。‘your’ and ‘yourself’, as appropriate) and Oriental Wealth Markets Limited (also referred to as ‘Oriental Wealth Markets Limited’, the ‘Firm。‘we’, ‘us。‘our’ and ‘ourselves’, as appropriate) concerning the services we provide and your activity with us.

1.2For your benefit and protection, please ensure you take sufficient time to read the Agreement as well as any other additional documentation and information available to you via our Website prior to opening an account and/or carrying out any activity with us. You should contact us for any further clarification, or seek independent professional advice (if necessary).

2.SCOPE OF THE AGREEMENT

2.1By accepting these terms you enter into a legally binding agreement with us.

2.2A glossary of any capitalised terms can be found on Schedule A to this Agreement.

2.3The Agreement includes, in addition to any Schedules and the ‘Account Opening Form’ completed by you through our Website, any information provided to you during the registration procedure.

2.4Please note that there are other documents and information available on our Website, which form part of the Agreement, and provide more details on us and your activities carried on with us, such as:

a)the ‘Order Execution Policy7 that explains how trades are executed; and

b)the ‘Risk Disclosure Notice7 that summarises the key risks involved in investing in CFDs and Spread Bets.

Additional documents and other information which are available to you on our Website and through our trading platforms, but that do not form part of the Agreement include:

c)the ‘Conflicts of Interest Policy’ that explains how we handle any conflicts of interest in order to treat our Clients fairly;

d)the ‘Client Categorisation Notice’ specifies how a client is being categorised in accordance with applicable legislation;

e)the ‘Privacy Policy’ that explains how we deal with certain information you provide to us;

f)the ‘Key Investor Information Documents’ that provide you with key information about the products we offer; and

g)various instructions, guides and working examples.

3.COMMENCEMENT, DURATION OF THE AGREEMENT AND RIGHT TO CANCEL

3.1The Agreement shall commence once we have informed you about your account being activated. This is, once we have completed due diligence and satisfied our requirements in terms of ‘Know-Your-Customer’ or any other procedures.

3.2You have the right to cancel the Agreement by giving us notice in writing within the first fourteen (14) days of your account being activated. We will return to you any amount you have transferred to us, subject to you not having entered into any trades via our platform(s).

3.3Where the Agreement has not been cancelled, it will continue to be in effect until its termination, in accordance with the provisions contained in the ‘Termination’ section of this document (section 24).

4.THE SERVICES WE PROVIDE

4.1We will offer you, on an execution-only basis, access to trading a number of instruments in the form of CFDs and Spread Bets (also referred to as leveraged Products’).

4.2We will act as ‘Matched-Principal7 at all times in relation to your trades with us, and we will do so on a non-advised basis.

4.3We do not provide investment, financial, legal, tax or regulatory advice nor do we provide any other form of recommendation. You understand that you shall make your own assessment of any transaction prior to entering into a trade or a bet, and shall not rely on any opinion, material or analysis provided by us or any of our affiliates, employees, or other related parties

as being advice or recommendation. If you are unsure of whether proceeding with this Agreement, you may wish to seek independent advice.

4.4We do not offer investment research, and any material containing market analysis is considered marketing communication and should not be construed as advice, recommendation or research.

4.5You understand that CFDs and Spread Bets are derivative products, and therefore you will not be entitled to own any underlying instrument. You also understand that no physical delivery of any underlying asset shall occur.

4.6You accept that OWM(Oriental Wealth Markets Limited) is the only execution venue in relation to your trading activity under this Agreement. Although we may transmit your orders for execution to third-party liquidity providers through an electronic communication platform, contractually we are the sole counterparty to your trades and bets and any execution of orders is done in our name. Further information can be found in our ‘Order Execution Policy’.

4.7You may trade from 00:00:01 (Eastern European Time Zone) on a Monday until 23:59:59 (Eastern European Time Zone) on a Friday. It should be noted that certain financial instruments have specific trading timeframes which can be found in the contract specifications on our Website. You are responsible for looking at these contract specifications for further details prior to trading. You shall be notified of any Firm holidays either through the internal e-mailing system or via any other means that we may from time to time employ.

4.8We are entitled to refuse the provision of any investment services to you, at any time we deem necessary, without being obliged to inform you of the reasons to do so.

5.CLIENT CATEGORISATION

5.1We can review the Client Categorisation at any time, in accordance with the applicable rules. You will be notified in writing in the event of any change which may affect you.

6.OPENING AN ACCOUNT

6.1Following receipt of your ‘Account Opening Application Form。we may use the information you have provided us to conduct any further enquiries about you as we may deem necessary or appropriate in the circumstances. This includes, but is not limited to, verifying your identity information, obtaining references from third parties such as financial institutions or your employer. We may also conduct other searches with third-party information providers and databases (public or otherwise), including credit searches which may appear on your credit history. You understand that we may conduct these enquiries at any stage of the relationship, and we expect you to assist us with any additional information we may require, as failure to do so may lead to termination of the relationship between you and us.

6.2We are entitled to rely on the information you have provided in your ‘Account Opening Application Form, as being correct and accurate at all times, unless you notify us otherwise in writing. It is your responsibility to notify us as soon as possible in writing of any change in the information provided.

6.3Based on the information provided by you, and in accordance with the applicable rules as amended from time to time, we will make an assessment of whether you have sufficient knowledge and/or experience to understand the risks associated with trading Leveraged Products. The acceptance of your account will be subject to the outcome of this assessment.

6.4Where we accept your application to open an account, we will confirm this to you in writing and we will provide you with details to access your account, specifically your account number and password (the ‘Access Codes’)• Acceptance of you as a Client is no guarantee that any further account with us will be accepted.

7.OUR PLATFORMS

7.1Following your account activation, you will be able to:

a)download and install (where applicable) the trading and/or spread betting platforms (the ‘Software’), or where you choose to use a web-based version of the Software (where available), you should ensure they are accessible and operational.

b)use your Access Codes to log in to the Software, as well as OWM(Oriental Wealth Markets Limited) Direct from where you can view your Vault. You are responsible for maintaining or changing your password at all times. It is also your responsibility to keep any correspondence from us regarding your Access Codes private and confidential.

7.2Further to the above, you are responsible for ensuring that you are able to access our Software when you need to and in the times when it is available. Your responsibility extends to ensuring you have access to a reliable internet connection, and maintaining any devices used to this end.

7.3The Software, which may have been developed by a third party, is provided ‘as is’. We will ensure, but cannot guarantee, that the Software supports data security protocols compatible with those used by OWM(Oriental Wealth Markets Limited). We also cannot guarantee that the Software is free of any errors or deficiencies.

7.4We will, to a reasonable extent, maintain the Software and any other related systems up to date. We and/or any relevant third party may perform this maintenance from time to time which includes shutting down, restarting and/or refreshing the servers to ensure, or procure to ensure the effective and efficient operation of the Software. These actions may cause the Software to be inaccessible and/or inoperative for a period of time, therefore you accept that we will bear no responsibility for any loss, including financial loss and/or loss of opportunity due to maintenance and/or any action or omission of OWM(Oriental Wealth Markets Limited) and/or the third-party software provider.

7.5We will endeavour to make the Software and any other systems available when required by you, but we cannot guarantee their continuous availability at all times for the following reasons, including but not limited to:

a)Failures and/or errors, including of technological nature such as failure with internet connectivity which may affect the access to the Software, which either you or we rely on;

b)Suspension of service availability due to maintenance, repairs, updates, developments and other issues outside of our control. We will exercise reasonable efforts to carry out such activities outside normal trading hours. Where this is not possible, we will endeavour, within reason, to provide you with prior notice.

SECURITY, AUTHENTICITY AND ACCESS

8・

8.1We will only accept instructions from you and/or your Authorised Representative pursuant to a duly signed ‘Power of Attorney’. For the avoidance of doubt, Authorised Representatives shall not be considered Clients of OWM(Oriental Wealth Markets Limited). However, we will consider any instructions from an Authorised Representative as coming directly from you, and we may act upon such instructions without the need to confirm their authenticity or validity.

8.2In addition to anything else specified above, we may rely on any instructions coming from any person in possession of your Access Codes as if these instructions were coming from yourself, without us making any further enquiry.

8.3If, under any circumstances, you reveal your Access Codes to any person, whether intentionally or unintentionally, we shall bear no responsibility for any loss that may arise, including, but not limited to financial loss and/or loss of opportunity due to your actions and/or omissions.

8.4You are responsible for keeping any information regarding your dealings with us, private and confidential. We will bear no responsibility in the event that any person attains unauthorised access to any information regarding your dealings with us, where that information is:

a)held by you;

b)being transmitted via electronic or any other means, by you to OWM(Oriental Wealth Markets Limited) and/or any other party authorised by us;

c)being transmitted via electronic or any other means, by us to you and/or any Authorised Representative.

8.5You must notify us as soon as possible if you become aware of your Access Codes or any other information regarding your dealings with us being used or becoming known by any person without your authorisation. You accept that we are unable to identify any instances where a person, other than yourself or your Authorised Representative (where applicable), is accessing our Software with your credentials without your express consent.

8.6We reserve the right to revoke your access and/or the access of any Authorised Representative to our Software at any time, where we deem necessary.

8.7Where you have not carried any activity and/or transactions for a period of time, as determined within reason by us, we reserve the right to carry out additional checks and/or request additional documentation from you before we allow you to resume any activity with us.

. INSTRUCTIONS AND ORDERS

9.1We will only accept instructions transmitted via the means approved by us, including, Under certain circumstances, provided that we are satisfied of your identity and of the clarity of the instructions, we accept instructions via telephone or in person. We will only accept orders transmitted via the Software. If for any reason you are unable to access the Software to transmit orders for the purposes of trading CFDs or Spread Bets, you may transmit orders by contacting the Dealing Department by telephone, in which case we need to be satisfied of your identity. Orders via telephone will be accepted only in our official language. It should be noted that the Firm reserves the right to reject such verbal orders when the operator of the Dealing Department is not satisfied with the Clients identify or clarity of the orders. The Client accepts that at times of excessive transaction flow there might be delay in connecting over the telephone with an operator of the Dealing Department, especially when there are important market announcements.

9.2You may communicate with us for support and any instructions other than orders in any of the languages available on our website during business hours. Communication after business hours that requires immediate action on our behalf will only be accepted in our official language.

9.3Where information has not been transmitted to us via approved means, or where you have misinterpreted any instruction and/or information, it is your responsibility to make the

necessary amendments and we will bear no responsibility for any loss, be it financial or of opportunity in connection to said instruction.

9.4We bear no responsibility for any loss that arises as a result of delayed or unreceived communication sent by us to you.

9.5You understand that time is important when trading Leveraged Products, therefore you are responsible for ensuring that any communication in relation to your dealings with us is sent to us on time.

9.6We reserve the right to accept, either in part or in full, or reject, any instructions from you. We may also contact you regarding changes in the execution of any recent or future transactions you may conduct, as a result of monitoring your trading activity. For instance, where your account balance frequently results in negative equity, we may propose to increase your margin requirements in order for you to continue trading, irrespective of the applicable trading conditions for other clients. Alternatively, we reserve the right to execute any instruction received from you without any further enquiry.

9.7We may, at our discretion confirm any instructions received from you via any durable medium or telephone.

9.8Where you have appointed an Authorised Representative to deal with us on your behalf, and you wish to cancel his/her appointment you must notify us in writing. Until we receive the said notice, any instructions we may receive from the Authorised Representative shall (a) be deemed valid, and (b) shall fully commit you.

9.9Except where the Software permits, all orders to trade or bet on the financial instruments we offer are final and cannot be cancelled or deleted, unless we expressly agree to such cancellation or deletion.

10.UNDERSTANDINGS OF BOTH PARTIES

10.1We shall enter into transactions with you and conclude them in good faith.

10.2We shall take all necessary steps to ensure compliance with the applicable rules and regulations. Therefore, you agree to be bound by any decision we make in order to comply with any rule, regulation or obligation of the Firm.

10.3Where we provide you via our Website, the Software, OWM(Oriental Wealth Markets Limited) Direct, with any links to other websites and/or resources from third parties, these links are provided for information only. We have no control over the content, quality or security of the information contained on those websites and/or resources, and therefore we cannot be made responsible for any losses that may arise from your use of these.

10.4We take reasonable care in trying to ensure that any information and/or content, including third-party features on our Website, the Software, OWM(Oriental Wealth Markets Limited) Direct and e-mail communications from us is accurate and complete. However, some information may be provided ‘as is’ and on an ‘if available’ basis, and therefore we cannot give any warranties or representations (either expressed or implied), relating said features and third-party information.

10.5The product specifications and/or conditions are to be found on our Website, as amended from time to time. It is your responsibility to ensure you remain updated with regards to our product specifications and conditions, as well as any other information which may be of your interest, and you shall take all necessary actions to safeguard your interest where you believe you may be affected. You understand that the product specifications and/or conditions may be varied. You will continue to be bound by the Agreement in the event of any of these amendments taking place. However, nothing in this clause shall affect your right to terminate the Agreement, without any penalty whatsoever, subject to any existing obligations.

10.6Further to the clause above, you understand that we may remove any of our products and/or cease providing you with the ability to place an order at any time. Where we have ceased to provide any product and you have a previously open position in that product, it is your responsibility to cancel and/or close such position, otherwise we will close the position at the last available price for the relevant instrument. You also understand that any open positions on CFDs or Spread Bets with expiration date will be automatically closed at the end of the last trading day.

10.7You understand that in order for us to provide you with our services, we may enter into agreements with external service providers for any activity and/or operation we may conduct. We will do so in accordance with the applicable rules.

10.8Where your relationship with us is between one or more persons, for example through a joint account or a legal entity, all obligations and liabilities under the Agreement shall be joint and several. Any communication, including but not limited to notices and orders shall be considered as delivered to all persons that together constitute the Client.

10.9We reserve the right to reverse any transactions which we deem to be contrary to your interest or ours, for any reason.

10.10Where you are in breach (or we have reasonable grounds to believe you may be in breach) of any term contained in the Agreement, we reserve the right to temporarily or permanently suspend your access to the Software, OWM(Oriental Wealth Markets Limited) Direct, your Account(s), and/or terminate the Agreement, and/or take any other actions as we may see fit in the circumstances.

10.11By becoming a client of OWM(Oriental Wealth Markets Limited), you do not obtain any rights in any intellectual property belonging to us. Our Website, the Software, any data, information, documentation and/or creation shall be protected in accordance with the applicable laws and you shall have no right, neither at the time of entering into the Agreement, nor at any point of time in the future. All rights whether expressed or implied, and whether existing now or in the future are reserved.

10.12You shall not cause or permit any actions to be caused which might endanger or damage any intellectual property belonging to us.

10.13 You understand that you shall not copy, reproduce, duplicate, translate, assume ownership or otherwise of any rights belonging to OWM(Oriental Wealth Markets Limited).

11.CONFLICTS OF INTEREST

11.1A conflict of interest may arise when our interests compete or interfere, or appearto compete or interfere with your interests under the Agreement. You understand and agree that such circumstances may arise, and where they do, we will exercise our best endeavours to mitigate them.

11.2We are required by law to take all reasonable steps to identify and manage any potential or actual conflicts of interest between:

a)Us and any Affiliate Entity or third-party

b)Us and you

c)You and any other client

Our procedures in place regarding how we manage potential conflicts of interest can be found on our ‘Conflicts of Interest Policy’, available on our Website.

11.3Where any conflicts of interest cannot be mitigated effectively, we will disclose the general nature and/or sources of such conflicts in our ‘Conflicts of Interest Policy’.

12.YOUR MONEY

12.1Your money shall be treated, at all times, in accordance with the applicable ‘Client Money’ rules.

12.2Unless otherwise indicated, we will deposit your money in one or more segregated accounts held with a financial institution within or outside theCentral Bank of Vanuatu，separated from the Firm’s money. This means that all Client Money is treated as belonging to our clients and under no circumstance we will use it to meet any of our obligations, at any time. Your money will be pooled with money belonging to other clients in a Segregated Account, which shall act as an omnibus account. Therefore, no single Client will have a claim against a specific sum in a specific account in the event of insolvency. Any Clients claim shall be against the Money held in the Segregated Account.

12.3Any transfers shall only be effective after our systems have made the relevant credit or debit of the funds to the relevant Account(s), and whilst we will make all reasonable efforts to ensure any transfers are made effective in a timely manner, we cannot guarantee how long this process may take. We will not be liable for any delays or other losses that may arise if, for instance, you provided us with wrong or incomplete information.

12.4Any monies you transfer to us for the purposes of funding your Account shall be deposited in your Vault on the Value Date, net of any transfer fees or other charges imposed by the financial institution(s), or any intermediary involved in the process of sending or receiving the funds. We may, at our sole discretion and under no obligation, credit funds which are still in transfer before the Value Date to your Vault.

12.5We shall deposit funds into your Vault only after we are satisfied, amongst other criteria, that the funds are being sent by you or your Authorised Representative from an account in your name, and that the funds do not breach any term contained within this Agreement and/or the law.

12.6We reserve the right to request additional information and/or documentation at any time in order to be satisfied that your dealings with us, including, but not limited to deposits and withdrawals are legitimate or for any other reason so as to comply with our regulatory obligations. It is your responsibility to provide us with complete and accurate information, as failure to do so may result in delays with processing a transaction, and/or a transaction may be rejected.

12.7Further, where we are not satisfied as to the above and reject an incoming transaction, we reserve the right to return the funds to the sender net of any transfer fees or charges which we may incur. Any refund will be sent to the same source from where the funds were received. We will only deviate from this policy where we believe, at our sole discretion, that this is necessary and always in accordance with the applicable legislation.

12.8It is our policy to ensure that all withdrawals, either in part or in full of the funds you deposit with us is sent to the same source where the funds came from. Where we are unable to do so, for whatever reason, and subject to any restriction under the regulatory regime, we shall return the funds as requested in part or in full, net of any transfer fees, charges or other deductions incurred by us.

12.9We reserve the right to accept or decline any funding and/or withdrawal request by you depending on the payment method you choose, and we may suggest you an alternative for your request. More information on our accepted payment methods can be found on our Website.

12.10Further, we reserve the right to decline any funding and/or withdrawal request where we believe that such request may lead to a breach of any legal and/or regulatory obligation. This includes instances where we are not satisfied with the documentation provided by you. In this case, we reserve the right to reverse the transaction in part or in full, net of any transfer fees, charges or other deductions incurred by us. You understand that there may be instances where we will be unable to provide you with an explanation as to why we cannot proceed with your request.

12.11Where you hold several Accounts with us, and we reverse any transaction from you for any reason, we may merge your funds held in those Accounts, as described above.

12.12You shall make any requests relating to the administration of your Account(s) via OWM(Oriental Wealth Markets Limited) Direct.

12.13We will take reasonable steps to ensure keeping you informed about the progress of any funding and/or withdrawal request, specifically in relation to processing times and any required documentation that if not in place may result in delays. Further information about the processing times can be found on our Website, however, this information is provided for indicative purposes only. You understand that there may be instances where we cannot guarantee these times because of events outside of our control.

12.23Where you receive money from us by mistake, you agree to hold such amount of money in trust for the benefit of OWM(Oriental Wealth Markets Limited) or the beneficial owner. In the event you use any funds sent to you by mistake, we will have a claim on those funds, together with any profit derived from the use of those funds, on behalf of the beneficial owner. In the same way, we shall not compensate you for any losses incurred by you as a result of you using the said funds. The claim for the full amount shall remain.

12.24Where we are required to do so by law and/or any applicable rules, we reserve the right to deduct or credit any amount from your Account(s).

12.25We reserve the right to set-off any liability of yours under this Agreement. Where the liabilities to be set-off are expressed in different currencies, we may convert said liabilities at a market rate of exchange.

12.26Where we net-off any amount due by deducting it from your Account(s), we will consider the obligation as satisfied and discharged. We reserve our rights on any obligation which cannot be considered satisfied.

12.27Where your Account is inactive for a period of 5 years with a positive balance (i.e. there are funds available on your Account), and you fail to be contacted after we take all reasonable steps to do so, we will have the right to cease treating those funds as Client Money and will transfer them either to a suspense account or to a charity of our choice. For the avoidance of doubt, an account shall be considered inactive when, during a 5 year period, no transactions have been carried out in relation to the account by you or any authorised person.

13. OUR CHARGES

13.1 Prior to entering into any transaction with us via the Software, please ensure you have considered any and all applicable charges such as Spread(s), Commissions and Swap(s), which are available on our Website. It is your responsibility to ask for further clarifications should you require so. Any applicable charges shall be directly deducted from your Account(s).

13.2We reserve the right to change, from time to time, any of the charges applicable to your dealings with us. We will provide you with prior written notice where we deem the changes to be material, unless such change comes as a result of an unforeseen market circumstance, where we may notify you on or after the event. You will find the most up-to-date information about our charges on our Website.

13.3In the event you are dissatisfied with any changes we may make to our charges, you may contact our Customer Support Department, and/or terminate the Agreement in accordance with the provisions contained herein.

13.4For Swaps, depending on the position held and the prevailing interest rates of the currency pair involved in a transaction, your Account may be credited or debited with financing. The operation is conducted at 23:59 (server time) and the resulting amount is automatically converted into your Balance Currency.

13.5From Mondays to Thursdays, Swaps are charged once for every business day, but on Fridays these are charged three times the size in order to account for the weekend. Further information on Swaps can be found on our Website.

13.6We charge our own interest rates, based on the overnight rate provided by Bloomberg. We update our rates as often as necessary.

13.7If your Account(s) remain inactive for 6 months, we reserve the right to charge you a one-off account maintenance fee of USD 15 (or currency equivalent), followed by a monthly fee of USD 5 for each month that the Account remains inactive. The status of your Account can be viewed via OWM(Oriental Wealth Markets Limited) Direct, and you can enable your Account at any time. We reserve the right to change the 6-month inactivity period as we deem necessary.

13.8For some payment methods there are transaction fees. Where you engage in deposit and withdrawal activity without entering into any trading activity with us, we reserve the right to impose any fees or charges with regards to specific payment methods. These fees are available on our website.

TAXATION

14.1Investing in financial instruments may be subject to tax depending on the jurisdiction where you are a resident. However, this will depend on your personal circumstances. You should seek for independent tax advice if you are unsure on how this may affect you, as we do not provide any financial advice, including tax advice.

14.2You understand that tax laws are subject to change, and in the event they do, we reserve the right to debit from your Account any tax payment, including, but not limited to stamp duty, capital gains tax or other forms of tax which may be levied in relation to your transactions with us.

14.3You understand that certain transactions in certain financial instruments may carry a tax obligation under the Financial Transaction Tax regime, stamp duty, transfer tax, dividend tax, withholding tax or other taxes or duties in any jurisdiction. Where there is such tax obligation we shall pass it on to you by debiting from your Account.

15CONFIDENTIALITY AND DATA PROTECTION

15.1We, as the controller of your personal data shall process your personal data during and after your relationship with us, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and other applicable data protection laws, as amended from time to time.

15.2By entering into the Agreement, you agree and acknowledge that we shall process your personal data including special categories of personal data as per our Privacy Notice available on our Website, as amended from time to time.

15.3We will process your personal data for the purposes of (i) providing our services to you, (ii) providing you with information about us and our services and improving our services from time to time, (iii) maintaining our IT systems, including our administrative and client management systems, (iv) complying with any requirement of law and/or regulation and/or of any competent authority or professional body (where applicable) of which we are a member.

15.4We process your personal data for the purposes mentioned herein on the lawful basis that (i) you have given consent (where applicable); (ii) the processing is necessary for the performance of our contract and in order to take steps at your request prior to entering into our contract; (iii) the processing is necessary for compliance with a legal obligation to which we are subject; and (iv) the processing is necessary for the purposes of the legitimate interests pursued by us (subject to the relevant individual’s fundamental rights and freedoms overriding such interests).

15.5You have the right to request from us access to and rectification or erasure of personal data or restriction of processing concerning you or to object to processing and to withdraw your consent (where applicable) at any time by notifying us in writing as well as the right to data portability.

15.6You acknowledge that we shall store your personal data (and records of your dealings with us) for as long as this Agreement is in force and for any additional period required for regulatory purposes or for the pursue of protecting our Affiliate Entities’ legitimate interests.

15.7Further details of how we process personal data including inter-alia our lawful basis of processing personal data, rights of the data subject and principles and information in respect of transfers of personal data are specified in our Privacy Policy available on our Website.

15.8 If, during the course of our business relationship, there is a change in your personal data you must ensure that this data is updated and accurate by contacting us as soon as practically as possible. You may do so via OWM(Oriental Wealth Markets Limited) Direct.

15.9 We shall implement appropriate technical and organisational measures to ensure an adequate level of security appropriate to the applicable risk. Transmission of data via the internet and/or other networks does not always ensure appropriate security of personal data hence you must always ensure that you transfer data to us via secure means.

16 OUR COMMUNICATIONS WITH YOU

16.1We will communicate with you about any notice, instruction, request or any other communication via your registered e-mail, the Software, telephone or, in the event of a formal communication to you in writing, via post to your registered address. All our contact details are available on our Website. Any communication from you to us shall be deemed effective on the date and time of reception by us. It is your responsibility to ensure you have read all and any communication we may send you from time to time, via any approved communication method.

16.2The Firm’s official language is the English language. Any translated version of the Agreement and/or any other communication, including our Website, may be provided solely for convenience purposes or due to legal requirements in the event of a dispute, the English version shall prevail.

16.3Any communication sent to you by OWM(Oriental Wealth Markets Limited) is intended to be received by you only. You are therefore responsible for keeping any information we send to you private and confidential.

16.4We may communicate with you from time to time, and in accordance with the applicable rules on Client Communications, about any business, marketing and/or promotional reasons.

16.5We bear no responsibility for any loss that arises as a result of delayed or unreceived communication sent to you by us.

17.RECORDING OF COMMUNICATIONS

17.1We record all incoming and outgoing telephone calls between you and us for quality monitoring, training and regulatory purposes. We will also record any other communication between you and us, including chat messages and e-mails. We reserve the right to use these records where we deem it necessary, including, but not limited to dispute resolution situations.

17.2We may provide copies of such recordings to regulatory authorities upon their request in order to comply with our regulatory obligations without your consent.

17.3You have the right to request a copy of the recorded communications. We will provide these to you following a written request by you.

18.REPRESENTATIONS AND WARRANTIES

18.1You hereby represent and warrant that you have not been coerced, or otherwise persuaded to enter into the Agreement, nor have you entered into the Agreement based on any representation other than what is included herein.

18.2Where you are an individual (i.e. natural person), you warrant that you are over 18 years of age at the moment of entering into the Agreement.

18.3Where you are a legally incorporated entity (i.e. a juridical person), you warrant that by entering into the Agreement you will not be in breach of your own constitutional documents or any law from the jurisdiction where you are incorporated.

18.4Further, you warrant that you are aware of any requirements and implications, including, but not limited to any restrictions or reporting requirements set by your local jurisdiction as a result of entering into the Agreement. OWM(Oriental Wealth Markets Limited) shall not be liable for any requirements imposed

to you by your local authorities, therefore you undertake to comply with any applicable requirements.

18.5You represent and warrant that you have been provided with a warning on trading Leveraged Products involving a significant risk of loss, and that due to the speculative nature of trading, you should not invest more than you can afford to lose.

18.6You also represent and warrant that the information you provided us during your registration for opening an Account accurately reflects your personal circumstances and you have not provided us with false or misleading information. Further, you warrant that should any information provided during the registration process becomes invalid, you will immediately notify us in writing of the change in your circumstances.

18.7You further represent and warrant that you will not redistribute information concerning financial instruments, including, but not limited to pricing information and chart data on offer by OWM(Oriental Wealth Markets Limited) to any third-party for commercial purposes.

18.8You warrant and covenant that:

a)The funds you will use to trade and bet with us belong to you and are free of any lien, charge, pledge or other encumbrance;

b)The funds are not the direct or indirect proceeds of any illegal act or omission, nor are they product of any criminal activity which constitutes a predicate offence under the Money Laundering Regulations 2017, or any other Anti-Money Laundering and Countering the Financing of Terrorism legislation.

c)Unless you are entering into the agreement as a representative or trustee of a third party and you provide us with the necessary documentation to satisfy our regulatory requirements, you are acting in your own name and you are not acting in representation or in trust of a third party.

18.9You warrant that any documents sent to us during your Account opening process, as well as throughout the duration of the Agreement, are valid and authentic. In the event that we believe, in our sole discretion, that any document is incorrect or invalid, we will request for alternative documentation. Failure from you to provide such documentation may lead us to taking action as we deem necessary.

19.EXCLUSION OF LIABILITY

19.1Except in the event of negligence or fraud from OWM(Oriental Wealth Markets Limited), we shall bear no responsibility for any loss as a result of any acts and/or omissions, whether carried out by you or by a third party on your behalf, in relation to your transactions with us.

19.2In general, neither party shall be liable for any losses which may arise as a result of unforeseeable events at the time when the Agreement was made effective, nor shall any party be liable for any losses that were not caused by any breach of the terms contained herein.

19.3Where we outsource any activity to third parties, in order to be able to provide you with our Services under the Agreement, we will exercise all reasonable endeavours prior to contracting with them. However, you understand that it is not within our possibilities to control the activities of such third parties. Our responsibility, therefore, shall be to exercise all efforts to minimise any losses that you may suffer as a result of an act and/or omission of the outsourced party(ies). Nonetheless, we shall not be liable for any loss that you may suffer as a result of such acts and/or omissions from third-party service providers, unless we have acted negligently.

19.4You acknowledge and accept that you are entering into all and any transactions with us at your own risk, and we assume no liability for any loss whatsoever as a result of your trading activity with us, unless in the event of any wrongdoing from our behalf. Nothing in this clause shall be taken to exclude any liability for death or personal injury.

19.5We shall not be liable for any direct, indirect, consequential, incidental and/or special losses (including, but not limited to loss of profits, trading losses, or damages) which result from a breach of contract by you.

19.6Further, and notwithstanding any other provision in the Agreement, we will not be liable to you as a result of:

a)Negligence, fraud, breach of the Agreement, breach of any law and/or any other act and/or omission by you;

b)Unavailability of the Software and/or our systems, other than in instances of wrongdoing by us;

c)You being unable to access our Software and/or OWM(Oriental Wealth Markets Limited) Direct or any other system, or any delay you may suffer when attempting to contact any of our customer support staff, unless this is due to wrongdoing by us.

d)Us taking measures to ensure compliance with any applicable law or regulation, including where we are precluded from processing any instruction from you which may result in us breaching the applicable law.

e)Any other event and/or circumstance which is outside our control.

19.7We shall not be liable for any failure to access the Software and/or OWM(Oriental Wealth Markets Limited) We are not responsible for any delays, delivery failures, or any loss or damage which results from the transmission of information over any network, including but not limited to the internet.

19.8The limitations and/or exclusions included in the Agreement shall apply irrespective of whether we, including any of our employees and/or affiliates are aware of any losses you may incur, or any claims you may make against the Firm.

19.9Where you have trusted a third party, and/or followed any instruction, indication or advice from a third party, including trading signals and/or copy trading strategies which resulted in any loss for you, we shall not be liable. You understand that the service we provide is on an execution-only basis and therefore we are not responsible for any losses you may incur as a result of these circumstances.

19.10Where you download, install and/or use any trading solutions such as algorithms, “Expert Advisors’ (‘EA’) or trailing stops, we shall not be held responsible for any losses which may beincurred by you pursuant to its use. If it comes to our attention that you are using any of these solutions, contrary to good faith or to the terms contained herein, we reserve the right to terminate the Agreement.

20.INDEMNITY

20.1You shall indemnify us on demand against all liabilities, costs, expenses, damages (including reputational) and losses (including, but not limited to any direct, indirect or consequential losses), and all interest, penalties and professional costs and expenses (calculated on a full indemnity basis) incurred by us as a result of:

a)your breach of the Agreement;

b)the provision by you of any false or misleading information to us; and/or

c)the enforcement of the Agreement.

20.2In general, indemnity means a sum of money paid as compensation for losses suffered.

21.EVENTS OUTSIDE OUR CONTROL (FORCE MAJEURE)

21.1This section refers to events which may occur from time to time, and which prevent us from performing any or all of our obligations (‘Specific Events’). Specific events may include:

a)any natural, technological, political, governmental, social, economic, act of god, pandemic, civil emergency, act of terror, interruption or failure of utility service;

b)non-performance by a third party, destruction caused by man or any similar event which is outside our reasonable control;

c)instances of illegitimate actions, errors, failures, disruptions in our systems, technological or other infrastructure (irrespective of whether it belongs to us or a third party) against our servers;

d)changes in the applicable legislation, any action of an official body or any other change in our legal or regulatory obligations as a result of unforeseen events;

e)an act or omission by any financial or other institution that we are unable to predict and/or prevent;

f)any event that prevents the Software or the systems from operating on an orderly or normal basis;

g)abnormal market conditions, such as significant volatility or instability in the markets, or the industry as a whole, preventing us from providing our services in an orderly manner, including any instances where we are unable to receive data and/or we receive incorrect data from our service providers;

h)any other event and/or circumstance which cannot be foreseen, within reason.

For the avoidance of doubt, a Specific Event is an event outside our control that, whilst it is reasonably likely to occur, or may be imminent, we cannot be expected to be prepared for, or we cannot prevent its occurrence.

21.2Where we determine that a Specific Event has occurred, without prejudice to any other rights of ours under the Agreement, or the law, we may take the following course of action(s):

Inform you, where we have sufficient time to do so in the circumstances;

Increase margin requirements / decrease leverage;

Increase spreads;

Change fixed spreads to floating spreads (only applicable to ‘Fixed Spreads’ Accounts);

Close any Open Position(s) at the price available in the circumstances, which may include:

a.Combine or close any open positions at ‘Volume-Weighted Average Price’ (‘VWAP’);

b.Request amendments to any closed position(s)

f)Suspend, limit or restrict the provision of our services to you;

g)Amend any part of the Agreement on the basis that it is no longer feasible for us to comply with it;

h)Cease trading;

i)Precluding you from accessing or using the Software, OWM(Oriental Wealth Markets Limited) Direct or any other system;

j)Make any necessary amendments to open trades;

k)Allow close-only functionality;

l)Reject or delay the processing of any withdrawal request from your Account(s)

m)Impose special or different terms regarding any of your orders in relation to size, volatility and/or liquidity of the instrument, amongst others;

n)Remove or temporarily suspend any products, or change any contract specifications;

o)Exercise any right to which we are entitled under the Agreement and our Order Execution Policy.

21.3We will exercise all necessary endeavours to resume the orderly provision of our services as soon as reasonably possible. Where this is not possible at all, we will inform you of the necessary actions to be taken in order to protect your interests and ours, where possible.

21.4Where we are unable to perform any of our obligations to you under the Agreement due to a Specific Event, we will not have breached the Agreement.

22.AMENDMENTS TO THE AGREEMENT

22.1We reserve the right to amend, from time to time and without your consent, any part of the Agreement, especially in, but not limited to, circumstances where we deem that such changes are necessary in order to comply with any obligation under the regulatory system. In these circumstances, we will notify you either in writing or via our Website.

22.2Where we deem that any amendments are material and/or would change the balance in our favour or to your detriment, such amendments will take effect on the date specified in our notice to you, in order to provide you with prior notice along with your right to cancel the Agreement.

22.3You have the right to cancel the Agreement where you do not agree with any amendments made by the Firm. In the same way, we reserve the right to terminate the Agreement where you do not agree with any amendments we may make.

22.4Any amendments will affect all ongoing business between you and us, unless stated otherwise in our notice.

22.5It is your responsibility to remain up-to-date with any changes we make to the Agreement. The applicable version at any time shall be the latest version available on our Website. In the event of a dispute, the latest version available at the time of the dispute shall prevail.

TERMINATION

23.1You may terminate the Agreement at any time and for whatever reason by providing us with written notice via e-mail using your registered e-mail address, provided that there are no open positions on your Account, nor are there any outstanding obligations to us.

23.2We may terminate the Agreement at any time and for whatever reason by providing you with a minimum of 7 days’ notice, except in the event of any of the provisions set out on clause

23.3occurring. Where we decide to terminate the Agreement, we will specify the termination date and we will proceed with closing any open positions on your Account.

23.3We shall terminate the Agreement with immediate effect in the event of:

a)a breach of any part of the Agreement by you;

b)where we have reasonable grounds to believe that you have not acted in good faith, including, but not limited to where we determine that you have, willingly or not, abused our ‘Negative Balance Protection’ policy. This includes, but it is not limited to you hedging your exposure using multiple trading Accounts, whether under your same profile or in connection with another Client.

c)an issuance of an application, order, resolution or other announcement in relation to bankruptcy or winding-up procedures involving you;

d)your death or incapacity (please note that in the event of death, any funds available in your Account(s) shall form part of your estate);

e)a breach of any applicable law by you, including, but not limited to the Money Laundering Regulations 2007;

f)you have acted contrary to our Order Execution Policy or any other of our policies or procedures.

23.4Termination of the Agreement shall not imply that any of your responsibilities cease to exist. Upon termination, you will still be liable to pay us, and/or we will have the right to immediately deduct from your Account:

a)any amount due to us;

b)any expenses incurred by us as a result of the termination of the Agreement;

any damage arisen after an arrangement or settlement.

23.5 Upon termination of the Agreement, we will transfer any amount available in your Account(s) to you, net of any outstanding amount that is due to us, except where we are prohibited to do so by law.

24 GOVERNING LAW AND JURISDICTION

24.1 The Agreement shall be governed by the laws of Vanuatu. Any proceedings and their settlement involving OWM(Oriental Wealth Markets Limited) and you shall take place in the competent courts of Vanuatu.

25 GENERAL PROVISIONS

25.1 Assignment: You shall not, under any circumstance, assign or transfer any of your rights and/or obligations under the Agreement to another person. We may, however, assign or transfer any of our rights and/or obligations under the Agreement to another person, provided that such person agrees to abide by the Agreement.

25.2 Entire agreement: The Agreement constitutes the entire agreement between you and our and supersedes all and any previous agreements, promises, assurances, warranties, representations and understandings between you and us, whether written or oral. You agree that you shall have no remedy in respect of any statement, representation, assurance or warranty that is not set out in the Agreement.

25.3 Severance: If, for any reason, part of the Agreement and/or any part of a specific clause is deemed to be unenforceable by a court of a competent jurisdiction then such part shall be severed from the rest of the Agreement or the term, and the remainder of the Agreement shall remain unaffected and enforceable.

25.4 Delay or inaction: No failure or delay by us to exercise any right or remedy provided under the Agreement or by law shall constitute a waiver of that right, or any other right or remedy, nor shall it prevent or restrict the further exercise of that right, or any other right or remedy. No single or partial exercise of such right or remedy shall prevent or restrict the further exercise of that right, or any other right or remedy.

25.5Meaning of certain words and phrases:

a)Unless indicated to the contrary words and expressions that begin with a capital letter in the Agreement will have a specific meaning.

b)Capitalised terms may be used in the singular or plural (as appropriate).

c)A reference to a statute or a statutory obligation is a reference to it as extended or reenacted from time to time.

d)Any reference to a document (including any information provided) shall include a reference to that document as amended from time to time.

e)Where there is a reference to ‘including’ or ‘includes’ this should be interpreted as including without any limitation.

f)Where there is a reference to the words ‘trading activity’, we are referring to the investment types CFDs and Spread Betting.

g)Any ‘sub-sections’, ‘clauses’, ‘titles’ have been inserted for convenience purposes only and shall not affect the construction of the Agreement.

h)The bolding of certain paragraphs, words or phrases in the Agreement is for ease of reference only. You should ensure that you read these Terms in full.

i)An obligation on one party not to do something shall include an obligation not to allow that thing to be done.

25.6 Survival: Clauses from the sections ‘Understandings of Both Parties’, ‘Confidentiality and Data Protection’, ‘Representations and Warranties’, “Exclusion of Liability7, Indemnity’, ‘Termination’, ‘Governing Law and Jurisdiction7, ‘General Provisions’ or any other clause that may be required to give effect to the meaning of the Agreement, shall survive termination of the Agreement.

Schedule A: Glossary

1.Account: means the trading account(s) and/or the Vault (as the context requires), which has a unique number, maintained by a Client for the purposes of trading financial instruments through the OWM(Oriental Wealth Markets Limited) trading and spread betting platform(s).

2.Authorised Representative or Attorney: means the person who is expressly authorised by the Client to act on his/ her behalf; the above mentioned relationship is documented through a Power of Attorney, a copy of which is held by the Firm.

currency in which Account(s) are denominated. All charges including spread(s), commission(s), and swap(s), will be calculated in that currency.

3.Balance: means the funds available in an Account that can be used for trading financial instruments.

4.Client Money: means money that is paid into OWM(Oriental Wealth Markets Limited) and is held for the Client. It is calculated as money deposited by the Client in his/her Account, plus or minus any unrealised or realised profit or loss of an open position, plus or minus any amount that is due by the Client to the Firm and vice versa.

5.Contracts for Difference: CFDs, which are traded off-exchange (or Over-the-Counter (‘OTC’)), are agreements to exchange the difference in value of a particular instrument or currency between the time at which the agreement is entered into and the time at which it is closed. This allows the Clients to replicate the economic effect of trading in particular currencies or other instruments without requiring actual ownership of those assets. The definition of Contracts for Difference includes Spread Betting, as a form of CFDs. A full list of the CFDs on offer by us is available on our Website.

6.Equity: means the balance plus or minus any profit or loss that derives from any Open Positions.

7.Instructions: means any request made by you in relation to your account, other than an order to buy or sell any of the financial instruments available on our platform(s).

8.Required Margin: means the required funds available in an Account for the purposes of opening a position.

9.Margin level: means the required funds to maintain a position and is calculated as Equity / Margin.

10.Matched-Principal: means the execution method where we are acting as principal in relation to all Client trades whilst simultaneously matching these trades with a counterparty. This is also known as ‘riskless principal’ since the Firm would not be taking the position in their proprietary book.

11.Segregated Account: means an account held with a banking institution for the purposes of holding Client money. The account is held in trust with Clients as ultimate beneficiaries, in accordance with the applicable rules.

12.Spread Bet: means the financial betting product where a Client can speculate by placing a bet on the direction in which the price of a particular instrument will move. The outcome of such bet will then be dependent on how much the price of the relevant financial instrument moved in favour or against the client, so therefore it is not a fixed-odd bet. As a form of CFDs, Spread Bets allow Clients to replicate the economic effect of trading in particular instruments without owning the underlying assets.

Enforcement Order Policy

1.INTRODUCTION

OWM (Oriental Wealth Markets Limited) is a broker registered in Vanuatu, VFSC supervision number 40299.

The Company has established and implements the Order Execution Policy (hereinafter the ‘Policy’) which aims to offer the best possible result to its clients when executing client orders. (hereinafter the “Best Execution”).

Oriental Wealth Markets Limitedduty is to act honestly, fairly, professionally and in the best interest of the client. The Company is required to take all sufficient steps to obtain the best possible result when executing or transmitting client orders.

2.SCOPE OF POLICY

This Policy provides an overview of how orders are executed, the factors affect the execution of orders and specifically upon market volatility and sudden market movements. In addition, the sole execution venue offered by the Company is presented, as well as an overview of the available financial instruments and order types.

When the Company executes a client order will always act as a principal and not as agent, this means that clients deal with the Company and not with the underlying market. The Company ensures to deliver the best possible execution rate but cannot guarantee that the execution rate given to the client will be more favorable than a rate that may have been available elsewhere.

The main purpose of this policy is to help clients understand how the Company executes client orders and help them to make an informed choice on whether to use Company’s services. You should ensure that you have read and understand the contents of this Policy.

By entering into an agreement with the Company you are agreeing to the terms of this Policy.

For the purposes of this Policy; an Order is the instruction to buy or sell a financial instrument, a Trade is the execution of the Order and a Position is the total of all Trades for a specific financial instrument.

3.BEST EXECUTION OBLIGATION

Best Execution is the process by which the Company seeks to obtain the best possible result when executing client orders. The company has obligation to ensure that all sufficient steps are taken into account when executing client orders, including price, costs, speed, likelihood of execution and settlement, size and nature upon client characteristics.

4.EXECUTION VENUES

The Company acts as principal and not as agent on the client’s behalf for all trades in the instruments provided by the Company and, therefore, is the sole venue for execution of the clients’ orders. All orders and trades entered through company’s trading platforms are NOT executed on a Trading Venue (Regulated Market, Multilateral Trading Facility or on an Organised Trading Facility) but they are executed by the Company. Therefore, the Client may be exposed to greater risks than trading on a Trading Venue. Furthermore, the Client is only able to close its open positions with the Company.

The Company’s internal procedures and high-performance standards ensure its clients receive the best possible result when dealing with their orders and does not transfer its execution

responsibilities to any other counterparty. The company ensures that all sufficient steps have been taken for the continuity of high performance, while continuously monitors the capacity and efficiency of trading platforms and update the software and servers where are deem necessary. In case of technical failure of the trading platforms and/or quote feeds, the company may not be able to execute an order or may need to cancel/adjust the price of any trade which is executed wrongly.

Your agreement to this Policy shall constitute your prior consent for us to execute orders outside a Trading Venue.

5.TRADING HOURS

Trading hours of each financial instrument appear in the Company’s website. Trading hours may change due to several factors such as Holidays, unusual market conditions which affect

liquidity, or circumstances out of Company’s control. The Company aims to update the trading hours as necessary to reflect these changes.

6.SPECIFIC INSTRUCTIONS

In case the Clients give specific instructions regarding Order execution or transmission, the Company shall execute their orders in accordance to the given instructions. Clients should be aware that the provision of specific instructions may prevent the Company from implementing its Order Execution Policy in obtaining the best possible result for the execution or transmission of an Order.

TRADING INSTRUMENTS, PLATFORMS AND SERVICES：

7.TRADING INSTRUMENTS

This Policy is applicable to the financial instruments and their trading conditions as publicly ，available on the Company’s website and can be traded through the Trading Services below. The offered financial instruments are Contracts for Difference (CFDs) and it is up to the discretion of the Company to discontinue trading and/or pricing at any time. There is no physical exchange of the assets, there is no central clearing of the transactions and they are traded ‘over-the-counter’ (‘OTC’).

8.ORDER EXECUTION POLICY

Best Execution applies when the Company executes a client order in financial instruments and products including:

• Spot and Forward on Currencies,

• Spot on Metals,

• Futures on Metals, Commodities and Indices,

• CFDs on Cryptocurrencies.

• CFDs on Shares

• Vanilla Options on Currencies, Metals, Commodities, Indices and Cryptocurrencies.

CFDs are speculative products which are traded with leverage and are not appropriate for all Investors. By investing in CFDs, you assume a high level of risk which can result in the loss of all of your invested capital. Thus, you should never invest more that you are willing to lose.

Further, Clients should consider whether CFDs are appropriate for them according to their financial status before initiating a trade. Trading CFDs require constant monitoring and may not be appropriate for persons who cannot devote time in this respect. If you do not have enough knowledge and experience to trade, we suggest you seek independent advice before you invest. If you still don’t understand these risks after consulting an independent financial advisor, then you should refrain from trading at all.

9.TRADING SERVICES

The Company provides the trading services listed below;

• Direct Phone Dealing

• Dealing via the Company Live Chat Service

• Direct Online Trading via the Trading Platforms listed below;

10.PROPRIETARY PLATFORMS

• Web Trading Platform for desktop devices

• Web Trading Platform for mobile devices

• Options Platform;

• iOS Application (Compatible with iPhone™, iPad™)

• Android Application

11.NON-PROPRIETARY PLATFORMS

• MetaTrader 4 (MT4) – proprietary rights of Metaquotes Software Inc.

• MetaTrader 4 (MT4 mobile version) – proprietary rights of Metaquotes Software Inc.

The Client acknowledges that all Orders and Trades in financial instruments entered with the Company, are not undertaken on a recognized exchange, therefore clients can only open, modify or close during the Company’s trading hours as displayed on the Company’s website.

In cases of technical failure on any of the trading platforms, the Company reserves the right not to execute an order or to cancel a trade.

12.ORDER TYPES AND EXECTUION ELEMENTS

The Order Types and Execution Elements that constitute the Order Execution on the Company’s proprietary platforms and the third-party platforms provided by Metaquotes Software Inc. (hereinafter ‘MT4’) are described below. Where the text does not explicitly specify a platform then the text applies to all platforms.

13. MARKET ORDERS – DAY TRADING

These are orders to buy or sell a financial instrument at the current market rate.Proprietary platforms will provide the requested market rate for execution or reject the market order when a rapidly moving market causes the market rate requested for execution to be significantly different from the prevailing market rate. MT4 platforms will not reject market orders based on the difference between requested and executed rate. The executed rate can be different from the requested rate, if the requested market rate is no longer available due to a rapidly moving market. The difference between the executed rate and the requested rate can be either in favor or against the client. The Company does not manually intervene in any way.

Opening a market order on Proprietary platforms requires the Margin at Risk (also known as “Amount to Risk”) to be available for collection upfront. Once the trade is closed, the Margin at Risk is returned. MT4 platforms will not allow a market order to be opened if the Margin Level as calculated and shown within the terminal is or by executing the order will go below 100%.

A Client trading on Proprietary platforms has the ability to use the trading tool ‘dealCancellation’ and cancel a losing day trade within one hour, for a fee. The fee calculation is based on the realised volatility of the selected product and it is paid once the Client initiates a day trade order. The trade that used the trading tool ‘dealCancellation’ can be cancelled with zero P&L at any time before the expiration time and the Margin at Risk provided upfront for the trade will be returned to the account balance. The fee paid is non-refundable and the ‘dealCancellation’ cannot be renewed once it is expired or exercised.

14.LIMIT ORDERS

These are orders to buy or sell a financial instrument at a pre-defined rate. A buy Limit Order requires the pre-defined rate to be lower than the current market rate, while a sell Limit Order requires the pre-defined rate to be higher than the current market rate. On Proprietary platforms, once the market rate reaches the pre-defined rate, the limit order is triggered, and a market order is executed at the pre-defined rate. On MT4 platforms, once the market rate reaches the pre-defined rate, the limit order is triggered, and a market order is executed at the next available rate.

Setting a Limit Order on Proprietary platforms requires the Margin at Risk to be available for collection upfront. If the Limit Order is cancelled, the Margin at Risk is returned. MT4 platforms will not allow the execution of Limit Order into a Market Order if the Margin Level as calculated and shown within the terminal is or by executing the order will go below 100%. In such a scenario the system will delete the Limit Order. In all other cases, in all platforms,once set a Limit Order will remain active until the client cancels it. This is known as Good ‘Til Cancelled (GTC).

15.STOP ORDERS

These are orders to buy or sell a financial instrument at a pre-defined rate. A buy Stop Order requires the pre-defined rate to be higher than the current market rate, while a sell Stop Order requires the pre-defined rate to be lower than the current market rate. On Proprietary platforms, once the market rate reaches the pre-defined rate, the limit order is triggered, and a market order is executed at the pre-defined rate.

Setting a Stop Order on Proprietary platforms requires the Margin at Risk to be available for collection upfront. If the Stop Order is cancelled, the Margin at Risk is returned. MT4 platforms will not allow the execution of a Stop Order into a Market Order if the Margin Level as calculated and shown within the terminal is below 100%. In such a scenario the system will delete the Stop Order. In all other cases, in all platforms, once set a Stop Order will remain active until the client cancels it. This is known as Good ‘Til Cancelled (GTC).

16.FORWARD ORDERS

These are orders to buy or sell at a Forward Rate in a future pre-defined date. The Forward Rate is derived from the current market rate and the Forward Points. The Forward Points are derived from the predefined future date, and the interest rate differential among the buying currency and the selling currency. The Forward Points can be either positive or negative.

The executed Forward Rate can be different from the requested Forward Rate, if the requested Forward Rate is no longer available due to a rapidly moving market. The difference between the executed Forward Rate and the requested Forward Rate can be either in favor or against the client. Forwards are only available on Proprietary platforms and they will be automatically rejected where the executed Forward Rate will be significantly different than the requested Forward Rate. The Company does not manually intervene in any way. Opening a Forward order requires the Margin at Risk to be available for collection upfront. Once the deal is closed, the Margin at Risk is returned.

17.VANILLA OPTIONS (EASY TRADE)

A bought Vanilla Option gives the buyer the right, but not the obligation, to buy (known as a ‘Call Option’) or sell (known as a ‘Put Option’) an underlying financial instrument at a predefined rate (known as the ‘Strike’) at a pre-defined date (known as the ‘Expiry’). When buying a Vanilla Option, the buyer pays the Premium for the abovementioned right on opening and this is collected from the account balance.

A sold Vanilla Option gives the seller the obligation and the buyer the right to buy (known as a ‘Call Option’) or sell (known as a ‘Put Option’) an underlying financial instrument at a predefined rate (known as the ‘Strike’) at a pre-defined date (known as the ‘Expiry’). When selling a Vanilla Option, the seller receives the Premium for the abovementioned obligation on opening and this is credited in the account balance. At the same time an Amount to Risk is collected, which acts as a Stop Loss and limits the maximum loss.

Order Execution Policy

An easyTrade deal is a bought Vanilla Option; where the buyer can buy (Up) a Call Option or sell (Down) a Put Option of an underlying financial instrument at a pre-defined rate and expiry time. When buying an easyTrade deal, the buyer pays the Premium (Risk) and this is collected from the account balance. At the closing of the deal, the Current Payout amount is returned in the account balance.

18.STOP LOSS & TAKE PROFIT ORDERS

A Stop Loss Order is a request to close an open trade when the market is moving against the trade at a pre-defined rate, while a Take Profit is a request to close an open trade when the market is moving in favor of the trade at a pre-defined rate.The execution of all Stop Loss Orders and all Take Profit Orders is guaranteed in all platforms.

In the Proprietary platform, the requested rate for Stop Loss and Take Profit is the same as the executed rate (no slippage). In the Non-Proprietary platform, Stop Loss and Take Profit Orders are executed at the prevailing market rate (subject to slippage).

When a deal is closed due to a Stop Out, it will be closed at the prevailing market rate.

Modification of the Stop Loss and Take Profit attached to market orders or forward orders are subject to the trading hours of each financial instrument. On proprietary platforms, Stop Loss on limit and stop orders cannot be modified, while Take Profit cannot be placed on stop orders.

19.STOP OUT

MT4 accounts will trigger a Stop Out if their Margin Level (as calculated and shown in the MT4 Client Terminal) goes at and below 30%. The platform is designed to automatically start closing open trades, with the most unprofitable closed first. The platform will stop closing trades either when the Margin Level is brought back above 30% or when there are no open trades left. The Stop Out is a higher priority action than Stop Loss and Take Profit and will close each trade at the prevailing market rate instead of the predefined rates. In case the client balance goes negative after all positions close, the Company will cover the negative balance and will not request from Clients to cover the required amount.

20.STOP LOSS, TAKE PROFIT, LIMIT AND STOP ORDERS DISTANCE

In anticipation of amplified volatility, such as ahead of major announcements, or thin liquidity, such as the re-commencement of trading following a break (for instance, following the weekend or a holiday) the Company reserves the right to widen the distances it will allow Clients to set their Stop Loss, Take Profit, Limit and Stop Orders rate, without any prior noticeto Clients.

21.EXECUTION FACTORS

The definition of best possible result will vary as the Company must take into account the below execution factors and determine their importance;

• Price, is the Company’s quoted market rates at which the order is executed.

• Costs, are any additional charges that may be incurred in executing the order over and above Company’s normal charges.

• Speed of Execution, can be particularly important in fast moving markets.

• Likelihood of Execution and Settlement, the best price obtain does not have relevance if the Company cannot execute the order or if the transaction fail to be completed.

• Size, nature and any other considerations of the transaction, is the way the Company may execute an order with unusual characteristics (for instance, an order which is larger than the normal market size or has unusual features such as an extended or shortened expiry date).

Best Execution is determined based on the total amount paid to or by the client, including the price of the order and all expenses incurred which are related to the execution of the order; such as venue execution fees and any other fees paid to third parties for the execution of the order.

22.EXECUTION CRITERIA

In the absence of specific instructions from you, we will balance the above-mentioned factors based on our professional experience and judgment in light of the available market information and market conditions at the appropriate time, and taking into account the following criteria:

• characteristics of the client including the categorization of the client as retail or professional,

• characteristics of the client’s Order,

• characteristics of the financial instrument that is the subject of that Order,

• characteristics of execution venues where that order can be covered.

23.COMPANY’s QUOTED RATES (HIGH IMPORTANCE)

The Company provides live streaming quotes for the financial instruments provided on its platforms. These rates are being reviewed continuously in real time in order to ensure live feeding quotes are competitive and in line with the market (known as “on market”). They are calculated with reference to the rate of the relevant underlying financial instrument, which the Company obtains from third party independent reference sources.

The Company normally provides liquidity from its inter-group liquidity flow as the Company believes that this provides the best outcome for its clients. The Company has internal capabilities to assess the price quality offered by other venues and ensures that prices proposed to the client are aligned with market benchmarks. Further, the company has procedures in place to review regularly its independent data providers and check the fairness of the price proposed to the client.

The Company does not charge commission fees since they are incorporated into the offered spread quoted in Bid (at which client can sell) – Ask (at which client can buy) rates. The company applies a consistent pricing methodology at all times; in which the offered spread is a mark-up and mark-down from the mid-rates provided by the third party independent data provider.

24.TARDE COSTS (HIGH IMPORTANCE)

Overnight financing fees may apply for some types of financial instruments, and trades in these will be subject to ‘rolling fees’ if kept open overnight. Details on the daily financing fees are available for each financial instrument within each trading platform.

• For the Non-Proprietary Platforms (MT4 Platforms), rolling/renewal fees are charged only on weekdays at 00:00GMT, with triple fee on Wednesday (triple fee is on Friday only for Cryptocurrencies) and they are deducted from the Balance when the position is closing.

• For the Proprietary Platforms, rolling/renewal fees are imposed only to Day Trading Deals which are automatically renewed every night at 22:00 GMT. In case the account balance has insufficient balance, the renewal fee will be deducted automatically from client’s credit card. In circumstances a collection of the fee is not viable, the company will inform the client for the uncollected rolling fees via email. If we are unable to collect the rolling fees, we will close some, or all of your opened positions after 24 hours. Closing of deals due to uncollected rolling fees will not take place during the weekend. Your Day Trading positions will remain opened until Monday at 22:00 GMT, when the rolling fees will be collected.

25.SPEED, LIKELIHOOD AND SETTLEMENT OF EXECUTION (MEDIUM IPORTANCE)

In its capacity as principal and not as agent on the client’s behalf, and as the sole execution venue, the Company seeks to execute clients’ orders with the fastest execution reasonably possible and within the limitations of technology and communication links. The Company’s order flow logic is designed in such way to accept automatically all orders and without manual intervention. In case of technical malfunctions, the Company has the right to cancel an order or trade of any type. It is worth noting that the company does not requote any type of order.

The Company strives to provide the best possible rate to its clients, however under certain circumstances, such as occasions of thin liquidity, of a fast-moving market or before or at the open/close of the trading session, it may not be possible to guarantee the execution of any or all orders. The Company reserves the right to decline an order of any type but will not delay the execution of an order in the hope that market conditions will improve. Further, Clients should be aware the risks associated while trading under the abovementioned occasions. A non-exhaustive list of such occasions is as follows;

• The opening price might be substantially different from the close of the previous trading session.

• Delays on execution of orders may occur due to high volume of orders waiting for execution. The Company does not manually intervene to delay execution in the hope that market conditions will change.

• The executed rate on MT4 Platforms can be different from the requested rate, if the requested market rate is no longer available due to a rapidly moving market. The difference between the executed rate and the requested rate can be either in favor oragainst the client. On Proprietary platforms the market order might be rejected when a rapidly moving market causes the requested market rate for execution to be significantly different from the prevailing market rate.

The Company proceeds with the settlement of all orders upon their execution.

26.NATURE AND SIZE OF ORDERS (LOW IMPORTANCE)

The Company strives to fill all orders of all sizes, however due to market volatility at the time of execution, the rate given may be different from the requested rate (see Order Types and Execution Elements for exact details). The Company may limit the maximum volume of a single trade as well as the maximum total position a client may hold on a financial product or a set of products.

27.NEGATIVE PRICING

The Company’s proprietary and non-proprietary platforms do not support sub-zero prices.

Therefore, the Company does not allow the trading of sub-zero (negative) prices. Where the prices of any financial instrument collapse in sub-zero (negative) prices, the Company is obliged to disable the trading for the specific instrument and as a result closure of the existing positions at zero price for the instrument affected will occur.

28.REGULAR MONITORING AND RIVIEW OF OUR ORDER EXECUTION POLICY

The Company monitors the implementation and effectiveness of its Order Execution Policy with regards to the procedures followed and all factors that may affect its Order Execution.

The Company reserves the right to correct any limitations and proceed to improvements.

The Company will review and evaluate its Policy at least annually and when a relevant material change occurs. In case of changes to the Policy, the Company will notify all Clients.

29.CLIENT CONSENT

The Company is obligated to obtain the client’s consent to its Order Execution Policy when commencing a business relationship.

By agreeing to the Terms, Conditions and Clauses described in the ‘Client Agreement’, the client provides the consents referred to in the paragraph above, where the client is informed that all orders placed with the Company, the Company acts as the principal and not as agent, and it is the sole execution venue, which is a non-regulated market.

Risk Warning: Forward Rate Agreements, Options and CFDs (OTC Trading) are leveraged products that carry a substantial risk of loss up to your invested capital and may not be suitable for everyone. Please ensure that you fully understand the risks involved and do not invest money you cannot afford to lose. Please refer to our full risk disclaimer.

OWM (Oriental Wealth Markets Limited)

Terms and Conditions

Ownership of Website and Legal background

OWM (Oriental Wealth Markets Limited) is a broker registered in Vanuatu, VFSC supervision number 40299.operates the website www.owmtrader.com

All Intellectual Property within and arising from the website is owned by OWM(Oriental Wealth Markets Limited)Brokers, and OWM(Oriental Wealth Markets Limited)Brokers reserves all rights therein. These terms are supplementary to any agreements and other legal documents.

Access & Use of the Website & Disclaimer

By accessing and or using the website and the services and products so offered, the User of the Website, agrees to be bound by the terms and conditions herein and arising from the use of the website, at any given time, in any given location and in accordance with the entity in which the User will proceed to open accounts with. OWM(Oriental Wealth Markets Limited)Brokers reserves the right to use its discretion to suspend, modify, amend and or cancel any access to the website, or any part thereof, including the products and services so offered through the website. OWM(Oriental Wealth Markets Limited)Brokers may change the terms and conditions, information and materials within the website, at any time and may without prior notice to the user and therefore it is for the user to stay up to date with all information and or changes to the website.

The user assumes the responsibility and obligation to ensure compliance with the laws, by laws, regulations, directives if any, applicable in the user’s country of residence. The user of the website will be held responsible for any unauthorized use of the website or any illegal acts related to the website.

The user understands and agrees, that the website is not a solicitation to buy nor is it an offer to sell any products and services, to any (legal) persons, in any jurisdictions, where such products and services would be considered as unlawful/prohibited, under the laws of such specific jurisdictions. Therefore it is the user’s responsibility to comply with such laws in the respective jurisdictions, and in such cases the user will hold OWM(Oriental Wealth Markets Limited)Brokers harmless from any and all consequences, damages, and or liabilities that may occur as a result and or arising from such prohibitions.

Trading in financial instruments can result in both losses as well as profits and the investments can be lost. Before investing, the user must consider available resources, level of experience and risks involved, and is free to obtain the advice from financial/tax/legal advisors), as the case may be.

OWM(Oriental Wealth Markets Limited)Brokers does not guarantee that access to the website and or any of the products and services will be available at all times, or in any jurisdiction at any specific time. OWM(Oriental Wealth Markets Limited)Brokers will not be held liable for any consequential, incidental, special, punitive, or exemplary damages of whatsoever nature, arising out of any use and/or inability to use the Website and/or any of the products and/or services, nor will OWM(Oriental Wealth Markets Limited)Brokers be held liable to the User for any lost profits, trading losses, damages that may result from use and/or loss of use of the Website and/or third party content, any inconvenience and/or delay, including any loss resulting from a cause over which Company has no control over, including failure of communication lines. By using the Website, the User agrees to indemnify and hold OWM(Oriental Wealth Markets Limited)Brokers , entities of the Group of Companies, and/or third party providers (if any), harmless from and against any and all claims, losses, liabilities, costs and expenses (including but not limited to attorneys’ fees) arising from the use of the Website, and/or any violation of the terms and conditions.

Insider trading and/or any other form of market abuse is strictly prohibited and any such acts will justify the immediate suspension of the activities. OWM(Oriental Wealth Markets Limited)Brokers reserves the right to report such activities to relevant authorities and disclose relevant information regarding such acts and/or regarding any suspicious and/or abusive use of the Website, services, products and/or any platforms provided through the Website.

Data and Confidentiality

Data provided via the Website is intended only for informational and private use purposes. The User may obtain the advice of independent investment, financial, legal and tax advisors, if desired, before proceeding with an investment. All information provided via the Website should not be read, interpreted or construed as providing any investment advice and/or solicitation by OWM(Oriental Wealth Markets Limited)Brokers nor any of the entities within the Group of Companies, its Employees, Officers, Directors, Affiliates, Agents, Service Providers and/or Licensors. This Website does not take into consideration any investment goals, financial situation and/or specific requirements of any User. Any person and/or entity should carefully consider their financial circumstances prior to entering into any transactions, investments and/or Agreements.

The User understands and consents to the storage and processing of data in accordance with the applicable laws, and that OWM(Oriental Wealth Markets Limited)Brokers treats this data with the strictest confidentiality unless required to be disclosed by the supervisory bodies, competent authorities, court order, legal request/legal obligation subjecting OWM(Oriental Wealth Markets Limited)Brokers or the entities within the Group of Companies, to make such disclosure.

The User is responsible and assumes all risks associated with the use of and storage of information on User’s electronic devices where through access and use of the Website is made.

It is the User’s responsibility to keep any account numbers and/or passwords and/or logins confidential at all times. User authorizes OWM(Oriental Wealth Markets Limited)Brokers and entities within the Group of Companies to act in good faith on any instructions received from the authorized email address.

OWM(Oriental Wealth Markets Limited)Brokers may use “Cookies”, which are minute files containing information that websites use to track visitors of the Website. OWM(Oriental Wealth Markets Limited)Brokers measures the activity of the Website through the use of “Cookies”. OWM(Oriental Wealth Markets Limited)Brokers may access Cookies on the User’s Computer in order to obtain information related to which website, banners and/or advertisements guided the User to OWM(Oriental Wealth Markets Limited)Brokers ’s Website. Details transmitted through Cookies shall not be used for any direct promotional and/or marketing purposes without the User’s Prior Consent.

Payment and Safety of Funds

The User is bound by any of the agreements signed, and in turn agrees and accepts to the online payment methods offered by OWM(Oriental Wealth Markets Limited)Brokers. Deposits and Withdrawals of Funds are executed as per the agreements entered into by the User and OWM(Oriental Wealth Markets Limited)Brokers. Withdrawals of funds are affected only upon the reception and approval of such requests by the entity and in accordance with the time frame, if any, of the payment providers.

OWM(Oriental Wealth Markets Limited)Brokers, deals with several reputable banks and client funds are held in segregated accounts, ensuring the continued safety of funds.

Linked Sites and Limitation of Liability

Access to the Website is provided on a “non-exclusive”, “non-transferable” basis and is in compliance with the terms and conditions, in addition to any other agreements signed by the User. The Website may contain hyperlinks to third-party websites, and as such, OWM(Oriental Wealth Markets Limited)Brokers and related entities, shall not be held accountable for the content and/or accuracy of information of any of those websites, and as such OWM(Oriental Wealth Markets Limited)Brokers does not endorse the contents within such websites. The Website is provided to the User on an “AS IS” and/or “AS AVAILABLE” basis. OWM(Oriental Wealth Markets Limited)Brokers does not provide any warranties and/or guarantees of any kind.

OWM(Oriental Wealth Markets Limited)Brokers, including its Employees, Officers, Directors, Affiliates, Agents, Service Providers and Licensors, does not warrant the accuracy, adequacy, completeness of the information, products and/or services within the Website, and expressly disclaims liability for any errors, interruptions, losses, damages, or inaccuracies in the information, products and/or services provided through the Website

Applicable Law and Jurisdiction

The access and use of the Website, is governed by the laws of Vanuatu and the User submits to the non-exclusive jurisdiction of the Vanuatu Court or any of the applicable Court and/or Laws of any of the group entities registered in any other jurisdiction as the case may be or where the cause of action arose/may arise.

In the event that any term or condition is deemed invalid or unenforceable, such term or condition will be declared invalid and excluded, however, the remaining provisions will remain with the full force and effect. The User may contact the OWM(Oriental Wealth Markets Limited)Brokers in order to lodge a formal complaint as per the details displayed on the Website, such complaint should be lodged within a reasonable time, and OWM(Oriental Wealth Markets Limited)Brokers undertakes to investigate such complaint and revert to the User with a decision.

Any translations of the contents of the Website including products and/or services provided through the Website is made as a goodwill for the convenience of the Users. In the event of a dispute between the various language versions, the “English Version” of the Website shall always prevail.

Risk Disclaimer

OWM (Oriental Wealth Markets Limited) is a broker registered in Vanuatu, VFSC supervision number 40299. The following risk statement customers need to know。

Trading in financial instruments is not suitable for many members of the public. The possibility exists that funds used for such trading in financial instruments sustain a loss of some or all of your investment. It is advisable to carefully consider whether trading in financial instrument(s) is appropriate for you in light of the experience, objectives, financial resources and any other relevant circumstances. You should understand all risks involved with trading in financial instruments and if necessary, seek for an independent advice.

Entering into any transactions in financial instruments is carried out voluntarily and at your own risk. There are high risks involved in trading and profit(s) from trading are not guaranteed whereas the past result(s)/historical performance do not assure/represent the future results.

The risk is high that you can sustain losses/damages to all or some of the capital/monies invested. An investment in any financial instrument carries a high degree of risk and the money that is invested might not remain the same, whereas you undertake the risk of sustaining a loss/damage, whilst, at the same time, the possibility exists that a profit/return can materialize.

Trading on the electronic trading system(s) carries a high risk since there is a large exposure to risks associated to the online system, including but not limited to the failure of hardware and/or software. The result of any system failure may be that your request is not executed according to instructions or not executed at all. All transactions effected are at your sole risk and you shall be solely liable under all circumstances. OWM(Oriental Wealth Markets Limited) Brokers , will not be held responsible for any delays in transmission, delivery or execution of your request(s) due to malfunctions of communications facilities or other causes.

The market conditions and the operation of the rules of certain markets, trading hours, dealing room hours and so forth, may increase the risk of loss because of the difficulty to effect transactions or liquidate/offset open positions. The Company may be unable to execute your instructions at the requested level.

Trading with Financial instruments on margin carries a high level of risk which can work both, to your advantage and disadvantage.

In certain cases, the protection of your money transferred for purposes of trading in Financial instruments, may have an impact in the event of the specific firm/company going insolvent/bankrupt. Specific legislation or local rules may govern the extent to which you may recover money. In some jurisdictions, property/money which has been specifically identifiable as your own property/money, will be appropriated in the same manner as cash for purposes of distribution in the event of a shortfall.

You understand that commissions, fees and other charges may be applicable, and as such these charges will affect/reduce the profit (if any), or increase the loss. Before trading in financial instruments, you should make yourself aware of all charges for which you will be liable, whether such charges are at predetermined amount or variable.

You understand that the profit or loss for transactions in foreign currency-denominated contracts will be affected by the fluctuations in currency rates when there is a need to convert from the currency denomination of the contract into another currency.

You understand that OWM(Oriental Wealth Markets Limited) Brokers does not guarantee access to the Website and/or any of the products and/or services to be available at all times, or in any given location at any specific time.

All transactions effected for your account(s) are at your sole risk and you shall be solely liable under all circumstances. OWM(Oriental Wealth Markets Limited) Brokers will not be held responsible for any delays in transmission, delivery or execution of your request(s) due to malfunctions of communications facilities or other causes.

The Company may, in its reasonable opinion, determine that an emergency or an exceptional market condition exists (a “Force Majeure Event”). A Force Majeure Event shall include but is not limited to the following – “any act, event or occurrence (including without limitation any strike, riot or commotion, interruption or power supply or electronic or communication equipment failure).In the event of such a situation, all disposal rights belong to OWM (Oriental Wealth Markets Limited).

You understand that there is the risk that the Financial instruments may be or become the subject to tax and/or any other applicable due amount(s) as per legislation, which will become your responsibility to carry out.

Disclaimer of Risk Disclosure

SCOPE OF THE NOTICE

1.1Oriental Wealth Markets Limited (referred to as ‘Oriental Wealth Markets Limited’, the ‘Firm’, ‘us’, ‘we’ and ‘our’) provides you with this ‘Risk Disclosure Notice’ (the ‘Notice’) to help you understand the risks that might arise when trading Contracts for Difference (‘CFDs’) and/or Spread Bets. However, you need to bear in mind that the Notice does not contain all the risks and aspects involved in trading said instruments. The Client (referred to as the ‘Client’, ‘you’, ‘your’ and ‘yourself’) should carefully read the Notice in conjunction with the ‘Client Agreement’, and the documentation/ information available to you through our Website.

1.2 You need to ensure that any decision to engage in trading CFDs and/or Spread Bets is made on an informed basis and in light of your knowledge and experience as well as to your personal circumstances (including but not limited to your financial position). In addition, you need to ensure that you understand the nature of CFDs and Spread Bets, and the extent of all risks and aspects involved in trading these instruments.

1.3Please note that CFDs and Spread Bets are leveraged financial products and therefore as such, trading these instruments involves a high risk of loss as price movements are influenced by the amount of leverage the client is using. For example, if a client is using 30 times leverage a movement of 0.5% will result in a gain or a loss of 15%. Nonetheless, as a result of the ‘Negative Balance Protection’ (‘NBP’) you may not lose more than your initial investment.

1.4Trading CFDs and/or Spread Bets is not appropriate for all investors. Under no circumstances, you should risk more than you are prepared to lose.

1.5For any capitalised term, which has not been defined in the Notice, please refer to Schedule A (‘Glossary’) of the ‘Client Agreement’.

APPROPRIATENESS ASSESSMENT

2.1 When processing your ‘Account Opening Form’ Oriental Wealth Markets Limited carries out an assessment of your

appropriateness to trade CFDs and/or Spread Bets and determines, based on information you provide us with, if you have sufficient knowledge and experience to understand the risks involved in trading leveraged products. We will inform you of the results of our assessment, but this does not relieve you of the need to carefully consider whether to trade with us. If we warn you that trading CFDs and/or Spread Bets may not be appropriate for you, then you should refrain from trading CFDs and/or Spread Bets until you attain sufficient knowledge and experience, for example you may trade on a demo account prior to trading in a live environment and you acquainted yourself sufficiently with the relevant risks.

3. NATURE OF CFDs AND SPREAD BETS

CFDs are agreements to exchange the difference in value of a particular instrument or currency between the time at which the agreement is entered into and the time at which it is closed. CFDs allow the Firm’s Clients to replicate the economic effect of trading in financial instruments without requiring actual ownership of those assets; a full list of the CFDs on offer by Oriental Wealth Markets Limited is available on our Website.

Spread Bets are a type of contract whereby a Client can speculate on the price movement of a financial instrument by placing a buy or sell order which will pay out a pre-determined amount per point gained. This means that for every point that the price of the financial instrument moves in your favour, you will gain multiples of that pre-determined amount (also known as ‘stake’). Conversely, if the price of the financial instrument moves against you, you will lose multiples of the stake. Like with the case of CFDs, with Spread Betting you can replicate the economic effect of trading in financial instruments without owning the underlying assets.

Profits derived from Spread Betting are free of capital gains tax and stamp duty for UK residents only. Tax laws are subject to change and depend on individual circumstances. You may wish to seek advice from a tax adviser if you are unsure of your circumstances.

CFDs and Spread Bets are derivative products traded off-exchange (or Over-the-Counter (‘OTC’)); this means Oriental Wealth Markets Limited is always the counterparty to the Client trades and any CFD and/or Spread Bet trades entered into with the Firm, can only be closed with us. Your ability to open and/or close trades is dependent on the availability of our trading platform(s).

You understand that you are not entitled to the physical delivery of the underlying instrument (or reference instrument) of the CFDs and/or Spread Bets you are trading, and you have no rights in the underlying instrument (such as voting rights in case you are trading CFDs and/or Spread Bets on shares).

CFDs and/or Spread Bets fluctuate in value during the day; the price movements of CFDs and/or Spread Bets are determined by a number of factors including but not limited to availability of market information.

PRICES AND COST

4.1 The prices generated by our trading platform(s) are derived from the prices of the relevant

underlying instruments, which the Firm obtains from third party liquidity/ price providers. The prices of CFDs and/or Spread Bets that you trade with us include a mark-up; this means thatthe spreads offered by us comprise of (i) the raw spreads received from liquidity/ price provider(s) and (ii) a mark-up (where applicable).

4.2For trading certain CFDs and/or Spread Bets, the Client may be required to pay a commission and/or other fees; these instances are described in detail in our Website. For all type of CFDs and/or Spread Bets offered by the Firm, the commission (if applicable) and financing/ overnight fees are not incorporated into the Firm’s quoted prices and are instead charged explicitly to the Client Account(s). In the case of financing/ overnight fees, the value of opened positions in some types of financial instruments is increased or reduced by a daily financing fee ‘swap’ throughout the life of the trade. The financing fees are based on prevailing market interest rates. From Mondays to Friday swap is charged once for every business day and on Wednesday swap is charged in triple size in order to account for the weekend; details of daily financing/ overnight fees applied, are available in our Website.

4.3You should not fund your Account using money obtained from any credit facility (including bank loan or otherwise). You should understand that your overall risks will be significantly increased. For instance, if you incur a loss on your trades, you will still have to repay any amount borrowed plus any interest or other costs. Therefore, you shall never finance any trades on such borrowed money, and you should never rely on being able to profit on any trade, in order to repay such amounts.

5. MARKET CONDITIONS, REQUIRED MARGIN, LEVERAGE AND STOP-OUT LEVELS

5.1Trading CFDs and Spread Bets enables you to use leverage to open a trade by depositing a fraction of the total trade value; this means that a relatively small market movement may lead to a proportionately much larger movement in the value of your trade. For margin calculation purposes, the leverage level used will be the lower of: (i) the Account or (ii) symbol traded. This logic applies on all our trading platforms.

5.2 Financial markets may fluctuate rapidly to reflect events that are outside the control of the

Firm and/or your control; as a result, prices will become volatile. One form of price volatility is ‘gapping’, which occurs when there is a sudden shift in prices from one level to another. This can be caused, for example by unexpected economic events or market announcements, within or outside trading hours. Consequently, Oriental Wealth Markets Limited may be unable to execute your instructions at the requested price. In addition, if prices move against you, this will have a direct and real time impact on your trades, which may be automatically stopped-out. It is possible that you all your trades will be stopped-out; not just the ones that are loss making.

5.4You should note that any changes made to your leverage level, on an already traded Account, can immediately affect your open positions and may result in a stop-out.

5.5It is your responsibility to monitor the required margin of your open positions and in order to avoid a stop-out you may have to fund your Account.

6. FOREIGN EXCHANGE AND OTHER RELATED RISKS

You will be impacted by foreign exchange movements, if you are trading in a product that is denominated in a currency other than the currency of your Account. Any currency conversion calculations are provided by the Firm to the Client in the currency in which the Client account is denominated and the currency of the relevant instrument, using the cross spot rate.

Your capacity to trade CFDs and Spread Bets may also be affected as a result of changes in the legal, regulatory, taxation environment and/or other.

7. TECHNICAL RISKS

7.1 We try to generate prices continuously and provide you with access* to our trading platforms

throughout the trading sessions as indicated on our Website. However, there are instances where this is not possible; for example, instances of poor telecommunication/ internet connectivity, system errors and outages and/or other factors. The above may cause prices to change between the time an order is placed and the time the order has been received by the Firm. In addition, these technical risks may significantly impact the execution of your orders.

* Access to our trading platforms includes access via mobile applications.

8 NO ADVICE

8.1Oriental Wealth Markets Limited may, from time to time and as often as it deems appropriate, issue and/or distribute third party material (the ‘Material’), which contains information including but not limited to the conditions of the financial markets, posted through our Website and other media and/or received by you. It should be noted that the Material is considered to be marketing communication only and does not contain, and should not be construed as containing, investment advice and/or an investment recommendation and/or, an offer of or solicitation for any transactions in financial instruments; any decision to enter into a specific transaction shall be made by the Client following an assessment by him/herself of their situation. Oriental Wealth Markets Limited makes no representation and assumes no liability as to the accuracy or completeness of the information provided, nor any loss arising from any investment based on a recommendation, forecast or other information supplied by any employee of Oriental Wealth Markets Limited, a third party or otherwise. The Material is not prepared in accordance with legal requirements promoting the independence of investment research and it is not subject to any prohibition on dealing ahead of the dissemination of investment research. All expressions of opinion included in the Material are subject to change without notice. Any opinions made may be personal to the author and may not reflect the opinions of Oriental Wealth Markets Limited.

8.2Oriental Wealth Markets Limited does not provide investment, financial, legal, tax, regulatory or other advice relating to investments or trading in financial instruments. Any material or information or other features, which may be provided to you through our Website, trading platforms, marketing or training events or otherwise, is generic and shall not be treated as advice appropriate for you or based on a consideration of your personal circumstances. You should seek independent professional advice from a suitably qualified adviser, if necessary, prior to engaging in trading with us.

9 PAST PERFORMANCE

9.1Past performance, simulation or prediction of any financial instruments does not constitute an

indication of future results. You should note that the value of your investment can decrease (as well as increase) as the market price of the underlying asset may fluctuate downwards (or upwards).