This Customer Agreement (this “Agreement”) governs the relationship between you (“you”, a
“User” or a “trader”), on the one hand, and International Finance Asia Ltd. and its subsidiaries
and affiliates, on the other hand (collectively, “Company”, “the Company”, “we” or “us”).
References in this Agreement to “Users” other than you are references to other parties to an
agreement with the Company in this form or substantially this form. International Finance Asia
Ltd. is a company incorporated under the laws of Labuan, with registration number LL 14391,
regulated in Labuan Financial Securities Authority as a securities licensee, license number
SL/18/0009, and has its principal place of business at Brumby Centre, Lot 42, Jalan Muhibbah,
87000 Labuan F.T., Malaysia. This Agreement contains important information about your use of
www.internationalfinanceasia.com, and any other affiliated site (the “Site” or the “Company
website”) and the risks associated with trading on the Company website. Upon your acceptance
of this Agreement by submission of your electronic signature, you and the Company will be
legally bound by the terms of this Agreement.
Please read this Agreement carefully.

1. INTRODUCTION
1.1. Scope of your agreement.
This Agreement incorporates by reference the Company Website Terms and
Conditions and Application Form (collectively, the “Terms and Conditions”). You
represent that you have read the Terms and Conditions, and agree that the
Terms and Conditions and this Agreement govern
a. your access to the Site and your use of the information, features,
products, services and tools on the Site (the “Services”) and
b. the terms and conditions for trading by using the Site.
This Agreement should be read carefully before using any Services or continuing
to access the Site. By using the Site in any manner, including but not limited to
visiting or browsing the Site, you agree and consent to this Agreement, and you
agree to be bound by this Agreement, the Terms and Conditions, and all other
operating agreements, rules, policies and procedures that may be published by
the Company from time to time on the Site, each of which is incorporated by
reference. Your use of the Services is governed by the version of this agreement
in effect on the date each Service is used by you. You are responsible for
checking this page on our website/applications periodically in order to review the
current version of this agreement. If you have any questions about any of the

International Finance Asia Ltd.

provisions of this Agreement, you may contact the Company at
client@internationalfinanceasia.com
1.2. Client categorization.
Company classifies all users as “retail clients”. You have a right to request a
different categorization (such as “professional client”) if you meet the criteria of
such category. Note that you will receive less regulatory protections if you
request a higher categorization. Please see our current client categorization
policy.
1.3. Complaints.
Any complaints about Company’s service should be directed, in the first
instance, to client@internationalfinanceasia.com. Please review our
current complaints policy for additional information.
1.4. Compensation Scheme.
If you make a valid claim against Company and it is unable to meet its liabilities
to you in full, you may be entitled to redress from the Investor Compensation
Fund (“Fund”). You must make your claim within a deadline which will be
published by the Fund. The deadline cannot be less than five months or more
than nine months from the date of the Fund’s last publication of the deadline.
Further details of the policy of the Fund are available on our Investor
Compensation Fund Policy.
1.5. Your right to cancel.
You have the right to give notice to the Company cancelling this Agreement. You
must do so within fourteen days beginning with the day after you have accepted
this Agreement, provided you have not commenced trading on the Site, by
submitting your electronic signature. Your notice to cancel must be in writing
addressed to or left at the Company’s principal place of business (as stated
above) or by e-mail to client@internationalfinanceasia.com.

1.6. Changes to this Agreement.
Your use of the Site is governed by the version of this Agreement in effect on the
date of use. We may modify the terms of this Agreement (including the Terms
and Conditions) at any time by prior notice posted prominently on the Company
website, but without affecting this Agreement (or the Terms and Conditions) as it
relates to any open positions, and you agree to be bound by this Agreement as
so modified. It is your responsibility to visit the link(s) accessible on the Site
home page periodically to review the most current terms of this Agreement
(including the Terms and Conditions) for changes. By accessing the Site after we
have made changes to this Agreement, you are agreeing to the terms of this

International Finance Asia Ltd.

Agreement as modified. If you do not wish to be bound by those changes, you
should cease to use the Company website and the Services. If this Agreement
varies from other information on the Company website, this Agreement prevails.

1.7. Indication of your Agreement.
By clicking any “I Agree” button or similar buttons or links when prompted to
show your assent and agreement to this Agreement (or any other agreements or
provisions presented to you for your indication of assent), you are entering into a
legally binding contract and you are agreeing to be bound by and to comply with
the terms of this Agreement (and any other such agreements or provisions).

2. OUR SERVICES
2.1. Our services.
We will provide to you the following services:
a. agency brokerage services, consisting of general dealing services,
including buying and selling securities, contracts for differences where the
underlying assets include shares or indices (“CFDs”) and other
investments on your specific instructions (whether you are dealing at your
sole discretion or following/piggybacking a lead User), in all cases as your
agent;
b. arranging for you the services described in (a) above;
c. advising you, via the Site, on buying, selling and otherwise acquiring and
disposing of securities, CFDs and other investments; and
d. custody services in relation to your securities, CFDs and other
investments and liquid funds.

2.2. Risk disclosures.
By accepting this Agreement you acknowledge you have read and understood
our risk disclosure document.

2.3. No tax advice by Company.
We will not provide any tax advice. In addition, we will not at any time be deemed
to be under any duty to provide tax advice.
2.4. No investment advice or recommendations by Company.
If you have requested Company to send you direct notification of any Lead
Traders’ trades, these notifications will not constitute investment advice.
Company provides an execution only dealing service and accordingly does not
offer any specific advice or recommendations on the making of investment

International Finance Asia Ltd.

agreements. Any advice on the making of investment agreements which may be
contained anywhere on the Company website is intended to be non-specific and
of a generic nature only. Where relevant you may be required to sign further
agreements with regard to any specific advice or investments we may from time
to time provide on the Company website.
2.5. Electronic dealings.
You agree to the use of electronic communications to enter into contracts, place
orders and receive delivery of notices, information and records of transactions
initiated or completed through the Company website. Furthermore, you hereby
waive any rights or requirements under any laws or regulations in any jurisdiction
that requires an original (non-electronic) signature or that requires delivery or
retention of non-electronic records, to the extent permitted under applicable law.
2.6. If approved, you may engage in margin trading.
If you selected to have your Account treated as a margin Account on your
Account Application Form and were approved by the Company in its sole
discretion to have a margin Account, then, subject to the requirements set out in
our suitability policy, you may engage in margin trading. By engaging in margin
trading, you may be borrowing money or securities from the Company. Different
instruments may have different margin requirements as shall be determined by
the Company from time to time. You agree that you are solely responsible for
determining whether margin is appropriate for you in the light of your financial
resources, objectives and other relevant circumstances. You understand and
agree that the Company will not make this determination on your behalf and that
an approval of a margin Account by the Company should not be construed as
such a determination.
Subject to any regulatory requirements, the minimum and maximum amount of
any particular margin transaction may be established by the Company at our
discretion regardless of the amount of collateral delivered to us, and we may
change such minimum and maximum amounts. Your margin transactions are
also subject at all times to our initial margin and maintenance margin
requirements. You shall monitor your margin Account to ensure that it contains
sufficient securities and liquid funds at all times to meet our current applicable
margin requirements. We may liquidate a position if the required amount of
margin is not met. We may ourselves meet margin calls and post collateral on
your Account, at our sole discretion.
We may modify our margin requirements for open and new positions at any time,
in our sole and absolute discretion. The margin that we require may exceed the
margin required by any exchange or association. We may reject any order if you
do not have a sufficient account balance to meet our current margin
requirements and may delay the processing of any order while determining the

International Finance Asia Ltd.

correct margin status of your Account. You shall maintain, without notice or
demand from us, a sufficient account balance at all times in order to continuously
meet our current margin requirements.
You acknowledge that we are not obligated to: (i) request additional securities or
liquid funds for margin purposes in the event your Account falls below, or
appears likely to fall below, the minimum margin requirements; (ii) notify you of
any such deficiency or likely deficiency; or (iii) provide you with additional time to
deposit additional securities or liquid funds. You agree to promptly satisfy all
margin calls. We reserve the right to institute immediate discretionary liquidation
of any and all securities in your margin Account, whether at a loss or a profit,
without prior notice and without giving you the opportunity to deposit additional
securities or liquid funds.
Unless otherwise agreed by us, you charge to us all margin as a continuing
security for your liabilities under or pursuant to this Agreement (including under
every transaction). You agree to execute such further documents and to take
such further steps as we may reasonably require to enable us to exercise our
rights or to satisfy any requirement.
You agree to pay interest on all debit balances in your margin Account. Interest
on your average daily net debit balance will be determined by us and may be
changed at any time in our sole and absolute discretion. Interest is accrued daily,
compounded monthly, and calculated on a 360-day year (365-day year in the
UK). For interest rates please contact our support at
client@internationalfinanceasia.com.
You agree to pay an overnight fee for any margin positions in your Account which
remain open overnight. If a position has been opened on a Friday or before a
holiday and held overnight until the coming Monday, the amount added or
subtracted for the overnight fee is usually three times the daily amount to cover
the entire weekend, or the corresponding amount to cover the holiday period.
The overnight fee is calculated in relation to market conditions (including, i.e.,
whether the transaction is a buy or a sell, interest rates, the currency in which it is
denominated, daily price fluctuations and other economic and market related
factors). The overnight fee will be deducted by us from your cash balance. To
receive the overnight fee rate relevant for your position, please contact
client@internationalfinanceasia.com, as it may change due to price fluctuations.
We reserve the right to change the overnight fees of instruments.
2.7. Your use of market data.
Any market data the Company provides to you, or you access through the Site,
will be provided or made accessible for convenience and information only solely
to assist you to make your own investment decisions, and does not amount to

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investment advice. THE DATA WILL THEREFORE BE PROVIDED OR MADE
ACCESSIBLE TO YOU WITHOUT ANY LIABILITY AND YOU SHOULD NOT
RELY UPON THE DATA IN ANY WAY. In particular, any price quoted in the
data may differ from the execution price you actually obtain.
“Market data” are data produced by an investment exchange in case of
securities, and a liquidity provider in case of CFDs. The data may include
(without limitation) current market prices (“real time” or delayed), opening and
closing market prices and ranges, high-low market prices, estimated and actual
market volumes and the size, number and existence of current market bids and
offers.
Market data constitute valuable confidential information. As such, the data are
the exclusive property of the exchange or liquidity provider which operates the
market. Accordingly, you may not redistribute the data in any way and you may
use the data only under the rules of the relevant exchange. You should consult
the website of the relevant exchange for full details of the rules.
You authorize the Company to enter into any agreement on your behalf with any
exchange(s) relating to the proper use of market data as the Company sees fit.
2.8. Your orders.
You agree that you will not transmit orders to us using electronic communications
other than those electronic communication features designated by the Company
and available on the Website for the express purpose of placing orders. We may,
in our sole discretion and at our sole option, decline to execute any orders for a
variety of reasons, including, but not limited to, the size of an order, market
conditions, your breach of this Agreement, a violation of any applicable rules or
regulations related to your orders, insufficient or inadequate securities or liquid
funds in your Account, insufficient margin, risk considerations and other matters
that affect trading generally. You are responsible for the monitoring of all of your
orders entered into our electronic systems until such orders are confirmed or a
cancellation is confirmed by us. You acknowledge and agree that the Company
reserves the right to cause any of your orders to be routed for execution to one or
more exchanges, associations, electronic communications networks or markets if
we, in our sole discretion, determine that doing so will result in the better
execution of your orders.
2.9. Transactions outside a regulated market or multilateral trading
facility.
You consent to the Company, its affiliate, or any third party broker chosen by the
Company as an execution venue, as the case may be, effecting transactions on
your behalf outside a regulated market or multilateral trading facility.

International Finance Asia Ltd.

2.10. Electronic access.
You agree not to use our electronic communication system for any purpose that
is unlawful, abusive, harassing, libelous, defamatory, obscene or threatening.
You agree that you will not use our electronic communication system to solicit
our users or any others for any purpose. You acknowledge that our electronic
communication system is protected by copyright and other intellectual property
rights. You agree that you will not, and that you will not attempt to, reproduce,
retransmit, disseminate, sell, distribute, publish or commercially exploit in any
way our electronic communication system. You agree to provide us with your
current email address and to promptly communicate to us any changes to your
email address or any other relevant information that may affect your Account with
Company. You agree to accept delivery of communications from us by email.
2.11. Your User identification, password and Account number.
You agree that you are responsible for the confidentiality and use of your User
identification, password and Account number. You agree that you are
responsible, and that you will be liable, for all securities trades and other
transactions effected through the use of your User identification, password and
Account number, even if such trades and other transactions were not authorized
by you. Any orders communicated to Company through the use of your User
identification, password and Account number will be considered to have been
sent and authorized by you. You agree to notify us immediately if you:
a. become aware of any loss, theft or unauthorized use of your User
identification, password or Account number,
b. receive a confirmation or other communication for an order that you did
not place, or
c. fail to receive an accurate confirmation for an order that you did place.

2.12. Version update to mobile application.
When using the Company’s mobile application (either apple or android) you
acknowledge that we may, from time to time, update the version of the
application. You agree that in case of a major update, we may discontinue the
old version and in order to continue using the mobile application you will be
required to download the new version.

2.13. Service providers.
Various services available to you through the Company website are offered or
processed through a service provider, which may be an unaffiliated company, or
an affiliate of the Company. Unless otherwise noted in this Agreement (if at all),
any authority granted by you to the Company, and/or any limitation of liability of

International Finance Asia Ltd.

the Company, shall also extend to include in the grant and limitation its affiliates,
agents and any service provider. The Company and the agents, affiliates or
service providers acting on behalf of the Company under this Agreement are
authorized to perform the services contemplated by this Agreement. You consent
to the Company providing your identifying information to any requesting service
provider of the Company.

3. ACCOUNT APPLICATION
In order to open a brokerage account with the Company, established in your name (an
“Account”), the Company must obtain, verify and record information that identifies you
and other Account holders, as applicable, in order to confirm your identity and comply
with applicable laws and regulations, and you must complete, and then submit to the
Company, an Account Application Form.
By providing the information requested below, you are confirming to the Company that
the information is current, true, accurate and complete. Unless you provide the
requested information, you will not be able to become a User or utilize the Services. If
you determine that you are unwilling to be bound by this Agreement, you should not
submit the Application Form to the Company.
You confirm that you have regular access to the internet and consent to the Company
providing you with information, including, without limitation, information about
amendments to its order execution policy and information about the nature and risks of
investments by posting such information on the Site at
www.internationalfinanceasia.com (or on such other website as the Company may from
time to time notify to you).

3.1. General representations, warranties, covenants.
a. Your legal capacity. You are of full legal age in the jurisdiction in which
you reside and have full capacity to enter into this Agreement.
b. You are not a specified United States person. You represent and
warrant that you are not a U.S. citizen (including dual citizen), a U.S.
resident alien for tax purposes, a U.S. privately owned domestic
corporation, a U.S. domestic partnership or a U.S. domestic trust or
estate.
c. You are not an ineligible User. You are not permitted to submit an
Account Application Form, or become or continue to act as a user of the
Company website, if you:

International Finance Asia Ltd.

i. are not 18 years old, or the age of legal consent for engaging in
financial investment activities under the laws of any jurisdiction
that applies to you;
ii. are not resident in a European Economic Area (“EEA”) State
(unless you are resident in a jurisdiction outside the EEA which,
as at the date of our consideration of your Account Application, we
have determined (in our sole discretion) is a “permitted country”)
or you are a “Specified United States Person” (as referred to in (b)
above);
iii. are affiliated with, employed by or are yourself a broker or dealer,
financial or investment advisor or manager, futures commission
merchant, commodity trading advisor, commodity pool operator, or
are affiliated with or employed by a bank, securities exchange,
market or clearing house;
iv. are a director, 10% beneficial shareholder or policy-making officer
of a publicly held company; or
v. fall into any of (i) – (iv) above as a result of a change of
circumstances.
Without limiting the foregoing, by using the Site and our Services you
acknowledge and understand that laws regarding financial instruments
vary throughout the world, and it is your obligation alone to ensure that
you fully comply with any law, regulation or directive, relevant to your
country of residency with regards to the use of the Site and our Services.
For avoidance of doubt, the ability to access the Site and use our
Services does not necessarily mean that our Services, and/or your
activities through it, are legal under the laws, regulations or directives
relevant to your country of residency. Our Site and/or any other online
material do not constitute, and may not be used for the purposes of, an
offer or solicitation to anyone in any jurisdiction in which such offer or
solicitation is not authorized, or to any person to whom it is unlawful to
make such an offer or solicitation.
Your investment expertise. You represent and warrant that you have
the necessary experience and knowledge to understand the risks
involved in trading through the Site and using the Services and that you
are financially able to bear the risks consistent with your investment
objectives. In entering into any trade, you represent that you have been
solely responsible for making your own independent appraisal and
investigations into the risk of the trade and that we have not provided any
advice to you in relation to the trade. You represent, and we are entitled
to assume, that you have sufficient knowledge and experience to
understand and make your own evaluation of the merits and risk of any

International Finance Asia Ltd.

trade. We assume no fiduciary duty to you pursuant to this Agreement, to
the extent permitted by applicable law and regulations.

d. You have non-commercial purposes. You represent and warrant that
your use of the Services is and will continue to be for non-commercial
purposes.
e. Changes to your information. You represent and warrant to the
Company that the answers you provided to the questions in the Account
Application Form are current, true, correct and complete and may be
relied upon by the Company in determining whether you are eligible to
trade using the Site. You agree to notify the Company of any change to
the information provided in the Account Application Form promptly, but in
any event within thirty (30) days of such change.
f. Approval, rejection, termination or restriction of Account. Company
may reject your Account, terminate or restrict (to any extent) your Account
for any reason, without disclosing the reason, (i) by a written notice to
you; or (ii) without notice, if the Company suspects that you have
breached applicable law or regulations or intend to do so, or if the
termination or restriction without notice is in accordance with the
Company’s internal policies as currently posted on the Site. Termination
or restriction will not affect our existing obligations to you (if any). We may
require that you provide us additional information in order for us to
approve your Account application or to continue carrying your Account. If
you do not provide the information within the required time frame, or
provide inaccurate, incomplete or otherwise misleading information, we
reserve the right to terminate, limit or block access to your Account. If we
terminate your Account, we may liquidate any securities you hold in it at
such time and price, and in such manner, as we determine.

g. Your covenants. You covenant to us that:
i. you will comply with all applicable laws and regulations in relation
to this Agreement and any transaction; in particular, you covenant
that you will not use the Site for the purposes of insider dealing,
market manipulation, front-running or any other form of securities
fraud or market abuse;
ii. upon demand, you will provide us with such information as we
may reasonably require in order to evidence your compliance with
(i) above or in order to comply with any applicable laws and
regulations.

International Finance Asia Ltd.

h. Disclosure to authorities. You agree that we may share any information
relating to your use of the Site or relating to your Account with any
competent authority.

3.2. Type of Account ownership. Company offers only individual Accounts.
3.3. Account authorization and signatures
a. Electronic communications and electronic delivery to You: We will
send notices and other communications relating to your Account to the
email address that you specified in your Account Application Form or that
you subsequently updated by using the customer information update
feature available on the Site. We will also post notices, statements and
other communications relating to your Account on a password-protected
part of the Site that you may view when you log into your Account. Any
communication we send to your email address that is on file with us is
considered delivered to you personally, whether you actually receive it or
not. You agree to inform us promptly of any changes in the email or
mailing addresses you provided when you submitted your Account
Application Form to us.
By submitting your Account Application Form to us, you agreed and
consented to receive account information and records electronically from
us. This included trade confirmations, Account statements, proxies,
shareholder information, tax statements and other documents and
communications, both regulatory and non-regulatory. As long as your
consent to electronic delivery of these records and information remains in
effect, access to and delivery of the records and information will be
provided to you when we post the records or information on a password-
protected part of the Site to which you have access. We will send you an
email regarding any posting of such information on the Site. You agree to
check the Site regularly to help ensure that you are aware of the records
and information that have been posted there. Some documents, such as
trade confirmations and Account statements, may be archived on the
Website for you to access and review at your future convenience.
There is no charge by us for electronic delivery and access to records
and information, but online access and usage charges by your Internet
service or access provider may apply. The records and information we
deliver to you electronically will be made available in HTML or PDF format
to facilitate your printing or saving of the records and information. You
represent and acknowledge to Company that you can access documents
in HTML and PDF format and that you have the software, hardware, skill

International Finance Asia Ltd.

and knowledge necessary to download, print and save documents in
those formats.
By agreeing and consenting to electronic delivery of records and
information, you are agreeing that we will not mail paper versions of
records and information to you. You may revoke your consent to
electronic delivery at any time by visiting the relevant part of the Website
or by notifying us in writing. Any revocation of your consent to electronic
delivery is only effective after we receive and process it. If you wish to
receive paper documents through the mail, you understand that you may
be charged fees for delivery of the paper documents.

4. ANTI-MONEY LAUNDERING
You acknowledge that in order to ensure compliance with the Cyprus Prevention and
Suppression of Money Laundering Activities Law of 2007 N. 118(I)/2007 (as amended
from time to time) or any other applicable regulations, we may require verification of
identity from you. You accordingly agree to provide to us on demand satisfactory
evidence of your identity and to do all other acts and things as we may reasonably
require so as to enable us to comply with such law and regulations. You acknowledge
that failure to provide the relevant information within a reasonable time may result in our
ceasing to deal with you or to provide any Services to you.

5. INDEMNIFICATION AND LIABILITY
5.1. You will indemnify Company against, and hold Company harmless from,
any and all harm, damages, claims, demands, liabilities, losses, costs, penalties,
fines and expenses, including reasonable attorneys’ fees, that result from (1) any
false representations made by you anywhere on the Site or in the Account
Application Form, (2) your negligent or willful misuse of the Site, or (3) any other
negligent or willful act or omission on your part. If you cannot truthfully state, or
have not truthfully made, any statements, representations and agreements made
through the Site, the Company may not accept any transaction that you make
through the Site, and any such transaction may be reversed or otherwise voided
by the Company. All information that you have provided and will provide to the
Company is and will be current, true, correct, complete and not misleading. You
agree to notify the Company if any of the information provided becomes
obsolete, untrue, incorrect, incomplete, or misleading. You agree that you
reaffirm the truthfulness of all information you have provided to the Company
each time you execute a new transaction on the Site.

International Finance Asia Ltd.

5.2. USER ACCEPTS THE COMPANY WEBSITE "AS IS", AND, SUBJECT
TO APPLICABLE LAW, WITHOUT WARRANTIES, EXPRESS OR IMPLIED,
INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF
MERCHANTABILITY OR FITNESS FOR A PARTICULAR USE, PURPOSE OR
APPLICATION; TIMELINESS; FREEDOM FROM INTERRUPTION; OR ANY
IMPLIED WARRANTIES ARISING FROM TRADE USAGE, COURSE OF
DEALING OR COURSE OF PERFORMANCE. COMPANY SHALL NOT BE
LIABLE TO USER BY REASON OF DELAYS OR INTERRUPTIONS OF
SERVICE OR TRANSMISSIONS, OR FAILURES OF PERFORMANCE OF THE
COMPANY WEBSITE, INCLUDING, BUT NOT LIMITED TO, THOSE CAUSED
BY HARDWARE OR SOFTWARE MALFUNCTION; GOVERNMENTAL,
EXCHANGE OR OTHER REGULATORY ACTION; ACTS OF GOD; WAR OR
TERRORISM. USER RECOGNIZES THAT THERE MAY BE DELAYS OR
INTERRUPTIONS IN THE USE OF THE COMPANY WEBSITE, INCLUDING,
FOR EXAMPLE, THOSE CAUSED INTENTIONALLY BY COMPANY FOR
PURPOSES OF SERVICING THE SITE. IN NO EVENT SHALL COMPANY’S
LIABILITY IN CONNECTION WITH USER’S USE OF, OR INABILITY TO USE,
THE COMPANY WEBSITE, REGARDLESS OF THE FORM OF ACTION AND
DAMAGES SUFFERED BY USER, EXCEED THE AGGREGATE FEES AND
COMMISSIONS PAID BY USER TO COMPANY OVER THE 6 MONTHS PRIOR
TO THE EVENT GIVING RISE TO USER’S CLAIM.
5.3. You are responsible for reading and understanding the risks associated
with the Site.
5.4. Notwithstanding any other provision of this Agreement, Company will not
be liable to you for any harm, damages, claims, demands, liabilities, losses,
costs, penalties, fines or expenses suffered or incurred by you under or in
connection with this Agreement except to the extent that the same are caused by
Company’s negligence, fraud, willful default or breach of any applicable law or
regulations. Without prejudice to the foregoing, and subject to applicable law,
Company will not under any circumstances be liable to you for indirect or
consequential loss.

6. TRADING RULES FOR ALL USERS
6.1. You are a brokerage customer of the Company.
Upon acceptance of your Account application by the Company, you will become
a brokerage customer of the Company. All transactions made by you through the
Site will be settled and executed by the Company as your agent using a
Company omnibus account with a third party execution broker (“Execution
Broker”). You will not have a brokerage account directly with the Execution
Broker and accordingly, the Execution Broker will only accept trade instructions

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from the Company and not directly from you. You should direct all trade
instructions and questions about your Account directly to the Company. The
Company will not be liable for the acts or omissions of the Execution Broker.
Company will always trade with you as your agent.
6.2. Your securities may be registered in a nominee’s name.
Securities which are held by the Company for your Account will be registered
either in (a) your name, (b) the name of the Company, as your custodian, or (c) a
nominee other than the Company, including a sub- custodian or a recognized
depository clearing organization. Your ownership of your securities will be
reflected in the Company’s records.
6.3. Company will hold all User assets in an omnibus account.
All liquid funds (that is, cash) held by the Company for a User will be deposited
by the Company in an omnibus client bank account in the name of the Company
and will therefore be pooled with liquid funds of other Users. All securities held by
the Company for a User will be deposited by the Company in an omnibus client
account with a third party depositary in the name of the Company, as the User’s
custodian, and will therefore be pooled with securities of other Users. In such
case, it may not be possible to separate it from the client’s money, or the third
party's money.
The Client acknowledges and confirms that no interest will be received on the
balance of your account. Omnibus Account Risk: The risk of loss emanating from
the use of omnibus accounts in third parties, i.e. financial or credit institutions.
The above risk may hold other types of risks including legal, liquidation risk,
haircut risk, third party risk etc.
In the event of the insolvency or any other analogous proceedings in relation to
that third party, the Company may only have an unsecured claim against the third
party on behalf of the client, and the client will be exposed to the risk that the
money received by the Company from the third party is insufficient to satisfy the
claims of the client with claims in respect of the relevant account. The Company
does not accept any liability or responsibility for any resulting losses.
6.4. Custody.
Company will maintain true, complete and accurate records relating to the liquid
funds and securities held by it for each User. Company will take reasonable care
in the selection and ongoing supervision of the bank and depositary with which
the liquid funds and securities are deposited, but will not be liable for the acts or
omissions of the bank or depositary. Your assets may be at risk if the bank or
depositary becomes insolvent. If any of the liquid funds or securities held for you
by the Company are properly passed to the account of a third party in connection
with a transaction or in order to meet margin or collateral obligations, the funds or

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securities may be at risk if the third party becomes insolvent. Since your liquid
funds and securities will be pooled by the bank or depositary with liquid funds
and securities belonging to other Users, you will not have a legal claim against a
specific sum of money or a specific security. Instead, any claim will be against
the pool in general. If there is an irreconcilable shortfall in the pool of liquid funds
or securities following a default by the bank or depositary (for example, if it
becomes insolvent), you may not receive your full entitlement to the liquid funds
or securities. If so, you will share in the shortfall pro rata. Pooling of securities
may also result in your allocation in a share issue being less than it would
otherwise have been, if the share issue’s allocation policy is designed to favor
small investors and under the policy you are not considered to qualify as a small
investor. If the Company becomes insolvent and any of your liquid funds or
securities are held in the name of the Company by a bank or depositary in such a
territory, those funds or securities will therefore be available to the Company’s
creditors generally and so may be at risk. If your liquid funds or securities are
held by a bank or depositary outside the EEA, the applicable legal and regulatory
regime may differ from that of the EEA. Your rights may differ accordingly,
particularly if the bank or depositary defaults.
6.5. Periodic reporting to you.
Company will send you by email an annual statement of all liquid funds and
securities held by it for your account. If the statement includes a valuation of the
securities, it will also include an explanation of how the securities have been
valued.
6.6. Company may aggregate your order with the orders of other Users.
We may combine your order with the orders of other Users. The average price of
executing such combined order will be assigned to your Account as the market
price for your trade. Combining orders may, in some cases, result in you
obtaining a less favorable price than if the orders had been executed separately.

6.7. Best execution and order handling and routing.
When executing an order you have placed, the Company will take all reasonable
steps to obtain the best possible result, taking into account price, costs, speed,
likelihood of execution and settlement, size, nature and any other relevant
considerations. YOU UNDERSTAND THAT YOUR SPECIFIC INSTRUCTIONS,
IF ANY, MAY PREVENT COMPANY FROM OBTAINING THE BEST
POSSIBLE RESULT IN RELATION TO THE MATTERS COVERED BY THE
INSTRUCTION. You agree that all your orders will be subject to the Company's
current order execution policy.
You understand that, subject to the terms of an order, the method of execution of
each order is in the sole discretion of the Company and its service provider.

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Orders that are accepted by the Company will be transmitted by the service
provider to the appropriate exchange or other market for placement and
execution. Certain orders, at the Company’s sole discretion, may be subject to
manual review and entry, which may cause delays in the execution of the order
and may cause the order to be executed at a price that is significantly different
from the price quote you obtained when you entered the order. For further
information please see Company’s current order execution policy.

6.8. You will be subject to certain fees and commissions. You will
receive any periodic payments accruing to your Account.
You agree to pay brokerage commissions, charges, foreign exchange dealing
commissions on currency conversions, credit card processing fees and other
fees promptly as set forth in the Company's then-current fee page and the
Company’s deposit page and as applicable to your Account and the transactions
and Services you receive. You also agree to pay all applicable country, federal,
state and local taxes. You authorize the Company automatically to debit your
account for any such commissions, charges, fees and taxes. The current fee
schedule is available here. Company may modify the fee schedule at any time,
but without affecting fees relating to any open positions, by posting a modified
schedule on the Site. Company may require you to make a minimum payment to
open an Account and to maintain a minimum balance in the Account thereafter. If
your Account’s value falls below the minimum balance or your Account is, in the
Company’s opinion, inactive, the Company may charge additional fees or, if it
deems appropriate in its discretion, close your Account. Account maintenance
fees (if any) will be as described in the current fee schedule on the Company
website.
Company will receive any periodic payments accruing to your Account, such as
dividends and interest, on your behalf, and will credit them to your Account on or
shortly after the date the funds are received by or on behalf of the Company,
converted to the base currency used for your Account. The payer may deduct tax
from the payment before the Company receives it, in order to comply with
applicable law. Applicable law may also require the Company to deduct tax from
the payment before it, or the balance, is credited to your Account and/or before
the payment (or the remaining balance) is remitted to you from the Account.
6.9. Trading markets and types of investments permitted.
You may purchase and sell securities, or CFDs with the underlying assets being
securities, which are publicly traded on exchanges in the United States and
Europe, and indexes. Over time, other types of investments, additional securities
exchanges or different trading markets may be available on the Site.

International Finance Asia Ltd.

6.10. You may place orders and instructions only through the Company
website or by telephone.
We do not accept orders through the mail. If for any reason you cannot place an
order through the Company website, you may place an order by telephone. You
acknowledge that the execution of orders placed by telephone may not be
immediate, which may cause the order to be executed at a price that is
significantly different from the price quote you obtained when you entered the
order. Please note that trading fees may be higher where orders are placed by
telephone.
6.11. You acknowledge that it may not be possible to cancel or modify an
order.
Any attempt to cancel or modify an order is simply a request to us to do so. We
are not liable to you if we are unable to cancel or modify an order. You
understand and agree that, if an order cannot be cancelled or modified, you are
bound by any execution of the original order. You further acknowledge that
attempts to modify or cancel and replace an order can result in an over-execution
of the order or the execution of duplicate orders, that our systems do not prevent
such over-executions or duplications from occurring, and that you shall be
responsible for all such over-executions or duplications. If you enter a
cancelation request, you agree to confirm that the cancellation request has been
effected prior to entering a replacement order. You agree not to assume that any
order has been executed or cancelled until you have received written
confirmation from us. You are responsible for knowing the status of your pending
orders before entering additional orders. You agree to contact us immediately if
you are unclear on the status of an order.
6.12. Confirmation of your orders.
Following execution by the Company of a purchase or sale order in your
Account, the Company will send you a confirmation of the order by email. The
terms of any such confirmation will be conclusive as between you and the
Company, unless you notify the Company otherwise before the order is settled.
6.13. You agree to comply with all applicable rules, regulations and laws
governing the trades made on the Site.
All transactions in your Account will be subject to the constitution, rules,
regulations, customs and usages of the exchange or market, and its clearing
house (if any), where such transactions are executed by the Company or its
agents, and of any applicable regulator, as well as the Company’s own trading
rules and policies.
6.14. Deposit of funds to your Account.
There are two ways to deposit funds to your Account: (i) via wire or bank transfer;
(ii) via credit card. Each of the deposit methods may be subject to a different

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processing fee, as provided in the Company’s deposit page, and may be altered
from time to time. The Company may require a minimum or maximum deposit
amount, which can be altered, in the Company’s sole discretion, from time to
time.
6.15. Settlement of your trades.
To execute a purchase order for securities, Company requires that your Account
contains available funds equal to or greater than the purchase price of the
securities plus any associated fees and commissions and that all payments for
the purchase be made without set-off, counterclaim or deduction. To execute sell
orders for securities, Company requires that your Account contains the securities
which are the subject of the sell order and that such securities are free and clear
of any liens, charges or encumbrances and are in good deliverable form or that it
contains the required collateral for the short sale (if applicable). To execute
orders for CFDs, Company requires that your account contains (and maintains)
the required margin applicable for such CFD order. You agree that any purchase
or sell order accepted (inadvertently or otherwise) by us without sufficient funds,
or securities or collateral or margin, respectively, in your Account, will be subject
to liquidation in the case of a purchase order, or buy-in in the case of a sell order,
at your expense.
In the event full funds are not available in your Account when a purchase order is
executed, you promise to pay the full amount due on or before the settlement
date for the purchase. In the event a sale order is executed and the securities
sold (or required collateral) are not in your Account, you promise to deliver all
securities sold (or the required collateral) on or before the settlement date. If
such funds or securities (or collateral) are not received on or before the
settlement date, we may liquidate your Account and you will be liable for any
resulting losses and all associated costs that we incur.
Settlement of purchases and sales will be at your risk. Accordingly, the Company
will not be liable to you if the Execution Broker or any other counterparty to an
order defaults. Applicable law may require the Company, the Execution Broker,
any other counterparty, a bank or a depositary to deduct tax from sale proceeds
before they are credited to your Account or remitted to you from your Account.
Company will effect any currency conversions necessary in order to settle a
purchase or sale at such rates, and in such manner, as it may, in its discretion,
determine.
6.16. You may place a market or limit order.
If you place a market order (whether during normal market hours or when the
market is closed), you agree to pay or receive the prevailing market price at the
time your market order is executed. You understand that the price you pay may
be significantly higher or lower than you had anticipated at the time you placed

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the market order. To avoid paying a higher price and possibly exceeding your
purchasing power, or selling it at a lower price than you would like, you may
choose to enter a limit order. You should note that all “piggyback” trades will be
executed as market orders and expire at the close of the relevant market on the
day the order is placed.
6.17. Your unexecuted limit orders.
Limit orders may not be executed at any particular time, or at all, if there is not
sufficient trading at or higher than the limit price you specify. Unless you
expressly notify Company otherwise in writing, any limit order in respect of
shares admitted to trading on an EEA regulated market which is not immediately
executed under prevailing market conditions will be made public immediately, so
that it is accessible to other market participants. Limit orders expire only when
canceled.
6.18. You may withdraw funds from your Account.
Any withdrawal of funds from your Account may be subject to a minimum
withdrawal amount requirement (as appears in the Company’s withdrawal page)
and may be subject to fees applied by third parties (such as your bank or credit
card provider). We may process your requested funds withdrawal, in total or in
part, by either a wire transfer or a credit card refund, according to our own
discretion. You will be able to withdraw all of your available funds only if you hold
no short positions and subject to the minimum withdrawal amount. The total
amount you receive may slightly differ from the amount you required due to
currency spot prices at the end of the trading day.

6.19. Traders using the Company website who are followed by other
traders (“Lead Traders”).
You may choose to manually follow one or more Lead Traders or instruct the
Company to automatically follow the trading activity of one or more Lead Traders,
subject to available funds and prior approval by us of certain types of trading. If
you do so, you agree to follow any selected Lead Traders (whether manually or
automatically) at your own risk. You understand that any actions or inactions by a
Lead Trader do not constitute a recommendation to buy, sell or hold a particular
security or asset, nor do they constitute a recommendation to pursue a particular
investment strategy. You understand that no Lead Trader has any legal
responsibility to you in connection with any trade you may, or may not, engage
in, and that acceptance of the terms and conditions of this Agreement constitutes
a waiver of any claim you may have against a Lead Trader in respect of
piggybacking. In addition, you agree to pay any Lead Traders you follow
(whether manually or automatically) commission at such rate(s) (if any) as are
applicable from time to time. The Company will not be liable to any Lead Trader if
you fail to make any such payment nor, under any circumstances, will the

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Company be liable to you for the acts or omissions of any Lead Trader you
follow.
6.20. Your portfolio and trading activity will be viewable by other Users of
the Company website.
At your full willingness to disclose your trading activities, if other users follow your
trades, you may charge them commission at such rates as are applicable from
time to time.
6.21. Subject to applicable law and regulations, you may engage in “short
sales” in an approved margin Account.
You agree to advise us prior to entering a sell order that is a "short sale" – that is,
the sale of a security you do not own. You agree that all short sale transactions
will be executed in a margin Account and are subject to initial and maintenance
margin requirements. You understand that, to facilitate a short sale, we must
borrow the security you sell short before you sell. If Company is or subsequently
becomes unable to borrow the security that you have sold short, you will be
subject to a "buy-in," meaning that Company may repurchase the security on the
open market to cover the short position, and you will be liable for any resulting
losses or costs. If a security is recalled by the lender of the security, Company
will attempt to re- borrow the security. If Company is unable to re-borrow the
security, Company may cover your short position by purchasing the security on
the open market, at the then current market price, without notice to you.
Company may cover a short position by such a purchase, at its discretion, if
Company anticipates an inability to borrow or re-borrow the security.
6.22. We may loan any of your securities held in a margin Account.
You authorize the Company to lend, as your agent, to ourselves or others any
securities held in your margin Account (if any) and neither we nor they shall have
any obligation to retain under our or their possession and control a similar
amount of such securities. In connection with such loans, we may receive and
retain certain benefits (including stock lending fees and interest on posted
collateral) to which you shall not be entitled. Such loans may limit, in whole or in
part, your ability to exercise any voting rights relating to the securities lent. Any
securities lent may be lent, in turn, by the borrower.
6.23. Corporate actions – you are responsible for knowing the rights and
terms attaching to all securities held in your Account.
This applies with respect to stock splits, reorganizations, mergers, take-over
offers (and similar), name and symbol changes, dividends, option symbol
changes and option deliverables, and any available insurance coverage,
including the limitations on such coverage. Certain securities may grant you
valuable rights that may expire unless you voluntarily take specific action. These
securities include bonds, convertible securities, warrants, options, rights to

International Finance Asia Ltd.

securities and securities subject to exchange or take-over offers or tenders. You
are responsible for knowing all expiration and redemption dates, and the other
circumstances under which rights associated with your securities may be
exercised, called, cancelled or modified. Company may, but is not obliged to,
provide information to you regarding any opportunity to take those voluntary
corporate actions referred to above and, if it does so, will do so only insofar as
reasonably practicable. If you wish the Company to take any such voluntary
action on your behalf, you must instruct the Company a reasonable time in
advance of the deadline for taking such action, and the Company will then use its
reasonable endeavours to implement your instructions. If the Company receives
no such instructions from you by that time, it will exercise, or refrain from
exercising, your rights at its discretion. In relation to a mandatory corporate event
(such as a dividend or interest payment or a stock split), the Company will use its
reasonable endeavours to process the event on your behalf.
If the Company has performed an action in your Account in relation to a
corporate event (whether in response to your instructions or in order to facilitate a
mandatory event), you will be notified.
6.24. Delisting.
If Company is notified that a security you hold in your Account is likely to be
delisted, the Company will promptly inform you, and then promptly sell the
security on your behalf at such time and price, and in such manner, as it
determines.
6.25. Your telephone conversations, email/chat communications with us
may be recorded/maintained by us with or without the use of an automatic
tone warning device.
Any recordings shall be and remain our sole property and will be accepted by
you as conclusive evidence of their content as recorded by us. You agree that we
may deliver copies of transcripts of such recordings to any court, regulatory or
government authority, including without limitation, in disputes which may arise
between you and us.

7. ADDITIONAL TRADING RULES FOR CFD TRADING
7.1. When effecting a transaction in CFDs, you shall not have any title or
ownership (beneficial or otherwise) in the underlying security.
As such, you shall not be entitled to any voting rights, rights to receive
notifications, dividend rights and/or other rights associated with ownership of a
security.
7.2. Underlying asset price.

International Finance Asia Ltd.

The execution price reported to you on the relevant confirmation of the buy or sell
order shall reflect the prices made available to us at the time of execution to
which our spreads shall be added or deducted, as the case may be. Such
execution prices shall not necessarily reflect the price of the underlying asset as
quoted on the relevant exchange in which the asset is traded and/or the prices
presented in charts and/or other market information made available by us. While
we take into account the underlying asset price, you acknowledge that we are
under no obligation to ensure that the bid-ask quotes it provides are within any
specific percentage of the underlying asset price. You undertake and agree not
to use the prices quoted by us for any purpose other than for your own trading
and you agree not to communicate our prices to any other person under any
circumstances.
You acknowledge that CFDs trading through the Company Website is
independent of any exchanges and therefore we are under no obligation to quote
a particular price or follow the trading rules consistent with such exchanges. You
further acknowledge that the triggering of your transaction is linked to the prices
we quote on our Website during trading hours and not the prices quoted on any
relevant exchanges.

7.3. You acknowledge that each transaction is made for a specified
number of units that constitute the underlying asset.
When trading CFDs, you may only complete transactions for the minimum
number of units set forth as the unit amount, and in multiples of such unit amount
up until the maximum amount permitted by us. You acknowledge and agree that
we may set the unit amount for each asset.
7.4. We may allow you to specify a closing price for a transaction
through a “stop loss” or “take profit” order.
Upon your offer and our acceptance of your “stop loss” or “take profit” order, you
hereby authorize us to close the transaction at the “stop loss” price or the “take
profit” price, as applicable, and as agreed in the order, without further instruction
from or notification to you. We may close the transaction when the price quoted
by us equals or exceeds the price accepted by us for such order.
7.5. We reserve the right to void from the outset any transaction
containing or based on any Indisputable Error or a price, which is
subsequently determined to be unrepresentative of the actual market
valuation of an asset.

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In the absence of our fraud or willful default, we will not be liable to you for any
loss, cost, claim, demand or expense following any Indisputable Error or such
erroneous price. For such purpose, an “Indisputable Error” means any error that
we reasonably believe to be obvious and clear, including without limitation, offers
to execute transactions for exaggerated volumes or at manifestly incorrect
market price quotes or prices at a clear loss.
Without derogating from the above, if, prior to the acceptance of your offer to
open or close a transaction, we become aware of such Indisputable Error or
erroneous price, we reserve the right to reject your offer outright. If we have,
nevertheless, already opened or closed a transaction prior to becoming aware of
such circumstances, we may, upon our reasonable discretion, either treat such a
transaction as void from the outset or close it at our then prevailing price.
7.6. Force Majeure Events.
We may, in our reasonable opinion, determine that a Force Majeure Event exists.
A Force Majeure Event will include, but is not limited to, the following: (i) any act,
event or occurrence (including without limitation any strike, riot or civil unrest, act
of terrorism, war, industrial action, acts and regulations of any governmental or
supra national bodies or authorities) that, in our opinion, prevents us from
maintaining an orderly market in the CFDs offered by us; (ii) the suspension or
closure of any exchange or the nationalization, government sequestration,
abandonment or failure of any instrument on which we base, or to which we in
any way relate, our quote, or the imposition of limits or special or unusual terms
on the trading in any such market or on any such event; (iii) the occurrence of an
excessive movement in the level of any transaction and/or exchange or our
anticipation (acting reasonably) of the occurrence of such a movement; (iv) any
breakdown or failure of transmission, communication or computer facilities,
interruption of power supply, or electronic or communications equipment failure;
or (v) the failure of any relevant supplier, financial institution intermediate broker,
agent or principal of ours, custodian, sub-custodian, dealer, exchange, clearing
house or regulatory or self-regulatory organization, for any reason, to perform its
obligations.
If we determine that a Force Majeure Event exists, we may without notice and at
any time, acting reasonably, take one or more of the following steps: (a) alter
your margin requirements; which may result in you being required to provide
additional margin; (b) close all or any of your open transactions at such closing
prices as we reasonably believe to be appropriate; (c) suspend or modify the
application of all or part of this Customer Agreement to the extent that the Force
Majeure Event makes it impossible or impracticable for us to comply thereto; (d)
alter the trading hours for a particular transaction; or (e) void all open affected
transactions. You agree that we will not be liable in any way to you or to any

International Finance Asia Ltd.

other person in the event of a Force Majeure Event, nor for our actions pursuant
to this section if we decide to take such action.

8. ADDITIONAL TRADING RULES FOR LEAD TRADERS USING THE COMPANY
WEBSITE
8.1. You agree to share your Company portfolio with other Users.
You agree to make your trades and investment strategy with respect to the
securities and assets traded using the Company website as transparent as
possible. Accordingly, you agree to refrain from trading in or beneficially owning
the same securities in your Company portfolio outside of the Company website.
8.2. You agree to let other Users “follow” your trading activities
executed through the Company website and to comply with anti-market
manipulation laws.
You must make all such trades based on your own investment strategy for the
relevant security and without the intent to manipulate the market for any such
security. You may have numerous Users manually or automatically following your
trading activity executed through the Company website, and, in such trading, you
must therefore comply with all applicable laws and regulations prohibiting market
manipulation. Involvement in market manipulation or securities fraud is a breach
of this Agreement and Company reserves the right to suspend or shut down any
account suspected of involvement in market manipulation or securities fraud and
will in such circumstances share information about you and your use of your
Account with relevant authorities.
8.3. No trading on others’ behalf.
You are prohibited from trading in the name of, or as agent of, any third party, or,
other than as contemplated by this Agreement, receiving compensation for
trading from other Users.
8.4. You are subject to additional rules on the content of your postings
on the Site.
Since certain comments and statements made by you on the Site may influence
other Users to engage or refrain from engaging in certain trades, your statements
may be construed as investment advice, which is heavily regulated. In order to
prevent the characterization of any of your statements as the provision of
investment advice, you undertake that you will not comment on any specific
securities or trades and will therefore limit your statements to your overall
investment strategy or your portfolio as a whole. You acknowledge that your
receipt of remuneration from other Users will be subject to additional regulatory
requirements in certain jurisdictions and that it is your responsibility to ensure
compliance with same. Please also refer to the Forums section of the Company

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Website Terms and Conditions for further rules in relation to the content of your
postings on the Site.
8.5. You agree to invest only in the securities of companies with which
you have no relationship.
In order to avoid conflicts of interest and possible breach of insider trading rules,
you agree to limit your trades to securities of companies with which you, any
immediate family member and any affiliate have no professional, employment,
business or other relationship.
8.6. You agree to act independently of other Lead Traders or Users.
You agree to not join with other Lead Traders or Users in order to develop a joint
investment strategy for trading on the Site.

9. SECURITY INTEREST AND SET OFF
9.1. Security interest granted by you.
You grant to the Company a first fixed charge on, a general lien over, and a right
of set-off in respect of, all securities and other assets of any kind (including liquid
funds) held by, delivered or paid (or due to be delivered or paid) to the Company
for your account. You appoint the Company as your agent to take any action
necessary to perfect this security.
If you fail to comply with any of the provisions of this Agreement, the security will
be enforceable by the Company. If you fail to comply as stated, the Company
may accordingly, without notice to you, cancel, close out or reverse any
transaction it has entered into for you, and sell or otherwise dispose of any
assets held by it for you, at whatever price and in whatever manner it, acting in
good faith, sees fit (with no responsibility for any diminution in price). In addition,
it may enter into any other transaction, or do (or not do) anything, which would
(or is intended to) have the effect of reducing or eliminating its liability under any
transaction it has entered into for you. The Company will not be liable to you for
its choice of assets sold or otherwise disposed of. The Company will apply the
proceeds of disposal (net of costs) in or towards your liabilities to it and will pay
you the balance. If the proceeds do not discharge the whole of your liabilities to
the Company, you will remain liable to the Company for the balance.
9.2. Set off.
Company may set off any indebtedness or other liability it has to you against (or
towards) any indebtedness or other liability you have to the Company (whether or
not expressed in the same currency). If it exercises its right of set off, the
Company may effect such currency conversions, and at such rates and in such

International Finance Asia Ltd.

manner, as it may, in its discretion, determine. Company's rights of set off against
you do not affect any rights of set off you may have against the Company at law.
9.3. Company’s remedies cumulative.
The remedies available to the Company under this section are additional to any
other remedies that may be available to it under this Agreement or at law.

10. DATA PROTECTION
We take the protection of your personal data seriously. Please see our Privacy Policy,
for further information.

11. TAX
11.1. Your tax.
You will be responsible for all aspects of your tax affairs. It will accordingly be
your responsibility to ensure that your tax affairs are in order. You should
remember that individual circumstances vary and that they can affect tax liability.
You should also remember that Labuan tax law may differ from that of your own
country of tax-residence or tax-domicile.
11.2. Sales taxes charged by Lead Traders.
Lead Traders may be obliged by law to charge value added tax or a similar sales
tax on any invoices they issue to "followers". It will be the responsibility of the
Lead Trader charging such a tax to account for it to the relevant taxation
authority.
11.3. Withholding taxes.
We may deduct or withhold all forms of tax (whether of Labuan or elsewhere)
from any payment, if obliged to do so under the applicable law or regulations. In
accounting for tax or making deductions or withholding of tax, we may estimate
the amounts concerned. Any excess of such estimated amount over the final
confirmed liability will be credited or sent to you as quickly as reasonably
practicable.

12. FOREIGN ACCOUNT TAX COMPLIANCE ACT (“FATCA”)
12.1. You acknowledge that, in order for us to comply with the provisions of
FATCA or any resulting intergovernmental agreement, and avoid the imposition
of any U.S. federal withholding tax imposed or collected pursuant to Sections
1471 through 1474 of the United States Internal Revenue Code of 1986, as

International Finance Asia Ltd.

amended (the “U.S. Code”), any current or future regulations or official
interpretations thereof, any agreement entered into pursuant to Section 1471(b)
of the U.S. Code, or any fiscal or regulatory legislation, rules or practices adopted
pursuant to any intergovernmental agreement entered into in connection with the
implementation of such Sections of the U.S. Code (a “FATCA Withholding
Tax”), you may, from time to time and to the extent provided under FATCA, be
required to:
a. provide further information and/or documentation to the IRS or other
relevant competent authority and/or us, which information and/or
documentation may include, but is not limited to, information and/or
documentation relating to or concerning you, your
b. direct and indirect beneficial owners (if any), and any such beneficial
owner’s identity, residence (or jurisdiction of formation) and income tax
status; and
c. certify to us your compliance or deemed compliance with, or exemption
from, the requirements under this Section 11.

12.2. You agree that you will provide such information and/or documentation
concerning you and your direct and indirect beneficial owners (if any), as and
when requested by us, as we, in our sole discretion, determine is necessary or
advisable for us or any of our Affiliates to comply with obligations under FATCA.
12.3. You acknowledge that (i) if you do not timely provide any such requested
certification, information and/or documentation, as applicable, or (ii) if such
certification, information and/or documentation is incorrect or incomplete, we
shall deduct and pay from your Account such FATCA Withholding Tax as may be
required under FATCA, and we may deduct or retain from your Account amounts
sufficient to indemnify and hold harmless Company, its affiliates and its agents
from and against any and all withholding taxes, interest, penalties and other
losses or liabilities suffered by any such person on account of your failure to duly
provide any requested certification, information and/or documentation or resulting
from such person’s reliance on any such certification, information and/or
documentation provided by you.
12.4. You acknowledge and agree that you shall have no claim against us, our
affiliates or our agents for any damages or liabilities attributable to determinations
made by us pursuant to this Section 11.

13. CONFLICTS OF INTEREST
13.1. Conflicts of interest policy.

International Finance Asia Ltd.

Company has taken reasonable steps to identify conflicts of interest that exist, or
may exist, between the Company and Users or between one User and another.
The Company has reviewed the organizational and administrative arrangements
in place to manage any such conflicts (or potential conflicts) and considers that
they are sufficient to ensure, with reasonable confidence, that the risk of damage
to Users’ interests will be prevented. Please note that these statements
concerning conflicts have been prepared for compliance purposes only and are
not intended to create any legal rights.
13.2. Organizational and administrative arrangements.
We maintain and operate effective organizational and administrative
arrangements with a view to taking all adequate measures to recognize actual
and potential conflicts of interest and to avoid an adverse effect on your interests
arising out of any actual conflicts of interest. Further information as to how we
manage conflicts of interest (actual or potential) can be found in our global
conflicts of interest policy.

14. CONFLICTS OF INTEREST
14.1. Governing law, exclusive jurisdiction and venue.
This Agreement is governed by and will be construed in accordance with the
laws of Labuan. You agree that Labuan Financial Securities Authority has and
will have exclusive jurisdiction over, and that such Court will be the exclusive
venue for, any dispute, litigation or claim that may arise or may be asserted
regarding this Agreement or your use of the Website.
14.2. Electronic copies.
The electronically stored copy of your signature, of any written instructions or
authorizations, of the Account Application Form and of this Agreement are
considered to be the true, complete, valid, authentic and enforceable record,
admissible in judicial, administrative or arbitration proceedings to the same extent
as if the record was originally generated and maintained in printed form. You
agree to not contest the admissibility or enforceability of Company’s electronically
stored copy of your signature and such documents in any proceeding between
you and Company.
14.3. Dormant Account.
If no activity occurs in your Account within the time period specified by applicable
law, your Account (including any assets held in it) may be transferred or forfeited
in accordance with applicable law.

International Finance Asia Ltd.

14.4. Assignment.
You may not assign or transfer your rights or duties under this Agreement without
first obtaining our prior written consent. We may assign and transfer our rights
and duties under this Agreement and may transfer your Account and this
Agreement to our successors any affiliate or any other entity without prior notice
to you. No such assignment or transfer by us will affect our existing obligations to
you (if any).
14.5. Applicable laws and regulations.
You acknowledge that this Agreement and all orders and transactions executed
in your Account will be subject to all applicable laws and regulations, and the
constitution, rules, regulations, customs, usages, rulings and interpretations of
the exchange or market and its clearing house (if any) where such orders and
transactions are executed.
14.6. Headings.
The headings in this Agreement are for descriptive purposes only and shall not
be deemed to modify or qualify any of the rights or obligations set out in this
Agreement.
14.7. Entire agreement and severability.
This Agreement contains the entire agreement between the parties with respect
to the subject matter hereof. If any provision of this Agreement shall be held to be
invalid or unenforceable by any court, or regulatory or self-regulating agency or
body, such provision shall be deemed modified, or if necessary, rescinded, in
order to comply with the ruling of the relevant court, or regulatory or self-
regulatory agency or body. The validity of the remaining provisions shall not be
affected thereby, and this Agreement shall be carried out as if such invalid or
unenforceable provision was not contained herein. You acknowledge that you
have entered into this Agreement and will enter into all transactions
contemplated by it in consideration of and in reliance upon the understanding
that this Agreement and all such transactions constitute a single business and
contractual relationship and have been made in consideration of each other.
Accordingly, in addition to any of the other rights and obligations set forth in this
Agreement; (i) you agree to perform all of your obligations in respect of each
such transaction; and (ii) payments, deliveries and other transfers made by us in
respect of any such transaction shall be deemed to have been made in
consideration of payments, deliveries and other transfers in respect of any other
such transaction.
14.8. Waiver by Company.
If you breach this Agreement and we take no action against you, we will still be
entitled to use and pursue our rights and remedies in any other situation where
you breach this Agreement. Any failure by us to insist at any time upon
compliance with this Agreement shall not constitute or be considered a waiver by

International Finance Asia Ltd.

us of any of our rights or remedies. No waiver by us of any provision of this
Agreement will be effective unless it is given by written notice by us to you.
14.9. Termination.
You may terminate this Agreement or your Account at any time upon written
notice to us, after paying any outstanding obligations you owe to us. You shall
remain responsible for all outstanding obligations initiated or authorized by you,
including without limitation, any transactions, debts and interest as provided
under this Agreement, whether arising before or after termination of this
Agreement. Without prejudice to Section 3.1(f) (termination of Account without
notice), we may terminate this Agreement or your Account at any time
by written notice to you and for any or no reason in our sole and absolute
discretion. The terms and conditions of this Agreement will survive termination of
your Account and will continue to apply to any remaining disputes or other
matters arising from our relationship.

14.10. Successors.
This Agreement will pass to the benefit of Company and its successors and
assigns permitted by Section 13.4. In addition, you hereby agree that this
Agreement and all the terms hereof, will be binding on your heirs, executors,
administrators, personal representatives and any assigns permitted by the
Company.
14.11. Agency – you appoint Company as your agent.
Without prejudice to Section 8 (security interest granted by you), you hereby
irrevocably appoint Company as your agent, with full power to act as such to the
fullest extent permitted by law, for the purpose of: (i) properly carrying out the
provisions of this Agreement; and (ii) taking any action and executing any
instrument that the Company reasonably and in good faith deems necessary or
advisable to accomplish the purposes of this Agreement.
14.12. No third party rights.
Notwithstanding any other provision of this Agreement, no third party will have
any right to enforce any of the provisions of this Agreement.
14.13. Language of communications.
All communications under or in connection with this Agreement will be in the
English language.
14.14. Recording of telephone calls.
Company may record telephone calls between it and you.

International Finance Asia Ltd.

14.15. Written notices by Company.
Where this Agreement provides for written notice to be given by Company, we
may give it by email or post it to your last email or postal address known to us.