Policies

If you are unsure if this form of investing suits you should seek advice from an authorized financial adviser. We are not currently authorised to give investment advice of any kind and therefore will not provide advice to you. However, from time to time, we may give you factual information in relation to an underlying market or a transaction which you have inquired about.

There are signs of suspicious activity that suggest money laundering. These are commonly referred to as “red flags.” If a red flag is detected, additional due diligence will be performed before proceeding with the transaction. If a reasonable explanation is not determined, the suspicious activity shall be reported to the AML Compliance Committee.

Examples of red flags are:

The customer exhibits unusual concern regarding the firm’s compliance with government reporting requirements and the firm’s AML policies, particularly concerning his/her identity, type of business, and assets, reluctant or refuses to reveal any information concerning business activities, or furnishes unusual or suspect identification or business documents.

The customer wishes to engage in transactions that lack business sense or apparent investment strategy or are inconsistent with the customer’s stated business strategy.

The information provided by the customer that identifies a legitimate source for funds is false, misleading, or substantially incorrect.

Upon request, the customer refuses to identify or fails to indicate any legitimate source for his/her funds and other assets.

The customer (or a person publicly associated with the customer) has a questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations.

The customer exhibits a lack of concern regarding risks, commissions, or other transaction costs.

The customer appears to be acting as an agent for an undisclosed principle but declines or is reluctant without legitimate commercial reasons to provide information or is otherwise evasive regarding that person or entity.

The customer has difficulty describing the nature of his/her business or lacks general knowledge of his/her industry.

The customer attempts to make frequent or large deposits of currency, insists on dealing only in cash equivalents, or asks for exemptions from the firm’s policies relating to the deposit of cash and cash equivalents.

For no apparent reason, the customer has multiple accounts under a single name or multiple names, with many inter-account or third-party transfers.

The customer’s account has unexplained or sudden extensive activity, especially in accounts that had little or no previous activity.

The customer’s account has many wire transfers to unrelated third parties inconsistent with the customer’s legitimate business purpose.

The customer’s account has wire transfers that have no apparent business purpose to or from a country identified as money laundering risk or a bank secrecy haven.

The customer’s account indicates large or frequent wire transfers, immediately withdrawn by check or debit card without any apparent business purpose.

The customer makes a funds deposit followed by an immediate request that the money is wired out or transferred to a third party, or another firm, without any apparent business purpose.

The customer makes a fund deposit to purchase a long-term investment followed shortly thereafter by a request to liquidate the position and transfer the proceeds out of the account.

The customer requests that a transaction be processed in such a manner to avoid the firm’s normal documentation requirements.

Know your customer – the basis for recognizing suspicions

A suspicious transaction will often be inconsistent with a customer’s known, legitimate business or personal activities or with the normal business for that type of customer. Therefore, the first key to recognition is knowing enough about the customer’s business to recognize that a transaction, or series of transactions, is unusual.

Questions you must consider when determining whether an established customer’s transaction might be suspicious are:

Is the size of the transaction consistent with the normal activities of the customer?

Is the transaction rationale in the context of the customer’s business or personal activities?

Has the pattern of the transaction conducted by the customer changed?

Suspicious scenarios

Issues that should lead you to have cause for suspicion would include:

Clients who are reluctant to provide proof of identity;

Clients who place undue reliance on an introducer (they may be hiding behind the introducer to avoid giving you a true picture of their identity or business);

Requests for cash-related business, for example, questions about whether investments can be made in cash, suggestions that funds might be available in cash for investment.

Where the source of funds for investment is unclear.

Where the magnitude of the available funds appears inconsistent with the client’s other circumstances (i.e. the source of wealth is unclear). An example might be students or young people with large amounts to invest.

Where the transaction doesn’t appear rational in the context of the customer’s business or personal activities. Particular care should be taken in this area if the client changes their method of dealing with you without a reasonable explanation.

Where the pattern of transactions changes.

Where a client who is undertaking international transactions does not appear to have any good reason to be conducting business with the countries involved (e.g. why do they hold monies in the particular country that the funds are going to or from? Do their circumstances suggest that it would be reasonable for them to hold funds in such countries?).

Clients who are unwilling to provide you with normal personal or financial information, for no apparent or rational reason. (care should be taken not to include all distance relationships as suspicious, because most will be for genuine reasons. Suspicions will ordinarily be based upon cumulative as opposed to standing alone issues)

A money launderer is likely to provide persuasive arguments about the reasons for their transactions. Those should be questioned to decide whether a transaction is suspicious.

Reporting a Suspicion

Where, for whatever reason, we suspect that a client or anybody for whom they are acting may be undertaking (or attempting to undertake) a transaction involving the proceeds of any crime it

must be reported as soon as practicably possible and in writing.

Internal reports must be made regardless of whether any business was or is intended to be written.

Investigation

Upon notification to the AML Compliance Committee, an investigation will be commenced to determine if a report should be made to the appropriate law enforcement or regulatory agencies.

The investigation will include but not necessarily be limited to a review of all available information such as payment history, birth dates, and address. If the results of the investigation warrant, a recommendation will be made to the AML Compliance Committee to file the SAR with the appropriate law enforcement or regulatory agency. The AML Compliance Committee is responsible for any notice or filing with law enforcement or regulatory agency.

Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. Under no circumstances

shall any officer, employee, or appointed agent disclose or discuss any AML concern, investigation, notice, or SAR filing with the person or person subject of such, or any other person including members of the officer’s, employee’s or appointed agent’s family?

Freezing of Accounts

Where we know that the funds in an account derive from criminal activity, or that they arise from fraudulent instructions, the account must be frozen. Where it is believed that the account holder may be involved in the fraudulent activity that is being reported, then the account may need to be frozen.

Transaction-based monitoring will occur within the appropriate business units of Seven Capitals Foreign Brokerage Limited Markets Limited. Monitoring of specific transactions will include but is not limited to transactions aggregating $5,000 or more and those concerning which Seven Capitals Foreign Brokerage Limited Market Limited has a reason to suspect suspicious activity. All reports will be documented.

Current bank statements, or credit/debit card statements issued by a regulated financial sector firm (but not ones printed off the internet and not less than 3 months old)

Utility bills (not including mobile phone bills, not ones printed off the internet and not less than 3 months old)

For increased risk level products, in addition to obtaining the standard information detailed above, the following know your customer information should be obtained and recorded:

Employment and income details Source of wealth (i.e. source of the funds being used in the transaction)

Verification of the information obtained must be based on reliable and independent sources – which might either be documents produced by the customer, or electronically by the firm, or by a combination of both. Where business is conducted face-to-face, firms should see originals of any documents involved in the verification.

If documentary evidence of an individual’s identity is to provide a high level of confidence, it will typically have been issued by a government department or agency, or by a court, because there is a greater likelihood that the authorities must have checked the existence and characteristics of the persons concerned. In cases where such documentary evidence of identity may not be available to an individual, other evidence of identity may give the firm reasonable confidence in the customer’s identity, although the firm should weigh these against the risks involved.

If the identity is to be verified from documents, this should be based on: a government-issued document that incorporates:

The customer’s full name, and their residential address, Photographic Government Issued Identity Documents, or Valid passport National Identity card alternatively, this can be done by a non-photographic government-issued document which incorporates the customer’s full name, supported by a second document, which incorporates: customer’s full name, and their residential address.

The standard identification requirement for customers who are private individuals is generally governed by the circumstances relating to the customer and the product type that is being dealt in, i.e. the level of risk attributed to the product whether it is reduced risk, intermediate-risk, or an increased risk product. Taking that into account for reduced risk and intermediate-risk products the following pieces of information are required as a standard for identification purposes:

Full Name

Residential Address

When a transaction takes place the source of funds, i.e. how the payment is to be made, from where and by who must always be ascertained and recorded in the client file (this would usually be achieved through retaining a copy of the cheque or direct debit mandate).

When a business relationship is formed, to establish what might constitute normal activity later in the relationship, the company must ascertain the nature of the business a the client expects to conduct.

Once an ongoing business relationship has been established, any regular business undertaken for that customer can be assessed against the expected pattern of activity of the customer. Any unexplained activity can then be examined to determine whether there is a suspicion of money laundering or terrorist financing.

Information regarding a client’s income, occupation, source of wealth, trading habits, and the economic purpose of any transaction is typically gathered as part of the provision of advice. At the start of the relationship personal information is also obtained such as nationality, date of birth, and residential address. These pieces of information should also be considered concerning the risk of financial crime (including AML and CTF). For high-risk transactions, it might be appropriate to seek verification of the information the client has provided.

Seven Capitals Foreign Brokerage Limited Market Limited will provide notice to customers that it is requesting information from them to verify their identities, as required by applicable law.

Seven Capitals Foreign Brokerage Limited Market Limited has adopted a Customer Identification Program (CIP). We will provide notice that they will seek identification information, collect certain minimum customer identification information from each customer, record such information, and the verification methods and results.

The level of due diligence required when considering anti-money laundering procedures within the firm should take a risk-based approach. This means the number of resources spent in conducting due diligence in any one relationship that is the subject risk should be in proportion to the magnitude of the risk that is posed by that relationship.

These can be broken down into the following areas:

Customer Risk

Different customer profiles have different levels of risks attached to them. A basic Know your Customer (KYC) check can establish the risk posed by a customer.

For example, near-retired individuals making small, regular contributions to a savings account in line with their financial details pose less of a risk than middle-aged individuals making ad-hoc payments of ever-changing sizes into a savings account that does not fit into the profile of the customers’ standing financial data. The intensity of the due diligence conducted on the latter would be higher than that carried out on the former as the potential threat of money laundering in the second case would be perceived as being greater. Corporate structures can be used as examples of customers that could carry a higher risk profile than the one just seen, as these can be used by criminals to introduce layers within transactions to hide the source of the funds, and like that, clients can be categorized into different risk bands.

Product Risk

This is the risk posed by the product or service itself. The product risk is driven by its functionality as a money-laundering tool. The Joint Money Laundering Steering Group has categorized the products with which firms typically deal into three risk bands – reduced, intermediate and increased. Typically, pure protection contracts are categorized as reduced risk and investments in unit trusts as increased risk. Additionally, a factor that will contribute to the classification of the risk category is the sales process associated with the product. If the transaction in the product takes place on an advisory basis as a result of a KYC, this will carry less risk than an execution-only transaction, whereby you know significantly less about the customer.

Country Risk

The geographic location of the client or origin of the business activity has a risk associated with it, this stems from the fact that countries around the globe have different levels of risk attached to them.

A firm would determine the extent of their due diligence measure required initially and on an ongoing basis using the above four risk areas.

Terrorist financing is the process of legitimate businesses and individuals that may choose to provide funding to resource terrorist activities or organizations for ideological, political, or other reasons. Firms must therefore ensure that:

customers are not terrorist organizations themselves; and

they are not providing the means through which terrorist organizations are being funded.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

Money laundering is the process by which criminally obtained money or other assets (criminal property) are exchanged for “clean” money or other assets with no obvious link to their criminal origins. Criminal property may take any form, including money or money’s worth, securities, tangible property, and intangible property. It also covers money, which is used to fund terrorism.

Money laundering activity includes:

Acquiring, using, or possessing criminal property

Handling the proceeds of crimes such as theft, fraud, and tax evasion

Being knowingly involved in any way with criminal or terrorist property

Entering arrangements to facilitate laundering criminal or terrorist property

Investing the proceeds of crimes in other financial products

Investing the proceeds of crimes through the acquisition of property/assets

Transferring criminal property.

There is no single stage of money laundering; methods can range from the purchase and resale of luxury items such as a car or jewelry to passing money through a complex web of legitimate operations. Usually, the starting point will be cash, but it is important to appreciate that money laundering is defined in terms of criminal property. This can be property in any conceivable legal form, whether money, rights, real estate, or any other benefits, if you know or suspect that it was obtained either directly or indirectly, as a result of criminal activity and you do not speak up then you too are taking a part in the process.

The money laundering process follows three stages:

Placement: Disposal of the initial proceeds derived from illegal activity e.g. into a bank account.

Layering: The money is moved through the system in a series of financial transactions to disguise the origin of the cash to give it the appearance of legitimacy.

Integration: Criminals are free to use the money as they choose once it has been removed from the system as apparently “clean” funds. No financial sector business is immune from the activities of criminals and firms should consider the money laundering risks posed by the products and services they offer.

It is the policy of Seven Capitals Foreign Brokerage Limited Market Limited to actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. Seven Capitals Market Limited is committed to AML compliance following applicable law and requires its officers, employees, and appointed producers to adhere to these standards in preventing the use of its products and services for money laundering purposes.

For the policy, money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets.

2.1 All of the Company’s employees are required to read and acknowledge the Anti- Money Laundering Manual of the Company and shall at all times act under the ‘Key Principles’ set out therein.

(a) Take appropriate steps to protect the Company and its domain from any activities which involve money laundering and terrorist financing.

(b) The Company must maintain and implement written policies and procedures concerning combating money laundering a system of internal controls to ensure ongoing compliance with applicable laws which shall be reviewed and monitored by a designated person and to take appropriate action once suspicious activity is detected through the reporting of such transactions in line with the guidelines set out by Global Anti – Money Laundering regulations.

(c) Comply with applicable anti-money laundering and terrorist financing laws and regulations as established by the Global Anti- Money Laundering guidelines.

(d) All business units of the Company shall follow the AML policies and procedures.

(e) Report all identified suspicious activities to the extent that it can do so under all applicable foreign and domestic laws.

(f) Compliance with the Company’s AML policies will be monitored through a combination of internal audit and regulatory reviews of compliance with relevant anti-money laundering legislation and/or regulations.

(g) Retaining all the customer-related documents for a period specified as per the Financial Services Authority St. Vincent.

(h) The Company does not offer services of opening anonymous accounts.

(i) Full cooperation with law enforcement and regulatory agencies to the extent that it can do so under all applicable laws.

(j) Train staff on Know Your Customer and Anti-Money Laundering policies and new AML laws and regulations.​

(k) The AML Compliance Committee is responsible for initiating Suspicious Activity Reports (“SARs”) or other required reporting to the appropriate law enforcement or regulatory agencies.

Any contacts by law enforcement or regulatory agencies related to the Policy shall be directed to the AML Compliance Committee.

The committee shall

Receive internal reports of (suspicions of) money laundering

Investigate reports of suspicious events

Make reports of relevant suspicious events to the relevant authorities

Ensure the adequacy of arrangements made for the awareness and training of staff and advisers

Report at least annually to the firm’s governing body on the operation and effectiveness of the firm’s systems and controls.

Monitor the day-to-day operation of anti-money laundering policies concerning: the development of new products; the taking on of new customers; and changes in the firm’s business profile.

1.1. Seven Capitals Foreign Brokerage Limited: Registered Addresses- Headquarter: Level-6 Ken Lee Building, 20 Edith Cavell Street, Port Luis 11302, Mauritius. Marketing Office: 403, API World Tower, Sheikh Zayed Road, World Trade Center 1, Dubai UAE. P.O Box-47425 We are authorized and regulated by the Financial Services Commission as An Investment Broker in Global Business with the License/registration No. GB 21026349.

The Company is authorized as a Business Company under the Business Companies (Amendment and Consolidation) Act, in Dubai (herein the “Law”).

1.2. The objects of the Company are all subject matters not forbidden by Business Companies (Amendment and Consolidation) Act in Dubai (herein the “Law”), in particular, but not exclusively all commercial, financial, lending, borrowing, trading, service activities and the participation in other enterprises as well as to provide brokerage, training and managed account services in currencies, commodities, indexes, CFDs and leveraged financial instruments.

1.3. The Company is committed to combating money laundering and for this reason, it has appointed a dedicated Anti-Money Laundering Compliance Officer (the “AMLCO”) who is accountable to the Board of Directors and Senior Management of the Company.

The AMLCO is further responsible for the training of employees concerning the Anti-Money Laundering Law and any amendments thereof as well as for the preparation of the internal procedures of the Company.

Seven Capitals Foreign Brokerage Limited must keep and regularly update a written record of the kinds of ancillary services or activities carried out by or on behalf of the firm in which a conflict of interest entailing a material risk of damage to the interests of one or more clients has arisen or in case of an ongoing service or activity, may arise. These records will be for a minimum period from the date of creation and are maintained on an ongoing basis by the Compliance Officer.

Seven Capitals retains the right to limit the amount and/or total number of open positions that Client may acquire or maintain at Seven Capitals. Seven Capitals reserves the right to refuse to accept any order. Seven Capitals does not guarantee any or all profits resulting from trading entered into the system(s) of Seven Capitals, including but not limited to, profits realized during abnormal market conditions, extraordinary events or system malfunctions.
Seven Capitals shall not be responsible for any loss or damage caused, directly or indirectly, by any events, actions or omissions beyond the control of Seven Capitals including, without limitation, loss or damage resulting, directly or indirectly, from government restrictions, war, strikes, labor , Disruptions and terrorist acts or any other force majeure events. Seven Capitals shall not be liable for damages, including lost profits or trading losses caused by delays or inaccuracies in pricing or the transmission of orders or information due to a breakdown in or failure of any transmission or communication facilities, unauthorized access, theft or systems failures. Client understands Seven Capitals is authorized to reclaim any trading profits Client obtains through the trading of delayed or inaccurate pricing.

The management oversight and determination of appropriate remuneration of members of staff is conducted by Seven Capitals Foreign Brokerage Limited’s Senior Management. Remuneration is based on the overall results of the firm and is not based on the success of any particular transaction.

Remuneration for customer facing and sales staff should be partly based on business production. Staff are subject to appropriate management and supervision to ensure that Seven Capitals Foreign Brokerage Limited is able to demonstrate that it has appropriate and effective arrangements in place to ensure that conflicts of interest are properly managed.

Seven Capitals Foreign Brokerage Limited maintains appropriate policies in its internal policies detailing the potential use of “Insider Lists” and “Information Barriers” often known as Chinese Walls so as to limit or withhold the use of information that is price-sensitive, confidential, and could give rise to market abuse, restrictions on dealing, conflicts of interest, or any other improper or unethical activities. The Compliance Officer monitors along with the relevant business line managers the effectiveness of any Information Barriers that may be required. In certain circumstances staff may need to be taken “across the wall”, should this be required, the Compliance Officer must be notified and a record made thereof.

There are several distinct tasks within the investment management business that could lead to potential conflicts of interest that are mitigated by them being segregated from the individuals directly involved in the task.

In certain cases, Seven Capitals Foreign Brokerage Limited may disclose the general nature and/or source of potential or actual conflicts to its client in writing before undertaking business on its behalf so that the client can decide whether or not to accept these potential conflicts. If it is not possible to avoid or manage a conflict of interest, Seven Capitals Foreign Brokerage Limited may have no choice but to decline to provide the service requested.

Where Seven Capitals Foreign Brokerage Limited aggregates the orders of clients, it must ensure that this does not work to the overall disadvantage of any client whose order is to be aggregated. Seven Capitals Foreign Brokerage Limited makes reference to this within the Order Execution Policy.

No employee may engage in any additional occupation without the consent of the Company. In certain circumstances, consent may be withheld. Employees must not accept personal fiduciary appointments (such as trusteeships, Director Appointments or executorships other than those resulting from family relationships) without first obtaining written approval from the COO or the Compliance Officer.

Employees may only undertake personal investment activities that do not breach applicable law or regulation, do not unduly distract from their employment responsibilities and do not create an unacceptable risk to the company’s reputation. Transactions should also be free

from business and ethical conflicts of interest. Employees must never misuse proprietary or client confidential information in their personal dealings and must ensure that clients are never disadvantaged as a result of their dealings.

Seven Capitals Foreign Brokerage Limited’s Personal Account Dealing Policy has been established to ensure that personal account dealing by members of staff comply with this policy. This includes a requirement for pre-deal approval from the Compliance Officer. Such permission is normally only valid for 24 hours.

Seven Capitals Foreign Brokerage Limited’s Personal Account Dealing policy is set out in the firms’ Compliance Manual.

Seven Capitals Foreign Brokerage Limited maintains business relationships with third parties who may remunerate in the form of management and performance fees, which can constitute monetary or non-monetary benefits thereby impairing Seven Capitals Foreign Brokerage Limited’s fiduciary duties to the client. Such payments are classified as inducements. Further details are included in the Compliance Manual.

Gifts and hospitality could lead to potential conflicts of interest. No employee may accept from or give to, any person any gift or other benefit that cannot properly be regarded justifiable in all circumstances. Policies and procedures have been implemented to ensure that staff and their connected persons do not offer or accept gifts or inducements which may give the perception that decisions or actions are not impartial.

These policies are set out in the Compliance Manual. All employees must act with the highest standards of integrity to avoid any allegations of conflicts of interest.

A record is kept by the Compliance Officer of any gifts or hospitality received or given. Where an invitation to a hospitality event could be construed as being a business inducement, it must be declined and the Compliance Officer informed.

Seven Capitals Foreign Brokerage Limited has identified specific potential conflicts of interests, which may arise in relation to its activities. The general nature and/or source of these conflicts will be disclosed to clients before undertaking business in sufficient detail to enable the client to make an informed decision about the service in the context in which the conflict has arisen. For each potential situation, Seven Capitals Foreign Brokerage Limited has analysed whether or not the risk is actual or potential for one or more of its clients.

It is not always possible to prevent actual conflicts of interest from arising. In that case Seven Capitals Foreign Brokerage Limited will try to manage the conflicts of interests by segregating duties where possible or by establishing Chinese Walls. In certain circumstances, Seven Capitals Foreign Brokerage Limited may have to decline to take on a new client.

If Seven Capitals Foreign Brokerage Limited considers developing new products or services or making other changes to its business model or operations, Senior Management will consider whether any additional potential conflicts of interest arise.

Senior management will update the “Conflicts of Interest Policy” and “Register of Potential Conflicts of Interest” as necessary on an ongoing basis and formally consider the continued adequacy of the arrangements on an annual basis.

Seven Capitals Foreign Brokerage Limited has identified the following circumstances in which general types of potential conflicts of interest may arise:

The firm or an associate undertakes designated investment business for other clients including its associates and the clients of its associates

A partner or employee of the firm or of an associate is a director / partner which holds or deals insecurities of or is otherwise interested in any company whose securities are held or dealt in on behalf of a client.

A partner or employee of the firm or of an associate is involved in the management of any company whose securities are held or dealt in on behalf of a client.

A transaction is affected in units or shares of a fund or company of which the firm or an associate is the manager operator or adviser.

An associate or a partner, director or employee of the firm is contemporaneously trading or has traded on its/their own account or has either a long or short position.

When acting as an agent for a client, the firm may match an order of the client with an order of another client for whom it is acting as agent.

The circumstances giving rise to conflicts of interest include all cases where there is a conflict between the:

Interests of Seven Capitals Foreign Brokerage Limited, an individual member of staff, certain persons directly or indirectly connected to Seven Capitals Foreign Brokerage Limited or differing interests of two or more clients as Seven Capitals Foreign Brokerage Limited owes a separate duty to each of them.

Conflicts of interests could prejudice a client in various ways whether Seven Capitals Foreign Brokerage Limited suffers any financial loss and independently whether the actions or the motivations of the employees involved are intentional. For the purposes of identifying the types of conflicts of interest that arise or may arise. Seven Capitals Foreign Brokerage Limited must take into account the firm or a relevant person, example – a partner, employee, an appointed representative, a director, partner or employee of an appointed representative, a person who is directly involved in the provision of services to the firm, appointed representative under an outsourcing agreement and a person directly or indirectly linked by control to the firm:

Is likely to make a financial gain or avoid a financial loss, at the expense of the client

Has an interest in the outcome of the service to or a transaction carried out for, a client which differs from the client’s interest

Has a financial or other incentive to favour one client (or group of clients) over the interests of another

Carries on the same or similar business as the client

Receives an inducement from a third party in the execution of the service provided to the client other than the standard commission/fee for that service.

These services that Seven Capitals Foreign Brokerage Limited provides to its clients could potentially give rise to conflicts of interest entailing a material risk of damage to the interests of one or more clients. This document aims to set out these potential conflicts and the procedures that are in place to be followed and measures to be adopted in order to manage such conflicts.

Conflicts of interest may occur between a customer and Seven Capitals Foreign Brokerage Limited including its managers, employees or any persons directly or indirectly linked to the firm or between two or more clients.

Treating customers fairly is central to the core values of Seven Capitals Foreign Brokerage Limited. There is an embedded culture that understands what is considered acceptable and unacceptable behaviour. As such, conflicts of interest and the identification / management / mitigation thereof are central to this philosophy and culture.

It is important to identify and effectively manage conflicts of interest, which arise or may arise in the course of providing a service and carrying out activities, as their existence may lead to material risk of damage to a client’s interests.

This document sets out Seven Capitals Foreign Brokerage Limited policy for the management of such conflicts of interest. Seven Capitals Foreign Brokerage Limited Foreign Brokerage Limited: Registered Addresses- Headquarter: Level-6 Ken Lee Building, 20 Edith Cavell Street, Port Luis 11302, Mauritius. Marketing Office: 403, API World Tower, Sheikh Zayed Road, World Trade Center 1, Dubai UAE. P O Box 47425. We are authorized and regulated by the Financial Services Commission as An Investment Broker in Global Business with the License/registration No. GB 21026349.

Seven Capitals Foreign Brokerage Limited has taken this opportunity to examine its policies and procedures to ensure they remain fit for purpose and address the issues in a way which is proportionate to the scale and complexity of its business. Both the policy and the register of conflicts of interest will be reviewed on at least an annual basis.

This document does not intend to create third party rights or duties or form part of any contractual agreement between the firm and any client. This policy may be amended and updated at any time if any material change occurs and will be reviewed on at least an annual basis.

If at any time you are in doubt as to how to act in a given situation where you are faced with an actual or potential conflict of interest, you should contact the Compliance Officer.

Whilst conflicts of interest are important to be adhered to by all of Seven Capitals Foreign Brokerage Limited’s staff, they are non-exhaustive and certain other additional rules may apply to readers who are members of professional associations by virtue of their job role. Failure to follow any of the rules whether by express breach or failure to follow any of the spirit of identifying, mitigating and managing conflicts of interest may also be a breach of an employment contract. Disciplinary action may be taken by Seven Capitals Foreign Brokerage Limited as a result.

It is important to identify and effectively manage conflicts of interest, which arise or may arise in the course of providing a service and carrying out activities, as their existence may lead to material risk of damage to a client’s interests.

This document sets out Seven Capitals Foreign Brokerage Limited policy for the management of such conflicts of interest. Seven Capitals Foreign Brokerage Limited Foreign Brokerage Limited: Registered Addresses- Headquarter: Level-6 Ken Lee Building, 20 Edith Cavell Street, Port Luis 11302, Mauritius. Marketing Office: 403, API World Tower, Sheikh Zayed Road, World Trade Center 1, Dubai UAE. P O Box 47425. We are authorized and regulated by the Financial Services Commission as An Investment Broker in Global Business with the License/registration No. GB 21026349.

Seven Capitals Foreign Brokerage Limited has taken this opportunity to examine its policies and procedures to ensure they remain fit for purpose and address the issues in a way which is proportionate to the scale and complexity of its business. Both the policy and the register of conflicts of interest will be reviewed on at least an annual basis.

This document does not intend to create third party rights or duties or form part of any contractual agreement between the firm and any client. This policy may be amended and updated at any time if any material change occurs and will be reviewed on at least an annual basis.

If at any time you are in doubt as to how to act in a given situation where you are faced with an actual or potential conflict of interest, you should contact the Compliance Officer.

Whilst conflicts of interest are important to be adhered to by all of Seven Capitals Foreign Brokerage Limited’s staff, they are non-exhaustive and certain other additional rules may apply to readers who are members of professional associations by virtue of their job role. Failure to follow any of the rules whether by express breach or failure to follow any of the spirit of identifying, mitigating and managing conflicts of interest may also be a breach of an employment contract. Disciplinary action may be taken by Seven Capitals Foreign Brokerage Limited as a result.

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The client confirms that they are notified about risks related to performing trade operations at the world financial markets, including the following:

Leverage risk

9.1.1. While performing trade on the conditions of “Margin trading” a relatively small change of rate may strongly influence the client trading account balance due to the leverage effect. In the event of a market movement against the client position, he/she can bear loss in the amount of the initial deposit and any other additional funds deposited to support open orders. The client is fully liable for consideration of all risks, use of financial tools and a choice of the relevant trading strategy.

9.1.2. It is recommended to maintain Margin level at 100% and higher, as well as always submit Stop Loss orders to eliminate possible losses.

9.2. Risk of financial tool volatility

9.2.1. A wide range of tools has great change of rates during the day that implies high probability of receiving profits as well as bearing losses for trading.

9.3. Technical risks

9.3.1. The client accepts risks of financial losses due to a failure of information, communication, electrical and other systems from the client side.

9.3.2. During trading by means of the client terminal the client accepts the risks of financial losses, which might occur due to:

a) A failure in the hardware, software, and bad quality of connection from the client side.

b) A malfunctioning of the client equipment.

c) Wrong settings of the client terminal.

d) Not a timely update of the client terminal version.

e) A lack of the client knowledge about the instructions, described in the support installed in the terminal.

9.4. Risk of irregular market conditions

The client accepts that in market conditions different from regular, time of processing client orders may increase, spread may be widened and also an execution quote may differ from quotes in the flow.

9.5. Risk of technical peculiarities of the trading platform

9.5.1. The client accepts that in the queue of orders on the server there can be only one order. An attempt to submit any new order will be rejected and in the order window a notice will appear “Order is locked”.

9.5.2. The client accepts that the only authoritative source of information about the quote flow is the main server serving clients, performing trades at the real accounts. Quote databases at the client terminal shall not serve as an authoritative source of information about the quote flow, as in the event of an unstable connection between the client terminal and the server a part of quotes from the quote flow may not reach the client terminal.

9.5.3. The current rates for the underlying assets are those calculated by the company on the basis of the quotes received by the company. All issues regarding the market prices determination lie within the sole cognizance of the company.

9.5.4. The client unconditionally accepts the quotes provided by the company to its clients as exclusively correct, no claims about the quotes provided by the company being different from the quotes of other sources can be accepted for consideration.

9.5.5. The company reserves the right to reconsider the provided quotes for any time period if, according to the company, such quotes fall within the definition of an “Off-market quote” and/or “Irregular market conditions” and/or an “Obvious error” defined in the present agreement and/or in the “Terms and definitions” section and revise the financial results of the trading operations executed at such quotes.

9.5.6. In case of an unscheduled halt of the quotes flow on the trading server caused by a hardware or software failure, the company reserves the right to synchronize the quotes database on the server with other sources in order to reestablish the continuity of 0the quotes flow history. In such cases, the company is entitled, but not obliged to revise the financial results of the client’s trading operations executed within this time period.

9.5.7. The client accepts that closing a window of submitting/modifying/removing an order as well as the window of opening/closing an order does not cancel the order which has already been submitted to the dealer for processing.

9.5.8. The client accepts the risk of performing unplanned trading operations in the event of submitting an order second time before receiving information about the results of a previous order processing by dealer.

9.5.9. The client accepts that an order for simultaneous modification of the level of a pending order and levels Stop Loss and/or Take Profit, submitted for processing after the order has been executed, will be modified only in the part of modifying levels Stop Loss and/or Take Profit orders of the open for this order position.

9.5.10. The client accepts that in the event of submitting a pending order or Stop Loss and/or Take Profit orders for the level, equal to the current quote in the quote flow, an order will be executed only in the event when a new tick towards an order actuation will occur, provided the conditions in P. 4.5 are satisfied.

9.6. Risk of communication failure

9.6.1. The client accepts the risk of any financial losses caused by the fact that he/she did not receive or received with delay any message from the company.

9.6.2. The client acknowledges that non-encrypted information sent via e-mail is not protected from unauthorized access.

9.6.3. The client agrees that the company has the right to delete messages received by the client through an internal mail of the client terminal within three calendar days since the moment of the message sending.

9.6.4. The client is fully liable for keeping confidential information received from the company and accepts risks of any financial losses caused by unauthorized access of third parties to the trading account.

9.7. Risk of force majeure circumstances

9.7.1. The client accepts the risks of financial losses caused by force majeure circumstances.

Client understands and agrees that he/she/it will not enter into unlawful, illegal and immoral transactions or any transaction contrary applicable laws, regulations and/or rules or Seven Capital’s policy or any transaction for purposes of Scalping, arbitrage or to intentionally exploit or manipulate any inaccuracy, regardless of how minor, major, obvious or unobvious, in any rate or pricing offered by SEVEN CAPITAL whether through the usage Of scripts, codes, electronic advisors, software or any other form of computer program or manual trading. SEVEN CAPITAL defines scalping as any transaction which remains open for a period of less than three minutes in duration. Client understands SEVEN CAPITAL is authorized to retroactively cancel transactions found, in SEVEN CAPITAL ‘s sole discretion, to be transactions entered into in order to exploit or manipulate pricing by means as set forth within this Section. SEVEN CAPITAL is then authorized to reclaim any trading profits Client obtains through the entering of any transaction in breach of this Clause in particular transactions for purposes of scalping, arbitrage or intentional exploitation of inaccuracies of rates/ pricing offered by SEVEN CAPITAL. Client acknowledges and understands that SEVEN CAPITAL does not guarantee the execution of orders at specific prices, including conditional orders such as stops and/or limits, specifically at times of increased volatility or volume, including market news announcements, due to gapping markets, greyed out pricing, and market liquidity. Client understands and agrees that should they receive off-market prices, for any reason, including but not limited to, delays, malfunctions or manual trading errors, SEVEN CAPITAL shall retroactively cancel such trades and may elect to leave such trades cancelled or reopen such trades at the correct market price, Client understands that orders received during instances of increased market volatility will be filled at the next best price available or the fair market value Client acknowledges that during instances of gapping markets, conditional orders, specifically stop losses, will be filled at the next available price following a gapping market. Pricing can gap past the price set forth in conditional orders, resulting in clients losing more funds than initially intended. Client acknowledges that due to such risks, SEVEN CAPITAL encourages clients to utilize market orders rather than conditional orders, as market orders are provided with a requote and allow Clients to accept or reject the new price. Client agrees that SEVEN CAPITAL is not responsible for any loses, including margin calls, which occur as a result of conditional orders being filled during a gapping market or orders being filled at certain prices as a result of greyed out pricing and/or limitations in market liquidity.

7.1. The company uses the following communication means to contact the client:

a) Internal emails of the trading platform at their sole discretion (from the company to the client).

b) Corporate chat, realized through a Personal Area.

c) Telephone

d) Post

e) Announcements in the related sections of the company website

f) Corporate chat

g) To contact the client the company shall use the client references, stated while opening the account or changed in accordance to the present regulations.

7.2. To be able to react promptly to the client’s needs the company sets priorities in answering clients in the following way: communication means via which the client can perform trades: online chat (from a Personal Area) are served first, then questions from the forum and email are processed.

7.3. Correspondence (documentation, announcements, notifications, confirmations, reports, etc.) is considered to be accepted by the client:

a) An hour after sending it to their email

b) Immediately after sending it by internal email of the trading platform

c) Immediately after finishing a conversation by phone

d) After 7 days since sending it via post

e) An hour after placing it at the company website.

7.4. To provide confidentiality of all trading operations, performed by the client, access to a trader Personal Area and trading terminal are secured via passwords. The client is solely liable for keeping his/her logins and passwords.

7.5. For the purpose of providing security for all client trading operations, telephone conversations with the company are recorded on magnetic or electronic media. Such records are proprietary to the company and serve as evidence of orders submitted by the client.

6.1. The client shall pay to the company commissions and other costs in the amounts stated in the contract specifications. The company publishes the size of all the current commissions and other costs at their website.

6.2. The company is entitled to change the size of commissions and other costs without prior notification of the client. All changes are published at the company website in the section “Company news” and/or in contact specifications.\

6.3. Provided that all the applicable company rules and provisions are followed, the company is not liable to disclose to the client any reports regarding profits, commissions and other fees received by the company on the client’s trade, with the exception of the cases specially mentioned in the present agreement.

6.4. Swap-free accounts are provided on the following terms:

6.4.1. For long-term strategies (the deal which is open more than 2 days), the company charges a fixed fee for the total number of days during which the order was opened, the fee is fixed and determined as the value of 1 point of the transaction in US dollars, multiplied by the size of the currency pair swap point of the deal. This fee is not an interest and depends on whether the deal is open to buy or sell.

6.4.2. Swap Free option is not available for trading on “Forex Exotic” and CFD instruments.

6.4.3. Upon detecting:

6.4.3.1. The usage of a swap-free account for performing arbitrage orders.

6.4.3.2. The usage of the carry trade-related strategies.

6.4.3.3. A purposeful usage of a swap-free option to make additional profits. The company reserves a right to refuse to provide a client with swap-free services as well as debit the fee from his or her trading account at any time according to the p. 6.4.2, having notified the customer via email

5.1. Funds deposit to the client trading account

5.1.1. A client can deposit funds to his/her account by means of the methods and payment systems available in the Personal Area.

5.1.2. If it is impossible to execute a deposit automatically, the request will be carried out by the company’s financial department within 2 working days after it is created.

5.2. Withdrawal of funds from the client’s trading account

5.2.1. The client can withdraw funds from his/her account only to those payment systems which have been used in P. 5.1.1.

5.2.2. In the cases when deposit of the account was executed via various methods, withdrawal is executed via the same methods in the ratio according to the deposited sums.

5.2.3. In exceptional cases such as force majeure circumstances, termination of payment system operation, etc, the company is entitled to decline a client’s funds withdrawal in this payment system. Depending on circumstances such cases are considered case by case.

5.2.4. According to the company’s withdrawal policy, withdrawal requests are processed within 2 working days upon receipt of withdrawals request.

5.2.5. The comp

any in its sole discretion can request information from the client about his/her source of income and source of funds in order to verify legitimacy of client’s deposits and withdrawals and in order to comply with applicable regulations.

5.2.6. If an account has been deposited via a debit or a credit card at least one time, a withdrawal from the account should be executed back to this card during the year since last deposit made via the card.

5.2.7. If an account was funded via debit or credit card, a card copy is required to process a withdrawal. The copy must contain the first 6 digits and the last 4 digits of the card number, cardholder’s name, expiry date and cardholder’s signature.

5.2.8. If an account has been deposited by a debit or a credit card and a withdrawal request is submitted within one calendar year from the date of the deposit, the funds will be credited back to the card. Up to 100% of the initial deposit can be withdrawn to the card. The amount exceeding the initial deposit may be withdrawn in full or partially via any other payment system or bank where the client has his personal e-wallet or bank account.

5.2.9. The company reserves a right to reconcile financial operations on client’s trading accounts and payment systems, in order to see genuineness and consistency of the client’s trading activities on the company’s platform.

5.2.9.1. In case of discrepant transactions, the company may cancel any financial operations that are not found in the payment system’s records or were cancelled (chargeback). In this case, the company also reserves a right to cancel any trading operations made with the unconfirmed funds as well as call back any related payments for these operations, such as partner commission, auto-referral commission, promo and bonus lots, etc.

5.3. Internal transfer:

5.3.1. Up to 10 internal transfers are processed automatically. Above 10 internal transfers are processed manually by the financial department.

5.3.2. Transfer between third parties is not possible except internal transfers between a partner and his clients that are processed manually as well.

5.4. Financial security

5.4.1. To provide financial security the company is entitled to request from the client a confirmation of the verification of personal data submitted at the registration of a trading account. For this purpose, the company may at any moment ask the client to submit a copy of a passport or other equivalent document, certified by a notary (at company’s discretion).

5.4.2. The company is entitled to prohibit to deposit or withdraw funds to the third parties.

4.1. Order types in the trading platform Seven Capitals Foreign Brokerage Limited Trader.

4.1.1. The following order types to open a position (pending orders) may be located in the trading platform Seven Capitals Foreign Brokerage Limited Trader:

a) “Buy Stop” –expects to open a position to buy at a higher quote than the current one at the moment of an order placement.

b) “Sell Stop” –expects to open a position to sell at a lower quote than the current one at the moment of an order placement.

c) “Buy Limit” –expects to open a position to buy at a lower quote than the current one at the moment of order placement.

d) “Sell Limit” – expects to open a position to sell at a higher quote then the current one at the moment of an order placement. The following orders may be used to close a position.

e) “Stop Loss” –expects to close a previously opened position at a quote less profitable for the client, than the current quote at the moment of an order placement

f) “Take Profit” –expects to close a previously opened position at a quote more profitable for the client than the current quote at the moment of an order placement.

4.2. Time of placement and validity period of orders

4.2.1. Placement, modification and removal of orders by the client shall be performed only during the period when trading according with the following tool is allowed. Trading hours for each tool are stated in the tool specifications.

4.2.2. Should irregular market situations occur, the trading with a certain tool may be stopped mandatorily, till the causes of the closing are removed.

4.2.3. All pending orders as well as orders “Stop Loss” and “Take Profit” for financial tools have the GTC Status (“Good Till Cancelled”) and are accepted for the indefinite periods. The client is entitled to set the date and expiration date order validity him/herself, filling the date and time in the fields “Expiry”.

4.3. Order placement regulations.

4.3.1. At the moment when the client submits an order to place the pending orders the following parameters are to be determined:

a) Name of the tool

b) Volume

c) Order type (Buy Stop, Buy Limit, Sell Stop, Sell Limit)

d) Order level

4.3.2. Additionally, to the parameters determined in the client order, optional parameters may be stated in the order, such as the following:

a) Stop Loss level of a pending order. 0.0000 value means that Stop Loss is not placed (or deleted if it had been submitted earlier).

b) Take Profit level of a pending order. 0.0000 value means that Take Profit is not placed (or deleted if it had been submitted earlier).

c) Date and time of a pending order validity.

4.3.3. The trading server may decline an order in the following cases:

a) If the value of one or several required parameters is missing or wrong

b) In such a case if a pending order is placed by means of the client terminal without using an expert advisor, an error message will appear: “Invalid S/L or T/P”.

4.3.4. When the Client submits an order to place “Stop Loss” and “Take Profit” for open positions the following parameters are to be determined:

a) Ticker of the open position for which the orders are placed

b) “Stop Loss” order level. 0.0000 value means that “Stop Loss” is not placed (or deleted if it has been place earlier).

c) “Take Profit” order level. 0.0000 value means that “Take Profit” is not placed (or deleted if it has been placed earlier).

4.3.5. Orders of all types shall not be placed closer than a stated number of points to the current market quote. The minimum distance in points from the level of a placed order to the current quote (pending order level) for each tool is stated in tool specifications at the company website.

4.3.5.1. If the order is executed in irregular market conditions, Stop levels may be increased.

4.3.6. Requests for order closure or modification, in case the current quote is closer to the S/L or T/P levels of this order than to the “Stop levels” value, will be declined with the commentary as follows: “Modification disabled. The order is too close to the market” or “No quote”.

4.3.7. Requests to set, modify or delete a pending order, in case the current quote is closer to the S/L or T/P price of this order than to the “Stop levels” value, will be declined with the commentary as follows: “Invalid S/L or T/P” or “No quote”.

4.3.8. When a note about an order placement appears in the server log-file, it means that the client order has been processed and the order is placed.

4.3.9. Every pending order receives a ticker.

4.3.10. If an order for placement is received for processing before a first quote appears in the trading platform, it will be declined by a trading server. The window “No price/Trading is forbidden” will appear in the client terminal.

4.4. Orders modification and deletion

4.4.1. When the client submits an order to modify parameters of pending orders (level of a pending order, Stop Loss and Take Profit for this pending order) the following parameters are to be defined:

a) Ticker

b) Order level

c) Stop Loss order level. 0.0000 value means that Stop Loss is not places or deleted if it has been placed earlier. A trading server is entitled to cancel an order if a wrong value of one or several parameters has been given. In such a case a button “Modify” is not activated.

4.4.2. When the client submits an order to modify Stop Loss and Take Profit orders for the open position, the following parameters are to be defined:

a) Ticker for an open position

b) Stop Loss order level. 0.0000 value means that Stop Loss is not placed or deleted if it has been placed earlier.

c) Take Profit order level. 0.0000 value means that Take Profit is not placed or deleted if it has been placed earlier.

4.4.3. When the client submits an order to delete a pending order, he/she shall state the ticker of a deleting order.

4.4.4. When a note about modifying or deleting an order appears in the server log-file, the client order to modify or delete an order is considered processed and an order is considered to be modified or deleted.

4.4.5. A trading server may decline a modification or deletion order if it has been submitted for processing before a first quote in the trading platform at market opening appeared. If a dealer by mistake processes a client order, order modification or deletion may be cancelled. The client will receive a notification about it via internal email of a trading terminal.

4.5. Order execution

4.5.1. An order is executed in the following cases:

a) Orders Sell Stop –at the moment, when Bid price in the quote flow is equal or smaller than an order level.

b) Buy Stop order –at the moment, when Ask price in the quote flow is equal or bigger than an order level.

c) Sell Limit order –at the moment, when Bid price in the quote flow is equal or bigger than an order level.

d) Buy Limit order –at the moment, when Ask price in the quote flow is equal or smaller than an order level.

e) Take Profit order –for an open buying position, when Bid price in the quote flow is equal or bigger than an order level.

f) Stop Loss order –for an open buying position, when Bid price in the quote flow is equal or smaller than an order level.

g) Take Profit order –for an open selling position, when Ask price in the quote flow is equal or smaller than an order level.

h) Stop Loss order –for an open selling position, when Ask price in the quote flow is equal or bigger than an order level.

4.5.2. In the cases of price gaps order execution is determined by the following rules:

a) If “Take Profit” level of a pending order is in the price gap during order opening, once the order is opened Take Profit settings will be annulled. In such a case a note is added to the comments: (tp cancelled/gap).

b) “Take Profit” order with a level in the price gap is executed at the stated in the order quote.

c) “Stop Loss” order with a level in the price gap is executed at the first quote after a price gap. In such a case a note is added to the comments (sl/gap).

d) “Buy Stop” and “Sell Stop” pending orders are executed at the first quote after the price gap. In such a case a note is added to the comments (started/gap).

e) “Buy Limit” and “Sell Limit” pending orders are executed at the stated in them quotes. In such cases a note is added to the comments (started/gap).

f) in case a price gap is over 300 pips and profit is recorded on it, the company reserves the right to limit profit for such an order by 300 pips. In certain cases, with small price gaps orders may be executed in the standard mode at the stated in them quotes.

4.5.3. a) In regular market conditions the order is executed by the company at the price specified in the order.

b) If the order is executed in irregular market conditions, the order execution price may differ from the one specified in the order, either in favor of the client or not.

4.5.4. In case the following conditions are simultaneously met on the client’s account:

a) Margin level does not exceed the consequent of the leverage ratio currently set on the account.

b) 60% or more of total position volume is placed at one trading tool and in the same direction (sell or buy).

c) This part of the total position has been formed within 24 hours’ period before the market closes.

The company is entitled to set “Take Profit” for orders, included in the total position at the Ask price level of market closing for the tool minus one point (for sell orders) or at the bid price level of the market closing for the tool plus one point (for buy orders).

3.1. The company reserves a right to change the trading conditions with a prior notification

3.2. Client’s orders and requests

3.2.1. During trading operations, the following execution methods are applied:

a) “Market execution” method –for Futures and Stock CFDs

b) “Market execution” method –for FOREX market trading tools

3.2.2. Any client’s order given by means of Metatrader 5 trading terminal generally goes through the following steps:

a) The client submits an electronic order.

b) The client terminal sends the order or request to the server.

c) Provided there is a stable connectivity between the client terminal and the server, the order is received by the server and verified.

d) In case the order is valid, it is put into the queue. In this case “Please wait… Order is being processed by the server” message is displayed in the “Order” window of the client terminal.

e) The server returns the order processing results to the client terminal.

f) Provided there is a stable connectivity between the client terminal and the server, the terminal receives the order or request processing results.

3.2.3. The client can cancel a sent order only while it is in queue with “Order is accepted” status. In this case the client should press “Cancel order” button. Due to the specifics of Metatrader 5 platform order cancellation in this case cannot be guaranteed.

3.2.4. In case the order has reached the dealer and has “Order is in process” status, such order cannot be cancelled.

3.2.5. The time of the order processing depends on the connection between the client terminal and the company’s server, as well as on the current market conditions. During regular market hours the order processing time usually is 1 to 5 seconds. In irregular market conditions, the processing time can last longer.

3.2.6. In case the current quote of the financial instrument changes at the moment when the company is processing the client’s request, the company reserves the right to use the new price (Bid/Ask). In such case, the client’s request will be processed at the new price.

3.2.7. A client’s request is declined in the following cases:

a) During market opening when the order is sent before the first quote is received by the trading platform.

b) In irregular market conditions.

c) In case the client doesn’t have sufficient margin. In this case “No quote” or “Not enough money” message is displayed by the trading platform.

d) In case the client uses an electronic advisor performing over 30 requests per minute, the company reserves a right to ban such EAs.

e) For instruments with fixed spread or fixed commission for order opening with no spread, the company reserves the right to change to “Close only” mode and decline new requests for order opening with the comment “Trade is disabled” in case spread on the basic contract exceeds the size of fixed spread or commission amount.

3.2.8. The general means of sending orders and requests is the trading terminal. Orders and requests can also be sent by phone or live chat.

3.2.9. In exceptional cases the use of the same IP address by different clients can be a basis to consider all the orders on all the accounts, performed form this IP address as those performed by the same client.

3.2.10. Orders opened or closed by off-market quotes can be cancelled:

a) In case the order was opened by an off-market quote.

b) In case the order was closed by an off-market quote.

3.2.11. The company doesn’t allow the usage of arbitrage strategies on connected markets (e.g. currency futures and spot currencies). In case the client uses arbitrage in either clear or hidden way, the company reserves a right to cancel such orders.

3.2.12. The company reserves a right to cancel client’s orders in case they do not comply with this agreement.

3.3. Trading operations:

3.3.1. A buy order is opened by Ask price. A sell order is opened by Bid price.

3.3.2. A buy order is closed by Bid price. A sell order is closed by Ask price.

3.3.3. Position rollover: Swap addition/deduction to open orders is carried out from 23:59:00 to 00:10:00, trading platform time. So the swap will be added/deducted to all orders which were open during the period from23:59:00 to 00:00:00, trading platform time.

3.3.4. In case of trading those CFD contracts that have limited period of trading (expiration date), all orders executed on one contract will be closed by the last quote.

3.3.5. In regular market conditions a dealer keeps the spread within the range stated in the contract specifications.

3.3.6. Spread can be increased:

For all company clients without prior notification in the event, the conditions come different from the regular ones.

For all clients with obligatory prior update of contracts, specification changes at the company website.

For all clients without prior notification in the event of force majeure circumstances; For any request exceeding regular market volume for the tool stated in the contract specification.

3.3.7. Spread on trading accounts can be widened before, in time and after economic, political and other news release, during the gap, at the time of Market opening (on Monday) as well as at the time of low market liquidity and when a market situation is conditional on high spreads.

3.3.8 For instruments with fixed spread or fixed commission, the company reserves the right to increase spread in case spread on the basic contract exceeds the size of fixed spread.

3.4. Open an order:

3.4.1. The obligatory parameters for submitting an order are: Name of the tool, Trade volume and Order type.

3.4.2. To open an order by means of the client terminal without using an expert advisor, the client should press the button “Buy” or “Sell” at the moment, when company’s quotes satisfy him/her.

3.4.3. To open an order by means of the client terminal using an expert advisor, an order should be generated to perform trade at a current quote.

3.4.4. Order processing for open orders

a) At the moment when a client’s order to open the position comes to the server, an automatic check of the trading account for free margin for the open order is carried out. In the event that the necessary margin is present, the order is opened. If the margin is not sufficient, the order is not opened and a notice about absence of funds is created on the server.

b) In case of the “Market execution” trading tool type, a quote for opening an order may differ from the requested one.

c) The note about the open order appearing on log-file of the server declares that the client’s request has been processed and the order has been opened. Each open order on the trading platform receives a ticker.

d) An order to open a position submitted for processing before first quote appears on the trading platform at market opening, will be declined. In this event in the client terminal window a message will appear “No quote/trading is forbidden”. In the event of the dealer processing by mistake a client request to open an order at the price of the previous day closing, the company is liable to cancel such an order. In such a case the company contacts the client and informs about it.

3.5. Close an order:

3.5.1. To close an order by means of the client terminal without using an expert advisor, the client should press the button “Close” in the moment, when company quotes satisfy him/her.

3.5.2. To close an order by means of the client terminal using an expert advisor, an order shall be generated to close the order at a current quote.

3.5.3. The following orders “Stop Loss” and/or “Take Profit” may be used for closing an order.

3.5.4. Processing orders to close a position-

a) If in the list of open orders on a trading account there are two or more locked positions, then while generating a request or an order to close any of those, an option “Close by” appears in the dropdown “Type” list. After choosing it, one or several open positions of the reverse direction appear. After marking the needed position from the list, a button “Close#…by#…” is activated. By pressing it the client closes locked positions of equal volumes or partly closes two locked positions of different volumes. In such a case a smaller position and a symmetric part of a bigger one close and a new position in the direction of a bigger between the two stays open, thus receiving a new ticker.

b) If in the list of open orders on a trading account there are two or more locked positions, then while generating a request or an order to close any of those, an option “Multiple Close by” appears in the dropdown “Type” list. After choosing it, a list of all positions for the given tool appears and a button “Multiple Close By for…” is activated. By pressing this button, the client closes all locked positions for the tool. In such a case a new position(s) stays open in the direction of a bigger total volume, which receives a new ticker. Important: functions “Close By” and “Multiple Close By” do not operate for the tools with floating stock spread.

c) When the note about closing a position appears in the log-file, this means that the client’s order to close a position has been processed.

d) If an order to close a position has been submitted for processing before a first quote appeared at the trading platform at market opening, such an order shall be declined by the dealer. In the client terminal window, a message “No price” will appear. The company is entitled to cancel trade when the dealer processed the client’s order to close a position at a quote of a previous day closing by mistake. In such a case the company contacts the client and informs about it.

e) If a “Market execution” type is used for a trading tool, quote for closing an order may differ from the requested one.

3.6. Mandatory position closure:

3.6.1. If margin level is lower than 40% on the client account, margin call occurs. The company is entitled but not liable to close client positions. Decision to close positions is made by the server.

3.6.2. The company is entitled to mandatory closing of client open positions without prior notification of the latter one, if a margin level is less than or equal to 20% of the necessary margin for maintaining open positions.

3.6.3. The current account balance is controlled by the server, which in the event of execution of P. 3.6.2. of the present agreement generates an order to stop out. Stop out is executed at a current market quote on a first -come basis with client orders. Mandatory position closure is noted in the log-file of the server with a notice “stop out”.

3.6.4. In the event of executing conditions of P. 3.6.2. of the present agreement shall the client have several open positions, the first position closed is the one with biggest floating loss.

3.6.5. When after a mandatory position closure the client, account has a negative balance, compensation is added to the account, which sets the account to zero. However, in special cases (when the company considers client’s actions as intentional) the company reserves the right to claim a debt payment from the client.

3.6.6. In case the company has reasons to believe that a client operates two or more accounts under different registration data (e.g. opening opposite orders on the same trading instrument that are left open over the weekend or during the period between trading sessions), Seven Capitals Foreign Brokerage Limited reserves the right to deduct the losses exceeding the balance of one account from the funds of another account belonging to a client.

3.6.7. In case Balance fixed occurs on a client’s account, the amount of funds compensated by the company will be deducted from the total sum of the Cashback commission to be paid for the current day.

3.7. Leverage change:

3.7.1. For the company’s client leverage change is possible only once in 24 hours. For security reasons of trade operations performed by the client, it is impossible to change leverage if the account is in the trade mode (there are open orders).

3.7.2. The company is entitled to change leverage on the client account any time without prior notification.

3.7.3. In order to minimize client’s risks at the time of market opening on Monday, in case a client kept open orders during the weekend, the company reserves the right to lower the leverage and change margin requirements several fold.

3.7.4. The leverage for the trading of Metals, CFD, and Crypto currency trading at any trading account is set at:

1:333 for Metals

1:100 for CFD

1:10 for Stocks

1:3 for Crypto currencies.

2.1. The term “company’s services” refers to any interactive services or software provided by the company, which allow the client to:-

2.1.1. Connect the company or authorized third party, receive information and/or quotes from the company or authorized third party.

2.1.2. Perform transactions on financial markets through the company by means of Metatrader 4.0 software, including electronic data transmission between the client’s PC or any similar device connected to the internet and the company’s authorized network.

2.2. Accepting this agreement, the client confirms he/she has read the communication rules and agrees that he/she is only able to perform orders by means of trading terminal and the company’s live chat only.

2.3. Company’s services include Metatrader 5 software pack, technical analysis means and any third parties’ services offered along with the company’s services.

2.4. The client confirms that the company may modify, add, rename or leave unmodified the company’s services offered in compliance with this agreement without prior notification. The client also confirms that the agreement is applied to the services which may be modified, added or renamed in future in addition to the services provided by the company at present.

2.5. As far as trading operations are concerned the company only provides execution, not providing any asset management or recommendations.

2.6. The company is not liable to (unless set forth in this agreement): –

2.6.1. Track any client’s trading operation status and inform the client about it.

2.6.2. Close any client’s open position.

2.6.3. Attempt to execute any client’s order by different quotes than the quotes offered in Metatrader 5 trading platform.

2.7. Company’s services do not include providing recommendations or information capable of engaging the client to perform any transactions. In exceptional cases the company reserves a right to provide information, recommendations or advice to the client, however, in these cases the company will not be responsible for any consequences of such recommendations and advices. Despite the company reserves a right to close or decline any client’s position, all the trading operations performed by the client as a result of imprecise information and/or mistake still remain in force and are mandatory for both the client and the company.

2.8. The company is not a tax agent and acts under the legislation of the Belize. The parties comply with their tax and/or any other obligations independently and on their own.

2.9. The company reserves a right to decline the client and offer him/her to withdraw the deposit in case his/her activity or interaction with the company is deemed inappropriate and/or incorrect.

2.10. No actual supply of the currency or base asset of a CFD is made within a trading operation. All the profits and losses are deposited/deducted from the client’s trading account balance immediately after the position closure.

1.1. This agreement sets forth the terms and conditions of the company’s services provision. The company provides the following services to the customer: performing operations in financial markets, performing transactions with financial tools either presenting or not presenting on the organized market. This agreement also sets forth the order of payments between the parties in connection with the aforementioned services provision. Accepting this agreement, the client guarantees the following:

1.1.1. In case the client is a private person, he/she is a legal person of age. In case the Client is a legal entity, the entity is capable and no one except the Client has any rights of demand or obligation in respect to the transactions performed in the Client’s trading account.

1.1.2. All the transactions on the client’s trading account are performed in compliance with this agreement.

1.1.3. In case of any change or modification of personal data or expiration of personal identification documents, the client is obliged within 3 business days to inform the company of such changes/expiration. The notification must be sent by email containing the client’s first and last name, account number(s), phone, as well as client’s valid passport or ID and recent proof of residential address. The notification must be signed, scanned and sent to contact@fx7capitals.com from the email the client submitted during his/her account registration. The company has the right to request other verification documents in order to verify the client and comply with applicable know-your-client regulations. Any delay or failure to comply with this clause shall amount to breach of these agreement by the client and can lead to closure of the client’s account(s).

-In case the client is a private person he submits the registration form personally.

-If legal entity, the form is submitted by the person in charge.

1.2. Client’s Representations

1.2.1. The client represents and warrants that he/she is free to enter into this agreement, to perform each of the terms and covenants contained herein and that he/she is not restricted or prohibited, contractually or otherwise, from entering into or performing under this agreement and that his/her execution of and performance under this agreement is not a violation or breach of any other agreement between the company and any other person or entity.

1.2.2. The client understands and expressly agrees that the company shall exercise its right to monitor activity of the client and verify consistency of client’s behavior and trading activities on the company’s platform.

1.2.3. The client further represents that he/she has complete understanding and is agreeing with all terms and conditions of this agreement.

Seven Capitals Foreign Brokerage Limited provide clients with a clear and transparent refund policy. In cases, that the clients are not satisfied with the company’s service level and did not make trading, investing, conversion transactions, the client can request a refund. The company offers a 100% refund within 1 working day of the original service deposit. The request will be reviewed within 5 business days.

After one day, deposit will no longer be refundable and will be treated as normal withdrawal based on the existing withdrawal terms and conditions.

The client cannot request for a refund or chargeback from its payment method provider at any time while or after using the company’s services.

Profits or losses received from the client’s trading activity cannot be subject to refund.

Refunds should be made only to the payment system / card client which is used for deposit.

The clients may be required to send a scanned colored copy of both sides of the card to combat fraud. Failure to provide the requested scanned copy of the card used to deposit in the MT5 account will mean a refund of the amount net of PSP fees.

The clients may be required to submit the below additional documents regardless of the initial documents submitted during the account opening application process to combat terrorist financing:

Clearer copy of the Identification document (passport or any government issued identification cards).

Clearer copy of the address proof (utility bill, bank or card statement that holds the client’s name and full residential address issued within the last three months).

One or more of the following options to confirm possession of the card by the owner:- A recent copy of the bank statement containing the cardholder’s full name, first 6 and last 4 digits of card number (sensitive data must be covered). If screenshots are provided, the URL page must be visible. Authorization code for the payment in question (AUTH code)

Clear color copies of both sides of the card, where the middle of the card must be covered on both sides, leaving the first 6 and last 4 digits visible; the CVC / CVV codes at the back of the card must be covered. The card back side must be signed by the cardholder.

If the origins of the client’s funds and/or the whole activities are contrary to the Company’s Anti – Money Laundering Policy (AML Policy), the company reserves unilateral rights to cancel transferring of funds (deposit or withdraw) and freeze the assets to refund them back.

A refund request can be made in cases in which the deposit fund is received from third party bank account instead of from the client’s bank account. In this case, the same method of payment used for the deposit will be used for the refund. The refund will be for the full amount, less any applicable fees or dues including but not limited to wire fees.

Refund and all other funding requests will be treated as WITHDRAWALS and will be processed using those methods and procedures as described in the Withdrawal Procedures.

Failure to provide one of the requested above – mentioned documents will mean a refund of the amount net of PSP fees.

Third party payments are prohibited. Client can only use cards or bank accounts under the same name as registered with Seven Capitals Foreign Brokerage Limited. The company reserves the right to require proof from the client at any time and failure to comply may result for the payment being frozen or void.

Deposit to Seven Capitals Foreign Brokerage Limited should be made from a source (e.g. bank account, payment system, credit/debit cards, etc.). Funding via E-wallets or debit/ credit cards, client may login to his/her My Seven Capitals Foreign Brokerage Limited portal. The company’s bank account details are also mentioned if the client wishes to transfer via wire transfer.

The company enforces a limitation of up to 3 (three) cards per client. If the client need to replace card details, but surpassed the three cards allocation, client may contact the company’s payment team (accounts@fx7capitals.com). Please note that the team may request for the client’s card details. Clients need to refrain from using prepaid cards or any method of payments which does not allow refunds to be processed.

The company does not charge for any transfer fees for using its deposit/withdrawal methods, but intermediary banks or E wallets may do so, which is beyond the company’s control.

The clients may be required to send a scanned colored copy of both sides of the card to combat fraud. The client should NOT send these copies if the company did not require to do so.

Upon Client receipt of the request from the company and before sending these copies, the client must cover (black-out) all digits except the first 6 and last 4 on the front side of the card for security purposes.

The client is also requested to cover (black-out) the CVV code on the back side of the card, whilst the embossed copy of the first 6 and last 4 number of the front side must be visible. All other details must be clear and visible and the signature section must be signed.

The company will never ask for any sensitive card details such as the full card number, CVV code, 3D secure code, PIN code etc. If the client received any kind of suspicious request for any sensitive details from an unclear source, the client should contact the company’s compliance department for investigation at contact@fx7capitals.com

The client acknowledges that he/she has read, understood and accepted the Deposit and Refund conditions as amended and reviewed on a regular and ongoing basis, in addition to any other information and/or policy and/or agreements available on the company’s website: www.fx7Capitals.com

Introduction

This document sets out Seven Capitals Foreign Brokerage Limited policy for Deposit and Refund. Seven Capitals Foreign Brokerage Limited Foreign Brokerage Limited: Registered Addresses- Headquarter: Level-6 Ken Lee Building, 20 Edith Cavell Street, Port Luis 11302, Mauritius. Marketing Office: 403, API World Tower, Sheikh Zayed Road, World Trade Center 1, Dubai UAE. P O Box 47425. We are authorized and regulated by the Financial Services Commission as An Investment Broker in Global Business with the License/registration No. GB 21026349.

The deposit and refund conditions are provided by the company to its clients under the Execution Policy as amended from time to time. The clients must read carefully and understand the conditions set out herein before proceeding to funding their accounts.

Execution Venue means the firm directly executing the orders. In this instance Seven Capitals Foreign Brokerage Limited is the Execution Venue who is quoting prices which are provided to Seven Capitals Foreign Brokerage Limited by top tier global banks & non-bank liquidity providers in the wholesale foreign exchange markets.

Seven Capitals Foreign Brokerage Limited provides execution in trading and services for its Clients in Foreign Exchange and CFD Trading. Seven Capitals Foreign Brokerage Limited does not offer any advice and does not offer equity share trading in its CFD offerings. It is the decision of Seven Capitals Foreign Brokerage Limited as to what market it offers its clients and it does so, not as a broker but as a principle and counter-party to each trade.

As such, every market offered by Seven Capitals Foreign Brokerage Limited is quoted as a derivative of the underlying market and we are the only execution venue to which you have access.

Monitoring – Seven Capitals Foreign Brokerage Limited will monitor the effectiveness of its order execution arrangements, including this Order Execution Policy to identify and correct any deficiencies appropriate.

Review – We will review our order execution arrangements and this Order Execution Policy at least annually or whenever a material change occurs that affects our ability to obtain the best result for the execution of orders on a consistent basis using the venues included in this Order Execution Policy.

Consent – Seven Capitals Foreign Brokerage Limited is required to obtain your prior consent to our order execution policy. You will be deemed to provide such prior consent when you give us an order.

In order to determine the relative importance of these factors, Seven Capitals Foreign Brokerage Limited will take into account:

The characteristics of the client, i.e. whether the order is for a retail or professional client.

The characteristics of the client order.

Characteristics of the financial instruments involved

Characteristics of the execution venues being considered.

When executing an order, the best possible result is determined by the total consideration, i.e. the price of the investment and any associated costs, such as execution venue fees, clearing and settlement fees, and other third party fees.

Seven Capitals Foreign Brokerage Limited is obliged to seek the best possible result for its client in relation to each trade requested. The best possible result however, may vary depending on the situation and this may not always equate to obtaining the best price or the lowest cost. Seven Capitals Foreign Brokerage Limited is therefore required to consider and assess the relative importance of the relevant ‘execution factors’ in respect of each class of financial instrument in which it trades.

Price – This is the price at which a transaction is executed. Where the price has varied across the transaction, the blended average price should be considered.

Cost – This includes explicit external costs such as exchange or clearing fees, as well as implicit costs such as spreads and slippage. This should be restricted to costs borne by the client and should not include the firm’s internal costs relating to trading.

Speed – This refers to the amount of time that elapses between the trade order and the successful execution of that trade.

Likelihood of execution and settlement – This refers to firm’s estimation of the probability that the trade order will be successfully completed either in whole or in part.

Size – For large orders or illiquid instruments only a partial fill may be received and this may vary between venues. Where the whole trade order is unlikely to be filled, the size of the potential fill will increase in importance.

Other Factors – While the above four factors are considered by Seven Capitals Foreign Brokerage Limited to be the most important in our best execution policy, there are many other situations which can arise leading to price variations.

Some markets which are quoted by Seven Capitals Foreign Brokerage Limited are done outside of normal market hours and as Order Execution Policy such are known as ‘grey markets’ in these situations, while every effort is made to keep prices and spreads consistent, this may not always be possible during particular volatile periods or during periods of illiquidity in corresponding markets.

Financing charges made by Seven Capitals Foreign Brokerage Limited are fair, competitive and transparent. These may include fees required to roll over open positions and shall be disclosed to you on our website and the trading platform.

There may be situations through third party introductions or through partnership deals with affiliated companies that a commission or other income generated from your trade is shared with third parties. In such circumstances this will be made abundantly clear to the client by the party concerned and this information is available on request.

The nature or other relevant considerations of the order – This is a broad category that covers any other factor not listed in the regulations that firms may wish to prioritize in order to achieve the best result for its clients. Examples of this may be the need to reduce the market impact of the trade. Where the client has attached instructions to the order, these should also be taken into consideration.

Not all of these criteria are relevant in each case or relevant to our business model. For example, Seven Capitals Foreign Brokerage Limited is the sole execution venue for trade executed by it for its clients.

Seven Capitals Foreign Brokerage Limited is committed to ensuring that our clients are treated fairly and receive the best possible price when executing a trade. Best execution refers to our responsibility to take all enough steps to achieve the best possible result on a consistent basis when executing orders on our clients’ behalf. In practice there are a variety of factors that could be considered in order to achieve best execution. This document forms part of our terms of business. Therefore, by agreeing to our Terms and Conditions, you are agreeing to our Order Execution Policy.

Seven Capitals Foreign Brokerage Limited’ provides leveraged (margin) trading, on an execution only basis for its client’s in Forex and CFD trading.

It is Seven Capitals Foreign Brokerage Limited’ decision as to what markets to offer its clients and we will deal with you as principle and counter-party to each trade, providing you with two-way price quotes. As such, every market offered by Seven Capitals Foreign Brokerage Limited is quoted as a derivative of the underlying market and we are the only execution venue to which you have access through us.

Seven Capitals Foreign Brokerage Limited acknowledges that if you are a Retail Client, you may rely upon us to provide or display bid and offer prices which are the best available prices for retail investors on a consistent basis.

Seven Capitals Foreign Brokerage Limited will act in accordance with the best interests of our clients when placing orders with other entities for execution.

Seven Capitals Foreign Brokerage Limited has established this policy along with other arrangements to meet our overarching obligation to take all reasonable steps to obtain the best possible result for our clients.

Seven Capitals Foreign Brokerage Limited has an obligation to provide its clients with appropriate information on this policy. In order to comply with this obligation, the firm will make this policy available to clients upon written request.

Seven Capitals Foreign Brokerage Limited’ Execution Policy forms part of our Client Agreement and as such, by agreeing to the Client Agreement you are agreeing to the terms of our Order Execution Policy. This policy applies equally to orders and trades for both Retail and Professional Customers.

When Seven Capitals Foreign Brokerage Limited decides to deal, we will carry out the trade by executing the order directly in the market ourselves. The price feed streamed to clients consists of liquidity from various bank and non-bank providers to ensure the client has the best execution possible. We do not aggregate or allocate client orders when Straight Line Processing trades flow to Seven Capitals Foreign Brokerage Limited’ liquidity providers.

Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from Information Commissioner’s Office (“ICO”). Under certain circumstances, by law you have the right to:

Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. Therefore we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.

Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate interest in doing so.

Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us via our compliance team as per details below. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.

Our websites or apps may have links to external third party websites. Please note that third party websites are not covered by this privacy notice and those websites are not subject to Seven Capitals Foreign Brokerage Limited’ privacy standards and procedures. Please check with each third party regarding their privacy standards and procedures.

We want to provide you with better and improved experience through constant technology development. This may result in a change to the way in which personal information is collected or used. The impact of any technology changes which may affect your privacy will be notified in this privacy notice at the time of change.

Seven Capitals Foreign Brokerage Limited takes the safeguarding of your data very seriously. Seven Capitals Foreign Brokerage Limited has taken measures and precautions to protect the security of your personal information. Our employees understand to respect the confidentiality of your personal information. We have a Security Officer to ensure our compliance with this privacy policy and applicable laws and regulations.

We hold personal information in secure computer storage facilities, paper-based files, and/or other records. When we consider that personal information is no longer needed, we will remove any details that will identify you and we will securely destroy the records.

Please note that we are subject to certain laws and regulations which require us to retain a copy of the documents we used to comply with our customer due diligence obligations, and supporting evidence and records of transactions with you and your relationship with us for a minimum period of five (5) years after our relationship with you has terminated.

Personal information held in the form of a deed is subject to a storage period of twelve (12) years after our relationship with you has terminated.

If we hold any personal information in the form of a recorded communication, by telephone, electronic, in person or otherwise, this information will be held in line with local regulatory requirements which will either be five (5) or ten (10) years after our relationship with you has terminated.

Where you have opted out of receiving marketing communications, we will hold your details on our suppression list so that we know you do not want to receive these communications.

We may, in the standard operation of our business, share selected information to the following:

credit providers, any relevant governmental, or law enforcement authority as required by law or as agreed with you Our insurers, agents, service providers, specialist advisers, suppliers and subcontractors who provide us with insurance, administrative, IT, financial, verification, regulatory, compliance research or other services Professional advisors such as our solicitors in connection with any ongoing or prospective legal proceedings or in order to establish, exercise or defend our legal rights, and our auditors and accountants in order to satisfy our regulatory and financial reporting obligations

• Introducing brokers and affiliates with whom we have a mutual relationship;
• Credit reporting and reference agencies
• Any member of our group, meaning our subsidiaries, our ultimate holding company and its subsidiaries, and successors in title to our business
• Anyone authorised by you.

Generally, we require that third parties who handle or obtain your personal information acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with all the relevant data protection laws and this privacy notice. Where any third party uses your personal data as data controller, such use is not covered by this privacy notice and is not subject to Seven Capitals Foreign Brokerage Limited’ privacy standard and procedures.

Please note that third parties such as credit reporting and reference agencies may keep a record of any searches and may use the search details to assist other companies in performing their searches.

We may collect the following types of information from actual or potential customer:

Where the use of your personal information by us requires your consent, such consent will be provided in accordance with the applicable customer terms and conditions available on our website(s) or any other contract we may have entered into with you or stipulated in our communication with you from time to time.

Where we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw your consent at any time by contacting us using the contact details set out below.

We may collect the following types of information from actual or potential customer:

Name

address

contact details including but not limited to phone number

email address

Date of birth and gender

Professional and employment details

ID and/or passport number

National/tax identification number

Information about your income and wealth including details about your assets and liabilities, account balances, tax and financial statements

Trading history and performance

Social media or other network data when these technologies are used by you to communicate with Seven Capitals Foreign Brokerage Limited

Any other similar informationobligation.

We obtain this information through your use of our services or other dealings with us including through any of our websites, apps, the account opening applications, demo sign up, webinar sign up, subscribing to news updates and from information provided in the course of ongoing customer communication. We may collect this information about you from third parties either through bought-in third party marketing lists, publicly available sources or through our ‘refer a friend’ scheme. When we do so, we ensure that any third party providing personal data to us have the required consent from the data subject to disclose the personal data to Seven Capitals Foreign Brokerage Limited.

We may ask for other personal information voluntarily from time to time and if you choose not to provide the information we require to fulfil your request for a certain product or service, we may not be able to provide you with the requested product or service and it could mean that we need to terminate the service or account you have with us.

Please note that we keep records of your trading history including:

Products you trade and their performance

Products we trade on your behalf and their performance

Historical data about the trades and investments you made including the amount invested

Your preference for certain types of services and products

We may record any communications, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be our sole property and constitute evidence of the communications between us. Any telephone conversation may be recorded without the use of a warning tone or any other further notice. We record calls in order to fulfil our regulatory obligation. Please note that our offices or premises may have CCTV which will record your image.

Seven Capitals Foreign Brokerage Limited Foreign Brokerage Limited: Registered Addresses- Headquarter: Level-6 Ken Lee Building, 20 Edith Cavell Street, Port Luis 11302, Mauritius. Marketing Office: 403, API World Tower, Sheikh Zayed Road, World Trade Center 1, Dubai UAE. P O Box 47425. We are authorized and regulated by the Financial Services Commission as An Investment Broker in Global Business with the License/registration No. GB 21026349.

Seven Capitals Foreign Brokerage Limited recognizes the vital importance of protecting your personal and financial information. This enables us to provide you with a secure website for your transactions. This privacy policy details how we manage the personal information provided to us by you or a third party in connection with our provision of services to you or which we collect from your use of our services and/or our app(s) or website(s).

The General Data Protection Regulation 2018 require that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way

Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes

Relevant to the purposes we have told you about and limited only to those purposes.

Accurate and kept up to date

Kept only as long as necessary for the purposes we have told you about

Kept securely

We reserve the right to change and amend this privacy notice from time to time to take into consideration new technology, changes to our operations and practices and new laws and regulations. Our most current privacy policy will govern any personal information we hold on you.

The company reserves the right to cancel the client’s request for withdrawal due to any of the following reasons:

When the client has been asked to provide the company with updated identification information and the client has failed to provide valid KYC information and/or banking account details and/ or statement within 7 (seven) days. The company shall inform the client that the reason for the cancellation of the withdrawal is due to the failure of the client to provide the updated identification information. The company will ask the client to resubmit his/her withdrawal request once the requested identification information has been done.

When the client has not provided full and/or correct withdrawal information while submitting his withdrawal request, the company shall inform the client that the reason for the cancellation is due to failure on his behalf to provide full and/or correct withdrawal information to the company.

When the client has selected an incorrect withdrawal method, the company shall inform the client that the reason for the cancellation is the selection of the incorrect withdrawal method.

All withdrawal requests are processed from Monday to Friday between 10 am to 7 pm GST. All requests received outside of these hours will be processed on the next business day.

The company does not carry out funds withdrawals to bank cards held by a third party.

Clients need to ensure that there is sufficient free margin in their accounts to cover the withdrawal. If not, the client may choose to close some open positions in their account before requesting a withdrawal.

The company cannot send more funds back to the client’s credit card than initially deposited; if additional amounts need to be withdrawn funds will be sent using an alternative payment gateway (i.e. wire transfer or any e-wallet).

Funds cannot be refunded to expired credit /debit cards. If the card processor is unable to process the withdrawal request, the company’s back-office team may contact the client to discuss the alternative available methods.

If there is a profit made on the client’s account or restrictions that prevent the company from returning funds to the depositing card, the company may return funds to its registered bank account. The company will only be able to do this if a bank document is provided containing the relevant information.

Withdrawals are processed by the company within 24 hours of the request. The funds will be posted to the clients:

1. Bank wire transfers normally take 3 – 5 business days
2. Debit/credit card within one business week
3. E-Wallets within 24 to 48 hours
4. Credit card processor limits (per transaction):

• Minimum: no minimum amount
• Maximum: up to USD2,000.00

In case of no trading activity by the client after depositing or any form of abuse is found relating to the reimbursement policy, the company reserves the right to reclaim any reimbursement fees, including a 50% deposit commission refund. If the client request to withdraw funds after no trading activity, the company reserves the right to charge the client an equivalent amount of any banking or other payment gateways fees incurred, or 3% of the total withdrawal amount.

As per the general rule of AML regulations, withdrawals must be performed only through the same bank account or credit/debit card that the client used to deposit the funds. All withdrawals will be sent in the name of the account holder.

The client may be required to present additional information and documents.

The company withdrawal fees do not cover third–party fees. The client will be solely responsible for any fees assessed by a beneficiary or correspondent bank. Any processing fees charges by the client’s bank, which are not included in the company withdrawal fees, may be deducted from wire proceeds.

There may be a delay if the company is unable to verify the client’s information.

The clients are responsible for notifying the company of any canceled/stolen or change of details before requesting a withdrawal, additional documents and an official letter from the client’s bank may be required before effecting the amendments or canceled/stolen cards.

If an account has been deemed inactive (no trading activity) for six months, the company will apply an inactivity fee of 5 USD. These fees will be applied at the end of six months that the client has been dormant and the month thereon until the account has been classified as active.

The client acknowledges that he has read, understood, and accepted the withdrawal conditions as amended and reviewed on a regular and ongoing basis, in addition to any other information and/or policy and/or agreements available on the Company’s website:

www.fx7capitals.com

Seven Capitals Foreign Brokerage Limited: Registered Addresses- Headquarter: Level-6 Ken Lee Building, 20 Edith Cavell Street, Port Luis 11302, Mauritius. Marketing Office: 403, API World Tower, Sheikh Zayed Road, World Trade Center 1, Dubai UAE. We are authorized and regulated by the Financial Services Commission as An Investment Broker in Global Business with the License/registration No. GB 21026349.

The withdrawal conditions are provided by the company to its clients under the Execution Order Policy as amended from time to time. The clients must read carefully and understand the conditions set out hereinbefore proceeding with their withdrawal request.