Terms-And-Conditions - JFX.com

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Part A: GENERAL TERMS AND CONDITIONS

Transaction Fees For Clients

Please Note:
Jiffix Markets Ltd does not charge any fees for client deposit or withdrawals.
Clients making both deposit and withdrawals via Wire Transfers will be subject to the transferring bank(s) wiring fees.
For clients funding their accounts via Credit Card, MoneyBookers, Webmoney and Boleto Bancario – specific fees apply.

• For those funding via Credit Card, you will be charged 2.5% of your deposit amount depending on the deposit currency chosen and the nation of origin of the funds.
• For those funding via WebMoney, Jiffix Markets Ltd will credit your Trading Account with the net amount received (after deduction of charges paid by Jiffix Markets Ltd to WebMoney in relation to the amounts transferred to Jiffix Markets Ltd.
• For those funding via MoneyBookers, Jiffix Markets Ltd will credit your Trading Account with the net amount received (after deduction of charges paid by Jiffix Markets Ltd to MoneyBookers in relation to the amounts transferred to Jiffix Markets Ltd.
• For those funding via Boleto Bancario, Jiffix Markets Ltd will credit your Trading Account with the net amount received (after deduction of charges paid by Jiffix Markets Ltd to Boleto Bancario in relation to the amounts transferred to Jiffix Markets Ltd.

1. Parties and Introduction
1.1. The Agreement is entered by and between Jiffix Markets Limited (“the Company”) on the one part and the Client (which may be a legal entity or a natural person) who has completed the Application Form and has been accepted by the Company as its client (“the Client”) on the other part.
1.2. The Company is authorised and regulated by the Cyprus Securities and Exchange Commission (“CySEC”) as a Cyprus Investment Firm (“CIF”) to offer certain investment and ancillary services and activities, under the Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law of 2007, Law 144(I)/2007, as subsequently amended from time to time (“the Law”), with CIF license number 156/11. It is registered in Cyprus under the Companies Law, with registration number HE 290786. Its registered office is at Agias Fylaxeos Street & Amissou Street, 134, 4nd Floor, P.C. 3087 Limassol, Cyprus.

1.3. This Client Agreement with its Appendices 1-6 (“Services”, “Client Categorisation”, “Investor Compensation Fund”, “Risks Disclosures and Acknowledgements”, Policy to Act in the Best Interest of the Client”, “Conflicts of Interest Policy”) found on the Company’s Website, as amended from time to time (together “the Agreement”) set out the terms upon which the Company will offer services to the Client and shall govern all CFDs trading activity of the Client with the Company during the course of the Agreement. In addition, the Agreement sets out the matters which the Company is required to disclose to the Client under the Applicable Regulations.
1.4. The Agreement overrides any other agreements, arrangements, express or implied statements made by the Company or any Introducer(s).
1.5. Where the Client comprises two or more persons, the liabilities and obligations under the Agreement shall be joint and several. Any warning or other notice given to one of the persons which form the Client shall be deemed to have been given to all the persons who form the Client. Any Order given by one of the persons who form the Client shall be deemed to have been given by all the persons who form the Client.
1.6. In the event of the death or mental incapacity of one of the persons who form the Client, all funds held by the Company or its Nominee(s), will be for the benefit and at the order of the survivor(s) and all obligations and liabilities owed to the Company will be owed by such survivor(s).

2. Definitions
2.1. In this Agreement (Client Agreement and Appendices):
“Access Data” shall mean the Login and Password of the Client (which are required to place Orders with the Company on the Company Online Trading System); the Account Number, the Phone Password and telephone number (which are required to place Orders with the Company via phone); or any other codes or passwords which are essential in order to place Orders with the Company.
“Application Form” or “Client Account Opening Questionnaire” shall mean the application form/questionnaire completed by the Client (online or in a hard copy) in order to apply for the Company’s Services under this Agreement, via which the Company will obtain amongst other things information for the Client’s identification and due diligence, his categorization and appropriateness in accordance with the Applicable Regulations.
“Affiliate” shall mean in relation to the Company, any entity which directly or indirectly controls or is controlled by the Company, or any entity directly or indirectly under common control with the Company; and “control” means the power to direct or the presence of ground to manage the affairs of the Company or entity.
“Agreement” shall mean this Client Agreement and its Appendices 1-6, as amended from time to time, and any subsequent Appendices added thereto.
“Applicable Rate” shall mean:

Bank of Canada Bank Rate, if the Currency of the Client Account is in Canadian Dollar;
Bank of England Official Bank Rate, if the Currency of the Client Account is in Great Britain Pound;
Bank of Japan Discount Rate, if the Currency of the Client Account is in Japanese Yen;
European Central Bank (repo) Interest Rate, if the Currency of the Client Account is in Euro;
Federal Funds Rate, if the Currency of the Client Account is US Dollar;
Monetary Authority of Singapore Interest Rate, if the Currency of the Client account is in Singapore Dollar;
Reserve Bank of Australia Official Interest Rate, if the Currency of the Client Account is in Australian Dollar;
Reserve Bank of New Zealand Official Cash Rate, if the Currency of the Client Account is in New Zealand Dollar;
Swiss National Bank Key Interest Rate, if the Currency of the Client Account is in Swiss Franc.

“Applicable Regulations” shall mean:

- CySEC Rules or any other rules of a relevant regulatory authority having powers over the Company;
- the Rules of the relevant Underlying Market; and
- all other applicable laws, rules and regulations of Cyprus or of the European Union.

“Ask” shall mean the higher price in a Quote at which the price the Client may buy.
“Balance” shall mean the total financial result in the Client Account after the last Completed Transaction and depositing/withdrawal operation at any period of time.
“Base Currency” shall mean the first currency in the Currency Pair against which the Client buys or sells the Quote Currency.
“Bid” shall mean the lower price in a Quote at which the Client may sell.
“Business Day” shall mean any day, other than a Saturday or a Sunday, or the 25th of December, or the 1st of January or any other Cyprus or international holidays to be announced on the Company’s Website.
“Client Account” shall mean the exclusive personalised account of the Client consisting of all Completed Transactions, Open Positions and Orders in the Company Online Trading System, the balance of the Client money and deposit/withdrawal transactions of the Client money.
“Client Terminal” shall mean the MetaTrader program version 4, or later version, in addition to any platform trading facilitates including (but not limited to) web and mobile traders, which are used by the Client in order to obtain information on underlying markets in real-time, to make technical analysis of the markets, make Transactions, place / delete / modify Orders, as well as to receive notices from the Company and keep record of Transactions.
“Closed Position” shall mean the opposite of an Open Position.
“Company Online Trading System” shall mean the Software used by the Company which includes the aggregate of its computer devices, software, databases, telecommunication hardware, a trading platform, all programs and technical facilities providing real-time Quotes, making it possible for the Client to obtain information of Underlying Markets in real time, make technical analysis on the markets, enter into Transactions, place / delete / modify Orders, receive notices from the Company and keep record of Transactions and calculating all mutual obligations between the Client and the Company. The Company Online Trading System consists of the Server and the Client Terminal.
“Completed Transaction” shall mean two counter deals of the same size (opening a position and closing a position): buy then sell and vice versa.
“Contract for Differences” or “CFD” shall mean the Financial Instrument which is a contract for differences by reference to variations in the price of an Underlying Asset, although the Company on its Website or in advertisements or on the Company Online Trading System or in practice may use a different name for different types of CFDs depending on the Underlying Asset.
“Contract Specifications” shall mean the principal trading terms in CFDs (for example these may include Margin, Spread, Swaps, Lot Size, Initial Margin, Necessary Margin, Hedged Margin, Normal Market Size, the minimum level for placing Stop Loss, Take Profit and Limit Orders, financing charges, ticket fees for Swap Free Client Accounts, Company Costs, charges, minimum deposit requirements for different types of Client Accounts etc) for each type of CFD and / or type of Client Account as determined by the Company from time to time in its discretion. The Contract Specifications appear on the Website of the Company.
“Currency of the Client Account” shall mean the currency that the Client Account is denominated in, which may be Australian Dollar, British Pound, Canadian Dollar, Euro, Hong Kong Dollar, Japanese Yen, New Zealand Dollar, Singapore Dollar, Swiss Franc and US Dollar or any other currency as offered by the Company from time to time.
“Currency Pair” shall mean the object or Underlying Asset of a CFD Transaction based on the change in the value of one currency against the other. A Currency Pair consists of two currencies (the Quote Currency and the Base Currency) and shows how much of the Quote currency is needed to purchase one unit of the Base Currency.
“Custody Account” shall mean an account of the Client with the Company or a sub-custodian whereby Client Securities will be held in safe custody.
“Custody Services” shall have the meaning of paragraph 35.1.
“CySEC” shall mean the Cyprus Securities and Exchange Commission, which is the Company’s supervisory authority.
“CySEC Rules” shall mean the Rules, Directives, Regulations, Guidance notes of CySEC.
“Eligible Counterparty” shall mean an “Eligible Counterparty” for the purposes of the CySEC Rules, as determined in Appendix 2.
“Equity” shall mean the Balance plus or minus any Floating Profit or Loss that derives from an Open Position and shall be calculated as: Equity = Balance + Floating Profit - Floating Loss.
“Error Quote” or “Spike” shall mean an error Quote having the following characteristics:

a significant Price Gap; and
in a short period of time the price rebounds with a Price Gap; and
before it appears there have been no rapid price movements; and
before and immediately after it appears that no important macroeconomic indicators and/or corporate reports are released.

“Event of Default” shall have the meaning given in paragraph 18.1.
“Expert Advisor” shall mean a mechanical online trading system designed to automate trading activities on an electronic trading platform/system. It can be programmed to alert the Client of a trading opportunity and can also trade his account automatically managing all aspects of trading operations from sending orders directly to the Company Online Trading System to automatically adjusting stop loss, trailing stops and take profit levels.
“Financial Instrument(s)” shall mean the Financial Instruments in the Company’s CIF license appearing in Appendix 1.
“Floating Profit/Loss” shall mean current profit/loss on Open Positions calculated at the current Quotes (added any commissions or fees if applicable).
“Force Majeure Event” shall have the meaning as set out in paragraph 19.1.
“Free Margin” shall mean the amount of funds available in the Client Account, which may be used to open a position or maintain an Open Position. Free Margin shall be calculated as: Equity less (minus) Necessary Margin [Free margin = Equity- Necessary Margin].
“Hedged Margin” shall mean the necessary margin required by the Company so as to open and maintain Matched Positions for each type of CFD.
“Indicative Quote” shall mean a Quote at which the Company has the right not to accept any Instructions or execute any Orders.
“Introducer” shall mean a third party who introduces prospective clients to the Company.
“Initial Margin” shall mean the necessary margin required by the Company so as to open a position for each type of CFD.
“Instruction” shall mean an instruction from the Client to the Company to open or close a position or to place or delete an Order.
“Leverage” shall mean a ratio in respect of Transaction Size and Initial Margin. 1:100 ratio means that in order to open a position, the Initial Margin is one hundred times less than the Transactions Size.
“Long Position” shall mean a buy position that appreciates in value if Underlying Market prices increase. For example in respect of Currency Pairs: buying the Base Currency against the Quote Currency.
“Lot” shall mean a unit measuring the Transaction amount specified for each Underlying Asset of a CFD.
“Lot Size” shall mean the number Underlying Assets in one Lot.
“Margin” shall mean the necessary guarantee funds so as to open or maintain Open Positions for each type of CFD.
“Margin Call” shall mean the situation when the Company informs the Client to deposit additional Margin when the Client does not have enough Margin to open or maintain open positions.
“??rgin Level” shall mean the percentage of Equity to Necessary Margin ratio. It is calculated as: Margin Level = (Equity / Necessary Margin) x 100%.
“Margin Trading” shall mean Leverage trading when the Client may make Transactions having less funds on the Client Account in comparison with the Transaction Size.
“Matched Positions” shall mean Long and Short Positions of the same Transaction Size opened on the Client Account for the same CFD.
“Necessary Margin” shall mean the necessary margin required by the Company so as to maintain Open Positions, for each type of CFD.
“Normal Market Size” shall mean the maximum number of units of the Underlying Asset that are transmitted by the Company for execution for each type of CFD.
“Open Position” shall mean any position which has not been closed, a Long Position or a Short Position which is not a Completed Transaction.
“Order” shall mean an instruction from the Client to the Company to open or close a position when the price reaches the Order Level.
“Order Level” shall mean the price indicated in the Order.
“Parties” shall mean the parties to this Client Agreement – the Company and the Client.
“Politically Exposed Persons” shall mean:

natural persons who are or have been entrusted with prominent public functions, which means: heads of State, heads of government, ministers and deputy or assistant ministers; members of parliaments; members of supreme courts, of constitutional courts or of other high-level judicial bodies whose decisions are not subject to further appeal, except in exceptional circumstances; members of courts of auditors or of the boards of central banks; ambassadors, chargés d’affaires and high-ranking officers in the armed forces; members of the administrative, management or supervisory bodies of State-owned enterprises. None of the categories set out in the above shall be understood as covering middle ranking or more junior officials. Further, where a person has ceased to be entrusted with a prominent public function within the meaning of the above definition for a period of at least one year, such persons shall not be considered a Politically Exposed Person.
The immediate family members of such persons as set out under definition (a), which means: the spouse; any partner considered by national law as equivalent to the spouse; the children and their spouses or partners; and the parents.
Persons known to be close associates of such persons as set out under definition (a), which means: any natural person who is known to have joint beneficial ownership of legal entities or legal arrangements, or any other close business relations, with a person referred to in definition (a); any natural person who has sole beneficial ownership of a legal entity or legal arrangement which is known to have been set up for the benefit de facto of the person referred to in definition (a).

“Price Gap” shall mean the following:

- the current Quote Bid is higher than the Ask of the previous Quote; or
- the current Quote Ask is lower than the Bid of the previous Quote.

“Professional Client” shall mean a “Professional Client” for the purposes of CySEC Rules, as specified in Appendix 2.
“Quote” shall mean the information of the current price for a specific Underlying Asset, in the form of the Bid and Ask prices.
“Quote Currency” shall mean the second currency in the Currency Pair which can be bought or sold by the Client for the Base Currency.
“Quotes Base” shall mean Quotes Flow information stored on the Server.
“Quotes Flow” shall mean the stream of Quotes in the Company Online Trading System for each CFD.
“Request” shall mean a request from the Client to the Company given to obtain a Quote. Such a Request does not constitute an obligation to make a Transaction.
“Retail Client” shall mean a “Retail Client” for the purposes of the CySEC Rules, as specified in Appendix 2.
“Securities” shall mean shares, bonds, futures contracts, units in collective investment undertakings, money-market instruments, negotiable instruments and other Financial Instruments, which may be accepted by the Company for safekeeping.
“Server” shall mean the Meta trader program version 4, or later version, in addition to any platform trading facilitates including (but not limited to) web and mobile traders. The program is used to execute the Client’s Orders or Instructions or Requests, to provide trading information in real-time mode (the content is defined by the Company), in consideration of the mutual liabilities between the Client and the Company.
“Services” shall mean the services provided by the Company to the Client which are set out in paragraph 6.
“Short Position” shall mean a sell position that appreciates in value if underlying market prices fall. For example, in respect of Currency Pairs: selling the Base Currency against the Quote Currency. Short Position is the opposite of a Long Position.
“Slippage” shall mean the difference between the expected price of a Transaction in a CFD, and the price the Transaction is actually executed at. Slippage often occurs during periods of higher volatility (for example due to due to news events) making an Order at a specific price impossible to execute, when market orders are used, and also when large orders are executed when there may not be enough interest at the desired price level to maintain the expected price of trade.
“Spread” shall mean the difference between Ask and Bid of an Underlying Asset in a CFD at that same moment.
“Swap” or “Rollover” shall mean the interest added or deducted for holding a position open overnight.
“Trailing Stop” shall mean a stop-loss order set at a percentage level below the market price - for a long position. The trailing stop price is adjusted as the price fluctuates. A sell trailing stop order sets the stop price at a fixed amount below the market price with an attached “trailing” amount. As the market price rises, the stop price rises by the trail amount, but if the pair price falls, the stop loss price doesn't change, and a market order is submitted when the stop price is hit.
“Transaction” shall mean any CFD transaction transmitted for execution on behalf of the Client or entered into with the Client or executed on behalf of the Client under this Agreement.
“Transaction Size” shall mean Lot Size multiplied by number of Lots.
“Underlying Asset” shall mean the underlying asset in a CFD which may be Currency Pairs, equity indices, metals, commodities and forwards or any other asset available for CFD trading with the Company according to the Company’s discretion from time to time.
“Underlying Market” shall mean the relevant market where the Underlying Asset is traded.
“Website” shall mean the Company’s website at http://www.jfx.com or such other website as the Company may maintain from time to time.
“Written Notice” shall have the meaning set out in paragraph 13.2.
2.2. Words importing the singular shall import the plural and vice versa. Words importing the masculine shall import the feminine and vice versa. Words denoting persons include corporations, partnerships, other unincorporated bodies and all other legal entities and vice versa.
2.3. Paragraph headings are for ease of reference only and are not intended to denote meaning.
2.4. Any reference to any act or regulation or law shall be that act or regulation or law as amended, modified, supplemented, consolidated or re-enacted from time to time, all guidance noted, directives statutory instruments or orders made pursuant to such and any statutory provision of which that statutory provision is a re-enactment or modification.

3. Client Account Opening Procedure
3.1. After each prospective client fills in and submits a signed and dated Application Form together with all the identification documentation requested by the Company, the Company will perform all internal Company checks (including without limitation anti-money laundering checks and appropriateness tests) and the Company will send the prospective client a notice informing him whether he has been accepted as a client of the Company or not. The Agreement will take effect and commence on the date on which the Client receives a notice from the Company informing him that he has been accepted as the Company’s client and that a Client Account has been opened for him. It is understood that the Company is not to be required (and may be unable under Applicable Regulations) to accept any person as its client until all documentation it requires has been received by the Company, properly and fully completed by such person, and all internal Company checks (including without limitation anti-money laundering checks and appropriateness tests) have been completed to the Company’s satisfaction.
3.2. In the event that the Client is accepted by the Company as its client, the Company will open a Client Account for him, which will be activated upon the Client depositing the minimum initial deposit of 100 US Dollars or other amount in other currency (according to the Currency of the Client Account) as determined by the Company in its discretion from time to time.

4. Client Categorisation
4.1. According to Applicable Regulations, the Company will treat the Client as a Retail Client, Professional Client or Eligible Counterparty (“ECP”), depending on the information provided by the Client in his Application Form and according to the method of categorisation as this method is explained under the title “Client Categorisation” (Appendix 2). By accepting this Agreement the Client accepts application of such method. The Company will inform the Client of his categorization.
4.2. The Client accepts that when categorising the Client and dealing with him, the Company will rely on the accuracy, completeness and correctness of the information provided by the Client in his Application Form and the Client has the responsibility to immediately notify the Company in writing if such information changes at any time thereafter.
4.3. The Company gives different levels of regulatory protection to each Client category and hence to Clients within each category. In particular, Retail Clients are afforded the most regulatory protection; Professional Clients and ECPs are considered to be more experienced, knowledgeable and sophisticated and able to assess their own risk and are thus afforded fewer regulatory protections.

4.4. The Client has the right to request a different Categorisation thus to increase or decrease the level of regulatory protections afforded. Where a Client requests a different categorisation (either on an overall level or on a product level), the Client needs to meet certain specified quantitative and qualitative criteria (for more details as to the procedure please refer to Appendix 2). However, if the above-mentioned criteria are not met, the Company reserves the right to choose whether to provide services under the requested classification.

4.5. It is understood that the Company has the right to review the Client’s Categorisation and change his Categorisation if this is deemed necessary (subject to Applicable Regulations).

5. Suitability and Appropriateness Test
5.1. It is understood that when providing the Client with reception and transmission and execution Services, the Company is not required to assess the suitability of the Financial Instrument in which the Client wishes to transact, nor the service(s) provided or offered to him. As a result, the Client will not benefit from the protection of the Applicable Regulations as regards the assessment of suitability.
5.2. The Company is obliged under Applicable Regulations to obtain information about the Client’s knowledge and experience in the investment field so that it can assess whether the service or product envisaged is appropriate for the Client. If the Client elects not to provide such information to the Client, or if the Client provides insufficient information, the Company will not be able to determine whether the service or product envisaged is appropriate for the Client. The Company shall assume that information about his knowledge and experience provided from the Client to the Company is accurate and complete and the Company will have no responsibility to the Client if such information is incomplete or misleading or changes or becomes inaccurate and the Company will be deemed to have performed its obligations under Applicable Regulations, unless the Client has informed the Company of such changes.

6. Services
6.1. Subject to the Client’s obligations under the Agreement being fulfilled, the Company may at its discretion offer the following Services to the Client:

Receive and transmit Orders of the Client in CFDs.
Execution of Orders on behalf of the Client in CFDs.
Provide Custody Services (as and if applicable) and/or provide related services such as cash/collateral management, as described in PART C of this Client Agreement.
Provide Foreign Currency Services provided they are associated with the provision of the reception and transmission service of paragraph 6.1.(a).

6.2. The Services provided by the Company under paragraph 6.1.(a) and (b) may involve margined transactions or transactions in Underlying Assets which are: traded on exchanges which are not recognized or designated investment exchanges; and/or not traded on any stock or investment exchange.

6.3. The Company reserves the right, at its discretion, at any time to withdraw the whole or any part of the Services on a temporary or permanent basis and the Client agrees that the Company will have no obligation to inform the Client of the reason.

7. Advice
7.1. The Company will not advise the Client about the merits of a particular Transaction or give him any form of investment advice and the Client acknowledges that the Services do not include the provision of investment advice in Financial Instruments including CFDs or the Underlying Markets. The Client alone will enter into Transactions and will take relevant decisions based on his own judgement. In asking the Company to enter into any Transaction, the Client represents that he has been solely responsible for making his own independent appraisal and investigation into the risks of the Transaction. He represents that he has sufficient knowledge, market sophistication, professional advice and experience to make his own evaluation of the merits and risks of any Transaction. The Company gives no warranty as to the suitability of the products traded under this Agreement and assumes no fiduciary duty in its relations with the Client.
7.2. The Company will not be under any duty to provide the Client with any legal, tax or other advice relating to any Transaction. The Client may wish to seek independent advice before entering into a Transaction.

8. Market Commentary
8.1. The Company may, from time to time and at its discretion, provide the Client (or in newsletters which it may post on its Website or provide to subscribers via its Website or otherwise) with information, recommendations, news, market commentary or other information but not as a service. Where it does so:

the Company will not be responsible for such information;
the Company gives no representation, warranty or guarantee as to the accuracy, correctness or completeness of such information or as to the tax or legal consequences of any related Transaction;
this information is provided solely to enable the Client to make his own investment decisions and does not amount to investment advice or unsolicited financial promotions to the Client;
if the document contains a restriction on the person or category of persons for whom that document is intended or to whom it is distributed, the Client agrees that he will not pass it on to any such person or category of persons;
the Client accepts that prior to despatch, the Company may have acted upon it itself to made use of the information on which it is based. The Company does not make representations as to the time of receipt by the Client and cannot guarantee that he will receive such information at the same time as other clients.

8.2. It is understood that market commentary, news, or other information provided or made available by the Company are subject to change and may be withdrawn at any time without notice.

9. Currency Conversions
9.1. The Company is entitled, without prior notice to the Client, to effect any currency conversions which it deems necessary or desirable in order to make a deposit into the Client Account in the Currency of the Client Account or comply with its obligations or exercise its rights under this Agreement or complete any specific Transaction or Order. Any such conversion shall be made by the Company at reasonable exchange rates as the company shall select, having regards to the prevailing rates.
9.2. The Client will bear all foreign currency exchange risk arising from any Transaction or the exercise by the Company of its rights under the Agreement or any law.

10. Commissions, Charges and Other Costs
10.1. The provision of Services is subject to the payment of costs, fees, custody fees, commissions, custody fees, daily funding for CFDs, charges to the Company (the “Costs”), which are set out in the Contract Specifications or on the Company Website. In addition to Costs, other commissions and charges may be due by the Client directly to third parties. The Client shall be obliged to pay all such costs.

10.2. Certain types of Costs may appear as a percentage of the value of the CFD, therefore the Client has the responsibility to understand how Costs are calculated.

10.3. When providing a Service to a Client, the Company may pay or receive fees, commissions or other non-monetary benefits from third parties or Introducers as far as permissible under Applicable Regulations. To the extent required by law, the Company will provide information on such benefits to the Client on request.

10.4. Details of any taxes which the Company is required to pay on the Client’s behalf will be stated on Confirmations issued to the Client. The Client may also be liable for other taxes which are not collected by the Company and the Client should seek independent expert advice if he is in any doubt as to whether he may incur any further tax liabilities. Tax laws are subject to change from time to time.
10.5. The Client shall be solely responsible for all filings, tax returns and reports on any Transactions which should be made to any relevant authority, whether governmental or otherwise, and for payment of all taxes (including but not limited to any transfer or value added taxes), arising out of or in connection with any Transaction.
10.6. The Client undertakes to pay all stamp expenses relating to this Agreement and any documentation which may be required for the currying out of the transactions under this Agreement.
10.7. The Company may vary its Costs from time to time. The Company will send a Written Notice to the Client informing of any changes, before they come into effect. The variation will take effect from the date which the Company specifies in its notification to the Client. The Company will endeavour to provide the Client with at least two Business Days notice of such alteration save where such alteration is based on a change in interest rates or tax treatment or it is otherwise impractical for the Company to do so.
10.8. Swaps are calculated with the basis of the interbank market price.
10.9. All CFDs conducted with the Company relate to open-ended margined products that require funding on a daily basis.
10.10. Any amount which is not paid in accordance with paragraphs 10.1, 10.4 or elsewhere in this Agreement on the due date therefore shall bear interest at the Applicable Rate plus 4% per annum, for each day for which such amount remains unpaid.

11. Confirmations and Statements
11.1. Information on Order(s) status, Client Account status, Trade Confirmations and messaging facility between the Parties will be sent to the Client either in electronic form by e-mail to the email address which the Company will have on record and/or provided via its internal mail system of the Company Online Trading System.
11.2. The Client is obliged to provide the Company with e-mail address for the purposes of paragraph 11.1. It is the Client’s responsibility to inform the Company of any change to his email address (or any other relevant personal information), the non-receipt of a Confirmation, or whether any Confirmations are incorrect before settlement.
11.3. The Company will send to the Client, in the method specified above in paragraph 11.2, a Trade Confirmation in respect of each executed Order. Trade Confirmations will be sent prior to the close of the back office on the Business Day following the day on which the Order is executed or if the confirmation is received from a third party, no latter than the first business day following receipt of the confirmation.
11.4. If the Client has a reason to believe that the Confirmation is inconsistent or if the Client does not receive any Confirmation (though the Transaction was made), the Client shall contact the Company. Trade confirmations shall, in the absence of manifest error, be deemed conclusive unless the Client notifies the Company in writing to the contrary within two (2) Business Days following the Day of receipt of the said Trade Confirmation.
11.5. If the Company holds Client money and/or Securities, it shall send to him at least once every year a statement of those funds and Securities unless such a statement has been provided in any other periodic statements.
11.6. The Company will provide the Client with an online access to his Client Account via the Company Online Trading System, which will provide him with sufficient information in order to manage his Client Account and comply with CySEC Rules in regards to client reporting requirements, therefore the Company may not be providing the Client with a separate annual statements (as stated in paragraph 11.5).

12. Language
12.1. The Company’s official language is the English language and the Client should always read and refer to the main Website for all information and disclosures about the Company and its activities. Translation or information provided in languages other than English is for informational purposes only and do not bind the Company or have any legal effect whatsoever, the Company having no responsibility or liability regarding the correctness of the information therein.
13. Communications and Written Notices
13.1. Unless the contrary is specifically provided in this Agreement, any notice, instruction, request or other communication to be given to the Company by the Client under the Agreement shall be in writing and shall be sent to the Company’s address below (or to any other address which the Company may from time to time specify to the Client for this purpose) by email, facsimile, post if posted in Cyprus, or airmail if posted outside Cyprus, or commercial courier service and shall be deemed delivered only when actually received by the Company at:
Address: 155,157 Agias Fylaxeos St & Spyrou Kyprianou Avenue, Ersi Court, 2nd Floor, Office No. 202, P.C. 3083 Limassol, Cyprus.
Tel: +357-25385501

Fax: +357-25336086
Email: cth@jiffix.com
13.2. In order to communicate with the Client, the Company may use any of the following: email; Company Online Trading System internal mail; facsimile transmission; telephone; post; commercial courier service; air mail; or the Company’s Website. The methods of communication specified in this paragraph are also considered a Written Notice from the Company.
13.3. Any communications sent to the Client (documents, notices, confirmations, statements etc.) are deemed received:
(a) if sent by email, within one hour after emailing it;
(b) if sent by Company Online Trading System internal mail, immediately after sending it;
(c) if sent by facsimile transmission, upon receipt by the sender of a transmission report from its facsimile machine confirming receipt of the message by recipient’s facsimile machine during the Business Hours at its destination;
(d) if sent by telephone, once the telephone conversation has been finished;
(e) if sent by post, seven calendar days after posting it;
(f) if sent via commercial courier service, at the date of signing of the document on receipt of such notice;
(g) if sent by air mail, eight Business Days after the date of their dispatch;
(h) if posted on the Company Webpage, within one hour after it has been posted.
13.4. In order to communicate with the Client the Company will use the contact details provided by the Client on the Application Form or as updated latter on. Hence, the Client has an obligation to notify the Company immediately of any change in the Client’s contact details.
13.5. Faxed documents received by the Company may be electronically scanned and reproduction of the scanned version shall constitute conclusive evidence of such faxed instructions.
14. Website, Company Online Trading System and Safety
14.1. The Client will not proceed and avoid proceeding in any action that could probably allow the irregular or unauthorised access or use of the Company Online Trading System. The Client accepts and understands that the Company reserves the right, in its discretion, to terminate or limit his access to the Company Online Trading System or part of if the Company suspects that he allowed such use.
14.2. When using the Company Online Trading System the Client will not, whether by act or omission, do anything that will or may violate the integrity of the Company computer system or Company Online Trading System or cause such system(s) to malfunction.
14.3. The Client is solely responsible for providing and maintaining the compatible equipment necessary to access and use the Company Online Trading System.
14.4. The Client is permitted to store, display, analyse, modify, reformat and print the information made available to him through the Company’s website or Company Online Trading System. The Client is not permitted to publish, transmit, or otherwise reproduce that information, in whole or in part, in any format to any third party without the Company’s express written consent. The Client must not alter, obscure or remove any copyright, trademark or any other notices that are provided in connection with the information. The Client represents and warrants that he will not use the Company Online Trading System in contravention of this Agreement, that he will use the Company Online Trading System only for the benefit of his Client Account and not on behalf of any other person, and that he will not use (or allow another person to use) any software, program, application or other device, directly or indirectly, to access or obtain information through the Company Online Trading System or automate the process of accessing or obtaining such information.
14.5. The Client agrees to keep secret and not to disclose any Access Data to any person.
14.6. The Client should not write down his Access Data. If the Client receives a written notification of his Access Codes, he must destroy the notification immediately.
14.7. The Client agrees to notify the Company immediately if he knows or suspects that his Access Data has or may have been disclosed to any unauthorised person. The Company will then take steps to prevent any further use of such Access Data and will issue the with replacement Access Data. The Client will be unable to place any Orders via the Company Online Trading System until he receives the replacement Access Data.
14.8. The Client agrees that he will co-operate with any investigation the Company may conduct into any misuse or suspected misuse of his Access Data.
14.9. The Client acknowledges that the Company bears no responsibility if unauthorized third persons have access to information, including electronic addresses, electronic communication, personal data and Access Data when the above are transmitted between the parties or any other party, using the internet or other network communication facilities, post, telephone, or any other electronic means.

15. Personal Data, Confidentiality, Recording of Telephone Calls and Records
15.1. The Company may collect Client information directly from the Client (in his completed Application Form or otherwise) or from other persons including, for example, credit reference agencies, fraud prevention agencies and the providers of public registers.
15.2. The Company will use, store, process and handle personal information provided by the Client (in case of a natural person) in connection with the provision of the Services, in accordance the Processing of Personal Data (Protection of the Individual) Law of 2001.
15.3. Client information which the Company holds is to be treated by the Company as confidential and will not be used for any purpose other than in connection with the provision of the Services and for marketing purposes (if the Client’s consent is obtained). Information already in the public domain, or already possessed by the Company without a duty of confidentiality will not be regarded as confidential.
15.4. The Company has the right to disclose client information including recordings and documents of a confidential nature in the following circumstances:
(a) where required by law or a competent Court;
(b) where requested by CySEC or any other regulatory authority having control or jurisdiction over the Company or the Client or their associates or in whose territory the Company has Clients;
(c) to relevant authorities to investigate or prevent fraud, money laundering or other illegal activity;
(d) to execution venues or any third party as necessary to carry out Client Instructions or Orders and for purposes ancillary to the provision of the Services;
(e) to credit reference and fraud prevention agencies and other financial institutions for credit checking, fraud prevention, anti-money laundering purposes, identification or due diligence of the Client;
(f) to the Company’s professional advisors provided that in each case the relevant professional shall be informed about the confidential nature of such information and commit to the confidentiality herein obligations as well;
(g) to other service providers who create, maintain or process databases (whether electronic or not), offer record keeping services, email transmission services, messaging services or similar services which aim to assist the Company collect, storage, process and use Client information or get in touch with the Client or improve the provision of the Services under this Agreement;
(h) to data reporting service providers;
(i) to other service providers for statistical purposes in order to improve the Company’s marketing, in such a case the data will be provided in an aggregate form;
(j) to market research call centers that provide telephone or email surveys with the purpose to improve the services of the Company;
(k) where necessary in order for the Company to defend or exercise its legal rights;
(l) at the Client’s request or with the Client’s consent;
(m) to an Affiliate of the Company;
(n) to a nominee, third party, depository, Authorized Organization or custodian where the Company may hold Client Securities.
15.5. If the Client is an individual, the Company is obliged to supply the Client, on request, with a copy of personal data which it holds about the Client (if any), provided that the Client pays an administrative fee.
15.6. By entering into this Agreement, the Client will be consenting to the transmittal of the Client’s personal data outside the European Economic Area, according to the provisions of Processing of Personal Data (Protection of the Individual) Law of 2001.
15.7. Telephone conversations between the Client and the Company may be recorded and recordings will be the sole property of the Company. The Client accepts such recordings as conclusive evidence of the Orders/Instructions/Requests or conversations so recorded.
15.8. The Client accepts that the Company may, for the purpose of administering the terms of the Agreement, from time to time, make direct contact with the Client by telephone, fax, or otherwise.
15.9. Under Applicable Regulations, the Company will keep records containing Client personal data, trading information, account opening documents, communications and anything else which relates to the Client for at least five years after termination of the Client Agreement.

16. Amendment of the Agreement
16.1. Unless provided differently elsewhere in this Agreement, the Company has the right to amend the terms of the Agreement at any time giving to the Client at least five Business Days Written Notice prior to such changes. Any such amendments will become effective on the date specified in the notice. The Client acknowledges that a variation which is made to reflect a change of law or regulation may, if necessary, take effect immediately.

17. Termination of the Agreement
17.1. Each Party may terminate this Agreement with immediate effect by giving at least five Business Days Written Notice to the other Party.
17.2. Termination by any Party will not affect any obligation which has already been incurred by either Party in respect of any Open Position or any legal rights or obligations which may already have arisen under the Agreement or any Transactions and deposit/withdrawal operations made there under.
17.3. Upon termination of this Agreement, all amounts payable by the Client to the Company will become immediately due and payable including (but without limitation):

all outstanding Costs, custody fees and any other amounts payable to the Company;
funds as necessary to close positions which have already been opened;
any dealing expenses incurred by terminating the Agreement and charges incurred for transferring the Client’s investments to another investment firm;
any losses and expenses realised in closing out any Transactions or settling or concluding outstanding obligations incurred by the Company on the Client’s behalf;
any charges and additional expenses incurred or to be incurred by the Company as a result of the termination of the Agreement;
any damages which arose during the arrangement or settlement of pending obligations;
transfer fees for Client funds of Securities;
registration fees for Securities;
withholding taxes in relation to Securities;
fees of any nominee, third party, Associate, depository, Authorized Organization or custodian in relation to Securities;
any other pending obligations of the Client under the Agreement.

17.4. Upon Termination the Company reserves the right to without prior notice to the Client:

keep Client’s funds as necessary to pay the Company all amounts due of paragraph 17.3.
combine any Client Accounts of the Client, consolidate the Balances in such Client Accounts and to setoff those Balances;
close the Client Account;
cease to grant the Client access to the Company Online Trading System;
convert any currency ;
suspend or freeze or close any open positions or reject Orders;
sell any Client Securities to pay the Company all amounts due of paragraph 17.3.

17.5 Upon Termination if there is Balance in the Client’s favour or any remaining Securities, the Company will (after withholding money or Securities of the Client in such amounts that in the Company’s absolute discretion considers appropriate in respect of future liabilities) pay such Balance or transfer the remaining Securities to the Client as soon as reasonably practicable and supply him with a statement showing how that Balance or remaining Securities was arrived at and, where appropriate, instruct any Nominee or/and any Custodian to also pay any applicable amounts. Such funds and Securities shall be delivered in accordance to the Client’s instructions to the Company.

18. Default
18.1. Each of the following constitutes an “Event of Default”:

the failure of the Client to provide any Initial Margin and/or Hedged Margin, or other amount due under the Agreement;
the failure of the Client to perform any obligation due to the Company;
If an application is made in respect of the Client pursuant to the Cyprus Bankruptcy Act or any equivalent act in another Jurisdiction (if the Client is an individual), if a partnership, in respect of one or more of the partners, or if a company, a receiver, trustee, administrative receiver or similar officer is appointed, or if the Client makes an arrangement or composition with the Client’s creditors or any procedure which is similar or analogous to any of the above is commenced in respect of the Client;
where any representation or warranty made by the Client in paragraph 21 is or becomes untrue;
the Client is unable to pay the Client’s debts when they fall due;
the Client (if the Client is an individual) dies or is declared absent or becomes of unsound mind;
any other circumstance where the Company reasonably believes that it is necessary or desirable to take any action set out in paragraph 18.2;
the Client involves the Company in any type of fraud or illegality.
an action set out in paragraph 18.2 is required by a competent regulatory authority or body or court;
in cases of material violation by the Client of the requirements established by legislation of the Republic of Cyprus or other countries, such materiality determined in good faith by the Company;
if the Company suspects that the Client is engaged into money laundering activities or terrorist financing or other criminal activities.

18.2. If an Event of Default occurs the Company may, at its absolute discretion, at any time and without prior Written Notice, take one or more of the following actions:

terminate this Agreement without notice which will give the Company the right to perform any or all of the actions of paragraph 17.4;
combine any Client Accounts of the Client, consolidate the Balances in such Client Accounts and to setoff those Balances;
close the Client Account;
cease to grant the Client access to the Company Online Trading System;
convert any currency;
suspend or freeze or close any open positions or reject Orders;
refuse to accept Client Orders;
refuse to open new Client Accounts for the Client;

19. Force Majeure
19.1. A Force Majeure Event includes without limitation each of the following:

Government actions, the outbreak of war or hostilities, the threat of war, acts of terrorism, national emergency, riot, civil disturbance, sabotage, requisition, or any other international calamity, economic or political crisis;
Act of God, earthquake, tsunami, hurricane, typhoon, accident, storm, flood, fire, epidemic or other natural disaster;
Labour disputes and lock-out;
Suspension of trading on a Market, or the fixing of minimum or maximum prices for trading on a Market, a regulatory ban on the activities of any party (unless the Company has caused that ban), decisions of state authorities, governing bodies of self-regulating organizations, decisions of governing bodies of organized trading platforms;
A financial services moratorium having been declared by appropriate regulatory authorities or any other acts or regulations of any regulatory, governmental, or supranational body or authority;
Breakdown, failure or malfunction of any electronic, network and communication lines (not due to the bad faith or wilful default of the company);
Any event, act or circumstances not reasonably within the Company’s control and the effect of that event(s) is such that the Company is not in a position to take any reasonable action to cure the default;
The suspension, liquidation or closure of any market or the abandonment or failure of any event to which the Company relates its Quotes, or the imposition of limits or special or unusual terms on the trading in any such market or on any such event.

19.2. If the Company determines in its reasonable opinion that a Force Majeure Event exists (without prejudice to any other rights under the Agreement) the Company may without prior notice and at any time take any or all of the following steps:

increase Margin requirements without notice;
close out any or all Open Positions at such prices as the Company considers in good faith to be appropriate;
suspend or modify the application of any or all terms of the Agreement to the extent that the Force Majeure Event makes it impossible or impractical for the Company to comply with them;
take or omit to take all such other actions as the Company deems to be reasonably appropriate in the circumstances with regard to the position of the Company, the Client and other clients;
increase Spreads;
decrease Leverage.

19.3. Except as expressly provided in this Agreement, the Company will not be liable or have any responsibility for any type of loss or damage arising out of any failure, interruption, or delay in performing its obligations under this Agreement where such failure, interruption or delay is due to a Force Majeure event.

20. Limitations of Liability and Indemnity
20.1. In the event the Company provides information, recommendations, news, information relating to transactions, market commentary or research to the Client (or in newsletters which it may post on its Website or provide to subscribers via its Website or otherwise), the Company shall not, in the absence of its fraud, willful default or gross negligence, be liable for any losses, costs, expenses or damages suffered by the Client arising from any inaccuracy or mistake in any such information given. Subject to the right of the Company to void or close any Transaction in the specific circumstances set out the Agreement, any Transaction following such inaccuracy or mistake shall nonetheless remain valid and binding in all respects on both the Company and the Client.
20.2. The Company will not be held liable for any loss or damage or expense or loss incurred by the Client in relation to, or directly or indirectly arising from but not limited to:

any error or failure in the operation of the Company Online Trading System;
any delay caused by the Client Terminal;
Transactions made via the Client Terminal;
any failure by the Company to perform any of its obligations under the Agreement as a result of Force Majeure Event or any other cause beyond its control;
the acts, omissions or negligence of any third party;
any person obtaining the Client’s Access Data that the Company has issued to the Client prior to the Client’s reporting to the Company of the misuse of his Access Data;
all Orders given through and under the Client’s Access Data;
unauthorized third persons having access to information, including electronic addresses, electronic communication, personal data and Access Data when the above are transmitted between the Parties or any other party, using the internet or other network communication facilities, post, telephone, or any other electronic means;
a delay transmitting any Order for Execution;
the solvency, acts or omissions of any third party referred to in this paragraph 10.6;
if a situation of paragraph 10.7. arises;
currency risk;
Slippage;
any of the risks relating to CFDs trading materialises;
any changes in the rates of tax;
any actions or representations of the Introducer;
the Client relying on Trailing Stop and/or Expert Adviser;
the Client relying in Stop Loss or Stop Limit Orders;
the solvency, act or omission of a third party, or nominee, or register, or depositary or Authorized organization or custodian where the Company may hold Client Securities.

20.3. If the Company incurs any claims, damage, liability, costs or expenses, which may arise in relation to the execution or as a result of the execution of the Agreement and/or in relation to the provision of the Services and/or in relation to any Order it is understood that the Company bears no responsibility whatsoever and it is the Client’s responsibility to indemnify the Company for such.
20.4. The Company shall in no circumstances be liable to the Client for any consequential, special or indirect losses, damages, loss of profits, loss of opportunity (including in relation to subsequent market movements), costs or expenses the Client may suffer in relation to the Agreement.

21. Representations and Warranties
21.1. The Client represents and warrants to the Company the following:

the information provided by the Client to the Company in the Application Form and at any time thereafter is true, accurate and complete and the documents handed over by the Client are valid and authentic;
the Client has read and fully understood the terms of the Agreement including the information in the Appendices;
the Client is duly authorised to enter into the Agreement, to give Orders, Instructions and Requests and to perform its obligations hereunder;
the Client is acting as a principal and not as agent or representative or trustee or custodian on behalf of someone else. The Client may act on behalf of someone else only if the Company specifically consents to this in writing and provided all the documents required by the Company for this purpose are received;
the Client is the individual who has completed the Application Form or, if the Client is a company, the person who has completed Application Form on the Client’s behalf is duly authorised to do so;
all actions performed under the Agreement will not violate any law or rule applicable to the Client or to the jurisdiction in which the Client is resident, or any agreement by which the Client is bound or by which any of the Client’s assets or funds are affected;
the Client funds and Securities are not in any direct or indirect way the proceeds of any illegal activity or used or intended to be used for terrorist financing;
the Client funds and Securities are free of any lien, charge, pledge or other encumbrance;
the documents handed over by the Client are valid and authentic;
the Client has chosen the particular type of service and Financial Instrument, taking his total financial circumstances into consideration which he consider reasonable under such circumstances;

the Client has declared in the Application Form if he is a Politically Exposed Person and will notify the Company if at any stage during the course of this Agreement he becomes a Politically Exposed Person;
there are no restrictions on the markets or Financial Instruments in which any transactions will be sent for execution, depending on the Client’s nationality or religion.

22. Client Acknowledgements of Risk and Consents
22.1. The Client unreservedly acknowledges and accepts that:

Trading in CFDs is not suitable for all members of the public and the Client runs a great risk of incurring losses and damages as a result of trading in CFDs and accepts and declares that he is willing to undertake this risk. The damages may include loss of all his money and /or Securities and also any additional commissions and other expenses.

CFDs carry a high degree of risk. The gearing or leverage often obtainable in CFDs means that a small deposit or down payment can lead to large losses as well as gains. It also means that a relatively small movement can lead to a proportionately larger movement in the value of the Client’s investment and this can work against him as well as for him. CFD Transactions have a contingent liability, and the Client should be aware of the implications of this in particular the margining requirements.

Trading on an electronic Company Online Trading System carries risks.

22.2. The Client agrees and understands that:

he will not be entitled to delivery of, or be required to deliver, the Underlying Asset of the CFD, nor ownership thereof or any other interest therein.
no interest shall be due on the money or Securities that the Company holds in his Client Account and the Custody Account.
when trading in CFDs the Client is trading on the outcome of the price of an Underlying Asset and that trading does not occur on a Regulated Market but Over-The-Counter (OTC).

22.3. The Client consents to the provision of the information of the Agreement and in particular the Appendices by means of a Website.
22.4. The Client confirms that he has regular access to the internet and consents to the Company providing him with information, including, without limitation, information about amendments to the terms and conditions, costs, fees, this Agreements, Policies and information about the nature and risks of investments by posting such information on the Website

23. Complaints and Disputes
23.1. If the Client wishes to report a complaint, he must send an email to the Company’s Customer Support Department. The Following information will need to be included:

Client name and surname;
Client Account number;
Detailed enquiry description;
The affected transaction numbers, if applicable;
The date and time that the issue arose.

23.2. The Company will try to reply within five Business Days from the receipt of the Client complaint. If the complaint requires further investigation and the Company cannot resolve it within five Business Days, the Company will issue a holding response. When a holding response is sent, it will indicate when the Company will make further contact (which should be within eight weeks of receipt of the Complaint).
23.3. If a situation arises which is not expressly covered by this Agreement, the Parties agree to try to resolve the matter on the basis of good faith and fairness and by taking such action as is consistent with market practice.
23.4. The Client’s right to take legal action remains unaffected by the existence or use of any complaints procedures referred to above.

24. Applicable and Governing Law and Applicable Regulations
24.1. If a settlement is not reached by the means described in paragraph 23, all disputes and controversies arising out of or in connection with the Agreement shall be finally settled in court in Cyprus.
24.2. This Agreement is governed by the Laws of Cyprus.
24.3. Notwithstanding any other provision of this Agreement, in providing Services to the Client the Company shall be entitled to take any action as it considers necessary in its absolute discretion to ensure compliance with the relevant market rules and or practices and all other applicable laws.
24.4. All transactions on behalf of the Client shall be subject to Applicable Regulations and any other public authorities which govern the operation of the Cyprus Investment Firms, as they are amended or modified from time to time. The Company shall be entitled to take or omit to take any measures which it considers desirable in view of compliance with the Applicable Regulations in force at the time. Any such measures as may be taken and the Applicable Regulations in force shall be binding on the Client.

25. Severability
25.1. Should any part of this Agreement be held by any Court of competent jurisdiction to be unenforceable or illegal or contravene any rule, regulation or by law of any Market or regulator, that part will be deemed to have been excluded from this Agreement from the beginning, and this Agreement will be interpreted and enforced as though the provision had never been included and the legality or enforceability of the remaining provisions of the Agreement or the legality, validity or enforceability of this provision in accordance with the law and/or regulation of any other jurisdiction, shall not be affected.

26. Non-Exercise of Rights
26.1. The Company’s failure to seek redress for violations, or to insist upon strict performance, of any condition or provision of this Agreement, or its failure to exercise any or part of any of right or remedy to which the Company is entitled under this Agreement, shall not constitute an implied waiver thereof.

27. Assignment
27.1. The Company may at any time transfer, assign or novate any of its rights, benefits or obligations under this Agreement subject to providing previous notification to the Client.
27.2. The Client may not transfer, assign, charge, novate or otherwise transfer or purport to do so the Client’s rights or obligations under the Agreement without prior written consent of the Company.

28. Introducer
28.1. In cases where the Client is introduced to the Company through an Introducer, the Client acknowledges that the Company is not responsible or accountable or to be held liable for the conduct, representations or inducements of the Introducer and the Company is not bound by any separate agreements entered into between the Client and the Introducer.
28.2. The Client acknowledges and confirms that his agreement or relationship with the Introducer may result in additional costs, since the Company may be obliged to pay commission fees or charges to the Introducer.

29. Third Party Authorisation
29.1 The Client has the right to authorise a third person to place Instructions and/or Orders to the Company or to handle any other matters related to the Client Account, the Custody Account or this Agreement, provided the Client notifies the Company in writing of exercising such a right and this person is approved by the Company fulfilling all of the Company specifications for this.
29.2 Unless the Company receives a written notification from the Client for the termination of the authorisation of the person as described in paragraph 29.1., the Company will continue accepting Instructions and/or Orders and/ or other instructions relating to the Client Account and Custody Account given by this person on the Client’s behalf and the Client will recognize such orders as valid and committing to him.
29.3 The written notification for the termination of the authorization to a third party has to be received by the Company with at least 5 days notice prior the termination of the authorization date.

Part B: CFD TRADING TERMS AND CONDITIONS

30. CFDS Trading
30.1. During the course of this Agreement in relation to individual CFD Transactions the Company will act either receive and transmit the Client Order for execution to a third party, which will be the execution venue and counterparty in the CFD or execute the Client Order itself on an own account basis in which case the Company will be the execution venue and counterparty in the CFD.
30.2. Orders may be placed with the Company either on the Company Online Trading System, through the Client’s compatible personal computer connected to the internet, or via phone with the use of Access Data. Orders via fax will be acceptable only after a special separate agreement between the Parties.
30.3. Apart from the Access Data, Orders made via phone will need to include the following essential details: instrument to the traded, orientation of the trade, trade size, entry price and order type.
30.4. In case of an order received by the Company in any means other than through the Company Online Trading System, the Order will be transmitted eventually by the Company to the Company Online Trading System.
30.5. The Company will be entitled to rely and act on any Order given by using the Client Access Data without any further enquiry to the Client and any such Orders will be binding upon the Client.
30.6. The Company shall receive and transmit for execution or execute Orders given by the Client strictly in accordance with their terms. The Company will have no responsibility for checking the accuracy of any Order. Any Order that the Client gives to the Company constitutes an irrevocable instruction to the Company to proceed with the Transaction on the Client’s behalf.
30.7. Orders can be placed, executed and (if allowed) changed or removed within the trading time From 22:00 Sunday to 22:00 Friday Central European Time (CET) and if they are not executed they shall remain effective through the next trading session (as applicable). All open spot positions will be rolled over to the next business day at the close of business in the relevant Underlying Market, subject to the Company’s rights to close the open spot position. Any open forward positions will be rolled over at the expiry of the relevant period into the next relevant period subject to the Company’s rights to close the open forward position.
30.8. The Company shall not be obliged to, but may, at its absolute discretion, execute the Client’s Orders in respect of any CFD out of normal trading hours.
30.9. The Company may establish cut-off times for instructions or Orders which may be earlier than the times established by the particular Market and/or clearing house involved in any Transaction and the Client shall have no claims against the Company arising out of the fact that an Order was not placed by the Client ahead of the cut-off time.
30.10. Orders shall be valid in accordance with the type and time of the given Order, as specified by the Client. If the time of validity of the order is not specified, it shall be valid for an indefinite period. However, the Company may delete one or all pending orders if the Client Account Equity reaches zero.
30.11. The following Orders may be given by the Client:

OPEN – to open a position;

CLOSE – to close an open position;

To add, remove, edit orders for Stop Loss, Take Profit, Buy Limit, Buy Stop, Sell Limit, Sell Stop;

30.12. Any other Orders not mentioned in paragraph 6.8 are unavailable and are automatically rejected.
30.13. Orders cannot be changed or removed if a confirmation is sent or they are executed or being executed. The Client has no right to change or remove Limit Orders if the price has reached the level of the Order Execution. If the market price moves close to the value of Take Profit order or Stop Loss order, or the opening price of a deferred order within a distance of 2 points, no modification or removal of such orders is allowed.

30.14. In order to change the expiry date of an Order, the Client will need to cancel the Order (subject to paragraph 6.10) and place a new Order.
30.15. Orders are executed as follows:
(a) CFDs on Currency Pairs:

Take Profit (T/P) orders are executed at stated prices;
Stop Loss (S/L) orders set for lock positions are executed at first tradable market prices;
Limit orders are executed at stated prices;
Buy Stop and Sell Stop orders for position opening are executed at first tradable market prices.

(b) CFD on other Underlying Assets other than Currency Pairs:

- - Take Profit (T/P) orders are executed at stated prices;
  - Limit orders are executed at stated prices;
  - Stop Loss (S/L) orders are executed at first tradable market prices;
  - Buy Stop and Sell Stop orders for the opening position are executed at first tradable market prices.

30.16. In the event that the Company is unable to proceed with a Client order with regard to price or size, will the Company re-quote to the Client a price that the Company is prepared to deal at.
30.17. For an open CFD position that the Client holds in relation to a particular Underlying Asset and then subsequently closes partially, will this position be closed on First in, First out basis (commonly known as FIFO) in relation to the multiple trades undertaken to build the particular position.
30.18. If the Client gives an Order which puts him in breach of any paragraph of this Agreement, the Company may in its absolute discretion fulfil such an Order to the extent it deems appropriate and the Client will not have any right to cancel any resultant partially filled Order. The Client will be liable for the breach of this Agreement and remain liable for the settlement of the resultant Transaction in accordance with the terms of this Agreement.
30.19. The Client acknowledges that Quotes displayed on the Company Website and on the Trading Terminal of the Client are Indicative Quotes.
30.20. The Company provides Quotes by taking into account the Underlying Asset price, but this does not mean that these Quotes are within any specific percentage of the Underlying Asset price. When the relevant Underlying Market is closed, the Quotes provided by the Company will reflect what the Company thinks to be the current Bid and Ask price of the relevant Underlying Asset at that time. The Client acknowledges that such Quotes will be set by the Company at its absolute discretion.
30.21. In the event that the Company is unable to proceed with an Order with regard to price or size or other reason, the Company will not send a re-quote to the Client with the price it is willing to deal.
30.22. The Company will delete Error Quotes (Spikes) from the Server’s Quotes Base.
30.23. The Company is under no obligation, unless otherwise agreed in the Agreement, to monitor or advise the Client on the status of any Transaction or to close out any Client’s Open Positions. When the Company decides to do so, this will be done on a discretionary basis and will not be considered an undertaking of an obligation to continue.
30.24. It is the Client’s responsibility to be aware of his positions at all times.
30.25. Save in the case of Costs and Margin requirements which may change with two days prior notice to the Client, the Company has the right to change the rest of the information in the Contract Specifications at any time without any prior notice to the Client; therefore the Client agrees to check the Contract Specifications of the CFDs before placing an Order.
30.26. The 1 (one) standard lot size is the measurement unit specified for each Financial Instrument. The Company may offer standard lots, micro-lots and mini-lots for different types of CFDs depending in the Underlying Asset, in its discretion, defined as follows: (1.0) standard lot = 100000 of the Underlying Asset, (0.1) mini lot = 10000 of the Underlying Asset (0.01) micro lot = 1000 of Underlying Asset.
30.27. The Client agrees that trading operations using additional functions of the Client Trading Terminal such as Trailing Stop and/or Expert Adviser are executed completely under the Client’s responsibility, as they depend directly on his trading terminal and the Company bears no responsibility whatsoever.

30.28. The Client agrees that placing a Stop Loss Order will not necessarily limit losses to the intended amounts, because market conditions may make it impossible to execute such an Order at the stipulated price and the Company bears no responsibility whatsoever.

31. Margin Requirements
31.1. The Client shall provide and maintain the Initial Margin and/or Hedged Margin in such limits as the Company, at its sole discretion, may determine at any time under the Contract Specifications for each type of CFD.
31.2. It is the Client’s responsibility to ensure that he understands how a Margin is calculated.
31.3. Unless a Force Majeure Event has occurred, the Company has the right to change the Margin requirements, giving to the Client two Business Days Written Notice prior to these amendments. In this situation the Company has the right to apply new Margin requirements to the new positions and to the positions which are already open.
31.4. The Company has the right to change Margin requirements without prior notice to the Client in the case of Force Majeure Event. In this situation the Company has the right to apply new Margin requirements to the new positions and to the positions which are already open.
31.5. If at any time Equity falls below a certain percentage (specified in the Contract Specifications) of the Necessary Margin, the Company has the right to close any or all of the Client’s Open Positions without the Client’s consent or any prior Written Notice to him. In order to determine if the Client has breached this paragraph, any sums referred to therein which are not denominated in the Currency of the Client Account shall be treated as if they were denominated in the Currency of the Client Account by converting them into the Currency of the Client Account at the relevant exchange rate for spot dealings in the foreign exchange market.
31.6. The Client has the responsibility to notify the Company as soon as he believes that he will be unable to meet a Margin payment when due.
31.7. Although the Company may make Margin Calls for the Client it has no obligation to do so.
31.8. Should the Client fail to meet a margin Call, the Company has the right to close part or all of Client’s Open positions.
31.9. Margin must be paid in monetary funds in the Currency of the Client Account. Non-monetary margin is acceptable on a case by case basis and depends on the Company’s discretion. If the Company decided to accept Securities as Margin, the Company will provide Custody Services in relation to such Securities.
31.10. The Client undertakes neither to create nor to have outstanding any security interest whatsoever over, nor to agree to assign or transfer, any of the Margin transferred to the Company.

32. Rejection of Client’s Orders, Requests and Instructions
32.1. Without prejudice to any other provisions herein, the Company is entitled, at any time and at its discretion, without giving any notice or explanation to the Client, to reject any Order or Request or Instruction of the Client, and the Client has no right to claim any damages, specific performance or compensation whatsoever from the Company, in any of the following cases:
(a) if the Order or Request or Instruction precedes the first Quote in the Company Online Trading System on the Market Opening;
(b) under Abnormal Market Conditions;
(c) if the Client has recently made an unreasonable number of Requests in comparison to the number of Transactions;
(d) if the Client’s Free Margin is less than the Initial Margin or the Necessary Margin or there are no available cleared funds deposited in the Client Account to pay all the charges of the particular Order;
(e) it is impossible to proceed with an Order or Instruction regarding the size or price or the proposed Transaction is of such a size (too small or too large), that the Company does not wish to accept that Order or Instruction or Transaction or the Company believes that it will not be able to hedge the proposed Transaction in the Underlying Market or it is impossible for the Order or Request or Instruction to be executed due to condition of the relevant Underlying Market;
(f) where the Company suspects that the Client is engaged in money laundering activities or terrorist financing or other criminal acts;
(g) in consequence of request of regulatory or supervisory authorities of Cyprus or a court order;
(h) where the legality or genuineness of the Order is under doubt;
(i) there is absence of essential detail of the Order or the Order or Request or Instruction is not clear or has more than one interpretation;
(j) the Transaction Size is less than the minimum Transaction Size for the particular CFD as indicated in the Contract Specifications;
(k) a Quote is not obtained from the Company or the Quote obtained by the Company is an Indicative Quote or the Quote is manifestly erroneous or Quote is an Error Quote (Spike);
(l) internet connection or communications are disrupted;
(m) a Force Majeure Event has occurred;
(n) in an Event of Default of the Client;
(o) the Company has sent a notice of Termination of the Agreement to the Client;
(p) the Client has failed to meet a Margin Call of the Company.

33. Swap Free Client Accounts
33.1. The Company offers Swap free Client Accounts for CFD trading in certain Underlying Assets. The Company in its discretion may change the Underlying Assets available for Swap free Client Accounts without prior notice to the Client.
33.2. If the Client has a Swap free Client Account, no Swaps or roll over charges will be applied to trading positions overnight.
33.3. Swap free Client Accounts will be charged a ticket fee which appears in the Contract Specifications or on the Company’s website or will be communicated directly to the Client.
33.4. All the provisions herein in this entire Agreement apply to Swap
free Client Accounts save any mentions to Swaps.
33.5. The Client who has a Swap free Client Account may not hold his floating positions for a long time period and hence gain profits. In such an event, the Client must close the floating positions and Swaps will be applied retroactively.

33.6. Hedging a position by its corresponding CFD contract in a Swap Free Account is forbidden. In such an event, the Client must close the hedges immediately and Swaps will be applied retroactively.

Part C: SAFE CUSTODY AND CLIENT MONEY HANDLING TERMS AND CONDITIONS

34. Client Money and Client Account

34.1. Unless otherwise agreed with the Client in writing and to the extent allowed under Applicable Regulations, the Company will deal with any funds that it holds on the Client Account it holds in accordance with the Applicable Regulations. This means that such Client money will be segregated from the Company’s own money and cannot be used in the course of its business. Upon receipt of the Client money, the Company will promptly place such money into one or more Segregated Client Account(s).

34.2. The Company shall not account to the Client for profits or interest earned on Client money (other than profit gained through trading Transactions from his Client Account(s) under this Agreement) and the Client waives all right to interest.

34.3. The Company may deposit Client money in overnight deposits and will be allowed to keep any interest.

34.4. The Company may hold Client money and the money of other clients in the same bank account (omnibus account).

34.5. The Company may deposit Client money with a third party who may have a security interest, lien or right of set-off in relation to that money.

34.6. Client money may be held on the Client’s behalf with an intermediate broker, a bank, a market, a settlement agent, a clearing house or OTC counterparty located within or outside Cyprus or the EEA. The legal and regulatory regime applying to any such person outside Cyprus or the EEA will be different from that of Cyprus and in the event of the insolvency or any other equivalent failure of that person, the Client’s money may be treated differently from the treatment which would apply if the money was held in a Segregated Account in Cyprus. The Company will not be liable for the solvency, acts or omissions of any third party referred to in this paragraph.

34.7. The third party to whom the Company will pass money may hold it in an omnibus account and it may not be possible to separate it from the Client’s money, or the third party’s money. In the event of the insolvency or any other analogous proceedings in relation to that third party, the Company may only have an unsecured claim against the third party on behalf of the Client, and the Client will be exposed to the risk that the money received by the Company from the third party is insufficient to satisfy the claims of the Client with claims in respect of the relevant account. The Company does not accept any liability or responsibility for any resulting losses.

34.8. The Company is a member of the Investors Compensation Fund (ICF). So, depending on his classification, the Client may be entitled to compensation from the ICF in the event that the Company is unable to meet its obligations as explained in the document with the title “Investors Compensation Fund” (Appendix 3).

34.9. Profit or loss from CFDs trading is deposited in/withdrawn from the Client Account once the Transaction is closed.

34.10. If the Client Account has funds of less than minimum initial deposit of 100 US Dollars or other amount in other currency (according to the Currency of the Client Account) as determined by the Company in its discretion from time to time in the Contract Specifications, the Company reserves the right to close the Client Account, notify the Client accordingly and charge the Client any bank or other related charges.

34.11. If the Client Account is inactive for a calendar year or more, the Company reserves the right to charge an account maintenance fee of as determined by the Company in its discretion from time to time in the Contract Specifications (depending in the Currency of the Client Account) in order to maintain the Client Account open and any bank or other related charges.

35. Custody Services and Custody Account
35.1. Custody Services include safekeeping of the Client’s Securities, maintenance of records, exercising of the rights to Securities (including any encumbrances), transfer of Securities, administration of Securities by means of opening and maintenance of the Custody Account and carrying out operations with such account.

35.2. The Company does not have an obligation to provide Custody Services to the Client or open a Custody Account, with the signing of this Agreement. This is subject to the Company’s approval in its absolute discretion, following a request made by the Client.

35.3. The Custody Account cannot be created unless the Client holds a Client Account with the Company to which the revenue from the Custody Account is created and any custody fees, etc. may be debited.

36. Client Securities
36.1. The Client Securities may be held in the same custody account (omnibus account) with the securities of other Clients, in the name of the Company instead of the Client’s name. Thus the Client is not individually or personally entitled to compensation for any error made by the relevant institution.

36.2. In the event the Company will hold Client Securities in an omnibus custody account, it will maintain a register, clearly stating the individual Client’s ownership to the Securities kept in such omnibus custody account.

36.3. Unless otherwise agreed with the Client in writing and to the extent allowed under Applicable Regulations, the Company will deal with any Securities that it holds on the Custody Account it holds in accordance with the Applicable Regulations. This means that such Client Securities will be segregated from the Company’s own securities and cannot be used in the course of its business. Upon receipt of the Client Securities, the Company will promptly place such Client Securities into one or more Segregated Custody Account(s). For the avoidance of any doubt this does not prohibit the Company from holding Client Securities in omnibus custody accounts.

36.4. Client Securities may be held on the Client’s behalf with a third party located within or outside Cyprus or the EEA. The legal and regulatory regime applying to any such person outside Cyprus or the EEA will be different from that of Cyprus and in the event of the insolvency or any other equivalent failure of that person, the Client’s Securities may be treated differently from the treatment which would apply if the money was held in Cyprus. The Company will not be liable for the solvency, acts or omissions of any third party referred to in this paragraph.

36.5. The third party to whom the Company will pass Client Securities may hold it in an omnibus account and it may not be possible to separate it from the Company’s securities, or the third party’s securities. In the event of the insolvency or any other analogous proceedings in relation to that third party, the Company may only have an unsecured claim against the third party on behalf of the Client, and the Client will be exposed to the risk that the compensation received by the Company from the third party is insufficient to satisfy the claims of the Client with claims in respect of the relevant account. The Company does not accept any liability or responsibility for any resulting losses.

36.6. The Company may hold Client Securities with a third party who may have a security interest, lien or right of set-off in relation to that money.

36.7. The Company may register the Client Securities, without contacting the Client, in a register, depositary, Authorized organization or other custodian to ensure their appropriate safekeeping and record keeping, exercise of rights attached to Securities in cases where the Company considers that exercise of such rights is in the best interest of the Client.

36.8. The Company will not check for any deficiencies, including insufficient title and authenticity of the Securities when submitting or transferring Securities in the Custody Account.

37. Lien
37.1. The Company shall have a general lien on all Client money held by the Company or its Associates or its nominees on the Client’s behalf until the satisfaction of the Client’s obligations.

37.2. The Company shall have a general lien on all Client Securities held by the Company or the Company’s nominees, or register, or depositary or Authorized organization or other custodians on the Client’s behalf until the satisfaction of the Client’s obligations towards the Company.

38. Netting and Set-Off
38.1. If the aggregate amount payable by the Client is equal to the aggregate amount payable by the Company, then the Company may determine that the mutual obligations to make payment are set-off and cancel each other.

38.2. If the aggregate amount payable by one party exceeds the aggregate amount payable by the other party, then the party with the larger aggregate amount shall pay the excess to the other party and all obligations to make payment will be automatically satisfied and discharged.

38.3. The Company has the right to combine all or any Client Accounts opened in the Client name and to consolidate the Balances in such accounts and to set-off such Balances.

39. Reconciliations
39.1. The Company will carry out reconciliations of records and Client money with the records and accounts of the money the Company holds in the Segregated Client Account(s) on a daily basis. If a transfer is required to or from the Segregated Client Account(s) this will be done by the close of business on the day that the reconciliation is performed. The Company has the right, but not an obligation, to carry out reconciliations and transfers more frequently, if it considers that this is necessary to protect the Company’s or a Client’s interests.

39.2. The Company shall quarterly reconcile the records of each register, depositary, Authorized organization or other custodian where it holds Client Securities with those compiled by the Company with respect to each Security held for the Client.

40. Deposits and Withdrawals
40.1. The Client may deposit funds into the Client Account at any time during the course of this Agreement. Deposits will be accepted by bank transfer, Swift, E-wallet, debit / credit card or any other method of electronic money transfer (where the originator is the Client) acceptable by the Company from time to time. The Company shall credit the Client Account within one Business Day after the amount is cleared in the bank account of the Company with the relevant amount. The relevant amount will be net of any transfer fees or other charges incurred by JFX.com that are imposed by the Institution (or intermediary involved in the process) that holds the Funds.

40.2. If the Company agrees to provide Safe Custody Services to the Client, the Client may deposit Securities in the Custody Account, only with the previous consent of the Company, the Company being free to reject such a claim without stating a reason.

40.3. The Company will not accept third party or anonymous payments of funds in the Client Account or third party or anonymous deposits of Securities in the Custody Account.

40.4. The client accepts that the Funds shall be deposited in his/her trading account only if the Company is satisfied that the sender of the Funds is the client or his/ her authorized representative; if JFX.com is not satisfied as to the above then the Company has the right to reject the Funds and return them to the remitter net of any transfer fees or other charges incurred by JFX, using the same transfer method as the one through which it originally received the Funds.

40.5. The Company will effect withdrawals of Client funds or Securities, either upon the receipt of a form bearing the signature of the Client (which must match the specimen signature of the Client or its Representative provided to the Company) or upon an application for withdrawal made via the Company Online Trading System (if available at the time).
40.6. The client accepts that withdrawal of any part of the Funds shall be concluded using the same transfer method and the same remitter as the one which the Company originally received the Funds from; under such circumstances, JFX.com shall return the part of the Funds requested net of any transfer fees or other charges incurred by JFX.

40.7. The Company reserves the right to decline a withdrawal request of the Client asking for a specific transfer method and the Company has the right to suggest an alternative.

40.8. Upon the Company receiving an instruction from the Client to withdraw funds from the Client Account and/or Securities from the Custody Account, the Company shall pay the funds within two Business Days and withdraw the Securities within five Business Days, if the following requirements are met:
(a) the withdrawal instruction includes all necessary information;
(b) the instruction is to make a bank transfer of funds to the account of the Client or a withdrawal of Securities in the name of the Client;
(c) at the moment of payment, the Client’s Free Margin exceeds the amount specified in the withdrawal instruction including all payment charges; and
(d) in relation to Securities, there is no delay or other barrier on behalf of the third party where the Client Securities are held.

40.9. Withdrawals will only be effected towards the Client. The Company will not to effect withdrawals to any other third party or anonymous account.

40.10. The Firm reserves the right to request additional information and/ or documentation to satisfy itself that the request is legitimate. In addition, JFX.com reserves the right to reject such a request if it deems that this may not be legitimate. The client accepts that under such circumstances there may be a delay in processing the request.

40.11. All payment and transfer charges will be borne by the Client and the Company shall debit the Client Account for these charges.

41. Custody Fees and Other Related Expenses
41.1. The Company may charge a custody fee for the provision of the Custody Services, which appears in the Contract Specifications and/or the Company Website.

41.2. Custody fees may be altered by the Company in accordance to paragraph 10.7.

41.3. The Client shall compensate the Company for all incurred expenses connected to registration of Securities in a nominee, or third party, or register, or with an Authorized organization or custodian, for all losses or damage, charges, withholding taxes, any collections or fees (including all legal costs) suffered by the Company in connection with the Custody Services. The Company is allowed to debit such amounts in the Client Account.

41.4. The Company is not obliged to or liable for claiming back any foreign withheld tax in relation to the Securities unless otherwise agreed by the Parties.

41.5. Any dividends on Securities actually received by the Company are credited in the Client Account.

Appendix 1: SERVICES

1. The Company

1.1. Jiffix Markets Ltd (the “Company”) is authorised and regulated by the Cyprus Securities and Exchange Commission (“CySEC”) as a Cyprus Investment Firm (CIF) to offer the services and activities enlisted herein in this document, under the Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law of 2007, Law 144(I)/2007, as subsequently amended from time to time (“the Law”).

1.2. Its CIF license number is 156/11.

2. Investment Services

2.1. Under its CIF License the Company may offer the following Investment Services:

Reception and transmission of orders in relation to one or more Financial Instruments;
Execution of Orders on behalf of Clients;
Dealing on Own Account;
Portfolio Management;
Investment Advice.

3. Ancillary Services

3.1. Under its CIF License the Company may offer the following Ancillary Services:

Safekeeping and administration of Financial Instruments for the account of Clients, including custodianship and related services such as cash/collateral management;
Granting credits or loans to an investor to allow him to carry out a transaction in one or more Financial Instruments where the Company is involved in the transaction;
Foreign exchange services where these services are connected to the provision of investment services;
Investment research and financial analysis of other form.

4. Financial Instruments

4.1. Under its CIF license the Company may offer the above services in relation to certain financial instruments, which have the meaning given to it in paragraph 2 of the Law:

Transferable Securities;
Money-market instruments;
Units in collective investment undertakings;
Options, futures, swaps, forward rate agreements and any other derivative contracts relating to securities, currencies, interest rates or yields, or other derivatives instruments, financial indices or financial measures which may be settled physically or in cash;
Options, futures, swaps, forward rate agreements and any other derivative contracts relating to commodities that must be settled in cash or may be settled in cash at the option of one of the parties (otherwise than by reason of a default or other termination event);
Options, futures, swaps, and any other derivative contract relating to commodities that can be physically settled provided that they are traded on a regulated market and/or an MTF;
Options, futures, swaps, forwards and any other derivative contracts relating to commodities, that can be physically settled not otherwise mentioned in the paragraph above and not being for commercial purposes, which have the characteristics of other derivative financial instruments, having regard to whether, inter alia, they are cleared and settled through recognised clearing houses or are subject to regular margin calls;
Derivative instruments for the transfer of credit risk;
Financial contracts for differences;
Options, futures, swaps, forward rate agreements and any other derivative contracts relating to climatic variables, freight rates, emission allowances or inflation rates or other official economic statistics that must be settled in cash or may be settled in cash at the option of one of the parties (otherwise than by reason of a default or other termination event), as well as any other derivative contract relating to assets, rights, obligations, indices and measures not otherwise mentioned in this Part, which have the characteristics of other derivative financial instruments, having regard to whether, inter alia, they are traded on a regulated market or an MTF, are cleared and settled through recognised clearing houses or are subject to regular margin calls.

Appendix 2

Client Categorisation Notice

Appendix 3

Investor Compensation Fund (ICF) Notice

Appendix 4. RISKS AND IMPORTANT FACTORS FOR FINANCIAL INSTRUMENTS

1. Introduction

1.1. This notice is provided to prospective Clients of Jiffix Markets Ltd (the “Company”) in accordance with the Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law of 2007, Law 144(I)/2007 (the “Law”).

1.2. So, all prospective Clients of the Company, before entering into an agreement with the Company to deal in Financial Instruments, should read carefully the following risk warnings and other important factors contained in this document.

1.3. However, it is noted that this document cannot and does not disclose or explain all of the risks and other significant aspects involved when dealing in Financial Instruments (including derivative financial instruments such as Contracts For Differences). The notice was designed to explain in general terms the nature of the risks involved when dealing in Financial Instruments on a fair and non-misleading basis.

2. General Risk Warning

2.1. The Client should not engage in any investment directly or indirectly in Financial Instruments unless he knows and understands the risks involved for each one of the Financial Instruments.

2.2. The Company will not provide the Client with any investment advice relating to investments or possible transactions in investments or in Financial Instruments or make investment recommendations of any kind. So, prior to entering into an agreement with the Company to trade in Financial Instruments or every time before making an order, the Client should consider carefully whether investing in a specific Financial Instrument is suitable for him in the light of his circumstances and financial resources.

2.3. If the Client does not understand the risks involved he should seek advice and consultation from an independent financial advisor. If the Client still does not understand the risks involved in trading in any Financial Instruments, he should not trade at all.

2.4. The Client should acknowledge that he runs a great risk of incurring losses and damages as a result of the purchase and/or sale of any Financial Instrument and accept that he is willing to undertake this risk.

3. Technical Risks

3.1. While trading via the Online Trading System or by phone or fax the following types of risks may exist (but not limited to):

the Client's or Company's hardware or software may fail, malfunction or be misused;
poor internet connection either on the side of the Client or the Company or both, or interruptions or transmission blackouts or public electricity network failures or hacker attacks, overload of connection;
wrong settings in the Client Terminal;
delayed Client Terminal updates;
the Client disregarding the applicable rules on the Client Terminal or the MetaTrader4;
at times of excessive deal flow the Client may have some difficulties to be connected over the internet or telephone with a dealer of the Company, especially in a Fast Market (for example, when key macroeconomic indicators are released);
delays or other errors caused during the transmission of orders and/or messages via computer or internet;
failure of transmission of information, communication, electronic and other systems.

3.2. The Client may suffer financial losses caused by the materialization of the above risks, the Company accepting no responsibility or liability in the case of such a risk materializing and the Client shall be responsible for all related losses he may suffer.

4. Placing Orders via the Trading System

4.1. Orders may be executed one at a time while being in the queue. Multiple orders from the same Client Account in the same time may not be executed.

4.2. The Client acknowledges that the only reliable source of Quotes Flow information is that of the real/live Server’s Quotes Base. Quotes Base in the Client Terminal is not a reliable source of Quotes Flow information because the connection between the Client Terminal and the Server may be disrupted at some point and some of the Quotes simply may not reach the Client Terminal.

4.3. The Client acknowledges that when the Client closes the Order, it shall not be cancelled.

4.4. In case the Client has not received the result of the execution of the previously sent Instruction but decides to repeat the Instruction, the Client shall accept the risk of making two Transactions instead of one.

4.5. The Client acknowledges that if the Pending Order has already been executed but the Client sends the Instruction to modify its level, the only Instruction, which will be executed, is the Instruction to modify Stop Loss and/or Take Profit levels on the position opened when the Pending Order triggered.

5. Communication between the Client and the Company

5.1. The Client shall accept the risk of any financial losses caused by the fact that the Client has received with delay or has not received at all any notice from the Company.

5.2. The Client acknowledges that the unencrypted information transmitted by e-mail is not protected from any unauthorised access. The Company has no responsibility if unauthorized third persons have access to information, including electronic addresses, electronic communication and personal data, access data when the above are transmitted between the Company and the Client or when using the internet or other network communication facilities, telephone, or any other electronic means.

5.3. The Client is wholly responsible for the privacy of the information received from the Company and accepts the risk of any financial losses caused by the unauthorised access of the third party to the Client’s Account.

5.4. The Client is fully responsible for the risks in respect of undelivered Company Online Trading System internal mail messages sent to the Client by the Company as they are automatically deleted within 3 (three) calendar days.

6. Refusal to Accept Client Orders

6.1. The Company is entitled, at any time and at its discretion, without giving any notice or explanation to the Client, to decline or refuse to transmit or arrange for the execution of any Order or Request or Instruction of the Client, and the Client has no right to claim any damages, specific performance or compensation whatsoever from the Company, in any of the following cases:

if the Order or Request or Instruction precedes the first Quote in the Company Online Trading System on the Market Opening;
under Abnormal Market Conditions;
if the Client has recently made an unreasonable number of Requests in comparison to the number of Transactions;
if the Client’s Free Margin is less than the Initial Margin or the Necessary Margin or there are no available cleared funds deposited in the Client Account to pay all the charges of the particular Order;
it is impossible to proceed with an Order or Instruction regarding the size or price or the proposed Transaction is of such a size (too small or too large), that the Company does not wish to accept that Order or Instruction or Transaction or the Company believes that it will not be able to hedge the proposed Transaction in the Underlying Market or it is impossible for the Order or Request or Instruction to be executed due to condition of the relevant underlying market;
where the Company suspects that the Client is engaged in money laundering activities or terrorist financing or other criminal acts;
in consequence of request of regulatory or supervisory authorities of Cyprus or a court order;
where the legality or genuineness of the Order is under doubt;
there is absence of essential detail of the Order or the Order or Request or Instruction is not clear or has more than one interpretation;
the Transaction Size is less than the minimum Transaction Size for the particular CFD as indicated in the Contract Specifications;
a Quote is not obtained from the Company or the Quote obtained by the Company is an Indicative Quote or the Quote is manifestly erroneous or Quote is an Error Quote (Spike);
internet connection or communications are disrupted;
a Force Majeure Event has occurred;
in an Event of Default of the Client (as this is explained in the Client Agreement document);
the Company has sent a notice of Termination of the Agreement to the Client.

7. Third Party Risk

7.1. The Company may pass money received from the Client to a third party (e.g. an intermediate broker, a bank, a market, a settlement agent, a clearing house or OTC counterparty located outside Cyprus or the) to hold or control in order to effect a Transaction through or with that person or to satisfy the Client’s obligation to provide collateral (e.g. initial margin requirement) in respect of a Transaction. The Company has no responsibility for any acts or omissions of any third party to whom it will pass money received from the Client.

7.2. The legal and regulatory regime applying to any such third party person will be different from that of Cyprus and in the event of the insolvency or any other equivalent failure of that person, the Client’s money may be treated differently from the treatment which would apply if the money was held in a Segregated Account in Cyprus. The Company will not be liable for the solvency, acts or omissions of any third party referred to in this clause.

7.3. The third party to whom the Company will pass money may hold it in an omnibus account and it may not be possible to separate it from the Client’s money, or the third party’s money. In the event of the insolvency or any other analogous proceedings in relation to that third party, the Company may only have an unsecured claim against the third party on behalf of the Client, and the Client will be exposed to the risk that the money received by the Company from the third party is insufficient to satisfy the claims of the Client with claims in respect of the relevant account. The Company does not accept any liability or responsibility for any resulting losses.

7.4. The Company may deposit Client money with a depository who may have a security interest, lien or right of set-off in relation to that money.

7.5. A Bank or Broker through whom the Company deals with could have interests contrary to the Client’s Interests.

8. Force Majeure Events

8.1. In case of a Force Majeure Event the Company may not be in a position to arrange for the execution of Client Orders or fulfill its obligations under the agreement with the Client. As a result the Client may suffer financial loss.

8.2. The Company will not be liable or have any responsibility for any type of loss or damage arising out of any failure, interruption, or delay in performing its obligations under this Agreement where such failure, interruption or delay is due to a Force Majeure event.

9. Abnormal Market Conditions

9.1. The Client acknowledges that under Abnormal Market Conditions the period during which the Orders are executed may be extended or it may be impossible for Orders to be executed at declared prices or may not be executed at all.

10. Foreign Currency

10.1. When a Financial Instrument is traded in a currency other than the currency of the Client’s country of residence, any changes in the exchange rates may have a negative effect on its value, price and performance and may lead to losses for the Client.

11. Commissions and Taxes

11.1. Before the Client begins to trade, he should make himself aware of all commissions and other charges for which he will be liable.

11.2. If any charges are not expressed in monetary terms (but, for example, as a percentage of contract value), the Client should ensure that he understands what such charges are likely to amount to.

11.3. The Company may change its charges at any time.

11.4. There is a risk that the Client’s trades in any Financial Instruments the trade may be or become subject to tax and/or any other duty for example because of changes in legislation or his personal circumstances. The Company does not warrant that no tax and/or any other stamp duty will be payable.

11.5. The Client is responsible for any taxes and/or any other duty which may accrue in respect of his trades.

11.6. It is noted that taxes are subject to change without notice.

12. General Risk Warning For Complex Financial Instruments (Derivative Financial Instruments)

12.1. Although Derivative Financial Instruments can be used for the management of investment risk, some of these products are unsuitable for many investors. Different Derivative Financial Instruments involve different levels of exposure to risk and in deciding whether to trade in such instruments the Client should be aware of the risks and factors contained in this document. However it is noted that this document cannot disclose all the risks and other important aspects of derivative financial instruments such as futures, options, and Contracts for Differences (CFDs).
12.2. The Client should not deal in these products unless he understands their nature and the extent of his exposure to risk and that he may loose entirely all of his money also any additional commissions and other expenses incurred.

12.3. The Client should also be satisfied that the product is suitable for him in the light of his circumstances and financial position.

12.4. Leverage and Gearing

12.4.1. Transactions in foreign exchange and derivative Financial Instruments carry a high degree of risk. The amount of initial margin may be small relative to the value of the foreign exchange or derivatives contract so that transactions are "leveraged" or "geared".

12.4.2. A relatively small market movement will have a proportionately larger impact on the funds the Client has deposited or will have to deposit; this may work against the Client as well as for the Client. The Client may sustain a total loss of initial Margin funds and any additional funds deposited with the Company to maintain his position. If the market moves against the Client’s position and/or Margin requirements are increased, the Client may be called upon to deposit additional funds on short notice to maintain his position. Failing to comply with a request for a deposit of additional funds, may result in closure of his position(s) by the Company on his behalf and he will be liable for any resulting loss or deficit.

12.5. Risk-reducing Orders or Strategies

12.5.1 The placing of certain Orders (e.g. "stop-loss" orders, where permitted under local law, or "stop-limit" Orders), which are intended to limit losses to certain amounts, may not be adequate given that markets conditions make it impossible to execute such Orders, e.g. due to illiquidity in the market. Strategies using combinations of positions, such as "spread" and "straddle"' positions may be as risky as taking simple "long" or "short" positions. Therefore Stop Limit and Stop Loss Orders cannot guarantee the limit of loss.

12.5.2. Trailing Stop and Expert Advisor cannot guarantee the limit of loss.

12.6. Volatility

12.6.1. Some Derivative Financial Instruments trade within wide intraday ranges with volatile price movements. Therefore, the Client must carefully consider that there is a high risk of losses as well as profits. The price of Derivative Financial Instruments is derived from the price of the Underlying Asset in which the Derivative Financial Instruments refer to (for example Currency Pairs, equity indices, metals, commodities and forwards or any other asset available for CFD trading with the Company according to the Company’s discretion from time to time). Derivative Financial Instruments and related Underlying Markets can be highly volatile. The prices of Derivative Financial Instruments and the Underlying Asset may fluctuate rapidly and over wide ranges and may reflect unforeseeable events or changes in conditions, none of which can be controlled by the Client or the Company. Under certain market conditions it may be impossible for a Clients order to be executed at declared prices leading to losses. The prices of Derivative Financial Instruments and the Underlying Asset will be influenced by, amongst other things, changing supply and demand relationships, governmental, agricultural, commercial and trade programs and policies, national and international political and economic events and the prevailing psychological characteristics of the relevant market place.

12.7. Margin

12.7.1. The Client acknowledges and accepts that, regardless of any information which may be offered by the Company, the value of Derivative Financial Instruments may fluctuate downwards or upwards and it is even probable that the investment may become of no value. This is owed to the margining system applicable to such trades, which generally involves a comparatively modest deposit or margin in terms of the overall contract value, so that a relatively small movement in the Underlying Market can have a disproportionately dramatic effect on the Client’s trade. If the Underlying Market movement is in the Client’s favor, the Client may achieve a good profit, but an equally small adverse market movement can not only quickly result in the loss of the Clients’ entire deposit, but may also expose the Client to a large additional loss.

12.8. Liquidity

12.8.1. Some of the Underlying Assets may not become immediately liquid as a result of reduced demand for the Underlying Asset and Client may not be able to obtain the information on the value of these or the extent of the associated risks.

12.9. Futures

12.9.1. Transactions in futures involve the obligation to make, or to take, delivery of the underlying asset of the contract at a future date, or in some cases to settle the position with cash. They carry a high degree of risk. The gearing or Leverage often obtainable in futures trading means that a small deposit or down payment can lead to large losses as well as gains. It also means that a relatively small movement can lead to a proportionately much larger movement in the value of the Client’s investment, and this can work against the Client as well as for the Client. Futures transactions have a contingent liability, and the Client should be aware of the implications of this, in particular the margining requirements, which are set out below.

12.10. Options

12.10.1. Buying options: Buying options involve less risk than selling options because, if the price of the underlying asset moves against the Client, the Client can simply allow the option to lapse. The maximum loss is limited to the premium, plus any commission or other transaction charges. However, if the Client buys a call option on a futures contract and he later exercise the option, he will acquire the future. This will expose the Client to the risks described under “Futures” and “Contingent Liability Investment Transactions”.

12.10.2. Writing options: If the Client writes an option, the risk involved is considerably greater than buying options. The Client may be liable for margin to maintain his position and a loss may be sustained well in excess of the premium received. By writing an option, the Client accepts a legal obligation to purchase or sell the underlying asset if the option is exercised against him, however far the market price has moved away from the exercise price. If the Client already owns the underlying asset which he have contracted to sell (when the options will be known as covered call options) the risk is reduced. If he does not own the underlying asset (uncovered call options) the risk can be unlimited. Only experienced persons should contemplate writing uncovered options, and then only after securing full details of the applicable conditions and potential risk exposure.

12.11. Contracts for Differences

12.11.1. The CFDs available for trading with the Company are non deliverable spot transactions giving an opportunity to make profit on changes in the Underlying Asset (cash indices, index futures, bond futures, commodity futures, spot crude oil, spot gold, spot silver, single stocks, currencies or any other asset according to the Company’s discretion from time to time). If the Underlying Asset movement is in the Client’s favor, the Client may achieve a good profit, but an equally small adverse market movement can not only quickly result in the loss of the Clients’ entire deposit but also any additional commissions and other expenses incurred. So, the Client must not enter into CFDs unless he is willing to undertake the risks of loosing entirely all the money which he has invested and also any additional commissions and other expenses incurred.

12.11.2. Investing in a Contract for Differences carries the same risks as investing in a future or an option and the Client should be aware of these as set out above. Transactions in Contracts for Differences may also have a contingent liability and the Client should be aware of the implications of this as set out below under “Contingent Liability Investment Transactions”.

12.12. Off-exchange transactions in Derivative Financial Instruments

12.12.1. CFDs offered by the Company are off-exchange transactions. While some off-exchange markets are highly liquid, transactions in off-exchange or non transferable derivatives may involve greater risk than investing in on-exchange derivatives because there is no exchange market on which to close out an Open Position. It may be impossible to liquidate an existing position, to assess the value of the position arising from an off-exchange transaction or to assess the exposure to risk. Bid prices and Ask prices need not be quoted, and, even where they are, they will be established by dealers in these instruments and consequently it may be difficult to establish what a fair price is.

12.12.2. In regards to transactions in CFD’s the Company is using an Online Trading System for transactions in CFD’s which does not fall into the definition of a recognized exchange as this is not a Multilateral Trading Facility and so do not have the same protection.

12.13. Contingent Liability Investment Transactions

12.13.1. Contingent liability investment transactions, which are margined, require the Client to make a series of payments against the purchase price, instead of paying the whole purchase price immediately. The Margin requirement will depend on the underlying asset of the Financial Instrument. Margin requirements can be fixed or calculated from current price of the underlying instrument and it can be found on the website of the Company.

12.13.2. If the Client trades in futures, Contracts for Differences or sell options, he may sustain a total loss of the funds he has deposited to open and maintain a position. If the market moves against the Client, he may be called upon to pay substantial additional funds at short notice to maintain the position. If the Client fails to do so within the time required, his position may be liquidated at a loss and he will be responsible for the resulting deficit. It is noted that the Company will not have a duty to notify the Client for any Margin Call to sustain a loss making position.

12.13.3. Even if a transaction is not margined, it may still carry an obligation to make further payments in certain circumstances over and above any amount paid when the Client entered the contract.

12.13.4. Contingent liability investment transactions which are not traded on or under the rules of a recognised or designated investment exchange may expose the Client to substantially greater risks.

12.14. Collateral

12.14.1. If the Client deposits collateral as security with the Company, the way in which it will be treated will vary according to the type of transaction and where it is traded. There could be significant differences in the treatment of the collateral depending on whether the Client is trading on a recognised or designated investment exchange, with the rules of that exchange (and the associated clearing house) applying, or trading off-exchange. Deposited collateral may lose its identity as the Client’s property once dealings on the Client’s behalf are undertaken. Even if the Client’s dealings should ultimately prove profitable, he may not get back the same assets which he deposited, and may have to accept payment in cash.

12.15. Suspensions of Trading

12.15.1. Under certain trading conditions it may be difficult or impossible to liquidate a position. This may occur, for example, at times of rapid price movement if the price rises or falls in one trading session to such an extent that under the rules of the relevant exchange trading is suspended or restricted. Placing a Stop Loss will not necessarily limit the Client’s losses to the intended amounts, because market conditions may make it impossible to execute such an Order at the stipulated price. In addition, under certain market conditions the execution of a Stop Loss Order may be worse than its stipulated price and the realized losses can be larger than expected.

12.16. Clearing House Protections

12.16.1. On many exchanges, the performance of a transaction by the Client is guaranteed by the exchange or clearing house. However, this guarantee is unlikely in most circumstances to cover the Client and may not protect him if he or another party defaults on its obligations to the Client. On request, the Company must explain any protection provided to him under the clearing guarantee applicable to any on-exchange derivatives in which he is dealing. It is noted that there is no clearing house for traditional options, nor normally for off-exchange instruments which are not traded under the rules of a recognised or designated investment exchange.

12.17. Insolvency of the Company

12.17.1. The Company’s insolvency or default, may lead to positions being liquidated or closed out without the Client’s consent. In certain circumstances, the Client may not get back the actual assets which he lodged as collateral and he may have to accept any available payments in cash.

12.17.2. Segregated Funds of Clients in such a case will be subject to the protections conferred by Applicable Regulations.

Appendix 5. BEST EXECUTION POLICY AND POLICY TO ACT IN THE BEST INTEREST OF THE CLIENT

1. Introduction

1.1. Under the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law of 2007, Law 144(I)/2007 (the “Law”), Jiffix Markets Ltd ( the “Company”) is required to provide its Clients and potential Clients with its Best Execution Policy and Policy to Act in the Best Interest of the Client (hereinafter the “Policy”).

1.2. Under the Law, the Company is required to take all reasonable steps to act in the best interest of the Client when receiving and transmitting orders for execution or executing such orders. In addition, these rules require Cyprus Investment Firms to put in place a relevant Policy and to provide appropriate information to their Clients on the Best Interest Policy.

2. Scope of Policy

2.1. The Policy applies to Retail and Professional Clients. So, if the Company classifies a Client as an Eligible Counterparty, this policy does not apply to such a Client.

2.2. The Policy applies to Financial Instruments including Stocks, Bonds, Exchange Traded Funds ("ETFs"), Futures, Options (OTC and exchange traded), Contracts For Difference ("CFDs"), Certificates, Warrants and Mutual Funds.

3. Best Execution Factors and Criteria

3.1. The Company shall take all reasonable steps to obtain the best possible results for its Clients taking into account the following factors when dealing with Clients orders: price, costs, speed, likelihood of execution and settlement, size, market impact or any other consideration relevant to the execution of the order. The Company does not consider the above list exhaustive and the order in which the above factors are presented shall not be taken as priority factor.

3.2. The Company will determine the relative importance of the above Best Execution Factors by using its commercial judgment and experience in the light of the information available on the market and taking into account the criteria described below:

The characteristics of the Client including the categorization of the Client as retail or professional;
The characteristics of the Client order;
The characteristics of financial instruments that are the subject of that order;
The characteristics of the execution venues to which that order can be directed.

3.3. For Retail Clients, the best possible result shall be determined in terms of the total consideration, representing the price of the financial instrument and the costs related to execution, which shall include all expenses incurred by the Client which are directly related to the execution of the order, including execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order.

3.4. Whenever there is a specific instruction from or on behalf of a Client, the Company will – to the extent possible - execute the order in accordance with the specific instruction. A specific instruction from a Client may prevent the Company from taking the steps that it has described in this Policy to obtain the best possible result for the execution of orders. Trading rules for specific markets may prevent the Company from following certain of the Client's instructions. To the extent that a Client instruction is not complete, if the Company does not reject the instruction, it will determine any non-specified components of the execution in accordance with this Policy.

3.5. When the Company executes orders on behalf of retail clients, Best Execution is determined on the basis of the total consideration paid by the Client, unless the objective of execution of the order dictates otherwise.

3.6. Whenever there is a specific instruction from or on behalf of a Client, the Company will – to the extent possible - execute the order in accordance with the specific instruction. A specific instruction from a Client may prevent the Company from taking the steps that it has described in this Policy to obtain the best possible result for the execution of orders. Trading rules for specific markets or market conditions may prevent the Company from following certain of the Client's instructions. To the extent that a Client instruction is not complete, the Company will determine any non-specified components of the execution in accordance with this Policy or reject the order.

4. Price

4.1. For any given CFD, the Company will quote two prices: the higher price (ASK) at which the Client can buy (go long) that CFD, and the lower price (BID) at which the Client can sell (go short) that CFD; collectively they are referred to as the Company’ price. The difference between the lower and the higher price of a given CFD is the spread.

4.2. The Company’ price for a given CFD is calculated by reference to the price of the relevant Underlying Asset (i.e. cash indices, index futures, bond futures, commodity futures, spot crude oil, spot gold, spot silver, single stocks, currencies or any other asset offered by the Company in its discretion from time to time), which the Company obtains from third party external reference sources.

4.3. The Company provides Quotes by taking into account the Underlying Asset price, but this does not mean that these Quotes are within any specific percentage of the Underlying Asset price. When the relevant Underlying Market is closed, the Quotes provided by the Company will reflect what the Company thinks to be the current Bid and Ask price of the relevant Underlying Asset at that time. The Client acknowledges that such Quotes will be set by the Company at its absolute discretion.

4.4. Orders are executed as follows:

4.4.1. Orders on CFD on Currency Pairs:

Take Profit (T/P) orders are executed at stated prices;
Stop Loss (S/L) orders set for lock positions are executed at first tradable market prices;
Limit orders are executed at stated prices;
Buy Stop and Sell Stop orders for position opening are executed at first tradable market prices.

4.4.2. Orders on CFD on other Underlying Assets:

- - Take Profit (T/P) orders are executed at stated prices;
  - Limit orders are executed at stated prices;
  - Stop Loss (S/L) orders are executed at first tradable market prices;
  - Buy Stop and Sell Stop orders for the opening position are executed at first tradable market prices.

5. Costs

5.1. The provision of Services from the Company to the Client is subject to the payment of costs, fees, commissions, charges, daily funding to the Company (the “Costs”).

5.2. In addition to Costs other commissions and charges may be due by the Client directly to third parties. The Client shall be obliged to pay all such costs.

5.3. CFDs available with the Company require daily funding.

6. Speed of Execution

6.1. Orders can be placed, executed and (if allowed) changed or removed within the trading time From 22:00 Sunday to 22:00 Friday Central European Time (CET) and if they are not executed they shall remain effective through the next trading session (as applicable).

6.2. All open spot positions will be rolled over to the next business day at the close of business in the relevant Underlying Market, subject to the Company’s rights to close the open spot position.

6.3. Any open forward positions will be rolled over at the expiry of the relevant period into the next relevant period subject to the Company’s rights to close the open forward position.

6.4. The Company shall not be obliged to, but may, at its absolute discretion, execute the Client’s Orders in respect of any Financial Instrument out of normal trading hours which appear in the Contract Specifications for each Financial Instrument or the Company’s website.

6.5. Company may establish cut-off times for instructions or Orders which may be earlier than the times established by the particular Market and/or clearing house involved in any Transaction and the Client shall have no claims against the Company arising out of the fact that an Order was not placed by the Client ahead of the cut-off time.

6.6. Orders with the Company may be placed on the Company’s Online Trading System via the Client’s computer. The use of wireless or dial up connection or any other form of unstable connection or lack of signal strength or connectivity problems or any telecommunication malfunctions may cause delays in the transmittal of messages between the Client and the Company when using the Company’s Online Trading System. The delay may result in sending Orders out of the Company’s operating times or after cut-off times imposed by the Company and so such Orders may be declined by the Company or executed at the following trading session. It is noted that the Company will not send back an updated price (re-quote) for which it is willing to trade.

6.7. In case of an order received by the Company in any means other than through the Company Online Trading System, the Order will be transmitted eventually by the Company to the Company Online Trading System, a process which may take longer time.

6.8. The Company places a significant importance when transmitting Client’s Orders for execution but within the limitations of technology and communications links at all times.

6.9. It is noted that when receiving and transmitting Client Orders, the Company will not be the counterparty in a CFD transaction but it will transmit the Order to some other Financial Institution for execution, which other Financial Institution will be the execution venue and this process may cause delays. In other cases the Company may execute the Orders itself on an own account basis, in which case it will be the execution venue.

7. Likelihood of Execution

7.1. When the Company transmits Orders, some other Financial Institution(s) will be Execution Venue(s) and execution may be more difficult. This means that likelihood of execution depends on the availability of prices of other market makers/financial institutions. In some case it may not be possible to arrange an Order for execution, for example but not limited in the following cases: during news times, trading session start moments, during volatile markets where prices may move significantly up or down and away from declared prices, where there is rapid price movement, where there is insufficient liquidity for the execution of the specific volume at the declared price, a force majeure event has occurred.

7.2. In the event that the Company is unable to proceed with an Order with regard to price or size or other reason, the Company will not send a re-quote to the Client with the price it is willing to deal.
7.3. The Company is entitled, at any time and at its discretion, without giving any notice or explanation to the Client, to decline or refuse to transmit or arrange for the execution of any Order or Request or Instruction of the Client in circumstances explained in the Client Agreement.

8. Market Impact

8.1. Some factors may affect rapidly the price of the Underlying Assets from which the Company’s quoted price is derived and may also affect the rest of the factors herein. The Company will take all reasonable steps to obtain the best possible result for its Clients.

9. Execution Venues

9.1. Execution Venues are the entities with which the orders are placed. For the purposes of Orders for the Financial Instrument of CFDs, in some cases the Execution Venue may be the Company and in other cases some other third Financial Institution.

9.2. When the Company executes Orders on an own account basis it is a counterparty in the CFD and it is the Execution Venue.

9.3. When the Company receives and transmits an Order for execution to some other Financial Institution, such Financial Institution will be the Execution Venue. These Execution Venues used by the Company are the following:

Appendix 6. CONFLICTS OF INTEREST POLICY

1. Introduction

1.1. Under the Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law of 2007, Law 144(I)/2007 (the “Law”), Jiffix Markets Ltd (the “Company”) is required to take all reasonable steps to detect and avoid conflicts of interest. The Company is committed to act honestly, fairly and professionally and in the best interests of its Clients and to comply, in particular, with the principles set out in the above legislation when providing Investment and Ancillary Services.

1.2. The Company provides herein a summary of the policy it maintains in order to manage conflicts of interests.

2. Scope

2.1. The Policy applies to all its directors, employees, any persons directly or indirectly linked to the Company (hereinafter called “related persons”) and refers to the provision of all Investment and Ancillary Services to all Clients.

3. Identification of Conflicts of Interest

3.1. The Company hereby identifies and discloses a range of circumstances which may give rise to a conflict of interest and potentially but not necessarily be detrimental to the interests of one or more Clients. Such a conflict of interest may arise if the Company, or any person directly or indirectly controlled by the Company or a client, is likely to make a financial gain, or avoid a financial loss, at the expense of a Client or may have an interest, relationship or arrangement that is material in relation to the transaction concerned or that conflicts with the Client’s interest.

3.2. The Company has identified the following circumstances which may give rise to a conflict of interest:

the Company may be matching the Client’s orders with that of another Client by acting on such other Client’s behalf as well as on the Client’s behalf;
the Company may be advising and providing other services to associates or other Clients of the Company who may have interests in Financial Instruments or investments or Underlying Assets, which are in conflict or in competition with the Client’s interests;
the Company may be dealing in the CFD concerned as a counterparty;
the Company may be dealing in the CFD which the Company recommends to the Client (including holding a Long or Short Position);
the Company may have an interest that is contrary to Clients’ transactions, e.g. when the Client trades in securities or Underlying Markets where the Company acts as a market maker or when the Company wishes to invest in the same Financial Instrument as the Client;
the Company’s portfolio managers may trade in securities, CFDs or other Financial Instruments on behalf of the clients knowing that the trades will be beneficial to the Company, its employees’ or related persons’ positions in the same Financial Instruments;
the Company, its employees and related legal persons may have, establish, change or cease to have positions in securities, foreign exchange, CFDs or other Financial Instruments covered by an investment recommendation or advice;
the Company may have an interest in maximizing trading volumes in order to increase its commission revenue, which is inconsistent with the Client’s personal objective of minimizing transaction costs;
the Company’s bonus scheme may award its employees based on the trading volume etc.;
the Company may receive or pay inducements to or from third parties due to the referral of new Clients or Clients' trading;
the Company or a related person has an interest in the outcome of a service provided to the Client or of a transaction carried out on behalf of the Client, which is distinct from the Client's interest in that outcome;
the Company or a related person has a financial or other incentive to favour the interest of another Client or group of Clients over the interests of the Client;
the Company or a related person carries on the same business as the Client.

4. Procedures and Controls to Managing Conflicts of Interests

4.1. In general, the procedures and controls that the Company follows to manage the identified conflicts of interest include the following measures:

Effective procedures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests of one or more Clients.
All employees are bound by professional secrecy and confidential information is only to be shared if essential for performing a job function.
All employees receive instructions and guidance regarding managing of conflicts of interest.
The separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, Clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company.
The removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities.
Measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities.
Chinese walls restricting the flow of confidential and inside information within the Company, and physical separation of departments.
Procedures governing access to electronic data.
Segregation of duties that may give rise to conflicts of interest if carried on by the same individual.
Personal account dealing requirements applicable to relevant persons in relation to their own investments.
A gifts and inducements log registering the solicitation, offer or receipt of certain benefits.
Prohibition of external business interests conflicting with our interests as far as the Company’s officers and employees are concerned, unless Board of Directors approval is provided.
Establishment of in-house Compliance Department to monitor and report on the above to the Company’s Board of Directors.
Appointment of Internal auditor to ensure that appropriate systems and controls are maintained and report to the Company’s Board of Directors.
Establishment of the four-eyes principle in supervising the Company’s activities.
The Company also undertakes ongoing monitoring of business activities to ensure that internal controls are appropriate.

5. Disclosure of Conflicts of Interest

5.1. The Client consents to and authorises the Company to deal with or for the Client in any manner which the Company considers appropriate, notwithstanding any conflict of interest or the existence of any material interest in a transaction, without prior reference to the Client. If the measures in place are not sufficient to avoid or manage a conflict of interest relating to a Client, the Company will disclose the conflict of interest before undertaking further business with the client.