Client Agreement (Terms & Conditions)

1. About this Agreement

1.1 This Agreement sets out the terms on which GCC Brokers ("we", "us", "our", the "Company") will open and operate a trading account for you and deal with you in contracts for difference and other margined transactions.

1.2 This Agreement, together with the documents listed in Clause 1.3, forms the entire agreement between you and us in relation to your Account. It replaces any earlier terms and conditions between us.

1.3 The following documents form part of this Agreement and should be read with it. They are available at all times on our website:

• the Risk Disclosure;
• the Order Execution Policy;
• the Negative Balance Protection Policy;
• the Weekend Risk Policy;
• the AML & KYC Policy;
• the Privacy Policy;
• the Complaint Handling Policy;
• the Contract Specifications, which set out the instruments we quote and their trading conditions; and
• any product-specific or promotional terms you have accepted.

1.4 Where this Agreement conflicts with any document listed in Clause 1.3, this Agreement prevails, except where that document expressly states otherwise.

1.5 Our website and trading platforms are also subject to separate Website Terms of Use, which govern your use of those systems rather than our dealings with you as a client.

1.6 This Agreement is written in English. The English version governs. Any translation is provided for convenience only, and in the event of any inconsistency the English text prevails.

1.7 By opening an Account, funding it, or placing an order, you accept this Agreement.

---

2. Who you are contracting with

2.1 "GCC Brokers Limited" is the name of two separate companies. Your Account is held with one of them, and only one of them — the "Contracting Entity". They are:

2.2 How your Contracting Entity is determined. When you apply for an Account, we determine which Contracting Entity you will contract with, as part of our assessment of your application and of the suitability of our services for you. That determination is ours to make and is final. We will tell you which entity you are contracting with. You may decline to proceed, but you may not require us to accept you onto a different entity.

2.3 Changes after onboarding. If we wish to move your Account to the other Contracting Entity after it has been opened, we will tell you and we will obtain your consent before doing so.

2.4 Where there is any doubt. If at any time it is unclear which Contracting Entity holds your Account, we will confirm it to you in writing. Our written confirmation is conclusive.

2.5 Each Contracting Entity is responsible only for its own clients and its own obligations. Neither guarantees the obligations of the other, and nothing in this Agreement makes one liable for the acts or omissions of the other.

2.6 Important — no compensation scheme. Neither Contracting Entity participates in any statutory or regulatory investor compensation or deposit guarantee scheme in any jurisdiction. If we were unable to meet our obligations to you, no compensation scheme would pay you.

2.7 If your Contracting Entity is the Saint Vincent and the Grenadines company, you should understand that it is not licensed or regulated for investment business, that the regulatory protections available to clients of the Mauritius entity do not apply to you, and that your recourse is contractual only. The Negative Balance Protection Policy and the Weekend Risk Policy apply to you as a matter of contract, not of regulation.

2.8 Our Dubai representative office. The Mauritius company maintains a representative office in the United Arab Emirates — GCC Brokers Limited Representative Office, licence number 1202392, Office 302, The Exchange Tower, Business Bay, Dubai.

That office is not a Contracting Entity. You do not contract with it, it does not hold your Account, it does not execute your orders, and it is not licensed or regulated by any financial services regulator in the United Arab Emirates. Its licence is a Dubai Department of Economy and Tourism professional licence for the activity of a representative office, and its role is limited accordingly. It does not hold or handle client money.

2.9 The two companies are not a group. Each Contracting Entity is separately owned by the same ultimate beneficial owner. Neither is a subsidiary of the other, and neither guarantees the other's obligations.

---

3. Definitions

Account — the trading account or accounts we open for you under this Agreement.

Applicable Law — any law, regulation, rule, licence condition, market practice or order that applies to us or to you in connection with this Agreement.

Business Day — a day other than a Saturday, Sunday or public holiday in the jurisdiction of your Contracting Entity.

Contract Specifications — the trading conditions applying to each Instrument we quote, including contract size, trading hours, minimum and maximum order sizes, Margin Requirements, swap and financing rates, expiry arrangements and applicable charges. These are published on the instrument pages of our website and in the Trading Platform, and are amended from time to time. Where the two differ, the Trading Platform governs.

Contracting Entity — the company identified in Clause 2 with which your Account is held.

Equity — the balance on your Account, adjusted for the unrealised profit and loss on your open Positions and for any credit applied to the Account.

Expiry Date — for an instrument with a fixed term, the date on which it expires as set out in the Contract Specifications.

Free Margin — your Equity less the Margin Requirement of your open Positions.

Instrument — a contract for difference or other margined product we quote, as listed in the Contract Specifications.

Margin — the funds you are required to have on your Account to open and maintain Positions.

Margin Level — Equity expressed as a percentage of the Margin Requirement of your open Positions.

Margin Requirement — the amount of Margin required for a Position, as set out in the Contract Specifications or otherwise notified to you.

Our Quote — the bid and offer prices we quote for an Instrument.

Position — an open transaction on your Account.

Trading Platform — any platform, application or interface we make available for you to view prices, place orders and manage your Account.

Underlying Market — the market, exchange, instrument or reference from which Our Quote for an Instrument is derived.

---

4. Eligibility and your standing

4.1 We will open an Account for you only if you satisfy our client acceptance requirements, including identification, verification and any suitability or appropriateness assessment we carry out.

4.2 You confirm that you are of legal age and full legal capacity, that you are acting on your own behalf and not for any undisclosed person, and that the funds you deposit are lawfully yours and not the proceeds of any unlawful activity.

4.3 We do not accept clients resident in, or accessing our services from, jurisdictions where doing so would be contrary to Applicable Law or to our own policies. We may decline an application without giving reasons, and we may close an Account if we later determine that we should not have accepted it.

4.4 It is your responsibility to satisfy yourself that trading with us is lawful where you are. We give no assurance that our services are lawful in your jurisdiction, and you agree not to use them if they are not.

4.5 Client classification. Unless we notify you otherwise in writing, we treat you as a retail client. If we classify you differently, we will tell you, and some of the protections in this Agreement and in our policies — including the Negative Balance Protection Policy — may not apply to you.

---

5. The service we provide

5.1 Execution only. We deal with you on an execution-only basis. We carry out your instructions. We do not manage your Account, and we do not decide what you should trade or when.

5.2 No advice. We do not provide investment, tax, legal or accounting advice, and nothing we say or publish is a recommendation. Market commentary, research, analysis, signals, educational material, third-party content and anything said in conversation with our staff is provided for information only. Any decision to trade is yours alone.

5.3 No statement by us about an Instrument, a market or a Position is a representation that a trade is suitable or appropriate for you, or that it will be profitable.

5.4 We may decline to act on any instruction, or to open an Account or Position, without giving reasons.

---

6. How we deal with you

6.1 We deal as principal. Every Position you open is a contract between you and your Contracting Entity. We are your counterparty. We are not your agent or broker to a third party, and you have no rights against, or interest in, any Underlying Market or any transaction we may enter into with a third party.

6.2 Off-exchange. Positions with us are off-exchange (over-the-counter). They are not traded on a regulated exchange or cleared through a clearing house. You cannot transfer, assign or settle a Position other than with us.

6.3 Execution and risk management are separate. How your order is executed, and how we manage the risk that results from it, are two separate processes. Your order is executed automatically by our systems at the price the market gives. No person approves, rejects, delays or intervenes in the execution of your order, and execution does not vary according to who you are or how profitable your trading has been. Any decision about our own risk is taken afterwards, on our own book, and cannot affect the price you received.

6.4 Our dealing desk, and what our licence permits. We operate a dealing desk. Its role is to monitor market conditions and the performance of our liquidity providers, to manage our own risk — including the steps described in Clause 10.9 — and to support clients with payments and order requests. It does not intervene in the execution of your orders.

Our ordinary practice is to pass the risk arising from your trading to a liquidity provider or hedging counterparty — straight-through processing, commonly called A-Book execution — and we seek to avoid holding a directional position against our clients. Our Investment Dealer Licence also authorises us to deal on our own account, and we may retain the risk of a Position rather than passing it on. In practice that applies to a limited proportion of accounts and positions, at our discretion.

6.5 The conflict this creates, and how we manage it. Where we retain risk, then because we are your counterparty your loss on that Position is our gain, and your profit is our loss. That is a conflict of interest, and you are entitled to know of it before you trade. We manage it by:

• (a) making it our ordinary practice to pass risk on rather than retain it, as stated in Clause 6.4;
• (b) the separation in Clause 6.3 — your order executes automatically, and any decision about our own risk is taken afterwards and cannot affect the price you received; and
• (c) the undertaking in Clause 9.6, which applies whether or not we hold the risk of your Position.

We are not obliged to tell you, in relation to any particular Position, how we have managed the risk arising from it. Our Order Execution Policy sets out how we execute your orders.

6.6 Inducements and third parties. We may pay or receive fees, commission or non-monetary benefits in connection with introducing, marketing or servicing your Account, including payments to introducing brokers and affiliates. Where an introducing broker or affiliate is involved with your Account, they act for themselves and not for us, and we are not responsible for anything they say to you — including any advice, forecast or assurance about returns. We will disclose the existence and nature of such arrangements on request.

6.7 We maintain a conflicts of interest policy, a summary of which is available on request.

---

7. Instructions and orders

7.1 Channels. You may give us instructions through:

• (a) the Trading Platform, which is the ordinary and preferred channel;
• (b) telephone, where we have agreed to accept telephone dealing on your Account; and
• (c) other digital channels we have expressly approved for your Account, which may include a dedicated messaging group with our dealing team, or another messaging or conferencing service we have agreed in writing.

7.2 Telephone and other digital dealing is offered at our discretion and only where we have approved it for your Account, on your request. We may withdraw that approval at any time. We are not obliged to accept, monitor or act on instructions sent through any channel we have not approved, and instructions sent to an unapproved channel are not received by us.

7.3 Identification. When placing an instruction other than through the Trading Platform, you must identify yourself and your Account to our satisfaction. We will not act on an instruction — including an instruction to close a Position — until we are satisfied as to your identity.

7.4 Acceptance. An instruction given other than through the Trading Platform takes effect only when we confirm that we have accepted it. Until then no Position is opened, closed or amended. Our confirmation of acceptance does not affect either party's rights in respect of a pricing error or manifest error under Clause 9.7.

7.5 Recording. We record our dealings with you. This includes telephone calls, and messages, chats and other written communications on any channel approved under Clause 7.1(c), as well as the complete order and transaction history retained by the Trading Platform. You consent to that recording. These records are our property, and we may use them as evidence in any dispute, including a dispute about whether an instruction was given or accepted. We will provide a copy of a recording relating to you on reasonable request, subject to Applicable Law.

7.6 Authorised persons. We may act on instructions from any person we reasonably believe to be you or to be authorised by you. You must tell us immediately in writing if any authority you have given is withdrawn.

7.7 Order types. We accept the order types made available on the Trading Platform and described in the Contract Specifications, which may include market orders, pending orders and orders attached to a Position such as stop-loss and take-profit orders. Orders may be subject to an immediate-or-cancel (IOC) fill condition, so that any part of the order that cannot be filled immediately is cancelled rather than held. The order types available, and their duration and fill behaviour, are as set out on the Trading Platform and in the Contract Specifications and may change.

7.8 Stop-loss orders are not guaranteed. A stop-loss order is an instruction to close a Position when Our Quote reaches a level you specify. It is not a guarantee that your Position will close at that level. In a fast or gapping market, the next available price may be materially worse, and your Position will be closed at that price. See Clause 9.4.

7.9 Amendment and cancellation. You may amend or cancel an order only while it is not executed. We are not obliged to accept an amendment or cancellation, and an instruction to amend or cancel has no effect if the order has already been executed.

---

8. Instruments we quote

8.1 We quote contracts for difference and other margined transactions on a range of underlying markets, currently including foreign exchange, stock indices, precious metals, energy and other commodities, cryptocurrencies, and dated futures. The instruments we quote at any time, and their terms, are set out in the Contract Specifications.

8.2 We may add or withdraw an Instrument, change its Contract Specifications or cease to quote it, at any time. Where we cease to quote an Instrument in which you hold a Position, we will give you reasonable notice where we can.

8.3 Cryptocurrency instruments. Cryptocurrency Instruments are contracts for difference referencing the price of a digital asset. You do not buy, hold or own any digital asset, and you have no rights in respect of one. Digital asset markets are exceptionally volatile, may move sharply outside conventional trading hours, and may be affected by events that have no equivalent in other markets. Margin requirements for these Instruments are typically higher and may be changed at short notice.

8.4 Dated Instruments. Some Instruments have an Expiry Date.

• (a) You are not required to close a Position before its Expiry Date, provided your Account is not in deficit and you continue to meet the Margin Requirement.
• (b) A Position still open at expiry will be closed automatically at our quoted price at expiry. There is no physical delivery and no rollover unless we say otherwise in the Contract Specifications.
• (c) Where an Expiry Date falls on a day that is not a Business Day, or on which the Underlying Market is closed, the Position will expire on the preceding Business Day on which the Underlying Market is open.
• (d) We may close a Position before its Expiry Date where this Agreement permits or Applicable Law requires it.

8.5 Partial fills and illiquidity. In some market conditions a Position cannot be opened or closed in full at a single price. Where that happens, your order may be filled in part, or filled at more than one price, reflecting the prices at which we are able to transact. If the Underlying Market for an Instrument becomes illiquid, suspended or unavailable, we may close all or part of your Position at Our Quote at the time, and we may decline to open new Positions in that Instrument.

---

9. Pricing and execution

9.1 Our Quote. We quote a bid price and an offer price for each Instrument. The difference between them is the spread. Our Quote is derived from the Underlying Market but is our price, not the Underlying Market's, and may differ from prices quoted elsewhere.

9.2 Spreads are floating. We do not offer fixed spreads. Our spreads vary with market conditions. We maintain relationships with our liquidity providers in order to obtain the best pricing, stability and market depth we reasonably can, and we pass that through to you. Spreads widen, sometimes substantially, during volatile conditions, around economic releases, at market open and close, and in thin liquidity. That is a feature of the market and not a fault in our pricing.

9.3 Validity of quotes. Our Quote is valid for the size and the moment for which it is given. Prices move continuously, and a price you see may no longer be available when your instruction reaches us.

9.4 Slippage and gapping. Your order is executed at the next price available to us when it reaches us, which may be better or worse than the price you saw. Where a market gaps — including over a weekend, around a news event, or on a suspension — the next available price may be very far from the last traded price, and orders including stop-loss orders will be executed at that price. Slippage occurs in both directions and we do not apply it selectively.

9.5 Execution during trading hours. We execute orders only during the quoting hours for the relevant Instrument, as set out in the Contract Specifications. An order placed outside those hours will be executed, if at all, when quoting resumes, at the price then available.

9.6 What we will never do. We will not manipulate our prices, the execution of your orders, the timing or duration of that execution, or the slippage applied to it, in order to benefit ourselves or to disadvantage you. We will not requote you, delay you or reject your order because of the direction or profitability of your trading, and no person intervenes in the execution of your order. This undertaking is given expressly, it applies to every order without exception, it applies whether or not we hold the risk of your Position on our own book, and it is not qualified by Clause 6.

9.7 Manifest error. A manifest error is a quote, execution or price we give or act on which is materially wrong, having regard to the state of the Underlying Market at the time, and which a reasonable person would recognise as wrong. Manifest errors arise from, among other things, a fault or interruption in a price feed, a mistyped price, and erroneous data from a third party.

• (a) We may void a Position affected by a manifest error, or amend its terms to those that would have applied without the error, acting in good faith and as soon as reasonably practicable after we become aware of it.
• (b) We will tell you if we do so, and explain the basis.
• (c) We will not be liable for any loss arising from a manifest error or its correction, except where the error resulted from our fraud or wilful default.
• (d) Where a manifest error has operated in our favour, the same principle applies and we will correct it.

9.8 Trading on price outcome. You may not deal on Our Quote where you know, or ought reasonably to know, that it does not reflect the Underlying Market — including a quote arising from a manifest error, a stale or interrupted feed, or a latency in our systems. Dealing of that kind is a Prohibited Trading Technique under Clause 14.

---

10. Margin

This Clause is central to the Agreement. Please read it.

10.1 You must maintain Margin at all times. You must have sufficient cleared funds on your Account to meet the Margin Requirement for every Position you hold, at all times and without demand from us. Meeting your Margin obligations is your responsibility, not ours.

10.2 Margin Requirement. The Margin Requirement for each Instrument is set out in the Contract Specifications. It may differ by Instrument, by account type, by position size and by client.

10.3 Margin Level. Your Margin Level is your Equity expressed as a percentage of the total Margin Requirement of your open Positions.

10.4 The levels that apply to your Account. Unless we notify you otherwise:

10.5 Automatic closure is not a service and not a protection. Closure at the Stop Out level is an automated function of the Trading Platform operated for our protection. It does not guarantee that your loss will be limited to your Equity at that level. In a fast or gapping market, the price at which a Position is actually closed may be far worse than the price at which the Stop Out was triggered, and your Account may be left with a negative balance. See Clause 13.

10.6 We are not obliged to make a Margin Call. It is your responsibility to monitor your Account, your Positions and your Margin Level. We are not obliged to notify you of a Margin Call, to contact you before closing Positions, or to do either within any particular time. The absence of any notice from us does not mean your Account is adequately funded, and a notice we do send does not extend any period for you to act.

10.7 We may vary Margin Requirements and levels. We may change the Margin Requirement for any Instrument, and the Margin Call and Stop Out levels for any account or group of accounts, at any time. We may do so in particular:

• (a) during periods of high or expected volatility;
• (b) ahead of scheduled economic or corporate events;
• (c) ahead of a weekend, a public holiday or any other market closure;
• (d) where an Instrument's liquidity deteriorates; and
• (e) in the light of the size, concentration or nature of the Positions held on an Account.

10.8 A change under Clause 10.7 applies to your existing Positions as well as to new ones, and may itself cause your Margin Level to fall to the Margin Call or Stop Out level. We will give you notice of a change where it is practicable to do so; where market conditions do not allow it, we may make the change without prior notice.

10.9 Steps we may take on an Account at risk. Where an Account's Margin Level is at or approaching the Stop Out level, or where in our reasonable opinion an Account is exposed to a risk we are not prepared to carry, we may, at our sole discretion and without prior notice:

• (a) open one or more Positions on your Account in the opposite direction to your existing Positions, so as to reduce or remove the Account's net exposure ("hedging");
• (b) close or reduce any or all of your Positions, in whole or in part, at prices reasonably available to us;
• (c) increase the Margin Requirement on some or all Instruments; or
• (d) restrict the opening of new Positions on the Account.

10.10 Where we hedge under Clause 10.9(a):

• (a) the hedging Position is opened on your Account and forms part of it;
• (b) Margin is charged on the larger of the two offsetting Positions and not on both, except where we determine that hedging is being used to manipulate Margin Requirements, in which case we may charge Margin on both;
• (c) our ordinary spreads, commissions and financing charges apply to the hedging Position as they would to any other; and
• (d) once the relevant market reopens you may close either side, or both, and resume trading normally. We do not undertake to close the hedge for you, and it will remain open, incurring any applicable charges, until it is closed.

10.11 These are rights, not obligations. We are not obliged to take any step under Clause 10.9, and we do not undertake to do so. We give no assurance that we will identify an Account at risk, that we will act on it, or that we will act within any particular time. Having taken a step on one occasion does not oblige us to take it on another, and you must not rely on us taking any of them. You remain responsible for your Account and your Positions at all times.

10.12 Weekend and other closures. The circumstances in Clause 10.9 arise most often, but not only, ahead of a weekend. Our Weekend Risk Policy describes how we monitor Accounts before the weekly close, what we may ask of you and what we may do if you do not act. That Policy is the principal application of Clause 10.9 but does not limit it, and Clause 10.9 applies equally to public holidays, scheduled events and any other period in which we consider the risk to warrant it.

10.13 Outcomes. Any step taken under Clause 10.9 fixes your position at the prices then available. An intervention may produce a worse outcome than taking no action, including where the market subsequently moves in your favour, and a hedge removes the further gain as well as the further loss. To the maximum extent permitted by Applicable Law, we are not liable for any loss, cost or lost opportunity arising from our taking, or from our not taking, any step under this Clause.

---

11. Client money

11.1 Money you deposit is held in an account with a bank or payment institution separate from our own funds, and is not used for our own account or to meet our own obligations.

11.2 We do not pay interest on money held for you unless we agree otherwise in writing, and you waive any entitlement to interest.

11.3 We may hold your money with a third party, including outside the jurisdiction of your Contracting Entity, where the legal and regulatory regime may differ. We select and monitor those institutions with reasonable care, but we are not liable for the insolvency, acts or omissions of a third-party bank or payment institution, except where we have failed to exercise reasonable care in selecting it.

11.4 Deposits. We accept deposits only from a source in your own name. We may reject or return a deposit that we cannot satisfactorily identify, and we may require evidence of source of funds at any time.

11.5 Withdrawals. You may request withdrawal of funds not required as Margin for your open Positions. We will process a valid request within a reasonable time. We may refuse or defer a withdrawal where it would leave insufficient Margin, where you owe us any amount, where we are required to do so by Applicable Law, or where the request is inconsistent with our AML & KYC Policy. We ordinarily return funds by the route from which they were received.

11.6 Currency. Your Account is denominated in the currency in which it was opened. Where a transaction, charge or adjustment is in another currency, we convert it at a rate we reasonably determine by reference to prevailing market rates. You bear the risk of currency movements.

---

12. Charges, swaps and financing

12.1 Our charges are set out in the Contract Specifications and on our website, and may include spreads, commissions, financing or swap charges, account fees and charges levied by payment providers.

12.2 Swap and financing charges. A Position held overnight is subject to a swap charge or credit.

• (a) Swap rates are received daily from our liquidity providers, who generally pass them through from the underlying banks. We process those rates and apply them to your Account.
• (b) Swap rates are not fixed. They change daily and may be positive or negative for either side of an Instrument.
• (c) Prevailing swap rates for each Instrument are shown on the Trading Platform and in the Contract Specifications.
• (d) Swaps may be charged at a multiple on a particular day of the week to account for weekends and holidays, as shown in the Contract Specifications.

12.3 Account-specific arrangements. We may agree different swap, financing or charging arrangements with an individual client, and we may vary or withdraw such an arrangement on notice. Any such arrangement applies only to the Account and the period for which it is agreed, is not an entitlement, and does not create any expectation in respect of any other client, Account or period.

12.4 We may change our charges. We will give you notice of a change before it takes effect, except where a change results from a change by a third party or from market conditions outside our control.

12.5 Taxes. You are responsible for any tax arising from your trading. We do not withhold or account for tax on your behalf unless required by Applicable Law, and we give no tax advice.

12.6 Dormant accounts. We may apply a dormancy fee to an Account with no trading activity for a continuous period stated in the Contract Specifications. A dormancy fee will not take your Account below zero.

---

13. Negative balance

13.1 Because you trade on Margin, your losses are not limited to the funds you have deposited, and your Account may be left with a balance below zero.

13.2 A negative balance is a debt owed by you to us.

13.3 Our Negative Balance Protection Policy sets out the limited circumstances in which we absorb a shortfall. In summary, and subject to that Policy:

• (a) for a retail client, where an Account is left with a negative balance, we will automatically credit the Account to bring it to zero up to a maximum of USD 100 (or its equivalent) per occurrence;
• (b) any shortfall above that amount remains payable by you in full; and
• (c) protection does not apply where the negative balance arises from or in connection with a Prohibited Trading Technique, a breach of this Agreement, or fraud.

13.4 Where a shortfall is payable, we may set it off under Clause 16 and recover it by any lawful means, including proceedings and the recovery of our costs of doing so.

13.5 Negative balance protection is offered as a matter of contract. It is not a compensation scheme and it is not a guarantee. It does not transfer responsibility for your Positions to us.

---

14. Prohibited trading techniques and unwanted order flow

14.1 You must not use, or attempt to use, any of the following in connection with your Account:

• (a) Latency or feed arbitrage — exploiting a delay or difference between Our Quote and the price in the Underlying Market or on another venue, including through the use of software, plug-ins or connectivity designed for that purpose;
• (b) Exploitation of erroneous or stale quotes — dealing on a price you know or ought reasonably to know does not reflect the Underlying Market, including a price arising from a manifest error or an interrupted feed;
• (c) Coordinated or concerted trading — trading across multiple Accounts, whether your own or with others, in a coordinated way designed to circumvent a limit, a Margin Requirement or a Contract Specification, or to exploit any of the techniques in this Clause;
• (d) Abuse of hedging to manipulate Margin — opening offsetting Positions principally in order to reduce the Margin we require rather than to manage market risk;
• (e) Abuse of any promotion, bonus or protection we offer, including trading designed to exploit negative balance protection by taking Positions that could not be supported by the Account's Equity; and
• (f) any manipulative or abusive practice prohibited by Applicable Law, including market manipulation and insider dealing.

14.2 Unwanted order flow. Separately from Clause 14.1, certain trading strategies are treated by our liquidity providers, and by the market generally, as toxic order flow — order flow that cannot be hedged on normal terms and which damages our ability to obtain pricing and liquidity for our clients as a whole. These include in particular high-frequency trading, latency-sensitive strategies, and strategies dependent on holding Positions for very short durations.

Where we consider that trading on your Account constitutes or is likely to constitute unwanted order flow, we may:

• (a) decline to accept, or restrict, that trading on your Account;
• (b) apply different execution, spread, commission or Margin conditions to your Account, or move it to a different account type; or
• (c) require that the trading ceases as a condition of our continuing to deal with you.

We will tell you if we take a step under this Clause.

14.3 The difference between Clauses 14.1 and 14.2. Clause 14.1 concerns conduct that exploits a defect in pricing, connectivity or Margin, and a breach of it engages Clause 14.6. Clause 14.2 concerns the commercial terms on which we are able to deal, and a step taken under it is not a finding that you have breached this Agreement and does not of itself engage Clause 14.6.

14.4 Trading in concert. Where two or more clients place identical or substantially similar trades in concert, we may treat them as a single trade. If the combined size exceeds available liquidity and slippage results, we may fill all of those clients at the same price — the price at which we were realistically able to transact — regardless of individual size.

14.5 Connected accounts. Where Accounts are held by the same client, or by clients we reasonably consider to be acting together, we may treat them as a single Account for the purposes of this Clause, Clause 13 and Clause 16.

14.6 Consequences of breaching Clause 14.1. Where we reasonably determine that Clause 14.1 has been breached, we may void the affected Positions, withhold or reverse any profit arising from them, close Positions, restrict or close the Account, withhold negative balance protection, and terminate this Agreement. We will tell you what we have done and on what basis.

---

15. Your undertakings

15.1 You represent and undertake, on a continuing basis, that:

• (a) the information you have given us is true, complete and not misleading, and you will tell us promptly if it changes;
• (b) you are acting on your own behalf;
• (c) funds you deposit are lawfully yours;
• (d) you have read the Risk Disclosure and understand that you may lose your entire deposit and, subject to Clause 13, more than it;
• (e) you will comply with Applicable Law, including any law applying to you in your own jurisdiction; and
• (f) you will not use our services for any unlawful purpose.

15.2 Account security. You are responsible for keeping your credentials secure and for all activity on your Account.

• (a) You must not disclose your credentials to anyone, and you must use reasonable security measures on the devices you use.
• (b) You must tell us immediately if you know or suspect that your credentials have been disclosed, or that your Account has been accessed without your authority.
• (c) Until you tell us, we may treat any instruction given using your credentials as given by you, and you are responsible for it.
• (d) After you have told us, we will take reasonable steps to secure the Account, and you will not be responsible for unauthorised activity occurring after that point, except where it results from your fraud or your deliberate or reckless failure to keep your credentials secure.

15.3 You must not use any software, device or method intended to interfere with, gain unauthorised access to, or manipulate the Trading Platform or our systems.

---

16. Default, set-off and our remedies

16.1 Each of the following is an Event of Default:

• (a) you fail to meet a Margin Requirement or any other obligation to pay;
• (b) you breach this Agreement in any material respect, including Clause 14;
• (c) any representation you have given proves to have been untrue or misleading;
• (d) you become insolvent, bankrupt, or subject to any analogous proceeding, or you die or lose legal capacity;
• (e) we reasonably consider it necessary to protect ourselves or you from a regulatory, legal or fraud risk; or
• (f) we are required to act by Applicable Law or by a regulator, court or other competent authority.

16.2 On an Event of Default we may, without prior notice, do any of the following: close any or all of your Positions; refuse to open new Positions; suspend or close your Account; cancel outstanding orders; convert currencies at a rate we reasonably determine; retain funds pending resolution; and exercise our rights under Clause 16.3.

16.3 Set-off. We may set off any amount you owe us against any money or credit we hold for you, on any Account you hold with your Contracting Entity, and where Clause 14.5 applies, across Accounts we treat as a single Account. We will tell you when we have exercised this right.

16.4 Our rights under this Clause are in addition to any other right we have at law.

---

17. Exceptional events and technology

17.1 Exceptional Event. An Exceptional Event is any event beyond our reasonable control that prevents or materially impairs our ability to provide our services or to maintain an orderly market in an Instrument. It includes: suspension, closure or failure of an Underlying Market; a governmental, regulatory or exchange action; failure or interruption of a liquidity provider, bank, payment provider or price feed; failure of power, telecommunications or internet infrastructure; cyber attack, malicious code, denial-of-service attack or unauthorised intrusion; war, terrorism, civil unrest, natural disaster, epidemic or pandemic; and labour disputes.

17.2 During an Exceptional Event we may, acting reasonably: suspend or restrict trading in any or all Instruments; alter Margin Requirements; alter quoting hours; close, void or amend Positions at prices we reasonably determine; or suspend the operation of any part of this Agreement. We will not be liable for any loss arising from an Exceptional Event or from any step we take in response to one.

17.3 Systems and maintenance. The Trading Platform and our systems may be unavailable from time to time, whether for planned maintenance, upgrade, or because of failure or fault. We will give notice of planned maintenance where practicable. We are not liable for any loss arising from the unavailability, failure, delay, interruption or malfunction of the Trading Platform, our systems, your own equipment or connection, or any third-party service, except where the loss results from our fraud or wilful default.

17.4 You should maintain an alternative means of contacting us — in particular the telephone number published on our website — so that you can manage your Positions if the Trading Platform is unavailable to you. We may, but are not obliged to, accept instructions by that route during an outage.

17.5 Third-party content and connections. Where we make available third-party data, tools, signals, expert advisors, bridges or applications, we do so as a convenience. We do not endorse them, we do not verify them, and we are not responsible for their performance or for any loss arising from their use.

---

18. Termination

18.1 You may terminate this Agreement at any time, by written notice, provided you have no open Positions and owe us nothing.

18.2 We may terminate this Agreement on thirty days' written notice without giving reasons, and immediately on an Event of Default or where required by Applicable Law.

18.3 On termination: all outstanding amounts become immediately due; we may close any remaining Positions; we will return any remaining balance to you, subject to Clause 11.5 and to our rights of set-off; and any provision which by its nature should survive termination — including Clauses 13, 16, 20, 24 and 25 — continues in force.

18.4 Termination does not affect any right, obligation or liability accrued before it takes effect, nor any Position or instruction outstanding at that time.

---

19. Confirmations, statements and records

19.1 Confirmations. We will make a confirmation of each executed transaction available to you within 24 hours of execution, through the Trading Platform or by other electronic means.

19.2 Statements. We make a statement of your Account available to you:

• (a) daily, for each day on which there has been activity on your Account; and
• (b) monthly, for as long as your Account remains open, whether or not there has been any activity.

This meets or exceeds any minimum reporting frequency applicable to your Contracting Entity.

19.3 Confirmations and statements available on the Trading Platform are treated as delivered to you when they are made available.

19.4 Checking and objecting. You must check every confirmation and statement promptly. If you believe an entry is wrong, you must tell us within five Business Days of it being made available. In the absence of a notice from you within that period, and of manifest error or fraud, the confirmation or statement is treated as accepted by you.

19.5 We keep records of your Account, orders, transactions and communications in accordance with Applicable Law, and will provide copies on reasonable request.

---

20. Liability and indemnity

20.1 What we are responsible for. We will provide our services with reasonable care and skill. Nothing in this Agreement excludes or limits our liability for fraud, fraudulent misrepresentation, or any liability that cannot lawfully be excluded or limited.

20.2 What we are not responsible for. Subject to Clause 20.1, and to the maximum extent permitted by Applicable Law, we are not liable for:

• (a) any loss arising from your own trading decisions, or from your failure to monitor your Account, your Positions or your Margin Level;
• (b) any loss arising from market movement, volatility, spread widening, slippage, gapping or illiquidity;
• (c) any loss arising from an Exceptional Event or from a step taken under Clause 17;
• (d) any loss arising from our taking, or not taking, any step under Clause 10.9;
• (e) any loss arising from the act, omission or insolvency of a third party, including a liquidity provider, bank, payment provider, introducing broker or data provider, except as provided in Clause 11.3;
• (f) any loss arising from an instruction given using your credentials before you have notified us under Clause 15.2(b); or
• (g) any indirect or consequential loss, or any loss of profit, loss of opportunity, or loss of anticipated saving, however arising.

20.3 Cap on liability. Subject to Clause 20.1, our total liability to you — for any single claim, and in aggregate for all claims arising in any twelve-month period — is limited to the greater of:

• (a) USD 1,000; and
• (b) the total Charges you paid us in the three months immediately before the event giving rise to the claim,

and in no event more than USD 10,000.

20.4 What "Charges" means for Clause 20.3. Charges means the spreads, commissions, swap and financing charges and account fees actually borne by you on your Account. It does not include your deposits, your trading losses, or any amount paid by you to a third party.

20.5 Indemnity. You will indemnify us against any loss, cost, liability or expense we reasonably incur as a result of your breach of this Agreement, your breach of Applicable Law, or any claim brought by a third party in connection with your Account — except to the extent it results from our own fraud or wilful default.

---

21. Communications and notices

21.1 We will communicate with you in English, using the contact details registered on your Account.

21.2 We may communicate by email, through the Trading Platform, through the client portal, by post, by telephone, or through a channel approved under Clause 7.1(c). You consent to receiving communications, including this Agreement, contract documentation, confirmations, statements and notices, in electronic form.

21.3 A notice is treated as received: if sent by email or through the Trading Platform or portal, when sent; if given by telephone, when the call ends; if posted, five Business Days after posting.

21.4 You must keep your contact details current and monitor them. A notice sent to the details registered on your Account is effective even if you do not in fact read it.

21.5 Notices to us must be sent to the address published on our website for your Contracting Entity.

---

22. Complaints

22.1 If you are dissatisfied, please contact us using the details on our website. Our Complaint Handling Policy sets out how we handle complaints and the timescales that apply.

22.2 We will acknowledge your complaint, investigate it, and give you a written response.

---

23. Data protection

23.1 We process personal data about you in accordance with our Privacy Policy and Applicable Law, including for client verification, sanctions and AML screening, transaction monitoring, service provision, and compliance with our legal and regulatory obligations.

23.2 We may share your personal data with service providers, banks and payment providers, affiliated companies under common ownership, professional advisers, and regulators, courts and law enforcement where required.

23.3 Some recipients may be outside the jurisdiction of your Contracting Entity. Where we transfer personal data, we take steps to ensure it is appropriately protected.

---

24. Changes to this Agreement

24.1 We may amend this Agreement and the documents listed in Clause 1.3.

24.2 We will give you not less than ten Business Days' notice of a material change, by email or through the Trading Platform or portal, except where a change is required by Applicable Law, is needed immediately to protect you or us, or is in your favour — in which case it may take effect immediately.

24.3 If you do not accept a change, you may terminate this Agreement under Clause 18.1 before it takes effect. If you continue to trade after a change takes effect, you accept it.

24.4 The current version of this Agreement is always available on our website, and applies to any event occurring while it is in force.

---

25. General

25.1 Assignment. You may not assign or transfer your rights under this Agreement. We may assign or transfer ours, including to an affiliated company under common ownership, on notice to you.

25.2 Severability. If any provision is found to be invalid or unenforceable, the remainder continues in force.

25.3 No waiver. A failure or delay by us in exercising a right is not a waiver of it.

25.4 Third parties. No person other than you and your Contracting Entity has any right under this Agreement.

25.5 Entire agreement. This Agreement, with the documents in Clause 1.3, represents the entire agreement between us and supersedes any prior representation, understanding or arrangement — except that nothing excludes liability for fraudulent misrepresentation.

25.6 Language. As stated in Clause 1.6, the English version of this Agreement governs. Translations are for convenience only.

25.7 Recording and evidence. Our records, including those referred to in Clause 7.5, are conclusive evidence of your instructions and of the transactions on your Account in the absence of manifest error.

---

26. Governing law and jurisdiction

26.1 Where your Contracting Entity is GCC Brokers Limited (Mauritius, company number 193243), this Agreement is governed by the laws of the Republic of Mauritius, and the courts of Mauritius have exclusive jurisdiction.

26.2 Where your Contracting Entity is GCC Brokers Limited (Saint Vincent and the Grenadines, company number 25578 BC 2019), this Agreement is governed by the laws of Saint Vincent and the Grenadines, and the courts of Saint Vincent and the Grenadines have exclusive jurisdiction.

26.3 The forum follows your Contracting Entity. Nothing in this Clause permits proceedings against one Contracting Entity in respect of an Account held with the other.