Trading Policy

The Investment Company is committed to adopting written codes of ethics that include provisions necessary to prevent customers and other individuals engaging in trading from violating these rules. The company will also maintain records, exercise reasonable diligence, and establish procedures to prevent, detect, and rectify any violations.

Violations of the Trading Policy

If the Compliance Team becomes aware of a violation or potential violation of the Trading Policy by an individual, it is obligated to investigate the matter, which may result in penalties, if deemed appropriate.

Upon completion of the investigation, the Compliance Team may recommend appropriate actions to determine the necessary remedial measures.

Trading Policy Conditions

The client acknowledges that any investment is highly speculative and carries a significant risk of loss.

The company assumes no responsibility for any trading decisions made by the client, including decisions related to opening orders, investing in specific orders, or using automated trading programs. The company may accept trading responsibility only if it is stated in writing.

In accordance with the company's operating regulations, the company reserves the right to temporarily suspend a customer's trading account or trading activity and cancel any bonuses given during the cooperation, along with the earned profits, if the manager is unable to contact the customer for a period of 2 months or more.

The Company reserves the right to introduce additional fees and charges, as well as modify existing fees and charges, at any time.

Since most trading is conducted upon the customer's request and with the assistance of a personal manager, any accumulated profits may be considered the property of the Company until the orders are closed. In order to initiate a withdrawal or submit a withdrawal request, all orders must be closed and settled. If there are any open orders in the account, no outgoing transactions can be processed.

In accordance with the Company's policies, quotes may differ from market prices due to intermediation between the market and the liquidity provider. The intermediary party has the discretion to change the quotes. The Company collaborates with various liquidity providers, which may result in discrepancies between the opening price and the market price. Any losses incurred due to changed quotations by the liquidity provider do not impose any financial obligations on the Company towards the client.