Protection of Clients

Retail Clients / Professional Clients

Where the Company treats the client as a retail client, the client will be entitled to more protections under the law than it would be entitled to as a professional client. In summary, the additional protections retail clients are entitled to are as follows:

A. A retail client will be given more information and disclosures with regard to the Company, its services and any investments, its costs, commissions, fees and charges and the safeguarding of client financial instruments and client funds.

B. Under the law, where the Company provides investment services other than investment advice (in the form of personal recommendations) or discretionary portfolio management, the Company shall ask a retail client to provide information regarding his knowledge and experience in the investment field relevant to the specific type of product or service offered or demanded so as to enable the Company to assess whether the investment service or product envisaged is appropriate for the client. In case the Company considers, on the basis of the information received, that the product or service is not appropriate to a retail client, it shall warn the client accordingly. please note that the Company is not required to assess appropriateness in certain cases specified by law. the Company shall be entitled to assume that a professional client has the necessary experience and knowledge in order to understand the risks involved in relation to those particular investment services or transactions, or types of transaction or product, for which the client is classified as a professional client. consequently, and unlike the situation with a retail client, the Company should not generally need to obtain additional information from the client for the purposes of the assessment of appropriateness for those products and services for which they have been classified as a professional client.

c. When executing orders, the Company must take all reasonable steps to achieve what is called “best execution” of the client’s orders that is to obtain the best possible result for its clients. Where the Company executes an order on behalf of a retail client, 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. When providing professional clients with best execution the Company is not required to prioritize the overall costs of the transaction as being the most important factor in achieving best execution for them.

D. The Company must obtain from clients such information as is necessary for it to understand the essential facts about the client and to have a reasonable basis for believing, giving due consideration to the nature and extent of the service provided, that the specific transaction to be recommended in the course of providing the service of investment advice, or entered into in the course of providing a portfolio management service, satisfies the following criteria:

i. it meets the investment objectives of the client in question;
ii. it is such that the client is able financially to bear any related investment risks consistent with his investment objectives;
iii. it is such that the client has the necessary experience and knowledge in order to understand the risks involved in the transaction or in the management of his portfolio.

Where the Company provides an investment service to a professional client it shall be entitled to assume that, in relation to the products, transactions and services for which it is so classified, the client has the necessary level of experience and knowledge for the purposes of paragraph (iii) above. in addition, under certain circumstances, the Company shall be entitled to assume that a professional client is able financially to bear any investment risks consistent with its investment objectives.

E. The Company must informretail clients of material difficulties relevant to the proper carrying out of their order(s) promptly upon becoming aware of the difficulty The Company is required to provide retail clients: i. with more information than professional clients as regards execution of orders, other than for portfolio management ii. with periodic statements in respect of portfolio management activities carried out on their behalf, more frequently than for professional clients. where the Company provides portfolio management transactions for retail clients or operate retail client accounts that include an uncovered open position in a contingent liability transaction, it shall also report to the retail client any losses exceeding any predetermined threshold, agreed between the company and the client, no later than the end of the business day in which the threshold is exceeded or, in a case where the threshold is exceeded on a non- business day the close of the next business day.

F. If the Company provides an investment service other than investment advice to a new retail client for the first time after 1 November 2007, it must enter into a written basic agreement with the client,setting out the essential rights and obligation of the firm and the client.

G. The Company shall not use financial instruments held by it on behalf of a client for its own account or the account of another client of the Company, without the client’s prior express consent to the use of the instruments on specified terms, as evidenced, in the case of a retail client, by his signature or equivalent alternative mechanism.

H. Retail clients may be entitled to compensation under the Investor Compensation Fund for Clients of investment Firms.

I. Ownership of Cash: Any money transfers to the Company by You or on Your behalf will not be held as “client money” under the CySEC’s client money rules and you agree to transfer the ownership of such monies to the Company. Any money you transfer to the Company is treated as a full transfer to us in order to secure or cover your present, future, actual, contingent or prospective obligations, even where we are acting as your agent, and we may have dealt with it in our own right. Where Company considers after applying its own methodology that money received from You or on Your behalf is more than what is needed to cover for.

Eligible Counterparties

Where the Company treats the client as an eligible counterparty, the client will be entitled to fewer protections under the law than it would be entitled to as a professional client. In particular, and in addition to the above:
A. The Company is not required to provide the client with best execution in executing client’s orders;
B. The Company is not required to disclose to the client information regarding any fees or commissions that the Company pays or receives;
C. The Company is not required to assess the appropriateness of a product or service that the Company provide to the client;
D. The Company is not required to provide the client with information about the Company, its services and the arrangements;
E. Through which the Company will be remunerated;
F. The Company is not required to provide the client with risk disclosures on the products or services that the client selects from the Company;
G. The Company is not required to provide reports to the client on the execution of his / her / it orders.